IR 05000244/2017003
| ML17312A665 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/08/2017 |
| From: | Anthony Dimitriadis Division of Reactor Safety I |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2017003 | |
| Download: ML17312A665 (33) | |
Text
Hanson UNITED STATES mber 8, 2017
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2017003
Dear Mr. Hanson:
On September 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC (Ginna). On October 23, 2017, the NRC inspectors discussed the results of this inspection with Mr. William Carsky, Site Vice President, and other members of the Ginna staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
However, NRC inspectors documented two licensee-identified violations which were determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, 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. 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 NRCs 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 05000244/2017003 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ
SUMMARY
Inspection Report 05000244/2017003; 07/01/2017 - 09/30/2017; Ginna; Routine Integrated
Inspection Report.
This report covered a three month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. Two licensee-identified violations of very low safety significance (Green) were documented. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated April 29, 2015. All violations of NRC requirements are dispositioned in accordance with the U.S.
Nuclear Regulatory Commissions (NRCs) Enforcement Policy, dated November 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.
Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity
No findings were identified.
Other Findings
Two violations of very low safety significance that were identified by Exelon were reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program (CAP). These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Ginna began the inspection period operating at 100 percent power. The unit 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 Impending Adverse Weather Conditions
a. Inspection Scope
On August 22, 2017, the inspectors reviewed Exelons readiness for a tornado watch.
The review focused on the adverse weather preparation procedure implementation during the issued tornado watch period on the afternoon of August 22, 2017. The inspectors performed walkdowns of selected systems to ensure station personnel identified issues that could challenge the operability of the systems during tornado conditions. The inspectors verified that operator actions defined in Exelons adverse weather procedures maintained the readiness of essential systems. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), control room logs, and the CAP to determine what weather conditions could challenge these systems, and to ensure Exelon personnel had adequately prepared for such challenges. The inspectors reviewed station procedures, including Exelons adverse weather plan and applicable operating procedures. 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 September 7, 2017 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, 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 external areas of the plant, including the screen house, turbine building, and auxiliary building to ensure that Exelon erected flood protection measures in accordance with design specifications. 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
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the systems below. 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.
- Service air / instrument air cross tie following return to service from maintenance on July 25, 2017
- A containment spray on September 13, 2017
- A residual heat removal (RHR) on September 15, 2017
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Resident Inspector Quarterly Walkdowns
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
- Cable tunnel on August 18, 2017
- Auxiliary building basement level on August 24, 2017
- Intermediate building controlled side basement on September 1, 2017
- Intermediate building controlled side top floor on September 8, 2017
- A battery room on September 25, 2017
- Auxiliary building intermediate level on September 28, 2017
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 boundaries between the turbine building to battery room and turbine building to emergency diesel generator rooms. The inspectors verified the adequacy of flood barrier controls, equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers. The inspectors assessed the adequacy of operation actions that Exelon had identified as necessary to cope with flooding in this area 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.
1R07 Heat Sink Performance
.1 Triennial Sample
a. Inspection Scope
Based on Exelons risk ranking of safety-related heat exchangers (HXs) and in consideration of postulated events involving anticipated transient without scram and steam generator tube rupture, past triennial heat sink inspections, recent operational experience, and resident inspector input, the inspectors selected the standby auxiliary feedwater (AFW) room coolers, AFA01A and AFA01B, for inspection. A third sample involved the ultimate heat sink.
The inspectors reviewed program documents, reports, and Exelons methods for inspection, cleaning, maintaining, and performance monitoring used to ensure heat removal capabilities for the standby AFW room coolers. The inspectors compared the technical elements of the controlling procedures to the programmatic essentials contained in Exelons commitments to NRC Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Equipment, and accepted industry practices.
Accompanied by the responsible system engineer, the inspectors observed the current condition of the standby AFW room coolers, AFA01A and AFA01B, including supporting piping, pumps, and valves.
The inspectors performed a review of the service water system from the ultimate heat sink, Lake Ontario, to the common discharge header. The inspectors reviewed Exelons controls to prevent clogging due to macrofouling and verified that macrofouling was adequately monitored, trended, and controlled, consistent with maintenance program frequencies and assumptions. The inspectors walked-down the service water intake structure, noting the condition of the intake structure, traveling screens, pumps, piping, supports, and the biocide treatment injection system. The inspectors noted the structural integrity of component mounts. The inspectors discussed silting of the intake bay and zebra mussel intrusion with the system engineer. The inspectors reviewed results of service water system inspection. Proper functioning of traveling screens and strainers, including strainer backwash function, were reviewed.
The inspectors reviewed the results of visual inspections to determine the structural integrity of the piping.
The inspectors verified Exelon staff entered HX/sink performance problems into their CAP. Using inspection procedure (IP) 71152, Problem Identification and Resolution, as guidance the inspectors verified the corrective actions were appropriate.
b. Findings
No findings were identified.
.2 Annual Sample
a. Inspection Scope
The inspectors reviewed the following HXs readiness and availability to perform their safety functions. The inspectors reviewed the design basis for the components and verified Exelons commitments to NRC GL 89-13, Service Water System Requirements Affecting Safety-Related Equipment, dated July 18, 1989. The inspectors reviewed the results of previous inspections of the HXs. 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.
- A component cooling water HX on September 26, 2017
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 September 19, 2017, the inspectors observed licensed operator simulator training, which included, in part, a failure of nuclear instrumentation, loss of offsite power, emergency diesel generator (EDG) failure, and loss of all alternating current (AC) power.
The inspectors evaluated operator performance during the simulated event and verified completion of risk-significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the unit supervisor. The inspectors verified the accuracy and timeliness of the emergency classifications made by the shift manager and the TS action statements entered by the unit supervisor.
Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
On September 29, 2017, the inspectors observed and reviewed routine activities in the main control room. The inspectors observed operators responding to alarms, coordinating activities with maintenance personnel, conducting a pre-job briefing for a post-maintenance test (PMT), and performance of the PMT. The inspectors verified that the briefing met the criteria specified in procedures HU-AA-1211, Pre-Job Briefings.
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 inspector 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, and maintenance rule (MR) basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by Exelon staff were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2).
Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.
- Microprocessor rod position indication on August 24, 2017
- MR (a)(3) evaluation on September 7, 2017
- Service air on September 29, 2017
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 risk 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.
- Elevated risk for planned maintenance on service air to instrument air cross tie valve on July 18, 2017
- Unplanned maintenance on the standby AFW EDG with fire protection compensatory actions on August 16, 2017
- Planned maintenance on the A EDG on September 14, 2017
- Unplanned maintenance on a B RHR valve (weld repair) on September 19, 2017
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the degraded or non-conforming conditions listed below 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.
- C instrument air compressor motor coupling issues on August 11, 2017
- D standby AFW pump elevated temperatures on August 17, 2017
- Turbine driven AFW flow to the A steam generator indicating 50 gallons per minute with no flow and channel check on September 1, 2017
- Microprocessor rod position indication loss for rod I-11 on September 6, 2017
- A reactor trip bypass breaker failure on September 14, 2017
- C standby AFW flow indicator below zero on September 22, 2017
b. Findings
No findings were identified.
1R17 Evaluations of Changes, Tests, or Experiments
a. Inspection Scope
Three inspectors from the NRC Region I Office completed an inspection on September 25 through 28, 2017, at Ginna to determine if Exelon staff performed screens and evaluations of changes and tests in accordance with regulatory requirements and Exelon implementing guidance. The team reviewed eight safety evaluations to determine whether the changes to the facility or procedures, as described in the UFSAR, had been reviewed and documented in accordance with 10 CFR 50.59 requirements. The safety evaluations were selected from those completed by Exelon staff since the last NRC inspection of this area and had not been previously reviewed by NRC inspectors. In addition, the team evaluated whether Exelon staff had been required to obtain NRC approval prior to implementing the changes. The team interviewed Exelon staff and reviewed supporting information including calculations, analyses, design change documentation, procedures, the UFSAR, the TS, and plant drawings to assess the adequacy of the safety evaluations.
The team compared the safety evaluations and supporting documents to the guidance and methods provided in Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Evaluations, as endorsed by NRC Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, to determine the adequacy of the safety evaluations.
The team also reviewed a sample of 19 screenings and applicability determinations for which Exelon staff had concluded that a 50.59 safety evaluation was not required to be performed. These reviews were performed to assess whether Exelons threshold for performing safety evaluations was consistent with 10 CFR 50.59 requirements. The sample included design changes, evaluations, and procedure changes. The screenings and applicability determinations were selected based on the safety significance, risk significance, and complexity of the change to the facility.
In addition, the team compared Exelons implementing administrative procedures, used to control the screening, preparation, review, and approval of safety evaluations, to the guidance in NEI 96-07 to evaluate whether those procedures adequately implemented the requirements of 10 CFR 50.59. The reviewed safety evaluations, screenings, and applicability determinations are listed in the Attachment.
The team verified that Exelon staff entered performance issues concerning their evaluation of changes and tests into their CAP. The team verified that Exelon staff developed appropriate corrective actions to address those issues.
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed a temporary modification to install alternate cooling to the C instrument air compressor (Engineering Change Package (ECP) -17-000541) to determine whether the modification affected the functions of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modification did not degrade the design bases, licensing bases, and performance capability of the affected systems. In addition, the inspectors reviewed modification documents associated with the design change, including piping configuration and flow path, pipe stress analysis, support design analysis, code applicability, and work planning instructions.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the PMTs 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, 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.
- Containment nitrogen gas supply valve unplanned maintenance on July 24, 2017
- A SFP pump planned maintenance on August 16, 2017
- B5b fire pump planned maintenance on August 23, 2017
- Standby AFW 30 percent load run planned maintenance on August 25, 2017
- A containment spray planned maintenance on September 13, 3017
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests (STs) 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 STs:
- STP-E-10.1, Quarterly Surveillance B Station Battery on July 31, 2017
- STP-O-12.2, B EDG on August 2, 2017
- STP-E-12.3, Security EDG on August 18, 2017
- STP-O-12.2, B EDG on August 30, 2017
- STP-O-16QT, Turbine Driven AFW Pump on September 5, 2017
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observations
a. Inspection Scope
On September 19, 2017, the inspectors evaluated the conduct of a routine Exelon emergency drill to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate Exelons critique and to verify whether Exelon was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety (PS)
2RS7 Radiological Environmental Monitoring Program
a. Inspection Scope
The inspectors reviewed the radiological environmental monitoring program (REMP) to validate the effectiveness of the radioactive gaseous and liquid effluent release program, and implementation of the groundwater protection initiative (GPI). The inspectors used the requirements listed in 10 CFR Part 20, 40 CFR 190, 10 CFR Part 50 Appendix I, and the sites TSs, offsite dose calculation manual (ODCM), NEI 07-07, and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed: the Ginna 2015 and 2016 annual radiological environmental and effluent monitoring reports, REMP program audits; ODCM changes, land use census, UFSAR, and inter-laboratory comparison program results.
Site Inspection (1 sample)
The inspectors walked down various thermoluminescent dosimeter and air and water sampling locations, and reviewed associated calibration and maintenance records. The inspectors observed the sampling of various environmental media as specified in the ODCM and reviewed any anomalous environmental sampling, events including assessment of any positive radioactivity results. The inspectors reviewed any changes to the ODCM. The inspectors verified the operability and calibration of the meteorological tower instruments and meteorological data readouts.
The inspectors reviewed environmental sample laboratory analysis results, laboratory instrument measurement detection sensitivities; and results of the laboratory quality control program audit, and the inter- and intra-laboratory comparison program results.
The inspectors reviewed the groundwater monitoring program as it applies to select potential leaking SSCs, and 10 CFR 50.75(g) records of leaks, spills, and remediation since the previous inspection.
GPI Implementation (1 sample)
The inspectors reviewed: groundwater monitoring results; changes to the GPI program since the last inspection; anomalous results or missed groundwater samples; leakage or spill events, including entries made into the decommissioning files (10 CFR 50.75(g));
evaluations of surface water discharges; and Exelons evaluation of any positive groundwater sample results, including appropriate stakeholder notifications and effluent reporting requirements.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with the REMP were identified at an appropriate threshold and properly addressed in Exelons CAP.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index (5 samples)
a. Inspection Scope
The inspectors reviewed Exelons submittal of the mitigating systems performance index for the following systems for the period of July 1, 2016, through June 30, 2017:
- Emergency AC Power System (MS06)
- High-Pressure Injection System (MS07)
- Heat Removal System (MS08)
- RHR System (MS09)
- Cooling Water System (MS10)
To determine the accuracy of the performance indicator (PI) data reported during those periods, the inspectors used definitions and guidance contained in NEI 99-02, Regulatory Assessment PI Guideline, Revision 7. The inspectors also reviewed Exelons operator narrative logs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
The inspectors reviewed Exelon submittals for the occupational radiological occurrences PI for the third quarter 2016 through the third quarter 2017. The inspectors used PI definitions and guidance contained in NEI 99-02, 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 walk-downs of various locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas.
b. Findings
No findings were identified.
.3 Radiological Effluent TS/ODCM Radiological Effluent Occurrences (1 sample)
a. Inspection Scope
The inspectors reviewed Exelon submittals for the radiological effluent TS/ODCM radiological effluent occurrences PI for the third quarter 2016 through the third quarter 2017. The inspectors used PI definitions and guidance contained in NEI 99-02, Revision 7, to determine if the PI data was reported properly. The inspectors reviewed the public dose assessments for the PI for public radiation safety to determine if related data was 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 offsite dose calculations to determine if indicator results were accurately reported.
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 IP 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.
4OA5 Other Activities
Institute of Nuclear Power Operations (INPO) Report Review The inspectors reviewed the final report for the INPO plant assessment of Ginna conducted in March 2017. The inspectors evaluated this report to ensure that NRC perspectives of Exelon performance were consistent with any issues identified during the assessments. The inspectors also reviewed this report to determine whether INPO identified any significant safety issues that required further NRC follow-up.
4OA6 Meetings, Including Exit
On October 23, 2017, the inspectors presented the inspection results to Mr. William Carsky, Site Vice President, and other members of the Ginna staff. The inspectors verified that no propriety information was retained by the inspectors or documented in this report.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation (NCV).
- Facility Operating License, DRP-18, for R.E. Ginna Nuclear Power Plant, paragraph 2.C.(3), Fire Protection, requires that all provisions of 10 CFR 50.48(a)and 10 CFR 50.48(c) are implemented and maintained in effect. 10 CFR 50.48(a)(2)(i), in part, states that the fire protection plan must describe specific features such as personnel requirements for fire protection. Fire Protection Program document, EPM-FPPR, section 7.15, specifies the required number of fully qualified fire brigade members as five. Contrary to the above, on July 3, 2017, Ginna determined that an individual assumed fire brigade member duties for an entire shift with expired qualifications. This resulted in such a manner that the fire brigade position could not be staffed by any qualified individual onsite.
Upon identification, Exelon entered this into the CAP as AR 04028605. The inspectors evaluated this finding using IMC 0609 Attachment 4, Initial Characterization of Findings, effective October 7, 2016, which directs the inspectors to use IMC 0609 Appendix A, The SDP for Findings at Power Exhibit 2, Mitigating System Screening Questions, issued June 19, 2012, in which upon answering the questions in paragraph D it directs the use of IMC 0609 Appendix M, SDP Using Qualitative Criteria, issued April 12, 2012. The inspectors determined that the finding was of very low safety significance (Green) due to the relatively short exposure time, the specific qualification which had expired and because a prior similar violation significance bounded this findings significance. The prior similar violation occurred at Nine Mile Point Nuclear Station, which was documented in inspection report 05000220/410/2016004.
- TS 5.2.1.a, Onsite and Offsite Organizations, states, in part, that onsite organizations shall be established for plant operation and shall include positions for activities affecting the safety of the nuclear power plant. Furthermore, it states that these requirements shall be documented in the UFSAR. UFSAR 13.1.3.10.1.1 Shift Managers states, in part, the duties and responsibilities of the shift manager.
Additionally, pursuant to 10 CFR 50.47(b)(2), the onsite shift emergency response responsibilities are to be staffed and assigned. Contrary to the above, Ginna determined that on July 1 and 2, 2017, an individual assumed the role of shift manager, and onsite shift emergency response duties, for two complete shifts with expired qualifications. This resulted in such a manner that the shift manager position could not be staffed by any qualified individual on site.
Upon identification, Exelon entered this into the CAP as AR 04029514. This finding was evaluated in accordance with IMC 0609 Attachment 4, Initial Characterization of Findings, effective October 7, 2016, which directed the inspector, a senior reactor analyst, and regional management to assess the finding in accordance with IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria, issued April 12, 2012, due to the non-applicability of the SDP Appendix Router tables. The inspectors determined the finding was very low safety significance (Green) based on the short exposure time, the fact that the shift manager did not make errors related to the expired qualification, and other requirements of the shift manger qualification were satisfied.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- W. Carsky, Site Vice President
- P. Swift, Plant General Manager
- D. Blankenship, Director, Site Operations
- M. Bodine, System Manager
- F. Bundy, Security Work Control and Project Analyst
- M. Burgess, Chemistry
- K. Conner, Reactor Engineering Manager
- A. Culotta, Plant Engineering
- T. Edwards, Manager, Site Chemistry
- R. Fellows, Operations Support Manager
- J. Fischer, Senior Regulatory Engineer
- M. Fitzsimmons, Structural Engineer
- D. Gardiner, Mechanical Design Engineering
- K. Garnish, Manager, Site Regulatory Assurance
- K. Gould, Manager, Radiation Protection
- M. Layton, Radiation Protection Technical Specialist
- J. Massari, Manager of Engineering Safety Analysis
- G. Meixell, Structural Engineer
- T. Parsons, Mechanical Maintenance Lead Technician
- D. Pascuzzi, Branch Manager
- D. Peters, Senior Manager, Plant Engineering
- B. Raczkiewicz, Equipment Qualification Program Owner
- B. Rapin, System Manager
- A. Stavalone, Chemist
- D. Wilson, Director, Site Engineering
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
None Open None
Closed
None