IR 05000244/2022003

LLC - Integrated Inspection Report 05000244/2022003

ML22307A234
Person / Time
Site:	Ginna
Issue date:	11/03/2022
From:	Erin Carfang NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2022003
Download: ML22307A234 (1)

Text

November 3, 2022

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2022003

Dear David Rhoades:

On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC. On October 11, 2022, the NRC inspectors discussed the results of this inspection with Doug Hild, plant manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be of very low safety significance (Green) is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at R.E. Ginna Nuclear Power Plant, LLC. This letter, its enclosure, and your response (if any) will be made 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 (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Digitally signed by Erin E.

Erin E. Carfang Date: 2022.11.03 Carfang 14:59:53 -04'00'

Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety Docket No. 05000244 License No. DPR-18

Enclosure:

As stated

Inspection Report

Docket Number: 05000244 License Number: DPR-18 Report Number: 05000244/2022003 Enterprise Identifier: I-2022-003-0033 Licensee: Constellation Energy Generation, LLC Facility: R.E. Ginna Nuclear Power Plant, LLC Location: Ontario, New York Inspection Dates: July 1, 2022 to September 30, 2022 Inspectors: J. Schussler, Senior Resident Inspector C. Swisher, Resident Inspector S. Veunephachan, Health Physicist Approved By: Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety Enclosure

SUMMARY

The NRC continued monitoring the licensees performance by conducting an integrated inspection at R.E. Ginna Nuclear Power Plant, LLC, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: 71114.0

List of Findings and Violations

'A' Residual Heat Removal Heat Exchanger Bypass Isolation Valves 712A and 712B Over Torque Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None 71111.12 Systems NCV 05000244/2022003-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1.a, Procedures, when Ginna did not establish and implement written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, Section 3, Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems. Specifically, Ginna failed to adequately convey technical requirements into procedure M-37.108, Aloyco Bolted Bonnet Gate Valve Maintenance Procedure, Revision 11, which resulted in over torquing the flange of residual heat removal heat exchanger bypass valves 712A and 712B.

Additional Tracking Items

None.

PLANT STATUS

Ginna began the inspection period operating at rated thermal power and remained at, or near, rated thermal power for the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (1 Sample)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 'B' emergency diesel generator following maintenance and testing on September 12, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (IP Section 03.01) (3 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Screenhouse operating floor on September 11, 2022

(2) Screenhouse basement on September 11, 2022

(3) Turbine building intermediate floor on September 23, 2022

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 'A' emergency diesel generator jacket water heat exchanger on July 6, 2022

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the main control room during:

• Response to a grid disturbance on July 19, 2022

• Reactivity control during a turbine driven auxiliary feedwater test on August 31, 2022

• Emergency diesel pre-job brief and activities to prepare for a surveillance test on September 7, 2022

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the simulator during licensed operator requalification training on July 26, 2022. The training involved a scenario that contained, but was not limited to, electrical safety bus failures, emergency diesel generator failures, and a loss of all offsite power.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (5 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) Safety-related 125 volt direct current battery chargers on August 1, 2022

(2) 'C' safety injection pump breaker logic testing to ensure the start function works on safety-related buses 14 and 16 on August 4, 2022

(3) Maintenance frequency changes to perform ultrasonic testing inspections of residual heat removal, safety injection, and containment spray piping on September 9, 2022

(4) Safety injection breaker preventative maintenance template and maintenance frequency on September 26, 2022

(5) Residual heat removal heat exchanger bypass valves 712A and 712B overhaul and maintenance on September 30, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Evaluation of plant risk (action Green) during unplanned 'B' emergency diesel generator lubricating oil filter replacement and instrumentation calibration on August 3, 2022

(2) Evaluation of plant risk (action Green) during planned turbine driven auxiliary feedwater maintenance and instrument calibration on August 31, 2022

(3) Evaluation of plant risk (action Green) during unplanned 'B' emergency diesel generator maintenance involving Kiene valve replacement on September 7, 2022

(4) Evaluation of plant risk (Green) during planned 'B' service water pump maintenance and motor replacement on September 19, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Operability of safety-related systems during an instrument air pressure decrease over a 4-minute period on August 16, 2022

(2) Operability of the 'A' emergency diesel generator following an identified jacket water pump tell-tale leak on August 30, 2022

(3) Operability of the 'A' motor driven auxiliary feedwater pump with increased motor vibration levels on the inboard horizontal location on September 6, 2022

(4) Common cause failure operability determination for the 'A' emergency diesel generator following 'B' emergency diesel generator high differential pressure alarm for the lubricating oil filter and strainer on September 14, 2022

(5) Operability of residual heat removal heat exchanger bypass valves 712A and 712B as pressure boundaries following the bonnet to valve body elevated torque, and boric acid build up on valve 712A on September 30, 2022

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) 'B' motor driven auxiliary feedwater lube oil cooler service water piping permanent modification ECP-21-000008 on September 16, 2022

Severe Accident Management Guidelines Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site's Severe Accident Management Guidelines were updated in accordance with the pressurized water reactor owners group Severe Accident Management Guidelines PWROG-15015-P and validated in accordance with Nuclear Energy Institute 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1, on September 22, 2022.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) Functional testing of the diesel fire pump following planned maintenance and inspections of the engine, control panel and pump on July 28, 2022

(2) Functional testing of the 'C' charging pump following planned pump maintenance and inspection of the variable frequency drive on August 3, 2022

(3) Operational testing of the 'B' emergency diesel generator following unplanned maintenance on the lubricating oil system filters and instrumentation on August 5, 2022

(4) Functional testing of the safety injection accumulator make-up pump following unplanned maintenance and inspection of the pump and check valve 2817J on August 17, 2022

(5) Operational testing of the turbine driven auxiliary feedwater pump following planned corrective maintenance and modification to the turbine quench tank and instrumentation on August 31, 2022

(6) Operational testing of the 'B' emergency diesel generator following unplanned engine maintenance on September 7, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (3 Samples)

(1) STP-I-9.1.18, "Undervoltage Protection - 480 Volt Safeguard Bus 18" on August 18, 2022

(2) STP-O-R-2.3B, "Diesel Generator B Trip Testing" on September 7, 2022

(3) STP-O-12.2, "Emergency Diesel Generator B" on September 7, 2022

In-service Testing (IP Section 03.01) (1 Sample)

(1) STP-O-2.1QA, "Safety Injection Pump A Quarterly Test" on September 15, 2022

FLEX Testing (IP Section 03.02) (1 Sample)

(1) STP-O-40.3B, "Beyond Design Basis Flex Pump PBD01B Flow Test" on July 25, 2022

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) The biennial emergency preparedness exercise was previously evaluated on August 24, 2021 at Ginna and documented in inspection report 05000244/2021501 (ML21271A046). The August 21, 2021 evaluated exercise did not include full participation by offsite agencies due to recovery actions that were still underway from Tropical Storms Henri and Ida which passed through the state of New York in the weeks prior to the exercise. On December 15, 2021, the NRC granted an exemption request (ML21344A206) for Ginna to delay completion of the offsite participation portion of the exercise as required by 10 CFR Part 50, Appendix E, Section IV.F.2.c. In addition to the inspection procedure scope requirements, the inspectors reviewed the July 13, 2022 exercise to determine if the 10 CFR Part 50, Appendix E, Section IV.F.2.c requirements were completed.

On July 13, 2022 with the participation of the offsite agencies the inspectors evaluated an emergency drill in the simulator control room and emergency offsite facility involving an Alert, Site Area Emergency and General Emergency declaration due to a scenario which contained, but was not limited to, a simulated loss of coolant accident in a reactor coolant loop, fuel failure and containment penetration failure.

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Workers exiting the radiological controlled area through contamination monitors

(2) Licensee surveys of potentially contaminated material leaving the radiological controlled area

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Boric acid transfer pump replacement

(2) Auxiliary building supply air handling unit preheat coil

(3) Operator activities into a locked high radiation area and high radiation area with continuous radiation protection coverage High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Locked high radiation area volume control tank room

(2) Locked high radiation area radiologically controlled filter room

(3) Locked high radiation area spent fuel pool filter room

(4) Locked high radiation area waste hold up tank room Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) Submitted data from July 1, 2021 through June 30, 2022

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) Submitted data from July 1, 2021 through June 30, 2022

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) Submitted data from July 1, 2021 through June 30, 2022

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) Submitted data from July 1, 2021 through June 30, 2022

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) Submitted data from July 1, 2021 through June 30, 2022

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Emergency response planning area sector W-4 missing from protective action recommendation chart AR 04492235

(2) Adverse reliability trend of FLEX equipment AR 04413873, OpESS Smart Sample 2020/01, Flex Equipment Design Control, Maintenance, and Testing

INSPECTION RESULTS

'A' Residual Heat Removal Heat Exchanger Bypass Isolation Valves 712A and 712B Over Torque Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None 71111.12 Systems NCV 05000244/2022003-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1.a, Procedures, when Ginna did not establish and implement written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, Section 3, Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems. Specifically, Ginna failed to adequately convey technical requirements into procedure M-37.108, Aloyco Bolted Bonnet Gate Valve Maintenance Procedure, Revision 11, which resulted in over torquing the flange of residual heat removal heat exchanger bypass valves 712A and 712B.

Description:

In June of 2022, NRC inspectors identified a dried boric acid deposit on the bonnet to valve body flange joint of residual heat removal heat exchanger bypass valve 712A.

Ginna entered the issue into the corrective action program as AR 04506193 and completed an associated operability evaluation which declared valve operability was maintained with the presence of dried boric acid. Residual heat removal valves 712A and 712B are manual isolation valves that are opened when the residual heat removal system is aligned for shutdown cooling.

Through the operability evaluation process Ginna identified that work order C19100743 performed in March of 1993 last torqued the bonnet to valve body flange joint to 150 ft-lbs. in accordance with procedure M-37.108, Aloyco Bolted Bonnet Gate Valve Maintenance Procedure, Revision 11. Ginna determined that 150 ft-lbs. exceeded the desired torque based on the joint design and contrary to the current specification of 90 to 98 ft-lbs. in procedure GMP-37-01-300/6/TV Aloyco, 6 Inch, 300 lb. Gate Valve Maintenance, Revision 00103, which became effective in 1999. Additionally, Ginna identified that the identical valve 712B had also been torqued to 150 ft-lbs. in April of 1992 per work order C19200863 using the same procedure M-37.108. Ginna documented this condition adverse to quality in the corrective action program as AR 04517523.

Ginna evaluated the excessive torque condition adverse to quality as part of the initial dried boric acid operability evaluation. This evaluation concluded the applied torque exceeded the longitudinal hub yield stress allowed for the valve body flange joint. Subsequently, Ginna determined that the applied torque did not exceed 70 percent of ultimate yield allowed by ASME Appendix F, which provided a reasonable assurance of valve operability.

Corrective Actions: Ginna performed an operability evaluation, extent of condition review and maintenance work orders relating to 712A. Long-term corrective actions include evaluating a replacement for 712A, design modification for 712B or maintenance of 712B.

Corrective Action References: 04506193, 04517523

Performance Assessment:

Performance Deficiency: The inspectors determined that Ginna failed to establish correct torque values in procedure M-37.108. An applicable vendor manual contained torque information therefore this performance deficiency was reasonably within the licensees ability to foresee and prevent.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Ginna applied a torque that exceeded yield stress on the valve flanges of 712A and 712B.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process for Findings At-Power, dated January 1, 2021. The inspectors performed a review of this finding using the guidance provided in IMC 0609 Appendix A, Exhibit 2, Mitigating Systems Screening Questions, and because 712A and 712B maintained operability this finding is of very low safety significance (Green)because the deficiency affected the design or qualification of a mitigating system, structure or component.

Cross-Cutting Aspect: This performance deficiency is not indicative of current licensee performance; therefore, no cross-cutting aspect applies.

Enforcement:

Violation: Technical Specification 5.4.1.a, Procedures, requires in part, Written procedures shall be established, implemented, and maintained covering the following activities: The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 3.c, identifies Shutdown Cooling System, and Section 3.d identifies Emergency Core Cooling System as recommended procedures. Constellation procedure M-37.108, Aloyco Bolted Bonnet Gate Valve Maintenance Procedure, Revision 11, implemented this requirement.

Contrary to the above, from 1992 until 1999, Ginna did not establish a procedure to apply the correct torque values to shutdown cooling and emergency core cooling systems. Specifically, procedure M-37.108 did not establish the correct torque values for a shutdown cooling system. As a result, the valve flanges were torqued to a value that exceeds the yield stress of the material.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation 71114.06 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

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

10 CFR 50.47(b)(10), requires, in part, that a range of protective actions have been developed for the plume exposure pathway emergency planning zone for emergency workers and the public, and guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway emergency planning zone appropriate to the locale have been developed.Section IV.B.1 of 10 CFR 50, Appendix E, requires, in part, that the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of State and local agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety.

Contrary to the above, from May 12, 2014 through April 11, 2022, Constellation failed to maintain in effect at Ginna an Emergency Plan that met the standards in 10 CFR 50.47(b).

Specifically, Constellation procedure EP-AA-111-F-13, Ginna PAR Flowchart, Page 1 Initial Protective Action Recommendation ONLY, Revision A, Table 1 omitted emergency response planning area W-4 in wind direction 327 to 348 degrees. As a result, Constellation would not have recommended W-4 to be evacuated during a rapidly progressing severe accident, when the page 1 flow chart for initial protective action recommendation only Table 1 was used for wind direction from 327 to 348 degrees. Constellations immediate corrective actions included entering the issue into their corrective action program and correcting the error with the emergency response planning area sector in Table 1.

Significance/Severity: Green. The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated December 20, 2019. Since the performance deficiency affected the emergency preparedness cornerstone, the inspectors were directed to Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, to assess the issues significance. The inspectors utilized Table 5.10-1 for planning standard function (b)(10) and mitigating factors which were in place at the time of the performance deficiency. The mitigating factors are specific to the scenario of a rapidly progressing event, where the initial protective action recommendation is being made, when wind direction was from 327 to 348 degrees. The first mitigating factor is that W-4 is not in the direct path, emergency response planning areas W-1, W-2, W-7 and W-6 are within the direct wind path of wind direction 327 to 348 degrees. Emergency response planning area sector W-4 is included because of an elective wind variance study in accordance with NUREG-0654 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, Supplement 3 that added two emergency planning area sectors on either side of the wind direction. Additionally, while emergency response planning area sector W-4 was not identified for the initial protective action recommendation Table 1, that flowchart path is not used again. Furthermore, emergency response planning sector W-4 was included in all other succeeding procedure steps and processes, and would therefore be captured in all future protective action recommendations. Given the specific mitigating factors and risk insights, the regional management, inspectors, and the Nuclear Security and Incident Response Division of Preparedness and Response agreed to the conclusion of dispositioning the finding as very low safety significance (Green). Because this violation is of very low safety significance, Green, and has been entered into Constellations corrective action program as IR 04492235, this finding is being treated as a non-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy.

Corrective Action References: Issue Report 04492235 was written to document this issue, and the protective action recommendation chart was corrected April 11, 2022. This issue report also captured the root cause investigation report.

Assessment - Emergency Response Planning Area W-4 missing from Protective 71152A Action Recommendation Chart The inspectors reviewed corrective actions regarding Constellations omission of emergency response planning area W-4 from Table 1 of Ginnas Protective Action Recommendation Chart in procedure EP-AA-111-F-13, Ginna PAR Flowchart, Revision A for the north-northwest wind direction between 327 and 348 degrees as required by a rapidly progressing severe accident.

The inspectors reviewed Constellations initial and long-term corrective actions. The issue was documented in Constellations corrective action program as AR 04492235 and root cause investigation report Missing Sector in Table 1 of EP-AA-111-F-13. Constellation determined the omitted emergency response planning area was due to less than adequate rigor in technical human performance tool use during first-time preparation, implementation, and review of the NEI 12-10 template into procedure EP-AA-111-F-13.

Constellation identified that in 2014 the licensee developed protective action recommendations with information supplied by a vendor who utilized NEI 12-10, Revision 0 template. This template included evacuation time estimates and an elective wind persistence study. Specific to Ginna, the elective wind persistence study added two emergency response planning areas adjacent to the identified wind direction. Constellation notes that omitted emergency response planning area occurred in 2014 when updates were implemented for the Ginna protective action recommendation chart, specifically the wind persistence study which identified additional adjacent sectors on either side of the sections required by regulation. Wind persistence issues relate to a study of site specific meteorology wind shift data on a timescale and correlating emergency response planning area sector evaluation times, NUREG-0654 FEMA-REP-1, Revision 1 Supplement 3 contains additional information.

The inspectors independently performed an in-depth review and held discussions with Constellation staff regarding emergency response procedure changes, root cause analysis, and corrective actions associated with omission of W-4 on the protective action recommendation chart in procedure EP-AA-111-F-13 Revision A. The inspectors assessed Constellations problem identification threshold, cause analysis, prioritization, and timeliness of corrective actions to determine whether Constellation was taking timely and appropriate corrective actions.

As a result of its review, the inspectors concluded that Constellations actions in identifying and resolving the omitted emergency planning area W-4 were aligned with the safety significance. The inspectors determined the details relating to the omission of emergency response planning are W-4 were unique, in that W-4 was added specifically because of the elective wind persistence study not due to the direct wind direction. The inspectors also confirmed that subsequent procedure steps identified emergency response planning are W-4 as a sector which would be included in a protective action recommendation. Lastly, the inspectors noted that dose assessors would have an opportunity to identify emergency response planning area W-4 as an area subject to a protective action recommendation.

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 the deficiency was of greater than minor significance and is documented within this integrated inspection report 2022003 as a licensee-identified violation of Green significance in accordance with the NRCs Enforcement Policy.

Assessment - Flex Equipment Failure Trend 71152A The inspectors reviewed Constellations work group evaluation, corrective actions, procedure changes, completed work orders and conducted field walkdowns regarding issues with flex system components. Constellation identified within their corrective action program an action to evaluate and correct adverse trends with the flex system to promote higher levels of reliability.

The inspectors reviewed Constellations initial and long-term corrective actions. The issues were documented in their corrective action program as AR 04413873. Constellation identified that from October 2019 to April 2021 there had been several condition reports relating to degraded batteries, battery tenders or power cords that could or have resulted in flex equipment failing to start or meet the intended purpose. Additionally, over the same period Constellation identified failures with engine block heaters, and degradation of equipment trailers which could impact relocation and leveling of Flex equipment.

Constellations review of the flex equipment issues was captured in a work group evaluation that concluded the identified conditions adverse to quality could be grouped into three categories: relocation equipment, block heaters, and battery/power issues. Corrective actions associated with the issue were to develop new and modify existing preventative maintenance strategies, generate maintenance work orders, and change associated procedures. Noting that the preventative maintenance actions are captured in AR 04411720.

The inspectors independently conducted field walkdowns of the flex equipment trailers, battery tenders, power cords, batteries, diesel engines, pumps, and compressors. The inspectors reviewed Constellations corrective actions associated with procedure changes, preventative maintenance strategies, and completed work orders. During the field walkdowns the inspectors identified different configurations of block heaters and block heater controllers connected or disconnected. The inspectors reviewed the corrective actions and corresponding procedure change to procedure O-6.1 Equipment Operator Rounds and Log Sheet Revision 126. The inspectors noted this procedure Step 6.2.18 is not clear to the performer if the block heater controller is included when directing to plug in or disconnect the block heaters. The inspectors shared this assessment with Constellation, who acknowledged that clarity could be added in the procedure.

As a result of its review the inspectors concluded that Constellations actions in identifying and resolving the various flex equipment issues was commensurate with the safety significance. 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 that none of the conditions were deficiencies of greater than minor significance and therefore are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 14, 2022, the inspectors presented the radiological hazard assessment and exposure controls inspection results to James Bement, radiation protection manager and other members of the licensee staff.

• On October 11, 2022, the inspectors presented the integrated inspection results to Doug Hild, plant manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.12 Corrective Action AR 04506193 DBA on 712A RHR HX Bypass Isolation Valve 06/17/2022

Documents AR 04517523 High Body/Bonnet Torque for 712B 08/18/2022

Resulting from

Inspection

Miscellaneous PMC-21-131286 Change frequency of P201400 based on PHC approval of GIN-

21-0048 Alternative 5

PMC-21-132322 Revise PM PS00745 and PS00956 to start SI C from only one

bus (14 or 16) during surveillance testing

Procedures ER-AA-200 Preventative Maintenance Program Revision 6

ER-AA-200-1004 PCM Templates Revision 1

M-37.108 Aloyco Bolted Bonnet Gate Valve Maintenance Procedure Revision 11

VTD-A0200-4002 Maintenance Manual - Manually Operated Gate Valves Revision 1

Work Orders 9100743 Replace Bonnet Gasket on V-712A 03/23/1993

200863 Repair Bonnet Leak on V-712B 03/23/1993

71111.15 Operability OPEVAL-22-002 RHR 712A and 712B - Dry boric acid on 712A and over torque Revisions

Evaluations of 712A and 712B 000, 001,

2

71152A Corrective Action AR 04411720 Flex Equipment PM Optimization 03/23/2021

Documents AR 04413873 Trending IR for Flex Equipment Issues 04/01/2021

AR 04492235 Missing Sector in Table 1 of EP-AA-111-F-13 04/11/2022

Work Group Revision 0

Evaluation AR

04413873

Corrective Action AR 04509610 Easternmost steam gland on LP turbine leaking steam into TB 07/06/2022

Documents AR 04511590 Small roof leak behind bus 14 07/18/2022

Resulting from AR 04517790 Dry Boric Acid on 868D 08/19/2022

Inspection AR 04524721 Damaged wall panels behind MCC B 09/26/2022

Miscellaneous AR 04492235 Missing Sector in Table 1 of EP-AA-111-F-13 06/2/2022

Root Cause

Evaluation

Procedures O-22 Cold Weather Walkdown Procedure Revision 033

O-23 Hot Weather Seasonal Readiness Walkdown Revision 024

Inspection Type Designation Description or Title Revision or

Procedure Date

O-6.1 Equipment Operator Rounds and Log Sheet Revision 126

Work Orders C93767661 Annual Functional Test of the Flex Fuel Oil Transfer Trailers

C93781036 Perform Annual PM Inspection on PBD04 Alt RCS Injection

Diesel Driven Flex Pump and Diesel Engine

C93809753 Flex Cable and Cable Trailer Inspection

16