IR 05000244/2024011
| ML24101A111 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/10/2024 |
| From: | Glenn Dentel Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024011 | |
| Download: ML24101A111 (1) | |
Text
April 10, 2024
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - FIRE PROTECTION TEAM INSPECTION REPORT 05000244/2024011
Dear David Rhoades:
On March 21, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC and discussed the results of this inspection with Daren Blankenship, Senior Vice President, 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 (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; 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 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety
Docket No. 05000244 License No. DPR-18
Enclosure:
As stated
Inspection Report
Docket Number:
05000244
License Number:
Report Number:
Enterprise Identifier: I-2024-011-0016
Licensee:
Constellation Energy Generation, LLC
Facility:
R.E. Ginna Nuclear Power Plant, LLC
Location:
Ontario, NY
Inspection Dates:
March 4, 2024 to March 21, 2024
Inspectors:
L. Cline, Senior Reactor Inspector
M. Patel, Senior Reactor Inspector
J. Tifft, Reactor Inspector
Approved By:
Glenn T. Dentel, Chief
Engineering Branch 2
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team 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.
List of Findings and Violations
Failure to Evaluate a Temporary Change to Electrical Cabinets in the Relay Room for Fire Protection Impact Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000244/2024011-01 Open/Closed
[H.13] -
Consistent Process 71111.21N.
The team identified a Green finding and associated non-cited violation (NCV) of the Ginna Operating License Condition 2.C.(3), Fire Protection, where Constellation failed to evaluate a temporary change to the plant for fire protection impact. Specifically, the licensee did not perform a required fire protection applicability review for a test configuration in the relay room which allowed combustible test equipment in the room and three normally closed electrical enclosure doors to remain open.
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.
REACTOR SAFETY
===71111.21N.05 - Fire Protection Team Inspection
Structures, Systems, and Components Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)===
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).
- (1) Detection System
- (2) Water Suppression System
- (3) National Fire Protection Association (NFPA) Diesel KDG09 and Standby Auxiliary Feedwater (SAFW) Diesel KDG08
- (4) Auxiliary Feedwater System
Fire Protection Program (FPP) Administrative Controls (IP Section 03.02) (2 Samples)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
- (1) NFPA 805 Monitoring Program and Fire Probabilistic Risk Assessment (PRA)
- (2) Control of Ignition Sources (Hot Work Program)
Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)
The inspectors verified the following:
a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.
b. The adequacy of the design modification, if applicable.
c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.
d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.
e. Post-fire Safe Shutdown operating procedures, such as abnormal operating procedures, affected by the modification were updated.
- (1) ECP-23-000461, Yard Loop Pipe Replacement
- (2) ECP-23-000015, Oil Storage Room Automatic Deluge Fire Suppression System S16 Replacement
INSPECTION RESULTS
Failure to Evaluate a Temporary Change to Electrical Cabinets in the Relay Room for Fire Protection Impact Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000244/2024011-01 Open/Closed
[H.13] -
Consistent Process 71111.21N.05 The team identified a Green finding and associated non-cited violation (NCV) of the Ginna Operating License Condition 2.C.(3), Fire Protection, where Constellation failed to evaluate a temporary change to the plant for fire protection impact. Specifically, the licensee did not perform a required fire protection applicability review for a test configuration in the relay room which allowed combustible test equipment in the room and three normally closed electrical enclosure doors to remain open.
Description:
On September 11, 2023, the licensee implemented monitoring of the overspeed protection controller circuit as part of the adverse condition monitoring plan put in place following the reactor scram on September 9, 2023. This monitoring required recording equipment to be installed on the electrohydraulic (EH) cabinets in the relay room. A temporary change to the configuration of the relay room cabinets was performed during the implementation (work order C93941104), requiring that the three EH cabinets remain open to accommodate the connection of the test equipment. These cabinets are normally closed and are modeled as closed in the site fire PRA. Additionally, a transient combustible permit (TCP-1345) was issued for the addition to the relay room of the testing equipment (recorders and test leads) and a plastic cart.
Procedure CC-AA-415, Maintenance Specification - Measurement and Test Equipment, step 6.7, requires that measurement and test equipment be removed within 90 days of installation or a 50.59 review be performed. On December 12, 2023, a 50.59 review (B-2023-023, Revision 0) was performed. However, this review did not identify the impact this equipment configuration would have on the fire protection program. Specifically, the open cabinets would change the impact that a fire in the cabinet would have. The open configuration would result in an increase in both heat release rate and the size of the zone of influence of a potential fire.
Additionally, the added transient combustibles of the test equipment and plastic cart next to the open cabinets would also increase the size of the potential fire. This would change the analysis for the relay room area in the fire PRA. The licensee did not perform an evaluation for this fire PRA impact consistent with requirements in procedures ER-AA-600-1068, Fire PRA Risk Evaluation Support for NFPA 805 Program and LS-AA-128-101, Regulatory Review of Proposed Changes to the Approved NFPA 805 Fire Protection Program. As of the date of the exit, this configuration still existed unanalyzed in the relay room.
Corrective Actions: Initially upon inspector identification, Constellation instituted an hourly fire watch of the relay room. Constellation revised the 50.59 evaluation for this work order (B-2023-023, Revision 1) to account for the impact of the increased fire risk. They also performed an NFPA 805 Fire PRA Risk Screening and Plant Configuration Evaluation in accordance with ER-AA-600-1068. This evaluation screened to requiring a detailed risk evaluation. That risk evaluation was performed and determined that the bounding risk for this configuration was below the self-approval limit of less than 1x10-7/year for core damage frequency (CDF) and less than 1x10-8/yr for large early release frequency (LERF). Upon the results of this detailed risk analysis and replacing the combustible plastic cart with a metal one, Constellation secured the fire watch.
Corrective Action References: AR 04760102
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to perform a fire protection applicability review for the temporary configuration change was a performance deficiency.
Ginna Operating License Condition 2.C.(3), Fire Protection paragraph (a)(2) requires a plant change evaluation be performed to evaluate if the change in risk is below the threshold for NRC review. Prior to implementing the temporary change, the licensee did not complete a plant change evaluation that demonstrated that the change resulted in a risk increase of less than required for NRC review.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, by not evaluating the modified configuration, the licensee failed to evaluate the likelihood of a design fire with a higher heat release rate and increased zone of influence.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors determined this finding to be under the Fire Prevention and Administrative Controls category, in accordance with Table 1.2.1, Finding Categories of IMC 0609, Appendix F. A low degradation rating could not be assigned in accordance with step 1.3.1. This issue screened to very low safety significance (Green) in Phase 1, step1.4.1-B because the finding adversely affected an area with adequate automatic detection and suppression. The relay room is protected by adequate detection and an automatic halon suppression system. Additionally, the inspectors assessment also took into consideration a risk evaluation completed by Constellation that demonstrated that the change in risk is within the limit for self-approval of the temporary change. Therefore, the inspectors determined the finding is of very low safety significance (Green).
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Specifically, individuals did not demonstrate a consistent use of the fire protection program impact and change review process and did not incorporate risk insights into the decision making of whether an evaluation was necessary.
Enforcement:
Violation: Ginna Operating License Condition 2.C.(3), Fire Protection paragraph (a)(2) states that prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year
- (yr) for CDF and less than 1x10-8/yr for LERFThe change may be implemented following completion of the plant change evaluation. Contrary to the above, on December 12, 2023 and ongoing at the time of the exit meeting, the licensee implemented a change to the Ginna approved fire protection program without prior NRC approval, but did not complete a plant change evaluation that demonstrated that the change resulted in a risk increase of less than 1x10-7/yr for CDF and less than 1x10-8/yr for LERF.
Specifically, the licensee did not perform a required fire protection applicability review for a test configuration in the relay room which allowed combustible test equipment in the room and three normally closed electrical enclosure doors to remain open.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 21, 2024, the inspectors presented the fire protection team inspection results to Daren Blankenship, Senior Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N.05 Calculations
DA-ME-2000-052
Fire Detection System Evaluation
G1-SDP-005
Risk Evaluation of Three Open EHC Cabinets with a Cart
Corrective Action
Documents
Corrective Action
Documents
Resulting from
Inspection
Drawings
10905-0656
Elementary Wiring Diagram, TDAFW Pump Discharge
Valve MOV 3996
21946-0656
TDAFW Pump Discharge Valve MOV 3996 Control
Schematic
33013-2539
Plant Load Distribution One Line Wiring Diagram
33013-2886
SAFW Building Annex - Embedded Conduit Layout
33013-3131
SAFW and NFPA 804 - 1000 kW Standby Diesel
Generator Sets - 480 Vac Single line
Engineering
Changes
ECP-23-000015-
001-F-02
Oil Storage Room Automatic Deluge Fire Suppression
System S16 Replacement
ECP-23-000461
Yard Loop Pipe Replacement
Miscellaneous
Ginna Fire PRA Notebook
Measurement and Test Equipment Evaluation for Work
Order C93941104
09/10/2023
NFPA 805 Fire PRA Risk Screening and Plant
Configuration Evaluation for B-2023-023 Rev 1
03/22/2024
B-2023-023
50.59 Review for Work Order C93941104
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
B-2023-023
50.59 Review for Work Order C93941104
EPM-FPPR
FR-H.1
Background Information for Ginna Station Emergency
Operating Procedure FR-H.1 Response to Loss of
Secondary Heat Sink
G1-FQ-F001
R. E. Ginna Fire PRA Notebook Fire Risk Quantification
G1-PRA-003
Ginna Nuclear Power Plant Probabilistic Risk Analysis
Success Criteria Notebook
SC-3.15.15
R. E. Ginna Nuclear Power Plant Technical Procedure -
Emergency Fire Equipment Inventory and Inspection
Completed
2/28/2023
Procedures
2.12
Non-functional Equipment Important to Safety
117
Maintenance Specification - Measurement and Test
Equipment
EOP Att-22
EOP Attachment Restoring Feed Flow
007
EOP Att-5.1
014
Fire PRA Risk Evaluation Support for NFPA 805 Program
NFPA 805 Monitoring Program
ER-FIRE.0
Control Room Response To Fire Alarms And Reports
ER-FIRE.1
Alternate Shutdown For Control Room Abandonment
FR-H.1
R.E. Ginna Nuclear Station - Response to Loss of
Secondary Heat Sink
Regulatory Review of Proposed Changes to the Approved
NFPA 805 Fire Protection Program
Operator Response Time Program
Fire Prevention for Hot Work
Fire Protection System Impairment Control
Control of Transient Combustible Material
OP-GI-102-106
Operator Response Time Program At Ginna Station
Work Orders
C93773580
Phase 1 Replacement Domestic Water Piping In PA with
2/02/2020
C93855778
C93964384