IR 05000220/2016007

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NRC Evaluation of Changes, Tests and Experiments and Permanent Modifications Team Inspection Report 05000220/2016007 and 05000410/2016007
ML16320A096
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 11/10/2016
From: Christopher Cahill
Engineering Region 1 Branch 2
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2016007
Download: ML16320A096 (25)


Text

ber 10, 2016

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC EVALUATION OF CHANGES, TESTS AND EXPERIMENTS AND PERMANENT MODIFICATIONS TEAM INSPECTION REPORT 05000220/2016007 AND 05000410/2016007

Dear Mr. Hanson:

On October 12, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Nine Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2. On October 12, 2016, the NRC inspectors discussed the results of this inspection with Mr. A. Sterio, Site Engineering Director, 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 at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Christopher G. Cahill, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-220 and 50-410 License Nos.: DRP-63 and NPF-69

Enclosure:

Inspection Report 05000220/2016007 and 05000410/2016007 w/Attachment: Supplemental Information

REGION I==

Docket Nos. 50-220, 50-410 License Nos.: DPR-63, NPF-69 Report Nos. 05000220/2016007 and 05000410/2016007 Licensee: Nine Mile Point Nuclear Station, LLC (NMPNS)

Facility: Nine Mile Point, Units 1 and 2 Location: Oswego, New York Inspection Period: September 12, 2016 through October 12, 2016 Inspectors: J. Ayala, Reactor Inspector, Division of Reactor Safety (DRS)

Team Leader E. DiPaolo, Senior Reactor Inspector, DRS K. Mangan, Senior Reactor Inspector, DRS J. Schoppy, Senior Reactor Inspector, DRS Approved By: Christopher G. Cahill, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

IR 05000220/2016007, 05000410/2016007; 09/12/2016-10/12/2016; Nine Mile Point Nuclear

Station, Units 1 and 2; Permanent Plant Modifications Engineering Team Inspection.

This report covers a 2 week on-site inspection period of the evaluations of changes, tests, or experiments and permanent plant modifications. The inspection was conducted by four region based engineering inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6, dated July 2016.

No findings were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

(IP 71111.17)

.1 Evaluations of Changes, Tests, or Experiments (32 samples)

a. Inspection Scope

The team reviewed eight safety evaluations to determine whether the changes to the facility or procedures, as described in the Updated Final Safety Analysis Report (UFSAR), had been reviewed and documented in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.59 requirements. In addition, the team evaluated whether Exelon had been required to obtain NRC approval prior to implementing the changes. The team interviewed plant staff and reviewed supporting information including calculations, analyses, design change documentation, procedures, the UFSAR, the Technical Specifications (TSs), and plant drawings, to assess the adequacy of the safety evaluations. The team compared the safety evaluations and supporting documents to the guidance and methods provided in Nuclear Energy Institute (NEI)96-07, Guidelines for 10 CFR 50.59 Evaluations, as endorsed by NRC Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," to determine the adequacy of the safety evaluations.

The team also reviewed a sample of twenty-four 10 CFR 50.59 screenings and applicability determinations for which Exelon had concluded that no safety evaluation was required. These reviews were performed to assess whether Exelons threshold for performing safety evaluations was consistent with 10 CFR 50.59. The sample included design changes, calculations, procedure changes, and setpoint changes. The screenings and applicability determinations were selected based on the safety significance, risk significance, and complexity of the change to the facility.

In addition, the team compared Exelons administrative procedures used to control the screening, preparation, review, and approval of safety evaluations to the guidance in NEI 96-07 to determine whether those procedures adequately implemented the requirements of 10 CFR 50.59. The reviewed safety evaluations, screenings, and applicability determinations are listed in the Attachment.

b. Findings

No findings were identified.

.2 Permanent Plant Modifications (15 samples)

.2.1 ECP14-00915, Unit 2 Division 2 Emergency Diesel Generator Fuel Oil Piping Rerouting

a. Inspection Scope

The team reviewed engineering change package (ECP) 14-00915 that replaced and rerouted the fuel oil piping from the motor-driven fuel oil booster pump (2EGF*P4) to the shaft-driven fuel oil pump (2EGS*EG3) on the Unit 2 Division 2 emergency diesel generator (EDG). Exelon replaced and rerouted the original vendor-supplied piping to address minor fuel oil leakage and improve system reliability. The ECP also included the installation of three new piping supports.

The team reviewed the modification to verify that the design bases, licensing bases, and structural integrity of the EDG fuel oil piping and supports had not been adversely impacted by the modification. The team interviewed engineering staff and reviewed technical evaluations (including piping stress analyses) associated with the modification to determine if the Unit 2 Division 2 EDG would function in accordance with the design assumptions. The team compared installation drawings and plans to the as-built configuration to determine if Exelon appropriately implemented the modification as designed. The team performed several walkdowns of the Unit 2 Division 2 EDG and accessible fuel oil piping to independently assess Exelons configuration control, the operating environment, and the material condition of the associated structures, systems, and components (SSCs). The team reviewed the system health report and recent surveillance test results to verify that the Unit 2 Division 2 EDG functioned as designed following the modification. The team also reviewed corrective action issue reports (IRs)to determine if there were reliability or performance issues that may have resulted from the modification. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.2 ECP-14-000852, Increase Thermal Breaker Size on Core Spray Valves

a. Inspection Scope

The team reviewed modification ECP-14-000852 that replaced 600 Volt (V) breakers for core spray (CS) injection valves. Exelon performed the modification to increase the breaker size to allow throttling/jogging of CS valves without challenging the protective devices. The CS system provides emergency core cooling in the event of a loss of coolant accident. The valves are required to close as required for containment isolation, and open and be capable of throttling as directed by the emergency operating procedures. Exelon evaluated the seismic and environmental qualifications (EQ) of the breaker to verify adequate margin existed for design basis events.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the CS valves had not been adversely impacted by the modification of the breakers. The team interviewed design and EQ engineers and reviewed coordination curves and vendor specifications to determine if the new breakers met design requirements. Finally, the team performed a walkdown of the breakers to determine if the modification was installed in accordance with the design, and to assess the overall material conditions of the breakers following the modification work. The 10 CFR 50.59 screening determination performed for this modification, was also reviewed as described in Section 1R17.1 of this report. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.3 ECP-14-000679, Liquid Poison Relief Valve Replacement

a. Inspection Scope

The team reviewed modification ECP-14-000679 that replaced the relief valves on each train of the liquid poison system. The relief valves provide over pressure protection for the liquid poison system discharge piping. Exelon performed the modification to provide additional valve liquid relief capacity. The modification was performed as a corrective action to address an NRC identified issue which determined that, due to an upgrade to the liquid poison system positive displacement pumps, the previously installed valves liquid relief capability were not adequate to ensure piping design pressure would not be exceeded. Exelon performed pre-installation testing on the valves to ensure the valves met lifting pressure requirements and performed post-installation testing to verify the valves were properly installed.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the valve and associated liquid poison pumps had not been adversely impacted by the modifications. The team interviewed design engineers and reviewed design drawings, calculations, and vendor specifications to determine if the valves met the design and licensing requirements of the system. Additionally, the team reviewed post maintenance testing (PMT) results, associated maintenance work orders and lift check procedures to determine if the changes were appropriately implemented.

Finally, the team performed a walkdown of the valves to determine if the modification was installed in accordance with the design, and to assess the overall material conditions of the systems following the modification work. The 10 CFR 50.59 screening determination performed for this modification, was also reviewed as described in Section 1R17.1 of this report. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.4 ECP-13-00418, Unit 1 Emergency Service Water Pump Shaft Coupling Modification

a. Inspection Scope

The team reviewed ECP-13-00418 that modified the shaft coupling on the No. 11 emergency service water (ESW) pump. Specifically, following reassembly of the pump shaft motor couplings during a planned pump refurbishment, which included installing a new pump motor and couplings, Exelon technicians identified that the gap between the motor and pump couplings exceeded the required tolerance. Engineering designed and maintenance installed a spacer between the motor shaft coupling and pump shaft coupling in order to satisfy the required gap tolerance between the couplings.

The team reviewed the modification to verify that the design bases, licensing bases, and performance capability of the ESW system had not been adversely impacted by the modification. The team interviewed engineering staff and reviewed technical evaluations associated with the modification to determine if the ESW pump would function in accordance with the design assumptions. The team also performed several walkdowns of the ESW pump to independently assess Exelons configuration control, the operating environment, and the material condition of the ESW pump and support systems. The team also reviewed completed surveillances, corrective action IRs, and the ESW system health report to determine if there were reliability or performance issues that may have resulted from the modification. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.5 ECP-16-000294, Unit 2 Reactor Building Polar Crane Weigh System Bypass Switch and

ECP-14-000812, Reactor Building Polar Crane Upgrade (2 samples)

a. Inspection Scope

The team reviewed modification ECP-16-000294 that replaced the Unit 2 Reactor Building Polar Crane (RBPC) weigh system spring-return bypass switch with a key-lock switch. The RBPC weigh system provides a function to prevent lifting the main hoist in the event of an overload condition. During the spring 2016 refueling outage, several invalid overweight and underweight faults were experienced during crane operation due to the weigh systems load cell malfunctioning. Replacing the spring-return momentary bypass switch with a key-lock switch reduced the burden on the crane operator when false conditions were encountered.

The team reviewed the modification to verify that the design bases, licensing bases, and performance capability of the RBPC had not been adversely impacted by the modification. The team interviewed engineering staff and reviewed technical evaluations associated with the modification to determine if the RBPC would function in accordance with the design assumptions and that the crane remained single-failure-proof in accordance per NUREG-0544, Single-Failure-Proof Cranes for Nuclear Power Plants, per licensing commitments.

The team reviewed ECP-14-000812, Reactor Building Polar Crane Upgrade, which replaced the RBPC motors and controls with a new system. The team verified that the weigh system was not the primary means of providing overload protection for the crane.

Instead, new controls and protective features associated with the variable frequency drives for the main hoist motors were relied upon for overload protection. The team also reviewed the procedural controls associated with bypassing RBPC interlocks and protective features to verify that the controls satisfied licensing commitments documented in the UFSAR. Corrective action IRs were also reviewed to verify that Exelon had properly addressed the issues associated with the malfunctioning crane load cell experienced during the refueling outage. The team verified that the controls and features associated with RBPC overload protection were tested during acceptance testing of ECP-14-000812. The team also verified that the licensee had evaluated NEI 08-05, Industry Initiative on Control of Heavy Loads, and Regulatory Issues Summary (RIS) 2008-28, Endorsement of NEI Guidance for Reactor Vessel Heavy Load Lifts, for applicability on Units 1 and 2. The documents reviewed are listed in the

.

b. Findings

No findings were identified.

.2.6 ECP-14-000823, HVP DIV III Exhaust Fan Circuit Modification

a. Inspection Scope

The team reviewed modification ECP-14-000823 that installed a jumper around the set of control switch contacts for the EDG room exhaust fans. The EDG ventilation system provides temperature control and ventilation for the EDG rooms and EDG control rooms.

The ventilation system is required to maintain air temperature below the maximum design temperature of 125°F. Exelon performed the design change because the fans could not be operated manually above 77°F to cool the room without declaring the associated EDG inoperable due to contacts in series that would remain open when the switch was in the normal after start position. If a loss of the bus were to occur, the associated exhaust fan would not re-start when the diesel generator restored power to the bus. The jumper, around the set of control switch contacts that prevent the fan from auto starting, would remain closed with the switch in normal after start and normal after stop; allowing the fan to auto start after a power loss.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the EDG exhaust fans had been degraded by the jumper of the control circuit. The team interviewed design engineers and reviewed logic diagrams to determine if the EDG circuit met design requirements. The 10 CFR 50.59 screening determination performed for this modification, was also reviewed as described in Section 1R17.1 of this report. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.7 ECP-13-00781, Unit 2 Service Water Pump Rebuild and Material Changes

a. Inspection Scope

The team reviewed ECP-13-00781 that modified the materials used during the refurbishment of a Unit 2 safety-related service water (SW) pump (S/N 12386).

Specifically, the material changes were limited to the set screw used to lock the sleeve nut which in turn locks the shaft sleeve that provides the running surface for the pump packing, and the sleeve nut elastomeric insert that seals the sleeve nut to the pump shaft to prevent process fluid leakage from under the shaft sleeve and sleeve nut. At the time of the inspection, the modified SW pump was installed on the E SW pump (2SWP*P1E); however, Exelon could install it in any of the six Unit 2 SW pump locations.

The team reviewed the modification to verify that the design bases, licensing bases, and performance capability of the SW system had not been adversely impacted by the modification. The team interviewed engineering staff and reviewed technical evaluations associated with the modification to determine if the SW pump would function in accordance with the design assumptions. The team also performed several walkdowns of the SW pump to independently assess Exelons configuration control, the operating environment, and the material condition of the SW pump and support systems. The team also reviewed completed surveillances, corrective action IRs, and the SW system health report to determine if there were reliability or performance issues that may have resulted from the modification. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.8 ECP-14-000581, Material Change for Disc Spring on NMP1 Electronic Relief Valves

a. Inspection Scope

The team reviewed modification ECP-14-000581 that replaced the main spring in the electronic relief valves (ERV). Exelon replaced the original spring, made of Inconel X-750, with a similar style spring made of Inconel X-718. As part of the modification Exelon verified the spring coefficient was the same as the original spring, the physical dimensions of the two springs were the same, and the valve operated at the pressures required in the licensing basis following completion of the modification. Exelon performed the modification to improve the material characteristics of the spring.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the relief valve had not been adversely impacted by the modification. The team interviewed design engineers and reviewed design drawings, vendor documentation, and calculations to determine if the spring met the design and licensing requirements of the system. Additionally, the team reviewed PMT results and associated maintenance work orders to determine if the changes were appropriately implemented and the valve lift point and post maintenance leakage were within the required American Society of Mechanical Engineers (ASME) code and licensing specification. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.9 ECP-16-000339, Replace the Unit 1 Emergency Diesel Generator 102 and EDG 103

Timing Relays

a. Inspection Scope

The team reviewed modification ECP-16-000339 that was planned to replace relays in Unit 1s EDG 102 and EDG 103 automatic starting system. The replacement relays were Allen Bradley Relay Model 700RTC and were the subject of several 10 CFR Part 21 Notifications (2015-26-00, 2015-33-00, and 2015-36-00). The Notifications were written because, between 2009 and 2010, the manufacturer made an unpublished design change that replaced the relays solid state circuitry with a digital complex programmable logic device. Because the manufacturer did not change the part number, the relay had not been evaluated and tested as a digital device in accordance with industry guidelines for safety-related use. This same model relay had already been installed in the Unit 1 automatic depressurization system circuitry and in the emergency condenser initiation circuitry.

The team reviewed the modification to verify that the design bases, licensing bases, and performance capability of the systems with the relays installed or planned to be installed had not been or would not be degraded by the modification. The team interviewed design engineers, and reviewed evaluation and the commercial grade dedication verification and validation report which qualified the relay for safety-related use. The team reviewed the licensees evaluation the 10 CFR Part 21 Notifications to verify the licensee appropriately addressed the operating experience. The inspectors reviewed post modification test plans and test results to verify that the new relays functioned properly following installation. The team also reviewed corrective action IRs to determine if there were reliability or performance issues that may have resulted from the modification. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.10 ECR-15-00047, Reactor Building Closed-Loop Cooling Water System Containment

Isolation Logic Modification

a. Inspection Scope

The team reviewed ECR-15-00047 that install key-lock bypass selector switch for the Reactor Building Closed-Loop Cooling Water (CCP) system containment isolation valve circuits associated with reactor recirculation pump cooling. Exelon implemented the modification to eliminate a single-point vulnerability for the reliable operation of the system. Specifically, failure of one primary containment isolation valve circuit relay causes the closure of either an inboard or outboard CCP containment isolation valve.

This results in a loss of cooling water to the reactor recirculation pumps (i.e., pump seal coolers, motor winding coolers, and motor bearing coolers). Operators would then be required to take prompt action to secure the reactor recirculation pumps and cause a plant transient (e.g., reactor shutdown or unplanned reactor scram). The installation of the switches would allow operators to bypass the Primary Containment Isolation system closure signal to the effected CCP valves when a when a valid isolation signal does not exist or the isolation logic power source is lost. This would allow operators to re-open the valves to restore cooling water flow to the reactor recirculation pumps to avoid a potential unnecessary plant transient.

The team reviewed the modification to verify that the design bases, licensing bases and performance capability of the CCP and the Primary Containment Isolation systems had not been adversely impacted by the modification. The team interviewed design engineers, and reviewed evaluations, surveillance results, and associated maintenance work orders to verify that Exelon implemented the modification in accordance with design assumptions. The team verified that administrative controls on the bypass switches were established to ensure the switches would only be used to restore the ability to open the containment isolation valves during an invalid primary containment isolation. The team reviewed the modification to verify that Control Room indication satisfied the guidance in Regulatory Guide 1.47, Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems. The team also verified that divisional separation of the newly installed switches and associated wiring was maintained. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.11 ECP-13-000524, Separation of the Unit 2 Instrument Air Supply to the Main Steam

Safety Relief Valves and the Main Steam Isolation Valves

a. Inspection Scope

The team reviewed modification ECP-13-000524 that installed piping and isolation valves in order to separate portions of the safety-related air systems. Exelon rerouted the instrument air system (IAS) supply header for the NMP2 inboard main steam isolation valves (MSIV) so that this header can be isolated separately from the IAS supply header for the safety relief valves (SRV). The new header which included a new isolation valve was connected at a separate location on the common supply header.

Additionally, a normally closed test tap off line on the SRV supply header which included a valve and plug were also installed. The new piping and valves were installed on existing pipe supports and/or the structural steel in the drywell. Exelon evaluated the seismic qualifications of the piping and associated supports to verify adequate structural margin existed for design basis seismic events.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the air systems, SRVs, or MSIVs had not been adversely impacted by the modification. The team interviewed design engineers and reviewed design drawings and calculations to determine if the new piping and valves met design and licensing requirements. Additionally, the team reviewed PMT results and associated maintenance work orders to determine if the modification was appropriately implemented. Finally, the team reviewed the implementing procedures and associated drawings to determine if they had been appropriately updated to reflect the new configuration. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.12 ECP-16-000278, Revise Unit 2 Degraded Grid, Undervoltage, and Time Delay Relay

Calibration Frequency for Emergency Switchgears 2ENS*SWG101, 2ENS*SWG102, and 2ENS*SWG103

a. Inspection Scope

The team reviewed modification ECP-16-000278 that changed the calibration frequency for the Unit 2 degraded grid, undervoltage, and time delay relay for the safety-related emergency switchgears from 24 months to 48 months. The relays function to detect loss of or degraded electrical grid voltage and initiate signals to the 4160-Volt Load Sequencing Logic used during both loss of coolant accident and loss of offsite power events as well as loss of offsite power only scenarios. The calibration frequency change was made in order to better coordinate electrical divisional outages. The team utilized the guidance in Appendix A, Risk Management Technical Specifications Initiative 5b Surveillance Frequency Control Program, of Inspection Procedure 71111, 22, Surveillance Testing, as a guide during the review of the change.

The team reviewed the modification to verify that the requirements of TS 5.5.14, Surveillance Frequency Control Program, and that the guidance in NEI 04-10, Risk-Informed Method for Control of Surveillance Frequency, were satisfied. The team reviewed the design base, the licensing bases, and design calculations to verify the relays had not been degraded by the modification. In particular, the team reviewed EC-196, Degraded Grid Relay, Undervoltage Relay, and Associated Timer Relay Setpoint Calculation, to verify that there was adequate margin available to account for setpoint drift due to the extended calibration interval. The team also reviewed calibration test history of the relays to determine whether reliability or performance issues with the relays prior to implementing the modification. The documents reviewed are listed in the

.

b. Findings

No findings were identified.

.2.13 ECP-13-000103, 2SWP*FS146A & 2SWP*FS146B - EQV - Magnetic Yokogawa Flow

Switch

a. Inspection Scope

The team reviewed modification ECP-13-000103 that replaced the flow switch in the service water effluence cabinets 2SWP*CAB146A and 2SWP*CAB146B. The flow switches monitor for low and high flow rates supplied to the radiation detectors in the effluence cabinets. Exelon replaced the original low power heater probe based switches with a magnetic based Yokogawa switches. Exelon performed the modification to retain calibration and improve operation of the flow switches as a result of biological and/or corrosion buildup on the old heater probe based switches. The replacement flow switches are flanged connection that consist of a Teflon inner lining to minimize coating buildup and do not require a probe to be placed in the into the flow stream.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the flow switches and associated radiation monitors had not been adversely impacted by the modification. The team interviewed design engineers and reviewed design drawings, calculations, and vendor specifications to determine if the valves met the design and licensing requirements of the system. Finally, the team performed a walkdown of the switches and recorders to determine if the modification was installed in accordance with the design, and to assess the overall material conditions of the systems following the modification work. The 10 CFR 50.59 screening determination performed for this modification, was also reviewed as described in Section 1R17.1 of this report. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.14 ECP 14-00584, Unit 1 Emergency Diesel Generator No. 102 Copper Tubing

Replacement

a. Inspection Scope

The team reviewed ECP 14-00584 that replaced copper tubing with American Society for Testing and Materials (ASTM) A213 stainless steel tubing on several skid-mounted EDG 102 support systems. In 2014, Exelon identified copper instrument tubing on the Unit 2 EDGs that over time could potentially fail due to engine vibration and poor support (CR-2014-0422). Exelon performed an extent-of-condition walkdown and also identified similar copper instrument tubing on the Unit 1 EDGs. This ECP proactively replaced the following copper tubing on EDG 102:

(1) a 1/2 lube oil line,
(2) a 3/8 air starter line,
(3) a 5/8 turbocharger oil separator line, and
(4) a 5/8 cooling water line.

The team reviewed the modification to verify that the design bases, licensing bases, and structural integrity of the EDG support system piping had not been adversely impacted by the modification. The team interviewed engineering staff and reviewed technical evaluations associated with the modification to determine if EDG 102 would function in accordance with the design assumptions. The team compared installation plans to the as-built configuration to determine if Exelon appropriately implemented the modification as designed. The team performed several walkdowns of EDG 102 and its support system piping to independently assess Exelons configuration control, the operating environment, and the material condition of the associated SSCs. The team also reviewed completed surveillances, corrective action IRs, and the EDG system health report to determine if there were reliability or performance issues that may have resulted from the modification. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems (IP 71152)

The team reviewed a sample of problems that Exelon had previously identified and entered into the corrective action program. The team reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions. In addition, the team reviewed corrective action IRs written on issues identified during the inspection to verify adequate problem identification and incorporation of the problem into the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the

.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (IP 71153)

.1 Plant Events

a. Inspection Scope

The team reviewed Exelons response to a Unit 1 fault in the in-service 11 Reactor Protective System Ultimate Power Supply that resulted in an isolation of both emergency condensers. The inspectors performed a review of Event Notification 52133 as directed by the NRCs review of the event details with criteria contained in Inspection Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors.

The team reviewed the emergency condensers Agastat time-delay relay preventive maintenance program. The team reviewed the adequacy of the relay replacement PM.

The relays were on a 10-year replacement frequency that has been adjusted to a 2-year replacement frequency due to problems with the relays. Specifically, quarterly testing of the relays has identified several relays with set-point drift. The team interviewed engineers and reviewed condition reports, maintenance work orders and vendor specifications. The team also observed quarterly surveillance testing of the Agastat relays.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

The team presented the preliminary inspections results to Mr. R. Kreider, Plant Manager, and other members of Exelons staff at a debrief on September 30, 2016. The team also presented the inspection results to Mr. A. Sterio, Site Engineering Director, and other members of Exelons staff at an exit meeting on October 12, 2016. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Exelon Personnel

R. Kreider, Plant Manager
P. Bartolini, Supervisor, Design Engineering
D. Blocher, Design Engineering (Mechanical)
D. Bradshaw, System Manager
R. Close, Senior Staff Engineer, Fuels
P. Doran, Electrical and I&C Design Manager
R. Franklin, Mechanical Design Engineer
R. Glerum, System Manager
S. Homoki, EDG System Manager
G. Inch, Senior Mechanical Design Engineer
P. Martini, Design Engineering
J. Massari, Manager of Engineering Safety Analysis
D. Pokon, Design Engineer
J. Rossman, Electrical I&C Design
F. Sgroi, Design Engineering
J. Shaver, Design Engineering
A. Sterio, Director, Site Engineering
N. Tryt, Design Rapid Response Manager

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED