IR 05000244/2006002

IR 05000244-06-002 on 01/01/2003 - 03/31/2006 for Constellation Energy; R.E. Ginna Nuclear Power Plant; Fire Protection, Licensed Operator Requalification Program, and Program Identification and Resolution, Cross-Cutting Areas

ML061250176
Person / Time
Site:	Ginna
Issue date:	05/05/2006
From:	Brian Mcdermott Reactor Projects Branch 1
To:	Korsnick M Constellation Energy Group, Ginna
References
IR-06-002
Download: ML061250176 (36)

Text

May 5, 2006Mrs. Mary Vice President, R.E. Ginna Nuclear Power Plant

R.E. Ginna Nuclear Power Plant, LLC

1503 Lake Road

Ontario, New York 14519SUBJECT:R. E. GINNA NUCLEAR POWER PLANT- NRC INTEGRATED INSPECTION REPORT 05000244/2006002

Dear Mrs. Korsnick:

On March 31, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspection at your R. E. Ginna facility. The enclosed inspection report documents the inspection results, which were discussed on April 14, 2006 with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

This report documents three findings of very low safety significance (Green) which were determined to involve a violation of NRC requirements. However, because of the very low

safety significance and because they were enter ed into your corrective action program, the NRC is treating these three findings as non-cited violat ions (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your denial, to

the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C.

20555-0001; with copies to the Regional Administrator Region I; the Director, Office of

Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001;

and the NRC Resident Inspector at R.E. Ginna Nuclear Power Plant.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the M. Korsnick2 NRC Public Document Room or from the Public ly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/Brian J. McDermott, Chief Reactor Projects Branch 1

Division of Reactor Projects Docket No.: 50-244 License No.: DPR-18Enclosure:Inspection Report 05000244/2006002 w/ Attachment: Supplemental Information cc w/encl:

M. J. Wallace, President, Constellation Generation

J. M. Heffley, Senior Vice President and Chief Nuclear Officer

P. Eddy, Electric Division, NYS Department of Public Service

C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law

C. W. Fleming, Esquire, Senior Counsel, Constellation Energy Group, Inc.

P. R. Smith, New York State Energy Research and Development Authority

J. Spath, SLO Designee New York State Energy Research and Development Authority

T. Wideman, Director, Wayne County Emergency Management Office

M. Meisenzahl, Administrator, Monroe County, Office of Emergency Preparedness

T. Judson, Central New York Citizens Awareness Network

SUMMARY OF FINDINGS

IR 05000244/2006-002; 01/01/2006 - 03/31/2006; R. E. Ginna Nuclear Power Plant; Fire

Protection, Licensed Operator Requalification Program, and Problem Identification and

Resolution, Cross-Cutting Areas.

The report covered a 3-month period of inspection by resident inspectors and announced inspections by regional specialists. Three Green findings, all of which were non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination

Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor

Oversight Process," Revision 3, dated July 2000. A.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation (NCV) of Technical Specification (TS) 5.4.1.d, which requires, in part, that written procedures be established, implemented, and maintained for the fire protection program.

Contrary to TS 5.4.1.d, during a fire walkdown of the auxiliary building operating floor the inspectors identified four drums of charcoal which were not identified as a transient combustible load and did not have a transient combustible permit in violation of Ginna fire protection procedure FPS-16. Ginna entered this performance deficiency into their corrective action program for resolution.

The inspectors determined that the failure to properly implement procedure FPS-16 was more than minor because it affected the objectives of availability and reliability for systems which respond to mitigate events under the protection against external hazards attribute of the Mitigating Systems cornerstone and because the amount of charcoal exceeded the transient combustible limit of the

Fire Hazards Analysis for that area of the plant. The inspectors assessed the finding using Appendix F of the Significance Determination Process (SDP). The finding is of very low safety significance because the charcoal in question has a high ignition point (350C) and was stored in approved containers resulting in a Degradation Rating of Low, which screens to Green in the fire protection SDP.

This finding has a cross-cutting aspect in Human Performance because Ginna personnel did not follow established procedures for the control of transient combustibles. (Section 1R05)*Green. The inspectors identified a non-cited violation (NCV) of 10 CFR 55.46 (c)(1) which requires, in part, that the plant-referenced simulator must show the expected plant response to operator input and to normal, transient, and accident conditions. Contrary to the above, the inspectors identified that certain elements of the plant process computer system (PPCS) as displayed in the simulator had not correctly replicated the expected plant response since PPCS was added to iv the simulator in 2001. This performance deficiency was entered into the Ginna corrective action program for resolution.

The inspectors determined that this simulator fidelity issue was more than minor because it affected the capability objective of the human performance attribute under the Mitigating Systems cornerstone. The finding was evaluated using the

Operator Requalification Human Performance SDP (MC 0609 Appendix I). The inspectors determined that the deviation in the simulator had impacted operator actions and could potentially lead to a failure to use PPCS to diagnose conditions on the actual plant. The finding was of very low safety significance because the failure to use PPCS as a diagnostic tool in the simulator had no actual plant impact on equipment or personnel safety. (Section 1R11)*Green. The inspectors identified a non-cited violation (NCV) of 10 CFR 50, App.

R III.I.3.b which requires that drills shall be performed at regular intervals not to exceed 3 months for each shift fire brigade. Contrary to the requirement, four of five shift fire brigades were not drilled during the fourth quarter of 2005. This performance deficiency was entered into Ginna's corrective action program for resolution.

The inspectors determined that the failure to meet the fire brigade drill requirement was more than minor because it affected the reliability and capability objectives of the protection against external factors attribute under the Mitigating

Systems cornerstone. The finding was evaluated using Fire Protection

Significance Determination Process (Manual Chapter 0609, App F). The finding category is Fire Prevention and Administrative Controls with an assigned degradation factor of low which screens to Green (very low safety significance).

This finding has a cross-cutting aspect in Human Performance associated with a poor turnover of responsibilities and poor management oversight of the turnover process when fire personnel changed jobs. (Section 4OA2)

B. Licensee-Identified Violations

None

REPORT DETAILS

===Summary of Plant Status

Ginna began the period at full Rated Thermal Power (RTP) and operated at full power for the entire report period.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection (71111.01 - 2 samples, impending weather)

a. Inspection Scope

On February 17, 2006, Control Room Operators entered ER-SC.1, "Adverse Weather Plan," when predicted high winds exceeded the limit in the procedure. The inspectors

had monitored preparations the previous day when the forecast was made for high

winds and continued to monitor site response throughout the morning of the 17 th until the high winds had passed. Processes were followed site wide and no incidents occurred

do to the high winds.

On March 2, 2006, Control Room Operators entered ER-SC.3, "Low Screenhouse Water Level," when the plant experienced an unexpected six inch decrease in Screenhouse

water level. The inspectors monitored plant response and operator response as

corrective actions were taken by on-shift personnel. Several cycles of the screenhouse

recirculation gate restored screenhouse level in the intake water bay during the ensuing

three hour time period. Over the next several days the condition repeated itself and

was solved in a similar fashion by the operat ors. The formation of ice observed in the screenhouse intake bay did not resemble frazile ice in structure or form. The intake bay

water level did not approach any limiting parameters during the transient.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment (71111.04).1Partial Walkdown (3 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of plant systems to verify operability of redundant or diverse trains and components when safety equipment was inoperable.

The inspectors used plant technical specifications, Ginna operating procedures, plant

piping and instrument drawings (P&ID), and the UFSAR as guidance for conducting

partial system walkdowns. The inspection re viewed the alignment of system valves and electrical breakers to ensure proper in-service or standby configurations as described in

plant procedures and drawings. During the walkdown, the inspectors evaluated material 2 Enclosure conditions and general housekeeping of the system and adjacent spaces. The inspectors also verified that operations personnel were following plant technical

specifications (TS). The following plant system alignments were reviewed:On January 17, 2005, the inspectors completed a walkdown of the "A" motor

driven auxiliary feedwater system when the "B" motor driven auxiliary feedwater pump was out of service for scheduled ma intenance. This system was examined because it is a diverse means of supplying water to the steam generators in the

event offsite power was lost.On February 9, 2006, the inspectors completed a walkdown of the "B"

emergency diesel generator (EDG) when the "A" EDG was out of service for

scheduled maintenance. This system was examined because it provides backup emergency power to vital class 1E equipment and was the sole source for

backup alternating current power while the "A" EDG was not available.On March 7, 2006, the inspectors completed a walkdown of the "C" standby

auxiliary feedwater (SAFW) pump after quarterly maintenance had been

performed and the system had been restored to an operable status. This risk

significant system was examined because it is an important backup means for supplying water to the steam generators in the event of a high energy line break

or other event that disables the preferred auxiliary feedwater pumps.

b. Findings

No findings of significance were identified..2Complete Walkdown (1 sample)

a. Inspection Scope

The inspectors conducted a detailed walkdown of the alignment and condition of the safety injection (SI) system. The SI system was chosen because of the important role it would play to provide makeup water to the reactor under a small -break loss of coolant (SBLOCA) accident . In addition to verifying proper system alignment as required by

plant TS, the plant UFSAR, and Ginna procedures and drawings, the inspector reviewed

system maintenance and action reports. None of the action reports or maintenance

work orders indicated the performance reliability of the system had declined.

b. Findings

No findings of significance were identified.

3 Enclosure1R05Fire Protection (71111.05 - 8 samples)

a. Inspection Scope

Using the Ginna Fire Protection Program documents as a guide, the inspectors performed walkdowns of the following fire areas to determine if there was adequate

control of transient combustibles and ignition sources. The material condition of fire

protection systems, equipment and features, and the material condition of fire barriers

were also inspected against industry standards. In addition, the passive fire protection

features were inspected, including the ventilation system fire dampers, structural steel

fire proofing, and electrical penetration seals. The following plant areas were inspected:*Intermediate Building Sub-basement, Fire Zone IB-0*Cable Tunnel, Fire Zone, Fire Zone CT

• Class 1E Switchgear, Fire Zone ABO

• Intermediate Building Controlled Side Operating Floor, Fire Zone IBN-1

• Diesel Generator Room, Fire Area EDG1A

• Diesel Generator Room and Vault, Fire Area EDG1B

• Screenhouse, Fire Area, Fire Zones SH-2 and SH-3

• Screenhouse, Fire Area, Fire Zone SH-1

b. Findings

Introduction

The inspectors identified a Green non-cited violation (NCV) of TS 5.4.1.d, which requires in part, that procedures be established, implemented and maintained

covering the fire protection program. A Ginna procedure was not properly implemented

when four drums of charcoal were stored in an area adjacent to the class 1E bus 14

switchboard and motor control center (MCC) L without a required transient combustible

permit (TCP).

Description

Procedure FPS-16, "Bulk Storage of Combustible Materials and Transient Fire Loads," provides requirements for controlling the storage and use of transient

combustible materials at Ginna. During a walkdown of the auxiliary building on January

26, 2006, the inspectors observed four drums of charcoal stored on the auxiliary building operating floor near class 1E Bus 14 and MCC L. A tag affixed to the drums indicated

that they were placed in the auxiliary building on December 2, 2005. The inspectors

discussed the drums with the on-duty fire protection supervisor and were initially

informed that no TCP was required. The on-duty fire protection supervisor notified both

the Fire Protection Program Manager and the Fire Protection System engineer who

recognized the error and wrote a Condition Report to get the material removed from the

area. The inspectors discussed the issue with the Fire Protection System Engineer.

On January 31, 2006, the drums of charcoal were moved from the auxiliary building to the contaminated storage building (CSB) where a TCP was not required. Ginna initiated

condition report 2006-0370 to address this problem in their corrective action program.

4 Enclosure

Analysis:

The inspectors determined that the failure to properly implement procedure FPS-16 was more than minor because it was associated with the protection against

external factors attribute of the Mitigating Systems cornerstone and affected the

objective to ensure the reliability of the mitigating systems. The increased combustible

loading from the improperly stored drum s potentially reduced the availability and reliability of mitigating systems in and adjacent to class 1E switchgear and MCC "L" in

the event of a postulated fire. The inspectors assessed the finding using Appendix F of

the Significance Determination Process (SDP) and determined the finding to be of very

low safety significance. The finding is of very low safety significance because the

materials in question have a fairly high ignition point (350C) and were stored in approved containers. As a result, the combustible material controls issue was assigned

a degradation of low, which screens to Green in the fire protection SDP. This finding

involved an amount of combustible material which exceeds the fire hazard analysis load

limit for the area, thus meeting the more than minor criteria of example 4.k in NRC

Inspection Manual Chapter 0612, Appendix E. This finding has a cross-cutting aspect

in Human Performance because Ginna personnel did not follow established procedures

for the control of transient combustibles.

Enforcement:

TS 5.4.1.d requires that written procedures be established, implemented, and maintained for the fire protection program. Ginna fire protection procedure FPS-16, Step 5.10.1 requires a Transient Combustible Permit be utilized when transient

combustibles must be stored in the protected area of the plant. Step 5.10.2 requires that

the Job Supervisor initiate the TCP.

Step 5.3 states that no combustibles shall be

stored in either the combustible control zones listed in Attachment 2 or safety related

areas, except what is specifically approved by the Fire Hazard Analysis unless

accompanied by an approved TCP. Contrary to these requirements, between December 2, 2005 and January 31, 2006 Ginna stored four drums of charcoal, more than the

transient combustible limit allowed in the fire hazards analysis, in a safety-related area

without an engineering approved transient combustible permit. Because this violation

was determined to be of very low safety significance and Ginna entered the deficiency

into their corrective action system in condition report 2006-0370, it is being treated as a NCV, consistent with section VI.A.1 of the NRC Enforcement Policy. (NCV 5000244/2006002-01, Inadequate Control of Transient Combustible Material).

1R06 Flood Protection Measures (71111.06 - 1 sample, internal flood protection)

a. Inspection Scope

The inspectors evaluated Ginna's internal flood protection measures for the cable tunnel. To perform this evaluation, the inspectors reviewed the Ginna UFSAR, design

drawings for the cable tunnel and associated drain systems, work orders, and toured the

cable tunnel, intermediate building, and turbine building areas.

b. Findings

No findings of significance were identified.

5 Enclosure1R07Heat Sink Performance (71111.07 - 2 samples)

a. Inspection Scope

The inspectors evaluated Ginna's heat sink performance by monitoring the heat exchanger effectiveness for the Containment Recirculating Fan Coolers (CRFC) and the

"B" Emergency Diesel Generator (EDG) Coolers. To perform this inspection, the

inspectors reviewed the Ginna UFSAR, the Ginna Service Water System Reliability

Optimization Program (SWSROP), periodic tests PT 2.9Q (Containment Recirc Fan

Testing) and PT 12.2 (EDG "B") and observed the execution of PT 2.9Q and PT 12.2.

The inspectors also interviewed the SWSROP System Engineer and reviewed "as

found" and "as left" photos of the last clean and inspected evolutions when the heat

exchangers were open. The inspectors also observed actions taken to mitigate actual

icing conditions in the service water intake structure during cold weather.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11).1Resident Inspector Quarterly Review (1 sample)

a. Inspection Scope

On January 25, 2006, the inspectors observed a licensed operator simulator scenario.

The test observed was scenario ECA00-06, "Loss of All AC Power." The inspectors

reviewed the critical tasks associated with the scenario, observed the operators'

performance, and observed the post-evaluation critique. The inspectors also reviewed

and verified compliance with Ginna procedure OTG-2.2, "Simulator Examination

Instructions."

b. Findings

Introduction:

The inspectors identified a Green non-cited violation (NCV) of 10 CFR 55.46(c)(1), which requires in part that a plant-referenced simulator used for the

administration of operating tests must demonstrate expected plant response to normal, transient and accident conditions. An annual requalification scenario was observed in

which Ginna's simulator did not replicate the expected plant response during a loss of all

AC power accident condition because the Plant Process Computer System (PPCS)

indicated steam generator (SG) water level to be 28% when actual SG level was 42%.

Description:

While observing an Annual Requalification operating exam, the inspectors noted several instances where the simulator failed to replicate expected plant response.

The inspectors determined, from discussions with 2 simulator instructors and both the

current and former PPCS system engineers, that PPCS in the simulator responds

differently than PPCS in the plant. The plant PPCS is designed to recognize the data 6 Enclosure from the de-energized equipment as being "failed" and will not use this data in applicable calculations. Inspectors learned through discussion with the systems engineers that the

PPCS modification made to the simulator in 2001 was implemented with failed

transmitters modeled as a "zero" input versus a failed input to the computer. Since

PPCS sees a zero input as valid (e.g. SG level could be zero), this input is used in

numerous simulator PPCS calculations (e.g. SG level, PZR level, RCS temperature, RCS subcooling, etc.) and results in the simulator's PPCS providing the operator with

invalid data.

The inspectors were informed that the PPCS software would flag the data

as failed and not use the data in calculations if the simulator modeled the failed inputs as

"-999" or sent over a failed data point to PPCS.

Interviews of 5 currently licensed operators revealed a general misunderstanding of how the PPCS functions to automatically delete the averaged input from a failed channel.

Operators expect the PPCS to provide erroneous indications of SG level during a loss of

all AC power event or any event in whic h a vital bus is de-energized. One operator stated that due to the problems with false information coming from PPCS they typically don't use PPCS for information during simulated accident scenarios.

This issue has resulted in negative training of the licensed operators and shift technical advisors. Through repeated simulator training over the last few years, the operators

have learned to work-around the problem with PPCS in the simulator providing them

invalid information and as a result they would no longer use PPCS, a valuable tool for

rapid assessment of plant status, during emergencies in the real control room.

Analysis:

The inspectors determined that this simulator fidelity issue was more than minor because it affected the capability objective of the human performance attribute

under the Mitigating Systems cornerstone. The finding was evaluated using the

Operator Requalification Human Performance SDP (MC 0609 Appendix I). The

inspectors further determined that the deviation in the simulator had impacted operator

actions through negative training and could potentially lead to a failure to use PPCS to

diagnose conditions on the actual plant. The finding was of very low safety significance

because the failure to use PPCS as a diagnostic tool in the simulator had no actual plant

impact on equipment or personnel safety.

Enforcement:

10 CFR 55.46 (c)(1) requires a plant-referenced simulator used for the administration of the operating test or to meet experience requirements must

demonstrate the expected plant response to operator input and to normal, transient, and

accident conditions to which the simulator has been designed to respond.

Contrary to

the above, on January 25, 2006, the inspectors identified that Ginna failed to ensure that

the simulator correctly replicated the expected plant response to accident conditions as

a result of an improperly implemented modification which added PPCS to the simulator

in 2001. Because this violation was determined to be of very low safety significance and

entered into the corrective action program in condition report 2006-0467, it is being treated as a NCV, consistent with section VI.A of the NRC enforcement policy.

(NCV5000244/2006002-02: Simulator Incorrectly Replicated Plant Design)..2Biennial Review (1 sample)===

a. Inspection Scope

On March 13, 2006, the inspector conducted an in-office review of licensee annual

operating test results. The annual operating tests were conducted from January 3 to

February 4, 2006. This inspection assessed whether pass rates were consistent with the

guidance of NRC Manual Chapter 0609, Appendix I, "Operator Requalification Human

Performance Significance Determination Process (SDP)". For Ginna, the inspector

verified that: *Crew failure rate was less than 20%. (Crew failure rate was 11.0%.)*Individual failure rate on the dynamic simulator test was less than or equal to 20%. (Individual failure rate was 0% at both units.)*Individual failure rate on the walk-through test was less than or equal to 20%. (Individual failure rate was 0%)*Overall pass rate among individuals for all portions of the exam was greater than or equal to 75%. (Overall pass rate was 91.6%)

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12 - 2 samples)

a. Inspection Scope

The inspectors evaluated Ginna's work practices and follow-up corrective actions for selected system, structure, or component (SSC) issues to assess the effectiveness of Ginna's maintenance activities. The inspectors reviewed the performance history of

those SSCs and assessed Ginna's extent-of-condition determinations for those issues

with potential common cause or generic implications to evaluate the adequacy of

Ginna's corrective actions. The inspectors reviewed Ginna's problem identification and

resolution actions for these issues to evaluate whether Ginna had appropriately

monitored, evaluated, and dispositioned the issues in accordance with Ginna

procedures and the requirements of 10 CFR 50.65, "Requirements for Monitoring the

Effectiveness of Maintenance." In addition, the inspectors reviewed selected SSC

classification, performance criteria and goals, and Ginna's corrective actions that were

taken or planned, to verify whether the actions were reasonable and appropriate. The

following issues were reviewed:*Failure of three check valves and a lube oil pump trip associated with MDAFW Pump "A" testing were evaluated. The repair activities were conducted February

22-24, 2006.*Repairs and ongoing maintenance efforts in the "B" Emergency Diesel Generator (EDG) Vault associated with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier which assures division between

the two EDGs were evaluated. The repair activities were conducted the week of

March 13, 2006. Additionally reviews were conducted to determine treatment of

the entire Diesel Generator building structure maintenance.

b. Findings

8 Enclosure No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples)

a. Inspection Scope

The inspectors evaluated the effectiveness of Ginna's maintenance risk assessments required by paragraph a(4) of 10 CFR 50.65. This inspection included discussions with

control room operators and scheduling department personnel regarding the use of

Ginna's online risk monitoring software. The inspectors reviewed equipment tracking

documentation and daily work schedules, and performed plant tours to gain reasonable

assurance that actual plant configuration matched the assessed configuration.

Additionally, the inspectors verified that Ginna's risk management actions, for both

planned and/or emergent work, were consistent with those described in procedure

IP-PSH-2, "Integrated Work Schedule Risk Management." Risk assessments for the

following out-of-service systems, structures, and / or components were reviewed:*Planned maintenance on the "B" motor driven auxiliary feedwater pump (January 16-18, 2006)*Emergent work on the service water piping to the stand-by auxiliary feedwater pumps (February 6-7, 2006)*Emergent Work on the "A" motor driven auxiliary feedwater system check valves and lube oil support system (February 22-25, 2006)*Maintenance conducted by RG&E in the 13A switchyard which increased overall plant risk in a 100/0 lineup while already in a high winds condition (March 15, 2006)*Planned maintenance to replace the "A" Battery Charger with a new 200 amp charger (weeks of March 13 and March 27, 2006)

b. Findings

No findings of significance were identified.

1R14 Operator Performance During Non-Routine Evolutions and Events (71111.14 - 1sample)

a. Inspection Scope

For the non-routine event described below, the inspectors reviewed operator logs, plant computer data, the Updated Final Safety Analysis Report (IFSAR) and station

procedures to determine what occurred and how the operators responded, and to

determine if the response was in accordance with plant procedures.*On February 6, 2006 during a walkdown of the service water system in preparation for power uprate a system engineer determined that the increased

feed requirements for power uprate vacuum breakers in the service water 9 Enclosure system, installed in the mid 1990's to prevent water hammer, could cause air binding of the standby auxiliary feedwater pumps. The inspectors followed the

plant response to this determination by the engineer including declaration of the

system as inoperable and an engineering evaluation recommending isolation of

the previously installed vacuum breakers. The repairs and plant response were

reviewed and the restoration of the system to operable status was evaluated by

the inspectors.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - 4 samples)

a. Inspection Scope

The inspectors reviewed four operability determinations to verify that the operability of systems important to safety was properly established, that the affected components or systems remained capable of performing their intended safety functions, and that no

unrecognized increase in plant or public risk occurred. In addition, the inspectors

reviewed the following operability evaluations to determine if system operability was

properly justified in accordance with IP-CAP-1.1, "Technical Evaluation for Current

Operability and Past Operability Determination Worksheet":*Condition Report (CR) 2006-0436, Operability of the Standby Auxiliary Feedwater System under Specific Accident Conditions with Recommendations to

Change the Service Water System Vacuum Breaker Configuration*CR 2006-0446, Evaluation of Siren Operability Under Winter Weather Conditions Causing Freezing of Rotating Elements*CR 2006-0719, MDAFW Pump "A" Lube Oil Pump Trip During Testing

• CR 2006-0786, Incorrect Resistance Found on Reactor Protection Channel 2 Distribution Block

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing (71111.19 - 6 samples)

a. Inspection Scope

The inspectors observed portions of post-maintenance testing activities in the field to determine whether the tests were performed in accordance with approved procedures.

The inspectors assessed the test's adequacy by comparing the test methodology to the

scope of maintenance work performed. In addition, the inspectors evaluated the test

acceptance criteria to verify that the tested components satisfied the applicable design

and licensing bases and technical specification requirements. The inspectors reviewed 10 Enclosure the recorded test data to determine whether the acceptance criteria were satisfied. The following post-maintenance testing activities were reviewed:*Work Order (WO) 20504209, Replace Letdown Line Temperature Controller Pair TC-130 and HC-130 with new NUSI Style Controllers (January 16-17, 2006*PT-16Q-B, Auxiliary Feedwater Pump "B" - Quarterly (January 18, 2006)

• PT-3Q, Containment Spray Pump Quarterly Test (January 24, 2006)

• PT-2.8Q, Component Cooling Water Pump Quarterly Test (February 15, 2006)

• PT-16Q-A, Auxiliary Feedwater Pump "A" - Quarterly (February 24, 2006)

• WO 20502387, Replace the 150 Amp Battery Charger "BYCA" with a new 200 Amp Battery Charger per PCR 2004-0046 - March 13-31, 2006

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22 - 5 samples)

a. Inspection Scope

The inspectors witnessed the performance and/or reviewed test data for the following five surveillance tests that are associated with selected risk-significant systems, structures, and components (SSCs) to verify that TS were followed, and that acceptance

criteria were properly specified. The inspectors also verified that proper test conditions

were established as specified in the procedures, that no equipment preconditioning

activities occurred, and that acceptance criteria had been met.*PT-12.1, Emergency Diesel Generator A - Monthly (January 12, 2006)*PT-2.7.1, Service Water Pumps - Quarterly (January 16, 2006)

• PT-36.Q, "D" Standby Auxiliary Feedwater Pump (February 1, 2006)

• PT-2.2Q, Residual Heat Removal (February 6, 2006)

• PT-16.3A, AFW Pump "A" Discharge MOV and Check Valve Test (February 24, 2006)

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications (71111.23 -1 sample)

a. Inspection Scope

The inspectors reviewed the following temporary plant modification to determine whether the temporary change adversely affected syst em or support system availability, or adversely affected a function important to plant safety. The inspectors reviewed the

associated system design bases, including the UFSAR and TS, and assessed the

adequacy of the safety determination screening and evaluation. The inspectors also 11 Enclosure assessed configuration control of the temporary change by reviewing selected drawings and procedures to verify whether appropriate updates had been made. The inspectors

compared the actual installation with the temporary modification documents to determine

whether the implemented change was consistent with the approved documented

modification. The inspectors reviewed the post-installation test results to verify whether

the actual impact of the temporary change had been adequately demonstrated by the

test. The temporary modifications were review ed by the inspectors to verify they were installed in conformance with the instructions contained in procedure IP-DES-3, "Temporary Modifications."*Temporary Modification 2006-0002, Cap Vacuum Breakers 9640E and 9640G on Service Water Piping to SBAFW

b. Findings

No findings of significance were identified.Cornerstone: Emergency Preparedness1EP4Emergency Action Level and Emergency Plan Changes (71114.04 - 1 sample)

a. Inspection Scope

An in-office inspection that reviewed recent changes to the Ginna emergency plan implementing procedures was conducted on January 26, March 1, and March 10, 2006.

These changes were made in accordance with 10 CFR 50.54(q), which the licensee had

determined did not result in a decrease in effectiveness to the Plan and concluded that

the changes continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to

10 CFR 50. During this inspection, the inspector conducted a sampling review of the

changes which could potentially result in a decrease in effectiveness. This review does

not constitute an approval of the changes and, as such, the changes are subject to

future NRC inspection. The inspection was conducted in accordance with NRC

Inspection Procedure 71114, Attachment 4, and the applicable requirements in 10 CFR

50.54(q) were used as reference criteria.

b. Findings

No findings of significance were identified.

12 Enclosure1EP6Drill Evaluation (71114.06 - 1 sample)

a. Inspection Scope

On January 25, 2006, the inspectors observed a licensed operator simulator scenario that included a limited test of the Ginna emergency response plan. Scenario ECA00-06, "Loss of All AC Power," was observed. During the exercise, the crew successfully

classified the event in a timely manner, and the drill was counted as a success in the

Ginna "Drill/Exercise Performance" performance indicator.

b. Findings

No findings of significance were identified.2.

RADIATION SAFETY

===Cornerstone: Occupational Radiation Safety2OS1Access Control to Radiologically Significant Areas (71121.01 - 8 samples)

=

The inspector reviewed radiological work activities and practices and procedural implementation during observations and tours of the facilities and inspected procedures, records, and other program documents to evaluate the effectiveness of Ginna's access

controls to radiologically significant areas. This inspection activity represents the

completion of eight

(8) samples relative to this inspection area (i.e., inspection procedure

sections 02.01, 02.02.f, 02.03.b, c, and d, and 02.05.a, b, and c) and partially fulfills the

annual inspection requirements.

Inspection Planning (02.01)

The inspector verified that site procedures stated that the following types of occurrences required the generation of an incident report: high radiation area non-conformance, very

high radiation (> one rem per hour) area non-conformance, and unintended exposure

occurrence. The inspector reviewed radiation protection incident reports generated

since the last inspection and also discussed experience in this area with the site Senior

Health Physicist responsible for evaluating these type of issues. Based on this

inspection activity, the inspector verified that there were no licensee Performance

Indicator events for the Occupational Exposure Cornerstone which required follow-up.

Plant Walkdowns and RWP Reviews (02.02.f)

During this inspection, the inspector examined the licensee's physical and programmatic controls for highly-activated or contaminated materials (non-fuel) stored within the spent

fuel and other storage pools. The inspector noted that the licensee had incorporated

guidance for this area in numerous procedures, including in the radiation protection 13 Enclosure procedures for labeling radioactive materials, radiation work permits (RWPs), job coverage, and for use of underwater filters and vacuums. The inspector reviewed the

subject procedures (as listed in the List of Documents Reviewed section) to verify the

adequacy of the controls.

Problem Identification and Resolution (02.03.b, c, & d)

The inspector reviewed corrective action reports related to access controls and included in this review any high radiation area radiological events that have occurred since the

last inspection in this area. The inspector discussed the corrective action reports with

several members of the radiological protection staff to determine that the follow-up

activities were being conducted in an effective and timely manner commensurate with

their importance to safety and risk. Also, the inspector reviewed the licensee's self-

assessment activities for any results related to the access control program. The intent of

this review was to determine if identified problems were entered into the corrective

action program for resolution. There were no licensee Performance Indicator (PI) events

or licensee documentation packages for the Occupational Exposure Control

Effectiveness PI which required review.

High Risk-Significant, High Dose Rate HRA and VHRA Controls (02.05.a, b, & c)

During this week of inspection, the inspector discussed, with several members of site radiation protection supervision, including the radiation protection manager (RPM), the

procedural controls for entrances to high-dose-rate high radiation areas (HDR-HRAs)

and very high radiation areas (VHRAs). The inspector reviewed the subject procedures (as listed in the List of Documents Reviewed section) to verify the adequacy of the

controls. During tours of the radiologically-controlled area, the inspector examined the

postings and barriers at selected accessible locations of locked high radiation areas.

The inspector verified adequate posting and locking of the entrances to the selected

locations which were examined.

Related Activities The inspector performed a selective examinati on of documents (as cited in the List of Documents Reviewed section) to evaluate the adequacy of radiological controls. The

review in this area was against criteria contained in 10 CFR 19.12, 10 CFR 20 (Subparts D, F, G, H, I, and J), site Technical Specifications, and site procedures.

b. Findings

No findings of significance were identified.

14 Enclosure2OS2ALARA Planning and Controls (71121.02- 5 required & 2 optional samples)

a. Inspection Scope

The inspector reviewed the effectiveness of the licensee's program to maintain occupational radiation exposure as low as is reasonably achievable (ALARA). This

inspection activity represents the completion of five

(5) required and two

(2) optional

samples relative to this inspection area (i.e., inspection procedure sections 02.01.a & d, 02.03.a, 02.05.a, b*, and c*, and 02.07) and partially fulfills the biennial inspection

requirements.

Inspection Planning (02.01.a & d)

The inspector reviewed the plant collective exposure history for the last three full years (2003 through 2005), the current exposure trends in 2006, and ongoing or planned

activities to reduce individual, work group, and site collective exposure. The inspector

examined the plant's current three-y ear rolling average collective exposure in comparison with industry experience. The inspector also evaluated the adequacy of the

site-specific procedures associated with maintaining occupational exposures ALARA

which included the procedures for radiation work permits, ALARA job reviews, and

ALARA job review preparation. The inspector also reviewed the processes currently

used to estimate and track work-activity-specific exposures.

Verification of Dose Estimates and Exposure Tracking Systems (02.03.a)

During this inspection, the inspector met with the Lead ALARA Technician. During this meeting, the inspector discussed the assumptions and bases for the current annual

collective exposure estimate. This included the estimate for on-line operation and that

for the refueling outage scheduled for this coming October. The inspector also reviewed

the applicable ALARA procedures used for pre-job planning to determine the

methodology employed for estimating work-activity-specific exposures and the intended

dose outcome.

Source-Term Reduction and Control (02.05.a, b*, & c*)

The inspector utilized licensee records to determine the historical trends and current status of tracked plant source terms. The inspector determined that the licensee had

developed an understanding of the plant source-term, including knowledge of input

mechanisms to reduce the source term. This understanding was evidenced in their five-

year ALARA plan and their source term reduction plan. The former included plans for

permanent shielding and permanent scaffolding and improved ALARA processes. The

inspector noted that the radiation protection group was working closely with the

chemistry group to assure that the on-line and shut down chemistry procedures provided

for an appropriate clean-up of the reactor coolant during operation and shut down. A

review of the five-year ALARA plan showed specific actions had been identified, assigned to an owner, and assigned a due date, and the person-rem impact for each

specific action had been estimated.

15 Enclosure Declared Pregnant Workers (02.07)

The inspector determined that there had been no declared pregnant workers during the current assessment period. The inspector verified that adequate procedures and

monitoring controls were in place to implement the requirements of 10 CFR 20.1208, Dose equivalent to an embryo/fetus.

Related Activities The inspector performed a selective examinati on of documents (as cited in the List of Documents Reviewed section) for regulatory compliance and for adequacy of control of

radiation exposure. The review was against criteria contained in 10 CFR 20.1101 (Radiation protection programs), 10 CFR 20.1701 (Use of process or other engineering

controls), and site procedures.

b. Findings

No findings of significance were identified.2OS3Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 2 samples)

a. Inspection Scope

The inspector reviewed the program for health physics instrumentation and protective equipment to determine the accuracy and operability of the instrumentation and of the

personnel protective equipment. This inspection activity represents the completion of

two

(2) samples relative to this inspection area (i.e., inspection procedure sections 02.01

and 02.02) and partially fulfills the biennial inspection requirements.

Inspection Planning (02.01)

The inspector reviewed the plant's Updated Final Safety Analysis Review (UFSAR) and identified applicable radiation monitors associated with transient high and very high

radiation areas including those used in remote emergency assessment. The inspector

identified the appropriate installed area and process radiation monitors, emergency

assessment instrumentation, and portable radiation instruments that are used to identify

changing radiological conditions such that actions to prevent an overexposure may be

taken. The identified monitors, instrum entation, and instruments will be examined in future inspections.

Identify Additional Radiation Monitoring Instrumentation (02.02)

The inspector identified the types of portable radiation detection instrumentation used for job coverage for high radiation area work, types of temporary area radiation monitors

currently used in the plant, and types of continuous air monitors associated with jobs

with the potential for workers to receive fifty millirems of committed effective dose

equivalent (CEDE). The inspector also reviewed the types of whole body counter 16 Enclosure equipment in place and the types of radiation detection instruments utilized for personnel release from the radiologically controlled area.

Related Activities The inspector performed a selective examinati on of documents (as cited in the List of Documents Reviewed section) for regulatory compliance and adequacy in this area.

The review was against criteria contained in 10 CFR 20.1501, 10 CFR 20 Subpart H, site Technical Specifications, and site procedures.

b. Findings

No findings of significance were identified.4.OTHER ACTIVITIES4OA1Performance Indicator Verification.1Initiating Events Cornerstone (71151 - 3 samples)

a. Inspection Scope

Using the criteria specified in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 2, the inspectors verified the

completeness and accuracy of the performance indicator data for unplanned scrams per

7,000 critical hours, scrams with loss of normal heat removal and unplanned power

changes per 7,000 critical hours for calendar year 2005. To verify the accuracy of the

data the inspector reviewed monthly operating reports, NRC inspection reports and

licensee event reports issued during calendar year 2005.

b. Findings

No findings of significance were identified.4OA2Identification and Resolution of Problems

.1 Review of Items Entered into the Corrective Action Program:

As required by Inspection Procedure 71152, "Identification and Resolution of Problems," and in order to help identify repetitive equipment failures or specific human performance

issues for follow-up, the inspectors performed a daily screening of items entered into the

Ginna corrective action program. This review was accomplished by reviewing paper

copies of each condition report (CR) , attending daily screening meetings, and accessing

Ginna's computerized database.

17 Enclosure

.2 Annual Sample: Process for Transitioning Fire Fighting Responsibilities into Operations

Department (71152 - 1 sample)

a. Inspection Scope

The inspectors conducted interviews of operations department personnel and fire fighting personnel, reviewed documents presented (which consisted of project plans and

a task to training matrix of requirements for the transition of fire fighting responsibilities)

and reviewed AR's associated with the current change over of personnel from contractor

fire team to Operations Department employ ees. Records of recent performance to meet training requirements of Appendix R were obtained and reviewed as well as future plans

to ensure that Appendix R requirements will continue to be met by Ginna.

b. Findings and Observations

Introduction

The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix R III.I.3.b which requires that drills shall be performed at regular intervals not

to exceed three months for each shift fire brigade. A review of records for the fourth

quarter of 2005 revealed that four of five shift fire brigades did not drill during that period.

Description

On February 27, 2006, while reviewing Ginna plans for turning over fire brigade responsibilities from a contractor vendor to the Operations Department, the

inspectors requested a copy of fire brigade drill records. The following day a condition

report was written by Ginna personnel that documented a failure to drill four of five shift

fire brigade teams during the fourth quarter of 2005 documenting the failure to conduct

the required fire drills and subsequently the records were delivered to the Resident

Office. A review of the records by the inspectors confirmed the failure to meet the drill

requirement.

Additional review of the documents associated with the turnover plan revealed that the plan as presented was not on schedule and the task to training matrix was still being

developed. No other failures to meet regulatory requirements were noted at the time of

the review.

Analysis:

The inspectors determined that the failure to conduct the fire drills constituted a failure to comply with the requirements of 10 CFR 50 Appendix R III.I.3.b. The finding

was determined to be more than minor because it affects the reliability and capability

objective of the protection against external factors attribute of the Mitigating Systems

Cornerstone. The finding was evaluated using Appendix F of the Significance

Determination Process of Manual Chapter 0609. The issue was determined to fall in the

category of Fire Prevention and Administrative Controls and was assigned a degradation

factor of low which screens directly to green in step 1.3.1 of Appendix F. The finding has

a cross-cutting aspect in Human Performance associated with a poor turnover of

responsibilities and poor management oversight of the turnover process when fire personnel changed jobs.

18 Enclosure Enforcement

10 CFR 50, Appendix R III.I.3.b which requires, in part, that drills shall be performed at regular intervals not to exceed three months for each shift fire brigade.

Contrary to the above, during the fourth quarter of 2005, Ginna failed to drill four of five

shift fire brigades. Because this violation was determined to be of very low safety

significance and entered into the corrective action program in condition report 2006-

0785, it is being treated as a NCV, consistent with section VI.A of the NRC enforcement policy. (NCV 5000244/2006002-03, Missed Fire Brigade Drills).3.Identification and Resolution of Problems - Occupational Radiation Safety (71121)

a. Inspection Scope

The inspector selected six issues identified in the Corrective Action Program (CAP) for detailed review (RP Incident Report Nos. 2005-6717 and -6862 and 2006-0651, -0882, -

0909, and -0923). These issues were associated with a procedural reference to 10 CFR

20.1101( c ), a containment entry exceeding the ALARA estimate, an incident involving

portal monitor alarms, and several equipment contamination events, respectively. The

documented reports for the issues were reviewed to ensure that the full extents of the

issues were identified, appropriate evaluations were performed, and appropriate

corrective actions were specified and prioritized.

b. Findings

No findings of significance were identified. 4OA6Meetings, Including Exit On April 14, 2006, the resident inspectors presented the inspection results to Ms. M.

Korsnick and other members of her staff, who acknowledged the findings. The

inspectors asked the licensee whether any of the material examined during the

inspection should be considered proprietary.

Proprietary information was examined during this inspection, but is not specifically discussed in this report.4OA7Licensee-identified Violations None.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. AdamsManager of OperationsD. BlankenshipManager, Radiation Protection

M. ColemanLORT Training Instructor

M. GallawayManager, Ginna Maintenance

D. HolmPlant Manager

M. KorsnickVice President - Ginna

B. LeonardManager of Nuclear Training

K. MaskerSenior Licensed Instructor

R. PloofDirector Operations Training

B. RandallNuclear Safety and Licensing Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None Opened and Closed5000244/2006002-01NCVInadequate Control of Transient Combustible

Material (Section 1R05)5000244/2006002-02NCVSimulator Incorrectly Replicated Plant Design

5000244/2006002-03NCVMissed Fire Brigade Drills

Closed

None

Discussed

None

Attachment