IR 05000244/2016008
| ML16126A297 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/05/2016 |
| From: | Anthony Dimitriadis Reactor Projects Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2016008 | |
| Download: ML16126A297 (21) | |
Text
May 5, 2016
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000244/2016008
Dear Mr. Hanson:
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your R.E. Ginna Nuclear Power Plant, LLC (Ginna). The enclosed report documents the inspection results, which were discussed on March 31, 2016, with Mr. William Carsky, Plant General Manager, and other members of the Ginna staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the samples selected for review, the inspection team concluded that Exelon Generation Company, LLC (Exelon) was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.
No NRC-identified or self-revealing findings were identified during this inspection. In accordance with Title 10 of the Code of Federal Regulations 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects
Docket No.
50-244 License No.
Enclosure:
Inspection Report 05000244/2016008 w/Attachment: Supplementary Information
REGION I==
Docket No.
50-244
License No.
Report No.
Licensee:
Exelon Generation Company, LLC (Exelon)
Facility:
R.E. Ginna Nuclear Power Plant, LLC (Ginna)
Location:
Ontario, New York
Date:
March 14, 2016, through March 31, 2016
Team Leader:
K. Kolaczyk, Senior Resident Inspector
Inspectors:
J. Petch, Resident Inspector
J. Pfingsten, Project Engineer
K. Reid, Project Engineer
Approved by:
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects
SUMMARY
Inspection Report 05000244/2016008; 03/14/2016 - 03/31/2016; Ginna; Biennial Baseline
Inspection of Problem Identification and Resolution.
This U.S. Nuclear Regulatory Commission (NRC) team inspection was performed by two regional inspectors and two resident inspectors. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Problem Identification and Resolution
The inspectors concluded that Exelon was effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program (CAP) at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, Exelon appropriately screened issues for operability and reportability and performed causal analyses that appropriately considered extent-of-condition, generic issues, and previous occurrences. The inspectors also determined that Exelon typically implemented corrective actions to address the problems identified in the CAP in a timely manner.
The inspectors concluded that, in general, Exelon adequately identified, reviewed, and applied relevant industry operating experience to Ginnas operations. In addition, based on those items selected for review, the inspectors determined that Exelons self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual CAP and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. Documents reviewed during this inspection are listed in the Attachment.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described the Corrective Action Program (CAP) at Ginna. Since the last U.S. Nuclear Regulatory Commission (NRC) biennial problem identification and resolution inspection completed in March 2014, Ginnas management transitioned from Constellation Energy Nuclear Group, LLC (CENG) to Exelon. The transition, which occurred on April 1, 2014, resulted in the review of program effectiveness under two separate sets of program procedures and program processes. To assess the effectiveness of the CAP, the inspectors reviewed performance in three primary areas:
- (1) problem identification,
- (2) prioritization and evaluation of issues, and
- (3) corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action; Exelon procedure PI-AA-125, Corrective Action Program (CAP)
Procedure, Revision 3; and CENG procedure CNG-CA-1.01-1000, Corrective Action Program (CAP), Revision 01100.
For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed CENG condition reports (CRs) and Exelon issue reports (IRs)selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Station Ownership Committee (SOC), Management Review Committee (MRC), and plant production meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, nuclear oversight, and the CAP.
Effectiveness of Problem Identification
In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventive maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems onsite, including the feed and condensate, charging, and standby auxiliary feedwater (SAFW) systems. During the system walkdown, plant structures were also examined. Additionally, the inspectors reviewed a sample of IRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Exelon staff entered conditions adverse to quality into its CAP as appropriate.
Effectiveness of Prioritization and Evaluation of Issues
The inspectors reviewed the evaluation and prioritization of a sample of CRs and IRs issued since the last NRC biennial problem identification and resolution inspection completed in March 2014. The inspectors also reviewed IRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
Effectiveness of Corrective Actions
The inspectors reviewed Exelons completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed IRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelons timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of IRs associated with selected non-cited violations (NCVs) and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to 5 years to evaluate Exelons actions related to deficiencies associated with leakage from the spent fuel pool, spent fuel pool transfer canal, and actions taken to address ongoing groundwater leakage into the intermediate building sub-basement containment tendon area.
Trending
The inspectors reviewed Ginnas processes for identifying and addressing emergent and existing adverse trends in equipment and human performance. The inspectors conducted interviews with plant staff who conducted the department trend reviews, reviewed department trend reports, site trend reports, maintenance rule performance monitoring reports, and required 10 CFR 50.65a(1) action plans and evaluations. The inspectors also reviewed the minutes from system health committee meetings.
b.
Assessment
Effectiveness of Problem Identification
Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon identified problems and entered them into the CAP at a low threshold. Exelon staff at Ginna initiated approximately 15,000 IRs between March 2014 and March 2016. The inspectors observed supervisors at the daily production, SOC, and MRC meetings appropriately questioning and challenging IRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues and appropriately identified problems in IRs.
The inspectors verified that conditions adverse to quality identified through this review were entered into the CAP as appropriate. Although the inspectors identified during their plant walkdowns over 30 issues that were entered into Ginnas CAP, all of the items were minor and, in the inspector's determination, were not indicative that Ginnas CAP was not operating properly. For example, during a walkdown of plant areas, the inspectors identified several instances where cracks had appeared in the mortar for safety-related block walls. In some instances, the mortar gaps were large and deep enough to allow air from adjacent rooms to enter an adjoining fire area. These issues had not been identified by Exelon as part of the structures monitoring program or by personnel conducting area tours. During the tours, the inspectors also identified several instances where plant housekeeping and equipment status standards were not properly implemented. These examples included instances where ladders were not properly stored, leakage collection pads were not properly identified, and annunciators on the radioactive waste control panel were not properly tracked.
Finally, through discussions with station control room and non-licensed operators, it appeared there were knowledge gaps regarding how the backup diesel generators to the SAFW system would respond following a loss of the normal power supply. Specifically, operators believed that both SAFW diesel generators would start following a loss of the normal power supply when in fact, only one diesel would initially receive a start signal.
The inspectors noted that training material for the SAFW system was silent on the matter since the material had not been updated to reflect installation of the diesel generators, which has occurred over 12 months ago.
In response to these observations identified during the walkdowns, several IRs were written; and when appropriate, Exelon took action to address the issues. When evaluated, the inspectors determined none of the non-conformances and deficiencies would adversely impact the operability of the structures or enclosed equipment; therefore, these issues were determined to be of minor significance in accordance with the guidance of Inspection Manual Chapter 0612, Appendix B, Issue Screening. The IRs written are documented in the Attachment to this report.
Exelon monitored the performance of both the SOC and MRC meetings through the site internal assessment program. Observations and comments regarding SOC and MRC meeting effectiveness by the Exelon assessors closely matched views shared by inspectors who had also attended the meetings.
The inspectors also observed that, when required, SOC members went back to the originators of several IRs to obtain additional details regarding the item documented in the IR so the issue was clearly documented in the CAP and could be appropriately evaluated and resolved.
Effectiveness of Prioritization and Evaluation of Issues
The inspectors determined that Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon screened IRs for operability and reportability, categorized the IRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The IR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of IRs reviewed, the inspectors noted that the guidance provided by Exelon CAP implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted; and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent-of-condition or problem, generic issues, and previous occurrences of the issue. Root cause evaluations and apparent cause evaluations reviewed were completed when required and received management review prior to approval.
Effectiveness of Corrective Actions
The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective.
The inspectors reviewed the change management from CENGs CAP and CAP tracking systems to Exelons process. Inspectors verified through sampling that open CENG corrective actions were transferred to Exelons system. The inspectors determined that Exelon appropriately managed the transition and did not identify any open corrective action assignments in legacy CENG system, which failed to be moved to Exelons new CAP system database.
5-Year Review
The inspectors completed a 5-year look back of the structures condition monitoring program. The inspectors reviewed the results of the last periodic structural examination which was completed in 2012. The inspectors determined that the corrective actions coming out of the examination were implemented in a timely manner commensurate with the safety significance. In response to several questions regarding structures identified by the inspectors during plant walkdowns, Exelon personnel promptly initiated IRs and/or took immediate actions to address the issues. The inspectors reviewed IR/CRs related to the structure monitoring program, and determined that Exelon adequately developed and scheduled corrective actions.
Trending
The inspectors reviewed Exelons processes for identifying and addressing emergent and existing adverse trends in equipment and human performance. Exelon was able to identify trends at a low level using their department trending process. These trends were rolled up to the station level on a monthly basis and action and monitoring plans were developed as appropriate. Additionally, the stations maintenance rule performance monitoring program was effective in evaluating system performance and identifying trends. The SOC members also identified potential trends during their screening meetings and elevated the significance level low-level issues based on the identification of potential trends. During conversations with site personnel, many staff members commented on the emphasis by management to enter issues into the CAP at a very low level so trends could be identified.
c. Findings
No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of CRs and IRs associated with review of industry operating experience to determine whether Exelon staff had appropriately evaluated the operating experience information for applicability to Ginna, and if the station staff had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon staff adequately considered the underlying problems associated with the issues for resolution via its CAP. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b.
Assessment
Based upon a review of the documents, the inspectors determined that Exelon staff appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors observed that industry operating experience was routinely discussed and considered during the daily production and control room turnover meetings.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the CAP, departmental self-assessments, and assessments performed by independent organizations. The inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the CAP, when appropriate, and whether Exelon staff initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during NRC inspections.
At the time of the inspection, the Exelon site nuclear oversight group had recently reorganized as part of a fleet-wide restructuring that eliminated the onsite nuclear assessment organization at nuclear plant sites. Since this reorganization had only been effective at Ginna since February 1, 2016, the inspectors review of this area was based primarily on open assessments conducted under the previous organizational structure.
b.
Assessment
Based on the reviewed documents, the inspectors concluded that self-assessments, audits, and other internal Exelon assessments were critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. The inspectors observed that nuclear oversight was critical and where appropriate, identified weaknesses and areas requiring improvement. Exelon completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the CAP for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
c. Findings
No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious work environment at Ginna. While interacting with site personnel, the inspectors asked individuals if they were hesitant to raise safety concerns to their management and/or the NRC. A wide range of plant employees from various departments were questioned, including personnel from the operations, engineering, instrumentation and controls, planning, maintenance, chemistry, and security groups. The inspectors also interviewed the station Employee Concerns Program (ECP) coordinator and his predecessor to assess how well the ECP was implemented, what concerns they had addressed in the ECP, what actions they had implemented to ensure employees were aware of the program, and its availability with regards to raising safety concerns. The inspectors reviewed the ECP files to ensure that the ECP was implemented in accordance with Exelon procedures.
b.
Assessment
During interviews, Exelon staff expressed a willingness to use the CAP to identify plant issues and deficiencies and stated that they were willing to raise safety issues. All persons interviewed demonstrated an adequate knowledge of the CAP and the ECP.
Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
The inspectors did have several comments regarding the employee concerns governing document EI-AA-101-1000, "Employee Concerns Program Process," Revision 14.
Specifically, Section 4.4 of the procedure requires the ECP coordinator to notify the Site Vice President of all Class 1 or Class 2 concerns. The inspectors questioned the efficacy of the wording in that step since the Site Vice President may be the individual who caused the Class 1 or Class 2 concern to occur. Also, EI-AA-101-1000 contained references to a position (nuclear oversight manager) that had been eliminated in a recent reorganization.
Ginnas ECP manager discussed the observation with the inspectors, examined the issue and submitted a procedure change request in PCRA 2594006-81.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On March 31, 2016, the inspectors presented the inspection results to Mr. William Carsky, Plant General Manager, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- W. Carsky, Plant Manager
- T. Fabian, Engineer 2
- M. Fitzsimmons, Senior Staff Engineer
- A. Freedman, System Engineer
- K. Garnish, Senior Ops Support and Services Manager
- T. Harding, Manager Site Regulatory Assurance
- R. Hellems, Engineer 3
- K. Mack, Organizational Effectiveness Manager
- R. Marshall, Auxiliary Operator
- D. Peters, Mechanical Design Manager
- W. Rapin, Senior Engineer
- R. Reissner, Manager Operations Services
- C. Siverd, Regulatory Assurance
- J. Sperr, System Engineering Manager
- J. Stanger, System Engineer
- B. Stanfield, Ginna CAP Manager
- W. Tono, Senior Engineer
- M. Vail, Manager Maintenance Support
- B. Weaver, Engineering Manager
- G. Wrobel, Developmental Assignment
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
None