IR 05000244/2021001

LLC: Integrated Inspection Report 05000244/2021001

ML21125A026
Person / Time
Site:	Ginna
Issue date:	05/05/2021
From:	Erin Carfang NRC/RGN-I/DORS
To:	Rhoades D Exelon Generation Co
References
IR 2021001
Download: ML21125A026 (21)

Text

May 5, 2021

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2021001

Dear Mr. Rhoades:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC. On April 29, 2021, the NRC inspectors discussed the results of this inspection with Mr. Paul Swift, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. We are treating this violation as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, 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 R.E. Ginna Nuclear Power Plant, LLC.

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 R.E. Ginna Nuclear Power Plant, LLC.

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 at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, X /RA/

Signed by: Erin E. Carfang Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety Docket No. 05000244 License No. DPR-18

Enclosure:

As stated

Inspection Report

Docket Number: 05000244 License Number: DPR-18 Report Number: 05000244/2021001 Enterprise Identifier: I-2021-001-0097 Licensee: Exelon Generation Company, LLC Facility: R.E. Ginna Nuclear Power Plant, LLC Location: Ontario, New York Inspection Dates: January 01, 2021 to March 31, 2021 Inspectors: J. Schussler, Senior Resident Inspector S. Monarque, Resident Inspector S. Haney, Resident Inspector A. Patel, Senior Reactor Inspector S. Wilson, Senior Health Physicist Approved By: Erin E. Carfang, Chief Projects Branch1 Division of Operating Reactor Safety Enclosure

SUMMARY

The NRC continued monitoring the licensees performance by conducting an integrated inspection at R.E. Ginna Nuclear Power Plant, LLC, 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.

List of Findings and Violations

Containment Spray and Safety Injection Relief Valves 861 and 1817 Flange Over Torque Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71111.15 Systems NCV 05000244/2021001-01 Identification Open/Closed The NRC identified a Green finding and associated non-cited violation of Technical Specification 5.4.1.a, Procedures, when Exelon did not establish and implement required written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, Section 3, Procedures for Startup,

Operation, and Shutdown of Safety-Related PWR Systems. Specifically, Exelon failed to adequately convey technical requirements into procedure GMP-37-06-255/RV Crosby, 3/4 x 1 JRAK-SPEC-B, Relief Valve Maintenance and Testing of IST Group 3B Valves,

Revision 0204, which resulted in over torqueing and visual deformation of the raised face inlet flanges of relief valves 861 and 1817 in November 2015 and November 2018.

Failure to Address Leaking Fire Pipe Issue Prior to Failure Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.5] - Work 71152 FIN 05000244/2021001-02 Management Open/Closed A self-revealed Green finding (FIN) of PI-AA-125, Corrective Action Program Procedure, was identified when Exelon failed to address a leaking pipe threaded connection that was identified as an issue in the auxiliary building mezzanine east cable fire suppression system S04. Specifically, after an active water leak from a 1/2 threaded pipe was identified in June of 2019 Exelon failed to implement adequate actions to address the leak. As a result, the pipe failed allowing water to wet the nearby safety related 480-volt electrical bus 14 and electrical motor control center E and collect in the surrounding area.

Additional Tracking Items

None.

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 reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin tele-work and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk-significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk- significant systems from impending severe weather extreme cold on

February 12, 2021 External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that auxiliary building door 26 and standby auxiliary feedwater annex flood barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on January 15, 2021

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

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

(1) 'A' motor driven auxiliary feedwater system following quarterly surveillance testing on January 21, 2021

(2) Alternate reactor coolant injection system following system surveillance testing on March 25, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Cable tunnel on January 22, 2021

(2) Relay room on March 4, 2021

(3) Auxiliary building top level on March 5, 2021

(4) Auxiliary building middle level on March 18, 2021

(5) Auxiliary building basement on March 18, 2021

(6) Standby auxiliary feedwater annex on March 18, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors observed the performance of the fire brigade during an unannounced fire drill on March 20, 2021

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Manholes MH5A-01, MH5A-02, MH5A-03, MH4-01, MH4-02, and MH4-03 on March 9, 2021

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance and procedure use and adherence in the main control room during a power reduction, prior to, and reactivity management during, turbine driven auxiliary feedwater pump operation on March 8, 2021

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the simulator during licensed operator requalification training on February 2, 2021. The training involved a scenario that contained, but was not limited to, a component cooling water leak requiring letdown to be isolated, a moisture separator reheater dump valve failing open causing a power excursion, a loss of electrical circuit 5241, loss of all offsite power, and service water pump start failure.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) Maintenance Rule (a)(3) periodic maintenance effectiveness assessment for the period November 9, 2018 to July 31, 2020 on March 12, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Elevated risk, (green), during planned maintenance of the diesel driven fire pump and associated valves on January 25, 2021

(2) Elevated risk, (action green), during planned maintenance of 'B' charging pump, variable frequency drive and associated piping and valves on February 1, 2021

(3) Elevated risk, (action green), during unplanned maintenance of 'B' charging pump on February 8, 2021

(4) Elevated risk, (action green) during unplanned maintenance of 'A' emergency diesel generator on February 17, 2021

(5) Elevated risk, (green), during planned maintenance of 'B' spent fuel pool pump on February 17, 2021

(6) Elevated risk, (green), during planned maintenance of 'A' safety injection pump on March 15, 2021

(7) Elevated risk, (green), during unplanned maintenance of 'B' residual heat removal heat exchanger on March 15, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) 'A' containment recirculation fan cooler high efficiency particulate air filter degraded efficiency operability assessment on January 29, 2021

(2) 'A' battery room temperature lower than cold weather walkdown procedure specifications during the cold weather season on February 22, 2021

(3) 'B' residual heat removal heat exchanger head flange and fasteners boric acid leak evaluation on March 16, 2021

(4) Containment spray relief valve 816 raised face flange over torque bolting and flange analysis operability evaluation on March 31, 2021

(5) 'A' emergency diesel generator lower frequency after restart, following a manual stop, OpEVAL-21-001 on March 31, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Operational testing of the 'A' instrument air compressor, following planned compressor and air dryer maintenance on January 12, 2021

(2) Operational testing of the 'A' emergency diesel generator fuel oil transfer pump and associated valves following planned diesel fuel oil system maintenance on January 20, 2021

(3) Operational testing of the 'A' emergency diesel generator following planned replacement of the engine fuel oil duplex strainer gasket and strainer maintenance on January 20, 2021

(4) Operational testing of the central alarm system diesel generator following planned engine and starting battery maintenance on January 21, 2021

(5) Operational testing of the 'A' safety injection pump following planned motor oil change and associated maintenance on March 22, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) CPI-BISTABLES-N41, Calibration of Nuclear Instrumentation System Power Range N41 Bistables and Indicators, on January 2, 2021

(2) STP-I-9.1.17, Undervoltage Protection - 480 Volt Safeguard Bus 17, on January 12, 2021

(3) STP-O-36Q-D, Standby Auxiliary Feedwater Pump D - Quarterly Test, on

February 2, 2021 In-service Testing (IP Section 03.01) (1 Sample)

(1) STP-O-2.2-COMP-A, Residual Heat Removal Pump A Comprehensive Test, on March 29, 2021

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) The inspectors evaluated an emergency drill in the simulator control room, technical support center and emergency offsite facility involving an Alert, Site Area Emergency and General Emergency declaration due to a scenario which contained, but was not limited to, a unisolable reactor coolant leak due to steam generator tube rupture that was faulted outside containment on January 26,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) ===

(1) Submitted data from January 1, 2020 through December 31, 2020 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02)

(1 Sample)

(1) Submitted data from January 1, 2020 through December 31, 2020

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (1 Sample)

(1) Submitted data from January 1, 2020 through December 31, 2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)

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

(1) Containment recirculation fan cooler high efficiency particulate air filter surveillance test failure (AR 04376423) on January 28, 2021

(2) Turbine driven auxiliary feedwater pump steam supply valve 3505A failure to open (AR 04388834) on February 11, 2021

(3) 8 inch fire pipe elbow failure and 1/2 inch priming water pipe to deluge valve failure (AR 04366987, AR 04371341) on March 31,

INSPECTION RESULTS

Containment Spray and Safety Injection Relief Valves 861 and 1817 Flange Over Torque Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71111.15 Systems NCV 05000244/2021001-01 Identification Open/Closed The NRC identified a Green finding and associated non-cited violation of Technical Specification 5.4.1.a, Procedures, when Exelon did not establish and implement required written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, Section 3, Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems. Specifically, Exelon failed to adequately convey technical requirements into procedure GMP-37-06-255/RV Crosby, 3/4 x 1 JRAK-SPEC-B, Relief Valve Maintenance and Testing of IST Group 3B Valves, Revision 0204, which resulted in over torqueing and visual deformation of the raised face inlet flanges of relief valves 861 and 1817 in November 2015 and November 2018.

Description:

In November of 2020, NRC inspectors identified the inlet flanges and fasteners of relief valves 861 and 1817 were visually deformed. Relief valves 861 and 1817 are installed using raised face 150 pound, 1/2 A193 B7 flanges, 3/4 inlet and 1 outlet. Relief valve 861 is a containment spray suction relief valve and 1817 is a safety injection pump suction relief valve to containment spray pump discharge. Valve 1817 was designed to protect the suction side of the safety injection pump from an overpressure condition during post-accident high head recirculation. Valve 861 is part of the containment spray pressure boundary.

Once identified, Exelon entered the issues into the corrective action program as issue reports 4382562 and 04390110, which included performing a work group evaluation. Investigation by Exelon identified that in 2015 and 2018, work orders C92592643 and C93625144 were completed to remove, test and reinstall relief valves 861 and 1817 respectively. Procedure GMP-37-06-255/RV Crosby, 3/4 x 1 JRAK-SPEC-B, Relief Valve Maintenance and Testing of IST Group 3B Valves, Revision 0204, was performed on both valves. Steps 7.14.4 and 7.14.5 of the procedure specifies to torque the inlet and outlet flange nuts to a final torque of 100 ft-lbs (95 to 105 ft-lbs). Exelon determined the correct torque requirements for the raised face inlet and outlet flanges were specified in ME-320 Revision 1, Technical Specification R.E. Ginna Station Threaded Fastener and Torque Application Guidelines Document, Table 18, for 150 pound 3/4 and 1 flanges, 42.8 ft-lbs and 43.1 ft-lbs respectively, with an accuracy of 10 percent. Additionally, vendor technical manual VTD-C0710-4005, Revision 004, Section 7.5.1.4, annotates the stud torque should be between 30 and 60 ft-lbs.

Exelon performed an operability evaluation, OPEVAL-20-005, Revision 1, on the as found configuration. The safety injection and containment spray systems required an evaluation modeling the joint using a finite element analysis program to simulate a design basis accident, i.e. internal pressure load, bolting clamp load, safe shutdown earthquake (SSE)loads, and vibration loading induced by the safety injection and containment spray pump operations. Ultimately, Exelon documented that although the flange design torque was exceeded, a detailed engineering analysis concluded the systems were operable.

Corrective Actions: Exelon performed a work group evaluation to review appropriate actions and document the problem, an operability evaluation to determine acceptability of the as found over torque configuration. Long-term corrective actions include evaluating a design change to remove the over torque configuration.

Corrective Action References: 04382562, 04390110

Performance Assessment:

Performance Deficiency: The inspectors determined that Exelon did not establish and implement required torque values in procedure GMP-37-06-255/RV Crosby, 3/4 x 1 JRAK-SPEC-B, Relief Valve Maintenance and Testing of IST Group 3B Valves, Revision 00204. Specifically, in 2015 and 2018 work orders that completed paragraphs 7.14.4 and 7.14.5 of procedure GMP-37-06-255/RV, Revision 0204, provided instructions to torque joints to 100 ft-lbs, (95 to 105 ft-lbs). The correct torque value is specified in ME-320 Revision 1, Technical Specification R.E. Ginna Station Threaded Fastener and Torque Application Guidelines, Table 18, for 150 pound 3/4 and 1 flanges, 42.8 ft-lbs and 43.1 ft-lbs respectively, with an accuracy of 10 percent. Additionally, vendor technical manual VTD-C0710-4005, Revision 004, Section 7.5.1.4, annotates the stud torque should be between 30 and 60 ft-lbs. 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 was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the 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.m of IMC 0612, Appendix E, Examples of Minor Issues, issued January 1, 2021, because application of excessive torque to a flange joint required a different calculation approach than the original approach resulting in unfavorable margin. Consequently, the torque calculations were revised or accepted as is in order to establish operability. Specifically, a detailed finite element analysis was conducted of the safety injection system and containment spray system relief valves mechanical joint integrity during a design basis accident, i.e. internal pressure, bolting clamp load, SSE, and vibration loading induced by the containment spray pump operation.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated January 1, 2021. The inspectors performed a review of this finding using the guidance provided in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. Exelon was able to provide an operability determination and technical evaluation which concluded that during the time frame from November 2015 and November 2018, the flange joint would not have failed due to internal pressure, bolting clamp load, SSE, and vibration loading induced by the safety injection or containment spray pump operation. Consequently, the finding was determined to be of very low safety significance (Green), because the performance deficiency affected the design or qualification of a mitigating structure system or component, which maintained its operability.

Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, Exelon staff did not identify the flange distortion during joint make-up or field walkdowns.

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.d, identifies emergency core cooling, and Section 3.f.(2)(a) Special Containment Systems atmosphere as a recommended procedure. Exelon procedure GMP-37-06-255/RV Crosby, 3/4 x1 JRAK-SPEC-B, Relief Valve Maintenance and Testing of IST Group 3B Valves, Revision 0204, paragraphs 7.14.4 and 7.14.5 implement this requirement.

Contrary to the above, from November 2015 to November 2020, Exelon did not establish and implement procedure GMP-37-06-255/RV, paragraphs 7.14.4 and 7.14.5, to apply the correct torque valve to emergency core cooling and special containment systems. Specifically, paragraphs 7.14.4 and 7.14.5 of GMP-37-06-255/RV provided instructions to torque the inlet and outlet flanges to 100 ft-lbs (95 - 105 ft-lbs). As a result, the inlet and outlet flanges of relief valves 861 and 1817 were torqued beyond the limits specified in ME-320 Technical Specification R.E. Ginna Station Threaded Fastener and Torque Application Guidelines, Revision 1, Table 18, for 150 pound 3/4 and 1 flanges, 42.8 ft-lbs and 43.1 ft-lbs, with an accuracy of 10 percent, which lead to joint distortion.

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

Failure to Address Leaking Fire Pipe Issue Prior to Failure Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.5] - Work 71152 FIN 05000244/2021001-02 Management Open/Closed A self-revealed Green finding (FIN) of PI-AA-125, Corrective Action Program Procedure, was identified when Exelon failed to address a leaking pipe threaded connection that was identified as an issue in the auxiliary building mezzanine east cable fire suppression system S04. Specifically, after an active water leak from a 1/2 threaded pipe was identified in June of 2019 Exelon failed to implement adequate actions to address the leak. As a result, the pipe failed allowing water to wet the nearby safety related 480-volt electrical bus 14 and electrical motor control center E and collect in the surrounding area.

Description:

The auxiliary building mezzanine east cable fire suppression system S04 flood valve V-9242F is a Grinnell Model B valve constructed of cast bronze. The priming water line is a 1/2 galvanized pipe nipple threaded into the reverse side of the valve creating a dissimilar metal connection. The presence of water within the pipe and valve created a conducting environment where galvanic corrosion occurred.

In June of 2019 Exelon identified a leak at the connection joint of the 1/2 pipe to V-9242F valve body. This issue was entered into the corrective action program as issue report 04255421. As a result of the condition report Exelon generated a work order C93711961 to enter the identified issue into the work management process.

On September 22, 2020 the leaking 1/2 pipe joint to valve V-9242F failed causing water to spray on the side panels of a safety related 480-volt bus 14, adjacent motor control center E, and surrounding area. Exelon was notified of the pipe failure in the main control room by the alarm K-31 Fire System Alarm Panel. As a result, the control room staff entered emergency response procedure ER-FIRE.0, the fire brigade captain responded to the scene and assessed the situation. Subsequently the fire piping was isolated to stop the leak and compensatory fire watches were established in accordance with the technical requirements manual.

Procedure PI-AA-125, Revision 7, Corrective Action Program Procedure, Section 4.3.1 states, in part, to address and disposition any issues or questions identified by the issue report originator, reviewers, screeners, station ownership committee, or management review committee. Contrary to this, the inspectors determined Exelon did not address this issue commensurate with its safety significance as identified in June 2019. Specifically, the leaking threaded connection to valve V-9242F subsequently failed resulting in the fire suppression system piping to become unavailable and water wetting various electrical panels.

Corrective Actions: Exelon generated issue report 04371341 to capture the failed fire system pipe and initiate a work group evaluation. At the time of discovery immediate actions were taken to isolate the leak and establish a continuous fire watch. Additionally, an extent of condition review concluded that all nine similar locations required material replacement.

Furthermore, Exelon plans to incorporate the failure cause into aging management documents.

Corrective Action References: 04255421, 04371341

Performance Assessment:

Performance Deficiency: The inspectors determined that Exelons failure to address issues, identified in June of 2019, with the auxiliary building mezzanine east cable fire suppression system S04 threaded pipe connected to valve V-9242F, was contrary to Exelons PI-AA-125 Corrective Action Program Procedure, and was a performance deficiency that was reasonably within Exelons ability to foresee and correct and should have been prevented.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Exelon staffs failure to address the threaded pipe leak to valve V-9242F, which subsequently resulted in failure, allowed water to spray on and around 480-volt safety related bus 14 and motor control center E, as well as flow to subsequent spaces in the auxiliary building.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated January 1, 2021. The inspectors performed a review of this finding using the guidance provided in IMC 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions. Inspectors determined the finding to be of very low safety significance (Green) since the pipe failure did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Exelon staff adequately implemented a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the identified issue of a pipe leak at valve V-9242F was not addressed using the online work management process ahead of its failure.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Observation: Annual Follow-up: Containment Recirculation Fan Cooler HEPA 71152 Filter Surveillance Failure During the performance of surveillance test STP-E-47.5, containment recirculation fan coolers high efficiency particulate filter bank ACL06A failed to meet the < 1.0 percent bypass acceptance criteria in Technical Specification 5.5.10. The inspectors reviewed Exelons corrective action program evaluation, work orders, extent of condition review, and corrective actions associated with the efficiency failure of the 'A' containment recirculation fan cooler HEPA filters. The inspectors assessed Exelons problem identification threshold, causal analysis, prioritization, and timeliness of corrective actions to determine whether Exelon had taken timely and appropriate corrective actions. Exelon entered this issue into their corrective action program as AR 04376423.

The inspectors determined that Exelon performed a thorough review of the issue and determined the cause of the sample efficiency failure to meet the acceptance criteria.

Exelons immediate corrective actions were to declare the system inoperable and enter the applicable Technical Specification action statement. Exelon replaced 20 HEPA filters in 'A' train then retested the system and determined the system to be within the bypass acceptance criteria (>99 percent efficient) after the filters were replaced.

Exelon also performed additional testing of the failed HEPA filters to determine what caused the failure. The filters showed minor physical damage which had been identified in previous surveillance tests. The licensee determined that the most likely cause of the filter efficiency failures was due to in-service wear at locations of surface damage, which resulted in tears through the filter media. Through the corrective action program evaluation document, Exelon concluded the less efficient containment recirculation fan cooler HEPA filters remained able to meet the design basis requirements. Evaluations considering design basis accidents involving alternate source term and environmental qualification were completed and concluded that there was reasonable assurance that offsite and control room doses would not exceed 10 CFR 50.67 dose limits; therefore, the degraded filter system would have performed its intended function.

Additional corrective actions are long-term and appear to be appropriate and commensurate with the significance. Corrective actions included procurement of enough HEPA filters to support replacement of the remaining filters, work order and surveillance improvements to include HEPA filter inspection protocols, additional training regarding system filter surveillance improvements, and future filter inspections will include validation of allowable service damage.

The inspectors independently reviewed Exelons testing data, requirements, methodology, conclusion, and technical basis that the efficiency of the filter system would have met performance requirements outlined in the plants technical specifications. The inspectors determined that Exelons actions in identifying and resolving the issue were appropriate and timely and commensurate with the safety significance. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that none of the conditions were deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Annual Follow-up: Turbine driven auxiliary feedwater pump steam 71152 supply valve 3505A failure The inspectors evaluated Exelons initial, interim, and long-term corrective actions and past operability related to the turbine driven auxiliary feedwater pump steam supply valve (3505A)circuit failure caused by a binding mechanical interlock on December 7, 2020. The issue was documented in the Exelons corrective action program as AR 04388834. The inspectors reviewed the corrective actions taken, cause analysis, and the past operability evaluation. The inspectors assessed Exelons problem identification threshold, prioritization of the issues, apparent cause analyses, use of operating experience, and timeliness of corrective actions.

As a result of the review, the inspectors concluded that Exelon appropriately evaluated the issue, performed a thorough review of operating experience, and completed timely and appropriate corrective actions. The inspectors noted that the extent of condition is still in progress and Exelon plans to inspect similar valve circuitry mechanical interlocks. The inspectors determined that Exelon's actions in identifying and resolving the issues were commensurate with the safety significance. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that none of the conditions were deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Annual Follow-up: Fire Protection Piping Failures 71152 Review of Exelons evaluation and corrective actions for two separate fire piping failures, 8 and 1/2 fire piping failures: Fire system S04 pipe leak AR 04371341 and Fire system S05 piping elbow, between V5245 and 5203 AR 04366987.

The inspectors performed an in-depth review of Exelons analysis and corrective actions associated with the failure of an 8 fire piping cast elbow between valves V5245 and 5203 and a 1/2 pipe failure in fire system S04. The inspectors reviewed condition reports, engineering evaluations, cause evaluation, testing procedures, analysis reports, maintenance work orders and held discussions with plant personnel. Exelon entered these two issues into their corrective action program as AR 04366987 and AR 04371341 for the 8 elbow and 1/2 pipe respectively. The inspectors assessed Exelons problem identification threshold, cause analysis, prioritization and timeliness of corrective actions to determine whether Exelon was taking timely and appropriate corrective actions.

In the instance of the 8 cast iron elbow fitting, the inspectors observed that Exelon Power Labs performed a thorough review of the evidence and determined the likely failure cause of the 8 elbow was contributed to a casting void which created a weakness that was subject to two stress events. Specifically, the first stress event caused an initial, older fracture, which Exelon determined spanned from the internal corner of the elbow to the end of the threads. The remainder of the fracture surface exhibited a fresh fracture, suggesting the second event was due to hydrodynamic forces during a recent stress event likely associated with a surveillance test. Additionally, Exelon noted that an internal casting void likely contributed to the failure by creating a localized area of reduced material strength. Lastly, the elbow identified as gray cast iron is susceptible to selective leaching. Exelons inspection of the area surrounding the crack and cross-sections through-out the remainder of the elbow did not show indications of selective leaching.

As part of the 8 elbow failure, Exelons immediate corrective actions were to isolate the failed location and install a new elbow and pipe with flanged connections. Exelons additional corrective actions are long-term and appear to be appropriate and commensurate with the significance, which include to revise the aging management walkdown sheets, and extent of condition review for threaded fittings.

The second fire piping issue was a 1/2 blocking water line to a system flood valve V-9242F Grinnell Model B. Exelon concluded the likely cause of the failure to be galvanic corrosion.

This piping material is galvanized pipe with the valve material being made of cast bronze which create a dissimilar metal connection. Exelon completed an extent of condition review and found that all nine similar pipe joint configurations required replacement due to degradation or leaks. Additionally, Exelon has created actions to review the aging management program for the fire water system at Ginna, noting that galvanic corrosion is unlikely due to the non-corrosive conditions of Lake Ontario.

The inspectors independently reviewed the analysis, testing information, work order history, maintenance activities. During the time of Exelons immediate corrective actions, the inspectors observed infield activities to replace the 8 fitting and several 1/2 pipe sections. Regarding the 8 fire piping elbow failure, the inspectors independently reviewed Exelon Power Labs evaluation and concluded the failure mode analysis for the 8 gray cast iron fire water pipe presented reasonable conclusions which were support by visual inspection, fractography and metallographic techniques. The inspectors reviewed the extent of condition and inspected several similar threaded joint connections for external corrosion. Additionally, the inspectors reviewed the license renewal aging management program which aligned with generic aging lessons learned. Lastly, the inspectors reviewed operating experience for similar failures. While through wall leaks have occurred, a rupture of a casting was not identified during the review.

Pertaining to the 1/2 fire piping failure in fire system S04, the inspectors independently reviewed work orders associated with 1/2 piping leaks, and a specific leak identified at the failure location. The inspectors evaluated the issue and dispositioned in accordance current guidance. (FIN 05000244/2021001-02)

Pertaining to the 8 cast elbow failure, the inspectors determined that Exelons actions in identifying and resolving the issues were commensurate with the safety significance. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that the 8 cast elbow conditions were not deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 28, 2021, the inspectors presented the containment recirculation fan cooler filter surveillance problem identification and resolution sample inspection results to Mr. Paul Swift, Site Vice President and other members of the licensee staff.

• On February 11, 2021, the inspectors presented the turbine driven auxiliary feedwater pump steam supply valve (3505A) failure problem identification and resolution sample inspection results to Mr. Dave Wilson, Director of Engineering, and other members of the licensee staff.

• On April 29, 2021, the inspectors presented the integrated inspection results to Mr. Paul Swift, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action AR 0436198 Flood Barrier Inspection scope Frequency Discrepancy 01/15/2021

Documents

Resulting from

Inspection

71111.04 Corrective Action AR 04397240 A MDAFW lube oil cooler outlet flow different than B MDAFW 01/21/20201

Documents requiring adjustment

Resulting from

Inspection

71111.05 Corrective Action AR 04409876 1 drop per minute leak from fire valve 9241D2 03/18/2021

Documents

Resulting from

Inspection

71111.06 Corrective Action AR 04407679 MH4-CC will not pump down manholes 03/09/2021

Documents

Resulting from

Inspection

71111.15 Corrective Action AR 04403107 Emergency Diesel Generator A Diesel Frequency After Start 02/17/2021

Documents outside acceptance criteria

AR 04407795 Boric Acid found on RHR heat exchanger flange 03/10/2021

Corrective Action AR 04382562 NRC POV IR: flange for 1817 condition 11/05/2020

Documents AR 04390110 Condition of flange for valve 861 12/14/2020

Resulting from AR 04401998 Amplifying information for AR 04401056 (A battery room 02/12/2021

Inspection ambient temperature)

AR 04408560 Boric Acid on V-716 (RHR Inlet Block Valve to RHR Heat 03/12/2021

Exchanger B)

AR 04410688 NRC Identified Velcro Tape on Piping Under 'A' and 'B' RHR 03/22/2021

Heat Exchangers

Drawings 33013-1262 Safety Injection and Accumulators (SI) Revision 37

Sheet 1 of 2

DS-C-75799 Crosby Nozzle type relief valve Revision A1

Operability OpEVAL-20-005 Operability Evaluation for valves 1817 and 861 Revision 001

Evaluations

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures GMP-37-06- Crosby 3/4 X 1, JRAK-SPEC-B, Relief Valve Maintenance Revision

255/RV and Testing of IST Group 3B Valves 00204, 003

and 004

ME-320 Technical Specification R.E. Ginna Station Threaded Revision 01

Fastener and Torque Application Guidelines Document

VTD-C0710-4005 Nozzle relief valve maintenance manual Revision 004

Work Orders C92592643 RV-861 - remove / test/ rebuild if required / reinstall 11/05/2015

C93625144 Remove, test, rework, and reinstall, RV-1817 11/06/2018

71111.18 Operability OPEVAL-21-001 IR 04403107 Emergency Diesel Generator 'A' Frequency Revision 24

Evaluations after start was outside acceptance criteria

71111.19 Corrective Action AR 04409157 A safety Injection flow not consistent with Pump differential 03/15/2021

Documents pressure

Procedures STP-E-12.3 Security Emergency Diesel Test Revision 012

STP-O-12.1 Emergency Diesel Generator A Revision 035

STP-O-12.1 Emergency Diesel Generator A Revision 035

STP-O-12.6A Diesel Generator Fuel Oil Transfer Pump A Test Revision 018

STP-O-2.1QA Safety Injection Pump A Quarterly Test Revision 020

STP-O-2.5.7A Emergency Diesel Generator Air Operated Valves, Quarterly Revision 002

Surveillance for A Train Valves

STP-O-30.10 Emergency Diesel Generator A Pre-Startup Alignment Revision 016

Work Orders C93719524 Clean Strainer in Fuel Oil Transfer Pump Suction Strainer,

NDG04

C93731954 Central Alarm System Emergency Diesel Generator 01/19/2021

C93772028 Inspect and Replace Diesel Generator A primary 5927 Fuel

Filter Selector Valve O-Rings

71111.22 Corrective Action AR 04394778 Status Light for Bus 17 X2/17 Intermittent 01/08/2021

Documents AR 04396733 0.5 DPM leak from CV-4304A (A MDAFW RECIRC CHK 01/19/2021

Resulting from VLV)

Inspection

Procedures CPI-Bistables- Calibration of Nuclear Instrumentation System Power Range Revision 027

N41 N41 Bistables and Indicators

STP-I-9.1.17 Undervoltage Protection - 480 volt Safeguards Bus 17 Revision

00904

STP-O-2.2- Residual Heat Removal Pump A Comprehensive Test Revision 018

Inspection Type Designation Description or Title Revision or

Procedure Date

COMP-A

STP-O-36Q-D Standby Auxiliary Feedwater Pump D-Quarterly Revision 021

71152 Corrective Action 04388834

Documents AR 04255421 9242F leaking from 1/2 connection about 1 drop per second 06/08/2019

AR 04366987 Fire pipe break between valves 5245 and 5203 09/02/2020

AR 04371341 Fire system S04 water leak 09/22/2020

Corrective Action 04401455

Documents AR 04398366 Dried chromates on valve 776 CCW/NRHX relief 01/27/2021

Resulting from AR 04401455 DCCR IR 04388834 FMCT requires correction 02/10/2021

Inspection

Drawings 10905-0651 TDAFW Pump Steam Supply Valve MOV-3505A Revision 8

33013-1992 Fire protection system fire service water fire water header A Revision 15

auxiliary building header P&ID

Procedures PI-AA-125 Corrective Action Program (CAP) Procedure Revision 7

STP-O-16QT Auxiliary Feedwater Turbine Pump - Quarterly Revision 26

Work Orders C93711961 9242F leaking from 1/2 connection about 1 drop per second 06/11/2019

C93725016

C93767404

18