IR 05000244/2022010
| ML22256A046 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/13/2022 |
| From: | Erin Carfang NRC/RGN-I/DORS |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Carfang E | |
| References | |
| IR 2022010 | |
| Download: ML22256A046 (13) | |
Text
September 13, 2022
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000244/2022010
Dear David Rhoades:
On August 12, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your R.E. Ginna Nuclear Power Plant, LLC and discussed the results of this inspection with Daren Blankenship, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. 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 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Digitally signed by Erin E.
Erin E. Carfang Date: 2022.09.13 Carfang 12:24:20 -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: 05000244/2022010 Enterprise Identifier: I-2022-010-0015 Licensee: Constellation Energy Generation, LLC Facility: R.E. Ginna Nuclear Power Plant Location: Ontario, New York Inspection Dates: July 25, 2022 to August 12, 2022 Inspectors: J. England, Resident Inspector N. Floyd, Senior Reactor Inspector D. Kern, Senior Reactor Inspector C. Swisher, Resident Inspector Approved By: Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at R.E.
Ginna Nuclear Power Plant, 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees problem identification and resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the 480 volts alternating current (VAC) electrical system and the residual heat removal system.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
- Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Problem Identification and Resolution Effectiveness: The team determined that the problem identification and resolution program (referred to as the corrective action program in the licensees procedures) for R.E. Ginna Nuclear Power Plant (Ginna) was generally effective and adequately supported nuclear safety and security.
Problem Identification: The team determined that, in general, the licensee identified issues and entered them into the corrective action program at a low threshold. However, the team identified one observation regarding plant conditions that were not previously captured in Ginnas corrective action program. This observation is documented below.
Problem Prioritization and Evaluation: Based on the samples reviewed, the team determined that the licensee appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. In most cases, the licensee appropriately screened condition reports for operability and reportability, categorized condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution.
Corrective Actions: The team determined that, in general, the overall corrective action program performance related to resolving problems was effective. In most cases, the licensee implemented corrective actions to resolve problems in a timely manner. However, the team identified one observation regarding the extent of condition actions not performed at the earliest opportunity. This observation is documented below.
Assessment 71152B Operating Experience: The team determined that the licensee appropriately evaluated industry operating experience for its relevance to Ginna. In most cases, the licensee appropriately incorporated both internal and external operating experience into plant procedures and processes, as well as lessons learned for training and pre-job briefs.
Assessment 71152B Self-Assessments and Audits: The team reviewed a sample of self-assessments and audits to assess whether the licensee was identifying and addressing performance trends. The team determined that the licensee had an effective self-assessment and audit process at Ginna.
Assessment 71152B Safety-Conscious Work Environment: The team interviewed approximately 25 individuals.
The purpose of these interviews was to evaluate the willingness of licensee staff to raise nuclear safety issues; to evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and to evaluate the licensees safety-conscious work environment. The personnel interviewed were randomly selected by the team from the Operations, Engineering, Maintenance, Security, Chemistry, Radiation Protection, and Emergency Preparedness work groups. The team also interviewed licensee staff during the discussion of technical issues as part of the corrective action program review. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP)representative to assess her perception of the plant employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files. All individuals interviewed indicated that they would raise safety concerns.
All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern.
Interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of Constellation's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety-conscious work environment issues were adequately implemented.
Observation: Extent of Condition Actions Not Performed at Earliest Opportunity 71152B The team identified an observation regarding two examples where extent of condition actions were not performed at the earliest opportunity. Specifically, the licensee generated action tracking items (denoted as ACITs in the licensees corrective action program) to perform extent of condition actions for identified issues. These actions had varying due dates and were either deferred or not performed. Examples included:
- Issue Report (IR) 04336478 documented an issue with motor control center MCC-D missing internal seismic brackets. MCC-D houses circuit breakers for multiple safety-related systems. The licensee generated extent of condition actions to perform inspections on other electrical buses to verify whether a similar condition existed; however, the seismic mounting verification inspections of 480 VAC Buses 16, 17 & 18 were not performed. These buses contain electrical components for multiple safety-related systems. The original issue was identified in 2014. Work orders to perform the inspections were cancelled during past maintenance activities. The licensee captured the teams observation in IR 04514477 and scheduled the extent of condition actions as part of future planned maintenance.
- IR 04282792 documented a bound hand control valve HCV-487B on the controller board for AOV-4298 in the turbine-driven auxiliary feedwater system. The licensee generated an extent of condition action to perform visual inspections for similar degradation with hand controllers for other systems; however, the inspections have been deferred for the five remaining hand controllers installed in multiple safety-related systems. The original issue was identified in 2019. The remaining inspections are scheduled for 2023 and 2024.
The licensee determined that the component and associated systems remained operable for both issues captured in the two examples. The extent of condition actions were assignments to improve performance and not to correct a known problem. Licensee procedure PI-AA-125, Correct Action Program, differentiates ACITs from formal corrective actions in that ACITs are not actions to correct conditions adverse to quality. This procedure does not require or provide guidance on the timeliness of ACIT completion and allows the extension of due dates with no formal documentation. The team determined there was no performance deficiency associated with the extent of condition actions; however, the team observed that these actions could have been performed at an earlier opportunity and would provide insights for similar conditions.
Observation: Plant Conditions Not Previously Identified by Licensee Staff 71152B The team identified an observation regarding plant conditions that were not previously captured in Ginnas corrective action program. Specifically, the team performed walkdowns of accessible plant areas and observed a variety of adverse conditions that should have been identified and evaluated by the licensee. Example of conditions included:
- IR 04513538, long-standing operator aid tag not removed from sub-basement room
- IR 04513715, B residual heat removal pump missing a shaft guard
- IR 04515954, evidence of moisture on bottom of electrical panel door in the B battery room
- IR 04516103, corrosion in a fire water piping flange located in the auxiliary building
- IR 04516127, motor operated valve actuator leaking grease
- IR 04516131, incorrect revision of a procedure staged in the auxiliary building
- IR 04516296, electrohydraulic fluid inappropriately stored in the turbine building The team determined that the licensees failure to promptly identify, evaluate, and correct the adverse conditions was a performance deficiency. The team reviewed the conditions on an individual basis and determined each issue to be of minor significance in accordance with Appendix B of NRC Inspection Manual Chapter IMC 0612. The licensee staff promptly entered each issue into their corrective action program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 12, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Daren Blankenship, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action 4113127
Documents 4187909
4195963
230759
239042
242696
253986
255421
258517
266529
23014
28832
4331247
4331392
4332855
4332980
4332999
4333162
4335290
4335570
4336478
4337682
4338509
4339004
4340054
4340290
4341722
4344224
4346987
4347683
4347791
Inspection Type Designation Description or Title Revision or
Procedure Date
4349484
4351801
4354540
4357265
4358006
4358711
4358842
4358902
4362936
4363124
4363597
4363728
4366987
4371341
4377943
4378218
4378335
4380679
4387962
4388834
4403107
4407857
4409639
4419964
21357
22720
23071
29487
4430256
4450520
4450598
4451289
4452400
Inspection Type Designation Description or Title Revision or
Procedure Date
4453282
4453546
4453874
4459261
4466775
4473589
4473666
4473740
4477204
4493870
4494170
4496056
4498195
Corrective Action 4512348
Documents 4513554
Resulting from 4514636
Inspection 4514946
4515131
4515934
4516374
4516569
4516573
Procedures ER-AA-520 Instrument Performance Trending Revision 5
OP-AA-108-115 Operability Determinations (CM-1) Revision 24
PI-AA-115 Operating Experience Program Revision 5
PI-AA-120 Issue Identification and Screening Process Revision 12
PI-AA-125-1001 Root Cause Analysis Manual Revision 6
PI-AA-125-1003 Corrective Action Program Evaluation Manual Revision 7
PI-AA-125-1006 Investigations Techniques Manual Revision 6
Self-Assessments 4173930-32 Focused Area Self-Assessment, Fleet Inservice Testing (IST) 01/01/2021
Program
4373188 Clearance and Tagging Self-Assessment 11/17/2020
4378874-06-02 Rad Worker Performance 12/31/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
4384059-02 Operations Training Comprehensive Self-Assessment 09/03/2021
4394225 Ginna In-Storage Maintenance (ISM) Program Assessment 09/07/2021
NOSA-GIN-20-04 Chemistry Audit Report 04/08/2020
NOSA-GIN-20-05 Engineering Programs Audit Report 07/15/2020
NOSA-GIN-20-09 External Event and Emergency Operations Audit Report 08/21/2020
NOSA-GIN-21-06 Radiation Protection Audit Report 11/12/2021
NOSA-GIN-22-01 Maintenance Audit Report 02/09/2022
Work Orders C90685795
C91580104
C91640025
C91640026
C93273024
C93273024
C93658888
C93666534
C93711260
C93724145
C93747008
C93747483
C93757273
C93759668
C93759887
C93760195
C93760398
C93761200
C93763892
C93769757
C93771361
C93774129
C93774882
C93789284
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