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05000244/FIN-2018002-0130 June 2018 23:59:59GinnaNRC identifiedIncorrect Scaling Factors in Reactor Vessel Level Monitoring System Instrumentation Uncertainty CalculationThe inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, when Exelon failed to ensure that adequate design control measures existed to verify the adequacy of the Reactor Vessel Level Monitoring System (RVLMS) uncertainty calculation. Specifically, Exelon failed to identify errors in the RVLMS uncertainty calculation which resulted in a reasonable doubt of operability for the system after a temporary modification was implemented.
05000244/FIN-2018403-0130 June 2018 23:59:59GinnaNRC identifiedSecurity
05000244/FIN-2018011-0231 March 2018 23:59:59GinnaSelf-revealingFailure to Procedurally Verify Fuel Transfer Cart Results in Fuel Interference EventA self-revealing Green non-cited violation (NCV)of Technical Specification 5.4.1.a, Procedures, was identified for the failure of Exelon to operate refueling equipment in accordance with technical procedures in April and May of 2017, which resulted in a fuel interference event, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly
05000244/FIN-2018011-0131 March 2018 23:59:59GinnaNRC identifiedPotential Preconditioning of Turbine Driven Auxiliary Feedwater Surveillance TestingThe NRC identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control, because Exelon established unevaluated preconditioning, with a reasonable doubt of whether the preconditioning was acceptable, prior to testing of the turbine driven auxiliary feedwater pump. This results in the loss of as-found conditions which challenge the capability of the test to assure that the turbine driven auxiliary feedwater pump will perform satisfactorily in service.
05000244/FIN-2017004-0131 December 2017 23:59:59GinnaNRC identifiedInadequate Component Monitoring Relating to Online Risk Management and AssessmentThe inspectors identified a finding because Exelon personnel did not follow Procedure WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2 to sufficiently monitor components such that the latest information was used to evaluate plant risk. Specifically, on December 27, 2017, Exelon failed to sufficiently monitor the diesel driven air compressor, commensurate with its operating history, such that a failure would be assessed and updated in the current plant risk assessment. Exelon entered this issue into the corrective action program (CAP) for resolution as action request (AR) 0487519. Corrective actions included declaring the diesel driven air compressor non-functional, transitioned to Yellow online plant risk, and completed restoration of the C Instrument Air Compressor.This finding is more than minor because it is associated with the configuration control attribute of the Initiating Events cornerstone and adversely affected the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Additionally, this issue is similar to Example 7.f of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, because the overall elevated plant risk placed the plant into a higher licensee-established risk category. The inspectors evaluated this finding using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used Flowchart 2, Assessment of (risk management actions) RMAs, to analyze the finding and calculated the incremental large early release probability using PARAGON, Exelons risk assessment tool, and found the increase in incremental large early release probability was less than 1E-7. The inspectors determined that if this condition existed for the full duration of the maintenance period, the large early release probability would have been 2.22E-7. Because the increase in incremental large early release probability, was less than 1E-7, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon did not recognize and plan for the possibility of mistakes, latent issues and inherent risk, even while expecting successful outcomes. Specifically, Exelon did not ensure a component used to manage and assess risk was monitored at a frequency commensurate with its past performance. (H.12)
05000244/FIN-2017001-0131 March 2017 23:59:59GinnaLicensee-identifiedLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non- cited violation (NC V). Ginna TS Table 3.3.1- 1 requires the function of under frequency Bus 11A and 11B be tested to be greater than or equal to 57.5 hertz in accordance with surveillance requirement 3.3.1.10. Surveillance requirement 3.3.1.10 requires this testing to be completed in accordance with the Surveillance Frequency Control Program. The Surveillance Frequency Control Program requires the function of under frequency Bus 11A and 11B be tested every 24 months. Contrary to the above, on February 6, 2017, Ginna engineering personnel determined that the Bus 11A under frequency function had not been tested within the interval specified frequency ; the function had last been tested on May 1, 2014 . Upon identification, Exelon conducted a risk evaluation and completed the surveillance requirement at the next available opportunity i n accordance with surveillance requirement 3.0.3 for a missed surveillance. Exelon entered this issue into the CAP as AR 03970849 and completed the testing on March 11, 2017. Additional evaluation was required to demonstrate operability since the acceptance criteria of greater than or equal to 57.5 Hz was not met. The inspectors determined the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The SDP for Findings at Power, Exhibit 1, Initiating Events Screening Questions, issued June 19, 2012, because the transient initiator did not cause a reactor trip and the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
05000244/FIN-2016404-0131 December 2016 23:59:59GinnaNRC identifiedSecurity
05000244/FIN-2016003-0130 September 2016 23:59:59GinnaNRC identifiedFailure to Perform Drills Required by the Site Emergency PlanThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) for Exelons failure to maintain an emergency plan that meets the requirements in Appendix E, Content of Emergency Plans, to Part 50 and the planning standards of 50.47(b). Specifically, Exelon did not perform a drive-in augmentation drill during the required 3-year cycle nor did they perform a health physics drill semi-annually as required by Ginnas Emergency Plan Implementing Procedure EP-AA-122-100, Drill and Exercise Planning and Scheduling. Immediate corrective actions included entering this issue into their corrective action program (CAP). This finding is more than minor because it is associated with the emergency response organization (ERO) readiness attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that Exelon is capable of maintaining adequate measures to protect the health and safety of the public in the event of a radiological emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Attachment 2, Failure to Comply Significance Logic, the inspectors determined that the performance deficiency affected planning standard 10 CFR 50.47(b)(14). The inspectors concluded that this performance deficiency matched an example on Table 5.14-1 Significance Examples 50.47(b)(14), for a Degraded Planning Standard Function. Specifically, two drills had not been conducted during a 2year (calendar) period in accordance with the emergency plan, thus constituting a degraded planning standard function which corresponds to a very low safety significance (Green) finding. The cause of the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon did not schedule or plan for a drive-in augmentation drill or health physics drills in accordance with procedure EP-AA-122-100. (H.8)
05000244/FIN-2016002-0130 June 2016 23:59:59GinnaNRC identifiedIncorrect Emergency Action Level TableExelon identified that they had inadvertently made a change to the Ginna Emergency Plan. The NRC determined that this error is a preliminary White finding under the Reactor Oversight Process and a violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54 (q)(2), Emergency Plans, because Exelon did not maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and the planning standards of 10 CFR 50.47(b). Specifically, Exelon implemented a revision to the emergency action level (EAL) table for the fission product barrier matrix that was incorrect with respect to the EAL threshold associated with potential loss of containment barrier. This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely affected the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, Exelons EAL table was revised without adequate technical reviews resulting in a discrepancy between the EAL table and the EAL technical basis. The EAL wording of Table F-1 containment barrier potential loss, block C.6 did not meet the minimum required operable equipment in all situations and could have resulted in a delayed General Emergency declaration or a failure to declare a Site Area Emergency. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process (SDP), to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification system planning standard and is considered a risk-significant planning standard function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47 (b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. In accordance with Section 5.4, when an EAL has been rendered ineffective such that any General Emergency declaration would not be declared, but due to other EALs, an appropriate declaration would be made in a degraded manner or any Site Area Emergency would not be declared for a particular off-normal event, a degradation of risk-significant planning standard function (b)(4) is determined; and the finding is White. The finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, Exelon did not maintain a clear focus on nuclear safety when implementing changes to the EALs resulting in a significant unintended consequence, the potential to make an untimely emergency declaration.
05000244/FIN-2016403-0131 March 2016 23:59:59GinnaNRC identifiedSecurity
05000244/FIN-2016001-0131 March 2016 23:59:59GinnaLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities. Section IV.B.1 of 10 CFR 50, Appendix E, requires, in part, that the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of State and local agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. Contrary to the above, prior to January 7, 2016, Exelon procedure EP-AA-110-203, GNP Dose Assessment, Revision 003, did not consider the possibility of two different flow rate values through the plant vent. The plant vent has the capability to flow through filters when new fuel assemblies are added to the SFP resulting in the potential for two different flow rates out the ventone with the filters in service (69074 cubic feet per minute) and one without the filters in service (50560 cubic feet per minute). Due to the error, during certain events, Exelon would have inappropriately determined the event contaminant release rate to be higher than actual, resulting in the early declaration of an emergency action level. Upon identification, Exelon entered this into its CAP as AR 02609057 and implemented dose assessment compensatory measures to be used in EP-AA-110-203, Attachment 7, Ventilation Systems Flow Rates, table data. The inspectors determined the finding was of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 22, 2015, because a deficient emergency classification process which would result in an overclassification, but would not result in unnecessary public protective measures should be considered Green.
05000244/FIN-2015008-0131 December 2015 23:59:59GinnaNRC identifiedAlternative Shutdown Procedure Deficiencies for Postulated Spurious OperationsFailure to provide an adequate post-fire safe shutdown operating procedure to ensure the integrity of alternating current (AC) power availability was a performance deficiency (PD). This PD was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The team performed a Phase 1 Significance Determination Process (SDP) screening, in accordance with NRC Inspection Manual Chapter (IMC) 0609, Appendix F, Fire Protection Significance Determination Process. This deficiency affected the post-fire safe shutdown category because Exelon's fire response procedures were degraded. This issue was screened to very low safety significance (Green) because it was assigned a low degradation rating. The team determined this issue had a low degradation rating because the procedural deficiencies could be compensated by operator experience and system familiarity within sufficient time to maintain functionality of the A EDG. Cross-cutting aspects are not applicable to issues involving enforcement discretion. Ginna License Condition 2.C.(3), in part, required Exelon to implement and maintain in effect all fire protection features described in licensee submittals and as approved by the NRC. The Ginna FPP stated that the requirements of Appendix R, Section III.L were applicable for areas where alternative shutdown capability was selected and the B EDG Room and Vault was designated as an alternative shutdown area. Appendix R, Section III.L.3 required procedures to be in effect to implement the alternative shutdown capability. Contrary to the above, from 1983 (original Appendix R analysis) until present, Exelon had not implemented an adequate alternative shutdown procedure. Specifically, FRP-25.0 did not contain adequate instructions to ensure that postulated fire-damage to cables associated with A EDG auxiliary equipment, which were routed through the B EDG cable vault, would be mitigated prior to an adverse impact to the A EDG. As a consequence, an operator would have to recognize, diagnose, and correct a loss of power to MCC-H in sufficient time to prevent a loss of the A EDG. Exelon entered this deficiency into its CAP as CR 02563623. Exelon was in transition to NFPA 805 and, therefore, this NRC-identified issue was evaluated in accordance with the criteria established in NRC Enforcement Policy Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), and IMC 0305, Operating Reactor Assessment Program, Section 11.05, Treatment of Items Associated with Enforcement Discretion. Because all the criteria were satisfied, the NRC exercised enforcement discretion and did not issue a violation for this issue.
05000244/FIN-2015008-0231 December 2015 23:59:59GinnaNRC identifiedSpurious Operation of Pressurizer Power Operated Relief Valves not AnalyzedFailure to analyze the effects of spurious operation of a PORV was a PD. Specifically, Exelon's safe shutdown methodology postulated spurious operation of the PORVs, but had not analyzed the effect of the spurious operations. Exelon's safe shutdown analysis assumed operators had 23.9 minutes after a fire induced plant trip to re-establish the reactor coolant makeup (i.e., charging), but non-conservatively assumed that the PORVs remained closed. In addition, Exelon relied upon a non-time critical operator manual action to de-energize the PORV circuits from outside the control room after control room abandonment. This PD was more than minor because it was similar to Example 3.k of IMC 0612, Appendix E, Examples of Minor Issues, which determined that calculation errors would be more than minor if, as a result of the errors, there was reasonable doubt of the operability of the component. For this issue, the team had a reasonable doubt as to whether operators had sufficient time to re-establish charging to maintain pressurizer level within the indicated range. In addition, this issue was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The team performed an SDP Phase 1 screening, in accordance with IMC 0609, Appendix F. This deficiency affected the post-fire safe shutdown category because Exelon's safe shutdown analysis was incomplete. This issue was screened to very low safety significance (Green) because it was assigned a low degradation rating. The team determined this issue had a low degradation rating because Exelon's subsequent evaluation determined that the performance goals of Appendix R, Section III.L.2 were still satisfied, based on more restrictive administrative limits for RCS leakage than the Technical Specifications limits assumed in the original calculation. In addition, Exelon evaluated this issue with Ginna's fire probabilistic risk assessment (PRA) analysis and determined that the change in core damage frequency (CDF) attributed to this issue was in the low E-7 range. A Region I Senior Reactor Analyst reviewed Exelon's evaluation and concluded that the risk estimate was bounded by conservative assumptions and that this issue was of very low safety significance (Green). Cross-cutting aspects are not applicable to issues involving enforcement discretion. Ginna License Condition 2.C.(3), in part, required Exelon to implement and maintain in effect all fire protection features described in licensee submittals and as approved by the NRC. The Ginna FPP stated that the requirements of Appendix R, Section III.L were applicable for areas where alternative shutdown capability was selected and the control complex was designated as an alternative shutdown area. Appendix R, Section III.L.2 performance goals stated that pressurizer level shall remain within the indicated range. Contrary to the above, from March 2006 until present, Exelon had not adequately determined that pressurizer level would remain within the indicated range during alternative shutdown operations. Specifically, DA-EE-2000-066 determined that a fire in the control complex could result in spurious opening of a PORV until completion of an operator action outside of the control complex to de-energize the circuit. However, calculation DA-ME-2000-075 determined the time available for operators to re-establish charging following control room abandonment but assumed that the PORVs remained free of fire damage and did not spuriously open. Exelon entered this deficiency into its CAP as CRs 02563631 and 02563632. Exelon was in transition to NFPA 805 and, therefore, this NRC-identified issue was evaluated in accordance with the criteria established in NRC Enforcement Policy Section 9.1 and IMC 0305, Section 11.05. Because all the criteria were satisfied, the NRC exercised enforcement discretion and did not issue a violation for this issue.
05000244/FIN-2015008-0331 December 2015 23:59:59GinnaLicensee-identifiedUnanalyzed Condition due to postulated hot short fire event involving direct current (DC) control circuits affecting multiple fire areasFailure to ensure that one train of equipment necessary to achieve and maintain safe shutdown would remain free of fire damage was a licensee-identified PD. This PD was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Exelon evaluated this issue with Ginna's fire PRA analysis and determined that the change in CDF attributed to this issue was estimated to be 4E-5 per reactor year. A review of the dominant scenarios indicated that the risk from a large early release was bounded by the core damage assessment. A Region I Senior Reactor Analyst reviewed Exelon's evaluation and concluded that the risk estimate was bounded by conservative assumptions and that this issue would be of no greater than substantial safety significance (Yellow). Cross-cutting aspects are not applicable to issues involving enforcement discretion. Ginna License Condition 2.C.(3), in part, required Exelon to implement and maintain in effect all fire protection features described in licensee submittals and as approved by the NRC. The Ginna FPP required Exelon to maintain one train of equipment necessary to achieve and maintain safe shutdown free of fire damage. Contrary to the above, from 1967 (original construction) until April 11, 2014, Exelon postulated that fire damage to unprotected DC circuits could have resulted in secondary fires and, as a consequence, adversely affected equipment necessary to achieve and maintain safe shutdown. Exelon entered this issue into their CAP as CR-2014-001346, and subsequently corrected the condition. Exelon was in transition to NFPA 805 and, therefore, this licensee-identified issue was evaluated in accordance with the criteria established in NRC Enforcement Policy Section 9.1 and IMC 0305 Section 11.05. Because all the criteria were satisfied, the NRC exercised enforcement discretion and did not issue a violation for this issue.
05000244/FIN-2015002-0130 June 2015 23:59:59GinnaNRC identifiedFailure to Perform 1-Hour Fire Tours as Required By the Technical Requirements ManualThe inspectors identified a Green NCV of Ginna Operating License Condition 2.C.(3), Fire Protection, because Exelon Generation Company, LLC (Exelon) failed to perform 1-hour compensatory fire tours as required by the Technical Requirements Manual (TRM). Specifically, while a fire barrier component was physically removed, the TRM required a 1-hour fire watch inspection of the affected fire zone; Exelon was performing a 6-hour fire watch. Corrective actions included performing 1-hour fire tours, reinstalling the fire barrier when the work requiring its removal was completed so that fire tours were no longer required, and entering the issue into the corrective action program (CAP). This finding is more than minor because it adversely affected the protection against external factors (i.e., fire) attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609, Appendix F, Fire Protection Significance Determination Process, issued on September 20, 2013, the inspectors determined that the finding is of very low significance (Green), because for localized cable protection (task 1.4.4), an automatic suppression system protected the area where the cable protection was affected by the fire finding. Additionally, the finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that procedures were adequate to support nuclear safety.
05000244/FIN-2015002-0430 June 2015 23:59:59GinnaNRC identifiedAdequacy of Exelon's Protective Action Recommendation StrategyExelons Emergency Plan at Ginna was not in compliance with the regulation at the time the URI was opened. Specifically, as required by 10 CFR 50.47(b)(10), Exelon did not include bodies of water in their PAR scheme for the plume exposure pathway. In December 2014, Exelon worked with the local county OROs and revised the ERPAs at Ginna to include Lake Ontario. Exelon has amended Ginnas Emergency Plan (Revision 03900) and PAR scheme to reflect the change. The NRC concluded that it was not reasonable for Exelon to have been able to foresee and correct the violation caused by not having PARs for Lake Ontario. Specifically, in light of the NRC inspection reports, which approved the licensees Emergency Plan and did not identify this issue, the licensee reasonably concluded that it was in compliance with NRC requirements. Therefore, the NRC did not identify any performance deficiency associated with the violation. IMC 0612, Appendix B, Issue Screening, issued September 7, 2012, directs disposition of this issue in accordance with NRC Enforcement Policy because there was no performance deficiency. Therefore, in accordance with NRC Enforcement Policy, Section 2.2.4.d, which states that a violation involving no performance deficiency is considered an exception to using only the operating reactor assessment program, the inspectors dispositioned this violation using traditional enforcement. The inspectors used NRC Enforcement Policy, Section 6.6, Emergency Preparedness, to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor and best characterized as Severity Level III (low-to-moderate safety significance) because it is similar to Enforcement Policy Example Violation 6.6.c.2. Additionally, the inspectors compared this evaluation to the risk associated with the issue by using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 23, 2014. The inspectors screened the issue and evaluated it using Table 5.10-1, Significance Examples 50.47(b)(10), and Section 5.0.2.h, which describes the consideration of compensatory measures when screening for significance. The inspectors concluded that because Exelon provided the wind speed and direction on the notification form to the OROs, and because the counties take action to evacuate Lake Ontario at an Alert level, the planning standard function was not lost and would still be accomplished, albeit in a degraded manner. Based on these reviews, were it to be evaluated under the reactor oversight process, the issue would screen as low-to-moderate safety significance (White). This issue was entered into Exelons CAP as AR 1701509. Because the inspectors determined no performance deficiency existed, the NRC has decided to exercise enforcement discretion in accordance with Section 3.5 of the NRC Enforcement Policy and refrain from issuing enforcement action for the violation (EA-15-025). Further, because Exelons action and/or inaction did not contribute to this violation, it will not be considered in the assessment process, or the NRCs action matrix. This URI is closed.
05000244/FIN-2015002-0230 June 2015 23:59:59GinnaSelf-revealingInadequate Procedure Implementation Results in Inadvertent Entry into 72 Hour Technical Specification Action StatementA self-revealing Green NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for inadequate implementation of procedure M-71.4, Removal and/or Installation of Modules within Defeated or Out-of-Service Instrument Loops. Specifically, while performing maintenance procedures for the sodium hydroxide (NaOH) flow loop power supply replacement, Exelon inadvertently caused a short in electrical circuitry that resulted in an automatic switch of instrument bus C from inverter B to its backup power supply; this caused an entry into a 72-hour TS action statement and actuation of the control room emergency air treatment system (CREATS). Corrective actions included entering this issue into the CAP. This finding is more than minor because it is associated with the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, the inspectors determined that the finding is of very low significance (Green), because the finding was not a deficiency affecting the design or qualification of a mitigating structure, system, and component (SSC); did not represent a loss of system and/or function; and did not represent an actual loss of function of at least a single train. Additionally, the finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes.
05000244/FIN-2015002-0330 June 2015 23:59:59GinnaNRC identifiedInadequate Preferred Auxiliary Feedwater Protection from Potential Block Wall FailuresThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion III, Design Control, because Exelon did not provide for verifying or checking the adequacy of design, such as by the performance of design reviews and calculations to ensure that masonry block wall failures in the intermediate building would not challenge preferred auxiliary feedwater (AFW) piping operability. Corrective actions included installation of a temporary modification which corrected the condition, and entering this issue into the CAP. Exelon is evaluating options for a permanent modification to correct the issue. This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, if non-safety-related block wall 8-973-8I failed following a design basis seismic event, portions of the turbine-driven and B motor-driven AFW systems could be impacted by falling blocks. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibits 2 and 4 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the performance deficiency was a deficiency affecting external event mitigation systems (seismic/fire/flood/severe weather protection degraded). The performance deficiency did not involve the degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g., seismic snubbers, flooding barriers, tornado doors) only a reasonable doubt regarding the operability of the turbinedriven AFW system. Therefore, the inspectors determined that this finding is of very low safety significance (Green). Additionally, the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Identification, because Ginna did not implement a CAP with a low threshold for identifying issues and individuals did not identify issues completely, accurately, and in a timely manner in accordance with the program.
05000244/FIN-2015001-0331 March 2015 23:59:59GinnaLicensee-identifiedLicensee-Identified Violation10 CFR 50, Appendix B, Criterion XI, "Test Control," requires, in part, that a test program be established to assure that all testing required to demonstrate that SSCs will perform satisfactorily in service is performed in accordance with written test procedures. Contrary to the above, prior to October 2014, Exelon did not perform adequate periodic and independent testing to demonstrate that the relays that provide permissives for emergency diesel generator breaker closing to the emergency buses would perform satisfactorily in the event of a postulated single failure during a design basis event. Exelon entered the issue into their CAP as AR 02344861, and tested and replaced the relays in question. The inspectors determined the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating System Screening Questions, issued June 19, 2012, since the finding was not a deficiency affecting the design or qualification of a mitigating SSC, did not represent a loss of system and/or function, and did not represent an actual loss of function of at least a single train.
05000244/FIN-2015001-0131 March 2015 23:59:59GinnaSelf-revealingInadequate Corrective Actions Result in Failure of Bus 18 Undervoltage Solid State Switchboard CardA self-revealing Green NCV of Title 10 of the Code of Federal Regulations (10 CFR), Appendix B, Criterion XVI, Corrective Action, was identified for failure to establish measures to assure that a condition adverse to quality associated with the availability of the bus 18 solid state switchboard card (SS1) was promptly identified and corrected. Specifically, Ginna did not adequately complete previous corrective actions to ensure carbon resistors in risk significant components were identified and replaced in a timely manner prior to the occurrence of age-related failures, which resulted in the failure of a safety-related bus undervoltage solid state switchboard card and indication of an undervoltage condition. The inspectors determined that the failure to implement corrective actions to identify and correct a condition adverse to quality was a performance deficiency within Exelon Generation Companys, LLC (Exelons) ability to foresee and correct and should have been prevented. Specifically, Exelon failed to adequately execute corrective actions to identify and replace carbon resistors in risk significant components, which resulted in a failure of the bus 18 undervoltage solid state switchboard card. The inspectors determined that the failure to implement corrective actions was more than minor, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, technical specifications (TSs) require each safeguard bus to have two operable channels of loss of power diesel generator start instrumentation. However, this failure caused one channel to be declared inoperable and resulted in operators entering the TS action statement. Additionally, the bus 18 undervoltage solid state switchboard card failed while in service, incurred unnecessary unavailability hours, provided false indication of an undervoltage condition, and resulted in a maintenance preventable functional failure. The inspectors evaluated the finding using IMC 0609.04, Initial Characterization of Findings. The attachment instructs the inspectors to utilize IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the self-revealing performance deficiency was not a deficiency affecting the design or qualification of a mitigating structure, system, and component; did not represent a loss of system and/or function; and did not represent an actual loss of function of at least a single train. Therefore, the inspectors determined this finding to be of very low safety significance (Green). In accordance with IMC 0612, the finding does not have a cross-cutting aspect, because the performance deficiency occurred more than 3 years ago, would not likely occur today under similar circumstances, and is not reflective of present plant performance. In June 2011, when the performance deficiency occurred, the work planning process did not require the use of formal documentation, and briefings were not required for risk-significant work. However, today documentation and briefings are both required for risk-significant work done in the plant. Additionally, Exelon technicians replaced the failed card, completed an extent of condition review and entered the issue into the CAP.
05000244/FIN-2015001-0231 March 2015 23:59:59GinnaSelf-revealingInadequate Protective Action Recommendation FlowchartA self-revealing Green NCV of 10 CFR 50.54(q)(2), 10 CFR 50.47(b)(10), and 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, Section IV.B.1, was identified for Exelon inadequately maintaining the effectiveness of its Emergency Plan. Specifically, 10 CFR 50.54(q)(2) requires reactor licensees to follow and maintain the effectiveness of an emergency plan that meets the requirements in 10 CFR 50, Appendix E and the planning standards of 50.47(b), and Exelon did not adequately maintain the effectiveness of its Emergency Plan when Exelon implemented changes to the protective action recommendation (PAR) flowchart that would have resulted in Exelon inappropriately recommending evacuation of downwind areas and many more emergency response planning areas (ERPAs) than intended. The inspectors determined that Exelon did not adequately maintain the effectiveness of its Emergency Plan in accordance with 10 CFR 50.54(q)(2), 10 CFR 50.47(b), and 10 CFR 50, Appendix E, when Exelon implemented changes to the PAR flowchart. Specifically, Exelon implemented Figure 5.3, Scheme for Protective Action Recommendations, of the Nuclear Emergency Response Plan (NERP), and Attachment 3, Ginna PAR Determination Instructions, of CNG-EP-1.01-1013, Emergency Classification and PAR, Revision 00100, and the flowchart for Initial Protective Action Recommendation ONLY, with an unintentional error. Incorrectly revising and incorporating an inaccurate value in the implementing procedures for the NERP is considered a performance deficiency that was within Exelons ability to foresee and prevent. The inspectors determined that the inadequate maintenance of the Emergency Plan was more than minor because it was associated with the procedure quality attribute of the Emergency Preparedness cornerstone and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, Exelons PAR implementation procedure was revised and contained containment radiation level set points that would potentially result in an inappropriate recommendation to evacuate downwind areas and many more ERPAs than intended when fewer or no evacuations should have been recommended. The inspectors evaluated the finding using IMC 0609.04, Initial Characterization of Findings. The attachment instructs the inspectors to utilize IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, when the finding impacts the licensees Emergency Preparedness cornerstone. The performance deficiency is associated with the emergency protective actions planning standard and is considered a risk-significant planning standard function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.10, 10 CFR 50.47(b)(10), Emergency Protective Actions, to evaluate the significance of this performance deficiency. However, the examples in Table 5.10-1, Significance Examples 50.47(b)(10), address failure to make a PAR, but the examples do not specifically address unnecessary evacuations of ERPAs. Therefore, in accordance with the guidance in Section 5.0.3 of IMC 0609, Appendix B, the issue was evaluated using the Attachment 2 flowchart and informed by the examples provided in other sections of the Emergency Preparedness SDP as described below. In the subject scenario, the licensee will have already accurately made a General Emergency declaration prior to determining an initial PAR. At the General Emergency level, there is at least a loss of two fission product barriers and a potential or full loss of a third, and a release is either in progress or imminent at levels that are likely to exceed Environmental Protection Agency protective action guidelines (PAGs) at and beyond the site boundary. As such, there is potentially a dose avoidance benefit for the public even when a PAG has not been reached due to a General Emergency condition actually existing. Therefore, an inadequate PAR resulting in evacuations of ERPAs when no evacuations are otherwise called for is less significant than an emergency action level overclassification resulting in an unnecessary PAR, because there is a potential dose avoidance benefit to the public at the General Emergency level. In this instance, a PAR is made, which is sufficient to ensure public health and safety, although some additional risk will be incurred. The (b)(10) risk-significant planning standard functions are still met, although Exelon did fail to comply with the planning standard. Therefore, the inspectors determined the finding was of very low safety significance (Green). Exelon corrective actions included issuing NERP, Revision 04000, and CNG-EP-1.01-1013, Revision 00200, which corrected the PAR flowchart text ensuring all emergency directors were adequately trained and aware of the NERP and CNG-EP-1.01-1013 revisions. The finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon did not use a systematic process for evaluating and implementing change so that nuclear safety remained the overriding priority. Specifically, changes to the NERP were made, and the inadequate change and the importance of the changes were not recognized by Exelon corporate, the department review, or the plant operations review committee review. Managers did not ensure individuals understood the importance of, and their role in, the change management process, and managers did not maintain a clear focus on nuclear safety when implementing the change management process to ensure that significant unintended consequences were avoided (H.3).
05000244/FIN-2014005-0131 December 2014 23:59:59GinnaNRC identifiedIncomplete and Inaccurate Medical Information Provided by Exelon Which Resulted in Issuance of an Initial Senior Operator License without a Required Medical RestrictionExelon Generation Company, LLC (Exelon) identified two apparent violations (AVs): (1) An AV of Title 10 of the Code of Federal Regulations (10 CFR) 50.9, Completeness and Accuracy of Information; and (2) An AV of 10 CFR 50.74, Notification of Change in Operator or Senior Operator Status. Specifically, on October 8, 2008, Ginna submitted certified copies of an NRC senior operator license application that did not specify that the applicant required a restriction (to take medication as prescribed for high blood pressure) in order to maintain medical qualifications. The NRC issued the senior operators initial license on December 5, 2008, but without the necessary medical restriction (AV #1). From October 8, 2008, until July 16, 2014, Ginna had several additional opportunities to identify that the blood pressure medication was required to compensate for a disqualifying medical condition and that a license condition was required during the licensees biennial licensed operator requalification program reviews and medical examinations. On July 16, 2014, a period that exceeded 30 days from when the condition was identified, the facility notified the NRC of the medical condition via a letter requesting amendment to the operators license to include the restriction (AV #2). On August 28, 2014, the NRC issued the license amendment with the new restriction. This issue was entered into Exelons corrective action program (CAP). The inspectors determined that Exelons failure to provide complete and accurate information to the NRC in the senior operator license application and to notify the NRC of a change in a senior operators status for a condition which was known by the licensee and were a performance deficiencies that were within their ability to foresee and correct and should have been prevented. The inspectors determined that traditional enforcement applies, as the issue affected the NRCs ability to perform its regulatory function. Namely, the NRC relies upon Exelon to ensure all licensed operators meet the medical conditions of their licenses. If, during the term of the individual operator license, an operator develops a permanent physical or mental disability that causes the operator to fail to meet the requirements of 10 CFR 55.21, Medical Examination, the licensee shall notify the NRC within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c). Additionally, the NRC issued a senior operator license to the applicant based on information that was not complete and accurate in all material aspects. The performance deficiencies were screened against the Reactor Oversight Process per the guidance of IMC 0612, Appendix B, Issue Screening. No associated Reactor Oversight Process finding was identified and no cross-cutting aspect was assigned. These issues constitute AVs in accordance with the NRCs Enforcement Policy, and their final significance will be dispositioned in separate future correspondence. (Section 1R11)
05000244/FIN-2014005-0331 December 2014 23:59:59GinnaLicensee-identifiedLicensee-Identified ViolationAccording to 10 CFR 55.21 and 33, licensed operators are required to have a physical examination every 2 years to ensure that their medical condition and general health will not adversely affect the performance of assigned operator job duties or cause operational errors endangering public health and safety. As a part of licensed operator medical evaluations, olfactory testing is required as specified in ANSI/ANS 3.4 1983. Olfactory testing in the standard states, Nose. Ability to detect odor of products of combustion and of tracer and marker gases. Contrary to this requirement, in CR-2014-003860, Exelon identified that Ginna medical staff had not been testing operators for the mercaptan marker used in natural gas. This violation is subject to traditional enforcement because of the potential impact upon the regulatory process since the operators medical conditions are reviewed by the NRC when issuing or renewing operator licenses. This issue meets the criteria for a Severity Level IV violation because upon subsequent olfactory testing, all operators were found to meet the health requirements for licensing.
05000244/FIN-2014005-0531 December 2014 23:59:59GinnaNRC identifiedA' Emergency Diesel Generator Output Breaker Fails to Close during Routine Surveillance Testing Resulting in a Condition Prohibited by Technical Specifications and a Potential Inability to Fulfill a Safety FunctionOn September 10, 2014, during performance of a routine scheduled surveillance test, STP-O-12.1, Emergency Diesel Generator A, Revision 01600, the output supply breaker to safeguards bus 14 failed to close on demand. Initial troubleshooting revealed no obvious issues with the breaker, and the output supply breaker functioned as required during a second test. A spare breaker was installed and tested satisfactorily on Enclosure 22 September 11, and the A EDG was restored to operable. Exelon concluded that the A EDG had been inoperable since the last successful performance of STP-O-12.1 on August 13, 2014. This 29 day period exceeded the TS allowable outage time of 7 days. Exelons subsequent troubleshooting revealed no electrical issues with the circuit breaker, and the failure modes and effects analysis concluded that the most likely cause of the circuit breaker failing to close was the breaker did not properly reset after performance of the surveillance test on August 13, 2014. The breaker could not be verified to be reset without an internal inspection. The original equipment manufacturer was also requested by Exelon to investigate the cause of the breaker failure. The original equipment manufacturer concluded that the lack of free movement of the operating mechanism trip shaft was the cause of the breaker not resetting and closing. The trip shaft did not move freely due to lack of end-to-end play. Exelons apparent cause evaluation associated with this issue and AR 02178745 noted that these circuit breakers undergo full PM every 4 years, and all PMs on both EDG output breakers have been done in accordance with the PM frequency. The last performance of the PM for the bus 14 breaker was on November 14, 2011. The procedure for the PM has the technicians check for free movement of the trip of the trip shaft, but not end-to-end play movement or clearances to allow end-to-end play. Additionally, the vendor manual does not direct measuring clearances or verifying end-to-end play; this is called out as a vendor task. Therefore, the inspectors concluded that no performance deficiency existed since it was not reasonable for Exelon to foresee and prevent this issue. The inspectors reviewed LER 2014-003-00 and determined that traditional enforcement applies in accordance with IMC 0612, Sections 0612-09 and 0612-13, and NRC Enforcement Policy, Section 2.2.4.d, because a violation of NRC requirements existed without an associated Reactor Oversight Process performance deficiency. The inspectors determined that the maintenance completed on the bus breaker was in accordance with vendor recommendations. This issue was considered to be a Severity Level IV violation of TS 3.8.1 in accordance with Enforcement Policy Section 6.1.d. In addition, IMC 0612, Appendix B, Figures 1 and 2, Issue Screening, were referenced in documenting this Severity Level IV self-revealing violation. This issue was entered into Exelons CAP as AR 02178745. Because it was not reasonable for Exelon to have been able to foresee and prevent the breaker failure, the NRC determined no performance deficiency existed. Thus, the NRC has decided to exercise enforcement discretion in accordance with Section 3.5 of the NRC Enforcement Policy and refrain from issuing enforcement action for the violation (EA-15- 004). Further, because Exelons action and/or inaction did not contribute to this violation, it will not be considered in the assessment process or the NRCs action matrix. This LER is closed.
05000244/FIN-2014005-0431 December 2014 23:59:59GinnaLicensee-identifiedLicensee-Identified ViolationAccording to 10 CFR 50.74, each licensee shall notify the NRC within 30 days of a change in an operators or senior operators status including termination of any operator or senior operator. Contrary to this requirement, in AR 02120732, Exelon identified that Ginna staff did not notify the NRC of termination of two senior operators. The facility terminated the affected operators August 9, 2013, but did not notify the NRC of the change in status until September 10, 2014. This issue meets the criteria for a Severity Level IV violation because the September 10, 2014, notification did not result in increased inspection activities or cause the NRC to reconsider a regulatory position.
05000244/FIN-2014005-0231 December 2014 23:59:59GinnaNRC identifiedFailure to Report a Permanent Change in a Licensed Operator's Medical Status and Request a Condition be Placed on the Operator's LicenseExelon Generation Company, LLC (Exelon) identified two apparent violations (AVs): (1) An AV of Title 10 of the Code of Federal Regulations (10 CFR) 50.9, Completeness and Accuracy of Information; and (2) An AV of 10 CFR 50.74, Notification of Change in Operator or Senior Operator Status. Specifically, on October 8, 2008, Ginna submitted certified copies of an NRC senior operator license application that did not specify that the applicant required a restriction (to take medication as prescribed for high blood pressure) in order to maintain medical qualifications. The NRC issued the senior operators initial license on December 5, 2008, but without the necessary medical restriction (AV #1). From October 8, 2008, until July 16, 2014, Ginna had several additional opportunities to identify that the blood pressure medication was required to compensate for a disqualifying medical condition and that a license condition was required during the licensees biennial licensed operator requalification program reviews and medical examinations. On July 16, 2014, a period that exceeded 30 days from when the condition was identified, the facility notified the NRC of the medical condition via a letter requesting amendment to the operators license to include the restriction (AV #2). On August 28, 2014, the NRC issued the license amendment with the new restriction. This issue was entered into Exelons corrective action program (CAP). The inspectors determined that Exelons failure to provide complete and accurate information to the NRC in the senior operator license application and to notify the NRC of a change in a senior operators status for a condition which was known by the licensee and were a performance deficiencies that were within their ability to foresee and correct and should have been prevented. The inspectors determined that traditional enforcement applies, as the issue affected the NRCs ability to perform its regulatory function. Namely, the NRC relies upon Exelon to ensure all licensed operators meet the medical conditions of their licenses. If, during the term of the individual operator license, an operator develops a permanent physical or mental disability that causes the operator to fail to meet the requirements of 10 CFR 55.21, Medical Examination, the licensee shall notify the NRC within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c). Additionally, the NRC issued a senior operator license to the applicant based on information that was not complete and accurate in all material aspects. The performance deficiencies were screened against the Reactor Oversight Process per the guidance of IMC 0612, Appendix B, Issue Screening. No associated Reactor Oversight Process finding was identified and no cross-cutting aspect was assigned. These issues constitute AVs in accordance with the NRCs Enforcement Policy, and their final significance will be dispositioned in separate future correspondence. (Section 1R11)
05000244/FIN-2014405-0230 September 2014 23:59:59GinnaLicensee-identifiedLicensee-Identified Violation
05000244/FIN-2014007-0130 September 2014 23:59:59GinnaNRC identifiedInadequate Test Control for MSIV Solenoid Operated ValvesThe team identified a finding of very low safety significance involving a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control, in that Exelon did not assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service were identified and performed in accordance with written test procedures. Specifically, the team determined that the solenoid-operated valves that actuate the main steam isolation valves were not satisfactorily (independently) tested to demonstrate that the isolation valves would perform satisfactorily in service. In response, Exelon entered the issue into the corrective action program, evaluated current operability, and initiated efforts to develop satisfactory testing methods. The finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, the team determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding did not have a cross-cutting aspect because the most significant contributor of the performance deficiency was not reflective of current licensee performance.
05000244/FIN-2014004-0230 September 2014 23:59:59GinnaNRC identifiedAdequacy of Exelons Protective Action Recommendation StrategyThe inspectors identified an unresolved item (URI) during the inspection. The inspectors determined that additional NRC review and evaluation is required to determine whether Ginnas licensing basis relative to the Emergency Plan approval was adequate and met all NRC requirements and regulations. During the inspection, the inspectors reviewed Exelons protective action recommendation (PAR) procedure and strategy and determined that Exelon did not provide PARs for the entire plume exposure pathway emergency planning zone (EPZ). Specifically, Exelon did not provide PARs for the area over Lake Ontario at Ginna. The inspectors determined that Exelons PAR procedure and process at Ginna may not be consistent with the intent of the regulations. 10 CFR 50.47(b)(10) states, in part, that a range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. Appendix E to Part 50 states, in part, that generally, the plume exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles in radius. NUREG-0654/FEMA-REP-1, Supplement 3, Guidance for Protective Action Strategies, Revision 1, provides an expectation that licensees are to provide a PAR with the General Emergency notification. The offsite response organizations responsible for implementing protective actions use the licensees PARs to inform their decision making. Ginna Station Nuclear Emergency Response Plan (NERP), Revision 0, dated August 9, 1984, included a map of the 10-mile plume exposure pathway, identified as Figure F-3, which illustrated emergency response planning areas (ERPAs) in the 10-mile EPZ land area surrounding Ginna. Additionally, Section 1.0 of the NERP states that Exelon will recommend to Federal, State, and local authorities specific protective actions to limit the danger to the public, including evacuation. The inspectors compared the latest revision of the NERP, Revision 03801, dated July 11, 2014, to Revision 0 and determined that no ERPAs have existed over Lake Ontario. Figure 5.3, Scheme for Protective Action Recommendations, of the NERP provides shelter-in-place and evacuation PARs based on ERPAs, but does not include PARs for the potential transient population, such as boaters on Lake Ontario. Exelon provided documentation showing that Wayne Countys Radiological EP Plan provides for evacuation of Lake Ontario at an Alert emergency classification level. In response to the inspectors concern, Exelon entered the issue into the CAP as CR- 2014-004538 for further evaluation. The inspectors will coordinate with NRCs Office of Nuclear Security and Incident Response to review the adequacy of Exelons approved Emergency Plan to determine if this issue constitutes a violation and to ensure Exelon is meeting all NRC regulations and requirements. Pending resolution and determination of any potential enforcement actions, this issue is a URI.
05000244/FIN-2014004-0130 September 2014 23:59:59GinnaSelf-revealingInadequate Work Packages Associated with Maintenance on the Main Generator Exciter Air Cooler Reversing HeadA self-revealing Green finding (FIN) was identified for inadequate development and maintenance of work packages as required by Exelon Generation Company, LLC (Exelon) procedure CNG-MN-4.01-1003, Work Order Planning, Revision 00701. Specifically, the work packages associated with maintenance on the main generator exciter air cooler reversing head did not adequately incorporate and comply with vendor recommendations, which resulted in a service water (SW) leak on the reversing chamber of the generator exciter air cooler, a rapid downpower, and shutdown of the reactor. This finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the work packages associated with maintenance on the main generator exciter air cooler reversing head did not adequately incorporate and comply with vendor specifications, which resulted in a SW leak on the reversing chamber of the generator exciter air cooler, a rapid downpower, and shutdown of the reactor. Additionally, the finding is similar to Example 4.b of IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, in that a performance deficiency caused a transient. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green), because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Identification, because Exelon did not implement a corrective action program with a low threshold for identifying issues, and individuals did not identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, Exelon staff did not initiate condition reports and document reversing head material deficiencies identified by Exelons vendor and recommended for repair in 2009, 2012, and 2014 (P.1).
05000244/FIN-2014405-0130 September 2014 23:59:59GinnaNRC identifiedSecurity
05000244/FIN-2014003-0230 June 2014 23:59:59GinnaLicensee-identifiedLicensee-Identified ViolationTS 3.8.3, Diesel Fuel Oil, requires that EDGs and required support systems to be operable. TS 3.8.3 LCO condition B, one or more required EDGs with stored fuel oil total particulates not within limit, requires that the fuel oil total particulates be returned within limit within 7 days. TS 5.5.12, Diesel Fuel Oil Testing Program, established acceptance criteria for meeting the requirements of LCO 3.8.3 condition B. Contrary to the above, from January 7 until January 23, 2014, diesel fuel oil sample results were above the limit for particulates established by TS 5.5.12 thus rendering the B EDG inoperable for greater than its allowed outage time. Exelon entered the issue into their CAP as CR-2014-000303, conducted an apparent cause evaluation, and properly reported the issue to the NRC as LER 05000244/2014-001- 00, Total Particulate Concentration in B Emergency Diesel Generator Fuel Oil Storage Tank Exceeded Acceptance Criteria Cause Attributed to Contamination from Using a Temporary Fuel Oil Storage Tank. The inspectors determined the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating System Screening Questions, issued June 19, 2012, since the finding did not represent a loss of system and/or function.
05000244/FIN-2014403-0130 June 2014 23:59:59GinnaNRC identifiedSecurity
05000244/FIN-2014403-0230 June 2014 23:59:59GinnaNRC identifiedSecurity
05000244/FIN-2014403-0330 June 2014 23:59:59GinnaNRC identifiedSecurity
05000244/FIN-2014003-0130 June 2014 23:59:59GinnaSelf-revealingInadequate Procedure Implementation Results inA self-revealing Green NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for failure to perform maintenance as required by Exelon Generation (Exelon) procedure STP-I-9.1.16, Undervoltage Protection 480 Volt Safeguard Bus 16, Revision 01001. Specifically, while performing step 6.4.2.1 to place the BX1/16 relay toggle switch in the trip position, an incorrect switch manipulation by an instrumentation and control (I&C) technician resulted in an engineered safety feature (ESF) actuation, which included the automatic start of the B emergency diesel generator (EDG) and the de-energization of a safety-related bus. Immediate corrective actions included restoring Bus 16 to its normal power supply and entering this issue into the corrective action program (CAP) as condition report (CR)-2014-002741. The finding was more than minor, because it is associated with the human performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, due to a personnel error, an incorrect switch was manipulated during Bus 16 undervoltage testing. This resulted in the automatic start of the B EDG, the de-energization of Bus 16, and the transition of the outage defensein- depth from a Green to a Yellow risk condition. The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, Initial Characterization of Findings. This attachment directed the inspectors to evaluate the finding using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process. However, IMC 0609, Appendix G, directed the inspectors to contact the senior risk analyst for assistance as it does not apply when there are no fuel assemblies in the reactor vessel. The senior risk analyst directed the inspectors to evaluate the finding using Appendix M, Significance Determination Process Using Qualitative Criteria, which directed the inspectors to consider a bounding case. For this instance, if the bus had not been recovered with the fuel in the spent fuel pool (SFP), the only significant system lost would have been the redundant SFP cooling system. Therefore, the inspectors determined the finding to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon personnel did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, Exelon personnel did not implement appropriate error reduction tools or consider the potential undesired consequence of an ESF actuation before performing work.
05000244/FIN-2014404-0131 March 2014 23:59:59GinnaNRC identifiedSecurity
05000244/FIN-2014002-0131 March 2014 23:59:59GinnaSelf-revealingFailure to Adequately Implement the Preventive Maintenance Program Procedure for a Service Water Pump MotorA self-revealing Green NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for failure to modify an existing preventive maintenance (PM) task or schedule in accordance with CENG procedure CNG-AM-1.01-1018, Preventive Maintenance Program, Revision 00801. Specifically, CENG did not revise the PM for the B service water pump (SWP) motor despite having rewound the stator windings on the four other SWP motors after identifying poor manufacturing quality in the stator winding end turns of each of the motors. This resulted in the B SWP motor failing while in service on December 10, 2013. CENGs immediate corrective actions included replacing the failed motor with a refurbished spare and entering the issue into the corrective action program (CAP). Failure to modify an existing PM task in accordance with the PM program procedure was a performance deficiency within CENGs ability to foresee and correct and should have been prevented. Specifically, CENG did not adequately implement changes to the PM 3-year overhaul task or establish a revised schedule for which the SWP motors should be rewound. This ultimately resulted in the failure of the B SWP motor. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, due to the failure of the B SWP motor, the SWP was not operable or available until the motor was replaced. The inspectors evaluated the finding using Attachment 0609.04, Initial Characterization of Findings, worksheet to IMC 0609, Significance Determination Process (SDP). The attachment instructs the inspectors to utilize IMC 0609, Appendix A, Significance Determination Process for Findings At-Power. The inspectors determined this finding was not a deficiency affecting the design or qualification of a mitigating structure, system, and component (SSC), did not represent a loss of system and/or function, and did not represent an actual loss of function of at least a single train. Therefore, the inspectors determined this finding to be of very low safety significance (Green). In accordance with IMC 0612, the finding does not have a cross-cutting aspect, because the performance deficiency occurred between 2005 and 2008, would not likely occur today under similar circumstances, and is not reflective of present plant performance.
05000244/FIN-2014404-0231 March 2014 23:59:59GinnaLicensee-identifiedLicensee-Identified Violation
05000244/FIN-2014002-0231 March 2014 23:59:59GinnaNRC identifiedFailure to Ensure the Design Basis Analysis for the Emergency Diesel Generators Accounted for Limiting Cold Weather Conditions and LoadingThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion III, Design Control, because CENG did not ensure that the requirements and the design basis as specified in the Updated Final Safety Analysis Report (UFSAR) and Ginna TS bases were correctly translated into specifications, drawings, procedures, and instructions. Specifically, CENG failed to ensure the design basis analysis for the emergency diesel generators (EDGs) accounted for worst case EDG loading and EDG room heat loads during cold weather conditions, which resulted in a condition where there was a reasonable doubt of the operability of the EDGs. CENGs immediate corrective actions included entering the issue into its CAP, conducting an operability determination, and implementing compensatory measures via Engineering Change Package (ECP) 13-001076. The inspectors determined that CENGs failure to provide for verifying or checking the adequacy of design, such as by the performance of design reviews and calculations in accordance with 10 CFR 50, Appendix B, Criterion III, to ensure that EDG room temperatures would not challenge EDG operability, was a performance deficiency that was within CENGs ability to foresee and correct and should have been prevented. This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, following a design basis event during design basis extreme weather conditions, the EDG room temperatures could reach sub-freezing conditions that had not been previously analyzed. This condition could have impacted EDG availability, reliability, and capability if EDG fuel oil temperatures reached their cloud point, if jacket water pressure instrumentation sensing lines froze and resulted in a low jacket water pressure condition, and as other lines like service water (SW) pressure instruments for the jacket water and lube oil cooler froze or approached freezing. Additionally, the finding is similar to Example 3.j. of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, in that the EDG design basis analysis failed to consider worst case conditions, which resulted in a reasonable doubt on the operability of the EDGs that necessitated the implementation of compensatory actions via an ECP, extensive data gathering, modification of and evaluation utilizing the GOTHIC computer model, planned permanent modifications, and a past operability determination addressing two lines that could potentially freeze. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green), because the performance deficiency was a deficiency affecting the design of a mitigating SSC, and the SSC maintained its operability. In accordance with IMC 0612, the finding does not have a cross-cutting aspect, because the performance deficiency likely occurred during original plant design, would not likely occur today under similar circumstances, and is not reflective of present plant performance.
05000244/FIN-2014008-0131 March 2014 23:59:59GinnaNRC identifiedFailure to Effectively Implement Corrective Actions Associated with Heater Drain Tank Pump Tripping IssuesThe inspectors identified a Green finding (FIN) for CENGs 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 CENGs 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 crosscutting 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.
05000244/FIN-2014002-0331 March 2014 23:59:59GinnaNRC identifiedFailure or Emergency Preparedness Drill Critique to Identify a Risk-Significant Planning Standard WeaknessThe inspectors identified a Green NCV of 10 CFR 50.47(b)(14) and 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, Section IV.F.2.g. Specifically, CENG did not identify and critique a weakness related to a risk-significant planning standard during their critique following the March 11, 2014, emergency preparedness drill. CENGs immediate corrective actions included entering the issues associated with the drill critique into its CAP. The inspectors determined that CENGs failure to identify and critique an emergency preparedness drill performance weakness in the formal critique was a performance deficiency that was within CENGs ability to foresee and correct and should have been prevented. Specifically, CENG did not identify that operators failed to notice the loss of annunciator panels for approximately 7 minutes, contrary to the planned scenario summary and timeline, and that it took a computer alarm, not associated with the loss of annunciator panels, to alert the operators to the loss of the annunciator panels. The inspectors determined that the failure to identify the drill performance weakness was more than minor, because it was associated with the emergency response organization performance attribute of the Emergency Preparedness cornerstone and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, CENGs failure to effectively identify an emergency preparedness drill performance weakness caused a missed opportunity to identify and correct a drill-related performance deficiency. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings. The attachment instructs the inspectors to utilize IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, when the finding is in the licensees Emergency Preparedness cornerstone. The inspectors determined this finding was a critique finding, the drill scope was full scale, the planning standard was a risk-significant planning standard, and the performance opportunity status was a success. Therefore, the inspectors determined the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because CENG personnel did not use decision-making practices that emphasize prudent choices over those that are simply allowable. Specifically, CENG personnel did not exhibit conservative bias in their choice to consider the operators identification of the lost annunciator panels timely.
05000244/FIN-2014002-0431 March 2014 23:59:59GinnaSelf-revealingFailure to Adhere to Procedural Requirements for Authorizing the Application of a TagoutA self-revealing Green finding (FIN) was identified because Constellation Energy Nuclear Group, LLC (CENG) failed to authorize the application of a tagout in accordance with procedure CNG-OP-1.01-1007, Clearance and Safety Tagging, Revision 01101. Specifically, CENG did not adequately implement equipment tagging procedural requirements to verify plant effects and tagout boundary impact prior to removing the specified equipment from service. As a result, two air operated valves (AOVs) unexpectedly opened when a tagout was being hung and resulted in a trip of all running condensate booster pumps on low suction pressure and a plant transient. The inspectors determined that the failure to follow procedural requirements was more than minor because it was associated with the configuration control attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, CENG did not follow procedural guidance when reviewing the tagout to ensure that the consequences of removing the specified equipment from service had been evaluated from the perspective of plant effects and tagout boundary impacts. This resulted in a plant transient as operators rapidly reduced plant power in order to avoid a more significant plant transient. Additionally, the finding is similar to IMC 0612, Appendix E, Examples of Minor Issues, Example 4.b., in that a personnel error caused a plant transient. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, worksheet to IMC 0609, Significance Determination Process. The attachment instructed the inspectors to utilize IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The inspectors determined the performance deficiency to be of very low safety significance (Green), because it did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because CENG individuals did not recognize and plan for the possibility of mistakes, even while expecting successful outcomes.
05000244/FIN-2013005-0231 December 2013 23:59:59GinnaNRC identifiedProgrammatic Failure to Scope SSCs within the Maintenance Rule Monitoring ProgramThe inspectors identified an NCV of 10 CFR 50.65(b), because CENG staff did not include safety-related and non-safety-related structures, systems, and components (SSCs) within the scope of the maintenance rule monitoring program. Specifically, CENG staff failed to appropriately include an estimated 90 safety-related and non-safety-related SSCs within the scope of the maintenance rule monitoring program, which could have resulted in a failure to detect SSC degradation and to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions. Immediate corrective actions included placing these issues into the CAP as CR-2013-002083, CR-2013-004444, CR-2013-004993, CR- 2013-006139, CR-2013-006628, and CR-2013-006674. The finding is more than minor because if left uncorrected, the finding could become a more significant safety concern. Specifically, the failure to monitor SSC performance and condition could have resulted in a failure to detect SSC degradation and to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions. The failure to adequately scope an estimated 90 or more components could have resulted in the failure to detect degradation within multiple systems and to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions. Additionally, this issue is similar to Example 3j described in IMC 0612, Appendix E, Examples of Minor Issues, which states that issues are not minor if significant programmatic deficiencies were identified with the issue that could lead to worse errors if uncorrected. The inspectors evaluated the finding using IMC 0612, Attachment 0609.04, Initial Characterization of Findings. The attachment instructs inspectors to utilize IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, the inspectors determined that the finding did not represent an actual loss of function of one or more non-technical specification trains of equipment. Therefore, the inspectors determined the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because CENG personnel did not thoroughly evaluate problems such that the resolutions addressed causes and extent of conditions. Specifically, CENG had multiple opportunities following the inspectors identification of maintenance rule scoping issues on March 27, 2013, and prior to November 7, 2013, to thoroughly evaluate recent maintenance rule scoping problems such that the resolutions addressed causes and extent of conditions (P.1(c)).
05000244/FIN-2013005-0331 December 2013 23:59:59GinnaSelf-revealingFailure to Modify or Establish a PM for the TDAFW DC Lube Oil Pump SwitchA self-revealing finding was identified for failure to modify or establish a preventive maintenance (PM) schedule for the turbine-driven auxiliary feedwater (TDAFW) direct current (DC) lube oil pump control switch. On November 18, 2013, plant personnel found the main control room switch for the TDAFW DC lube oil pump failed due to switch contact oxidation. This resulted in the DC oil pump failing to automatically start when demanded during a surveillance test and the continued inoperability of the TDAFW pump. As immediate corrective actions for the November 18, 2013, TDAFW DC lube oil switch failure, CENG staff initiated CR-2013-006727, replaced the switch, verified continuity of the other two switches that were not modified in 1980, and established a compensatory action to verify continuity of the other two switches following manipulation of the switch until they are replaced. Additionally, an appropriate PM will be established for the three switches unless they are modified such that the main control board green light indicates continuity of the circuit. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, due to the failure of the main control board switch for the TDAFW DC lube oil pump, the pump failed to start during testing resulting in the continued inoperability of the TDAFW pump. The inspectors evaluated the finding using Attachment 0609.4, Initial Characterization of Findings, worksheet to IMC 0609, Significance Determination Process. The attachment instructs the inspectors to utilize IMC 0609, Appendix A, Significance Determination Process for Findings At-Power. The inspectors determined this finding was not a deficiency affecting the design or qualification of a mitigating SSC, did not represent a loss of system and/or function, and did not represent an actual loss of function of at least a single train. Therefore, the inspectors determined this finding to be of very low safety significance (Green). In accordance with IMC 0612, the finding does not have a cross-cutting aspect because the performance deficiency occurred in 1980 and is not reflective of present plant performance.
05000244/FIN-2013005-0131 December 2013 23:59:59GinnaNRC identifiedFailure to Identify and Correct Non-Hydrostatically Sealed Penetrations into Battery Room ?BThe inspectors identified a finding associated with an apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, for Constellation Energy Nuclear Group, LLC (CENG) staffs failure to assure that conditions adverse to quality were promptly identified and corrected. Specifically, CENG failed to identify the need to hydrostatically seal two cable penetrations between manhole 1 and battery room B after the sites design basis flood height was changed during the NRC Systematic Evaluation Program (SEP) in 1983; promptly correct the significant adverse condition in May 2013 when the condition was identified and take timely action in early September 2013 when CENG was presented with evidence challenging its May 2013 evaluation related to manhole 1 and the improperly sealed penetrations. As a result, various Deer Creek flooding scenarios could have resulted in flooding of both battery rooms. Immediate corrective actions included placing this issue in the corrective action program (CAP) as condition report (CR)-2013-003407, CR-2013- 005262, and CR-2013-005643; and hydrostatically sealing the penetrations on October 4, 2013. This finding is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, propagating flood water could damage mitigating equipment needed to prevent core damage with a flood below the design basis level of 273.8 feet because of the unsealed penetrations in manhole 1. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process For Findings At-Power, the inspectors utilized Section B, External Event Mitigation Systems (Seismic/Fire/Flood/Severe Weather Protection Degraded), of Appendix A and determined the finding involved the loss or degradation of equipment or function specifically designed to mitigate a flooding initiating event, which requires the inspector to go to Exhibit 4, External Events Screening Questions. The inspectors determined that a detailed risk evaluation (DRE) was needed because the loss of equipment and function would degrade two or more trains of a multi-train system or function, and the loss of equipment and function would degrade one or more trains of a system that supports a risk-significant system or function. The staff determined that, currently, there is not an existing SDP risk tool that is suitable to assess the significance of this finding with high confidence, mainly because of the uncertainties associated with extreme flood frequency extrapolations based on limited available historical data. Therefore, the risk evaluation was performed using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The change in core damage frequency (CDF) estimates ranged from Green, a finding of very low safety significance, to Yellow, a finding of substantial safety significance. A significance and enforcement review panel (SERP) held on January 28, 2014, made a preliminary determination that the finding was of low to moderate safety significance (White) based on quantitative and qualitative evaluations. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because CENG personnel did not thoroughly evaluate problems such that the resolutions addressed causes. Such evaluations should include properly classifying, prioritizing, and evaluating operability and reportability of conditions adverse to quality. Specifically, CENG personnel had an opportunity to thoroughly evaluate and assess impacts to the plant such that resolutions addressed causes, when two unsealed penetrations into battery room B were identified in May 2013; CENGs evaluation associated with CR-2013-003407 was not thorough and did not consider all flow paths for flooding through manhole 1. Additionally, the condition adverse to quality was not properly evaluated for operability. CENG personnel had an additional opportunity to thoroughly evaluate and assess impacts to the plant such that resolutions addressed causes and properly evaluate for operability when inspectors presented evidence of degraded manhole 1 conditions, e.g., clogged manhole drains, to CENG management on September 5, 2013 (P.1(c)).
05000244/FIN-2013404-0130 September 2013 23:59:59GinnaLicensee-identifiedLicensee-Identified Violation
05000244/FIN-2013004-0430 September 2013 23:59:59GinnaLicensee-identifiedLicensee-Identified ViolationGinna Operating License Condition 2.C.(3), Fire Protection, requires Ginna to implement and maintain in effect all fire protection features described in the licensees submittals referenced in and as approved or modified by the NRCs Fire Protection Safety Evaluation supplement dated December 17, 1980. The Fire Protection Safety Evaluation supplement contained a requirement for a backflow prevention check valve in the intermediate building basement. Contrary to License Condition 2.C.(3), on April 12, 2013, CENG personnel identified that the check valve, a required fire protection feature, had been removed. CENG personnel entered the issue into its CAP as CR-2013-002437. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix F, Fire Protection Significance Determination Process, issued February 28, 2005. The finding is considered to be in the fire confinement area and was assigned a moderate degradation rating. Per IMC 0609, Appendix F, Task 1.3.2, Supplemental Screening for Fire Confinement Findings, this finding screens to Green because there was a non-degraded, automatic, full- area, water-based fire suppression system in the exposing fire area.
05000244/FIN-2013007-0230 September 2013 23:59:59GinnaNRC identifiedAdequacy of Ginnas Licensing and Design Bases for Offsite Power Calculations and Degraded Voltage Relay Time DelaysRIS 2011-12 guidance indicated that the licensees voltage calculations should provide the basis for proper operation of the plant safety-related (SR) electrical distribution system, when supplied from the offsite circuits via the transmission network. These calculations should demonstrate that the voltage requirements (both starting and running voltages) of all plant SR systems and components are satisfied based on operation of the transmission system (including the bounding transmission system single contingency in terms of voltage drop). In addition, during accident conditions, the nuclear unit generator trip and associated transmission system voltage drop should be factored into the accident case voltage calculations since unit trip occurs as a result of the accident. Licensee calculations should also demonstrate that all SR systems and components will function as designed with proper starting and running voltages during all plant conditions and the DVRs will not actuate (separating the transmission network supply). The team noted that Constellation had not performed calculations to demonstrate that the offsite electric power system had sufficient capacity and capability to assure the voltage requirements for all SR systems and components initiated during the onset of a design basis accident were met. Specifically, Constellation assumed that following the accident signal and resulting turbine trip, that the main generator breaker stays connected as a synchronous condenser providing voltage support for an additional 60 seconds after the reactor trip. After this time delay, relays then open the breaker in the 115 kilovolt (kV) switchyard which results in a 115kV transmission system voltage drop to 108.9kV. This voltage level becomes the source of power to the 480V safety-related buses after the unit generator breaker opens. At this time, however, all of the accident initiated SR loads have already started and sequenced onto the buses as running loads. The team noted that due to the voltage drop at 60 seconds, the SR buses drop to approximately 382V or 79 percent of rated voltage, which is below the degraded voltage relay setting of 420V. Constellation credits operation of the #7 transformer and/or #6 transformer/767 regulator automatic LTC to restore the bus voltages to above the DVR reset within the design time delay of a nominal 68-125 seconds. The team determined that Constellation had not performed dynamic motor starting calculations to evaluate the terminal voltages to SR equipment while connected to the onsite main generator or offsite power during accident initiated load sequencing to ensure and demonstrate that the voltage requirements of all plant SR systems and components are satisfied. These calculations had not been performed, in part, because Constellation credits a dynamic emergency diesel generator (EDG) voltage analysis as bounding the voltage drops that would occur if on the main generator or offsite power. As a result, there are no calculations that show the voltage profile of the 480V SR buses, the terminal voltage of SR motors during motor starting and sequencing, or whether the DVR setpoints are exceeded or reset during the load sequencing event. The team determined that based on the assumption of reliance on the generator to boost voltage, the effect of the EDG being a bounding calculation may be technically accurate. However, the design assumption of the generator providing this voltage boost may be inconsistent with the RIS 2011-12 guidance for what is assumed in showing that offsite power, independently can provide the source of power to ensure engineered safety feature (ESF) loads have the proper voltage supply during sequencing. Degraded Voltage Relay Scheme Constellation uses an inverse-time delay (TD) ITE 27 undervoltage relay for the degraded voltage relays. The time delay as specified in TS SR 3.3.4.2 is 68-125 seconds at 420V. The team noted that the DVR time delay exceeds the TD for Ginna assumed in the UFSAR accident analyses, which is a nominal 10 seconds and is the time required for the EDGs to start and be ready to accept load. The team also determined that Constellation had not performed an analysis to verify that all SR equipment would not become unavailable due to protective device actuation for a degraded voltage within the bandwidth of the DVR and loss-of-voltage (LOV) setpoints for the existing time delay prior to re-sequencing onto the EDGs. The team reviewed the March 26, 1981, Amendment 38 to the operating license No. DPR-18, which docketed that the original TD setting of 8.5 seconds to above 1000 seconds, ensured that all Class 1E motors will start successfully and be loaded onto the EDG within the time assumed in the FSAR accident analysis. The team could not determine what the basis for this conclusion was because the TD approved was an inverse time characteristic which appeared to have a range outside of existing accident analyses assumptions for the timing of core re-flood during the limiting design basis accident. In response to the teams concerns, Constellation entered the issue into their corrective action program as CR-2013-004767 for further review recognizing that while the TD is consistent with their approved licensing bases, it is not consistent with current NRC guidance. The team will coordinate with the NRCs Office of Nuclear Reactor Regulation to review the adequacy of Constellations approved licensing and design bases to evaluate whether this issue constitutes a violation and to ensure Constellation is meeting all NRC regulations and requirements. Pending resolution of this issue and determination of any potential enforcement actions, this item is an Unresolved Item.
05000244/FIN-2013004-0130 September 2013 23:59:59GinnaNRC identifiedDesign Basis External Flooding and Unsealed Penetrations in the ?B? Battery RoomOn May 29, 2013, the east and west chambers of manhole 1 were opened to complete Fukushima flooding walkdown inspections of two penetrations. The east and west chambers of manhole 1 are located in the transformer yard on the east side of the plant directly adjacent to the control building. One penetration was between the east chamber of manhole 1 and the B battery room, and the other penetration was between the west chamber of manhole 1 and the B battery room. During this inspection, which focused only on the penetrations, the inspectors and CENG personnel identified that the penetrations appeared to be unsealed and only contained ceramic fiber insulation. By May 31, CENG personnel determined that each chamber of manhole 1 also contained a drain. Condition report (CR)-2013-003407 documented these conditions and documented an assessment that assumed flow into the manhole chambers via the edges around and holes in the manhole covers. This assessment assumed 50.3 gallons per minute (gpm) of flow into each chamber of manhole 1 based on a flood height of 1.73 feet above the outside of the manhole. The assessment assumed that each drain was capable of passing 95 gpm of water. The CR noted that a walkdown of the floor drains was required to verify that the floor drains were as designed and capable of passing the calculation assumed flow rate. The inspectors questioned the preventive maintenance frequency and previous testing of the drains and no licensee records could be located that indicated that the drains had ever been tested or cleaned. The inspectors were subsequently informed that the manhole drain inspections were not planned until October 2. The inspectors noted that Ginna had no definitive plans to seal the penetrations between manhole 1 and the B battery roomonly a potential enhancement action with a due date of December 1, 2014. Because the drains had never been inspected or tested, the inspectors expressed concerns to CENG personnel about the drains being clear and able to pass the assumed flows. On September 5, CENG electricians were performing periodic manhole inspections these inspections check for water in manhole chambers and pump it out, if necessary. The inspectors accompanied the electricians on this inspection. The inspectors captured photographs of substantial debris in both chambers of manhole 1 and both manhole 1 drains. In one chamber, a large sheet of plastic laid on the chamber floor among a layer of mud, rocks, and other debris. Other debris in one or both chambers of the manhole included large and small pieces of wood, 3-inch diameter pieces of foam, tie wraps, large nails and bolts, varying sizes of rocks and stones, rope, large pieces of hard plastic, wire, sticks, and tools. The photographs also documented likely water staining of the cinder block walls in both manhole chambers and significant debris was clearly visible in both drains. These photographs were shared with CENG management on September 5. CR-2013-005262 documented the debris in manhole 1, but stated that the condition could not affect operability of a structure, system, and component (SSC) and that the drain line would pass anticipated flow. The inspectors questioned this assessment and again expressed concern that the drains would not be capable of passing the necessary flow. Ginna took no additional immediate actions. On September 17, CENG personnel were reviewing the photographs that the NRC inspectors provided on September 5 and determined that the manhole drains were missing their covers. At this point, the issue was elevated to a priority two work order (WO). Compensatory measures were also established to check the 5-day weather forecast and maintain plastic covers and sandbags over the manhole covers. Plans to test the drains and clean the manhole chambers were also expedited. Finally, a modification package was created to permanently seal the penetrations between manhole 1 and the B battery room. On September 20, CENG tested the manhole 1 drains to determine the flow rate the drains were capable of passing; neither drain was able to pass the amount of water needed to prevent water accumulation during testing. CR-2013-005643 documented that the drains failed to demonstrate the ability to pass the required flow and noted that the penetrations between manhole 1 and the B battery room would be challenged. CENG management concluded that an unanalyzed condition existed due to unqualified battery room penetrations and partially blocked manhole chamber drains. On September 30, CENG completed modification engineering change package (ECP) 13-000854, Battery Room to Manhole 1 Penetrations Flood Barrier, Revision 0000, which installed permanent seals in both penetrations between manhole 1 and the B battery room; thereby, the flooding concern was addressed. Section 2.4.2.1, Flood Design Considerations, of Ginnas UFSAR states that the plant is protected from a Deer Creek flood at an elevation of 273.8 feet, which is equivalent to a Deer Creek flood of 26,000 cubic feet per second. Section 3.4.1.1.3, Deer Creek Flood Protection, states that a Deer Creek discharge of 26,000 cubic feet per second corresponds to an elevation of 272.0 feet on the north and east side of the plant. This is a flood height of approximately 2 feet in the transformer yard, where manhole 1 is located, because the general plant grade is approximately 270 feet. At the end of the inspection period, CENG personnel were completing an apparent cause evaluation (ACE) focusing on the unqualified penetrations in the B battery room, the clogged manhole 1 drains, and previous opportunities to identify and correct these conditions. CENG personnel were also conducting some additional flooding analyses to determine what, if any, safety-related equipment in the A and B battery rooms would be challenged by a design basis flood via the unqualified penetrations and what, if any, consequences would result. This issue will be opened as a URI in order to review and evaluate CENG new flooding analyses, ACE, and other supporting documentation to determine if a violation exists with respect to the issue of concern of not adequately assessing plant conditions or taking appropriate actions to ensure equipment in the A or B battery room would not be challenged by a design basis flood.