IR 05000244/2016001
| ML16120A390 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/28/2016 |
| From: | Anthony Dimitriadis Reactor Projects Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Dimitriadis A | |
| References | |
| IR 2016001 | |
| Download: ML16120A390 (30) | |
Text
April 28, 2016
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2016001
Dear Mr. Hanson:
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the R.E. Ginna Nuclear Power Plant, LLC (Ginna). The enclosed inspection report documents the inspection results, which were discussed on April 13, 2016, with Mr. Joseph Pacher, Site Vice President, and other members of the Ginna staff.
NRC inspectors 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.
The inspectors documented one licensee-identified violation which was determined to be of very low safety significance. The NRC is treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the NCV 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors 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/
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects
Docket No.
50-244 License No.
Enclosure:
Inspection Report 05000244/2016001 w/Attachment: Supplementary Information
REGION I==
Docket No.
50-244
License No.
Report No.
Licensee:
Exelon Generation Company, LLC (Exelon)
Facility:
R.E. Ginna Nuclear Power Plant, LLC (Ginna)
Location:
Ontario, New York
Dates:
January 1, 2016, through March 31, 2016
Inspectors:
N. Perry, Senior Resident Inspector
J. Petch, Resident Inspector
H. Anagnostopoulos, Health Physicist
A. Siwy, Project Engineer
Approved by:
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects
SUMMARY
Inspection Report 05000244/2016001; 01/01/2016 - 03/31/2016; Ginna; Routine Integrated
Inspection Report.
This report covered a 3-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. No findings were identified. The U.S. Nuclear Regulatory Commissions (NRCs) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Other Findings
A violation of very low safety significance that was identified by Exelon was reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program (CAP). This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Ginna began the inspection period operating at 100 percent power and remained at or near 100 percent power for the entire inspection 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 Exelons readiness for the onset of seasonal cold temperatures on February 11 and 12, 2016. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the screen house, the turbine building, intermediate building, standby auxiliary building, and the auxiliary building. The inspectors verified that operator actions defined in Exelons 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 service water (SW) loop on January 22, 2016
D standby auxiliary feedwater (AFW) system on February 2, 2016
Diesel fire pump on March 29 & 30, 2016
NaOH and containment spray system on March 30, 2016
Safety injection system on March 31, 2016
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), action requests (ARs), 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 determine if 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 Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On March 3, 2016, the inspectors performed a complete system walkdown of accessible portions of the B AFW 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 as-built system configuration matched plant documentation, and that system components and support equipment remained operable. The inspectors confirmed that systems and components were aligned correctly, free from interference from temporary services or isolation boundaries, environmentally qualified, and protected from external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related ARs and work orders to ensure Exelon 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 Exelon 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.
Technical support center on January 12, 2016
Cable tunnel on January 28, 2016
Auxiliary building operating floor on February 5, 2016
Intermediate building controlled side operating floor on February 7, 2016
A battery room on February 10, 2016
Intermediate building cold operating levels March 23, 2016
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors observed a fire brigade drill scenario conducted on January 20, 2016, that involved a fire in the air handling room. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Exelon personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated the following specific attributes of the drill:
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 Exelons fire-fighting strategies.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Annual Review of Cables Located in Underground Bunkers/Manholes
a. Inspection Scope
The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could affect risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including manhole MH-1A containing offsite power cables from the start-up transformer, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged.
The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed.
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 February 2, 2016, which included a condensate booster pump trip and loss of offsite power during the resulting reduction in power. 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 unit 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 unit supervisor. 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 the down power for turbine-driven AFW testing and control board annunciator repair and testing on March 9, 2016. The inspectors observed pre-job briefings and reactivity control briefings to verify that the briefings met the criteria specified in procedure HU-AA-1211, Pre-Job Briefings, Revision 011.
Additionally, the inspectors observed test performance 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 samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by Exelon staff were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2).
Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Fire protection on January 15, 2016
A emergency diesel generator (EDG) on February 18, 2016
b. Findings
No findings were identified.
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 Exelon 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 Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon 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 11, 2016
Planned maintenance on the B SW loop and C SW pump motor on January 21, 2016
Unplanned maintenance on the 12A transformer on February 18, 2016
Emergent maintenance on the station air compressors on March 14 and 15, 2016
Planned maintenance on fire suppression system S08 on March 25, 2016
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 based on the risk significance of the associated components and systems:
B EDG starters and contactors potential defect on February 26, 2016
Standby AFW suction relief valves weeping on March 15, 2016
Component cooling water heat exchanger SW minimum wall thickness on March 24, 2016
Emergency buses breakers potential failure to close on March 24, 2016
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 with Exelons evaluations to determine whether the components or systems were operable. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. 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 Exelon.
b. Findings
No findings were identified.
1R18 Plant Modifications
Permanent Modifications
a. Inspection Scope
The inspectors evaluated two related modifications to the turbine-driven AFW pump and one modification to the staircase tower block wall in the intermediate building. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modifications.
For the turbine-driven AFW modifications, the inspectors reviewed modification documents associated with the upgrade and design change that included the installation of two separate support brackets. Vibrations recorded on the turbine outer bearing housing rose to unacceptable levels following the turbine over-speed trip post-maintenance testing on November 16, 2015. To lower vibrations, one bracket was used to provide support to the outer turbine bearing housing and a second bracket for the low oil pressure trip device. After completion of the modifications, vibrations were lowered to acceptable levels.
For the intermediate building, staircase tower, block wall modification, the inspectors evaluated a structural modification to a fire barrier block wall on the inside of the staircase between the intermediate building cold side and the turbine building. The inspectors reviewed modification documents associated with the upgrade and design change that included the installation of a steel plate. In addition, the inspectors performed a walkdown of block walls in the vicinity to verify that no other sections of wall were affected.
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 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 test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post job critique where possible, confirmed that work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold points were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.
Bus 17/18 tie breaker planned maintenance on January 28, 2016
D standby AFW motor planned maintenance on February 1, 2016
A spent fuel pool (SFP) pump planned maintenance on February 9, 2016
Deluge system valve unplanned maintenance on February 19, 2016
B5B fire pump planned maintenance on February 26, 2016
B AFW pump valve V-4032 planned replacement on March 1, 2016
B flex pump annual maintenance on March 2, 2016
Motor-driven fire pump planned maintenance on March 31, 2016
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 Exelon 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 7, 2016
STP-I-9.1.14, Undervoltage Protection - 480 Volt Safeguard Bus 14 on January 14, 2016
STP-O-2.7.1B, Loop B Service Water Pump Test on January 21, 2016 (inservice testing)
STP-O-12.2, Emergency Diesel Generator B on February 2, 2016
STP-O-40.6, Standby AFW and NFPA [National Fire Protection Association] Diesel Generators (KDG08/KDG09) Pre-Startup Alignment on February 9, 2016
STP-O-36R, Valve 9786 Operability Verification on February 19, 2016
STP-O-22.16, Local Leak Rate Test of Mechanical Manifold J on February 22, 2016 (isolation valve)
STP-E-10.2, Station Battery B Monthly Surveillance on March 1, 2016
STP-O-16-COMP-T, Auxiliary Feedwater Turbine Pump - Comprehensive Test on March 9, 2016 (inservice testing)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine Exelon emergency preparedness drill on January 26, 2016, 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, technical support center, 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 Exelon staff in order to evaluate Exelons critique and to verify whether Exelon was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety and Occupational Radiation Safety
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors reviewed the control of in-plant airborne radioactivity and the use of respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR Part 20, Standards for Protection Against Radiation; NUREG/CR-0041, Manual of Respiratory Protection Against Airborne Radioactive Material; regulatory guides; TS; and procedures required by TS as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring systems associated with airborne radioactivity controls and respiratory protection equipment staged for emergency use. The inspectors also reviewed respiratory protection program procedures and current performance indicators for unintended internal exposure incidents.
Engineering Controls (1 sample)
The inspectors reviewed operability and use of both permanent and temporary ventilation systems, and the adequacy of airborne radioactivity radiation monitoring in the plant based on location, sensitivity, and alarm setpoints.
Use of Respiratory Protection Devices (1 sample)
The inspectors reviewed the adequacy of Exelons use of respiratory protection devices in the plant to include applicable as low as reasonably achievable (ALARA) evaluations, respiratory protection device certification, respiratory equipment storage, air quality testing records, and individual qualification records.
SCBA for Emergency Use (1 sample)
The inspectors reviewed the status and surveillance records for three SCBAs staged in-plant for use during emergencies; Exelons SCBA procedures and maintenance and test records; the refilling and transporting of SCBA air bottles; SCBA mask size availability; and the qualifications of personnel performing service and repair of this equipment.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were identified at an appropriate threshold and addressed by Exelons CAP.
The inspectors performed a follow-up observation of an item of concern from the previous inspection using Inspection Procedure 71124.03, In-Plant Airborne Radioactivity Control and Mitigation. This issue was documented in condition report (CR)-2014-001525. This review was to verify that Exelon appropriately identified the issue, properly assessed the cause(s), and performed adequate corrective actions to address the concern.
b. Findings and Observations
No findings were identified.
In CR-2014-001525, generated on March 21, 2014, Exelon identified that a design analysis (DA-ME-94-050) was performed in 1994 to study air movements and to provide a design basis for the placement of continuous air monitors (CAMs) in the auxiliary building. The CR indicated that the analysis had not been updated and that there had been some changes to the auxiliary building that had not been reflected in the design analysis. This appropriately identified the issue of concern.
The CR was closed on April 14, 2014. The evaluation comments section of the CR stated the Engineering Subject Matter Expert (SME) was consulted on this issue and determined that there are no impacts of plant changes on the conclusions of the design analysis. Therefore, this CR shall be closed with no further action. This assessment was further reviewed during the current inspection period. On March 23, 2016, the inspectors conducted a walkdown of auxiliary building ventilation systems with a system engineer. The engineer pointed out several modifications from the initial, as-built plant ventilation design. These included several modifications to the operating floor area near the SFP that were needed to support dry spent fuel storage operations. These modifications occurred after the 1994 design analysis and included the installation of a very large roll-up door near the SFP, the re-routing of ventilation ductwork near the SFP, and the installation of large metal and Plexiglas walls around the SFP. The inspectors also observed a CAM that was placed on the operating floor, near the new roll-up door, and outside of the SFP Plexiglas walls.
Upon completion of the walkdown, the inspectors met with engineering and radiation protection staff to determine whether the modifications around the SFP had the potential to impact airflow movements on the operating floor and, therefore, also impact the proper placement and operation of the nearby CAM that was specifically described and evaluated in the 1994 design analysis. Exelon generated AR 02645098 on March 24, 2016, to evaluate this condition. The inspectors questioned whether the closure of the original CR adequately described the plant changes since the 1994 design analysis and whether it provided an adequate basis for why the changes did not have an impact.
Exelon generated AR 02645327 on March 25, 2016, to re-evaluate the closure of the original CR. The NRC review indicated that the original cause assessment was not comprehensive and that, consequently, no corrective actions were originally assigned.
However, the inspectors noted there was no violation of NRC regulatory requirements.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors reviewed the monitoring, assessment, and reporting of occupational dose. The inspectors used the requirements in 10 CFR Part 20; regulatory guides; TSs; and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed radiation protection program audits, National Voluntary Laboratory Accreditation Program (NVLAP) dosimetry testing reports, and procedures associated with dosimetry operations.
Source Term Characterization (1 sample)
The inspectors reviewed the plant radiation characterization (including gamma, beta, alpha, and neutron) being monitored. The inspectors verified the use of scaling factors to account for hard-to-detect radionuclides in internal dose assessments.
External Dosimetry (1 sample)
The inspectors reviewed dosimetry NVLAP accreditation, onsite storage of dosimeters, the use of correction factors to align electronic personal dosimeter results with NVLAP dosimetry results, dosimetry occurrence reports, and CAP documents for adverse trends related to external dosimetry.
Internal Dosimetry (1 sample)
The inspectors reviewed internal dosimetry procedures, whole body counter measurement sensitivity and use, adequacy of the program for whole body count monitoring of plant radionuclides, adequacy of the program for dose assessments based on air sample monitoring and the use of respiratory protection, and internal dose assessments for any actual internal exposure.
Special Dosimetry Situations (1 sample)
The inspectors reviewed Exelons worker notification of the risks of radiation exposure to the embryo/fetus, the dosimetry monitoring program for declared pregnant workers, external dose monitoring of workers in large dose rate gradient environments, and dose assessments performed since the last inspection that used multi-badging, skin dose, or neutron dose assessments.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with occupational dose assessment were identified at an appropriate threshold and properly addressed in the CAP.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Unplanned Scrams, Unplanned Power Changes, and Unplanned Scrams with Complications
a. Inspection Scope
The inspectors reviewed Exelons submittals for the following Initiating Events cornerstone performance indicators for the period of January 1 through December 31, 2015:
Unplanned Scrams (IE01)
Unplanned Power Changes (IE03)
Unplanned Scrams with Complications (IE04)
To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed Exelons 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
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 Exelon 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 AR screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Exelon performed an evaluation in accordance with 10 CFR Part 21, Reporting of Defects and Noncompliance.
b. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
Plant Event
a. Inspection Scope
For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in Inspection Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors, issued October 28, 2011, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the event to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.
12A transformer failure on February 11, 2016
b. Findings
No findings were identified.
4OA5 Other Activities
World Association of Nuclear Operators (WANO) Report Review
a. Inspection Scope
The inspectors reviewed the final report for the WANO plant assessment of Ginna conducted in May 2015. The inspectors evaluated this report to ensure that NRC perspectives of Exelon performance were consistent with any issues identified during the assessments. The inspectors also reviewed these reports to determine whether WANO identified any significant safety issues that required further NRC follow-up.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On April 13, 2016, the inspectors presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the Ginna staff. The inspectors verified that no propriety information was retained by the inspectors or documented in this report.
4OA7 Licensee-Identified Violation
The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation.
Title 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities.Section IV.B.1 of 10 CFR 50, Appendix E, requires, in part, that the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of State and local agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. Contrary to the above, prior to January 7, 2016, Exelon procedure EP-AA-110-203, GNP Dose Assessment, Revision 003, did not consider the possibility of two different flow rate values through the plant vent.
The plant vent has the capability to flow through filters when new fuel assemblies are added to the SFP resulting in the potential for two different flow rates out the ventone with the filters in service (69074 cubic feet per minute) and one without the filters in service (50560 cubic feet per minute). Due to the error, during certain events, Exelon would have inappropriately determined the event contaminant release rate to be higher than actual, resulting in the early declaration of an emergency action level. Upon identification, Exelon entered this into its CAP as AR 02609057 and implemented dose assessment compensatory measures to be used in EP-AA-110-203, Attachment 7, Ventilation Systems Flow Rates, table data. The inspectors determined the finding was of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 22, 2015, because a deficient emergency classification process which would result in an overclassification, but would not result in unnecessary public protective measures should be considered Green.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Pacher, Site Vice President
- W. Carsky, Plant Manager
- D. Blankenship, Director, Site Operations
- R. Everett, Director, Site Engineering
- K. Garnish, Senior Manager, Operations Support and Services
- K. Gould, Manager, Radiation Protection
- T. Harding, Manager, Site Regulatory Assurance
- S. Holmes, Radiological Engineering Supervisor
- J. Jackson, Director, Emergency Preparedness
- P. Swift, Director, Site Work Management
- J. Wells, Maintenance & Technical Training Manager
- S. Wihlen, Director, Site Maintenance
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
None.