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IR 05000244-14-008; 02/24/2014 - 03/13/2014; R.E. Ginna Nuclear Power Plant, LLC (Ginna); Biennial Baseline Inspection of Problem Identification and Resolution
	ML14101A325
Person / Time
Site:	Ginna
Issue date:	04/11/2014
From:	Schroeder D L; Reactor Projects Branch 1
To:	Pacher J E; Exelon Generation Co
	Schroeder D L
References
	IR-14-008
	Download: ML14101A325 (21)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 April 11, 2014

Mr. Joseph Site Vice President R.E. Ginna Nuclear Power Plant, LLC Exelon Generation Company, LLC 1503 Lake Rd.

Ontario, NY 14519

SUBJECT: R.E. GINNA NUCLEAR POWER PLANT, LLC - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT

05000244/2014008

Dear Mr. Pacher:

On March 13, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your R.E. Ginna Nuclear Power Plant, LLC (Ginna). The enclosed report documents the inspection results, which were discussed on March 13, 2014, with Mike Philippon, General Plant Manager, and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. On April 1, 2014, the operating license for Ginna held by the Constellation Energy Nuclear Group, LLC (CENG) was transferred to Exelon Generation Company, LLC.

Based on the samples selected for review, the inspectors concluded that CENG was generally effective in identifying, evaluating, and resolving problems. CENG personnel identified problems and entered them into the corrective action program at a low threshold. CENG prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.

This report documents one NRC-identified finding of very low safety significance (Green). If you disagree with the finding or the assigned cross-cutting aspect, 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

Ginna.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's "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 component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Daniel L. Schroeder, Chief Reactor Projects Branch 1

Division of Reactor Projects

Docket No. 50-244 License No. DPR-18

Enclosure: Inspection Report 05000244/2014008 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ

ML14101A325 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME SShaffer/SWS RPowell/RP DSchroeder/DLS DATE 4/9/14 4/10/14 4/11/14

1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No. 50-244

License No. DPR-18

Report No. 05000244/2014008

Licensee: Constellation Energy Nuclear Group, LLC (CENG)

Facility: R.E. Ginna Nuclear Power Plant, LLC

Location: Ontario, NY

Dates: February 24, 2014 through March 13, 2014

Team Leader: Steve Shaffer, Senior Project Engineer

Inspectors: Doug Dodson, Resident Inspector, Ginna Brian Haagensen, Resident Inspector, Millstone Andrey Turilin, Project Engineer

Approved by: Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects

2 Enclosure

SUMMARY

IR 05000244/2014008; 02/24/2014 - 03/13/2014; R.E. Ginna Nuclear Power Plant, LLC (Ginna); Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified one finding in the area of effectiveness of corrective actions.

This NRC team inspection was performed by tw o regional inspectors and two resident inspectors. The inspectors identified one finding of very low safety significance (Green) during this inspection. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, "Aspects with Cross-Cutting Areas," dated January 1, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4.

Problem Identification and Resolution The inspectors concluded that CENG was genera lly effective in identifying, evaluating, and resolving problems. CENG personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, CENG appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that CENG typically implemented corrective actions (CAs) to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that, in general, CENG adequately identified, reviewed, and applied relevant industry operating experience to Ginna operations. In addition, based on those items selected for review, the inspectors determined that CENG's self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment.

Cornerstone: Initiating Events

Green.

The inspectors identified a Green finding (FIN) for CENG's failure to effectively implement a CA associated with an apparent cause evaluation (ACE) that addressed both heater drain tank (HDT) pumps tripping on October 21, 2012. Specifically, CENG failed to effectively implement a CA to modify all procedures in which the feedwater system would be impacted by stopping HDT or condensate booster pumps, which resulted in both HDT pumps tripping and an unplanned power reduction from approximately 79 percent power to approximately 48 percent power on January 14, 2014. These issues were entered into CENG's corrective action program as condition report (CR)-2014-000197 and CR-2014-001208.

This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to effectively implement CA-2012-003493 and modify all procedures impacted by stopping HDT or condensate booster pumps, including procedure AP-FW.1, resulted in both HDT pumps tripping and an unplanned power reduction of approximately 31 percent power. Additionally, this issue is similar to Example 4b described in IMC 0612, Appendix E, "Examples of Minor Issues," issued August 11, 2009, which states that issues are not minor if procedural issues cause a reactor trip or other transient. Using Exhibit 1, "Initiating Events Screening Questions," of IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," issued June 19, 2012, the inspectors determined this finding did not involve the complete or partial loss of a support system that contributes to the likelihood of, or causes, an initiating event and affects mitigation equipment and is therefore of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because individuals did not follow processes, procedures, and work instructions. Specifically, CENG staff did not follow procedure CNG-CA-1.01-1005 and ensure that CAs (CA-2012-003494) were effectively implemented and addressed identified causes associated with the ACE for CR-2012-007133.

[H.8] (Section 4OA2.1.c)

REPORT DETAILS

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

Main article: IP 71152B

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described CENG's corrective action program at Ginna.

To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in thes e areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, "Corrective Action," and CENG CNG-CA-1.01-1000, "Corrective Action Program," Revision 01000. For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed CRs selected across the seven

cornerstones of safety in the NRC's Reacto r Oversight Process. Additionally, the inspectors attended multiple Plan-of-the-Day, Condition Report Review Committee, and Management Review Committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.

(1) Effectiveness of Problem Identification

In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports.

The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators and auxiliary feedwater systems. Additionally, the inspectors reviewed a sample of CRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that CENG entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of CRs issued since the last NRC biennial Problem Identification and Resolution inspection completed in February 2012. The inspectors also reviewed CRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified 5 Enclosure causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed CENG's completed CAs through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CRs for adverse trends and repetitive problems to determine whether CAs were effective in addressing the broader issues. The inspectors reviewed CENG's timeliness in implementing CAs and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs associated with selected non-cited violations and findings to verify that CENG personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the CA review to five years to evaluate CENG actions related to the heater drain system.

b. Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that CENG identified problems and entered them into the corrective action program at a low threshold. CENG staff at Ginna initiated approximately 16,000 CRs between February 2012 and February 2014. The inspectors observed supervisors at the Plan-of-the-Day, Condition Report Review Committee, and Management Review Committee meetings appropriately questioning and challenging CRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that CENG trended equipment and programmatic issues, and appropriately identified problems in CRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, CENG personnel promptly initiated CRs and/or took immediate action to address the issues.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, CENG appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. CENG screened CRs for operability and reportability, categorized the CRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The CR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of CRs reviewed, the inspectors noted that the guidance provided by CENG's corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.

(3) Effectiveness of Corrective Actions

The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, CENG identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the inspection sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective. However, the inspectors did identify some instances where CENG's evaluation of issues was inconsistently implemented. Specifically, the inspectors identified some instances of CENG failing to meet the procedural requirements of CNG-CA-1.01-1000, "Corrective Action Program," Revision 01000, and CNG-CA-1.01-1005, "Apparent Cause Evaluation," Revision 00603. Specifically, the following instances were identified by inspectors as inadequate evaluation of issues:

The extent of condition review was not adequately performed for category three CR-2013-001099, which documented that the as left calibration values for the reactor vessel level instrumentation system train 'A' function generator could be left outside of the total instrument uncertainty (TIU) of 0.96 percent, because CPI-INSTR-15.1, "Calibration of Reactor Vessel Level Monitoring System Train A Instrumentation", Revision 01300, had a calibration tolerance of 1 percent. Consequently, the module could meet the procedure tolerance but be left outside the TIU and be non-functional for up to 18 months. The extent of condition review failed to recognize that the 'B' train calibration procedure CPI-INSTR-18.1, "Calibration of Reactor Vessel Level Monitoring System Train B Instrumentation," Revision 01401, allowed for the same inadequate condition. CENG entered the issue into the corrective action program as CR-2014-000975.

The extent of condition review within the ACE associated with CR-2010-006323, a category two CR, was not adequately performed. The evaluation associated with CR-2010-0006323 documents that there was high resistance on the contacts of charging pump selector switch L/428A that resulted in an increase in charging pump speed and pressurizer level until operators took manual control. In April 2013, pressurizer pressure selector switch P/429A malfunctioned during reactor protection system channel 3 calibrations due to oxidation on the switch contacts. This produced an unanticipated low output to pressurizer pressure controller PC-431K when operators placed the pressure control system back to automatic control after channel 3 calibrations were complete. The low output from the selector switch resulted in a low pressure signal that caused the proportional and backup heaters to be fully energized and closure of the spray valves, and pressurizer pressure unexpectedly rose from 2228 psig to 2245 psig in one minute until the system was

7 Enclosure taken to manual control. The extent of condition review associated with CR-2010-006323 failed to recognize that L/428A and P/429A were components with similar make and model. CENG entered the issue into the corrective action program as CR-2014-001289.

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 these conditions were deficiencies of minor significance, and therefore, are not subject to enforcement action in accordance with the NRC's Enforc ement Policy. While the inspectors concluded that the extent of condition evaluations for the above category two and category three CRs were not adequately performed, interviews conducted by the inspectors and reviews of CRs documented as a result of inspector questions revealed sufficient information to determine the abov e issues were resolved adequately by CENG staff. CENG documented these issues in CR-2014-000975 and CR-2014-001289.

Additionally, the inspectors identified one example of more than minor significance

where CENG personnel were not effective in evaluating and implementing effective corrective actions. The finding is documented below.

c. Findings

Failure to Effectively Implement Corrective Actions Associated with Heater Drain Tank Pump Tripping Issues

Introduction.

The inspectors identified a Green finding (FIN) for CENG's failure to effectively implement a CA associated with an ACE that addressed both HDT pumps tripping on October 21, 2012. Specifically, CENG failed to effectively implement a CA to modify all procedures in which the feedw ater system would be impacted by stopping HDT or condensate booster pumps, which resulted in both HDT pumps tripping and an unplanned power reduction from approximately 79 percent power to approximately 48 percent power on January 14, 2014.

Description.

On October 21, 2012, while reducing power for the 2012 refueling outage, the 'A' and 'B' HDT pumps tripped off approximately one minute after the second condensate booster pump was secured. This resulted in an unplanned power reduction to approximately 48 percent in accordance with AP-FW.1, "Abnormal MFW Pump Flow or NPSH," Revision 1801, using AP-TURB.5, "Rapid Load Reduction," Revision 1501.

The ACE for this issue determined that engineering change package (ECP)-2009-0262, "Condensate System Pressure Rerate," Revision 0000, was implemented without a complete understanding of the effect of increased main feedwater (MFW) pump suction pressure on HDT control system dynamic response. This issue was documented by CENG in CR-2012-007133.

On January 13, 2014, while the plant was at 100 percent power, a low pressure condition in the condensate system tripped both running condensate booster pumps and caused air operated valve (AOV)-3959, the condensate low pressure heater bypass valve, to open. This combination caused feed pump suction pressure to increase, and HDT level went high because of the slow response of AOV-3345, the level control valve.

Using AP-FW.1 and AP-TURB.5, the plant was stabilized at approximately 79 percent power. This issue was documented by CENG as CR-2014-000196.

On January 14, 2014, at 00:17, the plant was stable at approximately 79 percent power, and operators were in AP-FW.1 to return the condensate system lineup to normal for plant recovery. Operators were directed by the procedure to close AOV-3959 and place the valve control switch in AUTO. This procedure step puts all condensate flow through the low pressure heaters, returns AOV-3959 to normal position, and causes an approximate 60 psig drop in MFW pump suction pressure. This drop causes the backpressure to decrease for the HDT pumps, which results in HDT pump discharge header flow immediately increasing even though HDT level is dropping slowly due to the slow response of AOV-3345. Input flows into the HDT did not change, because the reactor was stable, so the increase of HDT pump flow reduced the water mass in the HDT. At 00:18, HDT pressure increased above saturation pressure and swelling effects stopped. This resulted in HDT level dropping rapidly, which caused both HDT pumps to trip. Subsequently, operators used AP-TURB.5 to reduce power to approximately 48 percent in accordance with AP-FW.1. CENG's ACE determined that the apparent cause of the HDT pumps tripping was "Inadequate procedure direction exists for all applicable procedures to preclude low level in the HDT and minimize the sudden large reduction in MFW pump suction pressure after shutting AOV-3959. This includes optimum settings for AOV-3345 gain and trim valve settings and initial HDT level." This issue and its corresponding ACE were documented by CENG in CR-2014-000197.

One of the CAs associated with the trip of the HDT pumps on October 21, 2012, CA-2012-003494, stated, "Modify all procedures that were affected by ECP-2009-0262 and complete procedure change requests for any that are required to prevent issues when stopping HDT and condensate booster pumps. Focus on AP-TURB.5 and O-5.1." CA-2012-003494 was closed on April 23, 2013, and documented that AP-TURB.5, AP-SG.1, AP-CVCS.3, O-5.1, and O-2.1 were updated. Although CA-2012-003494 references the modification of all relevant procedures, AP-FW.1 was not revised. The ACE for CR-2014-000197 recognized that CA-2012-003494 was written to modify all applicable procedures and identified that no analysis was conducted in the CR-2012-007133 ACE about destabilizing effects on HDT level control in other abnormal procedures like AP-FW.1. However, the CR-2014-000197 ACE did not determine that CA-2012-003494 was ineffectively implemented or recognize ineffective implementation of CA-2012-003494 as an apparent or contributing cause; these facts are evidenced by the ACE's failure to identify any CAs to address the ineffectively implemented actions of CA-2012-003494. Subsequent to NRC inspector inquiri es, these issues were documented by CENG in CR-2014-001208. Additionally, CA-2014-000730 and CA-2014-000731 document CENG's additional planned CAs to revise the CR-2014-000197 ACE and to evaluate whether additional CAs are necessary to adequately address the failure to

effectively implement CAs.

Procedure CNG-CA-1.01-1005, "Apparent Cause Evaluations," Revision 00603, requires, in part, that CAs are effective and address identified causes. It also states that the CA sponsor shall "review the proposed corrective, preventive, and compensatory actions to ensure the action is appropriate and will prevent recurrence."

Analysis.

The inspectors determined that CENG's failure to effectively implement a CA to address all concerns related to HDT pump trips was a performance deficiency within

CENG's ability to foresee and correct and should have been prevented. Specifically, CENG failed to effectively implement CA-2012-003493 to modify all procedures impacted by stopping HDT or condensate booster pumps. AP-FW.1 is such a procedure 9 Enclosure and should have been included in CA-2012-003493, but was not included. This ultimately resulted in both HDT pumps tripping and an unplanned power reduction of approximately 31 percent power. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to effectively implement CA-2012-003493 and modify all procedures impacted by stopping HDT or condensate booster pumps, including AP-FW.1, resulted in both HDT pumps tripping and an unplanned power reduction of approximately 31 percent power. Additionally, this issue is similar to Example 4b described in IMC 0612, Appendix E, "Examples of Minor Issues," issued August 11, 2009, which states that issues are not minor if procedural issues cause a reactor trip or other transient. The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, "Initial Characterization of Findings," issued June 19, 2012. The attachment instructs inspectors to utilize IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," issued June 19, 2012. Using Exhibit 1, "Initiating Events Screening Questions," of IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," issued June 19, 2012, the inspectors determined this finding did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affect mitigation equipment and is therefore of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because individuals did not follow processes, procedures, and work instructions. Specifically, CENG staff di d not follow their Apparent Cause Evaluation procedure and ensure that CAs (CA-2012-003494) were effectively implemented and addressed identified causes associated with the ACE for CR-2012-007133. [H.8]

Enforcement.

CENG failed to effectively implement CA-2012-003494 and modify all procedures impacted by stopping HDT or condensate booster pumps, which resulted in both HDT pumps tripping and an unplanned power reduction from approximately 79 percent power to approximately 48 percent power in January 2014. These issues were entered into CENG's CAP as CR-2014-000197 and CR-2014-001208. This finding does not involve enforcement action because no violation of a regulatory requirement was identified. Because this finding does not involve a violation and is of very low safety significance, it is identified as a FIN. (FIN 05000244/2014008-01, Failure to Effectively Implement Corrective Actions Associated with Heater Drain Tank Pump Tripping

Issues)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of CRs associated with review of industry operating experience to determine whether CENG appropriately evaluated the operating

experience information for applicability to Ginna and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that CENG adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed 10 Enclosure various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that CENG appropriately considered industry operating

experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Plan-of-the-Day meetings and pre-job briefs.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if CENG entered problems identified through these assessments into the corrective action program, when appropriate, and whether CENG initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal CENG assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that CENG personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. CENG completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

11 Enclosure

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at Ginna. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management

and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that CENG entered issues into the corrective action program when appropriate.

b. Assessment

During interviews, Ginna staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On March 13, 2014, the inspectors presented the inspection results to Mr. Michael

Philippon, Plant General Manager, and other members of the Ginna staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Pacher, Site Vice President

M. Philippon, Plant General Manager

C. Barrett, Associate Engineer

J. Brzezniak, Software Engineer

D. Crowley, Principal Engineer

R. Fellows, Control Room Supervisor

D. Garofoli, Principal Engineering Analyst

C. Hook, Employee Concerns Program Coordinator

D. Hudnut, Simulator Testing Engineer

M. Ives, General Supervisor, Security Operations

J. Jackson, Supervisor, Engineering

J. Jackson, Manager of Licensing

T. Joachimczyk, Shift Manager

J. Jones, Supervisor, Engineering

D. Kenneston, Supervisor, Security Programs

S. Kimbrough, Principal Engineer

H. Klingenberger, Senior Engineering Analyst

P. Ledain, Senior Analyst, Performance Improvement

T. Mogren, Engineering Manager

T. Paglia, Operations Manager

E. Palmer, Director, Security

D. Pascuzzi, Supervisor, Engineering

W. Rapin, Principle Engineer

J. Sperr, Supervisor, Engineering

B. Weaver, Supervisor, Engineering

J. Zapetis, Senior Engineering Analyst

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

05000244/2014008-01 FIN Failure to Effectively Implement Corrective Actions Associated with Heater Drain Tank Pump Tripping

Issues

Attachment

LIST OF DOCUMENTS REVIEWED

Section 4OA2: Problem Identification and Resolution

Audits and Self-Assessments

CAP-13-01-G, Corrective Action Program

RPP-13-01-G, Radiation Protection Program

SA-2011-000083, Radiation Program Training Program

SA-2011-000104, Operator Fundamentals

SA-2011-000127,

IER 11-3 Operator Fundamentals Self-Assessment

SA-2011-000304, Operator Fundamentals in Training

SA-2012-000035 Emergency Preparedness Readiness for NRC Inspection

SA-2012-000063 Chemistry Training Program

SA-2012-000142 Snapshot Self-Assessment of the FIN Team Crew MRM

SA-2012-000088 Ginna Licensed Operator Requalification, 71111.11-type, and Simulator Health Focused Self-Assessment

SA-2012-000111, Annual Assessment of Radiological Groundwater Protection Program

SA-2012-000126, Perform Interim Effectiveness Review to Assess ACE Corrective Actions,

CR-2011-006651

SA-2012-000152, Dosimetry Technician Training Program

SA-2012-000197, Radiation Protection (RP) Training MRM

SA-2012-000229, Assess Radiation Protection procedures to ensure alignment with A-601.1

SA-2012-000247, Effectiveness of

CNG-CM-1.01-1003 and

SEC-1005

SA-2013-000002, Equipment Reliability Semi-Annual Snapshot SA

SA-2013-000085, Equipment Reliability Semi Annual

SA-2013-000086, SOER 88-1 REC 4 IA System Failures

SA-2013-000213, Snapshot Self-Assessment for IER 4 11-38 Causes of Circuit Card Related Problems

SA-2013-000225 Snapshot Self-Assessment of SAT Process for Mechanical Maintenance 2012

SA-2013-000255, Security Response to Individuals Who Have Received an Explosive Alarm

SA-2013-000280, 2014 NS Snapshot: Access Control Program

SEC-13-01-G, Security, August 27, 2013

Condition Reports

CR-2009-006329

CR-2009-008477

CR-2010-000191

CR-2010-000210

CR-2010-005015

CR-2010-006323

CR-2010-007268

CR-2011-000299

CR-2011-000544

CR-2011-001113

CR-2011-002482

CR-2011-003110

CR-2011-002468

CR-2011-004498

CR-2011-004520

CR-2011-004914

CR-2011-005716

CR-2011-006025

CR-2011-006415

CR-2011-006652

CR-2011-007237

CR-2011-007245

CR-2011-007883

CR-2011-007889

CR-2011-008659

CR-2012-000056

CR-2012-000294

CR-2012-000297

CR-2012-000544

CR-2012-000591

CR-2012-000603

CR-2012-000728

CR-2012-000853

CR-2012-000936

CR-2012-000977

CR-2012-001084

CR-2012-001153

CR-2012-001292

CR-2012-001387

CR-2012-001548

CR-2012-002035

CR-2012-002234

CR-2012-002331

CR-2012-002569

CR-2012-002682

CR-2012-002771

CR-2012-002825

CR-2012-002926

CR-2012-003008

CR-2012-003351

CR-2012-003406

CR-2012-003458

CR-2012-003505

CR-2012-003506

CR-2012-003507

CR-2012-003508

CR-2012-003510

CR-2012-003793

CR-2012-003811

CR-2012-004066

Attachment

CR-2012-004267

CR-2012-004290

CR-2012-004385

CR-2012-004408

CR-2012-004569

CR-2012-004619

CR-2012-004628

CR-2012-004709

CR-2012-005457

CR-2012-005494

CR-2012-005588

CR-2012-005619

CR-2012-006048

CR-2012-006368

CR-2012-006529

CR-2012-007021

CR-2012-007027

CR-2012-007082

CR-2012-007133

CR-2012-007499

CR-2012-007594

CR-2012-007623

CR-2012-007630

CR-2012-007632

CR-2012-007792

CR-2012-007843

CR-2012-007874

CR-2012-008003

CR-2012-008208

CR-2012-008306

CR-2012-008407

CR-2012-008442

CR-2012-008494

CR-2012-008496

CR-2012-008504

CR-2012-008908

CR-2012-008912

CR-2012-009204

CR-2013-000028

CR-2013-000126

CR-2013-000296

CR-2013-000404

CR-2013-000493

CR-2013-000922

CR-2013-001093

CR-2013-001099

CR-2013-001102

CR-2013-001181

CR-2013-001223

CR-2013-001225

CR-2013-001243

CR-2013-001249

CR-2013-001252

CR-2013-001345

CR-2013-001368

CR-2013-001619

CR-2013-001929

CR-2013-001956

CR-2013-002275

CR-2013-002338

CR-2013-002350

CR-2013-002373

CR-2013-002389

CR-2013-002604

CR-2013-002608

CR-2013-002621

CR-2013-002659

CR-2013-002702

CR-2013-002790

CR-2013-002791

CR-2013-002828

CR-2013-002852

CR-2013-002906

CR-2013-003075

CR-2013-003111

CR-2013-003206

CR-2013-003246

CR-2013-003279

CR-2013-003377

CR-2013-003536

CR-2013-003682

CR-2013-003872

CR-2013-003889

CR-2013-003983

CR-2013-004063

CR-2013-004081

CR-2013-004427

CR-2013-004461

CR-2013-004474

CR-2013-004477

CR-2013-004582

CR-2013-004592

CR-2013-004708

CR-2013-004752

CR-2013-004765

CR-2013-004820

CR-2013-004859

CR-2013-004911

CR-2013-004920

CR-2013-004929

CR-2013-004975

CR-2013-004986

CR-2013-005033

CR-2013-005101

CR-2013-005221

CR-2013-005222

CR-2013-005274

CR-2013-005337

CR-2013-005378

CR-2013-005384

CR-2013-005599

CR-2013-005643

CR-2013-005667

CR-2013-005796

CR-2013-006041

CR-2013-006051

CR-2013-006153

CR-2013-006231

CR-2013-006232

CR-2013-006265

CR-2013-006296

CR-2013-006302

CR-2013-006559

CR-2013-006630

CR-2013-006643

CR-2013-006683

CR-2013-006684

CR-2013-006708

CR-2013-006730

CR-2013-006779

CR-2013-006874

CR-2014-000032

CR-2014-000196

CR-2014-000197

CR-2014-000216

CR-2014-000219

CR-2014-000229

CR-2014-000337

CR-2014-000499

CR-2014-000575

CR-2014-000582

CR-2014-000584

CR-2014-000587

CR-2014-000588

CR-2014-000795

CR-2014-000975

CR-2014-000981

CR-2014-000983

CR-2014-001011

CR-2014-001037

CR-2014-001053

CR-2014-001072

CR-2014-001208

CR-2014-001283

CR-2014-001287

CR-2014-001289

CR-2014-001291

CR-2014-001299

CR-2014-001304

Drawings

33013-1232, Main Steam Non-Safety Related (MS) P&ID, Revision 33

33013-1233, Condensate Low Pressure FW Heaters (CDST) P&ID, Revision 34

33013-1236, Feedwater (FW) P&ID, Sheet 1, Revision 17

33013-1250, Station Service Cooling Water Safety Related (SW) P&ID, Sheet 2, Revision 48 33013-1252, Condensate P&ID, Revision 30 33013-1922, Feedwater Heater Vents, Relief and Misc. Drains P&ID, Revision 20

33013-1923, Feedwater Heater Drain System P&ID, Revision 29

Attachment

Operating Experience

OE-2009-000565,

090310 -

IN 09-02 Biodiesel In Fuel Oil Could Adversely Impact Diesel Engine Performance

OE-2011-000530 Load Tap Changer Control Power

OE-2011-001480 IER L1-11-2 Weakness in Operator Fundamentals

OE-2011-002285 IER L4 11-38, Causes of Circuit Card Related Problems

OE-2011-002780,

111110 - IER L2-11-46, Extended Emergency Power Operations Following A

Loss of Off-Site Power

OE-2012-000883

IER-L2-12-27 Reactor Scram and Loss of Offsite Power

OE-2012-001119 IN12-04, Impacts on Normal Plant Operations Due to Leaks or Spills of Chemicals

OE-2012-001983 IN12-11, Age-Related Capacitor Degradation

OE-2012-002307, OE36593 - Emergency Diesel Generator Room Ventilation Test Adequacy (Point Beach)

OE-2012-002876, OE300567R20121120 Class 1E Instrument Power Inverter Constant Voltage

Transformer Failed Resulting In A Transfer To The Bypass Source

OE-2012-002876-001, OE300567R20121120 Class 1E Instrument Power Inverter Constant

Voltage Transformer Failed Resulting In A Transfer To The Bypass Source

OE-2012-003091 IN12-21, Reactor Vessel Closure Head Studs Remain Detensioned During Plant Startup

OE-2013-002484, OE306698R20130719 External Flood Paths Identified in Auxiliary Building

After Stator Drop Event

Non-Cited Violations and Findings

05000244/2012005-04 FIN, Incorrect Oil Filter Gasket Installed in the 'B' Main Feedwater Pump Canister Cover 05000244/2013004-03 FIN, Inadequate Guidance for Workers to Implement a Modification to the Main Generator Digital Protection Relays05000244/2012005-02 NCV Failure to Perform an Adequate Extent-of-Condition Review for Water Identified in the Technical Support Center Diesel Fuel Storage Tank 05000244/2012005 NCV Failure to meet conduct of operations requirements leads to loss of spent fuel pool cooling

05000244/2012008-01, Failure to Validate Plant Safe Shutdown Timeline for Design Basis Tornado 05000244/2012403-01, Failure to Analyze and Identify Site Specific Conditions05000244/2013003-01 NCV Failure to Establish Measures to Assure that a Misaligned Service Water Pump was Promptly Identified and Corrected

05000244/2013004-02 NCV Failure to Implement Scaffolding Procedure Requirements

05000244/2013007-01, NCV Required Voltage and Timing Criteria for Load Tap Changer Controls and Motor 05000244/2013202-01, Failure to Implement a Proper IDS Testing Program

Procedures

A-601.10, Time Critical Action Management Program, Revision 00003 A-601.10, Time Critical Action Management Program, Revision 00300

AP-FW.1, Abnormal MFW Pump Flow or NPSH, Revision 01802

AP-TURB.5, Rapid Load Reduction, Revision 01501

Attachment

CH-190, R.E. Ginna Nuclear Power Plant Technical Procedure, Diesel Fuel Oil Testing

Program, Revision 00500

CNG-AM-1.01-1018, Preventive Maintenance Program, Revision 00801

CNG-CA-1.01-1000, Corrective Action Program, Revision 01000

CNG-CA-1.01-1000, Constellation Energy Nuclear Generation Fleet Guideline, Corrective

Action Program, Revision 00902

CNG-CA-1.01-1001, Constellation Energy Nuclear Generation Fleet Guideline, Management

Review Committee, Revision 00500

CNG-CA-1.01-1004, Constellation Energy Nuclear Generation Fleet Administrative Procedure,

Root Cause Analysis, Revision 00804

CNG-CA-1.01-1005, Constellation Energy Nuclear Generation Fleet Administrative Procedure, Apparent Cause Evaluation, Revision 00603

CNG-CA-1.01-1007, Constellation Energy Nuclear Generation Fleet Guideline, Performance

Improvement Program Trending and Analysis, Revision 00401

CNG-CA-1.01-1010, Use of Operating Experience, Revision 01000

CNG-CA-1.01-GL002, Causal Analysis Handbook, Revision 00600

CNG-CA-1.01-GL002, Constellation Energy Nuclear Generation Fleet Guideline, Causal

Analysis Handbook, Revision 00600

CNG-CA-1.01-GL007, Constellation Energy Nuclear Generation Fleet Guideline, Departmental

Corrective Action Review Team (DCART), Revision 00100

CNG-CA-1.01-GL008, Constellation Energy Nuclear Generation Fleet Guideline, Corrective Action Completion Evaluation (CACE), Revision 00200

CNG-CA-2.01-1000, Constellation Energy Nuclear Generation Fleet Administrative Procedure, Self-Assessment and Benchmarking Process, Revision 00703

CNG-MN-1.01-1005, Scaffold Control, Revision 00400

CNG-NL-1.01-1005, 10

CFR 21 Screening, Evaluating, and Reporting, Revision 0000

CNG-OP-1.01-1009, Monitoring and Contingency Planning for Abnormal Conditions, Revision

00100

CNG-OP-1.01-GL007, Operational Configuration Control, Revision 00200

CNG-QL-3.01-1001, Constellation Energy Nuclear Generation Fleet Administrative Procedure, Safety Conscious Work Environment and Employee Concerns Program, Revision 00301

CPI-TRIP-TEST-5.40, Reactor Protection System Trip Test/Calibration for Channel 4 (Yellow)

Bistable Alarms, Revision 03204

ER-D/G.1, Restoring D/G's, Revision 01800

GL-SEC-04, Process Guideline Classification of Security Operating Experience (OE) Into Site

Process, Revision 00100

IP-ALA-1, R.E. Ginna Nuclear Power Plant Station Administrative Procedure, ALARA Challenge Board, Revision 00100

IP-OPS-6, R.E. Ginna Nuclear Power Plant Station Administrative Procedure, Control of Spent Fuel Pool Activities, Revision 00000

IP-RPP-9, R.E. Ginna Nuclear Power Plant Station Administrative Procedure, Department ALARA Advocate, Revision 00000

NTG-13, Ginna Station Nuclear Training Guideline, Continuing Training Plans, Revision 16

RPG-74, Radiation Protection Guideline, Revision 00001

Ginna Nuclear Procurement Specification, Circuit card refurbishment / Repair Specification, Revision 0 dated April 11, 2012

CNG-EV-1.01-1002, Constellation Energy Nuclear Generation Fleet Administrative Procedure, Chemical Control Program, Revision 00401

MMP-GM054-00001, Permanent Fire Barrier Penetration Seal Installation/Repair, Revision

00100 O-6.13, Daily Surveillance Log, Revision 18106

Attachment

OSG-01, Online Schedule Guideline, Revision 01500

OSG-01, Ginna Specific Online Scheduling Guideline, Revision 02400

SEC-1007, Protected & Vital Area Keys & Security Related Equipment Keys, Revision 00103

SEC-CAS-SAS, Central/Secondary Alarm Station Operation, Revision 00600

SES-SSS-RTL, Security Shift Supervisor/

Response Team Leader Duties," Revision 00500

STP-O-12.6-COMP-A, Diesel Generator Fuel Oil Transfer Pump A Comprehensive Test, Revision 00300

STP-O-12.6A, Diesel Generator Fuel Oil Transfer Pump A Test, Revision 00800

Work Orders

C91293582

C91864171

C92292290

C92491983

Miscellaneous

CFR 50.54(q) Analysis for Public Alerting System

AI-2011-001107-001

AI-2012-001423

ANSI/ANS 3.5-2009, Nuclear Power Plant Simulators for use in Operator Training and Examination Apparent Cause Evaluation for

CR-2012-006214, Negative Trend in decay Heat Removal

Category 1 Root Cause Analysis

CR-2011-000544, Safety Tagging Category 1 Root Cause Analysis

CR-2012-000544

Category 1 Root Causal Analysis for

CR-2013-003581, Operating crews do not implement some actions important to transient and accident mitigation Category 1 Root Cause Analysis

CR-2013-004461, Generator Trip during VAR Testing

CENG Letter Subject Report Taken in Response to INPO Event Report L1-11-3 dated September 30, 2011

CENG Letter Subject Report on Actions Taken in Response to INPO Event Report IER L2-12-

dated September 7, 2012 CENG Request for Quote Pref #10404 Revision 1

CENG email from Maureen Kuchta to Dale Markowski etal, dated April 29, 2013 Subject "B" SW Pump Shaft Charpy Impact Results CENG

PO 6612799 Revisions 0, 1, 2 and 3

DA-EE-96-068-03 Ginna Offsite Power Load Flow Study Data List of 94 pages of simulator CRs and discrepancies from 2009 to 2014

ECP-2009-0262, Condensate System Design Pressure Re-Rate, Revision 0

Flowserve Certificate of Conformance dated August 25 for

PO 6612799, Revision 3 Flowserve letter dated March 21, 2011, Subject

RFQ 10404 Flowserve letter dated April 19, 2013 Subject Shaft Design considerations for model 20H 500-2 Stage Service Water Pump, Worthington/Flowserve Serial Number

VTP-19891/94 G1-HRA-F001, FIRE PRA Notebook Human Reliability Analysis (HRA), Revision 002

Gap Analysis for

CR-2012-002926 NRC Green NCV

Gap Analysis for

CR-2013-001093 Failure to meet conduct of operations requirements

ISTM-160, In-Service Test Program

Memorandum, October 9, 2009

ISTM-172, In-Service Test Program

Memorandum, November 11, 2010

ISTM-182, In-Service Test Program

Memorandum, April 27, 2012

Performance Improvement Report, November 2013