IR 05000244/2008003

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July 25, 2008

Mr. John Vice President, R.E. Ginna Nuclear Power Plant R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519

SUBJECT: R.E. GINNA NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000244/2008003

Dear Mr. Carlin:

On June 30, 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 July 14, 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 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 one NRC-identified and two self-revealing findings of very low safety significance (Green). Two of these findings were 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. 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 and 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 2 NRC's 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 Projects Branch 1 Division of Reactor Projects Docket No. 50-244 License No. DPR-18

Enclosure:

Inspection Report No. 05000244/2008003 w/

Attachment:

Supplemental Information

cc w/encl: M. J. Wallace, Vice - President, Constellation Energy B. Barron, President, CEO & Chief Nuclear Officer, Constellation Energy Nuclear Group, LLC P. Eddy, Electric Division, NYS Department of Public Service C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law C. Fleming, Esquire, Senior Counsel, Nuclear Generation, Constellation Nuclear Energy Nuclear Group, LLC D. Wilson, Director, Licensing, R.E. Ginna Nuclear Plant , 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

3 NRC's 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 Projects Branch 1 Division of Reactor Projects Distribution w/encl: S. Collins, RA M. Dapas, DRA D. Lew, DRP J. Clifford, DRP S. Williams, RI OEDO R. Nelson, NRR D. Pickett, PM, NRR B. Vaidya, PM, NRR G. Dentel, DRP N. Perry, DRP J. Hawkins, DRP K. Kolaczyk, DRP, Senior Resident Inspector M. Marshfield, DRP, Resident Inspector H. Jones, DRS M. Rose, DRP, Resident OA Region I Docket Room (with concurrences)

ROPreports@nrc.gov (All IRs)

SUNSI Review Complete___NSP_____ (Reviewer's Initials) DOCUMENT NAME: T:\DRP\BRANCH1\Ginna\Reports\2008-003\2008-003 Draft Shell.doc After declaring this document "An Official Agency Record" it will be released to the Public. ML082110555 To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRP RI/DRP RI/DRP NAME *KKolaczyk/MJM For NPerry/NSP GDentel/GTD DATE 07/24/08 07/24/08 07/25/08 *Concurrence received via telecon OFFICIAL RECORD COPY 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I

Docket No.: 50-244

License No.: DPR-18

Report No.: 05000244/2008003

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

Facility: R.E. Ginna Nuclear Power Plant

Location: Ontario, New York Dates: April 1, 2008 through June 30, 2008

Inspectors: K, Kolaczyk, Senior Resident Inspector M. Marshfield, Resident Inspector K. Mangan, Senior Reactor Inspector M. Modes, Senior Reactor Inspector N. Perry, Senior Emergency Response Coordinator K. Young, Senior Reactor Inspector H. Jones, Reactor Inspector R. Rolph, Health Physicist

Approved by: Glenn T. Dentel, Chief Projects Branch 1 Division of Reactor Projects 2 Enclosure

SUMMARY OF FINDINGS

.........................................................................................................3

REPORT DETAILS

.....................................................................................................................5

REACTOR SAFETY

...........................................................................................................5 1R01 Adverse Weather Protection ...............................................................................5 1R04 Equipment Alignment .........................................................................................6 1R05 Fire Protection ....................................................................................................7 1R07 Heat Sink Performance ......................................................................................8 1R08 Inservice Inspection Activities .............................................................................8 1R11 Licensed Operator Requalification Program .......................................................9 1R12 Maintenance Effectiveness .................................................................................9 1R13 Maintenance Risk Assessments and Emergent Work Control ..........................10 1R15 Operability Evaluations .....................................................................................11 1R18 Plant Modifications ............................................................................................11 1R19 Post-Maintenance Testing ................................................................................12 1R20 Refueling and Other Outage Activities ..............................................................13 1R22 Surveillance Testing .........................................................................................16 1EP2 Alert and Notification System Evaluation...........................................................16 1EP3 Emergency Response Organization Staffing and Augmentation System..........17 1EP4 Emergency Action Level and Emergency Plan Changes...................................18 1EP5 Correction of Emergency Preparedness Weaknesses......................................19

RADIATION SAFETY

.......................................................................................................19 2OS1 Access Control To Radiologically Significant Areas ..........................................19 2OS2 ALARA Planning and Controls ..........................................................................20 2OS3 Radiation Monitoring Instrumentation and Protective Equipment ......................23

OTHER ACTIVITIES

.........................................................................................................23

4OA1 Performance Indicator Verification ....................................................................23 4OA2

Identification and Resolution of Problems .........................................................24

4OA3 Followup of Events and Notices of Enforcement Discretion ..............................26 4OA5

Other Activities...................................................................................................27

4OA6 Meetings, Including Exit.....................................................................................29

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

..................................................................................................A-1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

......................................................A-1

LIST OF DOCUMENTS REVIEWED

......................................................................................A-1

LIST OF ACRONYMS


.A-10

Enclosure

SUMMAR Y
OF [[]]
FINDIN [[]]

GS

IR 05000244/2008003; 04/01/2008 - 06/30/2008; R.E. Ginna Nuclear Power Plant (Ginna),

Refueling and Other Outage Activities, Emergency Response Organization Staffing and

Augmentation System, and

ALA [[]]

RA Planning and Controls.

The report covered a three-month period of inspection by resident inspectors and region-based

inspectors. Three Green findings, two 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). The NRC's

program for overseeing the safe operation of commercial nuclear power reactors is described in

NUR [[]]
EG -1649, "Reactor Oversight Process," Revision 4, dated December 2006.
A. [[]]
NRC -Identified and Self-Revealing Findings Cornerstone: Initiating Events Green. The inspectors identified a self-revealing
NCV of Technical Specification 5.4.1.a when control room operators closed the inlet and outlet Residual Heat Removal (

RHR)

system isolation valves while conducting a plant heat-up with the 'A' reactor coolant

system loop inoperable. This was contrary to procedural requirements which require

operators to verify that two reactor coolant system loops are operable and at least one is

operating prior to isolating the

RHR system. Several minutes after isolating the

RHR

system, the control room operators recognized they were not complying with the

procedure, and restored power to the

RHR isolation valves. The time that the

RHR

system was isolated from the reactor coolant system was 15 minutes. This finding was determined to be of very low safety significance (Green) using Phase 1,

Appendix G, Attachment 1, Checklist 4 of IMC 0609. This finding was of very low safety

significance because the finding did not increase the likelihood of a loss of RCS inventory,

degrade the ability of Ginna to terminate a leak path or add RCS inventory when needed,

nor degrade the ability to recover RHR. This finding has a crosscutting aspect in the area

of human performance because operators did not adhere to the procedural requirements

prior to removing the

RHR system from service (H.4.b per
IMC 0305). (Section 1R20) Cornerstone: Emergency Preparedness Green. The inspectors identified an
NRC -identified

NCV of 10 CFR 50.47(b)(2) for failure of Ginna's process for maintaining timely augmentation of on-shift staff. Ginna's nuclear

emergency response plan (NERP) states that the survey team member position will be

staffed by six individuals reporting onsite within one hour of the declaration of an

ALE [[]]

RT

or higher classification. Results from testing the off-hours notification of the response

organization for the four quarters, starting in June 2007 through March 2008, indicated

that fewer than six individuals would have responded for the survey team member position

within one hour of event declaration. Plant management entered the issue into their

corrective action program and took appropriate immediate corrective actions following

identification of the issue by the inspectors.

This finding is more than minor because it is associated with the emergency response organization (ERO) performance attribute and affected the objective of the Emergency

Preparedness cornerstone to ensure timely augmentation of on-shift staff. In accordance

with the Emergency Preparedness Significance Determination Process, this finding is of

Enclosure very low safety significance because the failure to comply with 10 CFR 50.47(b)(2) was a planning standard problem, but not a planning standard functional failure. The inspectors

determined that this finding has a crosscutting aspect in the area of problem identification and resolution because Ginna did not take appropriate corrective actions to qualify more

individuals for the survey team position in 2007 (P.1.d per

IMC 0305). (Section 1

EP3) Cornerstone: Occupational Radiation Safety Green. The inspectors identified a self-revealing finding of very low safety significance associated with occupational exposure control. During the planned refueling outage,

Ginna did not effectively manage its radioactive source term and work activities to prevent

unnecessary occupational exposure to workers during 'B' sump strainer modification and

steam generator inspections. Specifically, the collective occupational radiation dose

received by individuals for these two activities exceeded the planned or intended dose that

Ginna determined was as low as is reasonably achievable (ALARA) for the work activities.

This finding is more than minor because each of the two work activities exceeded their

initial estimates by more than 50 percent and each accumulated more than five person-

rem, as described in Appendix E of IMC 0612, example (6.b). Additionally, the finding

affected the program and process attribute of the Occupational Radiation Safety

cornerstone to ensure the adequate protection of the worker health and safety from

exposure to radiation from radioactive material during routine civilian nuclear reactor operations. This finding is of very low safety significance because the 3-year rolling

average exposure for Ginna was less than 135 person-rem. This finding has a

crosscutting aspect in the area of human performance work control because Ginna did not effectively coordinate work activities to incorporate actions to address the impact of

changes to the work scope or activity that were appropriate under the circumstances

(H.3.b per

IMC 0305). (Section 2

OS2)

B. Licensee-Identified Violations None.

Enclosure

REPORT [[]]

DETAILS

Summary of Plant Status

R.E. Ginna Nuclear Power Plant (Ginna) began the inspection period operating at full rated

thermal power (FRTP) and operated at essentially full power until April 20, 2008, when the plant

was shut down for a scheduled refueling outage (RFO). On May 11, the plant was restarted, and

the turbine synchronized to the grid. On May 14,

FR [[]]

TP was reached. On May 15, power was

rapidly reduced to 50 percent when both heater drain pumps tripped during maintenance

activities. On May 16, power ascension was started, and

FR [[]]

TP was reached on May 17. For the

remainder of the report period, with the exception of minor power reductions for testing, the plant

remained at full power. 1.

REACTO R

SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01 - Two samples) .1 Hot Weather Preparations

a. Inspection Scope

The inspectors reviewed Ginna's preparations for hot weather and performed walkdowns

of plant areas during the week of May 12, 2008. To perform the review, the inspectors

used the criteria and design criterion outlined in Ginna procedure O-23, "Hot Weather

Seasonal Readiness Walkdown," Rev. 00300, and the Updated Final Safety Analysis Report (UFSAR), Rev. 20. As part of the walkdown, local area temperatures were

checked, as well as the operability of ventilation and air conditioning cooling systems, to

ensure that the plant was prepared to handle warm weather conditions. Areas of focus

were the relay room, the 'A' and 'B' battery rooms, and the 'A' and 'B' emergency diesel

generator rooms. Documents reviewed are listed in the Attachment.

b. Findings No findings of significance were identified.

.2 Grid Stability

a. Inspection Scope Using the criteria in Ginna procedure O-6.9, "Ginna Station Operating Limits for Station

13A Transmission," during the week of May 12, the inspectors evaluated the readiness of

offsite and alternate AC power systems. The inspectors verified that communication

protocols between the transmission system operator and the plant were specified in

Ginna's procedures to ensure appropriate information was being exchanged. The

inspectors verified that the procedures addressed measures to monitor and maintain

availability and reliability of these systems during adverse weather conditions. Documents

reviewed are listed in the Attachment.

Enclosure b. Findings No findings of significance were identified. 1R04 Equipment Alignment (71111.04) .1 Partial System Walkdown (71111.04Q - Three 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

UFS [[]]

AR. 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 April 21 and 22, 2008, the inspectors used procedure "Alignment and Operation of the Reactor Vessel Overpressure Protection System," Rev. 04701 to conduct a

walkdown of the reactor vessel overpressure protection system when the system was

aligned to support Mode 5 plant operations;

  • On April 24, 2008, the inspectors performed a walkdown of the 'C' safety injection pump lineup established by O-2.3.1, "Draining and Operation at Reduced Inventory of

the Reactor Coolant System," Rev. 08500, to verify that the system was aligned

properly to support drain down for mid-loop operations; and * On April 30, 2008, during refueling operations, the inspectors performed a walkdown of the 'A' residual heat removal system line-up as established by O-15.2, "Valve

Alignment for Head Lift, Core Component Movement and Periodic Status Checks,"

Rev. 30. b. Findings No findings of significance were identified.

.2 Complete Walkdown (71111.04A - One sample)

a. Inspection Scope The inspectors performed a detailed walkdown of the auxiliary feedwater (AFW) system to

identify any discrepancies between the existing equipment lineup and the specified lineup.

The AFW system was chosen because of its risk significant function to provide makeup

water to the steam generators. The inspectors verified proper system alignment as

specified by

TS ,
UFSAR , plant procedures, and
P& [[]]

IDs. 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 database to verify that any

equipment alignment problems were being identified and appropriately resolved.

Enclosure Documents reviewed are listed in the Attachment.

b. Findings No findings of significance were identified. 1R05 Fire Protection (71111.05)

.1 Quarterly Inspection (71111.05Q - Five 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 Ginna's 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:

  • Auxiliary Building Mezzanine Level (Fire Zone
ABM ); * Auxiliary Building Basement (Fire Zone
ABB ); * 'B' Station Battery Room (Fire Zone
BR 1B); * Intermediate Building Cold Side Basement (Fire Zone

IBN-1); and * Containment Vessel (Fire Area RC). b. Findings

No findings of significance were identified.

.2 Annual Inspection (71111.05A - One sample) a. Inspection Scope The inspectors observed an announced test of Ginna's fire brigade on June 4, 2008. The

test involved a simulated fire in the all volatile treatment (AVT) room located in the

basement of the technical support center structure. The inspectors observed fire brigade

personnel obtain their protective equipment, travel to the simulated fire location, and

demonstrate how they would extinguish a fire in the AVT room. Following the drill, the

inspectors observed the post-drill critique, and verified that performance issues were

discussed and documented in Ginna's corrective action program. The inspectors

evaluated the performance of the brigade using the criteria outlined in the following

procedures: SC- 3.1.1, "Fire Alarm Response (Fire Brigade Activation)," Rev. 17;

SC- 3.4.1, "Fire Brigade and Control Room Personnel Responsibilities," Rev. 38; and

FRP- 28, "All-Volatile Treatment Room," Rev. 6.

b. Findings

No findings of significance were identified.

Enclosure 1R07 Heat Sink Performance (71111.07 - Two samples) a. Inspection Scope During the planned

RFO , the inspectors examined the heat exchangers (

HX) for the 'A'

and 'C' containment recirculating fans, which had been opened for inspection as part of

Ginna's Service Water System Reliability Optimization Program (SWSROP). The

inspectors verified the HX were inspected in accordance with the applicable procedure

and the

SWSROP . The purpose of the review was to verify that the

HX inspections

conformed to Ginna's commitments to Generic Letter 89-13, "Service Water System

Problems Affecting Safety-Related Equipment." The inspectors compared the inspection results for the HX to the established acceptance

criteria to verify that the results were acceptable and that the HX operated in accordance

with design. The inspectors reviewed system health reports and interviewed applicable

system engineers. The inspectors reviewed a sample of condition reports (CRs) related to the containment

air recirculation fan coolers to ensure that Ginna was appropriately identifying,

characterizing, and resolving problems related to these systems and components within

regulatory requirements and Ginna's commitments. Documents reviewed are listed in

the Attachment.

b. Findings

No findings of significance were identified.

1R08 Inservice Inspection Activities (71111.08 - One sample) a. Inspection Scope The purpose of this inspection was to assess the effectiveness of Ginna's Inservice

Inspection (ISI) program for monitoring degradation of the reactor coolant system

boundary, risk significant piping system boundaries, and the containment boundary. The

ISI activities were evaluated against the criteria specified in the American Society of

Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI

requirements, and applicable NRC Regulatory Requirements. Documents reviewed are

listed in the Attachment. In evaluating the effectiveness of the steam generator degradation management system,

the inspectors reviewed a number of Electric Power Research Institute (EPRI) eddy

current examination technique specification sheets to determine whether eddy current

probes and equipment were qualified for the expected degradation mechanisms. The

sheets corresponded to the degradation mechanism being evaluated. A Ginna qualified

examination technique was reviewed to determine if the technique qualification conformed

to the qualification requirements specified by

EP [[]]

RI guidelines, "Pressurized Water

Reactor Steam Generator Examination Guidelines, 100318, Appendix H." The procedure

was qualified in accordance with the guideline. The inspectors witnessed the calibration

and evaluation of a wear indication on R78C24 by a senior eddy current analyst.

Enclosure The inspectors performed an observation of an ultrasonic volumetric examination and the

visual surface examination of the contaiment liner. The inspectors reviewed a work order

package for ultrasonic examination on service water (SW) piping from reactor

compartment cooler. This examination was initiated to verify the minimum pipe wall

thickness of the 2-inch and 21/2-inch SW piping. The inspectors also observed the

ultrasonic examination of weld 14B-F5 using a 70 degree search unit. The ultrasonic examination disclosed that piping/fittings near penetration 209 inside the containment, in some local areas, were 0.064 inch, and 0.066 inch which were less than

code required minimum wall of 0.070 inch. These areas were less than 1-square inch

each. As corrective action, the piping in question was replaced. A CR (2008-3243) was

initiated to document, track, and disposition these findings in Ginna's corrective action

program.

b. Findings No findings of significance were identified. 1R11 Licensed Operator Requalification Program (71111.11Q - One sample) a. Inspection Scope On June 13, 2008, the inspectors observed licensed operator simulator training that

focused on emergency action level (EAL) event evaluation, classification, and

assessment. One scenario was run during the approximately 90-minute training session,

which was periodically stopped at different times to provide operators a chance to classify

the event given the plant conditions. Once operators classified the event, training

instructors discussed with operators the basis for the event classification and possible

alternative EAL classification scenarios. While reviewing the training session, the

inspectors verified that the instructors were following the guidance contained in a pre-

established lesson plan that was entitled "EAL Simulator Scenario Lesson Plan" dated

June 9, 2008.

b. Findings

No findings of significance were identified. 1R12 Maintenance Effectiveness (71111.12Q - Two samples) a. Inspection Scope The inspectors evaluated work practices and follow-up corrective actions for two issues

involving degraded conditions of safety-related systems, structures, and components

(SSCs) for maintenance effectiveness. The inspectors reviewed Ginna's implementation

of the maintenance rule and verified that the conditions associated with the referenced

CRs were evaluated against applicable maintenance rule functional failure criteria as

found in Ginna's scoping documents and procedures. 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

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

Effectiveness of Maintenance." In addition, the inspectors discussed these issues with

Enclosure system engineers and maintenance rule coordinators to verify that they were tracked against performance criteria and goals, and corrective actions were taken or planned to

verify whether the actions were reasonable and appropriate. Documents reviewed are

listed in the Attachment. The following conditions were reviewed: *

CR 2008-5445, Samples line valves

AOV 966B and AOV 953 leaking by

CR 2008-2428, Control room ventilation sensors

XE-6851and XE-6853 found out of position

b. Findings

No findings of significance were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Six samples) a. Inspection Scope The inspectors evaluated the effectiveness of Ginna's maintenance risk assessments

required by 10 CFR Part 50.65(a)(4). The inspectors discussed 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 verify that actual plant configuration

matched the assessed configuration. Additionally, the inspectors verified that risk

management actions, for both planned and emergent work, were consistent with those

described in

IP [[]]

PSH-2, "Integrated Work Schedule Risk Management." Documents

reviewed are listed in the Attachment. Risk assessments for the following out-of-service SSCs were reviewed: * A planned monthly surveillance on the 'A' emergency diesel generator while the 'A' service water pump was out for maintenance, and the plant was in adverse weather

conditions under

ER -

SC.1, for high winds (April 2, 2008); * Planned surveillance of emergency diesel generator sequence test while simultaneously conducting tests of safety injection logic circuitry and containment

radiation monitor calibrations (April 21, 2008); * Planned maintenance on the pressurizer level indicating system performed using

PT -32-B-

SD, "Reactor Trip Logic Test Train B," Rev. 14. (May 8, 2008);

  • Unplanned maintenance on the level indicating system for the heater drain tank (May 15 and 16, 2008); * Unplanned maintenance to replace a cracked actuator for valve 4629, service water return from 'A' containment recirculation fan cooler (May 21 and 22, 2008); and * Planned surveillance testing of the steam driven auxiliary feedwater pump (June 11, 2008).

Enclosure 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. Documents

reviewed are listed in the Attachment.

The inspectors performed field walkdowns, interviewed personnel, and reviewed the

following items: *

CR 2008-2745, 320A and/or 388A are leaking-by in containment, active boron leak in Chemical and Volume Control System impacting
FIT -179; *
CR 2008-3968, Eddy current inspection detected foreign material wear in A & B generator at lattice grid structures and lattice grid wear in the B steam generator; * Part 21-2008-04, "Notification Regarding Identification of Defect:
ALCO Snubber Valve Micro-cracking"; *
CR 2008-4203, Component cooling water heat exchanger coating degradation; *
CR 2008-3318,
MSU -26 continues to fail after repeated repairs; and *

CR 2008-5653, D Standby auxiliary feedwater discharge check valve failed prompt closure test.

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 2008-0011, "Disconnect

SI Accumulator B Drain Piping to the
RC [[]]

DT in Containment," 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

Enclosure 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, "Temporary Modifications,"

Revision 19. 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) 2008-0004, "Main Steam Check Valve Upgrade," which was installed during the RFO to address several material condition

issues with the valves including excessive packing leakage and repetitive failures of the

valve counterweight assemblies. The inspectors reviewed the PCR to ensure that the

change was performed in accordance with Ginna's licensing basis; and the post-

modification test would provide reasonable assurance that the valves would operate in

accordance with design criteria. Documents reviewed are listed in the Attachment. b. Findings

No findings of significance were identified. 1R19 Post-Maintenance Testing (71111.19 - Seven 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 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 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 -2.6.6, "Auxiliary Feedwater Valve Surveillance," Rev. 14, under

WO 20803111, "Troubleshoot and Repair AOV 9710B-Stroke Time Failure," which corrected the

stroke time failure of

AOV 9710B during

PT-36Q-D, "Standby Auxiliary Feedwater

Pump D - Quarterly," Rev. 54 (April 13, 2008); *

PT -16Q-T, "Auxiliary Feedwater Quarterly," Rev 5700 to address the issues identified in

CR 2008-3414, Steam Driven Auxiliary Feedwater Pump Inlet Valve MOV 3505A

in an Over Thrust Condition (April 25, 2008); *

STP -O-2.6.5, "
RCS Overpressure Protection System
PORV Operability Verification," Rev. 00000, and

STP-O-R-1.4, "Valve Interlock Verification - Reactor Coolant

Enclosure System," Rev. 00000, after repairs were performed during the

RFO per

WO 20700680, "PORV-430 is Leaking-by, Perform Inspection/Repair/Replace Internals,"

and

WO 20704149, "Perform a Major Inspection of

PORV-431C"

(May 4, 2008); * M-64.1.2, "MOVATs Testing of Motor Operated Valves (MOVs)," Rev. 35, after

RFO work was performed to repair

MOV-516 using WO 20602545, "Perform Major

Inspection of

MOV -516" (May 6, 2008); * S-23.3.A , "Reactor Compartment Cooling System Pre-startup Procedure," Rev.15, which was done, in part, for

WO 20803196, "Cut Out and Replace Service Water

Piping at Penetrations 209 and 201" (May 8, 2008); *

PCR 2008-0004, "Main Steam Check Valve Upgrade," Rev. 0, Post-Maintenance Test Activities (May 12, 2008); *
PT -2.3, "Safeguard Power Operated Valve Operations" Retest for
WO 20706890, "Grease/Lube

MOV 814" (June 23, 2008). b. Findings No findings of significance were identified. 1R20 Refueling and Other Outage Activities (71111.20 - One Sample) a. Inspection Scope On April 20, 2008, the inspectors observed the plant shutdown for a scheduled refueling

outage (RFO). The shutdown included a trip of the main turbine from approximately

percent power. Prior to the shutdown, the inspectors observed surveillance testing

activities for systems that would be placed in service during the RFO.

With one exception, the shutdown activities went as planned. The exception involved

difficulties encountered during testing of turbine protective trips when operators

determined the low lube oil pressure trip would not reset. The inspectors observed Ginna

troubleshooting operations and the implementation of compensatory actions.

Shortly after the plant entered Mode 4, the inspectors toured the containment structure to

examine the condition of plant structures and components. Particular attention was paid

to the Reactor Coolant Pump (RCP) oil leakage collection systems, the condition of the 'B'

containment sump, and Ginna's efforts to identify and assess boric acid leakage from

plant systems and components.

While the plant was in Mode 5, the inspectors walked down fire hose stations in

containment to ensure they had been correctly aligned. The inspectors also walked down

both trains of the residual heat removal (RHR) system to ensure they were available to

provide decay heat removal. During the RHR system walkdown, the inspectors verified

that both trains had electric power, and maintenance was not being performed on

protected systems.

Enclosure Using Operating Experience Smart Sample (OESS)

FY 2007-03, Revision 1, crane and heavy lift inspection, supplemental guidance for

IP-71111.20, a review of reactor head lift

plans was performed. The inspectors identified that Ginna had a valid load-drop analysis

and the movement of the head was performed both on and off in accordance with the

requirements of the analysis. A review of plans for movements of the 'A' RCP motor was

also performed to verify the activities were performed in accordance with the load drop

analysis.

Once the plant entered Mode 6, the inspectors toured the refueling cavity and examined

the sandbox area that had been removed for life extension-related inspection activities.

The inspectors verified that Ginna personnel were aware of potentially degraded areas in

the sandbox region, and had assessed the significance of the as-found condition.

The inspectors verified preparations for refueling and observed several hours of fuel

shuffle operations in containment and the control room. Ventilation line-ups and

equipment line-ups were verified prior to the commencement of refueling.

Several normally locked high radiation areas, that are not normally accessible during plant

operations because of high radiation levels, were walked down for general cleanliness

conditions, equipment performance, and boric acid leaks. Areas examined included the

rooms for volume control tank, reactor coolant pump seal injection filter, reactor coolant

filter, waste holdup tank, and non-regenerative heat exchanger.

When refueling was completed, the plant transitioned to Mode 5 in preparation for plant

startup. The inspectors toured containment to verify Ginna personnel were removing

refueling-related equipment and to ensure issues identified during boric acid walkdown

inspections had been resolved. Specific attention was devoted to the 'B' sump which was

walked down by the inspectors to ensure no foreign material was present that could

impact the performance of the emergency core cooling system pumps. The conditions of

the sump screens, which were modified during the outage were examined to ensure they

were intact and not obstructed. Sump walls were also verified to be intact.

While the plant was in Mode 5, the inspectors verified Ginna had established adequate

controls to ensure electrical power to safety-related equipment was protected.

The inspectors observed portions of the reactor coolant system (RCS) heat-up and toured

the containment when the 350 and 1,000 pound leak test inspections were being

performed by Ginna non-destructive evaluation personnel. When observing the leak test

inspections, the inspectors verified that examination points were identified in procedure,

PT 7, "

ISI System Leakage Test RCS," personnel were following the procedure, and

maintenance personnel were appropriately briefed on salient aspects of the examination.

b. Findings and Observations Introduction: A Green

NCV of

TS 5.4.1.a "Procedures" was identified for a failure of control room operators to correctly implement procedure O-1.1, "Plant Heat-up from Cold

Shutdown to Hot Shutdown," while conducting a plant heat-up following completion of the

RFO. Description: On May 8, 2008, at approximately 9:00 a.m. while the plant was in Mode 4 and conducting a plant heat-up per procedure O-1.1, control room operators isolated the
RHR system from the reactor coolant system by closing the

RHR inlet and outlet isolation

Enclosure valves MOVs 700, 701, 720 and 721, and de-energized the power supply breakers to the valves. At the time of the event, the 'A' reactor coolant system loop was not operable

because the lift pump for the 'A' reactor coolant pump was not functioning properly, which

prevented starting the reactor coolant pump. The 'B' loop pump was operable. Closing the inlet and outlet RHR system valves with the 'A' reactor coolant system loop

inoperable was contrary to the requirements of step 6.8.9(9)(a) of O-1.1, which stated that

prior to isolating the RHR system, operators shall verify that two reactor coolant system

loops are operable and at least one is operating. Several minutes after isolating the RHR system, the control room operators recognized

they were not complying with O-1.1, and they restored power to the RHR isolation valves.

The time that the RHR system was isolated from the reactor coolant system was 15

minutes. The performance deficiency associated with this finding was a failure of

operators to correctly implement O-1.1. A Ginna investigation into this event attributed the error to an inadequate understanding of

the requirements to meet the applicable governing TS 3.4.6, and a misreading of a step

6.8.9(9)(a) in procedure O-1.1. Analysis: This finding is more than minor because it is associated with the Initiating Events cornerstone and affects the cornerstone objective of limiting the likelihood of those

events that upset plant stability and challenge critical safety functions during shutdown as

well as power operations. This finding was determined to be of very low safety

significance (Green) using Phase 1, Appendix G, Attachment 1, Checklist 4 of IMC 0609.

This finding screened to Green because of the following: * The finding did not increase the likelihood of a loss of

RCS inventory. * The finding did not degrade the ability of Ginna to terminate a leak path or add

RCS inventory when needed. * The finding did not degrade the ability to recover Decay Heat Removal once it had been lost. This finding has a crosscutting aspect in the area of human performance because operators did not adhere to the procedural requirements outlined in O-1.1 prior to

removing the

RHR system from service (H.4.b per

IMC 0305). Enforcement: Technical Specification 5.4.1.a "Procedures" requires, in part, that the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A,

February 1978, be established, implemented, and maintained. Regulatory Guide 1.33

requires, in part, that procedures be implemented for heat-up of the reactor coolant

system. Procedure O-1.1 is required by Regulatory Guide 1.33. Step 6.8.9(9)(a) of O-1.1

states that operators shall verify that two reactor coolant system loops are operable and at

least one operating prior to isolating the RHR system. Contrary to the requirements of step 6.8.9(9)(a), during the May 8 plant heat-up,

operators isolated the RHR system when the 'A' reactor coolant system loop was

inoperable. Because this issue was determined to be of very low safety significance and

has been entered into Ginna's corrective action program (CR 2006-0370), this violation is

being treated as an

NCV , consistent with section
VI.A. 1 of the
NRC Enforcement Policy. (

NCV 05000244/2008003-01, Failure to Correctly Implement Reactor Coolant Heat-up Procedure)

Enclosure 1R22 Surveillance Testing (71111.22 - Seven 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

SSC s 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.

PT -3Q, "Containment Spray Pump Quarterly Test," Rev. 4501 (April 1, 2008) (
IST ) * S-12.4, "RCS Leakage Surveillance Record Instructions," Rev. 054 (April 17, 2008) (RCS) *
STP -O-2.6.5-
SD , "RCS Overpressure Protection System
PORV Operability Verification," Rev. 0000 (April 20, 2008) *
STP -O-R-2.2, "Diesel Generator Load and Safeguard Sequence Test," Rev. 00000 (April 21, 2008) (IST) *
PT -17.2, "Process Radiation Monitors R-11 - R-18, R-20 - R-22 Iodine Monitors R-10A and R-10B," Rev. 12600 (April 21, 2008) *
STP -O-12.1, "Emergency Diesel Generator A," Rev. 00201 (June 3, 2008) *
PT -2.3, "Safeguard Power Operated Valve Operations," Rev. 10500 (June 23, 2008) (

IST) b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness 1EP2 Alert and Notification System Evaluation a. Inspection Scope (71114.02 - One sample) An onsite review was conducted to assess the maintenance and testing of Ginna's alert

and notification system (ANS). During this inspection, the inspectors interviewed

emergency preparedness (EP) staff responsible for implementation of the ANS testing

and maintenance. Condition reports pertaining to the ANS were reviewed for causes,

trends, and corrective actions. The inspectors interviewed the system engineer regarding

the ANS siren system performance from January 2007 through May 2008. The inspectors

reviewed the

ANS procedures and the

ANS design report to ensure compliance with those

commitments for system maintenance and testing. In addition, the inspectors reviewed

changes to the design report and how these changes are captured. The inspection was

conducted in accordance with NRC Inspection Procedure 71114, Attachment 2. Planning

standard

10 CFR 50.47(b)(5) and the related requirements of 10

CFR 50 Appendix E

were used as reference criteria.

b. Findings No findings of significance were identified.

Enclosure

1EP 3 Emergency Response Organization Staffing and Augmentation System a. Inspection Scope (71114.03 - One sample) A review of Ginna=s emergency response organization (

ERO) augmentation staffing requirements and the process for notifying the ERO was conducted. This was performed to ensure the readiness of key staff for responding to an event and to ensure timely facility

activation. The inspectors reviewed procedures and

CR s associated with the

ERO

notification system and drills, and reviewed records from call-in drills. The inspectors

interviewed personnel responsible for testing the ERO augmentation process, and

reviewed the training records for a sampling of ERO to ensure training and qualifications

were up to date. The inspectors reviewed procedures for ERO administration and

training, and verified a sampling of ERO participated in exercises in 2007 and 2008. The

inspectors also reviewed records of offsite agency training and the June 2, 2008,

respirator and self-contained breathing apparatus (SCBA) qualification list. The

inspection was conducted in accordance with NRC Inspection Procedure 71114,

3. Planning standard 10 CFR 50.47(b)(2) and related requirements of

CFR 50 Appendix E were used as reference criteria.

b. Findings Introduction: The inspectors identified a Green

NCV associated with emergency preparedness planning standard 10

CFR 50.47(b)(2). Ginna failed to maintain timely

augmentation of on-shift staff regarding the radiological survey team member position.

Description: Ginna conducts a quarterly call test to ensure the

ERO is capable of being augmented in a timely manner. Ginna's nuclear emergency response plan (

NERP),

Section 4.2, Emergency Organization, states that the survey team member position will be

staffed by six individuals reporting onsite within one hour of the declaration of an

ALE [[]]

RT

or higher classification. During review of results of the previous four quarterly call tests,

the inspectors identified that the survey team member position had not been filled with six

individuals for any of the tests. For the testing conducted in June 2007 through March

2008, the survey team member position would not have been staffed by six responders

within one hour of event classification; only three or four individuals were able to respond

within one hour.

The survey team member position is a "pooled" position, meaning that the personnel are

not assigned on-call ERO duties, but are notified and are expected to respond as a group.

Ginna's ERO designated eight or nine individuals as survey team members during the four

quarter tests. However, during each test two of the individuals were identified as living

more than 60 minutes away and are noted as second shift only for off hours. This means

that all, or nearly all, of the identified individuals would have been required to respond

within 60 minutes. Ginna initiated CRs for each of the first two quarterly tests where the

positions were not filled. However, corrective actions to qualify more individuals for the

survey team position were not completed. The failure to maintain timely augmentation of

on-shift staff is a performance deficiency.

Following identification of the issue by the inspectors, Ginna entered the concern into their

corrective action program. The week following the inspection, Ginna indicated that they

had qualified three more individuals for the survey team position and were planning on

qualifying several additional individuals in the near future.

Enclosure Analysis: This finding is more than minor because it affected the Emergency Response Organization Readiness attribute of the Emergency Preparedness cornerstone to ensure

Ginna is capable of implementing adequate measures to protect the health and safety of

the public in the event of a radiological emergency. The inspectors assessed the finding using IMC 0609, Appendix B, Emergency

Preparedness Significance Determination Process, and determined the finding to be of

very low safety significance. IMC 0609, Appendix B, Sheet 1, "Failure to Comply," and

Section 4.2 of Appendix B were used to reach this determination. Using IMC 0609,

Appendix B, Sheet 1, the failure to comply with 10 CFR 50.47(b)(2) was a planning

standard problem, but not a planning standard functional failure. Ginna had other

qualified ERO survey team members who would have arrived, but later than one hour.

Therefore, the inspectors determined the planning standard function had been degraded,

and this finding was of very low safety significance (Green). The staffing deficiencies did

not affect the outcome of protecting the health and safety of the public. The inspectors

determined that this finding has a crosscutting aspect in the area of problem identification and resolution because Ginna did not take appropriate corrective actions to qualify more

individuals for the survey team position in 2007 (P.1.d per

IMC 0305). Enforcement: 10
CFR 50.47(b)(2) requires, in part, timely augmentation of response capabilities is available. Ginna's
NE [[]]

RP, Section 4.2, Emergency Organization, states that

the survey team member position will be staffed by six individuals reporting onsite within

one hour of the declaration of an

ALE [[]]

RT or higher classification. Contrary to the above, results from testing the off-hours notification of the response

organization for the four quarters, starting in June 2007 through March 2008, indicated

that fewer than six individuals would have responded for the survey team member position

within one hour of event declaration. Because this finding is of very low safety

significance and because it was entered into Ginna's corrective action program

(CR 2008-5153), this violation is being treated as an

NCV , consistent with Section
VI.A of the
NRC Enforcement Policy: (
NCV 05000244/2008003-02, Failure to Maintain Timely
ERO Augmentation of On-shift Staff) 1

EP4 Emergency Action Level and Emergency Plan Changes a. Inspection Scope (71114.04 - One sample) Prior to this inspection, the NRC had received and acknowledged changes made to Ginna's nuclear emergency plan and implementing procedures. These changes, which

Ginna 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, were made in accordance with 10

CFR 50.54(q). During this

inspection, the inspectors conducted a review of Ginna's 10 CFR 50.54(q) screenings for

all the changes made to the EALs and all of the changes made to the Plan from June

2006 through May 2008 that could potentially result in a decrease in effectiveness. This

review of the EAL and Plan changes did 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. The requirements in

CFR 50.54(q) were used as reference criteria. b. Findings No findings of significance were identified.

Enclosure 1EP5 Correction of Emergency Preparedness Weaknesses

a. Inspection Scope (71114.05 - One Sample) The inspectors reviewed a sampling of self-assessment procedures and reports to assess

Ginna's ability to evaluate their performance and programs. The inspectors reviewed CRs

from January 2007 through May 2008 initiated by Ginna from drills, self assessments, and

audits. Other drill reports reviewed included medical/health physics, fire, integrated, and

call-in. In addition, the inspectors reviewed two Unusual Event Reports and audits for

2007 and 2008 required by 50.54(t). This inspection was conducted in accordance with

NRC Inspection Procedure 71114, Attachment 5. Planning standard10

CFR 50.47(b)(14)

and the related requirements of 10 CFR 50 Appendix E were used as reference criteria.

b. Findings No findings of significance were identified. 2.

RADIAT [[]]
ION [[]]
SAFE [[]]

TY

Cornerstone: Occupational Radiation Safety (OS) 2OS1 Access Control To Radiologically Significant Areas (71121.01 - Eleven samples)

a. Inspection Scope From April 28 to May 2, 2008, the inspectors performed 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 the RFO. Implementation of these programs was reviewed against the

criteria contained in

10 CFR 20,

TSs, and Ginna's procedures.

Plant Walkdown and Radiation Work Permits (RWP) Reviews 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 to confirm the accuracy of survey data

and the adequacy of postings. The inspectors reviewed

RWP for work in

HRA and for

airborne radioactivity areas with a potential for internal exposures of greater than 50 mrem

committed effective dose equivalent (CEDE). During the period of the inspection and

since the start of the

RFO , there were no internal exposures greater than 50 mrem

CEDE.

The inspectors examined controls for highly activated or contaminated materials within the

spent fuel pool. Problem Identification and Resolution The inspectors reviewed Ginna's 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 eight CRs

related to access control to ensure follow-up actions were timely and effective. The

inspectors reviewed repetitive deficiencies to ensure these issues were also identified and

addressed in self assessments.

Enclosure Jobs-in-Progress Review

The inspectors selected the 'B' sump strainer modification, repack of valve 311C, and

steam generator activities for observation. The inspectors attended the management

oversight board,

ALA [[]]

RA brief, and observed the work from the radiation monitoring

system cameras for the repack of valve 311C. The inspectors reviewed the radiological

job requirements and observed the performance with respect to the requirements. The

inspectors questioned workers to assess the workers' knowledge of the radiological

conditions in the area and the radiological job requirements. The repack of valve 311C

required that the whole body dosimeter be relocated to the individual's head.

b. Findings No findings of significance were identified.

2OS 2

ALARA Planning and Controls (71121.02 - Thirteen samples)

a. Inspection Scope From April 28 to May 2, 2008, the inspectors performed the following activities to verify

that Ginna was properly implementing operational, engineering, and administrative

controls to maintain personnel exposure

ALARA for activities performed during

RFO

operations. Implementation of these controls was reviewed against criteria contained in

CFR 20, applicable industry standards, and Ginna's procedures. Inspection Planning

The inspectors reviewed pertinent information regarding cumulative exposure history,

current exposure trends, and ongoing activities. The inspectors reviewed Ginna's

3-year rolling average dose and compared Ginna's average with industry average. The

inspectors verified that Ginna's

ALARA program procedure and the

RWP procedure

include job estimating and tracking.

Radiological Work Planning The inspectors received a list of the five work activities ranked highest by estimated exposure for the

RFO. The inspectors reviewed the

ALARA evaluations and RWP for

these work activities. The inspectors reviewed the results achieved with the intended

dose established in Ginna's

ALA [[]]

RA planning for these work activities.

Verification of Dose Estimates

The inspectors reviewed the applicable procedures to determine the methodology for estimating work activity exposures. The inspectors reviewed Ginna's method for

adjusting exposure estimates. The inspectors attended an

ALA [[]]

RA committee meeting

where adjustments to the outage dose estimate were presented.

Job Site Inspections

The inspectors observed three job sites: 'B' sump strainer modification, 'A' reactor coolant

pump work, and work in the pressurizer area. The inspectors evaluated if the workers

received appropriate on-the-job supervision and appropriate briefings of radiological

Enclosure conditions.

Radworker Performance

The inspectors observed individual worker performance to determine if the workers

demonstrated

ALA [[]]

RA philosophy. The inspectors questioned workers about the

radiological conditions in the work area and if the workers knew where the highest and

lowest dose rates were in their area.

Source Term Reduction and Control

The inspectors reviewed the status and historical trends of source terms. The inspectors

reviewed the shutdown clean-up and chemistry controls prior to and during shutdown.

Declared Pregnant Workers

The inspectors selectively reviewed accumulated dose, controls, and monitoring for

declared pregnant workers. Ginna established an administrative limit (300 mrem) for a

declared pregnant worker.

Problem Identification and Resolution The inspectors reviewed audits and self assessments since the previous inspection to

verify identified problems were put in the corrective action program. The inspectors

reviewed elements of the corrective action program related to implementing the

ALA [[]]

RA

program to determine if problems were being entered into the program for timely

resolution. Four

CR s related to participation at
ALARA meetings, dose estimates, and
ALA [[]]

RA resources were reviewed.

b. Findings and Observations Introduction: The inspectors identified a self-revealing finding of very low safety significance (Green) associated with occupational exposure control. Specifically, Ginna

failed to implement effective occupational exposure control for two work activities ('B'

sump strainer modification and steam generator inspections) once plant radiation

conditions changed.

Description: During the RFO, Ginna did not effectively manage work activities to prevent unnecessary occupational radiation exposure to workers involved with the 'B' sump

strainer modification (RWP No. 5800) and the steam generator inspections (RWP Nos.

5711 and 9711) once plant radiation conditions changed. Specifically, three weeks prior

to plant shutdown, Ginna replaced demineralizer resins that changed reactor coolant

system (RCS) pH causing chemical shocks that resulted in several unexpected crud

bursts prior to plant shutdown. In addition, once the plant was shut down, cleanup of the

RCS was delayed following an induced crud burst (hydrogen peroxide addition), when the

purification system was isolated for greater than the expected 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> to facilitate

performance of a test of the safety injection system. The extended isolation of the

letdown system and pre-outage crud bursts caused an increased source term that was

not expected or planned relative to performance of reactor work activities to assure the

work was performed with occupational exposure

ALA [[]]

RA.

The initial dose estimates for the specified RWP were primarily based on historical dose

Enclosure rates for the same or similar work activities, person-to-hour estimates provided by maintenance and engineering groups to accomplish the work activities, and were

reviewed by Ginna management. However, Ginna failed to revise the RWP estimates

when the actual work environment and conditions were different than originally anticipated

due to the crud bursts and the expected work scope increased. For example, the 'B'

sump strainer modification had additional scope added and steam generator inspections

included significant rework which was not expected. Further, Ginna did not perform timely

in-progress reviews for these work activities even though actual dose accumulation was

significantly more than originally estimated.

The inspectors assessed this issue as a single performance deficiency for the failure to reassess work planning and controls following changes in working conditions that were

different than anticipated or planned and affected the ability to assure the occupational

exposure was maintained

ALA [[]]

RA. These two work activities were determined to have

exceeded Ginna's original

ALA [[]]

RA planning and estimation, i.e., occupational exposure

greater than five person-rem and greater than 50 percent of their initial estimated dose.

Specifically, as of May 1, 2008, the 'B' sump strainer modification work had an actual

accrued dose of 11.400 person-rem compared to Ginna's estimate of 5.427 person-rem;

and as of April 30, the steam generator inspections had an actual accrued dose of 11.932

person-rem compared to Ginna's estimate of 5.750 person-rem. The inspectors

determined that Ginna should have been able to recognize changes in the radiological

conditions and the emergent work affecting both of these activities and reassess the

conditions to assure that the radiological work exposure to personnel was

ALA [[]]
RA. The emergent and changed radiological conditions were not fully recognized and effectively assessed to assure occupational exposure to personnel was maintained
ALA [[]]

RA relative to work involving the 'B' sump strainer modification and the steam

generator inspections. Accordingly, the occupational exposure that was originally planned

and expected for these work activities was exceeded without sufficient reassessment,

planning, and work control to assure that, to the extent practical, occupational exposure

for these activities was maintained

ALA [[]]

RA. As a result, the activities resulted in

unplanned, unintended occupational collective dose, a condition that was well within

Ginna's ability to recognize, foresee, correct, and prevent by reassessment of the

conditions and implementation of commensurate planning and work control.

The failure to implement controls to achieve occupational doses that are

ALA [[]]

RA and which resulted in unplanned, unintended occupational collective dose is a performance

deficiency that was reasonably within Ginna's ability to foresee and correct and which

should have been prevented.

Analysis: This finding is more than minor because each of the two work activities exceeded their initial estimates by more than 50 percent and each accumulated more

than five person-rem, as described in Appendix E of IMC 0612, example (6.b).

Additionally, the finding affected the program and process attribute of the Occupational

Radiation Safety cornerstone to ensure the adequate protection of the worker health and

safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operations. This finding was determined to be of very low safety significance

(Green) because Ginna's 3-year rolling average was less than 135 person-rem, as

described in Appendix C of

IMC 0609, Section

IV, Step 2 (b).

This finding has a crosscutting aspect in the human performance work control area, because Ginna did not effectively coordinate work activities to incorporate actions to

Enclosure address the impact of changes to the work scope or activity that were appropriate under the circumstances, i.e., radiological conditions changed and emergent work was required, a circumstance for which it was appropriate to reassess the changed work conditions and

environment to assure that continued work was adequately planned, controlled, and

monitored to assure that occupational exposures were maintained

ALARA (H.3.b per
IMC 0305). Enforcement: The
ALARA rule contained in 10
CFR 20.1101(b), "Statements of Consideration," indicates that compliance with the
ALA [[]]

RA requirement will be judged on

whether Ginna has incorporated measures to track and, if necessary, to reduce

exposures and not whether exposures and doses represent an absolute minimum or

whether Ginna has used all possible methods to reduce exposures. Further, consistent

with Appendix B of IMC 0612, since Ginna does have a defined program to track and

reduce occupational exposure and this finding is considered an isolated example and not

an

ALARA program breakdown, it is not considered a violation of 10

CFR 20.1101(b). This issue was entered into Ginna's corrective action program (CR 2008-3957). (FIN 05000244/2008003-03 Failure to Implement Effective Occupational Exposure

Control) 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - One sample)

a. Inspection Scope From April 28 to May 2, 2008, the inspectors performed the following activities to evaluate

that Ginna was utilizing properly calibrated and source-checked radiological instruments

to monitor radiological conditions. Implementation of these programs was reviewed

against the criteria contained in 10 CFR 20, applicable industry standards, and Ginna's

procedures.

The inspectors observed 10 radiological instruments in use in the containment and

auxiliary building during the RFO. The inspectors verified the calibration due dates were

not expired and the instrument source checks were current. The inspectors reviewed six

CRs related to radiological instruments. The inspectors also observed a radiation

protection technician perform pre-use checks of an instrument.

b. Findings

No findings of significance were identified.

4.

OTHER [[]]

ACTIVITIES 4OA1 Performance Indicator Verification (71151) .1 Cornerstone: Mitigating Systems

a. Inspection Scope (71151 - One sample)

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 performance indicator (PI) data for safety system

functional failures. To verify the accuracy of the data, the inspectors reviewed monthly

Enclosure operating reports, NRC inspection reports, and Ginna event reports issued from January 2007 to March 2008.

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) leak rate PI.

The inspectors used the guidance provided in NEI 99-02, Revision 5, to assess the

accuracy of Ginna's collection and reporting of the PI data. The inspectors also observed

a sample of S-12.4, "RCS Leakage Surveillance Record Instructions," which determines

RCS leakage rates submitted under this
PI. The
PI data reviewed for

RCS leak rate

encompassed the period from August 2007 until March 2008.

b. Findings No findings of significance were identified.

.3 Cornerstone: Emergency Preparedness a. Inspection Scope (71151 - Three samples) The inspectors reviewed data for the emergency preparedness PIs which are: (1) Drill

and Exercise Performance; (2)

ERO Drill Participation; and (3)

ANS Reliability. The

inspectors reviewed supporting documentation from drills and tests for April 2007 through

March 2008 to verify the accuracy of the reported data. The review of these PIs was

conducted in accordance with NRC Inspection Procedure 71151. The acceptance criteria

used for the review were

10 CFR 50.9 and

NEI 99-02, Revision 5.

b. Findings No findings of significance were identified. 4OA2 Identification and Resolution of Problems (71152)

.1 Semi-Annual Review (71152 - One sample) a. Inspection Scope In order to identify trends that might indicate the existence of a more significant safety

issue, the inspectors reviewed CRs initiated from June 2007 to June 2008, the 4th quarter 2007 and 1st quarter 2008 corrective action trend reports, the daily plant status report, and the 1st quarter 2008 and 2nd quarter 2008 system health reports. The inspectors also discussed trends and potential trends with appropriate plant personnel.

Enclosure b. Findings and Observations No findings of significance were identified. No trends were noted that indicated a potential

significant safety issue. Trends identified by the inspectors had already been recognized

by Ginna, and corrective actions initiated as necessary.

.2 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

Ginna's corrective action program. This review was accomplished by reviewing condition

reports, periodic attendance at daily screening meetings, and accessing Ginna's

computerized corrective action database.

b. Findings No findings of significance were identified.

.3 Operator Workarounds (71152 - One sample)

a. Inspection Scope The inspectors reviewed the operator workaround program to verify that workaround

problems were identified at an appropriate threshold and entered into the corrective action

program. To perform this review, the inspectors performed a control room walkdown and

discussed deficiencies with control room operators to determine if deficiencies were

appropriately identified and that their impact on operations was assessed. Operator

workarounds that affected a mitigating system's function or the operator's ability to

implement abnormal and emergency operating procedures were reviewed more closely.

For example, one item that had been identified by Ginna as a degraded condition, the

need for operators to verify that an appropriate gap is maintained between the main

steam safety valves and their dead weight supports, was walked down by the inspectors.

As part of this review, the inspectors reviewed the procedure for workaround control and a

recent self-assessment report regarding the aggregate impact of the active operator

workarounds, challenges, and degraded operability items.

b. Findings and Observations No findings of significance were identified.

Enclosure

4OA 3 Followup of Events and Notices of Enforcement Discretion (71153 - Three samples) a. Inspection Scope .1 Seal Injection Indications Identified During

ISI Activities

On May 1, 2008, during a periodic non-destructive examination, Ginna Inservice

Inspection (ISI) personnel found three small circular indications on an elbow in the seal

injection line for the 'B' reactor coolant pump (RCP). The depth of the deepest indication

was 0.125 to 0.375 inches and appeared to have been made by a drill bit. A Ginna

evaluation determined that the indications did not affect the structural integrity of the pipe

which had a pipe wall thickness of 0.4 inches. The elbow was last inspected in 1997

during the last 10-year ISI examination. No indications were noted during that inspection.

A subsequent Ginna investigation concluded that the indications were probably caused

during the process of installing insulation on the pipe elbow. As part of an extent of

condition review, the pipe elbow on the 'A' RCP was examined and no indications were

identified. Inspectors' follow-up of this issue included examining the elbow on the 'B' RCP

seal injection line, reviewing the operability determination which evaluated the significance

of the indications, and verifying Ginna was following the appropriate event evaluation

procedures.

.2 Heater Drain Tank Pump Trip

On May 15, 2008, control room operators rapidly reduced reactor power to 50 percent

when both heater drain tank pumps tripped. Prior to the event, instrumentation and

control (I&C) technicians were troubleshooting failed level indicating and control systems

on the heater drain tank. A Ginna investigation determined that the most probable cause

for the loss of heater drain tank pumps was a low level in the heater drain tank, a

condition that was unknown to control room operators since the drain tank level indicating

systems were not functioning. The inspectors reviewed Ginna's investigation of this

event, verified that the failed level indicating systems had been restored to service, and

that, prior to the event, the troubleshooting actions that I&C personnel had performed on

the level indicating system were prudent given the plant conditions that existed at the

time.

.3 Unplanned Power Transient

On June 29, 2008, an unplanned reactor power decrease to 97 percent occurred when

control room operators added boric acid to the volume control tank (VCT). Prior to the

event, the chemical volume control system was automatically adding a blend of boric acid

and water to the VCT when operators noticed a decrease in Tavg followed by an increase

in Tavg. To compensate for the increase in Tavg, the operators added boric acid to the

VCT and reduced load off the turbine. No safety limits were exceeded. A Ginna

investigation determined that the most probable cause for the decrease and subsequent

increase in Tavg was malfunction of valves 110A, 110B, and 110C. The inspectors

reviewed Ginna's investigation of this event and verified operator actions were adequate.

An incident response team was assembled and troubleshooting actions were initiated by

operations and I&C personnel.

Enclosure b. Findings

No findings of significance were identified. 4OA5 Other Activities .1 Hemyc Compensatory Measures Review

a. Inspection Scope The inspectors completed a walkdown of plant areas containing systems protected by

Hemyc fire wrap and reviewed the commitments Ginna made to the NRC in a letter from

Ginna, dated June 9, 2006, in response to Generic Letter 2006-03, "Potentially

Nonconforming Hemyc and MT Fire Barrier Configuration," dated April 10, 2006. The

inspectors also reviewed the adequacy of compensatory measures outlined in Ginna's

documented evaluation (Fire Protection Program and Appendix R Conformance Review

Screen, Attachment A; and A-202 Evaluation of Compensatory Measures for Degraded

Hemyc, dated June 30, 2006) for deviations taken to the commitments previously made in

Ginna's June 9, 2006, letter. The review verified that the alternate compensatory

measures outlined in Ginna's evaluation would not adversely affect the ability to achieve

and maintain safe shutdown in the event of fire. The inspectors verified that Ginna

continues to track Hemyc installations as protection system impairments and the alternate

compensatory measures using staff guidance provided in Regulatory Issue Summary

2005-07, Compensatory Measures to Satisfy the Fire Protection Program Requirements,"

dated April 19, 2005, remain in place pending completion of the modifications and

evaluations.

b. Findings No findings of significance were identified. .2 (Closed) Temporary Instruction 2515/172, Reactor Coolant System Dissimilar Metal Butt Welds

a. Inspection Scope The purpose of this Temporary Instruction (TI) was to support the Office of Nuclear

Reactor Regulation/Division of Component Integrity by inspecting and reporting on

Ginna's performance on implementing MRP-139. Specifically, the inspectors provided a

qualitative description of the effectiveness of Ginna's dissimilar metal butt weld inspection

and mitigation program.

No welds exist at Ginna that fall under the jurisdiction of

MRP -139, and therefore, this

TI.

The inspectors reviewed with the engineering staff at Ginna how this was determined, the

records reviewed, and the conclusion supported.

b. Findings No findings of significance were identified.

Enclosure .3 (Closed) Temporary Instruction 2525/166, Pressurized Water Reactor Containment Sump Blockage a. Inspection Scope The inspectors performed the inspection in accordance with TI 2515/166, Pressurized

Water Reactor Containment Sump Blockage. The

TI was developed to support the
NRC review of Ginna's activities in response to
NRC Generic Letter (

GL) 2004-02, "Potential

Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water

Reactors." Specifically, the inspectors verified implementation of the modifications and

required procedure changes were consistent with the proposed actions committed to in

the GL response. The inspectors reviewed a sample of the licensing and design

documents to verify that they were either updated or in the process of being updated to

reflect the modifications. The inspectors performed a walkdown of the strainer installation

to verify it was performed in accordance with the approved design change package. In

addition, the inspectors walked down the containment to assess the adequacy of the

coatings on surfaces in containment. Finally, the inspectors verified that there were no

choke-points not accounted for by Ginna's calculations that could prevent water from

reaching the recirculation sump during a design basis accident. Documents reviewed are

listed in the Attachment.

Evaluation of Inspection Requirements

The TI requires the inspectors to evaluate and answer the following questions:

Did Ginna implement the plant modifications and procedure changes committed to in their

GL 2004-02 response? The inspectors verified that actions implemented by Ginna as

described in response to GL 2004-02 were complete related to the installation of the sump

screen. The inspectors determined that the procedures to programmatically control

potential debris generation sources were updated. Finally, the inspectors reviewed

Ginna's emergency operating procedures and verified that the procedures ensured the

assumptions described in Ginna's supplemental response to the GL were in alignment

with the procedure guidance.

Has Ginna updated its licensing basis to reflect the corrective actions taken in response to

GL 2004-02? The inspectors verified that changes to the facility or procedures as

described in the

UFSAR that were identified in Ginna's

GL 2004-02 response were

reviewed and documented in accordance with 10 CFR 50.59. As part of this review, the

inspectors verified that Ginna did not require NRC approval prior to implementing those

changes. The inspectors also verified that Ginna intends to update the

USF [[]]

AR to reflect

the final modification and associated procedure changes taken in response to GL 2004-

2. Finally, the inspectors verified that Ginna intends to provide a final response to GL

2004-02 within 60 days of startup from the RFO.

Based on the inspectors' review of the hardware modifications, and the procedure and

licensing bases changes, the inspection requirements of the

TI are complete, and the

TI is

closed.

This documentation of TI-2515/166 completion, as well as any results of sampling audits

of Ginna's actions, will be reviewed by the NRC staff (Office of Nuclear Reactor

Regulation) as input, along with the

GL 2004-02 responses to support closure of

GL 2004-

and Generic Safety Issue-191 (GSI), "Assessment of Debris Accumulation on

Enclosure Pressurized Water Reactor Sump Performance." The

NRC will notify Ginna by letter of the results of the overall assessment as to whether

GSI-191 and GL 2004-02 have been

satisfactorily addressed at Ginna.

b. Findings No findings of significance were identified.

l4OA6 Meetings, Including Exit

.1 Management Site Visit On April 28, 2008, a site visit was performed by Mr. J. Clifford, Deputy Director, Division of

Reactor Projects for Region I. During Mr. Clifford's visit, he toured portions of the plant

including the containment structure and met with Ginna managers.

.2 Exit Meeting Summary On July 14, 2008, the resident inspectors presented the inspection results to

Mr. John Carlin and other members of his staff, who acknowledged the findings. The

inspectors verified that none of the material examined during the inspection is considered

proprietary in nature.

ATTACH [[]]
MENT [[:]]
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION Attachment
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION [[]]
KEY [[]]
POINTS [[]]
OF [[]]

CONTACT Licensee 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

T. Hedges Emergency Preparedness Manager

D. Holm Plant Manager

J. Pacher Manager, Nuclear Engineering Services

J. Sullivan Manager of Operations
LIST [[]]
OF [[]]
ITEMS [[]]
OPENED ,
CLOSED ,
AND [[]]
DISCUS [[]]

SED Opened and Closed

05000244/2008003-01 NCV Failure to Correctly Implement Reactor Coolant Heat-up Procedure (Section 1R20)05000244/2008003-02

NCV Failure to Maintain Timely

ERO Augmentation of On-shift

Staff (Section 1EP3)05000244/2008003-03 FIN Failure to Implement Effective Occupational Exposure

Control (Section 2OS2)

Closed

05000244/2515/172 TI Reactor Coolant System Dissimilar Metal Butt Welds

(Section 4OA5)

05000244/2515/166 TI Pressurized Water Reactor Containment Sump Blockage

(Section

4OA 5)
LIST [[]]
OF [[]]
DOCUME [[]]
NTS [[]]
REVIEW [[]]

ED Section 1R01: Adverse Weather Protection Document Updated Final Safety Analysis Report (UFSAR) Rev. 20

Attachment Procedures

AP -
SW. 2 Loss of Service Water, Rev. 00801
EP [[]]
IP 1-17 Planning for Adverse Weather, Rev. 8
ER -
ELEC. 1 Restoration of Offsite Power, Rev. 17
ER -
SC. 1 Adverse Weather Plan, Rev. 01700
ER -
FIRE. 1 Alternate Shutdown for Control Complex Fire, Rev. 02701
ER -
SH. 1 Response to Loss of Screen House, Rev. 2
ER -

SC.3 Low Screen House Water Level, Rev. 02000

O-6.9 Ginna Operating Limits for Station 13A Transmission, Rev. 03100

O-23 Hot Weather Seasonal Readiness Walkdown, Rev. 00300

Condition Reports 2008-2834

2007-5821

2007-0012

2007-3616

2007-6286

Work Orders 20704997

20703056

20703617

20705288

Section 1R04: Equipment Alignment Documents

Diesel Generator Emergency Power System Health Report (Q2-2008)

UFS [[]]
AR 8.1.4.2, Emergency Power
TS Basis B 3.8.1,

AC Sources

4S Diesel Generator Emergency Power System

Integrated work schedule week 336L

Procedures O-7 Alignment and Operation of the Reactor Vessel Overpressure Protection System, Rev. 04701 O-2.3.1 Draining and Operation at Reduced Inventory of the Reactor Coolant System, Rev. 08500 O-15.2 Valve Alignment for Head Lift, Core Component Movement and Periodic Status Checks, Rev. 30 T-27.1 EDG 'A' Pre-Startup Alignment, Revision 05600

T-27.2 EDG 'B' Pre-Startup Alignment, Revision 05800

T-27.4 Diesel Generator Operation, Revision 039

Drawings 33013-1239 Diesel Generator 'A' and 'B', rev 4

33013-1247 Auxiliary Coolant Residual Heat Removal (AC)

P& [[]]

ID, Rev. 40

33013-1263 RCS Overpressure Protection Nitrogen Accumulator System, Rev. 10

33013-1261 Containment Spray (SI), Rev. 37

33013-1262 Safety Injection and Accumulators, Rev. 10

Attachment Condition Report 2008-004728

2008-003377

Section 1R05: Fire Protection Document Ginna Fire Protection Program, Rev. 4d

Procedures O-2.2 Plant Shutdown from Hot Shutdown to Cold Conditions, Rev. 14900

SC -3.16.3.1 Set Up of Containment Hose Reels during Outage, Rev. 1

SC- 3.1.1 Fire Alarm Response (Fire Brigade Activation), Rev. 17

SC- 3.4.1 Fire Brigade and Control Room Personnel Responsibilities, Rev. 38

FRP- 28 All-Volatile Treatment Room, Rev. 6

Drawings 33013-1991 Fire Protection Fire Service Water Auxiliary Building, Intermediate Building, and Containment Building

P&ID 33013-2542 Fire Response Plan
CNMT Structure and Intermediate Building Plan, Basement Floor Elev. 235 feet 8 inches 33013-2545 Containment Fire Response Plan
CN [[]]

MT, Structure and Intermediate Building Plan, Intermediate Floor Elev. 253 feet 3 inches

Condition Report 2008-5098

Section 1R07: Heat Sink Performance Documents Service Water System Reliability Optimization Program, Rev. 8

CMP -10-07-

RECIRCFANA, Rev. 000500

Work Order 206003248

Section 1R08: Inservice Inspection Documents

EP -
NDE -603, Grid Layout for Erosion/Corrosion UT Examinations, Rev. 000
EP -
NDE -605, UT Examinations for Erosion/Corrosion, Rev. 000
BOP -

UT-08-117, UT Data Sheet Report

Drawings C381 to C358, Station SW inside Reactor Containment from Penetration 209 to Reactor Cavity Cooler, Sheets 28, 30, 32

Condition Reports 2008-3243

2008-3244

Attachment Work Orders

20702150 UT Examination/Evaluation of 2-1/2"

SW System Piping at P209

Scope Expansion to Include Piping at P201, Rev. 5

Section 1R11: Licensed Operator Requalification Document EAL Simulator Scenario Lesson Plan, June 9, 2008 Section 1R12: Maintenance Effectiveness Documents System Health Report for Radiation Monitoring, Qtr 1, 2008

Record

ID 2007-005 Form

MR5, Maintenance Rule Goal Determination, Rev. 4

Record

ID 2004-010 Form

MR5, Maintenance Rule Goal Determination, Rev. 4

Ginna IST Program for Valves 951, 966B, and 966C

Procedures P-9, Radiation Monitoring System, Rev. 09801

S-14, Area and Process Radiation Monitoring System, Rev. 02601

S-14.8, Operation of Containment Ventilation, Rev. 14

S-14.7, Operation of Area Radiation Monitors, Rev. 7

S-14.10, Operation of Process Radiation Monitors, Rev. 16

STP -O-2.5.1, Air Operated Valves, Quarterly Surveillance, Rev. 00201
IP -
IIT -3, Containment Leakage Rate Testing Program, Rev. 00600
IP -

IIT-3.1, Containment Isolation Valve Leak Rate Testing, Rev. 1

PTT-23.12A, Containment Isolation Valve Leak Rate Testing Pressurizer Steam Sample Pen 207A, Rev. 3

Drawing 33013-1278 Nuclear Sampling

P& [[]]

ID, Sheets 1 and 2

Condition Reports 2008-5377

2008-5331

2008-5260

2008-5224

2008-5094

2008-4846

2008-4836 2008-4680 2008-4628

2008-4494

2008-3299

2006-1591

2006-6011

2007-3865 2008-1200 2008-3201

2008-4144

2008-4648

2008-4649

2008-4947

2008-5445 Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation Documents

STP -O-12.1, Emergency Diesel Generator 'A', Rev. 00100
ER -

SC.1, Adverse Weather Plan, Rev. 17

STP-O-R-2.2, Diesel Generator Load and Safeguard Sequence Test, Rev. 00000

PT-17.2, Process Radiation Monitors R-11 - R-18, R-20 - R-22 Iodine Monitors R-10A and

R-10B, Rev. 12600

STP-I-32.1-A, Plant Safeguard Logic Test Train 'A'

Attachment S-23.1, Containment Recirculation Fan 'A' Alignment, Rev.

18 UFS [[]]
AR 8.1.4.2, Emergency Power
TS Basis B 3.8.1,

AC Sources

Diesel Generator Emergency Power System Health Report, 2nd Qtr. 2008

Drawings 33013-1239 Diesel Generator 'A' and 'B', Sheets 1 and 2, Rev. 4

33013-1923 Feedwater Heater Drain System, Rev. 22

Condition Reports 2008-4728

2008-3377

2008-4627

Work Order 20803854 Actuator for Valve 4629 Cracked

Section 1R15: Operability Evaluations Documents Part 21-2008-04, Notification Regarding Identification of Defect:

ALCO Snubber Valve Micro-Cracking Immediate Change Processing Form for Procedure
STP -O-2.9, June 25, 2008
IS [[]]
TM -153, In-Service Test Program Memorandum, June 25, 2008
ACB No. 2008-0095, Acceptance Criteria Basis Form for
CV -9705B,
MOV -9704B, and

CV-9700B

Procedures STP-O-2.9, Check Valve and Manual Valve Exercising, Rev. 00100

PT -36Q-D, Standby Auxiliary Feedwater Pump D - Quarterly, Rev. 05500
PT -36-

COMP-D, Standby Auxiliary Feedwater Pump D - Comprehensive Test, Rev. 00500

Drawing 33013-1238 Standby Auxiliary Feedwater

P& [[]]

ID, Rev. 25

Condition Reports 2008-2745

2008-4166

2008-3968

2008-3477 2008-3687 2008-3318

2008-4203

2008-5653 Section 1R18: Plant Modifications Document PCR 2008-0004, Main Steam Check Valve Upgrade

Condition Reports 2008-4291

2008-4292

Attachment Section 1R19: Post-Maintenance Testing Documents M-64.1.2,

MOV [[]]

ATs Testing of Motor Operated Valves, Rev. 35

PT-36Q-D, Standby Auxiliary Feedwater Pump D, Quarterly, Rev. 05400

PT -2.6.6, Auxiliary Feedwater Valve Surveillance, Rev. 14
STP -O-2.6.5,
RCS Overpressure Protection System
PO [[]]

RV Operability Verification, Rev. 0

STP-O-R-1.4, Valve Interlock Verification - Reactor Coolant System, Rev. 0

Ginna ISI Program, Rev. 7

Condition Reports 2008-2854

2008-3928

2008-4139

2008-4177

2008-4198

Work Orders 20803111 Troubleshoot and Repair AOV-9710B, Stroke Time Failure

20602545 Perform Major Inspection of

MOV -516
20700680 PO [[]]

RV-430 is Leaking-by Perform Inspection/Repair/Replace Internals

20704149 Perform a Major Inspection of

PO [[]]

RV-431C

Section 1R20: Refueling and Other Outage Activities Documents NRC Inspection Report Docket No. 50-244 /86-02

Rigging Plan for Reactor Coolant Pump Motor Change Out

Final Report for the Reactor Head Drop Analysis for Ginna, Job # 83084, Cygna Energy

Services, March 9, 1984

Procedures O-2.1A Alternate Shutdown to Hot Shutdown with Reactor Trip at 30% Power, Rev. 00000

O-2.3 Draining the Reactor Coolant System to <84" but >64", Rev. 04400

O-2.3.1 Draining and Operation at Reduced Inventory of the Reactor Coolant System, Rev. 08500 STP-O-R-2.2 Diesel Generator Load and Safeguard Sequence Test, Rev. 00000

O-15.2 Valve Alignment for Reactor Head Lift, Core Component Movement, and Periodic Status Checks, Rev. 03100

Condition Reports 2008-2937

2008-3110

2008-3192

2008-3432

2008-3438

2008-3470

2008-3508

2008-3514

2008-3518

2008-3557 2008-3604 2008-3613

2008-3627

2008-3646

2008-3761

2008-3762

2008-3787

2008-3806

2008-3903

2008-4025 2008-4120 2008-4124

2008-4326

2008-4291

2008-4132

2008-4171

2008-4181

2008-4201

2008-4230

2008-4257 2008-4271 2008-4284

2008-4291

Attachment Section 1R22: Surveillance Testing Procedures PT-2.3 Safeguard Power Operated Valve Operations Rev 10500

PT -3Q Containment Spray Pump Quarterly Test, Rev. 04501
PT -17.2 Process Radiation Monitors R-11 to R-18, R-20 to R-22 Iodine Monitors R-10A and R-10B, Rev. 12600 S-12.4

RCS Leakage Surveillance Record Instructions, Rev. 54

STP-O-12.1 Emergency Diesel Generator 'A', Rev. 00201

STP -O-R-2.2 Diesel Generator Load and Safeguard Sequence Test, Rev. 0
STP -O-2.6.5
SD [[]]
RCS Overpressure Protection System

PORV Operability Verification Rev. 0

Condition Report 2008-2831

Section 1EP2: Alert and Notification System Evaluation Condition Reports 2008-5155

2007-7713

Section

1EP 3: Emergency Response Organization Staffing and Augmentation System Documents
IP -EPP-5, Emergency Response Organization Expectations and Responsibilities, Rev. 00400
EPIP 5-9, Testing the Off-Hours Notification of the Response Organization and Quarterly Telephone Number Checks, Rev. 01700

EPIP 1-5, Notifications, Rev. 07800

Ginna's Nuclear Emergency Response Plan, Rev. 02800

Condition Reports 2008-4938

2008-5153

2007-8076

2007-8075

2007-4782 Section 1EP4: Emergency Action Level and Emergency Plan Changes Condition Reports 2007-4228

2007-6652 Section 1EP5: Correction of Emergency Preparedness Weaknesses Document Unusual Events Reports for July 4, 2007, and January 30, 2008-07-03 Condition Report 2008-0391

2008-3990

Attachment 2008-0929 2007-8729

2008-0962

2008-3927

2007-5951

2008-4533

Section

2OS 1: Access Control to Radiologically Significant Areas Procedures
RP -ALA-PLAN/RWP-PREP,
ALARA Planning and

RWP Preparation, Rev. 1

Condition Reports 2008-0411

2008-0895

2008-1196

2008-1423 2008-1482 2008-2132

2008-2228

2008-2231

Audits and Assessments 2007-0078 Radiography/Boundary Control

4th Quarter 2007 Quarterly Report Section

2OS 2:
ALARA Planning and Controls Procedures
RP -
ALA -PLAN/RWP-PREP
ALARA Planning and
RWP Preparation, Rev. 1
RP -
ALA -REVIEW
ALA [[]]

RA Job Reviews, Rev. 8 Condition Reports 2008-1087 2008-1964

2008-2506 2008-3957

Audits and Assessments 2007-0076

ALA [[]]

RA Planning

2007-0093 Source Term Control

4th Quarter 2007 Quarterly Report Section 2OS3: Radiological Instruments and Other Protective Equipment Condition Reports 2008-0246 2008-0368

2008-1007 2008-2448

2008-2525

Section

4OA 1: Performance Indicator Verification Documents

NEI 99-02, Nuclear Energy Institute Regulatory Assessment Performance Indicator Guideline, Rev. 5, July 2007

Attachment S-12.4,

RCS Leakage Surveillance Record Instructions Section 4

OA2: Identification and Resolution of Problems Documents 4th Quarter 2007 and 1st Quarter 2008 Corrective Action Trend Reports 1st and 2nd Quarter 2008 System Health Reports for All Systems Available

Condition Reports 2008-4567

2007-6158

2008-0935

Section

4OA 3: Followup of Events and Notices of Enforcement Discretion Document Troubleshooting Plan for

CR 2008-5802, June 30, 2008

Drawing 33013-1266 Auxiliary Building Chemical Volume and Control System, Boric Acid

P& [[]]

ID

Condition Report 2008-5802

Section 4OA5: Other Activities Documents A202, Evaluation of Compensatory Measures for Degraded Hemyc, June 30, 2006

EP-3-S-0306, Change Impact Evaluation Form, Rev. 3

Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configuration

PCR 2007-0018, Containment Recirculating Fan Cooler System Duct Removal, Rev. 0

PCR 2007-0021, Containment Permanent Sump 'B' Strainer Upgrade, Rev. 0

Regulatory Issue Summary 2005-07, Compensatory Measures to Satisfy the Fire Protection Requirements, April 19, 2005 Security Training PowerPoint Concerning Vehicle Searches Supplementary Response to GL 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized Water Reactors, February 29, 2008 Updated Final Safety Analysis Report, Rev. 20

Procedures A-3.1, Containment Storage and Closeout Inspection, Rev. 39

CN -
SEE -I-07-9, Ginna Sump Debris Downstream Effects Evaluation for
ECCS Equipment, Rev. 1
CN -SEE-I-07-10, Ginna Sump Debris Downstream Effects Evaluation for Valves, Rev. 1
EC [[]]

CS Sump Strainer Replacement installation Procedure for Ginna, Rev. 2

EP-3-P-0601, Containment Coating Condition Assessment Procedure, Rev. 0

ES-1.3, Transfer to Cold Leg Recirculation, Rev. 42

GC-76.11, Painting Application and Inspection, Rev. 5

Attachment

LIST [[]]
OF [[]]
ACRONY [[]]
MS [[]]
ADA [[]]

MS Agency-Wide Documents Access and Management System

AFW Auxiliary feedwater
ALA [[]]

RA As low as is reasonably achievable

ANS Alert and notification system
AS [[]]

ME American Society of Mechanical Engineers

AVT All volatile treatment
CE [[]]

DE Committed effective dose equivalent

CR Condition report

EAL Emergency action level
EC [[]]

CS Emergency core cooling system

EP Emergency preparedness
EP [[]]

RI Electric Power Research Institute

ERO Emergency response organization
FR [[]]

TP Full rated thermal power

GL Generic letter
GIN [[]]

NA R.E. Ginna Nuclear Power Plant

GSI Generic Safety Issue

HRA High radiation areas

HX Heat exchangers

I&C Instrumentation and control

IMC Inspection Manual Chapter

ISI Inservice inspection
LH [[]]

RA Locked high radiation areas

MOV Motor operated valve

NEI Nuclear Energy Institute

NCV Non-cited violation
NE [[]]

RP Nuclear emergency response plan

NRC U.S. Nuclear Regulatory Commission
OE [[]]
SS Operating experience smart sample
P& [[]]
ID Piping & instrument drawings
PA [[]]

RS Publicly Available Records

PCR Plant change record

PI Performance indicator

PMT Post-maintenance testing

RCA Radiologically controlled area

RCP Reactor coolant pump

RCS Reactor coolant system

RFO Refueling outage

RHR Residual heat removal

RWP Radiation work permit

SDP Significance determination process
SC [[]]

BA Self Contained Breathing Apparatus

SSC Systems, structures, and components

SW Service water
SWSR [[]]

OP Service water system reliability optimization program

TI Temporary instruction

TS Technical specification
UFS [[]]

AR Updated Final Safety Analysis Report

VCT Volume Control Tank

WO Work order