IR 05000244/2009003
| ML092080369 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/27/2009 |
| From: | Glenn Dentel Reactor Projects Branch 1 |
| To: | John Carlin Ginna |
| Dentel, G RGN-I/DRP/BR1/610-337-5233 | |
| References | |
| IR-09-003 | |
| Download: ML092080369 (36) | |
Text
July 27, 2009
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000244/2009003
Dear Mr. Carlin:
On June 30, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your R.E. Ginna Nuclear Power Plant. The enclosed integrated inspection report documents the inspection results, which were discussed on July 9, 2009, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents two NRC-identified findings of very low safety significance (Green).
These findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV, you should provide a response within 30 days of the date of this inspection report, with the basis of your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at R.E. Ginna Nuclear Power Plant. In addition, if you disagree with the characterization of any finding 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 Regional Administrator, Region I, and the NRC Resident Inspector at R.E. Ginna Nuclear Power Plant.
The information you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Glenn T. Dentel, Chief Projects Branch 1 Division of Reactor Projects
Docket No. 50-244 License No. DPR-18
Enclosure: Inspection Report No. 05000244/2009003
w/ Attachment: Supplemental Information
cc w/encl:
M. J. Wallace, Vice - President, Constellation Energy B. Barron, President, CEO & Chief Nuclear Officer, Constellation Energy Nuclear Group, LLC P. Eddy, Electric Division, NYS Department of Public Service C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law C. Fleming, Esquire, Senior Counsel, Nuclear Generation, Constellation Nuclear Energy Nuclear Group, LLC T. Harding, Director, Licensing, Constellation Energy Nuclear Group, LLC A. Peterson, SLO Designee, New York State Energy Research and Development Authority F. Murray, President & CEO, New York State Energy Research and Development Authority G. Bastedo, Director, Wayne County Emergency Management Office M. Meisenzahl, Administrator, Monroe County, Office of Emergency Management T. Judson, Central New York Citizens Awareness Network
SUMMARY OF FINDINGS
IR 05000244/2009003; 04/01/2009 - 06/30/2009; R.E. Ginna Nuclear Power Plant (Ginna),
Access Control to Radiological Significant Areas, Radiation Monitoring Instrumentation and Protective Equipment.
The report covered a 3-month period of inspection by resident inspectors and region-based inspectors. Two Green non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect for each finding was determined using IMC 0305, Operating Reactor Assessment Program. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Cornerstone: Occupational Radiation Safety
- Green.
An NRC-identified NCV of Technical Specification 5.3.1, Plant Staff Qualifications, was identified for failure to ensure senior radiation protection technicians (RPTs) met the minimum qualification requirements specified in American National Standards Institute (ANSI) N18.1-1971, American National Standard Selection and Training of Nuclear Power Plant Personnel. Ginna entered this performance deficiency into their corrective action program (CAP) for resolution. Ginnas initial corrective actions included verifying all senior RPTs currently employed at the site meet the experience requirements contained in ANSI N18.1-1971. Future corrective actions will involve modifying Ginna procedures regarding the training and qualification of senior RPTs to ensure they meet ANSI N18.1-1971.
This finding is more than minor because, if left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern. This finding was evaluated using IMC 0609, Appendix C, Occupational Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (Green) because it did not involve: (1) as low as is reasonably achievable (ALARA) planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. Since this performance deficiency occurred in 2006 and does not reflect current performance, no cross-cutting aspect was assigned. (Section 2OS1)
Cornerstone: Emergency Preparedness
- Green.
An NRC-identified NCV of 10 CFR 50.54(q) was identified for a failure to follow and maintain in effect emergency plans which met the standards in 50.47(b). Specifically, 50.47(b)(8) states that adequate emergency facilities and equipment to support the emergency response are provided and maintained. Contrary to this requirement, Ginna failed to provide spectacle adapter kits for all eyeglass wearers (i.e., non-soft contact wearers) that were key emergency response organization personnel who were potentially required to wear a self-contained breathing apparatus (SCBA) in order to fulfill emergency response functions. Ginna entered this performance deficiency into their CAP for resolution. Ginnas correction actions included revising procedures and electronic data files that govern the training and qualification of licensed operators to include steps that ensure licensed operators who require corrective lenses are provided SCBA lens inserts.
This finding is more than minor because, if left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern. The inspectors determined that the finding was of very low safety significance (Green) using IMC 0609, Appendix B,
Emergency Preparedness SDP, in that it did not involve a risk-significant planning standard (PS) and was not indicative of a PS functional failure. An adequate number of SCBA-qualified plant personnel with no vision correction needed, wearers of soft contacts, or personnel with vision correction lenses, designated as key emergency responders, were available for actual response in the event of an actual emergency. Therefore, the issue did not result in the failure to meet an emergency PS. This finding has a cross-cutting aspect in the area of human performance because Ginna failed to ensure that equipment was available and adequate for key emergency response personnel (H.2.d per IMC 0305). (Section 2OS3)
Other Findings
None.
REPORT DETAILS
Summary of Plant Status
R.E. Ginna Nuclear Power Plant (Ginna) began the inspection period operating at full rated thermal power (FRTP). On May 17, 2009, plant power was reduced to 48 percent when the A circulating water pump suffered a mechanical failure. While the pump was undergoing repairs, plant power was maintained less than 60 percent. Following the completion of repairs, plant power was returned to FRTP on June 1 and operated at full power for the remainder of the report period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
==1R01 Adverse Weather Protection (71111.01 - Two samples)
==
.1 Hot Weather Preparations
a. Inspection Scope
The inspectors reviewed Ginnas preparations for hot weather and performed walkdowns of the plant areas during the week of April 13, 2009. To perform the review, the inspectors used the criteria and design criterion outlined in Ginna procedure O-23, Hot Weather Seasonal Readiness Walkdown, Revision 00400, and the updated final safety analysis report (UFSAR), Revision 21. As part of the walkdown, local area temperatures were checked, as well as the operability of ventilation and air conditioning (A/C) cooling systems, to ensure that the plant was prepared to handle warm weather conditions. Areas of focus consisted of the A and B emergency diesel generator (EDG) rooms, the main feed pump room, the standby auxiliary feedwater (SAFW) pump room, and the screen house. Documents reviewed for each inspection in this report are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Grid Stability
a. Inspection Scope
Using the criteria in Ginna procedure O-6.9, Ginna Station Operating Limits for Station 13A Transmission, Revision 03201, the inspectors evaluated the readiness of offsite and alternate A/C power systems. The inspectors verified that communication protocols between the transmission system operator and the plant were specified in Ginnas procedures to ensure appropriate information was being exchanged. The inspectors verified that the procedures addressed measures to monitor and maintain the availability and reliability of these systems during adverse weather conditions. In addition, the inspectors verified that the procedures were implemented as required during a period of inclement weather that occurred on June 15, 2009.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
Partial System Walkdown (71111.04Q - Four samples)
a. Inspection Scope
The inspectors reviewed the alignment of system valves and electrical breakers to ensure proper in-service or standby configurations as described in plant procedures, piping and instrument drawings (P&IDs), and the UFSAR. During the walkdown, the inspectors evaluated the material condition and general housekeeping of the system and adjacent areas. The inspectors also verified that operators were following plant technical specifications (TSs) and system operating procedures.
The following plant system alignments were reviewed:
- On April 6, 2009, the inspectors performed a walkdown of the safety injection (SI)system flow paths while the C SI pump was removed from service for planned maintenance. During this walkdown, valve positions were compared to system drawing 33013-1262, SI and Accumulators, Rev. 25;
- On May 11, 2009, the inspectors performed a walkdown of the A train of the residual heat removal (RHR) system before the B RHR train was removed for a scheduled surveillance test. During this walkdown, valve positions were compared to system drawing 33013-1247, Auxiliary Coolant and RHR, Rev. 44;
- On May 26, 2009, the inspectors performed a walkdown of the A train of the motor-driven auxiliary feedwater (MDAFW) system before the turbine-driven auxiliary feedwater (TDAFW) train was removed for a scheduled surveillance test. During this walkdown, valve positions were compared to system drawing 33013-1237, Auxiliary Feedwater (AFW), Rev. 48; and
- During the weeks of June 8 and June 15, 2009, the inspectors performed a walkdown of the containment penetration cooling system, while the service water (SW) heat exchanger (HX) for the system was out of service due to planned maintenance activities. During the walkdown, valve and breaker positions were compared to system drawing 33013-1866, Containment Heating, Ventilation, and Air Conditioning (HVAC)
Systems Penetration Cooling System, Rev 24.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
Quarterly Inspection (71111.05Q - Five samples)
a. Inspection Scope
The inspectors performed walkdowns of fire areas to determine if there was adequate control of transient combustibles and ignition sources. The material condition of fire protection systems, equipment and features, and the material condition of fire barriers were inspected against Ginnas licensing basis and industry standards. In addition, the passive fire protection features were inspected including the ventilation system fire dampers, structural steel fire proofing, and electrical penetration seals. The following plant areas were inspected:
- SAFW Pump Building (Fire Area SAF);
- Air Handling Room (Fire Zone AHR);
- A Diesel Generator Room (Fire Zone EDG-1A);
- B Battery Room (Fire Area BR1B); and
- Charging Pump Room (Fire Area CHG).
b. Findings
No findings of significance were identified.
==1R07 Heat Sink Performance (71111.07 - Two samples)
a. Inspection Scope
==
The inspectors reviewed performance tests, periodic cleaning, eddy current inspections, chemical control methods, tube leak monitoring, tube plugging condition, operation procedures, and maintenance practices for a sample of safety-related HXs. The inspectors examined and verified that the controls for the selected components conformed to Ginnas commitments to Generic Letter (GL) 89-13, SW System Problems Affecting Safety-Related Equipment.
The inspectors reviewed a cleaning and inspection of the A spent fuel pool (SFP) HX.
Eddy current results for the tube side, and visual inspections and ultrasonic testing of the shell side were compared to results from the most recent Ginna inspections of this component to validate trends. The inspectors also reviewed documentation for manufacture and installation of a replacement tube bundle for the B EDG jacket water HX. During these inspection activities, the inspectors interviewed the applicable system engineers.
b. Findings
No findings of significance were identified.
==1R11 Licensed Operator Requalification Program (71111.11Q - One sample)
a. Inspection Scope
==
On April 14, 2009, the inspectors observed a licensed operator simulator scenario, AP#3-INPO, Abnormal Evaluation Exercise, Revision 1. The inspectors reviewed the critical tasks associated with the scenario, observed the operators performance, and observed the post-evaluation critique. The inspectors also reviewed and verified compliance with Ginna procedure OTG-2.2, Simulator Examination Instructions, Revision 43.
b. Findings
No findings of significance were identified.
==1R12 Maintenance Effectiveness (71111.12Q - Two samples)
a. Inspection Scope
==
The inspectors evaluated work practices and follow-up corrective actions for selected systems, structures, and components (SSCs) for maintenance effectiveness. The inspectors reviewed the performance history of those SSCs and assessed extent-of-condition determinations for those issues with potential common cause or generic implications to evaluate the adequacy of corrective actions. The inspectors reviewed Ginnas problem identification and resolution actions for these issues to evaluate whether Ginna had appropriately monitored, evaluated, and dispositioned the issues in accordance with procedures and the requirements of 10 CFR Part 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. In addition, the inspectors reviewed selected SSC classifications, performance criteria and goals, and corrective actions that were taken or planned to verify whether the actions were reasonable and appropriate.
The following issues were reviewed:
- Fire door failures identified during routine inspection and surveillance testing activities; and
- Material and equipment deficiencies associated with the SAFW system.
b. Findings
No findings of significance were identified.
==1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Five samples)
a.
==
Inspection Scope
The inspectors evaluated the effectiveness of Ginnas maintenance risk assessments specified by 10 CFR Part 50.65(a)(4). The inspectors discussed with control room operators and scheduling department personnel required actions regarding the use of Ginnas online risk monitoring software. The inspectors reviewed equipment tracking documentation and daily work schedules, and performed plant tours to verify that actual plant configuration matched the assessed configuration. Additionally, the inspectors verified that risk management actions, for both planned and emergent work, were consistent with those described in CNG-OP-4.01-1000, Integrated Risk Management, Revision 00200.
Risk assessments for the following out-of-service SSCs were reviewed:
- Planned maintenance activities performed on the SW pump, motor-driven fire pump, and diesel-driven fire pump suction strainers (April 13 to 17, 2009);
- Planned maintenance on the pressurizer spray valve, AOV 341B (May 1, 2009);
- Unplanned maintenance on the diesel-driven station blackout air compressor following a failed surveillance test (May 13, 2009);
- Unplanned maintenance on the TDAFW pump following a failed surveillance test (May 26 to 28, 2009);
b. Findings
No findings of significance were identified.
==1R15 Operability Evaluations (71111.15 - Five samples)
a. Inspection Scope
==
The inspectors reviewed operability evaluations and/or condition reports (CRs) in order to verify that the identified conditions did not adversely affect safety system operability or plant safety. The evaluations were reviewed using criteria specified in NRC Regulatory Issue Summary 2005-20, Revision to Guidance formerly contained in NRC GL 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability, and Inspection Manual Part 9900, Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety. In addition, where a component was inoperable, the inspectors verified the TS limiting condition for operation implications were properly addressed.
The inspectors performed field walkdowns, interviewed personnel, and reviewed the following items:
- CR 2009-1489, TDAFW Pump Governor Not Set to PT-16Q-T Directed Value;
- CR 2009-3370, Containment Recirculation Fan Cooler Discharge SW Piping is BelowDesign Values;
- CR 2008-7647, Valve 8654, A SFP Suction Isolation Failed PT-33B;
- CR 2009-2727, Develop a Modification to Address Loss of Component Cooling Water Impact on Charging Pumps; and
- CR 2009-3680, TDAFW Tripped During Testing.
b. Findings
No findings of significance were identified.
==1R18 Plant Modifications (71111.18 - Two samples)
==
.1 Temporary Modification
a. Inspection Scope
The inspectors reviewed the following temporary plant modification to determine whether the temporary change adversely affected system availability or a function important to plant safety. The inspectors reviewed the associated system design bases including the UFSAR and TS, and assessed the adequacy of the safety determination screening and evaluation. The inspectors also assessed configuration control of the temporary change by reviewing selected drawings and procedures to verify whether appropriate updates had been made. The inspectors compared the actual installation with the temporary modification documents to determine whether the implemented change was consistent with the approved, documented modification. The temporary modification was reviewed by the inspectors in the field to verify it had been installed in conformance with the instructions contained in procedure CNG-CM-1.01-1004, Temporary Plant Configuration Change Process, Revision 0.
The inspectors reviewed the following temporary plant modification:
- C90202026, Install Temporary Recorder per Engineering Change Package (ECP)2009-0072.
b. Findings
No findings of significance were identified.
.2 Permanent Modification
a. Inspection Scope
The inspectors reviewed ECP 2009-0068, EDG Jacket Water HX Bundles, Revision 0.
The inspectors reviewed the ECP to ensure that the replacement components were consistent with design basis and were compatible with installed SSCs. The inspectors reviewed actions taken by Ginna personnel to complete the modification and test the resultant configuration.
b. Findings
No findings of significance were identified.
==1R19 Post-Maintenance Testing (71111.19 - Four samples)
a. Inspection Scope
==
The inspectors observed portions of post-maintenance testing (PMT) activities in the field to determine whether the tests were performed in accordance with approved procedures.
The inspectors assessed each tests adequacy by comparing the test methodology to the scope of maintenance performed. In addition, the inspectors evaluated the test acceptance criteria to verify that the tested components satisfied the applicable design, licensing bases, and TS requirements. The inspectors reviewed the recorded test data to determine whether the acceptance criteria were satisfied.
The following PMT activities were reviewed:
- STP-O-13, Fire Pump Operation and System Alignment, Rev. 00003, to test the diesel-driven fire pump after preventive maintenance activities performed under work order (WO) 20806148 (April 1, 2009);
- STP-O-2.1QC, SI Pump C Inservice Test, Rev. 00002, to test the C SI pump after preventive maintenance activities performed under WOs 20806291, 20806295, and 20504759, C SI Functional Equipment Group Maintenance Window, (April 7, 2009);
- STP-O-31B. Charging Pump B Inservice Test, Rev. 00201, to test the B charging pump after maintenance activities performed under WO C90219514 (May 19, 2009);and
- PT-16Q-T, AFW Turbine Pump - Quarterly, Rev. 05900, to test the TDAFW pump after emergent work was performed under WO C90462753 for the TDAFW pump failure during quarterly surveillance testing on May 26, 2009 (May 28, 2009).
b. Findings
No findings of significance were identified.
==1R22 Surveillance Testing (71111.22 - Ten samples)
a. Inspection Scope
==
The inspectors observed the performance and/or reviewed test data for the following surveillance tests that are associated with selected risk-significant SSCs to verify that TSs were followed and that acceptance criteria were properly specified. The inspectors also verified that proper test conditions were established as specified in the procedures, no equipment preconditioning activities occurred, and acceptance criteria were met.
- PT-3Q, Containment Spray Pump - Quarterly Test, Rev. 04502 (April 3, 2009)
Inservice Testing (IST);
- T-18B, Turbine Main Steam Stop Valve Testing, Rev. 02300; and T-18A, Turbine Intercept and Reheat Stop Valve Test, Rev. 12 (April 25, 2009);
- EPIP-4-11, Activation of the Ginna Sirens from the County Activation Points, Rev. 0500 (May 7, 2009);
- CH-PRI-SAMP-ROOM, Sampling in the Nuclear Sample Room, Rev. 01400 (May 20, 2009);
- S-12.4, Reactor Coolant System (RCS) Leakage Surveillance Record Instructions, Rev. 05401 (May 21, 2009);
- PT-9.1.17, Undervoltage Protection - 480 Volt Safeguard Bus 17, Rev. 02201 (May 22, 2009);
- PT-16Q-T, AFW Turbine Pump - Quarterly, Rev. 05900, to test the TDAFW pump after emergent work was performed under WO C90462753 for the TDAFW pump failure during quarterly surveillance testing on May 26, 2009 (June 4, 2009);
- STP-O-2.5, Air Operated Valves and Manual Valve, Quarterly Surveillance Auxiliary Building, Rev. 00003 (June 9, 2009) (IST);
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06 - One sample)
a. Inspection Scope
On April 14, 2009, the inspectors observed a licensed operator simulator scenario, AP#3-INPO, Abnormal Evaluation Exercise, Revision 1. The inspectors verified that emergency classification declarations and notifications were completed in accordance with 10 CFR Part 50.72, 10 CFR Part 50 Appendix E, and the site emergency plan implementing procedures.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)
a. Inspection Scope
From March 25 to May 1, 2009, the inspectors reviewed the qualification records for supplemental work force (SWF) senior radiation protection technicians (RPTs) hired for the 2006 refueling outage (RFO). The review was performed in the NRC Region 1 office and at Ginna. The purpose of the review was to verify Ginnas compliance with TS 5.3.1, Plant Staff Qualifications, regarding the 2-year experience requirement for the senior RPTs.
b. Findings
Introduction:
A Green NRC-identified NCV of TS 5.3.1 was identified for the failure to ensure SWF senior RPTs met the minimum qualification requirements specified in American National Standards Institute (ANSI) N18.1-1971, American National Standard Selection and Training of Nuclear Power Plant Personnel.
Description:
Prior to the 2006 RFO, Ginna hired 20 SWF senior RPTs. The criteria Ginna used to select these technicians were compared to the specific requirements of ANSI N18.1-1971. After completing a review of this selection process, the inspectors assessed whether the minimum qualification requirements were satisfied. The inspectors also discussed with Ginna the senior RPTs work history. Based on the review, the inspectors determined that three senior RPTs did not meet the minimum qualification requirements of ANSI N18.1-1971. Specifically, 3 out of 20 SWF senior RPTs hired for the 2006 RFO did not have the 2 years of experience in their area of specialty specified by ANSI N18.1-1971, Section 4.5.2. The three individuals performed tasks that would require senior RPTs experience during the 2006 RFO such as providing coverage for locked high radiation area (HRA) entries and removal of objects from the SFP.
The qualification requirements for the senior RPT position are referenced in TS 5.3.1 which states that plant staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971. At the time of the 2006 RFO, the three senior RPTs did not have 2 years of experience as an RPT. The radiation protection experience was mainly limited to experience with using low levels of contamination and low radiation dose rates. Operating experience has shown that inexperienced RPTs covering work activities have led to individual worker overexposures (HP POS-022, Qualification of Reactor Health Physics Technician).
Ginnas initial corrective actions included verifying all senior RPTs currently employed at the site met the experience requirements contained in ANSI N18.1-1971. Future
corrective actions will involve modifying Ginna procedures regarding the training and qualification of senior RPTs to ensure they meet ANSI N18.1-1971.
Analysis:
The failure to ensure senior RPTs are fully qualified is a performance deficiency.
It was in Ginnas ability to ensure the individuals work history and experience met the minimum qualification requirements prior to selection. This violation is associated with the Occupational Radiation Safety cornerstone and is greater than minor because, if left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern. Since, there were no actual safety consequences, the NRCs ability to perform its regulatory function was not impacted, and there were no willful aspects, traditional enforcement does not apply. This finding was evaluated using Inspection Manual Chapter (IMC) 0609, Appendix C, Occupational Radiation Safety Significance Determination Process. The inspectors determined that the finding was of very low safety significance (Green) because it did not involve
- (1) as low as is reasonably achievable (ALARA) planning and controls,
- (2) an overexposure,
- (3) a substantial potential for overexposure, or
- (4) an impaired ability to assess dose. Since this performance deficiency occurred in 2006 and does not reflect current performance, there is no cross-cutting aspect.
Enforcement:
TS 5.3.1 states that plant staff, which includes senior RPTs, shall meet or exceed the minimum qualifications of ANSI N18.1-1971. Paragraph 4.5.2 of ANSI N18.1-1971 specifies that technicians in responsible positions shall have a minimum of 2 years of working experience in their specialty.
Contrary to the above, three senior RPTs selected for the 2006 RFO did not have the 2 years of experience in their specialty. Because the failure to meet TS 5.3.1 was determined to be of very low safety significance (Green) and was entered into Ginnas CAP (CR 2009-3019), the violation is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 05000244/2009003-01, Failure to Meet Technical Specification Requirements for Senior Radiation Protection Technician Qualifications)
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - Nine samples)
a. Inspection Scope
From April 13 to 17, 2009, the inspectors performed the following activities to evaluate that Ginna was providing accurate and operable radiation monitoring instruments used for the protection of occupational workers and to verify the adequacy of Ginnas program to provide self-contained breathing apparatus (SCBA) for personnel entering and working in areas of unknown radiological hazards and/or potential immediately dangerous to life and health. Implementation of these programs was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Ginnas procedures.
Inspection Planning
The inspectors reviewed the UFSAR to identify applicable radiation monitors associated
with transient high and very HRAs including those used in remote emergency assessment.
The inspectors also determined which monitors were included under the maintenance rule program and excluded them from this inspection.
Identify Additional Radiation Monitoring Instrumentation
The inspectors identified the types of portable radiation detection instrumentation used for job coverage of HRA work, other temporary area radiation monitors currently used in the plant, and continuous air monitors. The inspectors also identified the types of radiation detection instruments utilized for personnel release from the radiological controlled area.
Verify Calibration, Operability, and Alarm Set-point of Several Types of Instruments
The inspectors reviewed calibration records and observed calibrator exposed readings.
The inspectors observed electronic and radiation calibration of several instruments. The inspectors verified that when instruments are found out of specification during source checks or during calibrations, a CR is entered into the CAP. The inspectors also verified the alarm set-points for a personnel monitor, a frisker, a small article monitor, and an area radiation monitor.
Problem Identification and Resolution
The inspectors reviewed five CRs related to portable radiation survey equipment, four CRs related to area radiation monitors, and six CRs related to SCBA equipment and qualifications since June 2008.
RPT Instrument Use
The inspectors observed an RPT obtain an appropriate portable radiation survey instrument for job coverage. The RPT verified the calibration due date and that the instrument needed source checked for the day. The technician source checked the instrument, and performed a battery check and zero check to complete the operability verification.
SCBA Maintenance and User Training
The inspectors reviewed the status and surveillance records of SCBA staged and ready for use in the plant. The inspectors observed the monthly checks of respirators in the control room and the fire brigade storage areas. The inspectors observed the simulation of filling bottles at Ginnas dedicated air fill compressor. The inspectors reviewed the current sample results for the dedicated air fill compressor. The inspectors reviewed the SCBA qualification records for control room shift crews, individuals from the radiation protection staff and the auxiliary fire brigade.
Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- exposure significant radiological incidents that involved radiation monitoring instrument deficiencies since the last inspection in this area;
- air monitors associated with jobs with the potential to receive 50 mrem committed effective dose equivalent; and
- personnel qualified to perform maintenance on SCBA equipment, since all maintenance is performed by a qualified contractor.
b. Findings
Introduction:
A Green NRC-identified NCV of 10 CFR 50.54(q) was identified for failure of operating crew members to have corrective eyewear for respiratory protection use as required for emergency response.
Description:
On April 16, 2009, during an observation of SCBA maintenance inspection activities in the control room, the inspectors identified that the operating shift crew wore eyeglasses. SCBA are used in the event the control room operators, who are key members of the emergency plan, must evacuate the control room in order to perform plant manipulations during certain postulated accidents. With the exception of the shift manager, none of the other operation crew members had eyewear that could be used in conjunction with the SCBA. Ginna had provided the respirator corrective lens kits (spectacle adapter kits) to other control room operators and staff that were key emergency responders. The corrective lens kits provide for proper vision correction while the employee is wearing the SCBA. The on-duty shift crew members were from a recently licensed operator training class who were not issued corrective eyewear for respirator use prior to assuming licensed duties. Only one other operating crew member from another shift was identified as needing and not having corrective lenses for SCBA use. A Ginna investigation determined that the recently licensed control room operators did not receive their lenses because of a program weakness. Specifically, the process used for establishing the medical readiness of control room operators did not ensure operators had received SCBA corrective lens inserts prior to assuming watch responsibilities. Ginnas correction actions included revising procedures and electronic data files that govern the training and qualification of licensed operators to include steps that ensure licensed operators who require corrective lenses are provided SCBA lens inserts.
10 CFR 50.54(q) requires, in part, that licensees follow and maintain emergency plans which meet the standards in 50.47(b). Specifically, emergency preparedness (EP)planning standards (PSs) in 10 CFR 50.47(b) require the protection of emergency workers from radiological exposure (i.e., those that would respond in the event of a radiological emergency), which includes the equipment necessary for personnel protection. Also, 10 CFR 20.1703(e) requires that the licensee consider the limitations for respirator use and shall provide for vision correction when selecting respiratory protective equipment. The consequences of some of the emergency responders having inadequate vision would challenge Ginnas state of operational readiness and emergency response capabilities.
Analysis:
The failure to follow and maintain emergency plans in accordance with 10 CFR 50.54(q) which meet the standards in 50.47(b) is a performance deficiency. Specifically,
since Ginna did not provide spectacle adapter kits for all eyeglass wearers (i.e., non-soft contact wearers) who were key emergency response organization (ERO) personnel that were potentially required to wear an SCBA in order to fulfill emergency response functions. Ginna did not provide adequate emergency equipment to support the emergency response as specified in 50.47(b) for these personnel. This violation is associated with the EP cornerstone, and if left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern. The inspectors determined that the finding was more than minor using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process.
This finding involved a failure to meet a regulatory requirement (respiratory protection) and represented a failure to meet a PS of 10 CFR 50.47(b). This finding, however, did not involve a risk-significant PS and was not indicative of a PS functional failure because other personnel that did not require vision protection, or had the proper vision correction, were available within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Therefore, this finding was determined to be of very low safety significance (Green). This finding was caused by Ginna not providing respirator vision corrective lenses to licensed operators that required corrective lenses as a condition of their license following initial training completion. Consequently, the cause of this finding has a cross-cutting aspect in the area of human performance. Specifically, Ginna did not ensure that equipment was available for key emergency response personnel (H.2.d per IMC 0305).
Enforcement:
10 CFR 50.54(q) requires, in part, that licensees follow and maintain emergency plans which meet the standards in 50.47(b). Specifically, 50.47(b)(8) states that adequate emergency facilities and equipment to support the emergency response are provided and maintained. Contrary to this requirement, Ginna failed to provide adequate equipment in that spectacle adapter kits were not provided for all eyeglass wearers (i.e., non-soft contact wearers) who were key ERO personnel that were potentially required to wear an SCBA in order to fulfill emergency response functions. However, since Ginna documented this issue in its CAP (CR 2009-2636) and because the violation is of very low safety significance, it is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 05000244/2009003-02, Operators Did Not Have Corrective Lens Kits Available to Implement Emergency Plan Requirements)
Cornerstone: Public Radiation Safety
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01 - 11 samples)
a. Inspection Scope
During the period June 1 to 5, 2009, the inspectors performed the following activities to verify that Ginna was properly maintaining the gaseous and liquid effluent processing systems to ensure that radiological releases were properly mitigated, monitored, and evaluated with respect to public exposure. The inspectors also performed the activities to verify that the quality control program for effluent sampling and analysis for releases adequately quantifies and evaluates releases.
Inspection Planning
The inspectors reviewed the most current radiological effluent release report to verify that the program was implemented as described in the radiological effluent technical specification/offsite dose calculation manual (RETS/ODCM) and reviewed the report for significant changes to the ODCM and to radioactive waste system design and operation.
The inspectors evaluated anomalous results reported in the current radiological effluent release report to ensure they were adequately resolved.
The inspectors reviewed the RETS/ODCM to identify the effluent radiation monitoring systems and its flow measurement devices, effluent radiological occurrence performance indicators (PIs) for incidents for onsite follow-up, and Ginnas self assessments, audits, and licensee event reports for activities that involved unanticipated offsite releases of radioactive material.
On-Site Inspection
The inspectors walked down the major components of the gaseous and liquid release systems (e.g., radiation and flow monitors, demineralizers and filters, tanks, and vessels)to observe current system configuration with respect to the description in the UFSAR, ongoing activities, and equipment material condition.
The inspectors reviewed eight liquid and five gaseous discharge permits including the projected doses to members of the public. The inspectors observed the routine sample collection and analysis for the D gas decay tank simulated release. The inspectors also observed the sample collection and analysis for the A monitor tank discharge and sampling for the continuous discharge of the A and B steam generator blow-down discharge. The observations were performed to verify that appropriate treatment equipment is used and that radioactive effluents are processed and released in accordance with RETS/ODCM requirements.
The inspectors reviewed the records of any abnormal releases or releases made with inoperable effluent radiation monitors and reviewed Ginnas actions for these releases to ensure an adequate defense-in-depth was maintained against an unmonitored, unanticipated release of radioactive material to the environment.
The inspectors reviewed Ginnas understanding of the location of underground piping and construction of underground pipes, tanks, and structures that contain radioactive contaminated liquid. The inspectors evaluated the capabilities of Ginna to detect spills or leaks and identify groundwater radiological contamination.
The inspectors reviewed changes made by Ginna to the ODCM since 2007 as well as to the liquid or gaseous radioactive waste system design or operation since the last inspection in 2007.
The inspectors reviewed Ginnas calculations for monthly, quarterly, and annual dose calculations to ensure they were completed correctly.
The inspectors reviewed the air cleaning system surveillance test results and the methodology used to determine the stack and vent flow rates and verified that the flow rates are consistent with RETS/ODCM or UFSAR values.
The inspectors reviewed records of instrument calibrations performed since the last inspection for each point of discharge effluent radiation monitor and flow measurement device, and reviewed any completed system modifications and the current effluent radiation monitor alarm set-point value for agreement with RETS/ODCM requirements.
The inspectors reviewed calibration records of radiation measurement (i.e., counting room) instrumentation associated with effluent monitoring and release activities. The inspectors reviewed the inter-laboratory comparison results to ensure the quality of radiological effluent sample analysis.
The inspectors reviewed Ginnas quality assurance audits to ensure they met the requirements of the RETS/ODCM.
Problem Identification and Resolution
The inspectors reviewed Ginnas self assessments, audits, and special reports related to the radioactive gaseous and liquid effluents program and processing systems. The inspectors reviewed 22 CRs related to the radioactive gaseous and liquid effluents program and processing systems to ensure followup actions were performed in a timely and effective manner.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1
Cornerstone: Barrier Integrity
a. Inspection Scope
(71151 - Two samples)
The inspectors reviewed Ginna's operations logs and chemistry surveillance records to verify the accuracy of data reported under the RCS leak rate and the RCS-specific activity PIs. The inspectors used the guidance provided in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment PI Guideline, Revision 5, to assess the accuracy of Ginnas collection and reporting of the PI data.
The inspectors observed a sample of S-12.4, RCS Leakage Surveillance Record Instructions, Revision 05401, which determines RCS leakage rates submitted under this PI. The PI data reviewed for RCS leak rate encompassed the period from April 2008 through March 2009.
The inspectors also observed chemistry sampling and analysis surveillance activities which determine the RCS-specific activity reported under this PI. The PI data reviewed for the RCS-specific activity encompassed the period from March 2008 through March 2009.
b. Findings
No findings of significance were identified.
.2
Cornerstone: Mitigating Systems
a. Inspection Scope
(71151 - One sample)
Using the criteria specified in NEI 99-02, Revision 5, the inspectors verified the completeness and accuracy of the PI data for safety system functional failures. To verify the accuracy of the data, the inspectors reviewed monthly operating reports, NRC inspection reports, and Ginna event reports issued from April 2008 through March 2009.
b. Findings
No findings of significance were identified.
.3
Cornerstone: Public Radiation Protection
a. Inspection Scope
(71151 - One sample)
Using the criteria specified in NEI 99-02, Revision 5 the inspectors reviewed relevant effluent release CRs for the period January 1, 2008, through December 31, 2008, for issues related to the RETS/ODCM radiological effluent PI which measures radiological effluent release occurrences that exceed 1.5 mrem/quarter whole body or 5.0 mrem/quarter organ dose for liquid effluents; 5 mrad/quarter gamma air dose, 10 mrad/quarter beta air dose, and 7.5 mrad/quarter for organ dose for gaseous effluents.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Semi-Annual Review (71152 - One sample)
a. Inspection Scope
In order to identify trends that might indicate the existence of a more significant safety issue, the inspectors reviewed CRs initiated from December 2008 to April 2009, corrective action trend reports from August 2008 to April 2009, system health reports, and departmental PIs. Additionally, the inspectors reviewed the temporary modification log, the maintenance rule status report, the low margin list, and a 2008 top 10 issues list. The inspectors also discussed trends and potential trends with appropriate Ginna personnel.
b. Findings and Observations
No findings of significance were identified. No trends were noted that indicated a potential safety significant issue. Although several trends or potential trends were identified by inspectors, plant personnel were aware of these and had initiated corrective actions as necessary.
.2 Operator Workarounds (71152 - One sample)
a. Inspection Scope
The inspectors reviewed the operator workaround program to verify that workaround problems were identified at an appropriate threshold and entered into the CAP. To perform this review, the inspectors performed a control room walkdown and discussed deficiencies with control room operators to determine if deficiencies were appropriately identified and that their impact on operations was assessed. Operator workarounds that affected a mitigating systems function or the operators ability to implement abnormal and emergency operating procedures were reviewed more closely. As part of this review, the inspectors reviewed the procedure for workaround control and a 2008 fourth quarter self-assessment report regarding the aggregate impact of the active operator workarounds, challenges, and degraded operability items.
b. Findings and Observations
No findings of significance were identified.
.3 Annual Sample - Technical Support Center Ventilation System (71152 - One sample)
a. Inspection Scope
Ginnas technical support center (TSC) HVAC system is located in the TSC mechanical equipment room. Section 9.4.8 of Ginnas UFSAR states that in addition to maintaining year-round occupancy comfort levels, the TSC HVAC system provides personnel protection from airborne radiological contaminants, maintains a positive pressure in the emergency mode relative to the outside environment, and provides cooling, heating, and ventilation required by special areas. Since April 2007, there have been several CRs initiated by Ginna personnel that documented concerns regarding the ability of the HVAC system to maintain the air temperature in the TSC within comfortable levels. These cooling issues were documented when the TSC HVAC system was both in the accident and standby modes of operation.
If the TSC HVAC system is not functional, Ginna procedure A-52.12, Nonfunctional Equipment Important to Safety, Revision 06200, requires the system to be repaired within 7 days or implement compensatory action. If the TSC HVAC system is not functional,
procedure A-52.12 requires control room operators to perform a risk assessment, develop recommendations to restore functionality, and implement documentation that would track the status of the plant equipment. The tracking documentation is used, in part, to inform plant management of deficiencies in plant equipment that are important equipment issues.
The inspectors reviewed the corrective actions implemented by Ginna to address the TSC HVAC issues documented in Ginnas CAP. To perform this review, the inspectors interviewed Ginna personnel, reviewed Ginnas UFSAR, TSC HVAC drawings, WOs, and plant procedures including procedure A-52.12. The CAP documents reviewed included the following CRs:
2007-3254, TSC Room A/C Unit Inoperable 2007-5577, A/C Not Working in the TSC 2008-8160, TSC HVAC Compressor Not Running With Disconnects 2009-1942, Marginal Cooling During Drill 2009-1965, TSC Ventilation Not Working Properly 2009-1971, Ventilation in TSC 2009-2851, A/C in TSC 2009-2872, TSC Ventilation is not Providing Adequate Cooling 2009-3539, A/C Not Working in the TSC 2009-3598, Tracking Documentation not Submitted When TSC System Not Functioning
In addition to reviewing documents, the inspectors also performed an independent walkdown of the TSC plant areas including the TSC mechanical equipment room.
b. Findings and Observations
No findings of significance were identified. However, as evidenced by the number of CRs that documented issues regarding the performance of the TSC HVAC system, Ginna has not effectively resolved the performance issues associated with this system. Further, when TSC HVAC performance issues were identified, operations personnel did not always properly assess the significance of these issues and initiate the appropriate tracking documentation as required by procedure A-52.12. A CR (2009-3598) was written to document the inconsistent implementation of procedure A-52.12. Although Ginna has not adequately resolved the TSC HVAC performance issues or consistently implemented procedure A-52.12, these issues were violations of minor significance that were not subject to enforcement action in accordance with the NRCs enforcement policy. This is due to the fact that the TSC HVAC system was either restored to a functional status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a failure, or the HVAC performance issue did not render the TSC HVAC incapable of meeting the design requirements contained in Ginnas UFSAR.
4OA3 Followup of Events and Notices of Enforcement Discretion (71153 - One sample)
Power Reduction Caused by Degraded Condenser Vacuum
a. Inspection Scope
On May 17, 2009, control room operators rapidly reduced reactor power to 48 percent
when control room operators noticed that vacuum in the A condenser began to decrease.
To reduce power and take action to mitigate the loss of condenser vacuum, Ginna operators utilized procedures AP-Turb.5, Rapid Load Reduction, Revision 01100, and AP-Turb.4, Loss of Condenser Vacuum, Revision 020. Upon learning of the power reduction, inspectors responded to the site, toured the intake structure, turbine building and control room, and interviewed the control room operators. The inspectors also observed Ginna troubleshooting activities. A Ginna investigation determined that the reduction in vacuum on the A condenser was caused by a failure of the A circulating water pump to maintain sufficient flow through the condenser because of mechanical failure (an end bell on the pump had become dislodged because of mechanical failure)which significantly degraded performance of the pump. With the pump damaged, less circulating water was flowing through the A condenser causing the vacuum decrease.
Because the mechanical failure caused significant pump damage, repairs could not be performed on site. Accordingly, the pump and attached motor were removed and sent to offsite vendors for refurbishment. While these components were being repaired, plant power was held to approximately 58 percent due to environmental limits concerning circulating water discharge temperature. On May 29, the A circulating water pump and motor were reinstalled, and following successful completion of PMT activities, plant power was increased. Full power was reached on June 1.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with Ginnas security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On July 9, 2009, the resident inspectors presented the inspection results to Mr. John Carlin and other members of his staff, who acknowledged the findings. The inspectors verified that none of the material examined during the inspection is considered proprietary in nature.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Carlin
Vice President, Ginna
R. Beske
Acting Scheduling Manager
D. Dean
Assistant Operations Manager (Shift)
T. Hedges
Emergency Preparedness Manager
E. Larson
Plant Manager
F. Mis
General Supervisor, Radiation Protection
S. Snowden
Chemistry Supervisor
J. Sullivan
Manager of Operations
P. Swift
Acting Manager, Nuclear Engineering Services
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000244/2009003-01 NCV Failure to Meet Technical Specification Requirements for Senior Radiation Protection Technician Qualifications (Section 2OS1)
- 05000244/2009003-02 NCV Operators Did Not Have Corrective Lens Kits Available to Implement Emergency Plan Requirements (Section 2OS3)