IR 05000244/2016004
| ML17038A212 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/06/2017 |
| From: | Anthony Dimitriadis Reactor Projects Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2016004 | |
| Download: ML17038A212 (32) | |
Text
UNITED STATES ary 6, 2017
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2016004
Dear Mr. Hanson:
On December 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC (Ginna). On January 13, 2017, the NRC inspectors discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President, and other members of the Ginna staff. The results of this inspection are documented in the enclosed report.
The NRC inspectors did not identify any finding or violation of more than minor significance.
This letter, its enclosure, and your response (if any) will be available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket No. 50-244 License No. DPR-18
Enclosure:
Inspection Report 05000244/2016004 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-244 License No. DPR-18 Report No. 05000244/2016004 Licensee: Exelon Generation Company, LLC (Exelon)
Facility: R.E. Ginna Nuclear Power Plant, LLC (Ginna)
Location: Ontario, New York Dates: October 1, 2016, through December 31, 2016 Inspectors: N. Perry, Senior Resident Inspector J. Petch, Resident Inspector H. Anagnostopoulos, Health Physicist M. Modes, Senior Reactor Inspector A. Rosebrook, Senior Project Engineer T. Fish, Senior Operations Engineer J. DeBoer, Emergency Preparedness Inspector Approved by: Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000244/2016004; 10/01/2016 - 12/31/2016; 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 6.
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
On November 10, 2016, the inspectors reviewed Exelons readiness for the onset of seasonal cold temperatures. The review focused on the auxiliary boiler heating system and the emergency diesel generators. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), control room logs, and the corrective action program (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 procedure 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 cold weather conditions. Documents reviewed for each section in this report are listed in the Attachment.
b. Findings
No findings were identified.
.2 External Flooding
a. Inspection Scope
On October 13, 2016, the inspectors performed an inspection of the external flood protection measures for Ginna. The inspectors reviewed TSs, procedures, design documents, and the UFSAR, Chapter 2.4.2, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of all external areas of the plant, including the turbine building, auxiliary building, and berm to ensure that Exelon erected flood protection measures in accordance with design specifications. Where applicable, the inspectors determined installed turbine building pressure wall seals were installed and adequate. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to confirm that, overall, Exelon had established adequate measures to protect against external flooding events.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial System Walkdowns (71111.04Q - 2 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
- A residual heat removal (RHR) system on October 28, 2016 and
- C standby auxiliary feedwater (AFW) system on December 20, 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), action requests (ARs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether 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 - 3 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 (OOS),degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
- B battery room on October 14, 2016
- HEMYC fire wrap areas in the control, intermediate, and auxiliary buildings on November 29, 2016
- Relay Room on December 9, 2016
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the following heat exchangers (HXs) readiness and availability to perform their safety functions. The inspectors reviewed the design basis for the components and verified Exelons commitments to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, dated July 18, 1989. The inspectors observed actual performance tests for the HXs and/or reviewed the results of previous inspections. The inspectors discussed the results of the most recent inspections with engineering staff, and reviewed pictures of the as-found and as-left conditions. The inspectors verified that Exelon initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the HXs did not exceed the maximum amount allowed in system design calculations.
- B emergency diesel generator (EDG) HX on November 17, 2016
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 November 29, 2016, the inspectors observed licensed operator simulator training, which included a loss of coolant accident (LOCA) outside containment. 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 classification 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 December 19, 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 011. 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.
.3 Biennial Review
- 1 sample)
a. Inspection Scope
The following inspection activities were performed using NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 10, and Inspection Procedure Attachment 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance.
Examination Results Facility staff had not completed administration of the annual operating tests and biennial written exams by the end of this inspection period and therefore Pass/Fail results were not inspected.
Written Examination Quality The inspectors reviewed a sample of reactor operator and senior reactor operator biennial written exams.
Operating Test Quality The inspectors reviewed the operating tests (scenarios and Job Performance Measures (JPMs)) associated with the on-site examination week.
Licensee Administration of Operating Tests The inspectors observed facility training staff administer dynamic simulator exams and JPMs during the week of December 12, 2016. These observations included facility evaluations of crew and individual operator performance during the simulator exams and individual performance of JPMs.
Exam Security The inspectors assessed whether facility staff properly safeguarded exam material, and whether test item repetition was excessive.
Conformance with License Conditions License reactivation and license proficiency records were reviewed to ensure that Title 10 of the Code of Federal Regulations (10 CFR) 55.53 license conditions and applicable program requirements were met. The inspectors also reviewed a sample of records for requalification training attendance, and a sample of medical examinations for compliance with license conditions and NRC regulations.
Simulator Performance Simulator performance and fidelity were reviewed for conformance to the reference plant control room. A sample of simulator deficiency reports was also reviewed to ensure facility staff addressed identified modeling problems.
Problem Identification and Resolution The inspectors reviewed recent operating history documentation found in inspection reports, licensee event reports, the licensees CAP, NRC End of Cycle reports, and the most recent NRC plant issues matrix. The resident staff was also consulted for insights regarding licensed operators performance. The inspectors focused on events associated with operator errors that may have occurred due to possible training deficiencies.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the sample listed below to assess the effectiveness of maintenance activities on structure, system, and component performance and reliability.
The inspectors reviewed CAP documents, maintenance WOs, and system design records to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the quality assurance program. For the sample selected, the inspectors reviewed multiple work packages to verify that quality control verifications were properly specified in accordance with the quality assurance program and were implemented as specified.
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 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.
The inspectors reviewed the maintenance and emergent work activities listed below:
- Planned maintenance on B EDG on November 1, 2016
- Planned maintenance on C standby AFW on November 14, 2016
- Planned maintenance on radiation monitor 14A on December 22, 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:
- Water leakage into B battery room on October 12, 2016,
- D service water pump high differential pressure on November 8, 2016,
- Nuclear instrument N-41 dirty potentiometer on December 2, 2016, and
- Review of Operator Work Arounds (OWAs) on December, 30, 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 to Exelons evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, such as in the case of OWAs, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon.
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, that the test results were properly reviewed and accepted, and that problems were appropriately documented. The inspectors also walked down the affected job site, 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.
- A RHR planned maintenance on October 19, 2016
- Alternate injection flex pump after installation on October 28, 2016
- B EDG planned maintenance on November 3, 2016
- Diesel Fire Pump planned maintenance on December 15, 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 structures, systems, and components (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-16QB, Auxiliary Feedwater Pump B - Quarterly on November 28, 2016 (inservice test),
- STP-O-2.8Q, Component Cooling Water Pump - Quarterly on December 9. 2016, and
- STP-O-2.8-COMP-A, Component Cooling Water Pump A Comprehensive Test on December 18, 2016.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Exelon implemented various changes to the Ginna Emergency Action Levels (EALs),
Emergency Plan, and Implementing Procedures. Exelon had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR Part 50, Appendix E.
The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Exelon as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Training Observations
a. Inspection Scope
On November 30, 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.
RADIATION SAFETY
Cornerstone: Public Radiation Safety and Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors reviewed Exelons performance in assessing and controlling radiological hazards in the workplace. The inspectors used the requirements contained in 10 CFR Part 20, Standards for Protection Against Radiation; TSs; Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants, Revision 1; and the procedures required by TSs as criteria for determining compliance.
Inspection Planning The inspectors reviewed the PIs for the occupational exposure cornerstone, radiation protection program audits, and reports of operational occurrences in occupational radiation safety since the last inspection.
Radiological Hazard Assessment (1 sample)
The inspectors conducted independent radiation measurements during walkdowns of the facility and reviewed the radiological survey program, air sampling and analysis, continuous air monitor use, recent plant radiation surveys for radiological work activities, and any changes to plant operations since the last inspection to verify survey adequacy of any new radiological hazards for onsite workers or members of the public.
Instructions to Workers (1 sample)
The inspectors reviewed high radiation area work permit controls and use, observed containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with requirements.
The inspectors reviewed several occurrences where a workers electronic personal dosimeter alarmed. The inspectors reviewed Exelons evaluation of the incidents, documentation in the CAP, and whether compensatory dose evaluations were conducted when appropriate. The inspectors verified follow-up investigations of actual radiological conditions for unexpected radiological hazards were performed.
Contamination and Radioactive Material Control (1 sample)
The inspectors observed the monitoring of potentially contaminated material leaving the radiological controlled area and inspected the methods and radiation monitoring instrumentation used for control, survey, and release of that material. The inspectors selected several sealed sources from inventory records and assessed whether the sources were accounted for and were tested for loose surface contamination. The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with requirements.
Radiological Hazards Control and Work Coverage (1 sample)
The inspectors evaluated in-plant radiological conditions and performed independent radiation measurements during facility walkdowns and observation of radiological work activities. The inspectors assessed whether posted surveys; radiation work permits; worker radiological briefings and radiation protection job coverage; the use of continuous air monitoring, air sampling, and engineering controls; and dosimetry monitoring were consistent with the present conditions. The inspectors examined the control of highly activated or contaminated materials stored within the SFPs and the posting and physical controls for selected high radiation areas, locked high radiation areas, and very high radiation areas to verify conformance with the occupation PI.
Risk-Significant High Radiation Areas and Very High Radiation Areas Controls (1 sample)
The inspectors reviewed the procedures and controls for high radiation areas, very high radiation areas, and radiological transient areas in the plant.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 sample)
The inspectors evaluated radiation worker performance with respect to radiation protection work requirements. The inspectors evaluated radiation protection technicians in performance of radiation surveys and in providing radiological job coverage.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with radiation monitoring and exposure control (including operating experience) were identified at an appropriate threshold and properly addressed in the CAP.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Occupational Exposure Control Effectiveness
a. Inspection Scope
The inspectors reviewed Exelons submittals for the occupational radiological occurrences (OR01) PI for the third quarter 2015 through the third quarter 2016.
The inspectors used PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the PI data reported.
The inspectors reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized PI occurrences. The inspectors conducted walkdowns of various locked high radiation area and very high radiation area entrances to determine the adequacy of the controls in place for these areas.
b. Findings
No findings were identified.
.2 Radiological Effluent Technical Specification (RETS)/Offsite Dose Calculation Manual
(ODCM) Radiological Effluent Occurrences
a. Inspection Scope
The inspectors reviewed Exelons submittals for the RETS/ODCM radiological effluent occurrences (PR01) PI for the third quarter 2015 through the third quarter 2016. The inspectors used PI definitions and guidance contained in NEI 99-02, Revision 7, to determine if the PI data were reported properly. The inspectors reviewed the public dose assessments for the PI for public radiation safety to determine if related data were accurately calculated and reported.
The inspectors reviewed the CAP database to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous and liquid effluent summary data and the results of associated dose calculations to determine if indicator results were accurately reported.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into its 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.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues to identify trends that might indicate the existence of more significant safety concerns. As part of this review, the inspectors included repetitive or closely related issues documented by Exelon in trend reports, major equipment problem lists, operator work-around and challenge lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Exelons CAP database for the third and fourth quarters of 2016 to assess ARs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily AR review (Section 4OA2.1). The inspectors reviewed Exelons quarterly trend reports for the third and fourth quarters of 2016, to verify that Exelon personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findings and Observations
No findings were identified.
The inspectors evaluated a sample of issues and events that occurred over the course of the third and fourth quarters of 2016 to determine whether issues were appropriately considered as emerging or adverse trends. The inspectors verified that these issues were addressed within the scope of the CAP or through department review.
The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that Exelon personnel were identifying trend issues at a low threshold, entered them into the CAP for resolution and had appropriately prioritized investigation reviews. The inspectors noted minor adverse trends identified by Exelon staff in the areas of procedure use and adherence, unit heaters not working, temperature switches out of tolerance, EP communication equipment failures, equipment protection discrepancies, roof leaks, and nuclear instrumentation calibration measurement issues.
There were no adverse safety consequences as a result of these low-level trend issues.
Based on the overall results of the semi-annual trend review, the inspectors determined that Exelon had properly identified adverse trends at Ginna before they became more significant safety problems. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined these conditions were deficiencies of minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.
.3 Annual Sample: Review of the Evaluations and Effectiveness of Corrective Actions for
Emergency Preparedness (EP) Violations at Ginna.
a. Inspection Scope
The inspectors performed an in-depth review of Exelons evaluations and corrective actions associated with a number of Emergency Preparedness Cornerstone violations and non-cited violations (NCVs). The inspectors assessed Exelons CAP evaluations and effectiveness of corrective actions for EP issues documented in NRC Inspection Reports between 2008 and 2015. The inspectors evaluated these issues to determine if there were any common root, apparent or contributing causes that have not been adequately addressed, and if the corrective actions developed for each issue were effective. The inspectors reviewed Exelon procedures, root and apparent cause evaluations, selected CRs and WOs, and reviewed audits and self-assessments associated with the EP program. The inspectors also conducted interviews with various Exelon staff knowledgeable with the evaluation of and corrective actions developed for these issues.
The sample focused on the evaluation and long term corrective actions associated with the following EP findings since 2014. These findings include a White Notice of Violation (NOV) for a Non Conservative EAL Criteria (NRC Inspection Reports (IR)05000244/2016002, 05000244/2016009, and 05000244/2016010); a Green NCV for an overly conservative protective action recommendation (PAR) (IR 05000244/2015001); a Green NCV for an inadequate EP Drill Critique (IR 05000244/2014002); an Exercise of Enforcement discretion for a White/SLIII finding associated with inadequate PARs over Lake Ontario (IR 05000244/2015002) and a Green licensee identified violation related to a calculation error for an EAL threshold value (IR 05000244/2016001). Additionally in 2008, a Severity Level III NOV (IR 05000244/2008502) was issued to Ginna for changes to its emergency plan which decreased its effectiveness without first obtaining NRC approval. The long term effectiveness of corrective actions to preclude repetition for this violation was also evaluated.
b. Findings and Observations
No new findings were identified.
The inspectors determined that although there have been a relatively large number of findings in this area, the corrective actions developed were generally effective and likely would not have precluded subsequent issues. In many cases, the performance deficiency which resulted in a finding or violation occurred several months prior to the issue being identified and documented. As such, corrective actions to preclude repetition would not have reasonably prevented these performance deficiencies.
However, the inspectors did identify that several of these issues had common contributing causes. Specifically, on several occasions, the Plant Operations Review Committee (PORC) did not perform an adequate review of changes to an emergency action threshold. On several occasions, PORC was asked to review and approve very large programmatic changes, where changes of a technical nature were not clearly distinguished from format or administrative changes, and was not effective in identifying issues which adversely impacted the EAL. Exelon captured the inspectors observations in the CAP and corrective actions included more clearly identifying technical changes and breaking significant changes into more manageable segments to ensure PORC is able to apply the right level of rigor in its review.
The inspectors also identified that failure to ensure cross disciplinary reviews of emergency plan changes were performed during review and approval of emergency plan changes was a contributing cause for two recent EAL violations, (the 2016 White NOV, and the 2016 Green LIV). Extent of cause and condition reviews for the Green licensee identified violation in the first quarter 2016 were not effective in identifying the White NOV which was identified in the second quarter 2016. This was captured in Exelons Root Cause Analysis Report for the White NOV and discussed in IR 2016010 as a missed opportunity to identify the issue.
The above issues were not determined to be violations of NRC requirements.
.4 Annual Sample: Review of Vibrations of Turbine Driven Auxiliary Feed Water Pump
Outboard Bearing Housing
a. Inspection Scope
The inspectors reviewed the actions taken in response to the discovery of elevated vibrations subsequent to maintenance, and during performance of STP-O-16QT, at the Turbine Driven AFW pump outboard bearing housing.
The inspectors reviewed the actions taken to evaluate and correct the condition and restore full operability of the Turbine Driven AFW pump which included designing and installing an additional qualified support intended to minimize movement of the turbine casing at the outboard bearing housing. Specifically, the inspectors assessed Exelons problem identification threshold, cause analyses, extent-of-condition reviews, and the prioritization and timeliness of Exelons corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Exelons CAP and 10 CFR Part 50, Appendix B.
b. Findings and Observations
No findings were identified.
The inspectors determined that upon termination of the pump test the vibration results were recorded in AR 02588214 and AR 02594391 in a complete, accurate, and timely fashion. Exelon personnel evaluated the operability of the pump and considered reportability issues.
The inspectors reviewed the actions taken to determine if the actions to install an additional qualified support, intended to minimize movement of the turbine casing at the outboard bearing housing, resulted in the correction of the identified problem. In the case of this condition adverse to quality, the inspectors determined it will preclude repetition as evidenced by the vibration testing results subsequent to the modification.
The inspectors reviewed operating experience and determined it was adequately evaluated for applicability, and that lessons learned were communicated to appropriate organizations and implemented.
.5 Annual Sample: Review of the Corrosion in Line Spec 125-11
a. Inspection Scope
The inspectors reviewed the actions taken in response to the discovery of significant corrosion on a 10 fire pipe in the west loop header (Line Spec 125-11), located in the screen house. The corrosion was located in the pipe at the point where the pipe exits the screen house in the circulation water bay south wall. The corrosion was discovered during the NRC license renewal walk-down.
The inspectors assessed Exelons problem identification threshold, cause analyses, extent-of-condition reviews, and the prioritization and timeliness of Exelons corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Exelons CAP and 10 CFR Part 50, Appendix B.
b. Findings and Observations
No findings were identified.
The observed corrosion condition was entered into Exelons corrective action program (AR01919187) on 10/27/2011, the same day it was discovered. The inspectors determined the documentation of the condition was complete, accurate, and timely. The condition was evaluated by ultrasonic thickness testing after the walk-down, and found to be above minimum wall, in a timely fashion. The inspectors reviewed the previously established WO to replace the penetration material and test the pipe for wall thickness.
The conditions were considered for operability and reportability issues in a timely fashion.
The extent of condition was evaluated by testing the second 10 pipe in a similar configuration at the time the originally noted condition was tested.
The inspectors reviewed the actions taken to determine if the actions resulted in the correction of the identified problem. In the case of this condition adverse to quality, the inspectors determined the corrective action taken would reasonably preclude repetition.
The inspectors reviewed operating experience to determine if it was adequately evaluated for applicability, and applicable lessons learned were communicated to appropriate organizations and implemented.
4OA5 Other Activities
(Closed) NRC Temporary Instruction (TI) 2515/192 - Inspection of the Licensees Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems
a. Inspection Scope
The objective of this performance based TI was to verify implementation of interim compensatory measures associated with an open phase condition design vulnerability in electric power systems for operating reactors. The inspectors conducted an inspection to determine if Exelon had implemented the following interim compensatory measures.
These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for open phase condition design vulnerability. The inspectors verified the following:
- Exelon identified and discussed with applicable plant staff the lessons learned from the open phase condition events at U.S. operating plants including the Byron station open phase condition event and its consequences. Exelon conducted operator training for promptly diagnosing, recognizing consequences, and responding to an open phase condition event.
- Exelon updated applicable plant operating procedures to help operators promptly diagnose and respond to open phase condition events on off-site power sources credited for safe shutdown of the plant.
- Exelon established and continued to implement periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible open phase condition.
- Exelon ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance and testing activities, Exelon assessed and managed plant risk in accordance with 10 CFR 50.65(a)(4) requirements.
b. Findings and Observations
No findings were identified.
This completes the inspection requirements of TI 2515/192.
4OA6 Meetings, Including Exit
On January 13, 2017, 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
- J. Brown, Manager, Operations Training
- T. Edwards, Manager, Site Chemistry, Environmental, & Radwaste
- R. Everett, Director, Site Engineering
- K. Garnish, Senior Manager, Operations Support and Services
- K. Gould, Manager, Radiation Protection
- T. Harding, Manager, Site Regulatory Assurance
- J. Jackson, Manager, Emergency Preparedness
- A. Smith, Director, Ginna Training
- P. Swift, Director, Site Work Management
- S. Wihlen, Director, Site Maintenance
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Closed
- 05000244/2515/192 TI Inspection of the Licensees Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (Section 4OA5)