IR 05000244/2014002

IR 05000244-14-002; 01/01/2014 - 03/31/2014; R.E. Ginna Nuclear Power Plant, LLC (Ginna); Maintenance Effectiveness; Operability Determinations and Functionality Assessments; Drill Evaluation; Follow-Up of Events and Notices of Enforcement

ML14118A115
Person / Time
Site:	Ginna
Issue date:	04/25/2014
From:	Daniel Schroeder Reactor Projects Branch 1
To:	Joseph Pacher Exelon Generation Co, Ginna
Schroeder D
References
IR 14-002
Download: ML14118A115 (43)

Text

April 25, 2014

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - NRC INTEGRATED INSPECTION REPORT 05000244/2014002

Dear Mr. Pacher:

On March 31, 2014, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your R.E. Ginna Nuclear Power Plant, LLC (Ginna). The enclosed inspection report documents the inspection results which were discussed on April 16, 2014, with Mr. Michel Philippon, Plant General Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. On April 1, 2014, the operating license for Ginna held by the Constellation Energy Nuclear Group, LLC (CENG) was transferred to Exelon Generation Company, LLC.

This report documents two NRC-identified findings and two self-revealing findings; all of which were determined to be of very low safety significance (Green). Three of these findings were also determined to be violations of NRC requirements. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at Ginna. In addition, if you disagree with a cross-cutting aspect, or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC resident inspector at Ginna.

Additionally, as we informed you in the most recent NRC annual assessment letter, cross-cutting aspects identified in the last 6 months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter (IMC) 0310, Aspects Within the Cross-Cutting Areas. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. If you disagree with the cross-cutting aspect assigned, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC resident inspector at Ginna.

In accordance with Title 10 of the Code of Federal Regulations 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects

Docket No.

50-244 License No.

DPR-18

Enclosure:

Inspection Report 05000244/2014002

w/Attachment: Supplementary Information

REGION I==

Docket No.

50-244

License No.

DPR-18

Report No.

05000244/2014002

Licensee:

Constellation Energy Nuclear Group, LLC

Facility:

R.E. Ginna Nuclear Power Plant, LLC

Location:

Ontario, NY

Dates:

January 1, 2014 through March 31, 2014

Inspectors:

N. Perry, Senior Resident Inspector

D. Dodson, Resident Inspector

H. Anagnostopoulos, Health Physicist

E. Burket, Emergency Preparedness Inspector

S. Horvitz, Reactor Engineer

P. Kaufman, Senior Reactor Inspector

M. Orr, Reactor Inspector

D. Silk, Senior Operations Engineer

Approved by:

Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects

Enclosure

SUMMARY

IR 05000244/2014002; 01/01/2014 - 03/31/2014; R.E. Ginna Nuclear Power Plant, LLC (Ginna); Maintenance Effectiveness; Operability Determinations and Functionality Assessments;

Drill Evaluation; Follow-Up of Events and Notices of Enforcement Discretion.

This report covered a 3-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified two Green non-cited violations (NCVs). Two self-revealing Green findings, one which was an NCV, were also identified. A findings significance is indicated by a color (i.e., greater than Green, or Green,

White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, issued December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Initiating Events

Green.

A self-revealing Green finding (FIN) was identified because Constellation Energy Nuclear Group, LLC (CENG) failed to authorize the application of a tagout in accordance with procedure CNG-OP-1.01-1007, Clearance and Safety Tagging, Revision 01101.

Specifically, CENG did not adequately implement equipment tagging procedural requirements to verify plant effects and tagout boundary impact prior to removing the specified equipment from service. As a result, two air operated valves (AOVs) unexpectedly opened when a tagout was being hung and resulted in a trip of all running condensate booster pumps on low suction pressure and a plant transient.

The inspectors determined that the failure to follow procedural requirements was more than minor because it was associated with the configuration control attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, CENG did not follow procedural guidance when reviewing the tagout to ensure that the consequences of removing the specified equipment from service had been evaluated from the perspective of plant effects and tagout boundary impacts. This resulted in a plant transient as operators rapidly reduced plant power in order to avoid a more significant plant transient. Additionally, the finding is similar to IMC 0612,

Appendix EProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0612,</br></br>Appendix E" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Examples of Minor Issues, Example 4.b., in that a personnel error caused a plant transient. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, worksheet to IMC 0609, Significance Determination Process.

The attachment instructed the inspectors to utilize IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The inspectors determined the performance deficiency to be of very low safety significance (Green), because it did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because CENG individuals did not recognize and plan for the possibility of mistakes, even while expecting successful outcomes [H.12]. (Section 4OA3)

Cornerstone: Mitigating Systems

Green.

A self-revealing Green NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for failure to modify an existing preventive maintenance (PM) task or schedule in accordance with CENG procedure CNG-AM-1.01-1018, Preventive Maintenance Program, Revision 00801. Specifically, CENG did not revise the PM for the B service water pump (SWP) motor despite having rewound the stator windings on the four other SWP motors after identifying poor manufacturing quality in the stator winding end turns of each of the motors. This resulted in the B SWP motor failing while in service on December 10, 2013. CENGs immediate corrective actions included replacing the failed motor with a refurbished spare and entering the issue into the corrective action program (CAP).

Failure to modify an existing PM task in accordance with the PM program procedure was a performance deficiency within CENGs ability to foresee and correct and should have been prevented. Specifically, CENG did not adequately implement changes to the PM 3-year overhaul task or establish a revised schedule for which the SWP motors should be rewound.

This ultimately resulted in the failure of the B SWP motor. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, due to the failure of the B SWP motor, the SWP was not operable or available until the motor was replaced. The inspectors evaluated the finding using Attachment 0609.04, "Initial Characterization of Findings," worksheet to IMC 0609, Significance Determination Process (SDP). The attachment instructs the inspectors to utilize IMC 0609,

Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Significance Determination Process for Findings At-Power. The inspectors determined this finding was not a deficiency affecting the design or qualification of a mitigating structure, system, and component (SSC), did not represent a loss of system and/or function, and did not represent an actual loss of function of at least a single train.

Therefore, the inspectors determined this finding to be of very low safety significance (Green). In accordance with IMC 0612, the finding does not have a cross-cutting aspect, because the performance deficiency occurred between 2005 and 2008, would not likely occur today under similar circumstances, and is not reflective of present plant performance.

(Section 1R12)

Green.

The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion III, Design Control, because CENG did not ensure that the requirements and the design basis as specified in the Updated Final Safety Analysis Report (UFSAR) and Ginna TS bases were correctly translated into specifications, drawings, procedures, and instructions. Specifically, CENG failed to ensure the design basis analysis for the emergency diesel generators (EDGs) accounted for worst case EDG loading and EDG room heat loads during cold weather conditions, which resulted in a condition where there was a reasonable doubt of the operability of the EDGs. CENGs immediate corrective actions included entering the issue into its CAP, conducting an operability determination, and implementing compensatory measures via Engineering Change Package (ECP) 13-001076.

The inspectors determined that CENGs failure to provide for verifying or checking the adequacy of design, such as by the performance of design reviews and calculations in accordance with 10 CFR 50, Appendix B, Criterion III, to ensure that EDG room temperatures would not challenge EDG operability, was a performance deficiency that was within CENGs ability to foresee and correct and should have been prevented. This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, following a design basis event during design basis extreme weather conditions, the EDG room temperatures could reach sub-freezing conditions that had not been previously analyzed. This condition could have impacted EDG availability, reliability, and capability if EDG fuel oil temperatures reached their cloud point, if jacket water pressure instrumentation sensing lines froze and resulted in a low jacket water pressure condition, and as other lines like service water (SW) pressure instruments for the jacket water and lube oil cooler froze or approached freezing. Additionally, the finding is similar to Example 3.j. of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, in that the EDG design basis analysis failed to consider worst case conditions, which resulted in a reasonable doubt on the operability of the EDGs that necessitated the implementation of compensatory actions via an ECP, extensive data gathering, modification of and evaluation utilizing the GOTHIC computer model, planned permanent modifications, and a past operability determination addressing two lines that could potentially freeze. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green), because the performance deficiency was a deficiency affecting the design of a mitigating SSC, and the SSC maintained its operability. In accordance with IMC 0612, the finding does not have a cross-cutting aspect, because the performance deficiency likely occurred during original plant design, would not likely occur today under similar circumstances, and is not reflective of present plant performance. (Section 1R15)

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a Green NCV of 10 CFR 50.47(b)(14) and 10 CFR 50,

Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV.F.2.g. Specifically, CENG did not identify and critique a weakness related to a risk-significant planning standard during their critique following the March 11, 2014, emergency preparedness drill. CENGs immediate corrective actions included entering the issues associated with the drill critique into its CAP.

The inspectors determined that CENGs failure to identify and critique an emergency preparedness drill performance weakness in the formal critique was a performance deficiency that was within CENGs ability to foresee and correct and should have been prevented. Specifically, CENG did not identify that operators failed to notice the loss of annunciator panels for approximately 7 minutes, contrary to the planned scenario summary and timeline, and that it took a computer alarm, not associated with the loss of annunciator panels, to alert the operators to the loss of the annunciator panels. The inspectors determined that the failure to identify the drill performance weakness was more than minor, because it was associated with the emergency response organization performance attribute of the Emergency Preparedness cornerstone and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically,

CENGs failure to effectively identify an emergency preparedness drill performance weakness caused a missed opportunity to identify and correct a drill-related performance deficiency. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings. The attachment instructs the inspectors to utilize IMC 0609,

Appendix BProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix B" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Emergency Preparedness Significance Determination Process, when the finding is in the licensees Emergency Preparedness cornerstone. The inspectors determined this finding was a critique finding, the drill scope was full scale, the planning standard was a risk-significant planning standard, and the performance opportunity status was a success. Therefore, the inspectors determined the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because CENG personnel did not use decision-making practices that emphasize prudent choices over those that are simply allowable. Specifically,

CENG personnel did not exhibit conservative bias in their choice to consider the operators identification of the lost annunciator panels timely [H.14]. (Section 1EP6)

REPORT DETAILS

Summary of Plant Status

R.E. Ginna Nuclear Power Plant, LLC (Ginna) began the inspection period operating at full power. On January 13, 2014, operators reduced power to approximately 79 percent after the condensate booster pumps tripped due to a tagging error. Approximately 35 minutes later, operators reduced power to approximately 48 percent after the heater drain tank pumps tripped due to level control issues in the heater drain tank. Plant power was restored to full power on January 15, and the plant operated at full power for the rest of the period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Constellation Energy Nuclear Groups, LLS (CENGs)implementation of adverse weather preparation procedures before the onset of and during seasonal cold temperatures on January 21 and 22, 2014. The inspectors walked down areas in the emergency diesel generator (EDG) rooms, turbine building, standby auxiliary feedwater (AFW) building, auxiliary building, and screen house to ensure system availability. The inspectors verified that operator actions defined in CENGs adverse weather procedures maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

==1R04 Equipment Alignment

==

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

B AFW during planned maintenance on the C standby AFW pump on February 20, 2014

B spent fuel pool (SFP) cooling during planned maintenance on the A SFP cooling pump on March 13, 2014

Standby AFW during planned maintenance on the A motor-driven AFW on March 17, 2014 The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.

The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether CENG staff had properly identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On March 30 and 31, 2014, the inspectors performed a complete system walkdown of accessible portions of the containment spray system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, drawings, equipment lineup check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs to ensure CENG staff appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

==1R05 Fire Protection

==

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that CENG controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

B EDG room on February 25, 2014

Relay room/multiplexer room/annex room on February 28, 2014

Intermediate building basement (non-radiologically controlled side) on March 25, 2014

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation

a. Inspection Scope

The inspectors observed a fire brigade drill scenario conducted on March 11, 2014, which involved a fire in the turbine building seal oil system. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that CENG personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:

Proper wearing of turnout gear and self-contained breathing apparatus (SCBA)

Proper use and layout of fire hoses

Employment of appropriate fire-fighting techniques

Sufficient fire-fighting equipment brought to the scene

Effectiveness of command and control

Search for victims and propagation of the fire into other plant areas

Smoke removal operations

Utilization of pre-planned strategies

Adherence to the pre-planned drill scenario

Drill objectives met

The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with CENGs fire-fighting strategies.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on March 18, 2014, which included a lowering screen house level due to frazil ice conditions, a loss of one offsite circuit, a feedwater pump trip, a loss of AFW flow, and a manual safety injection signal.

The inspectors evaluated operator performance during the simulated event and verified completion of risk-significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classifications made by the shift manager and the TS action statements entered by the shift technical advisor.

Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed and reviewed portions of operators increasing plant power from 48 percent to full power in the control room on January 14, 2014. The inspectors observed briefings to verify that the briefings met the criteria specified in CENG procedures CNG-OP-1.01-1000, Conduct of Operations, Revision 01000, and CNG-OP-3.01-1000, Reactivity Management, Revision 00800. Additionally, the inspectors observed reactivity changes made by the operators to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the B SWP to assess the effectiveness of maintenance activities on SSC performance and reliability. The inspectors reviewed system health reports, CAP documents, and maintenance rule basis documents to ensure that CENG was identifying and properly evaluating performance problems within the scope of the maintenance rule. For the sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by CENG staff were reasonable.

Additionally, the inspectors ensured that CENG staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

b. Findings

Introduction.

A self-revealing Green NCV of TS 5.4.1, Procedures, was identified for failure to modify an existing PM task or schedule in accordance with CENG procedure CNG-AM-1.01-1018, Preventive Maintenance Program, Revision 00801. Specifically, CENG did not revise the PM for the B SWP motor despite having rewound the stator windings on the four other SWP motors after identifying poor manufacturing quality in the stator winding end turns of each of the motors. This resulted in the B SWP motor failing while in service on December 10, 2013.

Description.

On December 10, 2013, with the plant operating at full power, the B SWP unexpectedly tripped. This pumps motor was purchased new in 1996 and was commercial-grade dedicated, as were three other SWP motors. Three of the four motors were rewound between 2005 and 2008 due to failure or due to degradation identified during testing; the insulation systems for all three motors were also upgraded. The fourth motor was never rewound. In 2006, a spare, fifth motor was purchased, commercial-grade dedicated, and proactively rewound prior to delivery to Ginna. All five motors use the same PM template that calls for an overhaul on a 3-year frequency and rewinding after 30 years of service.

After failing on December 10, the SWP motor was declared inoperable, was replaced with the recently refurbished spare motor that had been rewound, and was sent out to be tested and rewound. As an additional corrective action, CENG plans to complete an extent of condition review of similarly sized motors classified as critical or significant that were commercially dedicated.

The apparent cause of the motor failure was determined to be due to degraded stator winding insulation. This degradation occurred over time due to poor workmanship of the insulation material and its lower quality, along with a PM rewind frequency that did not recognize the impact of the insulations quality. As such, the 30-year rewind frequency was inadequate to prevent failure given the known deficiencies identified in the other four SWPs between 2005 and 2008.

CENG procedure CNG-AM-1.01-1018 requires CENG personnel to initiate PM program changes based on component trends, including changes based on work order (WO)feedback review, PM templates, and industry and station operating experience. CENG concluded that decisions to perform motor rewinds between 2005 and 2008 did not consider the full extent of condition.

Analysis.

The inspectors determined that the failure to meet the requirements of CENG procedure CNG-AM-1.01-1018 was a performance deficiency within CENGs ability to foresee and correct, and should have been prevented. Specifically, CENG did not adequately implement changes to the PM 3-year overhaul task or establish a revised schedule for which the SWP motors should be rewound. This ultimately resulted in the failure of the B SWP motor. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, due to the failure of the B SWP motor, the SWP was not operable or available until the motor was replaced.

The inspectors evaluated the finding using Attachment 0609.04, "Initial Characterization of Findings," worksheet to Inspection Manual Chapter (IMC) 0609, Significance Determination Process, issued June 2, 2011. The attachment instructs the inspectors to utilize IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, issued June 19, 2012. The inspectors determined this finding was not a deficiency affecting the design or qualification of a mitigating SSC, did not represent a loss of system and/or function, and did not represent an actual loss of function of at least a single train. Therefore, the inspectors determined this finding to be of very low safety significance (Green).

In accordance with IMC 0612, the finding does not have a cross-cutting aspect, because the performance deficiency occurred between 2005 and 2008, would not likely occur today under similar circumstances, and is not reflective of present plant performance.

Enforcement.

TS 5.4.1 requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Section 9, Procedures for Performing Maintenance, of Appendix A to Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements, Revision 2, February 1978, which states that PM schedules should be developed. CNG-AM-1.01-1018 requires CENG to initiate PM program changes based on component trends including changes based on WO feedback review, PM templates, and industry and station operating experience. Contrary to the above, since the pump motor quality issue was identified in 2008 until December 2013, CENG failed to adequately implement the PM procedure for developing PM program changes for one SWP motor. As a result, the SWP motor failed while in service on December 10, 2013. CENGs immediate corrective actions included replacing the failed motor with a refurbished spare and entering the issue into the CAP (CR-2013-007052). Because this violation is of very low safety significance and has been entered into CENGs CAP, this finding is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000244/2014002-01, Failure to Adequately Implement the Preventive Maintenance Program Procedure for a Service Water Pump Motor)

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that CENG personnel performed the appropriate risk assessments prior to removing equipment from service.

The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that CENG personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When CENG performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Planned maintenance on the A EDG on January 16, 2014

Planned maintenance on the reactor vessel level monitoring system on February 5, 2014

Planned maintenance on the diesel-driven fire pump on March 4, 2014

Planned maintenance on the C standby AFW pump, boric acid storage tanks, and A battery charger on March 10, 2014

Planned maintenance on the A motor-driven AFW on March 17, 2014

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

A and B EDG system design analysis was non-bounding for limiting cold weather conditions and loading operation on January 2, 2014

Lowering main condenser performance on January 27, 2014

Lowering screen house level due to icing on January 28, 2014

EDG thermostat contacts under rated on January 29, 2014

B SW check valve failed acceptance criteria on February 21, 2014

A motor-driven AFW pump discharge check valve, 4000C, leaking on March 18, 2014

The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to CENGs evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by CENG. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, because CENG did not provide for verifying or checking the adequacy of design, such as by the performance of design reviews and calculations to ensure that EDG room temperatures would not challenge EDG operability.

Specifically, CENG failed to ensure the design basis analysis for the EDGs accounted for worst case EDG loading and EDG room heat loads during cold weather conditions, which resulted in a condition where there was a reasonable doubt of the operability of the EDGs.

Description.

Ginna UFSAR Section 2.3.2.2, Severe Weather, states that the extreme minimum temperature appropriate to the Ginna site is 2 degrees Fahrenheit (°F). The TS bases for TS Section 3.8.1, AC Sources - MODES 1, 2, 3, and 4, states:

Each DG [diesel generator] room has its own ventilation system.

The ventilation system is designed to maintain the DG room between 60°F and 104°F during normal operation... Each ventilation system consists of two fans and associated ductwork and dampers. One fan is given a start permissive on DG actuation... The second fan [is] designed to start when the room temperature reaches 90°F. The second fans discharge temperature reaches a preset temperature to prevent potentially freezing the cooling water jacket piping during cold weather conditions.

While observing EDG testing during cold outside temperatures, the inspectors noted that the EDG room cooled quickly and approached 60°F. The inspectors questioned how the temperatures in the EDG rooms would be maintained during EDG operation coincident with cold outside temperatures if there were no design features that prevented the ventilation systems (the ADF01B and ADF02B fans automatically start when their respective EDG starts) from running while the corresponding EDGs were operating. On December 26, 2013, CENG documented CR-2013-007323, which stated there was no single source of information available (no analysis of record) to gain an understanding of the resulting temperatures inside the EDG rooms during extreme cold weather conditions.

Without a bounding design analysis for cold weather operation, CENG was not able to show that the jacket water pressure switch instrumentation line, SW pressure instruments for the jacket water and lube oil coolers, city water alternate supply piping, or fire water header and hose reel supply piping would not freeze and impact operability; CENG was also not able to show that fuel oil temperatures would remain above the cloud point temperature of 23°F.

An operability determination was completed on January 2, 2014, which discussed the compensatory measures needed to assure operability of the EDGs until additional analyses could be performed. Specifically, ECP 13-001076, EDG Cold Weather Mitigation Modification, Revision 0000, implemented compensatory measures on January 2, which opened the breakers for the automatic start fans, ADF01B and ADF02B, to limit the potential for freezing conditions in the EDG rooms; the other fans in each room would have still automatically cycled on and off as room temperature increased and decreased, as necessary.

In order to determine temperatures at different points in the room and to calculate low steady state temperatures in different areas of the EDG rooms, CENG modified its GOTHIC computer model, which had been developed specifically for calculating maximum steady state temperatures in the EDG building. On January 2, during the performance of STP-O-12.2, Emergency Diesel Generator B, Revision 01302, the inspectors observed CENG personnel gather room temperature data that would be used to validate the stations GOTHIC computer model.

In response to the inspectors questions and as part of the evaluation of CR-2013-

===007323, CENG completed a past operability determination. The past operability determination documented that ME-91-0010, D/G Buildings HVAC Analysis, Revision 2, previously calculated the EDG room temperatures and incorrectly assumed that a fully loaded EDG (2000 kW) with room heaters running was the limiting case; during a potential loss of offsite power scenario, the diesel loading would be approximately 750 kW.

Additionally, ME-92-0011, Evaluation of the Diesel Generator Jacket Water Pressure Sensing Line Freeze Time, Revision 0, had previously concluded that temperatures in the EDG rooms would not go below 39°F when outside temperatures reached -6°F, and the analysis concluded that freezing of the EDG jacket water pressure sensing tubing line was not a concern, even though Licensee Event Report 85-002-01, Manual Actuation of Engineered Safety Feature, May 31, 1985, documented that the jacket water pressure sensing line had frozen previously. Utilizing the updated GOTHIC computer model, the past operability determination associated with CR-2013-007323 determined that the EDG room temperatures could be below freezing if outside temperatures reached 16°F or less, and the model showed that for limiting design basis outside temperatures, 2°F, the EDG room temperatures could be between 15°F and 20°F with some colder areas as low as 8°F.

CENG assessed the potential degradation due to freezing, fuel oil clouding, and excitation system impacts and determined that some lines like the jacket water pressure switch instruments and the fire water hose reel supply piping were at risk of freezing prior to compensatory actions being implemented on January 2. On February 12, this issue was entered into CENGs CAP as CR-2014-000740. However, CENG determined that the EDGs remained capable of fulfilling their design basis functions prior to the implementation of compensatory actions.

CENG also implemented a permanent change, ECP 14-000037, ESR-14-0012 ESR (000) - Add Thermostats to 1/DSF1A2 and 1/DSF1B2 Logic, Revision 0000, to install thermostat switches to turn off ADF01B and ADF02B when room temperatures are below 40°F. Additionally, CA-20013-000014 was created to revise ME-91-0010, D/G Building HVAC Analysis, Revision 002, and ME-92-0011, Evaluation of The Diesel Jacket Water Pressure Sensing Line Freeze Time, Revision 000, or issue a new analysis for cold EDG heating, ventilation, and air conditioning (HVAC) analysis.

Analysis.

The inspectors determined that CENGs failure to provide for verifying or checking the adequacy of design, such as by the performance of design reviews and calculations in accordance with 10 CFR 50, Appendix B, Criterion III, to ensure that EDG room temperatures would not challenge EDG operability, was a performance deficiency that was within CENGs ability to foresee and correct and should have been prevented.

This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, following a design basis event during design basis extreme weather conditions, the EDG room temperatures could reach sub-freezing conditions that had not been previously analyzed. This condition could have impacted EDG availability, reliability, and capability if EDG fuel oil temperatures reached their cloud point, if jacket water pressure instrumentation sensing lines froze and resulted in a low jacket water pressure condition, and as other lines like SW pressure instruments for the jacket water and lube oil cooler froze or approached freezing.

Additionally, the finding is similar to Example 3.j. of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, in that the EDG design basis analysis failed to consider worst case conditions, which resulted in a reasonable doubt on the operability of the EDGs that necessitated the implementation of compensatory actions via an ECP, extensive data gathering, modification of and evaluation utilizing the GOTHIC computer model, planned permanent modifications, and a past operability determination addressing two lines that could potentially freeze.

In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green), because the performance deficiency was a deficiency affecting the design of a mitigating SSC, and the SSC maintained its operability.

In accordance with IMC 0612, the finding does not have a cross-cutting aspect because the performance deficiency likely occurred during original plant design, would not likely occur today under similar circumstances, and is not reflective of present plant performance.

Enforcement.

10 CFR 50, Appendix B, Criterion III, Design Control, states, in part, that measures shall be established to provide for verifying or checking the adequacy of design, such as by the performance of design reviews and calculations. Contrary to the above, prior to January 2, 2014, CENG failed to provide for verifying or checking the adequacy of EDG design. Specifically, CENG failed to ensure the design basis analysis for the EDGs accounted for worst case EDG loading and EDG room heat loads during cold weather conditions, which resulted in the potential for EDG room temperatures to reach sub-freezing conditions that had not been previously analyzed and a reasonable doubt on the operability of the EDGs. CENGs immediate corrective actions included entering the issue into its CAP, conducting an operability determination, and implementing compensatory measures via ECP 13-001076. Because this violation was of very low safety significance (Green), and CENG entered this issue into its CAP as CR-2013-007323 and CR-2014-000740, this violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000244/2014002-02, Failure to Ensure the Design Basis Analysis for the Emergency Diesel Generators Accounted for Limiting Cold Weather Conditions and Loading)

1R18 Plant Modifications

Temporary Modifications

a. Inspection Scope

The inspectors reviewed temporary modification ECP 13-001076, Cold Weather Mitigation Modification, Revision 0000, related to the EDG Ventilation System, to determine whether the modification affected the safety functions of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modification did not degrade the design bases, licensing bases, and performance capability of the affected systems.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

B EDG fuel oil transfer pump planned maintenance on February 4, 2014

A SWP planned maintenance on February 13, 2014

C standby AFW planned maintenance on February 21, 2014

Diesel-driven fire pump planned maintenance on March 4, 2014

A residual heat removal pump planned maintenance on March 12, 2014

A motor-driven AFW planned maintenance on March 17, 2014

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and CENG procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

STP-O-12.2, Emergency Diesel Generator B on January 2, 2014

STP-O-12.2, Emergency Diesel Generator B on February 4, 2014 STP-O-16QT, Auxiliary Feedwater Turbine Pump - Quarterly on February 18, 2014 (inservice test)

STP-O-2.2QA, Residual Heat Removal Pump A Inservice Test on March 12, 2014 (inservice test)

STP-O-31A, Charging Pump A Inservice Test on March 14, 2014 (inservice test)

STP-I-32B, Reactor Trip Breaker Testing - Train B on March 19 and 20, 2014

STP-E-11.4, Technical Support Center (TSC) 60 Cell Battery Bank and STP-E-12.5, TSC Diesel Test on March 24, 2014

STP-I-9.1.16, Undervoltage Protection - 480 Volt Safeguard Bus 16 on March 31, 2014

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

CENG implemented various changes to Ginnas emergency action levels (EALs),emergency plan, and implementing procedures. CENG had determined that in accordance with 10 CFR 50.54(q)(3) any change made to the EALs, emergency plan, and its lower-tier implementing procedures had not resulted in any reduction in effectiveness of the plan and that the revised plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50, Appendix E.

The inspectors performed an in-office review of all EAL and emergency plan changes submitted by CENG as required by 10 CFR 50.54(q)(5) including the changes to lower-tier emergency plan implementing procedures to evaluate for any potential reductions in effectiveness of the emergency plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.

b. Findings

No findings were identified.

=

a. Inspection Scope

The inspectors evaluated the conduct of a routine CENG emergency drill on March 11, 2014, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by CENG staff in order to evaluate CENGs critique and to verify whether CENG staff was properly identifying weaknesses and entering them into the CAP.

b. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50.47(b)(14) and 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV.F.2.g. Specifically, CENG did not identify and critique a weakness related to a risk significant planning standard during their critique following the March 11, 2014, emergency preparedness drill.

Description.

On March 11, 2014, Ginna conducted an emergency preparedness drill, which included activating the simulator control room, the TSC, the operational support center, and the emergency operations facility. At 8:00 a.m., with the plant at full power, the simulator control room experienced an unplanned loss of six annunciator panels; loss of these annunciator panels meets the notice of unusual event (NOUE) EAL criteria.

The loss of these annunciator panels was evident to the control room operators when nine lit annunciator green lights extinguished on the simulator panels at this time. These nine annunciator lights, along with three others, are normally lit when the plant is at full power. At 8:07 a.m., a plant computer alarm actuated in the simulator control room. A reactor operator immediately noticed the computer alarm and observed that a panel annunciator should also have alarmed; he notified the control room supervisor and then tested the annunciator panels, which revealed that the six annunciator panels were lost. During this time period, there were two reactor operators and two senior reactor operators in the simulator control room. During the next few minutes, the shift manager and shift technical advisor independently determined this met the NOUE EAL criteria (both circled the appropriate EAL on separate charts). After verifying other parameters, the shift manager declared an NOUE at 8:17 a.m.

Ginnas EAL for the loss of annunciator panels indicates that the unplanned loss of six or more annunciator panels for greater than or equal to 15 minutes is an NOUE. An associated note states that the emergency director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

CENG conducted the formal drill critique on March 12, 2014. During the critique, CENG failed to identify that it took longer than expected for operators to identify the main control board indication in a timely manner (it took approximately 7 minutes for the simulator control room operators to identify that the six annunciator panels were lost)and that it took another random computer alarm to bring it to their attention. For the NOUE portion of the critique, CENG was focused on the start time of the 15 minutes required to make the declaration and not on the operator performance weakness.

CENG incorrectly concluded that the start time for the 15 minutes to declare the NOUE was at 8:07 a.m., when the operators noticed the loss of the annunciator panels, rather than the time the indications became available to the operators. Additionally, CENG incorrectly concluded during the critique that the loss of the nine green annunciators was not an indication of loss of the annunciator panels. The drill scenario summary and timeline, which was developed prior to the drill, stated that the unplanned loss of annunciator panels would occur at approximately 8:00 a.m. The anticipated results were that operations would enter procedure ER-INST.2, Loss of Annunicators, Revision 00700, and should declare the NOUE within 15 minutes of the indication of the loss of annunciators. CENG counted the NOUE declaration as a successful drill and exercise performance indicator (PI) opportunity.

Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, the guidance used for determining if a PI criteria has been met, states that classification is expected to be made promptly following indication that the conditions have reached an emergency threshold in accordance with the EAL scheme.

For this EAL, the threshold is that the annunciators are lost for greater than 15 minutes.

NEI 99-02 also states that the 15-minute goal is a reasonable period of time for assessing and classifying an emergency once indications that an EAL has been exceeded are available to control room operators. It further defines timely as classifications are made consistent with the goal of 15 minutes once available plant parameters reach an EAL. For the drill conducted on March 11, the inspectors determined that the declaration of the NOUE at approximately 17 minutes after the annunciator panels were lost was performed in a timely manner for PI evaluation. This action was 2 minutes following the applicable time of 15 minutes that the annunciator panels were lost. Therefore, the inspectors concluded that the NOUE declaration was a drill and exercise PI success using a different line of reasoning than CENG.

When the inspectors questioned the amount of time it took the operators to notice the lost annunciator panels and the time it took to make the NOUE declaration, CENG initiated a CR for the operators not immediately identifying the extinguished green annunciators (CR-2014-001540). CENG also initiated a CR for a potential concern with the initiating time for classification and declaration of the NOUE (CR-2014-001430). The focus of this CR was on the failure of Ginna station to properly critique emergency response organization drill performance. The concerns in question centered on the length of time that changing conditions on the simulator main control board went unnoticed by control room personnel and the length of time it took the simulator shift manager to make the actual NOUE declaration.

Analysis.

The inspectors determined that CENGs failure to identify and critique an emergency preparedness drill performance weakness in the formal critique was a performance deficiency that was within CENGs ability to foresee and correct and should have been prevented. Specifically, CENG did not identify that operators failed to notice the loss of annunciator panels for approximately 7 minutes, contrary to the planned scenario summary and timeline, and that it took an unrelated computer alarm to alert the operators to the loss of the annunciator panels. The inspectors determined that the failure to identify the drill performance weakness was more than minor, because it was associated with the emergency response organization performance attribute of the Emergency Preparedness cornerstone and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the failure of CENG to effectively identify and critique an emergency preparedness drill performance weakness caused a missed opportunity to identify and correct a drill-related performance deficiency.

The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, issued June 19, 2012. The attachment instructs the inspectors to utilize IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued February 24, 2012, when the finding is in the licensees Emergency Preparedness cornerstone. The inspectors determined this finding was a critique finding, the drill scope was full scale, the planning standard was a risk-significant planning standard, and the performance opportunity status was a success. Therefore, the inspectors determined the finding was of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because CENG personnel did not use decision-making practices that emphasize prudent choices over those that are simply allowable. Specifically, CENG personnel did not exhibit conservative bias in their choice to consider the operators identification of the lost annunciator panels timely [H.14].

Enforcement.

10 CFR 50.54(q)(2) requires, in part, that the licensee shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of § 50.47(b). 10 CFR 50.47(b)(14)requires, in part, that periodic drills are conducted to develop and maintain key skills, and that deficiencies identified as a result of exercises are corrected.Section IV.F.2.g.

of Appendix E to 10 CFR 50 requires that all exercises, drills, and training that provide performance opportunities must provide for formal critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified in a critique must be corrected. Contrary to the above, CENG failed to identify and correct a performance weakness during the March 12, 2014, critique of the March 11 Ginna emergency preparedness drill. Specifically, CENG did not identify during its formal critique a weakness associated with the operators not identifying a simulator main control board indication in a timely manner. CENGs immediate corrective actions included entering the issues associated with the drill critique into its CAP. Because this violation is of very low safety significance and has been entered into CENGs CAP as CR-2014-001540 and CR-2014-001430, this finding is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000244/2013004-03, Failure of Emergency Preparedness Drill Critique to Identify a Risk-Significant Planning Standard Weakness)

.2 Training Observations (1 sample)

a. Inspection Scope

The inspectors observed a simulator training evolution for Ginna licensed operators on March 18, 2014, which required emergency plan implementation by an operations crew.

CENG planned for this evolution to be evaluated and included in PI data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that CENG evaluators noted the same issues and entered them into the CAP.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

From March 24 to 28, 2014, the inspectors reviewed CENGs performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR Part 20 and guidance in RG 8.38, Control of Access to High and Very High Radiation Areas for Nuclear Plants, Revision 1, May 2006, TSs, and CENG procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the results of radiation program audits. The inspectors reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection.

Radiological Hazard Assessment

The inspectors determined if there have been changes to plant operations since the last inspection that resulted in any new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether CENG assessed the potential impact of these changes.

The inspectors reviewed the last two radiological surveys from the auxiliary building 4 and 43 elevations and the SFP.

The inspectors conducted walkdowns and independent radiation measurements in the facility including radioactive waste processing, storage, and handling areas to evaluate material and radiological conditions.

Instructions to Workers

The inspectors selected five containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with 10 CFR Part 20 requirements.

The inspectors reviewed two occurrences where a workers electronic personal dosimeter malfunctioned or alarmed. The inspectors assessed any compensatory dose evaluations and if the issue was included in the CAP.

Contamination and Radioactive Material Control

The inspectors observed one location where CENG monitors material leaving the radiological control area and inspected the methods used for control, survey, and release of these materials from this area. The performance of personnel surveying and releasing material for unrestricted use was observed. The inspectors assessed the radiation monitoring instrumentation used for material release and the appropriate measurement sensitivity. The inspectors reviewed CENGs criteria for the survey and release of potentially contaminated material. The inspectors reviewed three sealed sources and verified that they were accounted for and tested. The inspectors evaluated recent transactions involving nationally tracked sources.

Radiological Hazards Control and Work Coverage

The inspectors evaluated plant radiological conditions and performed independent radiation measurements during walkdowns of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, radiation work permits, and associated worker briefings.

The inspectors examined CENGs access controls for highly activated or contaminated materials stored within the SFP and other storage pools.

The inspectors examined the posting and physical controls for selected high radiation areas, locked high radiation areas, and very high radiation areas.

Risk-Significant High and Very High Radiation Area Controls

The inspectors discussed with the radiation protection manager the controls and procedures for high-risk high and very high radiation areas. The inspectors discussed with first-line health physics supervisors the controls in place for areas that have the potential to become very high radiation areas during certain plant operations.

Radiation Worker Performance

The inspectors reviewed 10 radiological problem reports since the last inspection that attributed the cause of the event to human performance errors. The inspectors assessed the corrective action approach taken by CENG to resolve the reported problems.

Radiation Protection Technician Proficiency

The inspectors reviewed five radiological problem reports since the last inspection that attributed the cause of the event to radiation protection technician error. The inspectors assessed the corrective action approach taken by CENG to resolve the reported problems.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by CENG at an appropriate threshold and were properly addressed and resolved in CENGs CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by CENG that involve radiation monitoring and exposure controls. The inspectors assessed CENGs process for applying operating experience to their plant.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

From March 24 to 28, 2014, the inspectors verified in-plant airborne concentrations were being controlled consistent with as low as reasonably achievable principles and the use of respiratory protection devices on-site. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.15, Acceptable Programs for Respiratory Protection, Revision 1, October 1999; RG 8.25, Air Sampling in the Workplace, Revision 1, June 1992; NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, Revision 1, January 2001; TSs; and CENG procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the UFSAR to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. This review included instruments used to identify changing airborne radiological conditions, a review of the respiratory protection program, and a description of the types of devices used. The inspectors reviewed the UFSAR, TSs, and emergency planning documents to identify the location and quantity of respiratory protection devices stored for emergency use. The inspectors reviewed the procedures for maintenance, inspection, and use of respiratory protection equipment including SCBA, and procedures for air quality maintenance.

Engineering Controls

The inspectors reviewed CENGs use of permanent and temporary ventilation to determine whether CENG uses ventilation systems as part of its engineering controls to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems to reduce dose. The inspectors selected one installed ventilation system used to mitigate the potential for airborne radioactivity. The inspectors selected one temporary ventilation system setup used to support work in contaminated areas.

The inspectors reviewed airborne monitoring protocols to monitor and warn of changing airborne concentrations in the plant. The inspectors evaluated whether the alarms and set points were adequate.

The inspectors assessed whether CENG had established threshold criteria for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides.

Use of Respiratory Protection Devices

The inspectors reviewed records of air testing for supplied air devices and SCBA bottles to assess the air quality. The inspectors reviewed plant breathing air supply systems to determine whether they met the minimum pressure and airflow requirements for the devices in use.

The inspectors selected five individuals qualified to use respiratory protection devices and verified the currency of their qualifications.

The inspectors selected three individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device.

Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the device.

The inspectors chose ten respiratory protection devices staged and ready for use in the plant. The inspectors assessed the physical condition of the device components and reviewed records of equipment inspection for each type of equipment. The inspectors selected several of the devices and reviewed records of maintenance on the vital components. The inspectors verified that on-site personnel assigned to repair respiratory protection equipment had received vendor-provided training.

SCBAs for Emergency Use

The inspectors reviewed the status and surveillance records of SCBAs staged in-plant for use during emergencies. The inspectors reviewed CENGs capability for refilling and transporting SCBA air bottles to and from the control room and the operations support center.

The inspectors selected five individuals on control room shift crews and from designated departments currently assigned emergency duties to assess the currency of their qualifications for use of SCBAs. The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task.

The inspectors reviewed the past two years of maintenance records for three SCBA units to assess whether maintenance and repairs of SCBA units were performed by individuals certified by the manufacturer of the device to perform the work. For those SCBAs that were ready for use, the inspectors verified that the required periodic air cylinder hydrostatic testing was documented and up to date.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by CENG at an appropriate threshold and were properly addressed for resolution in CENGs CAP. The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by CENG.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors reviewed CENGs submittals for the following Initiating Events cornerstone PIs for the period of January 1 through December 31, 2013:

Unplanned Scrams (IE01)

Unplanned Power Changes (IE03)

Unplanned Scrams with Complications (IE04)

To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed CENGs operator narrative logs, maintenance planning schedules, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that CENG entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.

b. Findings

No findings were identified.

.2 Annual Sample:

Procedure Use and Adherence Deficiencies

a. Inspection Scope

The inspectors performed an in-depth review of CENGs evaluations and effectiveness of corrective actions associated with procedure use and adherence deficiencies. The inspectors assessed CENGs problem identification threshold, associated analyses and evaluations, and prioritization and timeliness of corrective actions pertaining to procedural use and adherence. The inspectors performed this review to determine whether CENG personnel were appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned and completed corrective actions were appropriate. The inspectors reviewed CRs, a root cause analysis (RCA)and an apparent cause evaluation (ACE) as well as conducted interviews with various CENG staff to assess the adequacy, effectiveness, and timeliness of implemented corrective actions.

b. Findings and Observations

No findings were identified.

In recent months, numerous CRs were written by CENG staff pertaining to procedural use and adherence deficiencies. In discussions with CENG personnel, it was determined that since the July 2013 generator trip event that resulted in an RCA, CENG has placed additional focus on plant personnels procedure use and adherence of procedures. One aspect of this focus was to create an oversight team (led by the site human performance coordinator) to assess procedure non-compliances with the intent to reinforce site standards regarding procedure compliance. This oversight team reviewed all site CRs to determine if there was a procedure use and adherence deficiency associated with the issue. When deficiencies were identified, procedure prompt reviews were conducted to identify the specific procedural issue(s) and to provide coaching/reinforcement of site standards, as applicable. This process was initiated in mid-November 2013.

While assessing the effectiveness of this and other corrective actions in the fourth quarter of 2013, CENG identified a declining trend in station implementation of safety program behaviors and multiple instances of procedure use and adherence deficiencies pertaining to the industry safety manual requirements. CENG initiated an ACE to further address procedure use and adherence deficiencies.

As a result of the RCA and ACE, over the past two quarters, numerous corrective actions were implemented which included focused management observations on procedure use and adherence, did you know? briefings, desk-top observations, establishing guidance for supervisor observations to provide improved feedback to station personnel, station-wide communications, and procedure usage emphasis during plan-of-the-day meetings. To assess the effectiveness of their corrective actions, CENG created a procedure compliance index, which is a function of the number of procedure prompt reviews, significance, and man-hours worked.

The inspectors concluded that, since the July 2013 generator trip event, CENG personnel had identified the existence of a culture that did not emphasize strict administrative procedure use and adherence. The procedure use and adherence deficiencies that were identified only had minor consequences. The inspectors reviewed CRs, a RCA and an ACE, and concluded that CENG staff had appropriately evaluated the problem. The inspectors found that the issues had been accurately documented within the CAP and appropriate extent-of-condition reviews had been performed. CENG personnel appropriately evaluated the causes of procedure use and adherence deficiencies as a lack of re-enforcement of site procedure standards. The inspectors determined CENG staffs overall response to the issue was commensurate with the safety significance, was timely and included appropriate corrective actions, and the inspectors found CENG staffs conclusions to be reasonable.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

a. Inspection Scope

For the plant down powers that occurred on January 13, 2014, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. The inspectors reviewed CENGs follow-up actions related to the events to assure that CENG implemented appropriate corrective actions commensurate with their safety significance.

b. Findings

Introduction.

A self-revealing Green finding (FIN) was identified because CENG failed to authorize the application of a tagout in accordance with procedure CNG-OP-1.01-1007, Clearance and Safety Tagging, Revision 01101. Specifically, CENG did not adequately implement equipment tagging procedural requirements to verify the effect on the plant systems and adequacy of the tagout boundary prior to removing the specified equipment from service. As a result, two air-operated valves (AOVs) unexpectedly opened when a tagout was being hung and resulted in a trip of all running condensate booster pumps on low suction pressure and a plant transient.

Description.

On January 13, 2014, with the plant operating at full power, plant operators were hanging a tagout to establish conditions for maintenance to replace the A condensate demineralizer regeneration sluice pump circuit breaker. As part of the tagout, operators were directed to open motor control center supply breaker Bus 13/06D.

When Bus 13/06D was secured, operators expected all of the loads on the bus to remain in their same state or position. However, the opening of this supply breaker caused the condensate demineralizer vessel bed inlet and outlet AOVs to open unexpectedly.

Since the associated manual inlet and outlet valves for the demineralizer beds were in their normal position (open), when the AOVs opened, four demineralizer beds, not at system operating pressure, were simultaneously placed in service. This resulted in a sudden drop in condensate system pressure as the demineralizer beds were pressurized and a low suction pressure trip of the two running condensate booster pumps.

Operators implemented corrective actions by immediately reclosing the bus supply breaker 13/06D and entered abnormal procedure AP-FW.1, Abnormal MFW Pump Flow or NPSH, Revision 01802, which required a plant power reduction to less than 80 percent in order to maintain adequate main feed pump net positive suction head.

Subsequently, with the plant at approximately 79 percent power, both heater drain tank pumps tripped when the condensate bypass was closed in accordance with an AP-FW.1 recovery action. The trip of both heater drain tank pumps required an additional load reduction to less than 50 percent power. The heater drain tank pump trip was assessed and a finding was documented in Ginnas Problem Identification and Resolution Team Inspection Report 05000244/2014008 (ML14101A325).

CENG entered the condensate booster pump event into their CAP as CR-2014-000196 and conducted an RCA. CENGs RCA determined that the equipment was incorrectly tagged because the operations impact reviewer wrongly assumed that the AOVs failed closed on a loss of power to the bus and did not validate this assumption with drawings or a field walkdown. Therefore, CENG did not meet the requirements of CNG-OP-1.01-1007 by failing to ensure that the consequences of removing the specified equipment from service had been evaluated from the perspective of plant effects and tagout boundary impacts. Plant equipment responded as designed.

Analysis.

The inspectors determined that the failure to meet the requirements of procedure CNG-OP-1.01-1007 was a performance deficiency within CENGs ability to foresee and correct and should have been prevented. Specifically, CENG did not adequately implement equipment tagging procedural requirements to verify plant effects and tagout boundary impact prior to removing the specified equipment from service.

The inspectors determined that the failure to follow procedural requirements was more than minor, because it was associated with the configuration control attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, CENG did not follow procedural guidance when reviewing the tagout to ensure that the consequences of removing the specified equipment from service had been evaluated from the perspective of plant effects and tagout boundary impacts. This resulted in a plant transient as operators rapidly reduced plant power in order to avoid a more significant plant transient. Additionally, the finding is similar to IMC 0612, Appendix E, Examples of Minor Issues, Example 4.b., issued August 11, 2009, which states that issues are not minor if a personnel error caused a plant transient.

The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, Initial Characterization of Findings, issued June 19, 2012. The attachment instructs the inspectors to utilize IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012. The inspectors determined the self-revealing performance deficiency did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment and is, therefore, of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because CENG individuals did not recognize and plan for the possibility of mistakes, even while expecting successful outcomes. Specifically, the two individuals who performed the operations impact review and the authorization of the tagout did not plan for the possibility of mistakes and failed to accurately assess the operations impact or the tagout boundary impacts [H.12].

Enforcement.

CENG failed to ensure that the consequences of removing the specified equipment from service had been evaluated from the perspective of plant effects and tagout boundary impacts. This issue was entered into CENGs CAP as CR-2014-000196. This finding does not involve enforcement action because no violation of a regulatory requirement was identified. Because this finding does not involve a violation and is of very low safety or security significance (Green), it is identified as a FIN. (FIN 05000244/2014002-04, Failure to Adhere to Procedural Requirements for Authorizing the Application of a Tagout)

4OA5 Other Activities

.1 Temporary Instruction (TI) 2515/182:

Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks, Phase 2

a. Inspection Scope

CENGs buried and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of TI 2515/182, and it was confirmed that activities corresponding to the completion dates specified in the program, which have passed since the Phase 1 inspection was conducted, have been completed.

CENG buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the TI and responses to specific questions found in www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to NRC headquarters staff.

b. Findings

No findings were identified.

.2 Cross-Cutting Aspects

The table below provides a cross reference for findings from 2013 that will be considered in the 2014 mid cycle plant assessment review and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January 2014 will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305, Operating Reactor Assessment Program, issued October 13, 2013, starting with the 2014 mid-cycle assessment review.

Finding Old Cross-Cutting Aspect

New Cross-Cutting Aspect 05000244/2013004-02 P.1(c)

P.2 05000244/2013004-03 H.3(b)

H.5 05000244/2013005-01 P.1(c)

P.2 05000244/2013005-02 P.1(c)

P.2 05000244/2013007-01 P.2(b)

P.5

4OA6 Meetings, Including Exit

On April 16, 2014, the inspectors presented the inspection results to Mr. Michel Philippon, Plant General Manager, and other members of the Ginna staff. The inspectors verified that no propriety information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Pacher, Vice President, Ginna

M. Philippon, Plant General Manager

J. Bowers, Radiation Protection Manager

S. Doty, Manager, Maintenance

L. Edwards, General Supervisor, Chemistry

K. Garnish, General Supervisor, Operations Support

T. Harding, Director, Licensing

J. Jackson, Supervisor, Engineering

D. Markowski, General Supervisor, System Engineering

T. Mogren, Manager, Engineering Services

T. Paglia, Manager, Operations

J. Scalzo, Director, Emergency Preparedness

R. Sova, Acting General Supervisor, Radiation Protection

S. Wihlen, Manager, Integrated Work Management

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Open/Closed

05000244/2014002-01 NCV

Failure to Adequately Implement the Preventive Maintenance Program Procedure for a Service

Water Pump Motor (Section 1R12)

05000244/2014002-02 NCV

Failure to Ensure the Design Basis Analysis for the

Emergency Diesel Generators Accounted for Limiting Cold Weather Conditions and Loading (Section 1R15)

05000244/2014002-03 NCV

Failure or Emergency Preparedness Drill Critique to

Identify a Risk-Significant Planning Standard

Weakness (Section 1EP6)

05000244/2014002-04 FIN

Failure to Adhere to Procedural Requirements for Authorizing the Application of a Tagout (Section 4OA3)