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| number = ML18122A332
| number = ML18122A332
| issue date = 05/01/2018
| issue date = 05/01/2018
| title = R.E. Ginna Nuclear Power Plant, LLC - Integrated Inspection Report 05000244/2018001
| title = LLC - Integrated Inspection Report 05000244/2018001
| author name = Catts M
| author name = Catts M
| author affiliation = NRC/RGN-I
| author affiliation = NRC/RGN-I
| addressee name = Hanson B C
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC
| addressee affiliation = Exelon Generation Co, LLC
| docket = 05000244
| docket = 05000244
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., Suite 100 KING OF PRUSSIA, PENNSYLVANIA 19406-2713 May 1, 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
{{#Wiki_filter:May 1, 2018


SUBJECT: R.E. GINNA NUCLEAR POWER PLANT, LLC
==SUBJECT:==
- INTEGRATED INSPECTION REPORT 05000 244/2018001
R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2018001


==Dear Mr. Hanso n:==
==Dear Mr. Hanson:==
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC (Ginna)
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC (Ginna). On April 16, 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.
. On April 16, 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.


The NRC inspectors did not identify any finding or violation of more than minor significance.
The NRC inspectors did not identify any finding or violation of more than minor significance.


This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading
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.
-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, "Public Inspections, Exemptions, Requests for Withholding."


Sincerely,
Sincerely,
/RA/ Michelle Catts , Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Number: 50-244 License Number: D PR-18 Enclosure:
/RA/  
 
Michelle Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects  
 
Docket Number: 50-244  
 
License Number: DPR-18  
 
===Enclosure:===
Inspection Report 05000244/2018001


==Inspection Report==
==Inspection Report==
05000 244/20 18 00 1 cc w/encl:
Docket Number:
Distribution via ListServ
50-244


ML18 122A322 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME NPerry/AR per tele conv ARosebrook MCatts DATE 0 5/1/18 0 5/1/18 0 5/1/18 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION
License Number:
DPR-18  


==Inspection Report==
Report Number:
Docket Number: 50-244 License Number: DPR-18 Report Number: 05000 244/20 18 00 1 Enterprise Identifier:
05000244/2018001
I-20 18-001-0045 Licensee: Exelon Generation Company, LLC (Exelon)
 
Facility: R.E. Ginna Nuclear Power Plant, LLC (Ginna)
Enterprise Identifier: I-2018-001-0045  
Location: Ontario, New York Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors:
 
N. Perry, Senior Resident Inspector J. Schussler, Resident Inspector A. Rosebrook, Senior Project Engineer H. Anagnostopoulos, Senior Health Physicist S. Obadina, Project Engineer Observer: K. Warner, Health Physicist Approved By:
Licensee:
M. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects
Exelon Generation Company, LLC (Exelon)  
 
Facility:
R.E. Ginna Nuclear Power Plant, LLC (Ginna)  
 
Location:
Ontario, New York  
 
Inspection Dates:
January 1, 2018 to March 31, 2018  
 
Inspectors:
N. Perry, Senior Resident Inspector  
 
J. Schussler, Resident Inspector  
 
A. Rosebrook, Senior Project Engineer  
 
H. Anagnostopoulos, Senior Health Physicist  
 
S. Obadina, Project Engineer  
 
Observer:
K. Warner, Health Physicist  
 
Approved By:
M. Catts, Acting Chief  
 
Reactor Projects Branch 1  


2
Division of Reactor Projects


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


Exelon's 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 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.
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.


No findings or more-than-minor violations were identified.
No findings or more-than-minor violations were identified.


Additional Tracking Item s  Type Issue number Title Report Section Status LER 05000244/201800 1-00 Leakage in Reactor Coolant System Pressure Boundary N/A Open LER 05000244/2017001
===Additional Tracking Items===
-01 During Surveillance Testing, Lift Pressure Setpoints on Three Main Steam Safety Valves F ound Outside Technical Specification Limits 71153 Open/Closed
Type Issue number Title Report Section Status LER 05000244/2018001-00 Leakage in Reactor Coolant System Pressure Boundary N/A Open LER 05000244/2017001-01 During Surveillance Testing,
Lift Pressure Setpoints on Three Main Steam Safety Valves Found Outside Technical Specification Limits 71153  


3
Open/Closed


=PLANT STATUS=
=PLANT STATUS=


The unit began the inspection period at 100 percent power and operated at full power until March 8 , 2018, when the unit was shut down to replace a faulty current transformer on the main generator's output line. The unit was returned to rated power on March 13, following replacement of the current transformer, and it remained at or near 100 percent power for the remainder of the inspection period.
The unit began the inspection period at 100 percent power and operated at full power until March 8, 2018, when the unit was shut down to replace a faulty current transformer on the main generators output line. The unit was returned to rated power on March 13, following replacement of the current transformer, and it remained at or near 100 percent power for the remainder of the inspection period.
 
==INSPECTION SCOPE==
S  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 Exelon's performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards."
==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.


==REACTOR SAFETY==
==REACTOR SAFETY==
==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection==
 
===Impending Severe Weather (1 Sample)===
Impending Severe Weather (1 Sample) The inspectors evaluated readiness for impending adverse weather conditions for predicted heavy snow accumulation on March 1, 2018
The inspectors evaluated readiness for impending adverse weather conditions for predicted heavy snow accumulation on March 1, 2018.
.


==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment==
 
===Partial Walkdown (3 Samples)===
Partial Walkdown (3 Sample s) The inspectors evaluated system configuration s during partial walkdowns of the following systems/trains
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
:
: (1) C standby auxiliary feedwater on January 26, 2018
: (1) 'C' standby auxiliary feedwater on January 26, 2018
: (2) Turbine-driven auxiliary feedwater on March 9, 2018
: (2) Turbine-driven auxiliary feedwater on March 9, 2018
: (3) 'B' safety injection on March 22, 2018
: (3) B safety injection on March 22, 2018


==71111.05Q - Fire Protection Quarterly==
==71111.05Q - Fire Protection Quarterly==
 
===Quarterly Inspection (5 Samples)===
Quarterly Inspection (5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas:
The inspectors evaluated fire protection program implementation in the following selected areas:
: (1) Co mpensatory measures during replacement of fire water piping in 'A' emergency diesel generator room on January 17, 2018
: (1) Compensatory measures during replacement of fire water piping in A emergency diesel generator room on January 17, 2018
: (2) 'B' b attery room on February 16, 2018
: (2) B battery room on February 16, 2018
: (3) Intermediate building controlled side basement on March 22, 2018
: (3) Intermediate building controlled side basement on March 22, 2018
: (4) Intermediate building controlled side top floor on March 30, 2018
: (4) Intermediate building controlled side top floor on March 30, 2018
: (5) Hemyc wrap on March 30, 2 018
: (5) Hemyc wrap on March 30, 2018


==71111.06 - Flood Protection Measures==
==71111.06 - Flood Protection Measures==
 
===Cables (1 Sample)===
Cables (1 Sample) The inspectors evaluated cable submergence protection in:
The inspectors evaluated cable submergence protection in:
: (1) Manholes MH1A-01, MH1B-01, MH3-03 West, MH5A
: (1) Manholes MH1A-01, MH1B-01, MH3-03 West, MH5A-01, 02, and 03 on February 19 and 20, 2018.
-01, 02 , and 03 on February 19 and 20, 2018.


==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
===Operator Requalification (1 Sample)===
The inspectors observed and evaluated a crew of licensed operators in the plants simulator during licensed operator requalification training, involving a failed steam flow transmitter, trip of a running component cooling water pump, a main steam line leak and a steam generator tube rupture, on February 13, 2018.


Operator Requalification (1 Sample) The inspectors observed and evaluated a crew of licensed operators in the plant's simulator during licensed operator requalification training, involving a failed steam flow transmitter, trip of a running component cooling water pump, a main steam line leak and a steam generator tube rupture, on February 13, 2018.
===Operator Performance (1 Sample)===
 
The inspectors observed Control Room operator performance during a lowering water level in the screen house intake on February 13, 2018, power decrease for the turbine-driven auxiliary feedwater run on March 7, 2018, and start up activities on March 10 to March 13, 2018.
Operator Performance (1 Sample)  The inspectors observed Control Room operator performance during a lowering water level in the screen house intake on February 13, 2018, power decrease for the turbine-driven auxiliary feedwater run on March 7, 2018
, and start up activities on March 10 to March 13, 2018.


==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness==
 
===Routine Maintenance Effectiveness (2 Samples)===
Routine Maintenance Effectiveness (2 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions.
.
: (1) House heating boiler maintenance rule (a)(1) evaluation on March 1, 2018
: (1) House heating boiler maintenance rule (a)(1) evaluation on March 1, 20 18
: (2) Chemical and volume control system (charging) on March 6, 2018
: (2) Chemical and volume control system (charging) on March 6, 2018


==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13|count=5}}
{{IP sample|IP=IP 71111.13|count=5}}
The inspectors evaluated the risk assessments for the following planned and emergent work activities
 
:
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
: (1) Elevated risk for planned under
: (1) Elevated risk for planned under-voltage testing on electrical busses 16 and 17 on February 1, 2018
-voltage testing on electrical bus s es 16 and 17 on February 1, 2018
: (2) Atmospheric relief valve 3411 hand-wheel planned replacement on February 27, 2018
: (2) Atmospheric relief valve 3411 hand-wheel planned replacement on February 27, 2018
: (3) 'A' residual heat removal planned maintenance on March 15, 2018
: (3) A residual heat removal planned maintenance on March 15, 2018
: (4) 'C' safety injection pump planned maintenance on March 21 and March 22, 2018
: (4) C safety injection pump planned maintenance on March 21 and March 22, 2018
: (5) 'A' component cooling water planned maintenance on March 26, 2018
: (5) A component cooling water planned maintenance on March 26, 2018


==71111.15 - Operability Determinations and Functionality Assessments==
==71111.15 - Operability Determinations and Functionality Assessments==
Line 137: Line 160:


The inspectors evaluated the following operability determinations and functionality assessments:
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) 'A' emergency diesel generator due to a ground on a lube oil heater on January 12, 2018
: (1) A emergency diesel generator due to a ground on a lube oil heater on January 12, 2018
: (2) 'B' battery room vault water intrusion on January 31, 2018
: (2) B battery room vault water intrusion on January 31, 2018
: (3) Fire suppression system S
: (3) Fire suppression system S-15 alarm inputs on February 13, 2018
-15 alarm inputs on February 13, 2018
: (4) Main steam safety valve 3512 seat leakage on February 28, 2018
: (4) Main steam safety valve 351 2 seat leakage on February 28, 2018


==71111.19 - Post Maintenance Testing==
==71111.19 - Post Maintenance Testing==
{{IP sample|IP=IP 71111.19|count=7}}
{{IP sample|IP=IP 71111.19|count=7}}
The inspectors evaluated post maintenance testing for the following maintenance/repair activities
 
:
The inspectors evaluated post maintenance testing for the following maintenance/repair activities:
: (1) Excess letdown divert valve AOV
: (1) Excess letdown divert valve AOV-312 gag installation on February 12, 2018
-312 gag installation on February 12, 2018
: (2) A spent fuel pool pump check valve, CV-8655 maintenance, on February 13, 2018
: (2) 'A' spent fuel pool pump check valve, CV-8655 maintenance, on February 13, 2018
: (3) A spent fuel pool pump maintenance and diode replacement on February 16, 2018
: (3) 'A' spent fuel pool pump maintenance and diode replacement on February 16, 2018
: (4) A flex diesel air compressor preventive maintenance on February 22, 2018
: (4) 'A' flex diesel air compressor preventive maintenance on February 22, 2018
: (5) D service water pump/motor replacement and maintenance on March 3, 2018
: (5) 'D' service water pump/motor replacement and maintenance on March 3, 2018
: (6) A residual heat removal pump/motor alignment on March 15, 2018
: (6) 'A' residual heat removal pump/motor alignment on March 15, 2018
: (7) Technical support center ventilation fan maintenance on March 22, 2018
: (7) Technical support center ventilation fan maintenance on March 22, 2018


==71111.20 - Refueling and Other Outage Activities==
==71111.20 - Refueling and Other Outage Activities==
{{IP sample|IP=IP 71111.20|count=1}}
{{IP sample|IP=IP 71111.20|count=1}}
The inspectors evaluated forced outage activities from March 7 t o March 10, 2018
 
.
The inspectors evaluated forced outage activities from March 7 to March 10, 2018.


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


The inspectors evaluated the following surveillance tests:
===Routine===
Routine (3 Samples)
{{IP sample|IP=IP 71111.22|count=3}}
: (1) STP-O-16QA , 'A' motor driven auxiliary feedwater pump surveillance test on January 10, 2018
: (1) STP-O-16QA, A motor driven auxiliary feedwater pump surveillance test on January 10, 2018
: (2) STP-O-40.5 , national fire protection association emergency diesel generator surveillance test on February 9, 2018
: (2) STP-O-40.5, national fire protection association emergency diesel generator surveillance test on February 9, 2018
: (3) STP-O-12.1 , 'A' emergency diesel generator surveillance test on February 12, 2018
: (3) STP-O-12.1, A emergency diesel generator surveillance test on February 12, 2018  


===Inservice (1 Sample)===
===Inservice (1 Sample)===
: (1) STP-O-3QB, containment spray pump 'B' quarterly test on March 20, 2018 RADIATION SAFET Y
: (1) STP-O-3QB, containment spray pump B quarterly test on March 20,


==RADIATION SAFETY==
==71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls==
==71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls==
===Radiological Work Planning (1 Sample)===
The inspectors evaluated Exelons radiological work planning by reviewing the following activities:
: (1) ALARA Plan 2017-1009
: (2) ALARA Plan 2017-1018
: (3) ALARA Plan 2017-1036


Radiological Work Planning (1 Sample)
===Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)===
The inspectors evaluated Exelon's radiological work planning by reviewing the following activities
The inspectors evaluated dose estimates and exposure tracking.
:
: (1) ALARA Plan 2017
-1009
: (2) ALARA Plan 2017
-1018
: (3) ALARA Plan 2017
-1036  Verification of Dose Estimates and Exposure Tracking


===Systems (1 Sample)===
===Implementation of ALARA and Radiological Work Controls (1 Sample)===
The inspectors evaluated dose estimates and exposure tracking
. Implementation of ALARA and Radiological Work Controls (1 Sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:
: (1) ALARA Plan 2017
: (1) ALARA Plan 2017-1009
-1009
: (2) ALARA Plan 2017-1018
: (2) ALARA Plan 2017
: (3) ALARA Plan 2017-1036
-1018
: (3) ALARA Plan 2017
-1036


==OTHER ACTIVITIES
==OTHER ACTIVITIES - BASELINE==
- BASELINE==
===71151 - Performance Indicator Verification The inspectors verified Exelons performance indicator submittals listed below.===
71151 - Performance Indicator Verification The inspectors verified Exelon's performance indicator submittals listed below. (3 Sample s)
{{IP sample|IP=IP 71151|count=3}}
: (1) Unplanned Scrams on March 16, 2018
: (1) Unplanned Scrams on March 16, 2018
: (2) Unplanned Scrams with Complications on March 16, 2018
: (2) Unplanned Scrams with Complications on March 16, 2018
Line 203: Line 219:


==71152 - Problem Identification and Resolution==
==71152 - Problem Identification and Resolution==
===Annual Follow-up of Selected Issues (1 Sample)===
The inspectors reviewed the Exelons implementation of its corrective action program related to the following issues:
: (1) Maintenance Rule availability performance criteria and reliability performance criteria selection in accordance with Exelon procedure ER-AA-310-1003 Revision 5, on March 30, 2018. Action Request (AR) 04126470 and 02658070.


Annual Follow
===71153 - Follow-up of Events and Notices of Enforcement Discretion Events===
-up of Selected Issue s (1 Sample)  The inspectors reviewed the Exelon's implementation of its corrective action program related to the following issues:
{{IP sample|IP=IP 71153|count=2}}
: (1) Maintenance Rule availability performance criteria and reliability performance criteria selection in accordance with Exelon procedure ER
 
-AA-310-1003 Revision 5, on  March 30, 2018. Action Request (AR)04126470 and 02658070
The inspectors evaluated response to the following events.
.
71153 - Follow-up of Events and Notices of Enforcement Discretion Events (2 Sample s)  T h e inspectors evaluated response to the following events
.
: (1) Reactor coolant system leak January 23 through January 27, 2018
: (1) Reactor coolant system leak January 23 through January 27, 2018
: (2) Forced outage March 7 to March 10, 2018 Licensee Event Reports (1 Sample)  The inspectors evaluated the following licensee event report which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx
: (2) Forced outage March 7 to March 10, 2018  
:
: (1) Licensee Event Report (LER) 05000244/2017-001-01, During surveillance testing, lift pressure s et points on three main stream safety valves found outside Technical Specifications limits on March 23, 2018. Revision 0 of this LER was previously closed in Inspection Report 05000244/2017004. Revision 1 updates the LER with the results of the cause evaluation.


No additional findings were identified. This LER is close d. Personnel Performance (1 Sample)
===Licensee Event Reports (1 Sample)===
: (1) Unplanned plant shutdown March 8 to 9, 2018, due to a current transformer failure on the main generator outgoing power line
The inspectors evaluated the following licensee event report which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
: (1) Licensee Event Report (LER) 05000244/2017-001-01, During surveillance testing, lift pressure set points on three main stream safety valves found outside Technical Specifications limits on March 23, 2018. Revision 0 of this LER was previously closed in Inspection Report 05000244/2017004. Revision 1 updates the LER with the results of the cause evaluation. No additional findings were identified. This LER is closed.
 
===Personnel Performance (1 Sample)===
: (1) Unplanned plant shutdown March 8 to 9, 2018, due to a current transformer failure on the main generator outgoing power line.


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Minor Violation 71152 Follow
Minor Violation 71152 Follow-up of Selected Issues Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (a)(2) allows safety system structure and components to not be monitored under 10 CFR 50 (a)(1), if an adequate demonstration that system performance is being maintained through effective maintenance is provided. In order to demonstrate this, Maintenance Rule availability performance criteria and reliability performance criteria are established and selected in accordance with Exelon procedure ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection. Section 4.4, Selecting Reliability Performance Criteria, Attachment 3, Process for Selecting Reliability Performance Criteria, contains a process to be used in which a criteria greater than or equal to two is acceptable with documentation of past performance. Contrary to the above, two maintenance rule systems contained criteria greater than or equal to two without documentation of past performance in the Basis and Justification for Criteria Values section of the maintenance rule basis document. Thus, an adequate technical basis was not documented for a required 10 CFR 50.65 (a)(2) performance criteria in accordance with Exelons procedures.
-up of Selected Issues Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (a)(2) allows safety system structure and components to not be monitored under 10 CFR 50 (a)(1), if an adequate demonstration that system performance is being maintained through effective maintenance is provided. In order to demonstrate this, Maintenance Rule availability performance criteria and reliability performance criteria are established and select ed in accordance with Exelon procedure ER
-AA-310-1003 , "Maintenance Rule  
- Performance Criteria Selection."  Section 4.4, "Selecting Reliability Performance Criteria,"
3, "Process for Selecting Reliability Performance Criteria," contains a process to be used in which a criteria greater than or equal to two is acceptable with documentation of past performance. Contrary to the above , two maintenance rule systems contained criteria greater than or equal to two without documentation of past performance in the "Basis and Justification for Criteria Values" section of the maintenance rule basis document.


Thus, an adequate technical basis was not documented for a required 10 CFR 50.65 (a)(2) performance criteria in accordance with Exelon's procedures.
Screening: The inspectors independently evaluated the deficiency for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, issued December 31, 2017, and Appendix E, Examples of Minor Issues, issued August 11, 2009.


Screening:
The inspectors determined that not documenting the past performance, which was used to determine the reliability criteria, was a deficiency of minor significance since the criteria selected did not require a maintenance rule a(1) evaluation. As a result it is not subject to enforcement action in accordance with the NRCs enforcement policy. This issue was captured in Exelons Corrective Action Program as AR 04126470 and 02658070.
The inspectors independently evaluated the deficiency for significance in accordance with the guidance in IMC 0612, Appendix B, "Is sue Screening," issued December 31, 2017, and Appendix E, "Examples of Minor Issues," issued August 11, 2009. The inspectors determined that not documenting the past performance , which was used to determine the reliability criteria
, was a deficiency of minor significance since the criteria selected did not require a maintenance rule a(1) evaluation. As a result it is not subject to enforcement action in accordance with the NRC's enforcement policy. This issue was captured in Exelon's Corrective Action Program as A R 04126470 and 02658070
.  


=====Enforcement:=====
=====Enforcement:=====
This failure to comply with procedure ER
This failure to comply with procedure ER-AA-310-1003, Revision 5, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
-AA-310-1003 , Revision 5, constitutes a minor violation that is not subject to enforcement action in accordance with the NRC's Enforcement Policy.


==EXIT MEETING S AND DEBRIEFS==
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
The inspectors verified no proprietary information was retained or documented in this report.
 
* On March 22, 2018, the inspectors presented the inspection results related to IP 71124.02 to Mr. William Carsky, Site Vice President, and other members of the Ginna staff.
On March 22, 2018, the inspectors presented the inspection results related to IP 71124.02 to Mr. William Carsky, Site Vice President, and other members of the Ginna staff.
* On April 16, 2018, the inspectors presented the integrated quarterly resident inspector report inspection results to Mr. William Carsky, Site Vice President and other members of the Ginna staff.
 
On April 16, 2018, the inspector s presented the integrated quarterly resident inspector report inspection results to Mr. William Carsky, Site Vice President and other members of the Ginna staff.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=
Line 251: Line 259:
71111.05 - Fire Protection
71111.05 - Fire Protection
Procedures
Procedures
A-54.7, Fire Protection Tour, Revision
A-54.7, Fire Protection Tour, Revision 37
A-601.13, Fire Protection Compensatory Actions, Revision
A-601.13, Fire Protection Compensatory Actions, Revision 8
FPS-3, Fire Barrier
FPS-3, Fire Barrier Inspection Program, Revision 3
Inspection Program, Revision
71111.06 - Flood Protection Measures
71111.06 - Flood Protection Measures
Condition Reports
Condition Reports
04106112 04106114 04106123 Drawings 33013-0014, 34.5KV Duct & Control Duct Plan & Profile, Revision L
04106112
04106114
04106123
Drawings
33013-0014, 34.5KV Duct & Control Duct Plan & Profile, Revision L
Maintenance Orders/Work Orders
Maintenance Orders/Work Orders
WO C 93597827  71111.11 - Licensed Operator Requalification Program
WO C93597827
71111.11 - Licensed Operator Requalification Program
Procedures
Procedures
HU-AA-1211, Pre-Job Briefings, Revision
HU-AA-1211, Pre-Job Briefings, Revision 11
OP-AA-101-113-1006, 4.0 Crew Critique Guidelines, Revision
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 4 71111.12 - Maintenance Effectiveness
TQ-GI-150-F31 (LORT), Ginna Site Specific License Operator Requalification Training Program,
Revision 4
71111.12 - Maintenance Effectiveness
Procedures
Procedures
ER-AA-310, Implementation of the Maintenance Rule, Revision
ER-AA-310, Implementation of the Maintenance Rule, Revision 11
1 ER-AA-310-1001, Maintenance Rule  
ER-AA-310-1001, Maintenance Rule - Scoping, Revision 4
- Scoping, Revision
ER-AA-310-1002, Maintenance Rule Functions - Safety Significance Classification, Revision 3
ER-AA-310-1002, Maintenance Rule Functions  
ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5
- Safety Significance Classification, Revision
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14
ER-AA-310-1003, Maintenance Rule  
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (A)(1) and (A)(2), Revision 7
- Performance Criteria Selection, Revision 5 ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision
ER-AA-310-1005, Maintenance Rule  
- Dispositioning Between (A)(1) and (A)(2), Revision 7
Condition Reports
Condition Reports
04068393 04083945
04068393
0  71111.13 - Maintenance Risk Assessments and Emergent Work Control
04083945  
 
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Procedures
Procedures
OP-AA-102-102, General Area Checks and Operator Field Rounds, Revision 15
OP-AA-102-102, General Area Checks and Operator Field Rounds, Revision 15
OP-A A-108-117, Protected
OP-AA-108-117, Protected Equipment Program, Revision 5
Equipment Program, Revision 5
OPG-PROTECTED-EQUIPMENT, Operations Protected Equipment Program, Revision 18
OPG-PROTECTED-EQUIPMENT, Operations Protected
Equipment Program, Revision
WC-AA-101, On-Line Work Control Process, Revision 27
WC-AA-101, On-Line Work Control Process, Revision 27
WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2
WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2
WC-AA-104, Integrated Risk Management, Revision
WC-AA-104, Integrated Risk Management, Revision 25
Condition Reports
Condition Reports
04099860 71111.15 - Operability Determinations and Functionality Assessments
04099860
71111.15 - Operability Determinations and Functionality Assessments
Procedures
Procedures
A-3.3, Containment Integrity Program, Revision 27
A-3.3, Containment Integrity Program, Revision 27
OP-AA-108-115, Operability Determinations, Revision 19
OP-AA-108-115, Operability Determinations, Revision 19
Condition Reports
Condition Reports
2534565 04091493 04096584 04099235 04101267 04108798* Miscellaneous
2534565
04091493
04096584
04099235
04101267
04108798*
Miscellaneous
ECP-17-000051, Technical Evaluation of Lube Oil Heaters, Revision 0
ECP-17-000051, Technical Evaluation of Lube Oil Heaters, Revision 0
OPEVAL-15-008, 64 - 125 VDC Electrical System SR, 65  
OPEVAL-15-008, 64 - 125 VDC Electrical System SR, 65 - Diesel Generator Emergency
- Diesel Generator Emergency Power System, Revision 1
Power System, Revision 1
OPEVAL-18-001, S/G 'B' Main Steam Safety Valve 3512, Revision 1
OPEVAL-18-001, S/G B Main Steam Safety Valve 3512, Revision 1
71152 - Problem Identification and Resolution
71152 - Problem Identification and Resolution
Procedures
Procedures
ER-AA-310, Implementation of the Maintenance Rule, Revision 11
ER-AA-310, Implementation of the Maintenance Rule, Revision 11
ER-AA-310-1003, Maintenance Rule  
ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5
- Performance Criteria Selection, Revision 5
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14
ER-AA-310-1004, Maintenance Rule  
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), Revision 7
- Performance Monitoring, Revision 14
ER-AA-310-1005, Maintenance Rule  
- Dispositioning Between (a)(1) and (a)(2), Revision 7
PI-AA-120, Issue Identification and Screening Process, Revision 7
PI-AA-120, Issue Identification and Screening Process, Revision 7
PI-AA-125, Corrective Action Program (CAP) Procedure, Revision
PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 4
Condition Reports (*initiated in response to inspection)
Condition Reports (*initiated in response to inspection)
AR 02658070
AR 02658070 AR 04126470*
AR 04126470
71153 - Follow-up of Events and Notices of Enforcement Discretion
*  71153 - Follow-up of Events and Notices of Enforcement Discretion
Procedures
Procedures
A-80, Startup Readiness Control, Revision019
A-80, Startup Readiness Control, Revision019
AP-TURB.5, Rapid Load Reduction, Revision 018
AP-TURB.5, Rapid Load Reduction, Revision 018
Condition Reports
Condition Reports
04096294 04097619 Maintenance Orders/Work Orders
04096294
WO C93654311
04097619
UNITED STATES NUCLEAR REGULATORY COMMISSION
Maintenance Orders/Work Orders
REGION I 2100 RENAISSANCE BLVD., Suite 100
WO C93654311  
KING OF PRUSSIA, PENNSYLVANIA
 
19406-2713   May 1, 2018 Mr. Bryan C. Hanson
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., Suite 100
KING OF PRUSSIA, PENNSYLVANIA 19406-2713  
 
May 1, 2018
Mr. Bryan C. Hanson
Senior Vice President, Exelon Generation Company, LLC
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
President and Chief Nuclear Officer, Exelon Nuclear
Line 327: Line 348:
Warrenville, IL 60555
Warrenville, IL 60555
SUBJECT:  
SUBJECT:  
: [[contact::R.E. GINNA NUCLEAR POWER PLANT]], LLC
: [[contact::R.E. GINNA NUCLEAR POWER PLANT]], LLC - INTEGRATED INSPECTION
- INTEGRATED INSPECTION REPORT 05000 244/2018001   Dear Mr. Hanso n: On March 31, 2018, the  
REPORT 05000244/2018001
: [[contact::U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant]], LLC (Ginna)
Dear Mr. Hanson:
. On April 16, 2018, the NRC inspectors discussed the results of this inspection with Mr. William Carsky, Site Vice President and other
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at  
: [[contact::R.E. Ginna Nuclear Power Plant]], LLC (Ginna). On April 16, 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.
members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspectors did not identify any finding or violation of more than minor significance.
The NRC inspectors did not identify any finding or violation of more than minor significance.
This letter, its enclosure, and your response (if any) will be made
This letter, its enclosure, and your response (if any) will be made available for public inspection
available for public inspection and copying at http://www.nrc.gov/reading
and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room
-rm/adams.html
in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public
and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations
Inspections, Exemptions, Requests for Withholding.
(10 CFR), Part 2.390, "Public Inspections, Exemptions, Requests for Withholding."
Sincerely,  
Sincerely,       /RA/ Michelle Catts , Acting Chief Reactor Projects Branch
 
/RA/
Michelle Catts, Acting Chief
Reactor Projects Branch 1
Division of Reactor Projects
Division of Reactor Projects
Docket Number:   50-244   License Number: D PR-18 Enclosure:
Docket Number: 50-244
Inspection Report
License Number: DPR-18
05000 244/20 18 00 1    cc w/encl:
Enclosure:
Distribution via ListServ
Inspection Report 05000244/2018001
 
cc w/encl: Distribution via ListServ
ML18122A322
SUNSI Review
 
Non-Sensitive
Sensitive
 
Publicly Available
Non-Publicly Available
OFFICE
RI/DRP
RI/DRP
RI/DRP
 
NAME
NPerry/AR per
tele conv
ARosebrook
MCatts
 
DATE
05/1/18
05/1/18
05/1/18
 
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
 
Docket Number:
50-244
 
License Number:
DPR-18
 
Report Number:
05000244/2018001
 
Enterprise Identifier: I-2018-001-0045
 
Licensee:
Exelon Generation Company, LLC (Exelon)


ML18 122A322  SUNSI Review
Non-Sensitive  Sensitive  Publicly Available
Non-Publicly Available  OFFICE RI/DRP RI/DRP RI/DRP  NAME NPerry/AR per tele conv ARosebrook
MCatts  DATE 0 5/1/18 0 5/1/18 0 5/1/18
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:  50-244  License Number: DPR-18  Report Number: 05000 244/20 18 00 1  Enterprise Identifier:
I-20 18-001-0045  Licensee: Exelon Generation Company, LLC (Exelon)
Facility:  
Facility:  
: [[contact::R.E. Ginna Nuclear Power Plant]], LLC (Ginna)
: [[contact::R.E. Ginna Nuclear Power Plant]], LLC (Ginna)  
Location: Ontario, New York
 
Inspection Dates: January 1, 2018
Location:
to March 31, 2018
Ontario, New York  
Inspectors:
 
: [[contact::N. Perry]], Senior Resident Inspector
Inspection Dates:
: [[contact::J. Schussler]], Resident Inspector
January 1, 2018 to March 31, 2018  
: [[contact::A. Rosebrook]], Senior Project
 
Engineer  
Inspectors:  
: [[contact::H. Anagnostopoulos]], Senior Health Physicist
: [[contact::N. Perry]], Senior Resident Inspector  
: [[contact::J. Schussler]], Resident Inspector  
: [[contact::A. Rosebrook]], Senior Project Engineer  
: [[contact::H. Anagnostopoulos]], Senior Health Physicist  
: [[contact::S. Obadina]], Project Engineer
: [[contact::S. Obadina]], Project Engineer
Observer:  
Observer:  
: [[contact::K. Warner]], Health Physicist
: [[contact::K. Warner]], Health Physicist
Approved By:
Approved By:  
: [[contact::M. Catts]], Acting Chief   Reactor Projects Branch
: [[contact::M. Catts]], Acting Chief  
Division of Reactor Projects
 
Reactor Projects Branch 1
 
Division of Reactor Projects  
 
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.
No findings or more-than-minor violations were identified.
 
Additional Tracking Items


SUMMARY  The U.S. Nuclear Regulatory Commission (NRC) continued monitoring
Type
Exelon's performance at Ginna by conducting the baseline inspections described in this report
Issue number
in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for
Title
overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html
Report
for more information.
Section
No findings
Status
or more-than-minor violations
LER
were identified.
05000244/2018001-00
Additional Tracking Item s  Type Issue number
Leakage in Reactor Coolant
Title Report Section Status LER 05000244/201800
System Pressure Boundary
1-00 Leakage in
N/A
Reactor Coolant System Pressure Boundary N/A Open LER 05000244/2017001
Open
-01 During Surveillance
LER
Testing, Lift Pressure Setpoints on
05000244/2017001-01
Three Main Steam Safety Valves F ound Outside Technical Specification
During Surveillance Testing,
Limits 71153 Open/Closed
Lift Pressure Setpoints on
Three Main Steam Safety
Valves Found Outside
Technical Specification
Limits
71153
Open/Closed  


PLANT STATUS
PLANT STATUS
The unit began the inspection period at 100 percent power and operated at full power until March 8 , 2018, when the unit was shut down to replace a faulty current transformer on the main generator's output line. The unit was returned to rated power on March 13, following replacement of the current transformer, and it remained at or near 100 percent power for the remainder of the inspection period.
The unit began the inspection period at 100 percent power and operated at full power until
INSPECTION SCOPE
March 8, 2018, when the unit was shut down to replace a faulty current transformer on the main
S  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
generators output line. The unit was returned to rated power on March 13, following
-rm/doc-collections/insp
replacement of the current transformer, and it remained at or near 100 percent power for the
-manual/inspection
remainder of the inspection period.
-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
INSPECTION SCOPES
-Water Reactor Inspection Program - Operations Phase."
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
The inspectors performed plant status activities described in IMC 2515 Appendix
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
D, "Plant Status" and conducted routine reviews using IP
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
71152, "Problem Identification and Resolution."
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
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."
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.
REACTOR SAFETY
REACTOR SAFETY
71111.01 - Adverse Weather Protection
71111.01 - Adverse Weather Protection
Impending Severe Weather
Impending Severe Weather (1 Sample)
(1 Sample) The inspectors evaluated readiness for impending adverse weather conditions for predicted heavy snow accumulation
The inspectors evaluated readiness for impending adverse weather conditions for predicted
on March 1, 2018
heavy snow accumulation on March 1, 2018.
. 71111.04 - Equipment Alignment
71111.04 - Equipment Alignment
Partial Walkdown
Partial Walkdown (3 Samples)
(3 Sample s) The inspectors evaluated system configuration
The inspectors evaluated system configurations during partial walkdowns of the following
s during partial walkdowns of the following systems/trains
systems/trains:
:  (1) 'C' standby auxiliary feedwater
(1) C standby auxiliary feedwater on January 26, 2018  
on January 26, 2018
(2) Turbine-driven auxiliary feedwater on March 9, 2018  
(2) Turbine-driven auxiliary feedwater on March 9, 2018
(3) B safety injection on March 22, 2018
(3) 'B' safety injection on March 22, 2018
71111.05Q - Fire Protection Quarterly
71111.05Q  
Quarterly Inspection (5 Samples)
- Fire Protection Quarterly
The inspectors evaluated fire protection program implementation in the following selected
Quarterly Inspection
areas:  
(5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas:  
 
(1) Co mpensatory measures during replacement of fire water piping in 'A' emergency diesel generator room on January
(1) Compensatory measures during replacement of fire water piping in A emergency diesel
17, 2018 (2) 'B' b attery room on February 16, 2018
generator room on January 17, 2018  
(3) Intermediate building controlled side basement on March 22, 2018
(2) B battery room on February 16, 2018  
(4) Intermediate building controlled side top floor
(3) Intermediate building controlled side basement on March 22, 2018  
on March 30, 2018
(4) Intermediate building controlled side top floor on March 30, 2018  
(5) Hemyc wrap on March 30, 2
(5) Hemyc wrap on March 30, 2018
018  71111.06 - Flood Protection Measures
71111.06 - Flood Protection Measures
Cables (1 Sample) The inspectors evaluated cable submergence protection in:
Cables (1 Sample)
  (1) Manholes MH1A-01, MH1B-01, MH3-03 West, MH5A
The inspectors evaluated cable submergence protection in:  
-01, 02 , and 03 on February 19 and 20, 2018.
(1) Manholes MH1A-01, MH1B-01, MH3-03 West, MH5A-01, 02, and 03 on February 19
and 20, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification
Operator Requalification (1 Sample)
(1 Sample) The inspectors observed and evaluated a crew of licensed operators in the plant's simulator during licensed operator requalification training, involving a failed steam flow transmitter, trip of a running component cooling water pump, a main steam line leak
The inspectors observed and evaluated a crew of licensed operators in the plants simulator
and a steam generator tube rupture, on February 13, 2018.
during licensed operator requalification training, involving a failed steam flow transmitter, trip
Operator Performance
of a running component cooling water pump, a main steam line leak and a steam generator
(1 Sample) The inspectors
tube rupture, on February 13, 2018.
observed Control Room
Operator Performance (1 Sample)
operator performance during a lowering water level in the screen house intake on February 13, 2018, power decrease for the turbine-driven auxiliary feedwater run
The inspectors observed Control Room operator performance during a lowering water level
on March 7, 2018
in the screen house intake on February 13, 2018, power decrease for the turbine-driven
, and start up activities on March 10
auxiliary feedwater run on March 7, 2018, and start up activities on March 10 to March 13,
to March 13, 2018. 71111.12 - Maintenance Effectiveness
2018.
Routine Maintenance Effectiveness
71111.12 - Maintenance Effectiveness
(2 Samples) The inspectors evaluated
Routine Maintenance Effectiveness (2 Samples)
the effectiveness of routine
The inspectors evaluated the effectiveness of routine maintenance activities associated
maintenance activities associated with the following equipment and/or safety significant functions
with the following equipment and/or safety significant functions.
.  (1) House heating boiler
(1) House heating boiler maintenance rule (a)(1) evaluation on March 1, 2018
maintenance rule (a)(1) evaluation on March 1, 20
(2) Chemical and volume control system (charging) on March 6, 2018
(2) Chemical and volume control system (charging) on March 6, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent
(5 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities
work activities:
:  (1) Elevated risk for planned under
(1) Elevated risk for planned under-voltage testing on electrical busses 16 and 17 on
-voltage testing on electrical bus
February 1, 2018  
s es 16 and 17 on
(2) Atmospheric relief valve 3411 hand-wheel planned replacement on February 27, 2018  
February 1, 2018
(2) Atmospheric relief valve
3411 hand-wheel planned replacement on February 27, 2018


(3) 'A' residual heat removal
(3) A residual heat removal planned maintenance on March 15, 2018  
planned maintenance on March 15, 2018
(4) C safety injection pump planned maintenance on March 21 and
(4) 'C' safety injection pump planned maintenance on March 21 and
March 22, 2018
(5) A component cooling water planned maintenance on March 26, 2018
71111.15 - Operability Determinations and Functionality Assessments (4 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) A emergency diesel generator due to a ground on a lube oil heater on January 12, 2018
(2) B battery room vault water intrusion on January 31, 2018
(3) Fire suppression system S-15 alarm inputs on February 13, 2018
(4) Main steam safety valve 3512 seat leakage on February 28, 2018
71111.19 - Post Maintenance Testing (7 Samples)
The inspectors evaluated post maintenance testing for the following maintenance/repair
activities:
(1) Excess letdown divert valve AOV-312 gag installation on February 12, 2018
(2) A spent fuel pool pump check valve, CV-8655 maintenance, on February 13, 2018
(3) A spent fuel pool pump maintenance and diode replacement on February 16, 2018
(4) A flex diesel air compressor preventive maintenance on February 22, 2018
(5) D service water pump/motor replacement and maintenance on March 3, 2018
(6) A residual heat removal pump/motor alignment on March 15, 2018
(7) Technical support center ventilation fan maintenance on
March 22, 2018
March 22, 2018
(5) 'A' component cooling water
71111.20 - Refueling and Other Outage Activities (1 Sample)
planned maintenance on March 26, 2018
The inspectors evaluated forced outage activities from March 7 to March 10, 2018.
71111.15 - Operability Determinations and Functionality Assessments
71111.22 - Surveillance Testing
(4 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
  (1) 'A' emergency diesel generator due to a ground on
a lube oil heater on January 12, 2018
(2) 'B' battery room vault water
intrusion on January 31, 2018
(3) Fire suppression system S
-15 alarm inputs on February 13, 2018
(4) Main steam safety valve
351 2 seat leakage on February 28, 2018
71111.19 - Post Maintenance Testing
(7 Samples)  The inspectors evaluated
post maintenance testing for the following maintenance/repair activities
:  (1) Excess letdown divert valve AOV
-312 gag installation on February 12, 2018
(2) 'A' spent fuel pool
pump check valve, CV-8655 maintenance, on February 13, 2018
(3) 'A' spent fuel pool
pump maintenance and diode replacement on February 16, 2018
(4) 'A' flex diesel air compressor preventive maintenance on February 22, 2018
(5) 'D' service water pump/motor replacement and maintenance on March 3, 2018
(6) 'A' residual heat removal
pump/motor
alignment on March 15, 2018
(7) Technical support center
ventilation fan
maintenance
on  March 22, 2018
71111.20 - Refueling and Other Outage Activities
(1 Sample) The inspectors evaluated forced outage activities
from March 7 t o March 10, 2018
. 71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
The inspectors evaluated the following surveillance tests:
Routine (3 Samples) (1) STP-O-16QA , 'A' motor driven auxiliary feedwater
Routine (3 Samples)  
pump surveillance test
(1) STP-O-16QA, A motor driven auxiliary feedwater pump surveillance test on
on January 10, 2018 (2) STP-O-40.5 , national fire protection association
January 10, 2018  
emergency diesel generator
(2) STP-O-40.5, national fire protection association emergency diesel generator surveillance
surveillance test on February 9, 2018
test on February 9, 2018  
(3) STP-O-12.1 , 'A' emergency diesel generator
(3) STP-O-12.1, A emergency diesel generator surveillance test on February 12, 2018
surveillance test on February 12, 2018
Inservice (1 Sample)  
Inservice (1 Sample)
(1) STP-O-3QB, containment spray pump B quarterly test on March 20, 2018  
  (1) STP-O-3QB, containment spray pump 'B' quarterly test on March 20, 2018


RADIATION SAFET
RADIATION SAFETY
Y  71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
Radiological Work Planning
Radiological Work Planning (1 Sample)
(1 Sample)
The inspectors evaluated Exelons radiological work planning by reviewing the following
The inspectors evaluated Exelon's radiological work planning by reviewing the following activities
activities:
:  (1) ALARA Plan 2017
(1) ALARA Plan 2017-1009  
-1009 (2) ALARA Plan 2017
(2) ALARA Plan 2017-1018  
-1018 (3) ALARA Plan 2017
(3) ALARA Plan 2017-1036
-1036 Verification of Dose Estimates and Exposure Tracking
Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)
Systems (1 Sample)
The inspectors evaluated dose estimates and exposure tracking.
The inspectors
Implementation of ALARA and Radiological Work Controls (1 Sample)
evaluated dose estimates and
The inspectors reviewed ALARA practices and radiological work controls by reviewing the
exposure tracking
following activities:  
. Implementation of ALARA and Radiological Work Controls
(1) ALARA Plan 2017-1009  
(1 Sample)
(2) ALARA Plan 2017-1018  
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:
(3) ALARA Plan 2017-1036
  (1) ALARA Plan 2017
OTHER ACTIVITIES - BASELINE
-1009 (2) ALARA Plan 2017
71151 - Performance Indicator Verification
-1018 (3) ALARA Plan 2017
The inspectors verified Exelons performance indicator submittals listed below. (3 Samples)  
-1036 OTHER ACTIVITIES
(1) Unplanned Scrams on March 16, 2018  
- BASELINE 71151 - Performance Indicator Verification
(2) Unplanned Scrams with Complications on March 16, 2018  
The inspectors verified Exelon's performance
(3) Unplanned Power Changes Per 7000 Critical Hours on March 16, 2018
indicator submittals
71152 - Problem Identification and Resolution
listed below. (3 Sample s) (1) Unplanned Scrams on March 16, 2018
Annual Follow-up of Selected Issues (1 Sample)
(2) Unplanned Scrams with Complications
The inspectors reviewed the Exelons implementation of its corrective action program related
on March 16, 2018
to the following issues:  
(3) Unplanned
(1) Maintenance Rule availability performance criteria and reliability performance criteria
Power Changes Per 7000 Critical Hours
selection in accordance with Exelon procedure ER-AA-310-1003 Revision 5, on
on March 16, 2018 71152 - Problem Identification and Resolution
March 30, 2018. Action Request (AR) 04126470 and 02658070.
Annual Follow
 
-up of Selected Issue s (1 Sample) The inspectors reviewed the Exelon's
71153 - Follow-up of Events and Notices of Enforcement Discretion
implementation of its corrective action program related
Events (2 Samples)
to the following issues:
The inspectors evaluated response to the following events.
  (1) Maintenance Rule availability performance criteria and reliability performance criteria selection in accordance with Exelon procedure ER
(1) Reactor coolant system leak January 23 through January 27, 2018  
-AA-310-1003 Revision 5, on March 30, 2018. Action Request (AR)
(2) Forced outage March 7 to March 10, 2018
04126470 and 02658070
Licensee Event Reports (1 Sample)
.
The inspectors evaluated the following licensee event report which can be accessed at
71153 - Follow-up of Events
https://lersearch.inl.gov/LERSearchCriteria.aspx:
and Notices of Enforcement Discretion
(1) Licensee Event Report (LER) 05000244/2017-001-01, During surveillance testing, lift
Events (2 Sample s) T h e inspectors evaluated response to the following events
pressure set points on three main stream safety valves found outside Technical
.  (1) Reactor coolant system
Specifications limits on March 23, 2018. Revision 0 of this LER was previously
leak January 23
closed in Inspection Report 05000244/2017004. Revision 1 updates the LER with
through January 27, 2018 (2) Forced outage March 7 to
the results of the cause evaluation. No additional findings were identified. This LER
March 10, 2018 Licensee Event Reports (1 Sample) The inspectors evaluated the following licensee event report which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx
is closed.
:  (1) Licensee Event Report (LER) 05000244/2017-001-01, During surveillance testing, lift
Personnel Performance (1 Sample)  
pressure s et points on three main stream
(1) Unplanned plant shutdown March 8 to 9, 2018, due to a current transformer failure
safety valves found outside Technical Specifications
on the main generator outgoing power line.
limits on March 23, 2018. Revision 0 of this LER was previously closed in Inspection Report 05000244/2017004. Revision 1 updates the LER with the results of the cause evaluation.
INSPECTION RESULTS
No additional findings were identified. This LER is close d. Personnel Performance
(1 Sample)
  (1) Unplanned plant shutdown March 8
to 9, 2018, due to a current transformer failure
on the main generator outgoing power line
. INSPECTION RESULTS
Minor Violation
Minor Violation
71152 Follow
71152 Follow-up
-up of Selected Issues Minor Violation: Title 10 of the Code of Federal Regulations  
of Selected
(10 CFR) 50.65 (a)(2) allows safety system structure and components to not be monitored under 10 CFR 50 (a)(1), if an adequate demonstration that system performance is being maintained through effective maintenance is provided. In order to demonstrate this, Maintenance Rule availability performance criteria and reliability performance criteria are established and select ed in accordance with Exelon procedure ER
Issues
-AA-310-1003 , "Maintenance Rule  
Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (a)(2) allows
- Performance Criteria Selection."  Section 4.4, "Selecting Reliability Performance Criteria,"
safety system structure and components to not be monitored under 10 CFR 50 (a)(1), if an
3, "Process for Selecting Reliability Performance Criteria," contains a process to be used in which a criteria greater than or equal to two is acceptable with documentation of past performance. Contrary to the above , two maintenance rule systems contained criteria greater than or equal to two without documentation of past performance in the "Basis and Justification for Criteria Values" section of the maintenance rule basis document.
adequate demonstration that system performance is being maintained through effective
Thus, an adequate technical basis was not documented
maintenance is provided. In order to demonstrate this, Maintenance Rule availability
for a required 10
performance criteria and reliability performance criteria are established and selected in
CFR 50.65 (a)(2) performance criteria in accordance with Exelon's procedures.
accordance with Exelon procedure ER-AA-310-1003, Maintenance Rule - Performance
Screening:
Criteria Selection. Section 4.4, Selecting Reliability Performance Criteria, Attachment 3,
The inspectors independently evaluated the deficiency for significance in accordance with the guidance in IMC
Process for Selecting Reliability Performance Criteria, contains a process to be used in
0612, Appendix B, "Is
which a criteria greater than or equal to two is acceptable with documentation of past
sue Screening," issued December 31, 2017, and Appendix E, "Examples of Minor Issues," issued August 11, 2009. The inspectors determined that not documenting the past performance , which was used to determine the reliability criteria
performance. Contrary to the above, two maintenance rule systems contained criteria greater
, was a deficiency of minor significance since the criteria
than or equal to two without documentation of past performance in the Basis and Justification
selected did not require a maintenance rule a(1) evaluation. As a result it is not subject to enforcement action in accordance with the NRC's enforcement
for Criteria Values section of the maintenance rule basis document. Thus, an adequate
policy. This issue was captured in Exelon's Corrective Action Program
technical basis was not documented for a required 10 CFR 50.65 (a)(2) performance criteria
as A R 04126470 and 02658070
in accordance with Exelons procedures.
. Enforcement: This failure to comply with procedure ER
Screening: The inspectors independently evaluated the deficiency for significance in
-AA-310-1003 , Revision 5, constitutes a minor violation that is not subject to enforcement action in accordance with the NRC's Enforcement Policy.
accordance with the guidance in IMC 0612, Appendix B, Issue Screening, issued
EXIT MEETING S AND DEBRIEFS
December 31, 2017, and Appendix E, Examples of Minor Issues, issued August 11, 2009.
The inspectors verified no proprietary information was retained or documented in this report.
The inspectors determined that not documenting the past performance, which was used to
On March 22, 2018, the inspectors presented the inspection results related to IP 71124.02 to Mr. William Carsky, Site Vice President, and other members of the Ginna staff.
determine the reliability criteria, was a deficiency of minor significance since the criteria  
On April 16, 2018, the inspector
 
s presented the integrated quarterly resident inspector report inspection results to Mr. William Carsky, Site Vice President
selected did not require a maintenance rule a(1) evaluation. As a result it is not subject to
and other members of the Ginna staff.
enforcement action in accordance with the NRCs enforcement policy. This issue was
captured in Exelons Corrective Action Program as AR 04126470 and 02658070.
Enforcement: This failure to comply with procedure ER-AA-310-1003, Revision 5, constitutes
a minor violation that is 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 March 22, 2018, the inspectors presented the inspection results related to IP 71124.02
to Mr. William Carsky, Site Vice President, and other members of the Ginna staff.  
*
On April 16, 2018, the inspectors presented the integrated quarterly resident inspector
report inspection results to Mr. William Carsky, Site Vice President and other members of
the Ginna staff.  
 
DOCUMENTS REVIEWED
DOCUMENTS REVIEWED
71111.01 - Adverse Weather Protection
71111.01 - Adverse Weather Protection
Line 590: Line 670:
71111.05 - Fire Protection
71111.05 - Fire Protection
Procedures
Procedures
A-54.7, Fire Protection Tour, Revision
A-54.7, Fire Protection Tour, Revision 37
A-601.13, Fire Protection Compensatory Actions, Revision
A-601.13, Fire Protection Compensatory Actions, Revision 8
FPS-3, Fire Barrier
FPS-3, Fire Barrier Inspection Program, Revision 3
Inspection Program, Revision
71111.06 - Flood Protection Measures
71111.06 - Flood Protection Measures
Condition Reports
Condition Reports
04106112 04106114 04106123 Drawings 33013-0014, 34.5KV Duct & Control Duct Plan & Profile, Revision L
04106112
04106114
04106123
Drawings
33013-0014, 34.5KV Duct & Control Duct Plan & Profile, Revision L
Maintenance Orders/Work Orders
Maintenance Orders/Work Orders
WO C 93597827  71111.11 - Licensed Operator Requalification Program
WO C93597827
71111.11 - Licensed Operator Requalification Program
Procedures
Procedures
HU-AA-1211, Pre-Job Briefings, Revision
HU-AA-1211, Pre-Job Briefings, Revision 11
OP-AA-101-113-1006, 4.0 Crew Critique Guidelines, Revision
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 4 71111.12 - Maintenance Effectiveness
TQ-GI-150-F31 (LORT), Ginna Site Specific License Operator Requalification Training Program,
Revision 4
71111.12 - Maintenance Effectiveness
Procedures
Procedures
ER-AA-310, Implementation of the Maintenance Rule, Revision
ER-AA-310, Implementation of the Maintenance Rule, Revision 11
1 ER-AA-310-1001, Maintenance Rule  
ER-AA-310-1001, Maintenance Rule - Scoping, Revision 4
- Scoping, Revision
ER-AA-310-1002, Maintenance Rule Functions - Safety Significance Classification, Revision 3
ER-AA-310-1002, Maintenance Rule Functions  
ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5
- Safety Significance Classification, Revision
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14
ER-AA-310-1003, Maintenance Rule  
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (A)(1) and (A)(2), Revision 7
- Performance Criteria Selection, Revision 5 ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision
ER-AA-310-1005, Maintenance Rule  
- Dispositioning Between (A)(1) and (A)(2), Revision 7
Condition Reports
Condition Reports
04068393 04083945
04068393
0  71111.13 - Maintenance Risk Assessments and Emergent Work Control
04083945  
 
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Procedures
Procedures
OP-AA-102-102, General Area Checks and Operator Field Rounds, Revision 15
OP-AA-102-102, General Area Checks and Operator Field Rounds, Revision 15
OP-A A-108-117, Protected
OP-AA-108-117, Protected Equipment Program, Revision 5
Equipment Program, Revision 5
OPG-PROTECTED-EQUIPMENT, Operations Protected Equipment Program, Revision 18
OPG-PROTECTED-EQUIPMENT, Operations Protected
Equipment Program, Revision
WC-AA-101, On-Line Work Control Process, Revision 27
WC-AA-101, On-Line Work Control Process, Revision 27
WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2
WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2
WC-AA-104, Integrated Risk Management, Revision
WC-AA-104, Integrated Risk Management, Revision 25
Condition Reports
Condition Reports
04099860 71111.15 - Operability Determinations and Functionality Assessments
04099860
71111.15 - Operability Determinations and Functionality Assessments
Procedures
Procedures
A-3.3, Containment Integrity Program, Revision 27
A-3.3, Containment Integrity Program, Revision 27
OP-AA-108-115, Operability Determinations, Revision 19
OP-AA-108-115, Operability Determinations, Revision 19
Condition Reports
Condition Reports
2534565 04091493 04096584 04099235 04101267 04108798* Miscellaneous
2534565
04091493
04096584
04099235
04101267
04108798*
Miscellaneous
ECP-17-000051, Technical Evaluation of Lube Oil Heaters, Revision 0
ECP-17-000051, Technical Evaluation of Lube Oil Heaters, Revision 0
OPEVAL-15-008, 64 - 125 VDC Electrical System SR, 65  
OPEVAL-15-008, 64 - 125 VDC Electrical System SR, 65 - Diesel Generator Emergency
- Diesel Generator Emergency Power System, Revision 1
Power System, Revision 1
OPEVAL-18-001, S/G 'B' Main Steam Safety Valve 3512, Revision 1
OPEVAL-18-001, S/G B Main Steam Safety Valve 3512, Revision 1
71152 - Problem Identification and Resolution
71152 - Problem Identification and Resolution
Procedures
Procedures
ER-AA-310, Implementation of the Maintenance Rule, Revision 11
ER-AA-310, Implementation of the Maintenance Rule, Revision 11
ER-AA-310-1003, Maintenance Rule  
ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5
- Performance Criteria Selection, Revision 5
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14
ER-AA-310-1004, Maintenance Rule  
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), Revision 7
- Performance Monitoring, Revision 14
ER-AA-310-1005, Maintenance Rule  
- Dispositioning Between (a)(1) and (a)(2), Revision 7
PI-AA-120, Issue Identification and Screening Process, Revision 7
PI-AA-120, Issue Identification and Screening Process, Revision 7
PI-AA-125, Corrective Action Program (CAP) Procedure, Revision
PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 4
Condition Reports (*initiated in response to inspection)
Condition Reports (*initiated in response to inspection)
AR 02658070
AR 02658070 AR 04126470*
AR 04126470
71153 - Follow-up of Events and Notices of Enforcement Discretion
*  71153 - Follow-up of Events and Notices of Enforcement Discretion
Procedures
Procedures
A-80, Startup Readiness Control, Revision019
A-80, Startup Readiness Control, Revision019
AP-TURB.5, Rapid Load Reduction, Revision 018
AP-TURB.5, Rapid Load Reduction, Revision 018
Condition Reports
Condition Reports
04096294 04097619 Maintenance Orders/Work Orders
04096294
04097619
Maintenance Orders/Work Orders
WO C93654311
WO C93654311
}}
}}

Latest revision as of 23:03, 5 January 2025

LLC - Integrated Inspection Report 05000244/2018001
ML18122A332
Person / Time
Site: Ginna Constellation icon.png
Issue date: 05/01/2018
From: Michelle Catts
NRC Region 1
To: Bryan Hanson
Exelon Generation Co
References
IR 2018001
Download: ML18122A332 (12)
v • d • e


Text

May 1, 2018

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2018001

Dear Mr. Hanson:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC (Ginna). On April 16, 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.

The NRC inspectors did not identify any finding or violation of more than minor significance.

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 05000244/2018001

Inspection Report

Docket Number:

50-244

License Number:

DPR-18

Report Number:

05000244/2018001

Enterprise Identifier: I-2018-001-0045

Licensee:

Exelon Generation Company, LLC (Exelon)

Facility:

R.E. Ginna Nuclear Power Plant, LLC (Ginna)

Location:

Ontario, New York

Inspection Dates:

January 1, 2018 to March 31, 2018

Inspectors:

N. Perry, Senior Resident Inspector

J. Schussler, Resident Inspector

A. Rosebrook, Senior Project Engineer

H. Anagnostopoulos, Senior Health Physicist

S. Obadina, Project Engineer

Observer:

K. Warner, Health Physicist

Approved By:

M. Catts, Acting Chief

Reactor Projects Branch 1

Division of Reactor Projects

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.

No findings or more-than-minor violations were identified.

Additional Tracking Items

Type Issue number Title Report Section Status LER 05000244/2018001-00 Leakage in Reactor Coolant System Pressure Boundary N/A Open LER 05000244/2017001-01 During Surveillance Testing,

Lift Pressure Setpoints on Three Main Steam Safety Valves Found Outside Technical Specification Limits 71153

Open/Closed

PLANT STATUS

The unit began the inspection period at 100 percent power and operated at full power until March 8, 2018, when the unit was shut down to replace a faulty current transformer on the main generators output line. The unit was returned to rated power on March 13, following replacement of the current transformer, and it remained at or near 100 percent power for the remainder of the 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for predicted heavy snow accumulation on March 1, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

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

(1) C standby auxiliary feedwater on January 26, 2018
(2) Turbine-driven auxiliary feedwater on March 9, 2018
(3) B safety injection on March 22, 2018

71111.05Q - Fire Protection Quarterly

Quarterly Inspection (5 Samples)

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

(1) Compensatory measures during replacement of fire water piping in A emergency diesel generator room on January 17, 2018
(2) B battery room on February 16, 2018
(3) Intermediate building controlled side basement on March 22, 2018
(4) Intermediate building controlled side top floor on March 30, 2018
(5) Hemyc wrap on March 30, 2018

71111.06 - Flood Protection Measures

Cables (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Manholes MH1A-01, MH1B-01, MH3-03 West, MH5A-01, 02, and 03 on February 19 and 20, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated a crew of licensed operators in the plants simulator during licensed operator requalification training, involving a failed steam flow transmitter, trip of a running component cooling water pump, a main steam line leak and a steam generator tube rupture, on February 13, 2018.

Operator Performance (1 Sample)

The inspectors observed Control Room operator performance during a lowering water level in the screen house intake on February 13, 2018, power decrease for the turbine-driven auxiliary feedwater run on March 7, 2018, and start up activities on March 10 to March 13, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples)

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

(1) House heating boiler maintenance rule (a)(1) evaluation on March 1, 2018
(2) Chemical and volume control system (charging) on March 6, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

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

(1) Elevated risk for planned under-voltage testing on electrical busses 16 and 17 on February 1, 2018
(2) Atmospheric relief valve 3411 hand-wheel planned replacement on February 27, 2018
(3) A residual heat removal planned maintenance on March 15, 2018
(4) C safety injection pump planned maintenance on March 21 and March 22, 2018
(5) A component cooling water planned maintenance on March 26, 2018

71111.15 - Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) A emergency diesel generator due to a ground on a lube oil heater on January 12, 2018
(2) B battery room vault water intrusion on January 31, 2018
(3) Fire suppression system S-15 alarm inputs on February 13, 2018
(4) Main steam safety valve 3512 seat leakage on February 28, 2018

71111.19 - Post Maintenance Testing

Main article: IP 71111.19

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

(1) Excess letdown divert valve AOV-312 gag installation on February 12, 2018
(2) A spent fuel pool pump check valve, CV-8655 maintenance, on February 13, 2018
(3) A spent fuel pool pump maintenance and diode replacement on February 16, 2018
(4) A flex diesel air compressor preventive maintenance on February 22, 2018
(5) D service water pump/motor replacement and maintenance on March 3, 2018
(6) A residual heat removal pump/motor alignment on March 15, 2018
(7) Technical support center ventilation fan maintenance on March 22, 2018

71111.20 - Refueling and Other Outage Activities

Main article: IP 71111.20

The inspectors evaluated forced outage activities from March 7 to March 10, 2018.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine

Main article: IP 71111.22
(1) STP-O-16QA, A motor driven auxiliary feedwater pump surveillance test on January 10, 2018
(2) STP-O-40.5, national fire protection association emergency diesel generator surveillance test on February 9, 2018
(3) STP-O-12.1, A emergency diesel generator surveillance test on February 12, 2018

Inservice (1 Sample)

(1) STP-O-3QB, containment spray pump B quarterly test on March 20,

RADIATION SAFETY

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Radiological Work Planning (1 Sample)

The inspectors evaluated Exelons radiological work planning by reviewing the following activities:

(1) ALARA Plan 2017-1009
(2) ALARA Plan 2017-1018
(3) ALARA Plan 2017-1036

Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

Implementation of ALARA and Radiological Work Controls (1 Sample)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:

(1) ALARA Plan 2017-1009
(2) ALARA Plan 2017-1018
(3) ALARA Plan 2017-1036

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification The inspectors verified Exelons performance indicator submittals listed below.

Main article: IP 71151
(1) Unplanned Scrams on March 16, 2018
(2) Unplanned Scrams with Complications on March 16, 2018
(3) Unplanned Power Changes Per 7000 Critical Hours on March 16, 2018

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Sample)

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

(1) Maintenance Rule availability performance criteria and reliability performance criteria selection in accordance with Exelon procedure ER-AA-310-1003 Revision 5, on March 30, 2018. Action Request (AR) 04126470 and 02658070.

71153 - Follow-up of Events and Notices of Enforcement Discretion Events

Main article: IP 71153

The inspectors evaluated response to the following events.

(1) Reactor coolant system leak January 23 through January 27, 2018
(2) Forced outage March 7 to March 10, 2018

Licensee Event Reports (1 Sample)

The inspectors evaluated the following licensee event report which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000244/2017-001-01, During surveillance testing, lift pressure set points on three main stream safety valves found outside Technical Specifications limits on March 23, 2018. Revision 0 of this LER was previously closed in Inspection Report 05000244/2017004. Revision 1 updates the LER with the results of the cause evaluation. No additional findings were identified. This LER is closed.

Personnel Performance (1 Sample)

(1) Unplanned plant shutdown March 8 to 9, 2018, due to a current transformer failure on the main generator outgoing power line.

INSPECTION RESULTS

Minor Violation 71152 Follow-up of Selected Issues Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (a)(2) allows safety system structure and components to not be monitored under 10 CFR 50 (a)(1), if an adequate demonstration that system performance is being maintained through effective maintenance is provided. In order to demonstrate this, Maintenance Rule availability performance criteria and reliability performance criteria are established and selected in accordance with Exelon procedure ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection. Section 4.4, Selecting Reliability Performance Criteria, Attachment 3, Process for Selecting Reliability Performance Criteria, contains a process to be used in which a criteria greater than or equal to two is acceptable with documentation of past performance. Contrary to the above, two maintenance rule systems contained criteria greater than or equal to two without documentation of past performance in the Basis and Justification for Criteria Values section of the maintenance rule basis document. Thus, an adequate technical basis was not documented for a required 10 CFR 50.65 (a)(2) performance criteria in accordance with Exelons procedures.

Screening: The inspectors independently evaluated the deficiency for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, issued December 31, 2017, and Appendix E, Examples of Minor Issues, issued August 11, 2009.

The inspectors determined that not documenting the past performance, which was used to determine the reliability criteria, was a deficiency of minor significance since the criteria selected did not require a maintenance rule a(1) evaluation. As a result it is not subject to enforcement action in accordance with the NRCs enforcement policy. This issue was captured in Exelons Corrective Action Program as AR 04126470 and 02658070.

Enforcement:

This failure to comply with procedure ER-AA-310-1003, Revision 5, constitutes a minor violation that is 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 March 22, 2018, the inspectors presented the inspection results related to IP 71124.02 to Mr. William Carsky, Site Vice President, and other members of the Ginna staff.
  • On April 16, 2018, the inspectors presented the integrated quarterly resident inspector report inspection results to Mr. William Carsky, Site Vice President and other members of the Ginna staff.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Procedures

ER-SC.1, Adverse Weather Plan, Revision 024

71111.05 - Fire Protection

Procedures

A-54.7, Fire Protection Tour, Revision 37

A-601.13, Fire Protection Compensatory Actions, Revision 8

FPS-3, Fire Barrier Inspection Program, Revision 3

71111.06 - Flood Protection Measures

Condition Reports

04106112

04106114

04106123

Drawings

33013-0014, 34.5KV Duct & Control Duct Plan & Profile, Revision L

Maintenance Orders/Work Orders

WO C93597827

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 4

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

Condition Reports

04068393

04083945

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 18

WC-AA-101, On-Line Work Control Process, Revision 27

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

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

Condition Reports

04099860

71111.15 - Operability Determinations and Functionality Assessments

Procedures

A-3.3, Containment Integrity Program, Revision 27

OP-AA-108-115, Operability Determinations, Revision 19

Condition Reports

2534565

04091493

04096584

04099235

04101267

04108798*

Miscellaneous

ECP-17-000051, Technical Evaluation of Lube Oil Heaters, Revision 0

OPEVAL-15-008, 64 - 125 VDC Electrical System SR, 65 - Diesel Generator Emergency

Power System, Revision 1

OPEVAL-18-001, S/G B Main Steam Safety Valve 3512, Revision 1

71152 - Problem Identification and Resolution

Procedures

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

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

PI-AA-120, Issue Identification and Screening Process, Revision 7

PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 4

Condition Reports (*initiated in response to inspection)

AR 02658070 AR 04126470*

71153 - Follow-up of Events and Notices of Enforcement Discretion

Procedures

A-80, Startup Readiness Control, Revision019

AP-TURB.5, Rapid Load Reduction, Revision 018

Condition Reports

04096294

04097619

Maintenance Orders/Work Orders

WO C93654311

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., Suite 100

KING OF PRUSSIA, PENNSYLVANIA 19406-2713

May 1, 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 - INTEGRATED INSPECTION

REPORT 05000244/2018001

Dear Mr. Hanson:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at

R.E. Ginna Nuclear Power Plant, LLC (Ginna). On April 16, 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.

The NRC inspectors did not identify any finding or violation of more than minor significance.

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 05000244/2018001

cc w/encl: Distribution via ListServ

ML18122A322

SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

OFFICE

RI/DRP

RI/DRP

RI/DRP

NAME

NPerry/AR per

tele conv

ARosebrook

MCatts

DATE

05/1/18

05/1/18

05/1/18

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

50-244

License Number:

DPR-18

Report Number:

05000244/2018001

Enterprise Identifier: I-2018-001-0045

Licensee:

Exelon Generation Company, LLC (Exelon)

Facility:

R.E. Ginna Nuclear Power Plant, LLC (Ginna)

Location:

Ontario, New York

Inspection Dates:

January 1, 2018 to March 31, 2018

Inspectors:

N. Perry, Senior Resident Inspector
J. Schussler, Resident Inspector
A. Rosebrook, Senior Project Engineer
H. Anagnostopoulos, Senior Health Physicist
S. Obadina, Project Engineer

Observer:

K. Warner, Health Physicist

Approved By:

M. Catts, Acting Chief

Reactor Projects Branch 1

Division of Reactor Projects

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.

No findings or more-than-minor violations were identified.

Additional Tracking Items

Type

Issue number

Title

Report

Section

Status

LER 05000244/2018001-00

Leakage in Reactor Coolant

System Pressure Boundary

N/A

Open

LER 05000244/2017001-01

During Surveillance Testing,

Lift Pressure Setpoints on

Three Main Steam Safety

Valves Found Outside

Technical Specification

Limits

71153

Open/Closed

PLANT STATUS

The unit began the inspection period at 100 percent power and operated at full power until

March 8, 2018, when the unit was shut down to replace a faulty current transformer on the main

generators output line. The unit was returned to rated power on March 13, following

replacement of the current transformer, and it remained at or near 100 percent power for the

remainder of the 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for predicted

heavy snow accumulation on March 1, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) C standby auxiliary feedwater on January 26, 2018

(2) Turbine-driven auxiliary feedwater on March 9, 2018

(3) B safety injection on March 22, 2018

71111.05Q - Fire Protection Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Compensatory measures during replacement of fire water piping in A emergency diesel

generator room on January 17, 2018

(2) B battery room on February 16, 2018

(3) Intermediate building controlled side basement on March 22, 2018

(4) Intermediate building controlled side top floor on March 30, 2018

(5) Hemyc wrap on March 30, 2018

71111.06 - Flood Protection Measures

Cables (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Manholes MH1A-01, MH1B-01, MH3-03 West, MH5A-01, 02, and 03 on February 19

and 20, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated a crew of licensed operators in the plants simulator

during licensed operator requalification training, involving a failed steam flow transmitter, trip

of a running component cooling water pump, a main steam line leak and a steam generator

tube rupture, on February 13, 2018.

Operator Performance (1 Sample)

The inspectors observed Control Room operator performance during a lowering water level

in the screen house intake on February 13, 2018, power decrease for the turbine-driven

auxiliary feedwater run on March 7, 2018, and start up activities on March 10 to March 13,

2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions.

(1) House heating boiler maintenance rule (a)(1) evaluation on March 1, 2018

(2) Chemical and volume control system (charging) on March 6, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Elevated risk for planned under-voltage testing on electrical busses 16 and 17 on

February 1, 2018

(2) Atmospheric relief valve 3411 hand-wheel planned replacement on February 27, 2018

(3) A residual heat removal planned maintenance on March 15, 2018

(4) C safety injection pump planned maintenance on March 21 and

March 22, 2018

(5) A component cooling water planned maintenance on March 26, 2018

71111.15 - Operability Determinations and Functionality Assessments (4 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) A emergency diesel generator due to a ground on a lube oil heater on January 12, 2018

(2) B battery room vault water intrusion on January 31, 2018

(3) Fire suppression system S-15 alarm inputs on February 13, 2018

(4) Main steam safety valve 3512 seat leakage on February 28, 2018

71111.19 - Post Maintenance Testing (7 Samples)

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

activities:

(1) Excess letdown divert valve AOV-312 gag installation on February 12, 2018

(2) A spent fuel pool pump check valve, CV-8655 maintenance, on February 13, 2018

(3) A spent fuel pool pump maintenance and diode replacement on February 16, 2018

(4) A flex diesel air compressor preventive maintenance on February 22, 2018

(5) D service water pump/motor replacement and maintenance on March 3, 2018

(6) A residual heat removal pump/motor alignment on March 15, 2018

(7) Technical support center ventilation fan maintenance on

March 22, 2018

71111.20 - Refueling and Other Outage Activities (1 Sample)

The inspectors evaluated forced outage activities from March 7 to March 10, 2018.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (3 Samples)

(1) STP-O-16QA, A motor driven auxiliary feedwater pump surveillance test on

January 10, 2018

(2) STP-O-40.5, national fire protection association emergency diesel generator surveillance

test on February 9, 2018

(3) STP-O-12.1, A emergency diesel generator surveillance test on February 12, 2018

Inservice (1 Sample)

(1) STP-O-3QB, containment spray pump B quarterly test on March 20, 2018

RADIATION SAFETY

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Radiological Work Planning (1 Sample)

The inspectors evaluated Exelons radiological work planning by reviewing the following

activities:

(1) ALARA Plan 2017-1009

(2) ALARA Plan 2017-1018

(3) ALARA Plan 2017-1036

Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

Implementation of ALARA and Radiological Work Controls (1 Sample)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the

following activities:

(1) ALARA Plan 2017-1009

(2) ALARA Plan 2017-1018

(3) ALARA Plan 2017-1036

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified Exelons performance indicator submittals listed below. (3 Samples)

(1) Unplanned Scrams on March 16, 2018

(2) Unplanned Scrams with Complications on March 16, 2018

(3) Unplanned Power Changes Per 7000 Critical Hours on March 16, 2018

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the Exelons implementation of its corrective action program related

to the following issues:

(1) Maintenance Rule availability performance criteria and reliability performance criteria

selection in accordance with Exelon procedure ER-AA-310-1003 Revision 5, on

March 30, 2018. Action Request (AR) 04126470 and 02658070.

71153 - Follow-up of Events and Notices of Enforcement Discretion

Events (2 Samples)

The inspectors evaluated response to the following events.

(1) Reactor coolant system leak January 23 through January 27, 2018

(2) Forced outage March 7 to March 10, 2018

Licensee Event Reports (1 Sample)

The inspectors evaluated the following licensee event report which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000244/2017-001-01, During surveillance testing, lift

pressure set points on three main stream safety valves found outside Technical

Specifications limits on March 23, 2018. Revision 0 of this LER was previously

closed in Inspection Report 05000244/2017004. Revision 1 updates the LER with

the results of the cause evaluation. No additional findings were identified. This LER

is closed.

Personnel Performance (1 Sample)

(1) Unplanned plant shutdown March 8 to 9, 2018, due to a current transformer failure

on the main generator outgoing power line.

INSPECTION RESULTS

Minor Violation

71152 Follow-up

of Selected

Issues

Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (a)(2) allows

safety system structure and components to not be monitored under 10 CFR 50 (a)(1), if an

adequate demonstration that system performance is being maintained through effective

maintenance is provided. In order to demonstrate this, Maintenance Rule availability

performance criteria and reliability performance criteria are established and selected in

accordance with Exelon procedure ER-AA-310-1003, Maintenance Rule - Performance

Criteria Selection. Section 4.4, Selecting Reliability Performance Criteria, Attachment 3,

Process for Selecting Reliability Performance Criteria, contains a process to be used in

which a criteria greater than or equal to two is acceptable with documentation of past

performance. Contrary to the above, two maintenance rule systems contained criteria greater

than or equal to two without documentation of past performance in the Basis and Justification

for Criteria Values section of the maintenance rule basis document. Thus, an adequate

technical basis was not documented for a required 10 CFR 50.65 (a)(2) performance criteria

in accordance with Exelons procedures.

Screening: The inspectors independently evaluated the deficiency for significance in

accordance with the guidance in IMC 0612, Appendix B, Issue Screening, issued

December 31, 2017, and Appendix E, Examples of Minor Issues, issued August 11, 2009.

The inspectors determined that not documenting the past performance, which was used to

determine the reliability criteria, was a deficiency of minor significance since the criteria

selected did not require a maintenance rule a(1) evaluation. As a result it is not subject to

enforcement action in accordance with the NRCs enforcement policy. This issue was

captured in Exelons Corrective Action Program as AR 04126470 and 02658070.

Enforcement: This failure to comply with procedure ER-AA-310-1003, Revision 5, constitutes

a minor violation that is 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 March 22, 2018, the inspectors presented the inspection results related to IP 71124.02

to Mr. William Carsky, Site Vice President, and other members of the Ginna staff.

On April 16, 2018, the inspectors presented the integrated quarterly resident inspector

report inspection results to Mr. William Carsky, Site Vice President and other members of

the Ginna staff.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Procedures

ER-SC.1, Adverse Weather Plan, Revision 024

71111.05 - Fire Protection

Procedures

A-54.7, Fire Protection Tour, Revision 37

A-601.13, Fire Protection Compensatory Actions, Revision 8

FPS-3, Fire Barrier Inspection Program, Revision 3

71111.06 - Flood Protection Measures

Condition Reports

04106112

04106114

04106123

Drawings

33013-0014, 34.5KV Duct & Control Duct Plan & Profile, Revision L

Maintenance Orders/Work Orders

WO C93597827

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 4

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

Condition Reports

04068393

04083945

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 18

WC-AA-101, On-Line Work Control Process, Revision 27

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

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

Condition Reports

04099860

71111.15 - Operability Determinations and Functionality Assessments

Procedures

A-3.3, Containment Integrity Program, Revision 27

OP-AA-108-115, Operability Determinations, Revision 19

Condition Reports

2534565

04091493

04096584

04099235

04101267

04108798*

Miscellaneous

ECP-17-000051, Technical Evaluation of Lube Oil Heaters, Revision 0

OPEVAL-15-008, 64 - 125 VDC Electrical System SR, 65 - Diesel Generator Emergency

Power System, Revision 1

OPEVAL-18-001, S/G B Main Steam Safety Valve 3512, Revision 1

71152 - Problem Identification and Resolution

Procedures

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

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

PI-AA-120, Issue Identification and Screening Process, Revision 7

PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 4

Condition Reports (*initiated in response to inspection)

AR 02658070 AR 04126470*

71153 - Follow-up of Events and Notices of Enforcement Discretion

Procedures

A-80, Startup Readiness Control, Revision019

AP-TURB.5, Rapid Load Reduction, Revision 018

Condition Reports

04096294

04097619

Maintenance Orders/Work Orders

WO C93654311

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