IR 05000244/2016002

LLC - Integrated Inspection Report 05000244/2016002 with Preliminary White Finding, and Independent Spent Fuel Storage Installation Report 07200067/2016001

ML16232A051
Person / Time
Site:	Ginna
Issue date:	08/18/2016
From:	Michael Scott Division Reactor Projects I
To:	Bryan Hanson Exelon Generation Co
References
EA-16-128 IR 2016001, IR 2016002
Download: ML16232A051 (34)

Text

ust 18, 2016

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2016002 WITH PRELIMINARY WHITE FINDING, AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07200067/2016001

Dear Mr. Hanson:

On June 30, 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 July 12, 2016, with Mr. Joseph Pacher, Site Vice President, and other members of the Ginna staff.

The enclosed inspection report discusses a finding that has preliminarily been determined to be a White finding with low to moderate safety significance that may require additional inspections, regulatory actions, and oversight. As described in Section 1EP4 of the enclosed report, the finding is associated with an apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2), Emergency Plans, because Exelon Generation Company, LLC (Exelon)

did not maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and the planning standards of 10 CFR 50.47(b). Specifically, Exelon implemented a revision to the emergency action level (EAL) table for the fission product barrier matrix that was incorrect with respect to the EAL threshold associated with potential loss of containment barrier.

This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event. This finding was assessed based on the best available information, using the NRCs Significance Determination Process (SDP). The basis for the NRCs preliminary significance determination is described in the enclosed report. Because the finding is also an apparent violation of NRC requirements, it is being considered for escalated enforcement action in accordance with the Enforcement Policy, which appears on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The NRC will inform you in writing when the final significance has been determined. We intend to complete and issue our final safety significance determination within 90 days from the date of this letter. The NRCs SDP is designed to encourage an open dialogue between your staff and the NRC; however, the dialogue should not affect the timeliness of our final determination.

We believe that we have sufficient information to make a final significance determination.

However, before we make a final decision, we are providing you an opportunity to provide your perspective on this matter, including the significance, causes and corrective actions, as well as any other information that you believe the NRC should take into consideration. Accordingly, you may notify us of your decision within 10 days to: (1) attend a regulatory conference where you can present to the NRC your point of view on the facts and assumptions used to arrive at the finding and assess its significance; (2) submit your position on the finding to the NRC in writing, or (3) accept the finding as characterized in the enclosed report. If you request a regulatory conference, it should be held within 30 days of your receipt of this letter. We encourage you to submit supporting documentation at least one week prior to the conference, in an effort to make the conference more efficient and effective. If you choose to attend a regulatory conference, it will be open for public observation. The NRC will issue a public meeting notice and press release to announce the conference. If you decide to submit only a written response, it should be sent to the NRC within 30 days of your receipt of this letter. If you choose not to request a regulatory conference or to submit a written response, The NRC will proceed with its regulatory decision, however, you will not be allowed to appeal the NRCs final significance determination.

Please contact Anthony Dimitriadis at (610) 337-6953 within 10 days from the issue date of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision. Because the NRC has not made a final determination in this matter, no notice of violation is being issued for this inspection finding at this time. In addition, please be advised that the number and characterization of the apparent violation may change based on further NRC review.

In addition, the enclosed inspection report documents one self-revealing Severity Level IV violation under the traditional enforcement process. 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 addition, if you disagree with the cross-cutting aspect assignment 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 Inspectors at Ginna. In accordance with 10 CFR 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 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/

Michael L. Scott Director Division of Reactor Projects Docket Nos. 50-244 and 72-067 License No. DPR-18

Enclosure:

Inspection Report 05000244/2016002 and 07200067/2016001 w/Attachment: Supplementary Information

REGION I==

Docket Nos. 50-244 and 72-067 License No. DPR-18 Report Nos. 05000244/2016002 and 07200067/2016001 Licensee: Exelon Generation Company, LLC (Exelon)

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

Location: Ontario, New York Dates: April 1, 2016 through June 30, 2016 Inspectors: N. Perry, Senior Resident Inspector J. Petch, Resident Inspector B. DeBoer, Health Physicist J. Furia, Senior Health Physicist J. Nicholson, Senior Health Physicist Approved by: Michael L. Scott Director Division of Reactor Projects Enclosure

SUMMARY

Inspection Report 05000244/2016002 and Independent Spent Fuel Storage Installation (ISFSI)

Report 07200067/2016001; 04/01/2016 - 06/30/2016; Ginna; Emergency Action Level and Emergency Plan Changes; Other Activities.

This report covered a 3-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors reviewed a preliminary White finding associated with an apparent violation. Additionally, the inspectors identified one self-revealing traditional enforcement Severity Level IV non-cited violation (NCV). 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, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, issued December 4, 2014. All violations of U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 5.

Cornerstone: Emergency Preparedness

Preliminary

White.

Exelon identified that they had inadvertently made a change to the Ginna Emergency Plan. The NRC determined that this error is a preliminary White finding under the Reactor Oversight Process and a violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54 (q)(2), Emergency Plans, because Exelon did not maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and the planning standards of 10 CFR 50.47(b). Specifically, Exelon implemented a revision to the emergency action level (EAL) table for the fission product barrier matrix that was incorrect with respect to the EAL threshold associated with potential loss of containment barrier. This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event.

Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely affected the associated 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, Exelons EAL table was revised without adequate technical reviews resulting in a discrepancy between the EAL table and the EAL technical basis. The EAL wording of Table F-1 containment barrier potential loss, block C.6 did not meet the minimum required operable equipment in all situations and could have resulted in a delayed General Emergency declaration or a failure to declare a Site Area Emergency.

The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process [SDP], to determine the significance of the performance deficiency.

The performance deficiency is associated with the emergency classification system planning standard and is considered a risk-significant planning standard function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47 (b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. In accordance with Section 5.4, when an EAL has been rendered ineffective such that any General Emergency declaration would not be declared, but due to other EALs, an appropriate declaration would be made in a degraded manner or any Site Area Emergency would not be declared for a particular off-normal event, a degradation of risk-significant planning standard function (b)(4) is determined; and the finding is

White.

The finding has a cross-cutting aspect in the area of Human Performance,

Change Management, because Exelon did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically,

Exelon did not maintain a clear focus on nuclear safety when implementing changes to the EALs resulting in a significant unintended consequence, the potential to make an untimely emergency declaration. [H.3] (Section 1EP4)

Miscellaneous Severity Level IV. A self-revealing Severity Level IV NCV of 10 CFR 72.150, Instructions,

Procedures, and Drawings, was identified when Exelon failed to maintain positive helium pressure during bulk water removal from a loaded spent fuel canister on May 25, 2016.

Specifically, site procedure GMM-24-02-ISFSI01A, ISFSI Operations Using Areva Equipment, did not provide a method of monitoring the pressure in the dry shielded canister (DSC) to ensure that a slight helium overpressure on the DSC was present. As a result, the DSC was unexpectedly exposed to a negative pressure for approximately 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> causing an unplanned entry into Technical Specification (TS) 1.2.17a of the general license for Transnuclears standardized NUHOMS horizontal storage modular storage system, certificate of compliance (COC) 1004, Amendment 10, 32PT DSC Vacuum Drying Duration Limit. Negative pressure is not allowed during these operations because it could, potentially, overly stress the fuel pins. Corrective actions included entering the condition into the corrective action program (CAP), developing and executing a detailed work plan returning the DSC to a positive pressure within the 31 hour3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> TS limit, and revising the procedure.

In accordance with 10 CFR 72.150, the inspectors determined that Exelon did not have adequate instructions and procedures to ensure that a slight helium overpressure was maintained on the DSC during bulk water removal on May 25. As a result, the DSC was unexpectedly exposed to a negative pressure for approximately 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> and TS 1.2.17a was entered. Because the issue involved independent spent fuel storage installation (ISFSI)operations, consistent with the guidance in Section 2.2 of the NRC Enforcement Policy, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using Example 6.3.d.3 from the NRC Enforcement Policy, the inspectors determined that the violation was a Severity Level IV violation. Because this violation involves the traditional enforcement process and was not associated with ISFSI support programs conducted under a 10 CFR 50 license, the inspectors did not assign a cross-cutting aspect to this violation. (Section 4OA5)

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

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors reviewed Exelons readiness for the onset of seasonal high temperatures. The review focused on the relay room, the main feed pump room, the screen house, the technical support center, station 13A, and the emergency diesel generators (EDGs). The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), TSs, control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Exelon personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Exelons seasonal weather preparation procedures and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during hot weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power systems to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Exelons procedures affecting these areas and the communications protocols between the transmission system operator and Exelon. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Exelon established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing electricians, reviewing action requests (ARs), and walking down portions of the offsite and AC power systems including the station 13A switchyard.

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:

A spent fuel pool (SFP) cooling on April 22, 2016 C charging pump on May 4, 2016 Turbine-driven auxiliary feedwater (AFW) following quarterly surveillance testing on May 26, 2016 Component cooling water (CCW) after surveillance testing on June 2, 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 UFSAR, TSs, work orders (WOs), 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.

1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 6 samples)

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.

Screen house building basement on April 21, 2016 Water treatment room on April 28, 2016 Air handling room on May 6, 2016 Control room on May 24, 2016 Standby AFW building and annex on May 27, 2016 Intermediate building radiological side operations floor on June 22, 2016

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to identify internal flooding susceptibilities for the site. The inspectors review focused on the circulating water and condenser pit areas. The inspectors verified the adequacy of equipment seals located below the flood line, floor and water penetration seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and Garlock flexible pipe connections. The inspectors assessed the adequacy of operator actions that Exelon had identified as necessary to cope with flooding in these areas and also reviewed the CAP to determine if Exelon was identifying and correcting problems associated with both flood mitigation features and site procedures for responding to flooding.

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

On June 14, 2016, the inspectors observed licensed operator simulator training which included failed fuel, a loss of heat sink, and an Alert declaration and a Site Area Emergency declaration. 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

On May 25, 2016, the inspectors observed and reviewed a power reduction, and turbine-driven AFW surveillance test. The inspectors observed the control room briefings to verify the briefings were in accordance with Exelons administrative procedure HU-AA-1211, Pre-Job Briefings, Revision 010. Additionally, the inspectors verified 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, maintenance WOs, maintenance rule expert panel minutes, 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 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.

Maintenance rule (a)(3) evaluation on May 2, 2016 12A transformer in (a)(2) on June 9, 2016 Main steam in (a)(1) on June 30, 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 B CCW heat exchanger and the C charging pump on May 2 and 3, 2016 Planned maintenance on the B EDG on May 6, 2016 Planned maintenance on the A EDG on May 19, 2016 Planned maintenance on the diesel fire pump on June 8, 2016 Unplanned maintenance on the A residual heat removal (RHR) pump on June 17, 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:

Westinghouse SFP analysis on April 15, 2016 Station service transformer 14 fuse 3B drawing high current on April 29, 2016 A RHR pump increased seal leakage immediate operability determination on June 16, 2016 Ammonia detector change from 7-day to 30-day technical requirement on June 20, 2016 Safety injection system check valve low differential pressure on June 22, 2016 Ammonia detector restoration to full functionality after extended period of maintenance on June 30, 2016 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 Exelons 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 Exelon. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Temporary Modification

a. Inspection Scope

The inspectors reviewed temporary modification Engineering Change Package (ECP)15-000125, Engineering Evaluation of Retention Tank Bypass Procedurally Controlled Temporary Configuration Change, Revision 0000, 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 modification 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.

.2 Permanent Modification

a. Inspection Scope

The inspectors evaluated a modification to the safety-related bus 14 and bus 16 station service transformer fans. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change that included reconfiguring the power such that each of the three cooling fan motors per bus were fused independently such that a failure or fault on a single fan will not result in a simultaneous loss of power to all three fans. The inspectors also interviewed engineering personnel to determine if the modification was installed and operating as designed.

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 appropriate 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.

ISFSI fuel handling tool planned maintenance on April 28, 2016 C charging flex line replacement on May 3, 2016 B EDG planned maintenance on May 7, 2016 A EDG planned maintenance on May 19, 2016 Diesel fire pump planned maintenance on June 8, 2016 A RHR pump emergent maintenance on June 19, 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-27.2, Tendon Surveillance Program on April 4, 2016 STP-O-13.11.19, Smoke Detector Testing Zone Z02 on April 12, 2016 STP-O-13.4.1, B5B Fire Pump Annual Flow Test on April 24, 2016 CH-PRI-SAMP-SPECIAL, Liquid Sampling Outside Nuclear Sample Room on May 4, 2016 STP-O-16QT, Auxiliary Feedwater Turbine Pump - Quarterly on May 25, 2016 (inservice test)

S-12.4, RCS [Reactor Coolant System] Leakage Surveillance Record Instructions on June 2, 2016

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Exelon implemented various changes to Ginnas EALs, Emergency Plan, and implementing procedures. Exelon determined that, in accordance with 10 CFR 50.54(q)(3), changes 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, Emergency Planning and Preparedness for Production and Utilization Facilities.

The inspectors performed a review of EAL and Emergency Plan changes submitted by Exelon as required by 10 CFR 50.54(q)(5), to evaluate for any potential reductions in effectiveness of the 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) Emergency Plans, were used as reference criteria.

b. Findings

Introduction.

Exelon identified that they had inadvertently made a change to the Ginna Emergency Plan. The NRC determined that this error is a preliminary White finding under the Reactor Oversight Process and a violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54 (q)(2), Emergency Plans, because Exelon did not maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and the planning standards of 10 CFR 50.47(b). Specifically, Exelon implemented a revision to the emergency action level (EAL) table for the fission product barrier matrix that was incorrect with respect to the EAL threshold associated with potential loss of containment barrier. This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event.

Description.

In February 2008, Ginna began the process of transitioning to Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 5, by commissioning a contractor to prepare the new EALs in accordance with NEI 99-01. The EAL-TECHBASIS, EAL Technical Basis, Revision 04800, became effective on November 22, 2010. Section 4.0, Containment, provides the minimum heat removal equipment required to maintain containment operability. For containment pressures > 28 pounds per square inch gauge (psig), a minimum of two containment recirculation fan cooler (CRFC) units and one containment spray (CS) pump are required.

Using the revised EAL technical basis, the Exelon staff compared the Ginna wording and the NEI initiating conditions on EAL Table F-1, block C.6 for potential loss of containment barrier. The table wording was changed to include a < symbol as follows:

Containment pressure > 28 psig and < two CRFC units and one CS pump. On December 23, 2013, the wording in Table F-1 was again changed such that the new wording was as follows: Containment pressure > 28 psig AND < two CRFC units AND

< one CS pump operating per design. This change to Table F-1 was developed based on comments from a prior training class to better clarify that the < symbol applied to both the two CRFC units and one CS pump. The resolution to the comment was to add a < symbol before the one CS pump. The change was considered to be for clarification only.

The inaccuracy with Table F-1 was discovered during development of a training scenario on April 22, 2016. In the training scenario development process, a shift manager typically reviews the proposed scenario. It was during this review that a shift manager discovered the inaccurate wording of EAL Table F-1. Upon discovery, the shift manager consulted the EAL technical basis document and verified that the statement in the containment barrier potential loss, block C.6, was inconsistent with the EAL technical basis document. The EAL technical basis specifies that a minimum of two CRFC units and one CS pump are required. The statement as written on the EAL Table F-1 would not account for a situation where > two CRFC units are operating but zero CS pumps are operating or > one CS operating and < two CRFC units are operating. The emergency directors are not required to refer to EAL technical basis when making an EAL declaration.

The impact of the error is a potential delay or failure to identify a potential loss of containment barrier. Using the fission product barrier matrix criteria, any loss or any potential loss of containment results in a Notice of Unusual Event. The loss or potential loss of any two fission product barriers results in a Site Area Emergency. The loss of any two fission product barriers and loss or potential loss of the third barrier results in a General Emergency. Thus for certain initiating conditions, such as a loss-of-coolant accident (LOCA) or a steam line break inside containment, the criterion in block C.6 is the primary indication of a potential loss of containment because it represents a high containment pressure and less than adequate containment heat removal capabilities to ensure design limits will not be exceeded. This is likely the first potential loss of containment criterion met for these initiating conditions. As such, the appropriate emergency declaration would likely have been delayed until a subsequent loss or potential loss of containment criterion is met or an alternate General Emergency/Site Area Emergency criterion is met. As a result, the declaration could be untimely for a General Emergency thus delaying issuance of protective action recommendations to ensure public health and safety. For certain initiating conditions, such as a medium break LOCA with no fuel damage, a Site Area Emergency may not be declared at all even if one is warranted.

On April 22, 2016, Exelon issued a standing order to inform plant personnel of the EAL table wording discrepancy. The standing order stated that the EAL table incorrectly interprets plant-specific basis information, and the language in the plant-specific technical basis is correct. The standing order provided some additional clarity on the minimum number of operating equipment required. Subsequently, Exelon revised EP-AA-1012 Addendum 3, Emergency Action Levels for Ginna Station, with the new EAL table wording as follows: Containment > 28 psig AND either of the following conditions: < 2 CRFC units operating <1 CS pump operating.

Analysis.

Exelons failure to maintain Ginnas Emergency Plan in accordance with the requirements of 10 CFR 50.54(q) is a performance deficiency that was within Exelons ability to foresee and correct and should have been prevented. Specifically, on December 23, 2013, a change to Ginnas EAL Table F-1 was made resulting in a potential effect on the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an EAL has been exceeded. Exelon implemented a revision to the EAL table for the fission product barrier matrix that was inconsistent with respect to the EAL threshold associated with potential loss of containment barrier, as defined in the EAL technical basis. This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event.

Using IMC 0612, Appendix B, Issue Screening, issued September 7, 2012, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely affected the associated 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, Exelons EAL table was revised without the adequate technical reviews resulting in a discrepancy between the EAL table and the EAL technical basis. The EAL table wording of Table F-1 containment barrier potential loss, block C.6 did not direct actions consistent with the minimum required operable equipment in all situations and could have resulted in a delayed General Emergency declaration or a failure to declare a Site Area Emergency.

The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process [SDP], issued September 22, 2015, to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification system planning standard and is considered a risk-significant planning standard function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47 (b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. In accordance with Section 5.4, when an EAL has been rendered ineffective such that any General Emergency declaration would not be declared, but due to other EALs, an appropriate declaration would be made in a degraded manner or any Site Area Emergency would not be declared for a particular off-normal event, a degradation of risk-significant planning standard function (b)(4) is determined; and the finding is White. This significance determination is preliminary. In accordance with IMC 0310, Aspects Within the Cross-Cutting Areas, issued December 4, 2014, the finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

Specifically, Exelon did not maintain a clear focus on nuclear safety when implementing changes to the EALs resulting in a significant unintended consequence, the potential to make an untimely emergency declaration [H.3]. This assigned cross-cutting aspect is dependent on the final significance determination being White.

Enforcement.

10 CFR 50.54(q)(2) requires that a holder of a license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part; and for nuclear power reactor licensees, the planning standards of § 50.47(b).

10 CFR 50.47(b)(4) requires that a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.

Appendix E, Section IV.C.2, requires that nuclear reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an EAL has been exceeded and shall promptly declare the emergency condition as soon as possible following indication of the appropriate emergency classification level.

Contrary to the above, from December 23, 2013, until April 22, 2016, Exelon did not maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E and the planning standards of 10 CFR 50.47(b). Specifically, Exelon did not use an emergency classification and action level scheme that maintained the licensees capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an EAL has been exceeded. This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event. Exelon implemented a revision to the EAL table for the fission product barrier matrix that was incorrect with respect to the EAL threshold associated with potential loss of containment barrier. Immediate corrective actions included Exelon entering this issue into its CAP (AR 02659732) and issuing a standing order to inform plant personnel of the EAL table wording discrepancy. In accordance with IMC 0612 and the NRC Enforcement Policy, the issue was preliminarily determined to be a White finding. This violation is being treated as an apparent violation pending a final significance determination.

(AV 5000244/2016002-01, Incorrect Emergency Action Level Table)

1EP6 Drill Evaluation

Training Observations

a. Inspection Scope

On June 21, 2016, the inspectors observed a simulator training evolution for Exelon licensed operators which required Emergency Plan implementation by an operations crew. Exelon planned for this evolution to be evaluated and included in performance indicator (PI) data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that Exelon evaluators noted the same issues and entered them in the CAP.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation (71124.08 - 6 samples)

a. Inspection Scope

The inspectors verified the effectiveness of Exelons programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 49 CFR Parts 170 through 177; 10 CFR Parts 20, 37, 61, and 71; applicable industry standards; regulatory guides; and procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors conducted an in-office review of the solid radioactive waste system description in the UFSAR, the process control program, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed. The inspectors reviewed the scope of quality assurance audits performed for this area since the last inspection.

Radioactive Material Storage (1 sample)

The inspectors observed radioactive waste container storage areas and verified that Exelon had established a process for monitoring the impact of long-term storage of the waste.

Radioactive Waste System Walkdown (1 sample)

The inspectors walked down the following and evaluated:

Accessible portions of liquid and solid radioactive waste processing systems to verify current system alignment and material condition Abandoned in place radioactive waste processing equipment to review the controls in place to ensure protection of personnel Changes made to the radioactive waste processing systems since the last inspection Processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers Current methods and procedures for dewatering waste

Waste Characterization and Classification (1 sample)

The inspectors identified radioactive waste streams and reviewed radiochemical sample analysis results to support radioactive waste characterization. The inspectors reviewed the use of scaling factors and calculations to account for difficult-to-measure radionuclides.

Shipment Preparation (1 sample)

The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness.

Shipping Records (1 sample)

The inspectors reviewed selected non-excepted package shipment records.

Problem Identification and Resolution (1 sample)

The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation were identified at an appropriate threshold and properly addressed in Exelons CAP.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Safety System Functional Failures (1 sample)

a. Inspection Scope

The inspectors sampled Exelons submittals for the Safety System Functional Failures (MS05) PI for the period of April 1, 2015, through March 31, 2016. 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; and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed Exelons operator narrative logs, operability assessments, maintenance rule records, maintenance WOs, ARs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Reactor Coolant System Specific Activity and Reactor Coolant System Leak Rate

(2 samples)

a. Inspection Scope

The inspectors reviewed Exelons submittal for the RCS specific activity (BI01) and RCS leak rate (BI02) PIs for the period of April 1, 2015, through March 31, 2016. To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in NEI 99-02, Revision 7. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the PI. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing an RCS sample.

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 Defects and Noncompliance.

b. Findings

No findings were identified.

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

(Closed) Licensee Event Report (LER) 05000244/2016-001-00: Loss of Station Auxiliary Transformer 12A Resulting in Automatic Start of Emergency Diesel Generator A due to Undervoltage Signals to Safeguards Buses 14 and 18 On February 11, 2016, Ginna experienced a loss of station auxiliary transformer 12A causing EDG A to automatically start due to undervoltage signals to safeguard bus 14 and bus 18. After the event, the inspectors reviewed the response of the plant and of the operators. No abnormalities were identified, and the inspectors did not identify any new issues during the review of the LER. This LER is closed.

4OA5 Other Activities

Operation of an ISFSI at Operating Plants (60855, 60855.1)

a. Inspection Scope

From May 23 to 27, 2016, the inspectors observed and evaluated Exelons loading of DSC-7, the first of four spent fuel canisters scheduled to be loaded during Exelons ISFSI dry cask campaign. The inspectors also reviewed Exelons activities related to long-term operation and monitoring of their ISFSI. The inspectors evaluated compliance with the COC, TSs, regulations, and licensee procedures.

The inspectors observed the heavy load movement of the transfer cask and the empty DSC to the SFP and loading of spent fuel assemblies into the DSC-7. Inspectors also observed other cask processing operations including welding of the DSC inner top cover, nondestructive examination of the lid weld, vacuum drying, and surveying. During performance of these activities, the inspectors verified that procedure use, communication, and coordination of ISFSI activities met established standards and requirements. The inspectors attended Exelon briefings to assess their ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent errors. The inspectors reviewed loading and monitoring procedures and evaluated Exelons adherence to these procedures. The inspectors also reviewed the training of personnel assigned to ISFSI activities.

The inspectors reviewed Exelons program associated with fuel characterization and selection for storage. The inspectors reviewed cask fuel selection packages to verify that Exelon was loading fuel in accordance with the COC, TSs, and procedures. The inspectors confirmed that Exelon did not plan to load any damaged fuel assemblies during this campaign. The inspectors reviewed recordings made of the fuel assemblies loaded into DSC-7 to ensure the loading was in accordance with Exelons loading plan.

The inspectors reviewed radiation protection procedures and radiation work permits associated with the ISFSI loading campaign. The inspectors observed radiation protection technicians as they provided job coverage for the cask loading workers. The inspectors reviewed survey data maps and radiological records from the DSC loading to confirm that measured radiation survey levels were within limits specified by the TSs and consistent with values specified in the final safety analysis report.

The inspectors performed a walkdown of the heavy haul path and ISFSI pad to assess the material condition of the path, pad, and the loaded horizontal storage modules. The inspectors also verified that transient combustibles were not being stored on the haul path, ISFSI pad, or in the vicinity of the horizontal storage modules. The inspectors also confirmed that transient combustible material entry onto the ISFSI pad was controlled in accordance with procedures.

The inspectors reviewed the CAP, ARs, audit reports, and self-assessments that were generated since Exelons last loading campaign to ensure that issues were being properly identified, prioritized, and evaluated commensurate with their safety significance.

b. Findings

Introduction.

A self-revealing Severity Level IV NCV of 10 CFR 72.150, Instructions, Procedures, and Drawings, was identified when Exelon failed to maintain a positive helium pressure during bulk water removal on May 25, 2016. Specifically, site procedure GMM-24-02-ISFSI01A, ISFSI Operations Using Areva Equipment, Revision 00000, did not provide a method of monitoring the pressure in the DSC to ensure that a slight helium overpressure on the DSC was present. As a result, the DSC was unexpectedly exposed to a negative pressure for approximately 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> causing an unplanned entry into TS 1.2.17A of the general license for Transnuclears standardized NUHOMS horizontal storage modular storage system, COC 1004, Amendment 10, 32PT DSC Vacuum Drying Duration Limit.

Description.

On May 25, 2016, ISFSI loading operations were performed in the cask processing building. DSC-7 was loaded with spent fuel, the inner top cover was welded to the DSC shell, and bulk water removal was in progress. The bulk water removal was being performed in accordance with site procedure, GMM-24-02-ISFSI01A. At approximately 11:00 p.m., Exelon personnel identified a negative pressure on the DSC when removing the Swagelok body fitting from the DSC vent port. Exelon personnel retightened the Swagelok body fitting, stopped work, and entered the appropriate TS action statement for the unexpected condition.

During bulk water removal, procedure GMM-24-02-ISFSI01A directed the removal of approximately 450 gallons through the siphon port while maintaining a helium purge on the vent port. The procedure directed the staff to adjust the flowmeter as necessary to maintain a slight helium overpressure, approximately 1 to 3 psig, on the DSC during the pump down. Exelon personnel set the flowmeter to approximately 80 standard cubic feet per minute in an effort to achieve a pressure of 1 to 3 psig. However, without a method of monitoring the helium pressure, the staff was unable to monitor, adjust, and maintain the pressure between 1 to 3 psig.

Exelon determined that the pump used to transfer the bulk water overcame the introduction of helium to maintain a positive pressure inside the DSC. As a result, the DSC was exposed to a negative pressure and TS 1.2.17a was entered. Exelon entered site procedure GMM-24-02-ISFSI15, ISFSI Abnormal Events and Recovery Actions, Revision 00100, and created a detailed work plan to bring the pressure in the DSC back to approximately 2.5 psig. On May 26, at approximately 4:00 p.m., the pressure in the DSC reached approximately 2.5 psig and Exelon exited TS 1.2.17a prior to exceeding the 31 hour3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> TS action statement limit. Corrective actions included Exelon entering the condition into its CAP (AR 02674062), developing a detailed work plan to return the DSC to a positive pressure, and revising the procedure.

Analysis.

The inspectors determined that Exelon did not have adequate instructions and procedures to ensure that a slight helium overpressure was maintained on the DSC in accordance with 10 CFR 72.150 during bulk water removal on May 25, 2016. As a result, the DSC was unexpectedly exposed to a negative pressure for approximately 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> causing made an unplanned entry into TS 1.2.17a of the general license for Transnuclears standardized NUHOMS horizontal storage modular storage system, COC 1004, Amendment 10. Because the issue involved ISFSI operations, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process, consistent with the guidance in Section 2.2 of the NRC Enforcement Policy. The inspectors determined this violation was most similar to Severity Level IV example 6.3.d.3 from the Enforcement Policy, A licensee fails to implement procedures including, but not limited to, recordkeeping, surveys, and inventories. Therefore, the inspectors determined that this was a Severity Level IV violation. Because this violation involved the traditional enforcement process and was not associated with ISFSI support programs conducted under a 10 CFR 50 license, the inspectors did not assign a cross-cutting aspect to this violation.

Enforcement.

10 CFR 72.150 states, in part, that the licensee, applicant for a license, certificate holder, and applicant for a COC shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstance and shall require that these instructions, procedures, and drawings be followed. Contrary to the above, Exelon did not prescribe activities affecting quality by documented instructions or procedures of a type appropriate to the circumstance.

Specifically, on May 25, 2016, Exelon procedure GMM-24-02-ISFSI01A did not provide a method of monitoring the pressure in the DSC to ensure that a slight helium overpressure on the DSC was present during bulk water removal. However, because the violation was of very low safety significance and was entered into Exelons CAP (AR 02674062), this violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy. (NCV 07200067/2016001-01, Inadequate Procedure Led to Unexpected Negative Pressure on Dry Shielded Canister)

4OA6 Meetings, Including Exit

On July 12, 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.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Pacher, Site Vice President

W. Carsky, Plant Manager

D. Blankenship, Director, Site Operations

M. Cazzolli, ISFSI Program Manager

R. Everett, Director, Site Engineering

K. Garnish, Senior Manager, Operations Support and Services

S. Gillen, Reactor Services Manager

K. Gould, Manager, Radiation Protection

T. Harding, Manager, Site Regulatory Assurance

S. Holmes, Radwaste Supervisor

J. Jackson, Director, Emergency Preparedness

P. Swift, Director, Site Work Management

B. Wade, Superintendent, Shift Operations

S. Wihlen, Director, Site Maintenance

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Open

05000244/2016002-01 AV Incorrect Emergency Action Level Table (Section 1EP4)

Opened/Closed

200067/2016001-01 NCV Inadequate Procedure Led to Unexpected Negative Pressure on Dry Shielded Canister (Section 4OA5)

Closed

05000244/2016-001-00 LER Loss of Station Auxiliary Transformer 12A Resulting In Automatic Start of Emergency Diesel Generator A due to Undervoltage Signals to Safeguards Buses 14 and 18 (Section 4OA3)