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| number = ML16337A092
| number = ML16337A092
| issue date = 12/02/2016
| issue date = 12/02/2016
| title = R.E. Ginna Nuclear Power Plant, LLC - Temporary Instruction 2515/191 Inspection Report 05000244/2016011
| title = LLC - Temporary Instruction 2515/191 Inspection Report 05000244/2016011
| author name = Dimitriadis A
| author name = Dimitriadis A
| author affiliation = NRC/RGN-I/DRP/PB1
| author affiliation = NRC/RGN-I/DRP/PB1
| addressee name = Hanson B C
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC
| addressee affiliation = Exelon Generation Co, LLC
| docket = 05000244
| docket = 05000244
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD. KING OF PRUSSIA, PA 19406-2713 December 2, 2016  
{{#Wiki_filter:December 2, 2016


Mr. Bryan Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road
==SUBJECT:==
 
R.E. GINNA NUCLEAR POWER PLANT, LLC - TEMPORARY INSTRUCTION 2515/191 INSPECTION REPORT 05000244/2016011
Warrenville, IL 60555
 
SUBJECT: R.E. GINNA NUCLEAR POWER PLANT, LLC - TEMPORARY INSTRUCTION 2515/191 INSPECTION REPORT 05000244/2016011


==Dear Mr. Hanson:==
==Dear Mr. Hanson:==
On November 10, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the R.E. Ginna Nuclear Power Plant, LLC (Ginna). On November 10, 2016, the NRC inspectors discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
On November 10, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the R.E. Ginna Nuclear Power Plant, LLC (Ginna). On November 10, 2016, the NRC inspectors discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.


The inspection examined activities conducted un der your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commission's rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with plant personnel.
The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with plant personnel.


The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.


Sincerely,
Sincerely,
/RA/ Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects  
/RA/  
 
Anthony Dimitriadis, Chief  
 
Reactor Projects Branch 1  
 
Division of Reactor Projects  
 
Docket No.
 
50-244 License No.
 
DPR-18
 
===Enclosure:===
Inspection Report 05000244/2016011 w/Attachment: Supplementary Information
 
REGION I==
Docket No.
 
50-244
 
License No.


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


Enclosure: Inspection Report 05000244/2016011 w/Attachment: Supplementary Information
Report No.


cc w/encl: Distribution via ListServ
05000244/2016011


ML16337A092 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRS RI/DRP RI/DRP NAME CCahill ADimitriadis MFerdas/CL for DATE 11/22/16 12/2/16 11/30/16
Licensee:


1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket No. 50-244
Exelon Generation Company, LLC (Exelon)


License No. DPR-18 Report No. 05000244/2016011
Facility:


Licensee: Exelon Generation Company, LLC (Exelon)  
R.E. Ginna Nuclear Power Plant, LLC (Ginna)  


Facility: R.E. Ginna Nuclear Power Plant, LLC (Ginna)
Location:  


Location: Ontario, New York  
Ontario, New York  


Dates: November 7-10, 2016
Dates:  


Inspectors: C. Cahill, PE, Senior Reactor Analyst, Division of Reactor Safety (DRS)
November 7-10, 2016
F. Arner, Senior Reactor Analyst, DRS J. Petch, Resident Inspector (Ginna)


Approved by: Anthony Dimitriadis, Chief Reactor Projects Branch 1
Inspectors:  


Division of Reactor Projects
C. Cahill, PE, Senior Reactor Analyst, Division of Reactor Safety (DRS)
F. Arner, Senior Reactor Analyst, DRS J. Petch, Resident Inspector (Ginna)


2
Approved by:
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects


=SUMMARY=
=SUMMARY=
Inspection Report 05000244/2016011; 11/7/2016 - 11/10/2016; R.E. Ginna Nuclear Power Plant, LLC (Ginna); Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency
Inspection Report 05000244/2016011; 11/7/2016 - 11/10/2016; R.E. Ginna Nuclear Power  
 
Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.


The inspection covered a one week inspection by two senior reactor analysts, and the resident inspector. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6.
Plant, LLC (Ginna); Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.


3
The inspection covered a one week inspection by two senior reactor analysts, and the resident inspector. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 6.


=REPORT DETAILS=
=REPORT DETAILS=
Line 78: Line 97:
==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
{{a|4OA5}}
{{a|4OA5}}
==4OA5 Other Activities==
==4OA5 Other Activities==
TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans


TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans The objective of TI 2515/191, "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans," is to verify:
The objective of TI 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify:
: (1) that licensees have adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16006A050)and the NRC's plant safety evaluation (ADAMS Accession No. ML16124A038);
: (1) that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16006A050) and the NRCs plant safety evaluation (ADAMS Accession No. ML16124A038);
: (2) that the licensees installed reliable water-level measurement instrumentation in their spent fuel pools (SFPs); and
: (2) that the licensees installed reliable water-level measurement instrumentation in their spent fuel pools (SFPs); and
: (3) that licensees have implemented emergency preparedness enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability, enhancements to ensure that staffing is sufficient, and that communications can be maintained during beyond-design-basis external events.
: (3) that licensees have implemented emergency preparedness enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability, enhancements to ensure that staffing is sufficient, and that communications can be maintained during beyond-design-basis external events.


The team verified that plans for complying with NRC Orders EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events," (ADAMS Accession No. ML12054A735) and EA-12-051, "Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation," (ADAMS Accession No. ML12056A044) were in place and were being implemented by Exelon. The team also verified that Exelon had implemented staffing and communications plans provided in response to the March 12, 2012, request for information letter and multi-unit dose assessment information provided per COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013 (ADAMS Accession No.
The team verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events, (ADAMS Accession No. ML12054A735) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12056A044) were in place and were being implemented by Exelon. The team also verified that Exelon had implemented staffing and communications plans provided in response to the March 12, 2012, request for information letter and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No.


ML12339A262).
ML12339A262).


The team discussed the plans and strategies with Exelon personnel, reviewed documentation, completed a tabletop exercise involving a beyond design basis event leading to an extended loss of offsite power and, where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in Exelon's submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections. Documents reviewed for each section of this report are listed in the Attachment.
The team discussed the plans and strategies with Exelon personnel, reviewed documentation, completed a tabletop exercise involving a beyond design basis event leading to an extended loss of offsite power and, where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in Exelons submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections. Documents reviewed for each section of this report are listed in the Attachment.


===1. Mitigation Strategies for Beyond-Design Basis External Events===
===1. Mitigation Strategies for Beyond-Design Basis External Events===
====a. Inspection Scope====
====a. Inspection Scope====
The team examined Exelon's established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the Exelon staff coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.
The team examined Exelons established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the Exelon staff coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.
 
The team verified that a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and that periodic


equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Ginna staff most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.
The team verified that a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Ginna staff most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.


b. Assessment Based on samples selected for review, the inspectors verified that Exelon satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation (ADAMS Accession No.
b. Assessment  


ML16124A038) and determined that Exelon was in compliance with NRC Order
Based on samples selected for review, the inspectors verified that Exelon satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation (ADAMS Accession No.


EA-12-049.
ML16124A038) and determined that Exelon was in compliance with NRC Order EA-12-049.


The team verified that Exelon satisfactorily:
The team verified that Exelon satisfactorily:
Line 114: Line 132:
* Developed procedures to ensure that the necessary off-site FLEX equipment will be available from off-site locations.
* Developed procedures to ensure that the necessary off-site FLEX equipment will be available from off-site locations.


The team verified that inspector observations identified during the inspection were entered into Exelon's corrective action program, where appropriate.
The team verified that inspector observations identified during the inspection were entered into Exelons corrective action program, where appropriate.


====c. Findings====
====c. Findings====
Line 120: Line 138:


===2. Spent Fuel Pool Instrumentation===
===2. Spent Fuel Pool Instrumentation===
====a. Inspection Scope====
The team examined Exelons newly installed SFP instrumentation. Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation, and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. In addition, the team verified that Exelon had evaluated environmental conditions and accessibility of the instrumentation.


====a. Inspection Scope====
The team verified that Exelon had approved procedures for maintenance, testing, calibration, and use of the primary and backup SFP instrumentation channels. The team also verified that the procedures followed the industry guidance contained in Nuclear Energy Institute 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, and that these procedures were part of an existing Exelon process to be maintained.
The team examined Exelon's newly installed SF P instrumentation. Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation, and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. In addition, the team verified that Exelon had evaluated environmental conditions and accessibility of the instrumentation.


The team verified that Exelon had approved procedures for maintenance, testing, calibration, and use of the primary and backup SFP instrumentation channels. The team also verified that the procedures followed the industry guidance contained in Nuclear Energy Institute 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," and that these procedures were part of an existing Exelon process to be maintained.
b. Assessment


b. Assessment Based on samples selected for review, the team determined that Exelon satisfactorily installed and established appropriate operating and maintenance controls for the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation. The team determined that Exelon was in compliance with NRC Order EA-
Based on samples selected for review, the team determined that Exelon satisfactorily installed and established appropriate operating and maintenance controls for the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation. The team determined that Exelon was in compliance with NRC Order EA-12-051.


12-051. The team verified that Exelon satisfactorily:
The team verified that Exelon satisfactorily:
* Installed the SFP instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittal(s) and safety evaluation;
* Installed the SFP instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittal(s) and safety evaluation;
* Installed the SFP instrumentation display in the accessible location, and environmental conditions as described in the plant specific submittal(s);
* Installed the SFP instrumentation display in the accessible location, and environmental conditions as described in the plant specific submittal(s);
Line 134: Line 153:
* Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation.
* Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation.


The team verified that issues identified during the inspection were entered into Exelon's corrective action program.
The team verified that issues identified during the inspection were entered into Exelons corrective action program.


====c. Findings====
====c. Findings====
Line 140: Line 159:


===3. Staffing and Communication Request for Information===
===3. Staffing and Communication Request for Information===
====a. Inspection Scope====
Through discussions with plant staff, review of documentation, and plant walk downs, the team verified that Exelon had implemented required changes to staffing, communications equipment, and facilities to support an extended loss of all AC power (ELAP) scenario as described in Exelons staffing assessment and the NRC safety evaluation. The team also verified that Exelon had implemented dose assessment (including releases from SFPs) capability using site-specific dose assessment software, as described in Exelons dose assessment submittal.


====a. Inspection Scope====
b. Assessment
Through discussions with plant staff, review of documentation, and plant walk downs, the team verified that Exelon had implemented required changes to staffing, communications equipment, and facilities to support an extended loss of all AC power (ELAP) scenario as described in Exelon's staffing assessment and the NRC safety evaluation. The team also verified that Exelon had implemented dose assessment (including releases from SFPs) capability using site-specific dose assessment software, as described in Exelon's dose assessment submittal.


b. Assessment The team reviewed information provided in Exelon's dose assessment submittal and in response to the NRC's March 12, 2012, request for information letter (ML12053A340), and verified that Exelon satisfactorily implemented enhancements pertaining to Near-Term Task Force (NTTF) Recommendation 9.3, response to a large scale natural emergency event that results in an ELAP to all site units and impedes access to the site.
The team reviewed information provided in Exelons dose assessment submittal and in response to the NRCs March 12, 2012, request for information letter (ML12053A340),and verified that Exelon satisfactorily implemented enhancements pertaining to Near-Term Task Force (NTTF) Recommendation 9.3, response to a large scale natural emergency event that results in an ELAP to all site units and impedes access to the site.


The team verified the following:
The team verified the following:
* Exelon satisfactorily implemented required staffing changes to support an ELAP scenario;
* Exelon satisfactorily implemented required staffing changes to support an ELAP scenario;
* Emergency preparedness communications equipment and facilities were sufficient for dealing with an ELAP scenario; and
* Emergency preparedness communications equipment and facilities were sufficient for dealing with an ELAP scenario; and
* Exelon implemented dose assessment capabilities (including releases from SFPs) using Ginna site-specific dose assessment software and approach.
* Exelon implemented dose assessment capabilities (including releases from SFPs)using Ginna site-specific dose assessment software and approach.


The team verified that issues identified during the inspection were entered into Exelon's corrective action program.
The team verified that issues identified during the inspection were entered into Exelons corrective action program.


====c. Findings====
====c. Findings====
No findings were identified.
No findings were identified.


{{a|4OA6}}
{{a|4OA6}}
 
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==
On November 10, 2016, the team presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the Ginna staff.
On November 10, 2016, the team presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the Ginna staff.


The team verified that no proprietary information was retained by team members or documented in this report.
The team verified that no proprietary information was retained by team members or documented in this report.


ATTACHMENT:
ATTACHMENT:  


=SUPPLEMENTARY INFORMATION=
=SUPPLEMENTARY INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
===Licensee personnel===
===Licensee personnel===
:
:  
: [[contact::J. Pacher]], Site Vice President  
: [[contact::J. Pacher]], Site Vice President  
: [[contact::W. Carsky]], Plant Manager  
: [[contact::W. Carsky]], Plant Manager  
Line 180: Line 199:
: [[contact::J. Fischer]], Regulatory Assurance  
: [[contact::J. Fischer]], Regulatory Assurance  
: [[contact::D. Gomez]], Training  
: [[contact::D. Gomez]], Training  
: [[contact::W. Henretty]], Training M. Starowitz Design Engineering  
: [[contact::W. Henretty]], Training
M. Starowitz Design Engineering  
: [[contact::R. White]], Unit Supervisor  
: [[contact::R. White]], Unit Supervisor  


==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED==
==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED==
Opened and Closed:
None


Opened and Closed:
None
Discussed:
Discussed:
None  
None  
 
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
Procedures:
 
: A-52.12, Nonfunctional Equipment Important to Safety, Revision 083
: CC-AA-102, Design Input and Configuration Change Impact Screening, Revision 29
: CC-GI-118, Ginna Implementation of Diverse and Flexible Coping Strategies (FLEX) and Spent Fuel Pool Instrumentation Program, Revision 004
: ECA-0.0, Loss of All AC Power, Revision 042
: EOP
: AP-Elec.4, Loss of All AC Power While on Shutdown Cooling, Revision 00000 EOP Att-5.5, Attachment SAFW with Suction from DI Water Storage Tank during SBO, Revision 004
: ER-COMM.1, Loss of Communications, Revision 001
: FSG-1, Long Term RCS Inventory Control, Revision 001
: FSG-2, Alternate SAFW Suction Source, Revision 00000
: FSG-3, Alternate Low Pressure Feedwater, Revision 00000
: FSG-4, ELAP DC Bus Load Shed/Management, Revision 003
: FSG-5, Initial Assessment and FLEX Equipment Staging, Revision 004
: FSG-6, Alternate SAFW DI Water Storage Tank Makeup, Revision 00000
: FSG-7, Loss of Vital Instrumentation or Control Power, Revision 00000
: FSG-8, Alternate RCS Injection, Revision 002
: FSG-9, Low Decay Heat Temperature Control, Revision 00000
: FSG-10, Passive RCS Injection Isolation, Revision 002
: FSG-11, Alternate SFP Makeup and Cooling, Revision 00000
: FSG-12, Alternate CNMT Cooling, Revision 00100
: FSG-13, Transition from FLEX Equipment, Revision 00000
: FSG-14, Shutdown RCS Makeup, Revision 00000
: FSG-100, Flex Support Equipment Inventory, Revision 005
: FSG-101, FLEX Support Equipment - Beyond Design Basis Flex Pump (PBD01A/PBD01B/PBD01C), Revision 001
: FSG-102, FLEX Support Equipment - Diesel Driven FLEX Generator (KBD01A) Revision 001
: FSG-103, FLEX Support Equipment - Diesel Driven FLEX Air Compressor, Revision 001
: FSG-105, FLEX Support Equipment - FLEX Fuel Tanker Trailer (TBD01A/TBD01B), Revision 00100
: FSG-107, Flex Support Equipment - Alternate RCS Injection Diesel Driven FLEX Pump (PBD04)
: FSG-109, Flex Support Equipment - Motorola Communications Repeater, Revision 00000
: FSG-118, Portable Satellite Communication Systems Operating User Aid, Revision 000
: O-22, Cold Weather Walkdown Procedure, Revision 019
: OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Revision 15
: Drawing:
: Drawing No.33013-1230, Revision 2, Alternate RCS Injection System (BDB) P&ID
: Drawing No.33013-1248, Revision 46, Auxiliary Cooling Spent Fuel Pool Cooling (AC) P&ID Drawing No.33013-1261, Revision 46, Containment Spray (SI) P&ID Drawing No.33013-1262, Sheet 1 of 2, Revision 34, Safety Injection and Accumulators (SI)
: P&ID Drawing No.33013-1262, Sheet 2 of 2, Revision 8, Safety Injection and Accumulators (SI) P&ID
: Drawing No.33013-2546, Revision 4, Fire Response Plan, Auxiliary Building, Elev. 253'0" Drawing No.33013-2552, Revision 15, Fire Response Plan, Auxiliary Building, Elev. 271'0" Drawing No.33013-2886, Sheet 9, Revision 1, SAFW Building Annex Embedded Conduit
: Layout
: Calculations:
: CALC-2014-0006, Auxiliary Building Environmental Conditions during ELAP, Revision 0
: CC-AA-309-1001, Ginna Standby Auxiliary Feedwater Room Heat-Up Analysis, Revision 8
: Evaluations:
: ECP-16-000103, Evaluate SAFW Bldg for Limiting SBO and FLEX Temperatures
: Work Orders:
: C92948909
: C93136817
: C93214421
: C93214428
: C93260455
: C93260457
: Other:
: FLEX-PROGPLAN, R. E. Ginna Nuclear Power Plant Final Integration Plan Mitigating Strategies (NRC Order
: EA 12-049), Revision 1
: FLEX-VALPLAN, R. E. Ginna Nuclear Power Plant
: NEI 12-06 FLEX Validation Plan,
: Revision 000 10-16
: EP-GI-124-1002-F-01, Control Room Communication Operational Check, completed October 28, 2016
: 10-16
: EP-GI-124-1002-F-04, EOF Communication Operational Checks, completed October 31, 2016 10-16
: EP-GI-124-1002-F-07, GTCW OMT Spare Comm Operational Checks, completed October 28, 2016 
===ARs===
: Reviewed:
: 2531358
: 2547043
: 2570522
: 02608676
: 02616697
: 2621537
: 02630635
: 02631163
: 2631728
: 02632037
: 02651286
: 2655947
: 02695312
: 02695333
: 2696029
: 02696036
: 02696793
: 2712066
: 02733479
: 02733583
: 2734051
: 02734053
: 02734056
===ARs===
: Generated:
: 2738166
: 02739076
: 2739495
==LIST OF ACRONYMS==
: [[AC]] [[Alternating Current]]
: [[ADAMS]] [[Agencywide Documents Access and Management System]]
: [[ELAP]] [[Extended Loss of all]]
: [[AC]] [[Power]]
: [[FLEX]] [[Diverse and Flexible Coping Strategies]]
: [[FSG]] [[]]
: [[FLEX]] [[Support Guidelines]]
: [[NRC]] [[Nuclear Regulatory Commission,]]
: [[U.S.]] [[]]
: [[NTTF]] [[Near Term Task Force]]
: [[SFP]] [[Spent Fuel Pool]]
: [[TI]] [[Temporary Instruction]]
}}
}}

Latest revision as of 18:53, 9 January 2025

LLC - Temporary Instruction 2515/191 Inspection Report 05000244/2016011
ML16337A092
Person / Time
Site: Ginna Constellation icon.png
Issue date: 12/02/2016
From: Anthony Dimitriadis
Reactor Projects Branch 1
To: Bryan Hanson
Exelon Generation Co
Dimitriadis A
References
IR 2016011
Download: ML16337A092 (12)
v • d • e


Text

December 2, 2016

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - TEMPORARY INSTRUCTION 2515/191 INSPECTION REPORT 05000244/2016011

Dear Mr. Hanson:

On November 10, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the R.E. Ginna Nuclear Power Plant, LLC (Ginna). On November 10, 2016, the NRC inspectors discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with plant personnel.

The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Anthony Dimitriadis, Chief

Reactor Projects Branch 1

Division of Reactor Projects

Docket No.

50-244 License No.

DPR-18

Enclosure:

Inspection Report 05000244/2016011 w/Attachment: Supplementary Information

REGION I==

Docket No.

50-244

License No.

DPR-18

Report No.

05000244/2016011

Licensee:

Exelon Generation Company, LLC (Exelon)

Facility:

R.E. Ginna Nuclear Power Plant, LLC (Ginna)

Location:

Ontario, New York

Dates:

November 7-10, 2016

Inspectors:

C. Cahill, PE, Senior Reactor Analyst, Division of Reactor Safety (DRS)

F. Arner, Senior Reactor Analyst, DRS J. Petch, Resident Inspector (Ginna)

Approved by:

Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects

SUMMARY

Inspection Report 05000244/2016011; 11/7/2016 - 11/10/2016; R.E. Ginna Nuclear Power

Plant, LLC (Ginna); Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.

The inspection covered a one week inspection by two senior reactor analysts, and the resident inspector. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 6.

REPORT DETAILS

OTHER ACTIVITIES

4OA5 Other Activities

TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans

The objective of TI 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify:

(1) that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16006A050) and the NRCs plant safety evaluation (ADAMS Accession No. ML16124A038);
(2) that the licensees installed reliable water-level measurement instrumentation in their spent fuel pools (SFPs); and
(3) that licensees have implemented emergency preparedness enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability, enhancements to ensure that staffing is sufficient, and that communications can be maintained during beyond-design-basis external events.

The team verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events, (ADAMS Accession No. ML12054A735) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12056A044) were in place and were being implemented by Exelon. The team also verified that Exelon had implemented staffing and communications plans provided in response to the March 12, 2012, request for information letter and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No.

ML12339A262).

The team discussed the plans and strategies with Exelon personnel, reviewed documentation, completed a tabletop exercise involving a beyond design basis event leading to an extended loss of offsite power and, where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in Exelons submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections. Documents reviewed for each section of this report are listed in the Attachment.

1. Mitigation Strategies for Beyond-Design Basis External Events

a. Inspection Scope

The team examined Exelons established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the Exelon staff coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

The team verified that a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Ginna staff most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.

b. Assessment

Based on samples selected for review, the inspectors verified that Exelon satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation (ADAMS Accession No.

ML16124A038) and determined that Exelon was in compliance with NRC Order EA-12-049.

The team verified that Exelon satisfactorily:

  • Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events;
  • Integrated their FSGs into their existing emergency operating procedures and off-normal procedures such that entry into and departure from the FSGs are clear when using existing plant procedures;
  • Protected FLEX equipment from site-specific hazards;
  • Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;
  • Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events; and
  • Developed procedures to ensure that the necessary off-site FLEX equipment will be available from off-site locations.

The team verified that inspector observations identified during the inspection were entered into Exelons corrective action program, where appropriate.

c. Findings

No findings were identified.

2. Spent Fuel Pool Instrumentation

a. Inspection Scope

The team examined Exelons newly installed SFP instrumentation. Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation, and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. In addition, the team verified that Exelon had evaluated environmental conditions and accessibility of the instrumentation.

The team verified that Exelon had approved procedures for maintenance, testing, calibration, and use of the primary and backup SFP instrumentation channels. The team also verified that the procedures followed the industry guidance contained in Nuclear Energy Institute 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, and that these procedures were part of an existing Exelon process to be maintained.

b. Assessment

Based on samples selected for review, the team determined that Exelon satisfactorily installed and established appropriate operating and maintenance controls for the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation. The team determined that Exelon was in compliance with NRC Order EA-12-051.

The team verified that Exelon satisfactorily:

  • Installed the SFP instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittal(s) and safety evaluation;
  • Installed the SFP instrumentation display in the accessible location, and environmental conditions as described in the plant specific submittal(s);
  • Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and
  • Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation.

The team verified that issues identified during the inspection were entered into Exelons corrective action program.

c. Findings

No findings were identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation, and plant walk downs, the team verified that Exelon had implemented required changes to staffing, communications equipment, and facilities to support an extended loss of all AC power (ELAP) scenario as described in Exelons staffing assessment and the NRC safety evaluation. The team also verified that Exelon had implemented dose assessment (including releases from SFPs) capability using site-specific dose assessment software, as described in Exelons dose assessment submittal.

b. Assessment

The team reviewed information provided in Exelons dose assessment submittal and in response to the NRCs March 12, 2012, request for information letter (ML12053A340),and verified that Exelon satisfactorily implemented enhancements pertaining to Near-Term Task Force (NTTF) Recommendation 9.3, response to a large scale natural emergency event that results in an ELAP to all site units and impedes access to the site.

The team verified the following:

  • Exelon satisfactorily implemented required staffing changes to support an ELAP scenario;
  • Exelon implemented dose assessment capabilities (including releases from SFPs)using Ginna site-specific dose assessment software and approach.

The team verified that issues identified during the inspection were entered into Exelons corrective action program.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On November 10, 2016, the team presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the Ginna staff.

The team verified that no proprietary information was retained by team members or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Pacher, Site Vice President
W. Carsky, Plant Manager
J. Jackson, Director, Emergency Preparedness
R. Fellows, Shift Manager
G. Wrobel, Fukushima Project Manager
M. McGraw, Program Manager
J. Becher, System Manager Portable Equipment
J. Fischer, Regulatory Assurance
D. Gomez, Training
W. Henretty, Training

M. Starowitz Design Engineering

R. White, Unit Supervisor

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed:

None

Discussed:

None

LIST OF DOCUMENTS REVIEWED

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