IR 05000244/2008002

IR 05000244-08-002, on 1/1/2008 - 03/31/2008, R.E. Ginna Nuclear Power Plant (Ginna), Refueling and Other Outage Activities, Identification and Resolution of Problems

ML081210304
Person / Time
Site:	Ginna
Issue date:	04/30/2008
From:	Glenn Dentel Plant Support Branch 1
To:	John Carlin Ginna
Dentel, G RGN-I/DRP/BR1/610-337-5233
References
IR-08-002
Download: ML081210304 (35)

Text

ril 30, 2008

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000244/2008002

Dear Mr. Carlin:

On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your R.E. Ginna Nuclear Power Plant. The enclosed integrated inspection report documents the inspection results, which were discussed on April 9, 2008, with you and members of your staff.

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

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

This report documents that two findings of very low safety significance (Green) were identified.

These findings were also determined to be violations of NRC requirements. However, because of their very low safety significance, and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a written 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. 220555-001; 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 Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket No. 50-244 License No. DPR-18 Enclosure: Inspection Report No. 05000244/2008002 w/ Attachment: Supplemental Information cc w/encl:

M. J. Wallace, President, Constellation Energy Nuclear Group, LLC B. Barron, 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.

B. Weaver, Director, Licensing, Constellation Energy Nuclear Group, LLC P. Tonko, President and CEO, New York State Energy Research and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority G. Bastedo, 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 05000244/2008-002; 1/1/2008 - 03/31/2008; R.E. Ginna Nuclear Power Plant (Ginna),

Refueling and Other Outage Activities, Identification and Resolution of Problems.

The report covered a three-month period of inspection by resident inspectors and region-based inspectors. Two Green 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, because Ginna did not adequately implement scaffolding control procedural requirements related to post-installation inspections and engineering safety evaluations for scaffolding constructed within 1 inch of safety-related equipment,. During a plant walkdown on March 18, 2008, the inspectors identified multiple examples where scaffolding was not installed in accordance with Constellation Energy corporate and site procedures. For example, contrary to step 3.3.8 of Ginna procedure A-1406.1, Requirements for the Installation of Scaffolding, scaffolds were installed within 1 inch of safety-related equipment and did not receive an engineering safety evaluation. Similar scaffold-related issues have occurred over 26 times since July 2007, as documented in CR 2008-0292.

This finding is more than minor because it was associated with the Mitigating System cornerstone attributes of protection against external factors such as a seismic event and equipment performance such as reliability. The finding affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding is of very low safety significance, because the finding is not a design or qualification deficiency, did not represent a loss of a safety function, and did not screen as potentially risk significant due to external events. This finding is similar to example 4.a in Appendix E of IMC 0612, in that Ginna had recurring examples of not performing evaluations for scaffolds constructed within the minimum allowed distance of safety related equipment. The finding has a crosscutting aspect in the area of human performance, in that the Ginna did not effectively communicate expectations regarding work practices to workers constructing scaffolding or to supervisors who routinely monitor these activities to follow procedural requirements (H.4.b). (Section 1R20)

Green.

Inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion XVI,

Corrective Action, when Ginna failed to promptly identify and correct a condition adverse to quality associated with out-of-specification oil samples for the A residual heat removal (RHR) and A safety injection pumps. Specifically, Ginna did not submit the oil samples for analysis for 37 days and when informed of out-of-specification conditions on the A safety injection pump on February 18, 2008, and the issue was not documented or assessed in the Ginna corrective action program until February 25, 2008.

This finding is greater than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstones objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by not promptly assessing the significance of the out-of-specification oil samples, the potential inoperability of the safety injection pump was not evaluated. The inspectors determined that this finding was of very low safety significance (Green), because the finding is not a design or qualification deficiency, did not represent a loss of a safety function, and did not screen as potentially risk significant due to external events. This finding is similar to example 3.k in Appendix E of IMC 0612, in that the oil sample program had programmatic weaknesses that could lead to worse conditions if not corrected. This finding has a cross-cutting aspect in the area of problem identification and resolution because Ginna had not implemented appropriate corrective actions to ensure oil samples that are out-of-specification are promptly assessed (P.1.d per IMC 0305). (Section 4OA2)

Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

R.E. Ginna Nuclear Power Plant (Ginna) began the inspection period operating at full rated thermal power and operated at full power for the entire period.

REACTOR SAFETY

Cornerstones: Mitigating Systems and Barrier Integrity

1R01 Adverse Weather Protection (71111.01 - Two samples)

a. Inspection Scope

On January 9, 2008, for 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, the site experienced strong winds with sustained speeds as high as 55 miles per hour. In accordance with procedure ER-SC.1, Revision 17, Adverse Weather Plan, the site implemented compensatory measures to mitigate the effects of the high wind conditions. At different times throughout this period, the inspectors toured plant buildings and exterior areas of the plant to ensure the applicable portions of ER-SC-1 had been implemented and plant equipment and structures had not been adversely affected by the high wind conditions.

On January 30, 2008, the site again experienced high winds with sustained values in excess of 55 miles per hour. The high winds were an expected condition, and as a result, prior to the event, Ginna personnel had walked down the protected area and the switchyard to ensure material that could become airborne had been tied down. As described in section 4OA3 of this report, during the event, communications with offsite agencies using the Ginna telephone land-line system was disabled for several hours when a falling tree disabled an onsite power line. At different times during this event, the inspectors toured plant buildings and exterior areas of the plant to ensure the applicable portions of ER-SC-1 had been implemented and plant equipment and structures had not been adversely affected by the high wind conditions.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Partial System Walkdown (71111.04Q - Four samples)

a. Inspection Scope

The inspectors reviewed the alignment of system valves and electrical breakers to ensure proper in-service or standby configurations as described in plant procedures, piping and instrument drawings (P&ID) and the updated final safety analysis report (UFSAR). During the walkdown, the inspectors evaluated the material condition and general housekeeping of the system and adjacent spaces. The inspectors also verified that operators were following plant technical specifications (TS) and system operating procedures.

Documents reviewed are listed in the Attachment.

The following plant system alignments were reviewed:

• On January 1, 2008, the inspectors performed a walkdown of the C train of the standby auxiliary feedwater (SAFW) system before the B auxiliary feedwater (AFW) pump and the steam driven AFW pump were removed from service to conduct planned surveillance activities;

• On January 24, 2008, the inspectors performed a walkdown of the A train of the RHR system following the completion of surveillance testing activities;

• On February 6, 2008, the inspectors completed a walkdown of the A train of the boric acid system following the completion of maintenance activities; and

• On February 11, 2008, the inspectors completed a walkdown of the auxiliary building ventilation system before the completion of planned maintenance and surveillance testing activities.

b. Findings

No findings of significance were identified.

.2 Complete Walkdown (71111.04S - One sample)

a. Inspection Scope

The inspectors performed a detailed walkdown of the instrument air (IA) system to identify any discrepancies between the existing equipment lineup and the specified lineup. The IA system was chosen because of its risk significant function to provide valve operations in containment during accident scenarios and control of secondary cooling functions. In addition, loss of the IA system is an accident initiator within the Ginna probabilistic risk analysis model. The inspectors verified proper system alignment as specified by the UFSAR and Ginna procedures and drawings. Documentation associated with open maintenance requests and design issues were reviewed and included items tracked by plant engineering to assess their collective impact on system operation. In addition, the inspectors reviewed the associated corrective action (CR) database to verify that any equipment alignment problems were being identified and appropriately resolved.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Quarterly Inspection (71111.05Q - Six samples)

a. Inspection Scope

The inspectors performed walkdowns of fire areas to determine if there was adequate control of transient combustibles and ignition sources. The material condition of fire protection systems, equipment and features, and the material condition of fire barriers were inspected against Ginnas licensing basis and industry standards. In addition, the passive fire protection features were inspected including the ventilation system fire dampers, structural steel fire proofing, and electrical penetration seals. Documents reviewed are listed in the Attachment. The following plant areas were inspected:

• Cable Tunnel (Fire Area CT);

• Charging Pump Room (Fire Area CHG);

• Auxiliary Building Operating Floor 271 (Fire Zone ABO);

• Intermediate Building 253 (Fire Zone IBS-1);

• Intermediate Building 271 (Fire Zone IBS-2); and

• Intermediate Building 298 (Fire Zone IBS-3).

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures (71111.06 - One sample)

a. Inspection Scope

The inspectors evaluated Ginnas internal flood protection measures for the intermediate building hot side elevations 253, 271, and 298. These areas contain ventilation systems for the auxiliary building, intermediate building, potentially contaminated portions of the service building, as well as containment penetrations for several systems including the post-accident sampling system. To perform this evaluation, the inspectors reviewed Ginnas UFSAR, piping drawings for the intermediate building sump and adjacent systems, work orders, and the site repetitive task database, and toured applicable areas.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review (71111.11Q - One sample)

a. Inspection Scope

On January 29, 2008, the inspectors observed a licensed operator simulator scenario, FRH1-04, Loss of Heat Sink Feed and Bleed Recovery. 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, Revision 43, Simulator Examination Instructions. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 Annual Review (71111.11 - One sample)

a. Inspection Scope

On February 19, 2008, the inspectors performed an in-office review of Ginna operator requalification exam results. These results included the annual operating tests administered for 2007. The inspection assessed whether pass rates were consistent with the guidance of NRC IMC 0609, Appendix I, AOperator Requalification Human Performance SDP. The inspectors verified that:

• Crew failure rate was less than 20 percent. (Failure rate was 0 percent);

• Individual failure rate on the dynamic simulator test was less than or equal to 20 percent. (Failure rate was 9.1 percent);

• Individual failure rate on the walkthrough test was less than or equal to 20 percent.

(Failure rate was 0 percent);

• Individual failure rate on the comprehensive biennial written exam was less than or equal to 20 percent. (Failure rate was 5.7 percent); and

• More than 75 percent of the individuals passed all portions of the exam (90.9 percent of the individuals passed all portions of the exam).

As per Ginnas program, individuals failing any portion of the requalification examination are put through remediation training and must pass a retest before being returned to shift.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q - Three samples)

a. Inspection Scope

The inspectors evaluated work practices and follow-up corrective actions for selected system, structure, or component (SSC) issues to assess the effectiveness of Ginnas maintenance activities. The inspectors reviewed the performance history of those SSCs and assessed extent-of-condition determinations for those issues with potential common cause or generic implications to evaluate the adequacy of corrective actions. The inspectors reviewed Ginnas problem identification and resolution actions for these issues to evaluate whether the station had appropriately monitored, evaluated, and dispositioned the issues in accordance with procedures and the requirements of 10 CFR Part 50.65, Requirements for Monitoring the Effectiveness of Maintenance. In addition, the inspectors reviewed selected SSC classification, performance criteria and goals, and corrective actions that were taken or planned to verify whether the actions were reasonable and appropriate. Documents reviewed are listed in the Attachment.

The following issues were reviewed:

• Instrument air (IA) system compressor lube oil deficiencies, service and IA system interconnection failures, and IA containment penetration deficiencies;

• Turbine control circuit card capacitors in service for greater than designed replacement life of the components with similar conditions existing with the capacitors on circuit cards in the emergency diesel generator output control circuitry; and

• Repetitive failures of charging pump discharge relief flex hoses.

b. Findings

No findings of significance were identified.

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

a. Inspection Scope

The inspectors evaluated the effectiveness of Ginnas maintenance risk assessments specified by paragraph a(4) of 10 CFR Part 50.65. The inspectors discussed with control room operators and scheduling department personnel the use of the stations 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 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, Revision 20, which was the governing procedure in effect at the time of the inspection activities. Documents reviewed are listed in the Attachment.

Risk assessments for the following out-of-service SSCs were reviewed:

• Unplanned outage of the A coolant charging pump (CCP) during routine maintenance on the vari-drive for the A CCP while the plant was experiencing high winds and during a scheduled plant process computer system outage (January 9, 2008);

• Unplanned loss of the rod deviation monitor alarm for one rod while normal maintenance and plant evolutions continued with the rod position alarm function inoperable (January 23, 2008);

• Planned maintenance on the reactor safety electrical bus under voltage relays while the plant was in adverse weather conditions under ER-SC.1 (January 30, 2008);

• Unplanned maintenance on the A spent fuel pool cooling pump because an oil sample identified potentially excessive bearing wear (March 7 and 8, 2008); and

• Calibration of turbine driven auxiliary feedwater pump flow indicator while the Technical Support Center diesel generator was out of service (March 11, 2008).

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - Six samples)

a. Inspection Scope

The inspectors reviewed operability evaluations and/or condition reports (CRs) in order to verify that the identified conditions did not adversely affect safety system operability or plant safety. The evaluations were reviewed using criteria specified in NRC Regulatory Issue Summary 2005-20, Revision to Guidance formerly contained in NRC Generic Letter 91-18, Information to Licensees Regarding two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability and Inspection Manual Part 9900, Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety.

In addition, where a component was inoperable, the inspectors verified the TS limiting condition for operation implications were properly addressed. The inspectors also reviewed the following operability evaluations to determine if system operability was properly justified in accordance with CNG-OP-1.01-1002, Conduct of Operability Determinations/Functionality Assessments, Revision 0. Documents reviewed are listed in the Attachment.

The inspectors performed field walkdowns, interviewed personnel, and reviewed the following items:

• CR 2007-8854, Operability of main turbine vibration monitoring system with the number nine bearing monitor inoperable;

• CR 2008-0654, Flood barrier safety notice;

• CR 2008-0744, Unclear if past EDG controlotron calibration status should have resulted in questioning EDG operability status;

• CR 2008-0520, Train A superheat one to two degrees below acceptance criteria;

• CR 2008-1147, Increase in leakage on A MDAFW pump inboard pump packing/seal;

• CR 2008-2030, Nonconforming condition with locked rotor analysis.

b. Findings

No findings of significance were identified.

1R18 Plant Modifications (71111.18 - Two samples)

.1 Temporary Modification (One sample)

a. Inspection Scope

The inspectors reviewed temporary plant modification 2007-0018, Removal of EDG A Fuel Oil Level Gauge LG-2040 in Tank Hardware, to determine whether the temporary change adversely affected 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 assessed configuration control of the temporary change by reviewing selected drawings and procedures to verify whether appropriate updates had been made. The inspectors compared the actual installation with the temporary modification documents to determine whether the implemented change was consistent with the approved, documented modification. The temporary modification was reviewed by the inspectors in the field to verify it had been installed in conformance with the instructions contained in procedure IP-DES-3, Revision 19, Temporary Modifications.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 Permanent Modification (One Sample)

a. Inspection Scope

The inspectors reviewed plant change record (PCR) 2005-0033, Fuel Transfer System Upgrades, which is being installed in several phases during calendar year 2008. The portion of the modification reviewed under this scope involved modifications to the transfer cart and fuel transfer operating equipment on the spent fuel pool side of the system.

Further modifications are planned during the refueling outage in April 2008. The inspectors reviewed the PCR to ensure that replacement components are consistent with design basis and were compatible with installed system structures and components. The inspectors observed actions taken by personnel to complete the modification and test the resultant configuration.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19 - Five samples)

a. Inspection Scope

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

The inspectors assessed each tests adequacy by comparing the test methodology to the scope of maintenance 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 TS requirements. The inspectors reviewed the recorded test data to determine whether the acceptance criteria were satisfied. Documents reviewed are listed in the Attachment.

The following PMT activities were reviewed:

• PT-2.1Q, Safety Injection System Quarterly Test, Rev. 58, following minor pump maintenance on the A SI Pump and inspections in support of license renewal under WO 20702023, Perform a One-Time Visual Inspection of the Internal Surfaces of the A Safety Injection Pump Outboard Bearing Cooler (January 7, 2007);

• Operational retest of A coolant charging pump after repairs to the vari-drive (air controlled variable drive) unit, under WO 20800141, Repair/Replace Loose Bolt on the A Charging Pump (PCH01A), when two bolts broke during normal in-service operation of the pump (January 10, 2008);

• PT-2.2Q, RHR System-Quarterly, Rev. 3101, following functional equipment group maintenance period for the A RHR pump involving several work orders including breaker replacement and pump lubrication (January 22, 2008);

• PT-31, Charging Pump In-service Test, Rev. 5201, following a major rebuild of the charging pump vari-drive unit as part of a planned maintenance activity under WO 20701801, Charging Pump A Vari-drive Overhaul (March 7, 2008); and

• PT-16Q-T, Auxiliary Feedwater Turbine Pump-Quarterly, Rev. 56, following a functional equipment group maintenance window during which several valves were worked and instruments were calibrated under several orders (March 12, 2008).

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

This entry documents the initial inspection efforts associated with Ginnas refueling outage that is scheduled for the second quarter of 2008 but does not document a completed sample under the inspection procedure. The inspectors toured the plant and examined scaffolding that had been installed to support outage-related activities. The purpose of the review was to verify that the scaffolding had been installed in accordance with corporate and site procedures. A particular focus of the review was to ensure that scaffolding installation did not adversely impact plant equipment.

b. Findings

Introduction:

The inspectors identified a finding of very low safety significance involving a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Ginna did not adequately implement scaffolding control procedural requirements related to post-installation inspections and engineering safety evaluations for scaffolding constructed within 1 inch of safety-related equipment.

Description:

On March 18, 2008, during a walkdown of scaffolding installed to support RFO activities, the inspectors identified multiple examples where scaffolding was not installed in accordance with Constellation Energy corporate and site procedures. For example, contrary to step 3.3.8 of Ginna procedure A-1406.1, Requirements for the Installation of Scaffolding, Revision 3701 scaffolds had been installed within 1 inch of safety-related equipment without having received an engineering safety evaluation on the containment spray, steam driven auxiliary feedwater, and fire main systems. In other instances, scaffolds were installed but not inspected in accordance with A-1406.1 or corporate procedure CNG-MN-1.01-1005, Scaffolding Control, Revision 100. Examples include scaffolding installed in the clean side of the intermediate building to support maintenance on the main steam and feedwater systems. These issues were subsequently identified in CRs 2008-2071/2072/2075. Ginna corrective actions included inspecting the scaffolding that had been installed, modifying it where appropriate, and posting the scaffold acceptability.

Over the past two years, there have been numerous instances where the inspectors and Ginna personnel have identified scaffolding that has not been installed in accordance with corporate and site procedures. For example, as identified in CR 2008-0292, since July 2007 there have been 26 CRs that have identified deficiencies regarding scaffolding installation. An apparent cause evaluation concluded that inadequate procedure guidance contributed to the improper installation of scaffolding; and as a result, procedure A-1406.1 was revised.

The inspectors concluded that based on the scaffolds that were installed in the plant after the procedure change became effective, the procedure was not effectively implemented.

The inspectors determined that the performance deficiency was that Ginna did not adequately implement the scaffolding control requirements in A-1406.1 and CNG-MN-1.01-1005.

Analysis:

The inspectors determined that this finding is more than minor because it was similar to example 4.a in Appendix E of IMC 0612, in that Ginna had recurring examples of not performing evaluations for scaffolds constructed within the minimum allowed distance of safety related equipment. This finding is associated with the external factors and equipment performance attributes of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the significance of this finding using Phase 1 of the IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. The inspectors determined that the finding was of very low safety significance (Green),because the finding is not a design or qualification deficiency, did not represent a loss of a safety function, and did not screen as potentially risk significant due to external events.

The finding has a cross-cutting aspect in the area of human performance, in that the Ginna did not effectively communicate expectations regarding work practices to workers constructing scaffolding or to supervisors who routinely monitor these activities to follow procedural requirements (H.4.b).

Enforcement:

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures. Ginna procedure A-1406.1, Requirements for the Installation of Scaffolding, and corporate procedure CNG-MN-1.01-1005, Revision 100, Scaffolding Control are procedures affecting quality that establish post-installation inspections, labeling, and the minimum clearance between scaffolds and plant equipment without engineering evaluations. Contrary to the above, on March 18, 2008, the inspectors identified multiple examples in safety-related systems in which installed scaffolds failed to meet specifications for post-installation inspections, labeling, and the minimum clearance between scaffolds and plant equipment without engineering evaluations. Because this issue is of very low safety significance (Green) and Ginna entered this issue into their corrective actions program (CAP) as CRs 2008-2071/2072/2075, this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000244/2008002-01: Did Not Implement Scaffolding Procedure Requirements)

1R22 Surveillance Testing (71111.22 - Eight samples)

a. Inspection Scope

The inspectors observed the performance and/or reviewed test data for the following surveillance tests that are associated with selected risk-significant SSCs to verify that TSs were followed and that acceptance criteria were properly specified. The inspectors also verified that proper test conditions were established as specified in the procedures, no equipment preconditioning activities occurred, and acceptance criteria were met.

Documents reviewed are listed in the Attachment.

• WO 20704171, Calibrate [Instrument Air] Pressure Switches PS-2090 and PS-2091, Rev. 0 (January 2, 2008)

• PT-13.4.40, TSC HVAC Charcoal Filter Deluge System S31, Rev. 13 (January 3, 2008). Test included an aging management inspection.

• WO 20702791, Perform Weekly Checks at [Swichyard] Station 13A, Rev. 13 (January 4, 2008)

• STP-O-12.1, Emergency Diesel Generator A, Rev. 2 (January 8, 2008)

• PT- 2.1S, A, B, and C Safety Injection Pump Service Water Cooler Flow Check, Rev.

7 (January 11, 2008)

• A-54.7, Fire Protection Tour, Rev. 31 (February 6, 2008)

• STP-O-2.9, Check Valve and Manual Valve Exercising, Rev. 1 (March 12, 2008)

• CH-PRI-SAMP-Room, [RCS Sample], Rev. 14 (March 24, 2008)

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06 - One sample)

a. Inspection Scope

On January 29, 2008, the inspectors observed a licensed operator simulator scenario, FRH1-04, Loss of Heat Sink Feed and Bleed Recovery, that included a limited test of Ginnas emergency response plan. The inspectors verified that emergency classification declarations and notifications were completed in accordance with 10 CFR Part 50.72, 10 CFR Part 50 Appendix E, and emergency plan implementing procedures.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety (OS)

2OS1 Access Control to Radiologically Significant Areas (71121.01 - Nine samples)

a. Inspection Scope

From February 11 to 15, 2008, the inspectors conducted the following activities to verify that Ginna was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas (LHRA), and other radiologically controlled areas (RCA) during normal power operations and workers were adhering to these controls when working in these areas. Implementation of these programs was reviewed against the criteria contained in 10 CFR 20, TS, and Ginnas procedures.

Inspection Planning, Plant Walkdown, and Radiation Work Permits (RWP) Reviews The inspectors reviewed all performance indicators (PIs) for the Occupational Radiation Safety cornerstone for follow-up. The inspectors identified exposure-significant work areas and reviewed associated Ginna controls, surveys, postings, and barricades for acceptability. The inspectors toured accessible RCA, and with the assistance of a radiation protection technician, performed independent radiation surveys of selected areas and components to confirm the accuracy of survey data and the adequacy of postings.

Problem Identification and Resolution The inspectors reviewed Ginnas self assessments, audits, and special reports related to the access control program since the last inspection to determine if identified problems were entered into the Corrective Action Program. The inspectors reviewed seven CRs related to access control to ensure follow-up actions were timely and effective.

High Radiation Area and Very High Radiation Area Controls The inspectors discussed with radiation protection technicians and supervision the controls in place for special areas that are or have the potential to become very high radiation areas (VHRA) during certain plant operations. The inspectors verified the key controls and the integrity of 12 of 13 locks to locked high radiation areas.

Radiation Worker and Radiation Protection Technician Performance Three radiologically related CRs were reviewed to evaluate if the incidents were caused by repetitive radiation worker errors and to determine if an observable pattern traceable to a similar cause was evident. The inspectors observed the performance of a radiation protection technician and questioned the technician regarding knowledge of plant radiological conditions and associated controls.

b. Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02 - Five samples)

a. Inspection Scope

From February 11 to 15, 2008, the inspectors performed the following activities to verify that Ginna was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as reasonably achievable (ALARA) for activities performed during routine plant operation. Implementation of these controls was reviewed against criteria contained in 10 CFR 20, applicable industry standards, and Ginnas procedures.

Inspection Planning

The inspectors reviewed pertinent information regarding cumulative exposure history, current exposure trends, and ongoing activities to assess preparations for the upcoming RFO and current exposure trends. The inspectors reviewed Ginnas 3-year rolling average dose and compared Ginnas average with the industry average. The inspectors verified that Ginnas ALARA program procedure and the radiation work permit procedure include job estimating and tracking.

Source Term Reduction and Control The inspectors reviewed the status and historical trends of source terms. The addition of macro porous resin to the letdown mixed bed has decreased the site source term. Dose rates on plant piping have trended down since the new resin was implemented.

Problem Identification and Resolution The inspectors reviewed audits, self assessments, and the quarterly report for the fourth quarter of 2007 to verify identified problems are put in the corrective action program. The inspectors reviewed elements of the Corrective Action Program related to implementing the ALARA program to determine if problems were being entered into the program for timely resolution. Five CRs related to dose/dose rate alarms, programmatic dose challenges, and the effectiveness in predicting and controlling worker dose were reviewed.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

.1 Cornerstone: Initiating Events

a. Inspection Scope

(71151 - Three samples)

Using the criteria specified in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, the inspectors verified the completeness and accuracy of the PI data for calendar year 2007 for unplanned scrams per 7,000 critical hours, unplanned power changes per 7,000 critical hours and unplanned scrams with complications. To verify the accuracy of the data, the inspectors reviewed monthly operating reports, NRC inspection reports, and Ginna event reports issued during 2007.

b. Findings

No findings of significance were identified.

.2 Cornerstone: Barrier Integrity

a. Inspection Scope

(71151 - One sample)

The inspectors reviewed Ginna's operations logs and chemistry surveillance records to verify the accuracy of data reported under the Reactor Coolant System (RCS) Specific Activity PI. The inspectors used the guidance provided in NEI 99-02, Revision 5, to assess the accuracy of Ginnas collection and reporting of the PI data. The inspectors also observed chemistry sampling and analysis surveillance activities which determine the RCS specific activity reported under this PI. PI data reviewed for the RCS specific activity encompassed the period from July 2007 until February 2008.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Continuous Review of Items Entered into the Corrective Action Program (71152 - One

sample)

a. Inspection Scope

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 condition reports, periodic attendance at daily screening meetings, and accessing Ginnas computerized corrective action database.

b. Findings

No findings of significance were identified.

.2 Annual Sample - Time Requirements for Operator Action During Steam Generator Tube

Rupture Events (71152 - One sample)

a. Inspection Scope

The inspectors reviewed the actions taken by Ginna to address discrepancies between the time requirements listed in the Updated Final Safety Analysis Report (UFSAR) and the results of timed steam generator tube rupture (SGTR) scenarios conducted in the Ginna simulator. The inspectors reviewed the results of six scenarios run in the simulator that mimicked the UFSAR Chapter 15 SGTR safety analysis for steam generator (SG) overfill and mass analyses. The review evaluated both the times to perform operator actions discussed in the UFSAR and when the actions were performed within the event timeline.

In addition, the inspectors interviewed operations department and engineering department personnel to determine what corrective actions were completed and where planned to address discrepancies between the safety analysis assumptions and the simulator results.

In addition, the inspectors walked down areas of the plant where operator actions are performed to determine if operators could perform the actions described in the UFSAR.

Documents reviewed are listed in the Attachment.

b. Findings and Observations

No findings of significance were identified. The inspectors concluded that for the mass release analysis, all critical operator actions were accomplished within the safety analysis timeframe. However, for the SG overfill analysis, the inspectors found that operations crews did not meet some time-critical requirement assumptions in the safety analysis.

The inspectors reviewed Ginnas assessment of the impact of the slower operator times and agreed with Ginnas determination that the safety analysis conclusion, that the SG would not be overfilled during the event, remained valid. In addition, the inspectors found that Ginna had performed several corrective actions to address the time discrepancies, including training and procedure revisions, and had other corrective actions planned. The inspectors also noted that following the completion of some corrective actions, Ginna operators, in a subsequent simulator scenario, performed all actions described in the UFSAR for the SGTR within the assumed timeframe.

The inspectors concluded that the initial failures were a result of the SGTR procedure not providing specific guidance or direction to the operators commensurate with their level of training to ensure that time-critical actions were accomplished within the UFSAR safety analysis timeframes. The inspectors determined that the inadequacies associated with Emergency Operator Procedure E-3, Revision 41, Steam Generator Tube Rupture, was a violation of 10 CFR Part 50, Appendix B , Criterion V, Instructions, Procedures, and Drawings. The inspectors concluded that this was a minor violation because implementation of the procedure, as written, ensured the SG did not overfill.

.3 Annual Sample - Lubricating Oil Sample Program Review (71152 - One Sample)

a. Inspection Scope

The inspectors reviewed actions taken by the plant staff to address a number of issues related to the oil sample program in Ginnas corrective action program. These issues appeared following the disbanding of the performance monitoring group in April 2006 as part of a station-wide organizational realignment. The performance monitoring group had been responsible for the oil sample program. The issues reviewed by the inspectors included the slow analyses and assessments of sample results, and weaknesses in the scheduling and tracking of samples. Untimely review and assessment of oil sample results has been a recurring problem at Ginna. For example, when out-of-specification conditions were identified on the B safety injection pump in June 2006, Ginna personnel did not examine the A and C safety injection pumps to determine if similar conditions existed until prompted by the inspectors. This condition was documented in CR 2006-2589.

The inspector reviewed CRs that documented issues associated with the sample program and the governing procedure for the sample program to determine if the issues identified in the CRs were properly addressed by corrective actions. Plant personnel who were involved in the lubricating oil sample program were also interviewed. Oil sample results for the A safety injection, A RHR, and A spent fuel pool cooling pumps taken in January and February 2008 were also reviewed. To verify oil samples and sample requirements were documented in the work control documents, the inspectors examined a work package that involved taking an oil sample on the A safety injection pump. The inspection also included a review of the station computer database that tracks the type of lubrication oil used in plant safety-related and non-safety equipment.

b. Findings and Observations

Introduction:

The inspectors identified a finding of very low safety significance (Green)involving a non-cited violation of 10 CFR 50, Appendix B, Criterion XVl, Corrective Action, in that Ginna did not promptly identify and assess out-of-specification lubricating oil sample results for the A RHR and A safety injection pumps. As a result, the operability of the pumps was not assured until additional analysis was conducted by Ginnas engineering staff.

Description:

The lubricating oil for the safety injection and RHR pumps is periodically sampled by Ginna as part of an equipment diagnostic monitoring program. Analysis of the sample results is performed by a third party vendor. The inspectors noted that oil samples taken on the A safety injection and RHR pumps had not been sent out for analysis; and when out-of-specification conditions were identified by the vendor, the significance of the condition was not assessed. For example, on January 7, 2008, oil samples were taken from the inboard and outboard bearings on the A safety injection pump as part of a routine surveillance procedure. However, the samples were not sent out to a vendor for analysis until February 13, 2008. This action occurred only after the inspectors inquired about the status of the safety injection pump samples. The sample analysis results were provided to Ginna on February 18, however, evaluation of out-of-specification conditions on both bearings due to high particulates was delayed, as results were not documented or assessed in the CRs until February 25, 2008, when the inspectors inquired about the test results. Similar, untimely review and analysis was also noted by the inspectors for an oil sample taken on January 22, 2008, for the A RHR pump. This oil sample was also found to have out-of-specification conditions.

To correct out-of-specification conditions, Ginna replaced the degraded oil and increased the frequency of oil sampling for the pumps. A subsequent engineering evaluation determined that the operability of the pumps had not been affected by the high particulate condition.

Analysis:

This finding is greater than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstones objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by not promptly assessing the out-of-specification conditions, the potential inoperability of the safety injection and RHR pumps was not addressed. The inspectors determined that this finding was of very low safety significance (Green), because the finding was not a design or qualification deficiency, did not represent a loss of a safety function, and did not screen as potentially risk significant due to external events. This finding is also similar to example 3k in Appendix E of IMC 0612, in that the oil sample program had programmatic weaknesses that could lead to worse conditions if not corrected.

This finding has a cross-cutting aspect in the area of problem identification and resolution, because Ginna did not implement appropriate corrective actions to ensure oil sample results that are out of specification are promptly assessed (P.1.d per IMC 0305).

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that conditions adverse to quality shall be promptly identified and corrected. Contrary to the above, Ginna did not promptly identify out-of-specification lubricating oil conditions for the A safety inspection and A RHR pumps, in that sample were not sent for analysis for 37 days and the abnormal results, available to the site on February 18, 2008, were not put into the Corrective Action Program until prompted by the inspectors on February 25, 2008.

Because this issue is of very low safety significance and has been entered into Ginnas corrective action program (CR 2008-1421/430), this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy.

(NCV 05000244/2008004-02, Failure to Promptly Identify and Correct Out-of-Specification Lubricating Oil Conditions.)

4OA3 Event Follow-up

.1 Loss of Routine Communications Capabilities to Off-site Agencies or Personnel (71153 -

One sample)

a. Inspection Scope

On January 30, 2008, the inspectors responded to a loss of off-site communications capability. The site had experienced sustained high winds in excess of 55 miles per hour beginning the morning of January 30; and at 7:06 a.m., entered ER-SC.1, Revision 1700, Adverse Weather Plan. Subsequently at 7:42 a.m., the Sodus Line, which powers the site training center and a few other non-critical buildings, was lost (it was determined later that a cracked power line pole in the owner-controlled area was the cause). The site entered ER-ELEC.9, Revision 700, Loss of Sodus Line Ckt 5241. In concert with the failure of the Sodus Line, a natural gas, back-up generator, designed to power the site phone relay system, failed to start and carry phone electrical loads for the duration of the outage. Procedure ER-ELEC.9 did not prompt verification of successful start of the generator. The battery back-up system to the generator supplied power to the phone system until depleted at approximately at noon. The control room became aware of the failure at 12:20 p.m. and declared an unusual event (UE) at 12:30 p.m. The UE was declared based on failure to meet Emergency Action Level (EAL) criteria 7.3.2, Loss of all communications capability affecting the ability to either: perform routine operations OR notify offsite agencies or personnel.

The Sodus Line was restored at 2:01 p.m. The technical support center (TSC) assumed command and control at 2:05 p.m. and supervised the recovery of the phone system and restoration of the back-up generator. The TSC was staffed with minimum manning but a full-incident response team was formed in the operations control center. The control card for the automatic function of the back-up generator for the phone system was replaced, and the generator was retested and restored to its back-up status. The UE was exited at 8:15 p.m. The plant remained at full power and safety systems were unaffected during the event.

The inspectors had initially responded to the high winds prior to 7:00 a.m. and completed walkdowns in the protected area early on the morning of January 30. The inspectors observed control room activities related to problem analysis and event declaration. Later, the inspectors manned a phone in the TSC for the duration of the event to provide information to the regional staff. The inspectors conducted walkdowns of the plant throughout the event to verify actions were in place to minimize plant transients and trip risks while communication capabilities were at reduced capacity.

b. Findings

No findings of significance were identified.

.2 Auxiliary Building Fire (71153 - One sample)

a. Inspection Scope

On January 20, 2008, at 3:34 a.m., operations personnel were investigating a problem associated the heat trace circuitry for the boric acid system in the auxiliary building, and the control room received a fire alarm in the auxiliary building mezzanine east cable tray area. The fire brigade responded to the area, and noticed smoke and charred insulation on a section of boric acid piping located adjacent to the cable tray detector. The damage was caused by a failed heat trace system.

The fire was extinguished and declared out at 3:48 a.m. when breakers that supplied power to the failed heat trace system tripped. The fire brigade did not have to apply any extinguishing agents to the damaged insulation.

The inspectors toured the auxiliary building and examined the section of boric acid piping where the heat trace equipment had failed. Although insulation that surrounded the piping was visibly charred, the piping and adjacent areas were undamaged. The inspectors interviewed shift personnel who were involved in the event and reviewed Ginnas emergency plan.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On April 9, 2008, the inspectors presented the inspection results to Mr. John Carlin and members of his staff, who acknowledged the findings. The inspectors verified that none of the material examined during the inspection was considered proprietary in nature.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Ginna Personnel

J. Carlin Vice President, Ginna

D. Blankenship Manager, Radiation Protection

D. Dean Assistant Operations Manager (Shift)

M. Giacini Scheduling Manager

E. Hedderman Chemistry Supervisor

D. Holm Plant Manager

J. Jones Emergency Preparedness Manager

J. Pacher Manager, Nuclear Engineering Services

B. Weaver Nuclear Safety and Licensing Manager

J. Yoe Manager of Operations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000244/2008002-01 NCV Did Not Implement Scaffolding Procedure Requirements

05000244/2008002-02 NCV Failure to Promptly Identify and Correct Out-of-Specification Lubricating Oil Conditions