IR 05000244/2012009

IR 05000244-12-009; 09/10/2012 - 09/28/2012; R.E. Ginna Nuclear Power Plant; Triennial Fire Protection Inspection

ML12311A124
Person / Time
Site:	Ginna
Issue date:	11/05/2012
From:	Christopher Miller Division of Reactor Safety I
To:	Pacher J E Constellation Energy Nuclear Group
References
EA-12-209 EA-12-209, IR-12-009
Download: ML12311A124 (32)

Text

withcopies to the Regional Administrator, Region l; the Director, Office of Enforcement; and theNRC Senior Resident Inspector at R.E. Ginna Nuclear Power Plant.

J. Pacherln accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will beavailable electronically for public inspection in the NRC Public Document Room or from thePublicly Available Records System (PARS) component of the NRC's document system,Agencywide Documents Access and Management System (ADAMS). ADAMS is accessiblefrom the NRC Web site at http://www.nrc.oov/readinq-rm/adams.html (the Public ElectronicReading Room).

Sincerely,.)/HDLG-"Christopher G. Miller, DirectorDivision of Reactor SafetyDocket No: 50-244License No: DPR-18

Enclosure:

Inspection Report 0500024412012009

w/Attachment:

Supplemental Informationcc w/encl: Distribution via ListServ

SUMMARY OF FINDINGS

lR 0500024412012009:0911012012 - A912812012; R.E, Ginna Nuclear Power Plant; TriennialFire Protection Inspection.This report covered a two week on-site triennialfire protection team inspection by specialistinspectors. The NRC's program for overseeing the safe operation of commercial nuclear powerreactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, datedDecember 2006.No findings were identified for assessment.Enclosure

REPORT DETAILS

BackqroundThis report presents the results of a triennial fire protection inspection conducted in accordancewith NRC Inspection Procedure (lP) 71 1 1 1.05T, "Fire Protection." The objective of theinspection was to assess whether Constellation Energy Nuclear Group (Constellation) hadimplemented an adequate fire protection program, and whether posffire safe shutdowncapabilities had been established and were properly maintained at R.E. Ginna Nuclear PowerPlant (Ginna). The following fire areas and associated fire zones were selected for detailedreview based on prior inspection results and risk insights from the Ginna Individual PlantExamination of External Events (IPEEE):Fire Areas and/or Fire Zoneso Fire Zone ABB, Auxiliary Bldg Basement,. Fire Area BR1B, 1B Battery Room, Elev.o Fire Area EDG1A, 1A Emergency DieselCable Vault. Elev. 253 ft.Elevation (Elev.) 235 ft.253 ft.Generator (EDG) room, including the 1A EDGInspection of these fire areaslzones fulfilled the inspection procedure requirement to inspect aminimum of three samples.The inspection team evaluated Constellation's fire protection program (FPP) against applicablerequirements which included Technical Specifications, Operating License Condition 2.C.(3),NRC Safety Evaluation Reports (SER), Title 10 of the Code of Federal Regulations(10 CFR) 50.48, and 10 CFR Part 50, Appendix R, and Branch Technical Position (BTP)Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1 and Appendix A. The teamalso reviewed related documents that included the Updated Final Safety Analysis Report(UFSAR), Section 9.5.1, fire protection plan, firehazards analysis (FHA), and post-fire safeshutdown analyses.The team evaluated aspects of three mitigating strategies for responding to large fires andexplosions, which are required by Operating License Condition 2.C.(8), and10 CFR 50.54(hhx2). The team also reviewed related documents that included NEI 06-12,"8.5.b Phases 2 & 3 Submittal Guidance," Revision 2 (ML070090060). Inspection of thesestrategies fulfills the inspection procedure requirement to inspect a minimum of one sample.Specific documents reviewed by the team are listed in the attachment to this report,Enclosure REACTOR SAFEWInitiating Events, Mitigating Systems, and Barrier lntegrity1R05 Fire Protection (lP 711 11.05T).01 Protection of Safe Shutdown Capabilitiesa. lnspection ScopeThe team reviewed the FHA, post-fire safe shutdown analyses, and supporting drawingsand documents to verify whether the safe shutdown capabilities were properly protectedfrom fire damage. The team evaluated equipment and cable separation to determinewhether applicable separation requirements of Section lll.G of 10 CFR 50, Appendix R,and the Ginna design and licensing bases were maintained for the credited safeshutdown equipment and their supporting power, control, and instrumentation cables.The team's review included an assessment of the adequacy of the selected systems forreactor pressure control, reactivity control, reactor coolant makeup, decay heat removal,process monitoring, and associated support system functions.b. FindinqsNo findings were.02Passive Fire ProtectionInspection ScopeThe team walked down accessible portions of the selected fire areas to evaluatewhether the material conditions of the fire area boundaries were adequate for the firehazards in the area. The team compared the fire area boundaries, including walls,ceilings, floors, fire doors, fire dampers, penetration seals, electrical raceway andconduit fire barriers, and redundant equipment fire barriers and radiant energy heatbarriers to design and licensing basis requirements, industry standards, and the GinnaFPP, as approved by the NRC, to identify any potential degradation ornon-conformances.The team reviewed selected engineering evaluations, installation work orders, andqualification records for a sample of penetration seals to determine whether the fillmaterial was properly installed and whether the as-left configuration satisfied designrequirements for the intended fire rating. The team also reviewed similar records forselected fire protection wraps to verify whether the material and configuration wasappropriate for the required fire rating and conformed to the engineering design.The team also reviewed recent inspection and functional test records for fire dampers,and the inspection records for penetration seals and fire barriers, to verify whether theinspection and testing was adequately conducted, the acceptance criteria were met, andany potential performance degradation was identified.Enclosurea.

b. FindinqsNo findings were.03a.Active Fire ProtectionInspection ScopeThe team evaluated manual and automatic fire suppression and detection systems in theselected fire areas to determine whether they were installed, tested, maintained, andoperated in accordance with NRC requirements, National Fire Protection Association(NFPA) codes of record, and the Ginna FPP, as approved by the U,S. NuclearRegulatory Commission (NRC), The team also assessed whether the suppressionsystems capabilities were adequate to control and/or extinguish fires associated with thehazards in the selected areas.The team reviewed the as-built capability of the fire water supply system to verifywhether the design and licensing basis and NFPA code of record requirements weresatisfied, and to assess whether those capabilities were adequate for the hazardsinvolved. The team reviewed the fire water system hydraulic analyses to assess theadequacy of a single fire water pump to supply the largest single hydraulic load on thefire water system plus concurrent fire hose usage. The team evaluated the fire pumpperformance tests to assess the adequacy of the test acceptance criteria for pumpminimum discharge pressure at the required flow rate, to verify whether the criteria wasadequate to ensure that the design basis and hydraulic analysis requirements weresatisfied. The team also evaluated the underground fire loop flow tests to verify whetherthe tests adequately demonstrated that the flow distribution circuits were able to meetdesign basis requirements. In addition, the team reviewed recent pump and loop flowtest results to verify whether the testing was adequately conducted, the acceptancecriteria were met, and any potential performance degradation was identified.The team walked down accessible portions of the detection and water suppressionsystems in the selected areas and major portions of the fire water supply system,including motor and diesel driven fire pumps, interviewed system and programengineers, and reviewed selected condition reports (CR) to independently assess thematerial condition of the systems and components. In addition, the team reviewedrecent test results for the fire detection and suppression systems for the selected fireareas to verify whether the testing was adequately conducted, the acceptance criteriawere met, and any potential performance degradation was identified'The team assessed the fire brigade capabilities by reviewing training, qualification, anddrill critique records. The team also reviewed Constellation's fire fighting strategies (i.e.,pre-fire plans) and smoke removal plans for the selected fire areas to determine ifappropriate information was provided to fire brigade members and plant operators toidentify safe shutdown equipment and instrumentation, and to facilitate suppression of afire that could impact post-fire safe shutdown capability. The team independentlyinspected the fire brigade equipment, including personnel protective gear (e,9., turnoutgear) and smoke removal equipment, to determine operational readiness for fire fighting.Enclosure

.04.0 5b.4In addition, the team observed an announced fire brigade training drill, includingConstellation's post drill critique.FindinqsNo findings were identified.Protection from Damase from Fire Suppression Activitieslnspection ScopgThe team performed document reviews and plant walkdowns to determine whetherredundant trains of systems required for hot shutdown, located in the same or adjacentfire areas, were not subject to damage from fire suppression activities or from therupture or inadvertent operation of fire suppression systems. Specifically, the teamevaluated whether:A fire in one of the selected fire areas would not release smoke, heat, or hotgases that could cause unintended activation of suppression systems in adjacentfire areas which could potentially damage all redundant safe shutdown trains; orA fire suppression system rupture, inadvertent actuation, or actuation due to afire, in one of the selected fire areas, could not directly damage all redundanttrains (e.g., sprinkler caused flooding of other than the locally affected train); ando Adequate drainage was provided in areas protected by water suppressionsystems.FindinqsNo findings were identified.Alternative Shutdown CapabilitvInspection ScopeThe team reviewed the safe shutdown analysis, operating procedures, piping andinstrumentation drawings (P&lD), electrical drawings, the UFSAR, and other supportingdocuments for the selected fire areas to verify whether Constellation had properlyidentified the systems and components necessary to achieve and maintain post-fire safeshutdown conditions. The team evaluated selected systems and components creditedby the safe shutdown analysis for reactor pressure control, reactivity control, reactorcoolant system (RCS) makeup, decay heat removal, process monitoring, and supportsystem functions to assess the adequacy of Constellation's alternative shutdownmethodology. The team also assessed whether alternative post-fire shutdown could beperformed both with and without the availability of off-site power. The team walkeddown selected plant configurations to verify whether they were consistent with theassumptions and descriptions in the safe shutdown and fire hazards analyses. lnEnclosure

b.5addition, the team evaluated whether the systems and components credited for useduring post-fire safe shutdown would remain free from fire damage.The team reviewed the training program for licensed and non-licensed operators toverify whether it included alternative shutdown capability. The team also verifiedwhether personnel required for post-fire safe shutdown, using either the normal oralternative shutdown methods, were trained and available on-site at all times, exclusiveof those assigned as fire brigade members.The team reviewed the adequacy of procedures utilized for post-fire shutdown andperformed an independent walk through of procedure steps (i.e., a procedure tabletop)to assess the adequacy of implementation and human factors within the procedures.The team also evaluated the time required to perform specific actions to verify whetheroperators could reasonably be expected to perform those actions within sufficient time tomaintain plant parameters within specified limits.Specific procedures reviewed for normal and alternative post-fire shutdown included:o ER-Fire.O, Control Room Response to Fire Alarms and Reports;. ER-Fire.3, Alternate Shutdown for Aux Building BasemenVMezzanine Fire;. ER-Fire.5, Alternate Shutdown for Battery Room "8" Fire;. FRP-4.0, Fire Response Plan for Auxiliary Building Basement;. FRP-5.0, Fire Response Plan for Auxiliary Building Intermediate Floor;. FRP-18.0, Fire Response Plan for Battery Room "8"; and,o FRP-24.0, Fire Response Plan for EDG Room "A" and Cable Vault.The team reviewed selected operator manual actions to verify whether they had beenproperly reviewed and approved and whether the actions could be implemented inaccordance with plant procedures in the time necessary to support the safe shutdownmethod for each fire area. The team also reviewed the periodic testing of the alternativeshutdown transfer and isolation capability, and instrumentation and control functions, toevaluate whether the tests were adequate to ensure the functionality of the alternativeshutdown capability.FindinqsFailure to Evaluate the lmpagt of Usinq the Volume Control Tpnk durinq AlternativeShutdownlntroduction: The team identified a violation of very low safety significance (Green) ofGinna Operating License Condition 2.C.(3), "Fire Protection Program," for failure toevaluate the affects of allowing the volume control tank (VCT) to remain aligned to the"A" charging pump during alternative shutdown activities. The alternative shutdownprocedures required manual alignment of the refuel water storage tank (RWST) to thecharging pump. However, the VCT, normally pressurized with hydrogen (H2)gas forreactor coolant chemistry control, remained connected to the charging pump suction inparallelwith the RWST, which was vented to atmosphere. The potentialfor Hz gas to.1Enclosure 6enter the charging pump was not analyzed to ensure the established safe shutdown flowpath would not be adversely affected. This issue was determined to satisfy the criteriaspecified for the exercise of enforcement discretion for plants in transition to a fireprotection program that meets the requirements of 10 CFR 50.48(c), "National FireProtection Association Standard NFPA 805."Description: The Ginna safe shutdown analysis, documented in DA-EE-2000-066,"Appendix R Conformation Analysis," credited the "A" charging pump, aligned to theRWST, as providing the RCS makeup function. The VCT flow path to the chargingpump was not protected from fire damage, and was not credited as a water source forRCS makeup in the safe shutdown analysis. ER-Fire.3, "Alternate Shutdown for AuxBuilding Basement/Mezzanine Fire," required operator manual actions (OMA) to alignthe RWST to the "A" charging pump and isolate sources of high-temperature water fromthe VCT, such as RCS letdown and reactor coolant pump (RCP) seal return water.Those OMAs were required to be performed prior to locally starting the charging pump,were included in Constellation's Time CriticalAction Management Program, and wereanalyzed in DA-NS-2002-008, "Operator Action Time Requirement Evaluation." Theteam identified that the VCT outlet valve was not procedurally closed and remainedopen, aligned to the charging pump suction, in parallel with the flow path from theRWST. ln addition, the team also identified that the procedure steps to close the H2 gassupply to the VCT required re-entry into the auxiliary building basement and mezzanine(ABBM) fire area, did not take place until after charging pump flow was re-established,and were not included in Constellation's Time CriticalAction Management Program.Based on available analysis and calculations, the team could not determine whether theVCT H2 gas could enter the pump's suction and gas bind the pump, resulting in a loss ofthe credited RCS makeup function. Therefore, the team concluded that Constellationhad not adequately evaluated the effects of allowing the VCT to remain in parallel withthe RWST during alternative shutdown for a fire in the ABBM.Constellation performed an immediate detailed evaluation of this issue inECP-12-000799, "Evaluation of Charging Pump Availability During Fire Scenarios."Based on that evaluation, Constellation concluded that under the worst case firescenario, the charging pump would entrain approximately 16 percent gas by volume forapproximately the first 5 minutes, after which the gas entrainment would be reduced toapproximately 2 percent. The calculation results were also reviewed by the pumpvendor, who determined the charging pump could be expected to operate successfullyunder those circumstances. In addition, while this issue was being analyzed,Constellation implemented several interim compensatory measures to reduce thelikelihood of fires in the ABBM, and installed a plant modification and procedure revisionto ER-Fire.3 that included instructions to locally isolate the VCT outlet valve.Constellation entered this issue into its corrective action program, as CR-2012-06410,for long term resolution.The team reviewed Constellation's evaluation, interim compensatory measures, andprocedure revisions, and concluded that the interim actions were adequate to addressthis fire protection program issue until a final evaluation is completed, in accordance withConstellation's NFPA 805 transition program.Enclosure 7Analvsis: Constellation's failure to ensure the RCS makeup function, credited in the safeshutdown analysis, would be maintained, and specifically to verify that the VCT and theH2 gas issue would not have an adverse effect on the reliability of the "A" charging pumpwas a performance deficiency. This finding was more than minor because it adverselyaffected the protection against external factors (i.e., fire) attribute of the MitigatingSystems Cornerstone and affected the cornerstone objective of ensuring the availabilityand reliability of systems that respond to initiating events to prevent undesirableconsequences. In addition, this issue was similar to NRC Inspection Manual Chapter(lMC) 0612, Appendix E, "Examples of Minor lssues," Example 3.k, which stated that ananalysis to verify the adequacy of design contained incorrect assumptions. The exampleconcluded that the issue was more than minor if the error resulted in a condition wherethere was a reasonable doubt on the operability of the component. For this issue, aknowledgeable engineer could not determine the adequacy of the safe shutdownanalysis based on a review of existing analysis or calculations without performingadditional complex analysis and preliminary calculations.The team used IMC 0609, Significance Determination Process (SDP), Appendix F,Attachment 1, "Fire Protection SDP Phase 1 Worksheet," to determine the safetysignificance of this finding. Based upon the postulated ABBM fire scenario,Constellation determined by analysis that the charging pump would remain available forsafe shutdown RCS makeup with both the VCT and RWST aligned and some limitedVCT H2 gas entrainment. Accordingly, the team assigned a low degradation rating tothis finding and the issue screened as very low safety significance (Green) per thePhase 1 evaluation risk criteria.Cross-cutting aspects are not applicable to findings involving enforcement discretion.Enforcement: Ginna Operating License Condition 2.C.(3), "Fire Protection Program," inpart, required Constellation to implement and maintain in effect all fire protectionfeatures described in licensee submittals referenced in and as approved or modified bythe NRC's SER, dated February 1979, and subsequent supplements. ND-FPP, "FireProtection Program," in part, stated that EPM-FPPR-ANL, "Fire Protection ProgramReport," was utilized to implement the fire protection program requirements approved bythe NRC SER. EPM-FPPR-ANL Volume 3, Part lV, Section 4.2.1, in part, stated that foreach safe shutdown system, the primary flow paths and operational characteristics thatmust be established to accomplish the desired safe shutdown performance goal wereidentified, as well as the components that established the primary safe shutdown flowpath and/or system operation.Contrary to the above, on September 21,2012, the NRC identified that Constellation didnot identify the VCT flow path to the "A" charging pump was part of the RCS makeupflow path, and did not identify the operational characteristics that must be established toaccomplish the desired safe shutdown performance goal of this flow path. Specifically,Constellation did not identify that the VCT remained connected to the charging pump(through the VCT outlet valve) in parallel with the RWST during alternative shutdownactivities. Further, Constellation did not evaluate the impact of the VCT, which wasnormally pressurized with Hz gas, on the safe shutdown performance goal of that flowEnclosure 8path. The violation was historical and occurred when Ginna completed its first safeshutdown analysis.Constellation was in transition to NFPA 805 and, therefore, this NRC-identified violationwas evaluated in accordance with the criteria established in Section 9.1 of the NRC'sEnforcement Policy regarding Enforcement Discretion for Certain Fire Protection lssues(10 CFR Part 50.48). Because allthe criteria were met, the NRC exercised enforcementdiscretion for this issue.Operator ManualActions to Restore Reactor Coolant Svstem Makeup Function notFeasible and Reliable Durinq Alternative Shutdownlntroduction: The team identified a violation of very low safety significance (Green) ofGinna Operating License Condition 2.C.(3), "Fire Protection Program," for failure toevaluate the feasibility and reliability of OMAs to restore the RCS makeup functionduring alternative shutdown for a fire in the ABBM. Several OMAs were required to beperformed in the fire area to locally align the credited charging pump and a thoroughevaluation of these OMAs as well as an evaluation to determine when the fire area couldbe reasonably reentered was not performed. This issue was determined to satisfy thecriteria specified for the exercise of enforcement discretion for plants in transition to aFPP that meets the requirements of 10 CFR 50.48(c), "National Fire ProtectionAssociation Standard NFPA 805,"Description: While evaluating the alternative shutdown capability for a fire in the ABBM,the team questioned whether Constellation appropriately evaluated the feasibility andreliability of several OMAs to locally align the credited charging pump for the RCSmakeup function of post-fire safe shutdown, The team walked down ER-Fire.3 andidentified that an OMA to isolate RCP seal return to the VCT was performed at a locationwithout any emergency light unit (ELU), During the walkdown, the team also identifiedthat several additional OMAs were performed in the fire area before entering thecharging pump room to locally operate the "A" charging pump. The charging pump roomwas a separate fire area within the ABBM.The team reviewed several analyses to determine the timeline requirements tore-establish charging pump flow during an ABBM fire scenario, including:. DA-ME-2000-075, Pressurizer, VCT, and RWST Evaluations for Appendix R;. DA-NS-2002-008, Operator Action Time Requirement Evaluation; and,. DBCOR 2006-0057, Appendix R, Time CriticalTasks Validation for EPU.The team identified that Constellation had determined by analysis that charging pumpflow must be re-established within 23.9 minutes (i.e., approximately 24 minutes) tomaintain pressurizer level in the indicating range consistent with the Appendix Rperformance goals for alternative shutdown systems. Additionally,lhe 24 minutetimeline requirement had been reduced from 36.75 minutes (i.e., approximately37 minutes) during the extended power uprate (EPU) modification in November 2006.To support the timeline reduction in 2006, Constellation had performed two timevalidations: in one validation, 16 minutes was required to perform the OMAs; in theEnclosure 9second validation, 17 minutes was required. Constellation concluded in DBCOR 2006-0057, "Appendix R Time Critical Tasks Validation for EPU," that operating crews couldcomplete the required time critical actions within the required 24 minutes.The team interviewed knowledgeable personnelabout the timeline validationperformances and determined that Constellation did not adjust the simulatedwalkthroughs for realistic conditions that would be expected during an ABBM firescenario. Realistic conditions that should have been considered included:Reduced visibility due to smoke;Lighting only provided by ELUs;Operators wearing a self contained breathing apparatus for the duration of theOMAs in the ABBM due to life safety concerns;Potential high temperature conditions and heat stress;Interference from fire brigade or fire suppression agents such as fire hoses andwet floors; and,Missing plastic valve labels or other challenges that may occur as the result offire damage.The team further determined that if 24 minutes were required to restore charging flowand, under the best conditions, 16 minutes were required to complete the OMAs withinthe ABBM, then an operator must enter the fire area, potentially alone and withoutturnout gear before the fire brigade would be expected to arrive on the scene, withinabout 8 minutes of fire initiation (24 - 16 = 8 minutes). The team concluded thatConstellation had not adequately evaluated the reasonableness of entering a fire areawithin I minutes and had not adequately determined the reliability and feasibility of theOMAs to restore charging pump flow. Constellation entered this issue into its correctiveaction program, as CR-2012-06530 and CR-2012-006184, for long term resolution.Constellation immediately staged a lantern at the RCP seal return isolation valvelocation, in lieu of an ELU, and performed a detailed assessment of the time required tore-establish charging pump flow, to evaluate the risk significance of a delay in this OMA.As interim compensatory measures, Constellation promptly initiated a procedure changeto ER-Fire.3 that provided operators with additional guidance on restoration of chargingpump flow. The operators were also provided a shift briefing package (i.e., operatortraining) to understand the risk perspective and priority of charging pump restoration.The team reviewed Constellation's interim compensatory measures and procedurerevisions, and concluded that the interim actions were adequate to address the fireprotection program issues until a final evaluation can be completed, in accordance withConstellation's NFPA 805 transition program.The inspectors also reviewed Constellation's procedures for the review of fire protectionprogram changes, because both issues (i.e., the lack of an ELU at the RCP seal returnisolation valves, and the timeline validation for RCS makeup restoration) were the resultof program changes to the fire protection program that had not been adequatelyreviewed. Constellation implemented and maintained two procedures that includedaaaaaEnclosure 10instructions for FPP change reviews, A-202, "Staff Responsibilities for the Fire ProtectionProgram," and EP-3-P-0132, "Fire Protection and Appendix R ConformanceVerifications." EP-3-P-0132 was intended for reviewing station modifications, while A-202 was intended for all other plant changes, such as procedures, which were notspecifically addressed by the modification process. Contrary to these procedurerequirements, the new OMA (i.e., isolate RCP seal return) and the timeline requirementchange (i.e., restore charging pump flow within 24 minutes) had not been reviewed inaccordance with the checklist instructions provided within these two procedures.Analvsis: Constellation's failure to adequately evaluate the FPP changes for OMAs thatisolated RCP seal return and timeline requirements to restore charging pump flow thatwere reduced as a result of EPU implementation was a performance deficiency. Thisfinding was more than minor because it adversely affected the protection againstexternal factors (i.e., fire) attribute of the Mitigating Systems Cornerstone and affectedthe cornerstone objective of ensuring the availability and reliability of systems thatrespond to initiating events to prevent undesirable consequences.The team used IMC 0609, "Significance Determination Process (SDP)," Appendix F,Attachment 1, "Fire Protection SDP Phase 1 Worksheet," and Attachment 2,"Degradation Rating Guidance Specific to Various Fire Protection Program Elements," todetermine the safety significance of this finding. A moderate degradation rating wasassigned to this finding because the feasibility to perform specified OMAs was notapparent. Ginna was in transition to NFPA 805 and had recently completed a peerreview of their fire probabilistic risk analysis (Fire PRA). Therefore, the team concludedthat a more appropriate and accurate characterization of the risk significance of thisissue would be obtained by using the Fire PRA to perform a Phase 3 evaluation.Additionally, the ABBM fire scenario required the implementation of alternative safeshutdown procedures (i.e., control of several safe shutdown systems or componentsfrom outside the main control room) and the Phase 2 SDP did not explicitly addressalternative safe shutdown fire scenarios.For the Phase 3 evaluation, the Region I Senior Reactor Analyst (SRA) reviewedConstellation's risk assessment of this issue. Constellation used its recently completedFire PRA to approximate the increase in risk associated with this issue. Constellation'sevaluation assumed that operators would have 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore charging flow for theABBM fire scenarios of interest. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time limit was conservatively establishedbased upon thermo-hydraulic analysis that determined there were approximately 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />sbefore core uncovery, assuming RCS leakage of 364 gpm, for postulated failures of bothRCP seals. The thermo-hydraulic analysis indicated that after 90 minutes (withoutoperator intervention) the RCS water level would decrease to the elevation of the RCPseals, at which point steam flashing would occur and reduce the postulated leakage rateto within the capacity of one charging pump. Accordingly, the Fire PRA conservativelyused two hours to complete the OMA. Unlike the Appendix R performance goals, tomaintain reactor water level within the indicating range of the pressurizer, the successcriteria for the Fire PRA model was to maintain RCS inventory sufficient to prevent coreuncovery. For the fire scenarios of interest, this equated to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Accordingly, a timedelay (due to fire fighting activities) before an operator could reasonably access theABBM, locally operate the charging pump, and perform related actions within theEnclosure 11conservatively established 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time period, would be insignificant with respect to thetime available to ensure the core remained covered. The SRA's review determined thatConstellation's risk assessment was reasonable and appropriately conservative for thisNRC-identified issue.Although Constellation's deterministic safe shutdown analysis relied upon completingthis OMA within 24 minutes, a more detailed analysis in the Fire PRA demonstrated thatallowing up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> would not result in any significant risk increase. Therefore, theSRA determined that this finding was of very low risk significance (Green).Cross-cutting aspects are not applicable to findings involving enforcement discretion.Enforcement. Ginna Operating License Condition 2.C.(3), "Fire Protection Program," inpart, required Constellation to implement and maintain in effect all fire protectionfeatures described in licensee submittals referenced in and as approved or modified bythe NRC's SER dated February 1979, and subsequent supplements. ln addition, thelicense condition allowed Constellation to may make changes to the approved fireprotection program without prior NRC approval only if those changes would notadversely affect the ability to achieve and maintain safe shutdown in the event of a fire.ND-FPP, "Fire Protection Program," in part, stated that A-2A2 and other Ginna StationProcedures were utilized to implement fire protection program requirements approved bythe NRC SER.EP-3-P-01 32, "Fire Protection and Appendix R Conformance Verifications," Section1.1.2, in part, stated that this procedure ensured applicable Appendix R analyses werereviewed for plant modifications. EP-3-P-0132, Attachment 2, "Appendix R/FireProtection Conformance Verification Checklist," Section C, required that the basis foracceptability and the conclusion that the change did not adversely impact the ability toachieve and maintain safe shutdown shall be documented.ln addition, A-202, "Staff Responsibilities for the Fire Protection Program," Section 3.1.2,"lnstructions," stated that the license condition allowed changes to the approved fireprotection program without prior NRC approval only if those changes did not adverselyaffect the ability to achieve and maintain safe shutdown. In addition, Section 3.1.2required that 4-202 Attachment A, "Fire Protection Program and Appendix RConformance Review Screen," shall be completed for all proposed changes that(1) were not addressed by the modification process, and (2) changed fire programprocedures, to determine if further review was required and to document theacceptability of the proposed changes.Contrary to the above, Constellation made changes to the approved fire protectionprogram, through a modification (in 2006) and a procedure change (in 2Q12), withoutfirst verifying that those changes did not require further review and did not adverselyaffect the ability to achieve and maintain safe shutdown in the event of a fire.Specifically, on October 31, 2006, Constellation implemented an EPU modification thatincluded revising DA-N5-2002-008, "Operator Action Time Requirement Evaluation," toreduce the timeline within which the "A" charging pump flow must be re-established.Enclosure

.061 2However, Constellation did not perform the required verifications and, as a result, did notevaluate the reasonableness of the reduced timeline to determine whether the changeadversely impacted the ability to achieve and maintain safe shutdown. Specifically, onApril 20, 2010, Constellation revised ER-Flre.3, "Alternate Shutdown for Aux BuildingBasement I Mezzanine Fire," to include operator manual actions within that fire area toisolate RCP seal return flow to the VCT. However, Constellation did not perform therequired screen and, as a result, did not determine whether further review was required.Constellation was in transition to NFPA 805 and, therefore, this NRC-identified violationwas evaluated in accordance with the criteria established in Section 9.1 of the NRC'sEnforcement Policy regarding Enforcement Discretion for Certain Fire Protection lssues(10 CFR Part 50.48). Because all the criteria were met, the NRC exercised enforcementdiscretion for this issue.Circuit AnalvsisInspection ScopeThe team reviewed Constellation's post-fire safe shutdown analysis for the selected fireareas to determine whether the analysis identified both required and associatedelectrical circuits and cables for the systems and components necessary to achieve andmaintain safe shutdown. The team reviewed electrical schematics and cable routingdata for power, control, and instrument cables associated with selected components.Specifically, the team evaluated the selected circuits and cables to determine whetherthey were (a) adequately protected from potential fire damage, or (b) analyzed to showthat fire-induced faults (e,g., hot shorts, open circuits, and shorts to ground) would notprevent safe shutdown, or (c) analyzed to show that potential damage could be mitigatedwith approved operator manual actions, in order to verify whether fire-induced faultscould adversely impact safe shutdown capabilities. The team's evaluations consideredcredible fire scenarios, cable insulation attributes, cable failure modes, cable routing,and common power supply or electrical bus configurations.In addition, the team reviewed cable raceway drawings and cable routing databases fora sample of components required for post-fire safe shutdown to determine whetherthose cables were routed as described in the safe shutdown analysis. The team alsoreviewed equipment important to safe shutdown, but not part of the success path, toassess whether Constellation's safe shutdown methodologies were appropriate,conformed to design and licensing basis requirements, and appropriately considered theguidance in NRC Regulatory Guide 1 .189, "Fire Protection for Nuclear Power Plants,"Revision 2.Cable failure modes were reviewed for the following components:. "A" Service Water Pump (PSW01A). "A" Charging Pump (PCH01A). "A" Component Cooling Water Pump (PAC02A). "A" Residual Heat Removal Pump (PAC01A)Enclosure

b.13o "A" Steam Generator Atmospheric Relief Valve (AOV-341 1). Pressurizer Power Operated Relief Valve (PCV-430). Pressurizer Power Operated Relief Valve (PCV-431C)The team reviewed a sample of circuit breaker and fuse over-current protectioncoordination studies to determine whether equipment, needed for postfire safeshutdown activities, could be adversely affected due to a lack of coordination that couldresult in a common power supply or common electrical bus concern. The team alsoevaluated whether coordination studies appropriately considered multiple faults due tofire. In addition, the team reviewed a sample of circuit breaker maintenance records, forcomponents required for safe shutdown, to determine whether the breakers wereproperly maintained.The team assessed the transfer of controlfrom the control room to the alternativeshutdown locations to determine whether it would be affected by fire-induced circuitfaults (e.g., by the provision of separate fuses and power supplies for alternativeshutdown control circuits).FindinqsNo findings were identified.CommunicationsInspection ScopeThe team reviewed safe shutdown procedures, the safe shutdown analysis, andassociated documents to verify whether an adequate method of communications wouldbe available to plant operators following a fire. Specifically, the team evaluated whetherplant telephones, page systems, and portable radios would be available for use andwere properly maintained. During this review, the team considered the effects ofambient noise levels, clarity of reception, reliability, and coverage patterns. The teaminspected selected emergency storage lockers to independently verify whether portablecommunication equipment was available for the fire brigade and plant operators. Inaddition, the team evaluated whether radio or phone repeaters, transmitters, and powersupplies would be reasonably unaffected by a fire.FindintrsNo findings were identified.Emerqencv LiqhtinqInspection ScopeThe team walked down the emergency lights in the selected fire areas to independentlyevaluate the placement and coverage areas of the lights. The team assessed whetherthe lights provided adequate illumination on local equipment and instrumentationEnclosure.07a..08a.

.09 b.a.b..1014required for post-fire safe shutdown, to ensure local operations could be reliablyperformed under expected post-fire conditions. Emergency light placement was alsoevaluated to determine adequate illumination of local area access and egress pathways.The team verified whether the emergency light batteries were rated for at least an 8-hourcapacity. Preventive maintenanCe procedures, the vendor manual, completedsurveillance tests, and battery replacement practices were also reviewed to evaluatewhether the emergency lighting had been maintained in a manner that would ensurereliable operation.FindinqsNo findings were identified.Cold Shutdqwn RepairsInspection ScopeThe team reviewed Constellation's procedure instructions to repair components whichmight be damaged by fire and were required to achieve post-fire cold shutdown. Theteam evaluated selected cold shutdown repairs to determine whether they could beachieved within the time frames assumed in the design and licensing bases. In addition,the team verified whether the necessary repair equipment, tools, and materials (e.9.,pre-cut cables with prepared attachment lugs) were available and accessible on site.FindinqsNo findings were identified.Compensatorv MeasuresInspection ScopeThe team verified whether compensatory measures were in place for out-of-service,degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems,or features (e,g., detection and suppression systems and equipment, passive firebarriers, pumps, valves, or electrical devices providing safe shutdown functions orcapabilities). The team evaluated whether the short term compensatory measuresadequately compensated for the degraded function or feature until appropriate correctiveaction could be taken and whether Constellation was effective in returning the equipmentto service in a reasonable period of time.The team noted that for the selected fire areas, which were designated as10 CFR Part 50 Appendix R, Section lll.G.2 areas, there were no compensatorymeasures in the form of operator manual actions.Enclosure

b..11a.15FindinosNo findings were identified.Review and Documentation of Fire Protection Proqram ChanqesInspection ScoQeThe team reviewed recent changes to the approved fire protection program to assesswhether those changes had an adverse effect on the ability to safely shutdown,FindinqsNo findings were identified.Control of Transient Combustibles and lqnition SourcesInspection ScopeThe team reviewed Constellation's procedures and programs for the control of ignitionsources and transient combustibles to assess their effectiveness in preventing fires andin controlling combustible loading within limits established in the FHA. A sample of hotwork and transient combustible control permits were reviewed to assess the adequacy ofConstellation's fire protection program administrative controls. The team performedplant walkdowns to independently verify whether transient combustibles and ignitionsources were being properly controlled in accordance with administrative controls.FindinqsNo findings were identified.Larqe Fires and Explosions Mitiqation StrateqiesInspection ScopeThe team reviewed selected mitigation strategies intended to maintain or restore coredecay heat removal and spent fuel pool cooling capabilities under the circumstancesassociated with loss of large areas of the plant due to large fires or explosions. Theteam assessed whether Constellation continued to meet the requirements of licenseCondition 2.C.(8) and 10 CFR 50.54(hhx2). The team reviewed three mitigationstrategies:. lnternal and External Spent Fuel Pool Makeup and Sprayr Turbine-Driven Auxiliary Feedwater Pump Manual Operation. Steam Generator Depressurization and Makeup Using the Portable PumpThe team's review included: a detailed assessment of the procedural guidance; a walkdown of the strategies with trained operators to assess the feasibility of the strategiesEnclosureb..12a.b..13a.

16and operator familiarity; maintenance and surveillance testing of all designated strategyequipment; and an independent inventory check of all strategy equipment to ensure theappropriateness of equipment storage and availability. The team also evaluated theadequacy of corrective actions associated with issues identified during previousinspections as well as reviewed a recent self-assessment in this area.b. FindinosNo findings were identified.4.

4OA2 ldentification and Resolution of Problems (lP 71152)a. Inspection ScopeThe team reviewed a sample of CRs associated with the fire protection program, post-fire safe shutdown issues, and mitigation strategy issues to determine whetherConstellation was appropriately identifying, characterizing, and correcting problemsassociated with these areas and whether the planned or completed corrective actionswere appropriate. The CRs reviewed are listed in the attachment'b. FindinqsNo findings were identified.4OAO Meetinqs. includinq ExitThe team presented the inspection results to Mr. Joseph Pacher, Site Vice President,and other members of Constellation's staff on September 28,2012. The team verifiedthat this report does not contain proprietary information'Enclosure

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTAGT

Licensee Personnel

K. Charland, Licensing Engineer

M. Edelstein, Fire Marshal

S. Kimbrough, PRA Engineer

J. Jackson, Supervisor, Licensing

C. Junot, Fire Protection Specialist

D. Lovegren, Electrical Design Engineer

K. Masker, Operations Procedure Writer

M. McGraw, Fire Protection System Engineer

T. Miller, Electrical Design Engineer

P. Schipp, Supervisor, Electrical/ l&C Design EngineeringB, Weaver, Supervisor, BOP Engineering

NRC Personnel

N. Perry, Senior Resident Inspector - Ginna

D. Dodson, Resident Inspector - Ginna

D. Frumkin, Fire Protection Branch, Risk Assessment Division, Nuclear Reactor Regulation(NRR)

P. Lain, Fire Protection Branch, Risk Assessment Division, NRRLIST OF ITEMS OPENED, CLOSED, AND DISCUSSEDNone.Attachment

A-2LIST OF DOCUMENTS REVIEWEDFire Protection Licensinq and Desion Basis DocumentsDA-EE-2000-066, Appendix R Conformation Analysis (safe shutdown analysis), Rev. 2EPM-FPPR ANL, Fire Protection Program Report Volumes 1, 2, & 3, Rev. 8Letter, RG&E to NRC, Appendix R, Alternative Shutdown System (accession no. 8401250104),dated 1116184Letter, RG&E to NRC, Fire IPEEE (M1080170020), dated 6/30/98Letter, RG&E to NRC, Fire Protection (accession no. 4006003751), dated 2124/77ND-FPP, Fire Protection Program (FPP), Rev 14NRC Branch Technical Position (BTP) APCSB 9.5-1 and Appendix A, Guidelines for FireProtection for Nuclear Power PlantsNRC Safety Evaluation Report (SER), Amendment No. 24 to Ginna Operating License AddingLicense Condition Relating to the Completion of Facility Modifications for Fire Protection(accession no. 79031 40202), dated 21 1 4/79NRC SER Supplement No. 1, Fire Protection (accession no. 8103090712), dated 12117180NRC SER Supplement No. 2, Fire Protection (accession no. 8102270116), dated 216181NRC SER Supplement No. 3, Fire Protection (accession no. 8107150433), dated 6122181NRC SER, Appendix R ltems lll.G.3. and lll.

L. (accession no. 8503050432), dated 2127185NRC SER, Exemptions to lll.

G. of Appendix R (M1010540388), dated 3121185UFSAR Section 9.5.1, Fire Protection Systems, Rev' 23Calculations. Analvsis. and Enqineerinq Evaluations109682-M-012, Appendix R Steam Generator Water Solid Cooldown Analysis with RELAP5 forEPU, Rev.01-DC-787-0428-11, Fixed Fire Suppression Systems Modifications (EWR-1833), Rev. 21-DC-787-0428-22, Fixed Fire Suppression Systems Modifications (EWR-1833), Rev. 032-5009845-00, Ginna Safe Shutdown RELAP5 Analysis, Rev' 051-9089546-00, Nuclear safety capability Assessment, dated 212112,4-601.10, Time CriticalAction Management Program, Rev' 0DA-EE-2000-066, Appendix R Conformance Analysis, Rev. 2DA-EE-93-104-07,480V Coordination and Circuit Protection Study, Rev. 7DA-EE-g3-107-O7,4kV Overcurrent Relays Coordination & Circuit Protection Study, Rev. 5DA-EE-96-005-07, Motor Control Center Coordination Analysis, Rev. 14DA-EE-99-066, DC System Fuse Coordination, Rev' 2DA-ME-2000-001, City Water Yard Loop to EDG Cooling, Rev. 5DA-ME-2000-040, City Water Yard Loop Cross-Tie to Fire Yard Loop, Rev. 3DA-ME-2000-062, lmpact of Fire on Service Water Piping in EDG1B, Rev. 0DA-ME-2000-075, Pressurizer, VCT, and RWST Evaluations Rev. 2DA-ME-2001-031, Fire System Flow & Pressure Requirements, Rev. 2DA-ME-94-004, Fire Hose Reel Design Analysis, Rev' 0DA-ME-94-118-02, PENQ-O2 Caulk Seal Qualification, Rev' 0DA-ME-94-118-10, PENQ-10 Cable Tray Seal Qualification, Rev. 0DA-ME-94- 118-11, PENQ-1 1 Pipe/ConduiUsleeve Seal Qualification, Rev. 0DA-ME-96-070, Fire Water Sprinkler Hydraulic Calculations, Rev. 1DA-NS-2002-008, Operator Action Time Requirement Evaluation, Rev. 5Attachment

A-3DBCOR 2006-0057, Appendix R Time Critical Tasks Validation for EPU, dated 10/31/06DBCOR 2008-0071, Review Fire Area Assessment - Fire Area ABBM, dated 811108DBCOR 2008-0079, Review Fire Area Assessment - Fire Area EDG1A, dated 811108ECP-12-000799, Evaluation of Charging Pump Availability During Fire Scenarios, Rev. 0ER-SC.2, High Water (Flood) Plan, Rev. IEWR-1833 Section 10, Sectionalizing Valves on Existing Fire Piping, Rev. 0JN-4, Sizing N2 Supply Requirements, Rev. 0SC-3.17, Auxiliary Bldg Flood Barrier Installation/Removal/lnspection, Rev. 2Drawinqs and Wirinq Diaorams03021-1055, Permanent Caulk Seal Details, Rev. 003021-1063, Cable Tray Penetration Seal Details, Rev. 003021-1064, Pipe/Conduit/Sleeve Fire Penetration Seal Details, Rev' 0$A21-1066, Non-rated Fire Penetration Seal Details, Rev' 021488-0100 Sh. 4, Fire, Smoke, & Pressure Barriers, Rev. 1321488-0102 Sh. 1, Battery Room Penetration Locations, Rev. 521488-0102 Sh. 2, Battery Room Penetration Locations, Rev. 1021488-011 1 Sh. 4, 1B EDG Penetration Locations, Rev. 521488-0201 Sh. 1&3, Hemyc FireWrap in Battery Room, Rev. 121946-0071A Sh. 1,480V Bus 14 Charging Pump A Control Schematic, Rev.521946-0071A Sh. 2,480V Bus 14 Charging Pump A Control Schematic, Rev. 321946-0072A Sh. 1, 480V Bus 14 Component Cooling Water Pump Control Schematic, Rev. 621946-0072A Sh. 2,480V Bus 14 Component Cooling Water Pump Control Schematic, Rev. 121946-00784, 480V Bus 14 Residual Heat Removal Pump Control Schematic, Rev. 521946-0081A Sh. 1, 480V Bus 18 Service Water Pump A Control Schematic, Ref 421946-0081A Sh. 2,480V Bus 18 Service Water Pump A Control Schematic, Ref 421946-0730 Sh. 1, AOV-341 1, S/G Atmospheric Relief Valve Control Schematic, Rev. 421946-0730 Sh. 2, AOV-3411, S/G A Atmospheric Relief Valve Control Schematic, Rev. 221946-0754 Sh. 1&2, Pressurizer Power Operated Relief Valve Control Schematic, Rev. 121946-0755 Sh. 1&2, Pressurizer Power Operated Relief Valve Control Schematic, Rev. 1330'13-0710A Sh. 1, EDG Elementary Diagram, Rev' 1133013-1537,18 EDG Vault Fire Barrier, Rev. 433013-1736 Sh. 1, EDG Control Schematic, Rev. 1533013-1736 Sh.2, EDG Control Schematic, Rev. 1733013-2543, Auxiliary Bldg Basement Fire Response Plan (hazard barrier dwg), Rev. 333013-2544, Turbine Bldg Basement Fire Response Plan (hazard barrier dwg), Rev. 1039013-2546, Auxiliary Bldg Intermediate Floor Fire Response Plan (hazard barrier dwg), Rev. 433013-2552, Auxiliary Bldg Operating Floor Fire Response Plan (hazard barrier dwg), Rev. 833013-2555, TSC Fire Response Plan (hazard barrier dwg), Rev' 833013-2559, Control Bldg Basement Fire Response Plan (hazard barrierdwg), Rev. 1133013-2560, Transformer Yard Fire Response Plan (hazard barrier dwg), Rev, 433013-2567, Control Bldg Sections Fire Response Plan (hazard barrier dwg), Rev. 333013-2568, Auxiliary Bldg Sections Fire Response Plan (hazard barrier dwg), Rev. 133013-2571, Screen House Fire Response Plan (hazard barrier dwg), Rev. 6A-221A-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112BB-1-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112BB-52-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112Attachment

A-4BB-56-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112C206886w, Motor Driven Fire Pump Certified Test Curve, dated 4126102C206888w, Engine Driven Fire Pump Certified Test Curve, dated 4126102D-201-016, EDG ElectricalVaults, Rev. 6D-215-161, EDG Power Duct Run , Rev. 7l-305A-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112PACAD-2103, Auxiliary Bldg Basement Floor Arrangement, Elev. 235 ft., Rev. 0Pioinq and lnstrumentation Diaqrams33013-1265, Sh. 1, Chemical Volume Control System Charging (CVCS)'33013-1265, Sh.2, ChemicalVolume Control System Charging (CVCS)'33013-1606 Sh. 1, Fire Protection System Yard Loop P&lD, Rev.233013-1989, Fire Protection System P&lD, Rev. 2533013-1990 Sh. 1, Fire Protection System P&lD, Rev'33013-1990 Sh. 2, Fire Protection System P&lD, Rev.33013-1991, Fire Protection System P&lD, Rev. 1933013-1992, Fire Protection System P&lD, Rev. 1133013-1993, Fire Protection System P&lD, Rev. 10Larqe Fires and Exolosions Mitiqation Strateoies DocumentsER-AFW.3, Alternate Standby Auxiliary Feedwater, Rev. 3ER-CNMT.1, Flooding Containment, Rev. 0ER-EDMG.0, Emergency Damage Mitigation Guidelines, Rev.ER-RWST.1, Alternate RWST Makeup, Rev. 1ER-SFP.2, Diverse SFP Makeup and Spray, Rev' 2sc-3.15.15, Emergency Fire Equipment Inventory and Inspection, Rev. 92Fire Protection Evaluations of Modifications and Desion ChanoesA-202, Evaluation of Compensatory Measures for Degraded Hemyc, Rev. 21ECP-12-000305, Appendix R Radio Communications Upgrade, Rev' 1Qualitv Assurance Audits and Self AssessmentsQA-201 2-0052 5.57.1, Fire Protection Program lnspection Readiness, dated 7131112SA-2009-000049, Fire Protection Program Focused Self Assessment, dated 7130109SA-2012-000153, Fire Protection Program Focused Self Assessment, dated 7119112Svstem Health Reports120VAC Instrument Power System, 1st Quarter 2012120VAC Instrument Power System, 2nd Quarter 2012125VDC Electrical System, 1st Quarter 2012125VDC Electrical System, 2nd Quarter 2Q124160VAC Electrical System, 1st Quarter 20124160VAC Electrical System, 2nd Quarter 201212241510Attachmenl

A-5480VAC Electrical System, 1st Quarter 2012480VAC Electrical System, 2nd Quarter 2012Diesel Generator Emergency Power System, 1st Quarter 2012Diesel Generator Emergency Power System, 2nd Quarter 2012Emergency Lighting System, 1st Quarter 2012Emergency Lighting System, 2nd Quarter 2012Fire Protection Program, 1st Quarter 2012Fire Protection Program, 4th Quarter 2011Fire Protection System, 1st Quarter 2012Fire Protection System, 4th Quarter 2011ProceduresA-102.12,Fire Watch Training, Rev. 16A-2Q2, Staff Responsibilities for the Fire Protection Program, Rev' 28A-905, Open Flame, Welding and Grinding Permit (Hot Work Permit), Rev. 42CH-190, Diesel Fuel OilTesting Program, Rev. 4CH-240, Sampling, Handling, & Evaluation of Fuel Oil Storage tanks, Rev. 0EP-3-P-0132, Fire Protection and Appendix R Conformance Verifications, Rev. 6 & 7ER-Fire.S, Alternate Shutdown for Battery Room B Fire, Rev. 2FPS-1, Fire Barrier Control Procedure, Rev. 11FPS-16, Butk Storage of Combustible Materials and Transient Fire Loads, Rev. 15FPS-2, Fire Barrier Penetration Seal Program, Rev. 7FPS-3, Periodic Inspection of Fire Barrier Penetration Seals, Rev' 1FPS-7, Velocity Flush of the Fire Water System, Rev. 15GME-00-99-ACFUSES, Replacement or Inspection of Ac Fuses, Rev. 01GME-00-99-DCFUSES, Replacement or Inspection of DC Fuses, Rev. 02GME-S0-02-D825, Westinghouse 480V Air Circuit Breaker, Type DB-25, Maintenance, Rev. 21GME-SO-02-D850, Westinghouse 480V AIR Circuit Breaker, Type DB-50, Maintenance, Rev. 23GME-S0-02-D875, Westinghouse 480V Air Circuit Breaker, Type DB-75, Maintenance, Rev. 25GME-50-02-DBSETUP, Westinghouse DB Breaker Setup, Rev. 9M-11.30.1, Motor Driven or Diesel Driven Fire Pump Minor Maintenance, Rev. 24M-11.30.2, Diesel Fire Pump Right Angle Drive Minor Maintenance, Rev' 19M-32.6, Molded Case Circuit Breaker Bench Test Trip Test, Rev' 12PRI-07-02-BUS11A, Protective Relay Calibration. 4kV Bus 11A Relaying, Rev. 7PRI-07-02-BUS1 18, Protective Relay Calibration, 4kV Bus 1 1B Relaying, Rev. 8PRI-07-02-BUS124, Protective Relay Calibration, 4kV Bus 12A Relaying, Rev. 3PRI-07-02-BUS128, Protective Relay Calibration, 4kV Bus 128 Relaying, Rev. 4SC-3.4.1, Fire Brigade Captain and Control Room Personnel Responsibilities, Rev. 3STP-O-12.8.1, DC Diesel Generator Load Test, Rev. 1STP-O-12.9,DC Diesel GeneratorTest, Rev. 1STP-O-13, Fire Pump Operation and System Alignment, Rev' 1STP-O-13.1 , Annual Fire Pump Insurance Surveillance Test, Rev. 3STP-O-13.2, Diesel Fire Pump Standard Protection Test, Rev' 0STP-O-13.4, Diesel Driven Portable Pump Test, Rev' 2STP-O-1 3.4.1, BSb Pump Annual Flow Test, Rev. 1STP-O-13.4.14, Deluge Valve System Test, Auxiliary Charcoal Filter, Rev. 0Attachment

A-6Operations ProceduresATT-12.0, Attachment N2 PORVS, Rev. 6ER-D/G.2, Alternate Cooling for D/GS, Rev. 19ER-Fire.0, Control Room Response to Fire Alarms and Reports, Rev. 9ER-Fire.3, Alternate Shutdown for Aux Building BasemenUMezzanine Fire, Rev. 32ER-Fire.S, Alternate Shutdown for Battery Room B Fire, Rev. 24O-20, Operations DC Fuse Replacement, Rev. 00-6.1, Auxiliary Operator Rounds and Log Sheets, Rev. 46PCR 2003-0028, Required Appendix R Spare Air Supply Volume, Rev. 0PCR 2004-0009, Ginna Extended Power Uprate Project, Rev. 0PCR 2005-0028, EPU NSSS Setpoint, Scaling and Instrumentation Changes, Rev. 0PCR 2005-0041, Consolidate Local Controls for Charging Pump A for EPU, Rev. 0PCR 2011-5468 to ER-D/G.1, Restoring Diesel Generators, Rev' 16PCR 2012-4881 to ER-FIRE.3, Alternate Shutdown for Auxiliary Bldg Basement Fire, Rev. 31SC-3.16.2.1, Fire Control Panel Operating Instruction, Rev' 5Operator Safe Shutdown TraininqContinuing Training Attendance Sheets for Lesson Plan RER22C, dated 4116110 to 5121110JPM J004.009, Take Local Manual Control of Charging Pump, Rev. 3JPM JR064.004, Start "A" EDG Locally per ER-Fire.1, Rev. 0Licensed Operator Initial Training Attendance Sheets for JPM JR 064.004, dated1120112 and 213112RER22C, Appendix R - Alternative Shutdown, Rev. 9Fire Fiqhtinq Strateqies (i.e., Pre-Fire Plans)FRP-4.0, Fire Response Plan for Auxiliary Building Basement, Rev. 8FRP-5.0, Fire Response Plan for Auxiliary Building Intermediate Floor, Rev. 9FRP-6.0, Fire Response Plan for Auxiliary Bldg Operating Floor, Rev' 7FRP-15.0, Fire Response Plan for Cable Tunnel, Rev' 7FRP-18.0, Fire Response Plan for Battery Room B, Rev. 6FRP-24.0, Fire Response Plan for EDG Room A and Cable Vault, Rev' 5Fire Briqade TraininqA-103.9, Fire Brigade Training, Rev. 3LP FFB31C, Fire Brigade Responsibilities, Rev. 9LP FFB36C, Fire Brigade Response, Rev. 3Fire Briqade Drills and CritiquesFire Drill Scenario 2007-002, performed 1113111Fire Drill Scenario 2008-008, performed 1119111Fire Drill Scenario 2011-003, performed 1121111Fire Drill Scenario 2011-002, performed 2110111Fire Drill Scenario 2011-006, performed 411111, 4112111,6116111, and 6126111Attachment

A-7Fire Drill Scenario 2008-010, performed 7 18111Fire Drill Scenario 2011-001, performed 7129111Fire Drill Scenario 2006-009, performed 812111Fire Drill Scenario 2009-003, performed 814111Fire Drill Scenario 2008-015, performed 9126111Fire Drill Scenario 2009-013, performed 1015111Fire Drill Scenario 2011-010, performed 1016111Fire Drill Scenario 2011-020, performed 1116111Fire Drill Scenario 2009-002, performed 1116111Fire Drill Scenario 2012-019, performed 9111112Transient Combustible Permits and Evaluations2012-003, 2012-004, 2012-005, 2012-006, and 2012-008Hot Work and lonition Source PermitsHot Work Permits12-127, 12-130,12-131, 12-133,12-134, 12-153, and 12-157Completed Tests and SurveillancesFPS-2.1, Appendix R Fire Barrier Verification, performed 10129107FPS-?.2, Non-Appendix R Fire Barrier Verification, performed 10122110FPS-3, Fire Barrier Penetration Seals Inspection, performed 5113111FPS-7, Fire Water System Velocity Flush, performed 4120109 and 5127112M-103, Fire Damper Maintenance and lnspection, performed 1117112PM P103343, Radio Communication System, performed 4114107PM P203302, Radio Communication System, performed 7 118109PM P900027, Radio Communication System, performed 4l28l10PT-13.26, Fire Damper Testing, performed 12119105STp-O-13, Fire Pump Operation and System Alignment, performed 615112 and 718112STP-O-1 3.1 , Annual Fire Pump insurance Surveillance Test, performed 12129110 and 12128111STP-O-1 3.11.19, Smoke Detector Testing, Auxiliary Bldg Basement, performed 4124110STP-O-13.2, Diesel Fire Pump Standard Protection Test, performed 1213Q111STP-O-13.22.1, Fire System Flow Alarm Check, performed 4116111Condition Reports (* denotes NRC identified during this inspection)cR-2009-0003cR-2009-0422cR-2009-0590cR-2009-0819cR-2009-0880cR-2009-0881cR-2009-1260cR-2009-1476cR-2009-2052cR-2009-2099cR-2009-2190cR-2009-2305cR-2009-2331cR-2009-3226cR-2009-3397cR-2009-3877cR-2009-4110cR-2009-4445cR-2009-5459cR-2009-5507cR-2009-5582cR-2009-6284cR-2009-7409cR-2009-7765cR-2009-8124cR-2009-8217cR-2009-8340cR-2009-8510cR,2009-8560cR-2009-8605cR-2009-8727cR-2009-8933cR-2009-8966cR-2009-9034cR-2009-9052cR-2009-9342cR-2009-9343cR-2009-9537cR-2010-0039cR-2010-0040Attachment

A-8cR-2010-0294cR-2010-2344cR-2010-3081cR-2010-3465cR-2010-4262cR-2010-4290cR-2010-4302cR-2010-4475cR-2010-4592cR-2010-6084cR-2010-6336cR-2010-6337cR-2010-7219cR-2010-7356cR-2010-7395Work Orders20504259c20600793c20900877c20901227c90678575c90732763Vendor ManualscR-2010-7620cR-2011-2140cR-2011-3484cR-2011-4605cR-2011-4985cR-2011-5120cR-2011-5708cR-2011-5716cR-2011-6390cR-2011-6392cR-201205261cR-2012-0649cR-2012-0838cR-2012-2413cR-2012-3286c90818690c90989518c90995122c91212076c91212107c91245345cR-2012-3299cR-2012-3511cR-2012-3607cR-2012-4281cR-2012-4324cR-2012-5024cR-2012-5035cR-2012-5254cR-2012-5255cR-2012-5256cR-2012-5258cR-2012-5259cR-2012-5993.cR-2012-6004"cR-2012-6144.c91246083c91268328c91268496c91 5381 71c91 539682c91640027cR-2012-6159.cR-2012-6161*cR-2012-6173"cR-2012-6184.cR-2012-6192*cR-2012-6196*cR-2012-6222*cR-2012-6223.cR-2012-6346.cR-2012-6390cR-2012-6410-cR-2012-6440"cR-2012-6501.cR-2012-6530*c91714786c91752548Rl 31 3946R1313950R1341339R1341340WD-C1436-4702, Emergency Lighting Units, Rev. 0Industrv StandardsNFPA 13-1985, lnstallation of Sprinkler SystemsNFPA 15-1985, Water Spray Fixed SystemsNFPA 20-1983, Centrifugal Fire PumpsMiscellaneous DocumentsA-52.12 Attachment 3, Control of LCO for Fire Suppression, Detection and Fire Barriers(lmpairment Log), dated 9110112A-54.7, Hemyc Wrap (Operator Rounds)Certificate of Analysis, Diesel Fuel Oil Sample, dated 2123112Fire Tank Booster Pump Trend Point Plot, from 8/15112to 8129112Letter, LS05-81-09-018, NRC to RG&E, Systematic Evaluation Program Topic lll-5.8, PipeBreak Outside Containment (M18109140113), dated 914181Margin lssue 2950, Fire Pumps Do Not Meet NFPA 20 Requirements, dated 9111112NRC Enforcement Policy (ML12132A394), dated 617112NRC Information Notice (lN) 2009-02, Biodiesel Fuel Oil Adverse lmpact to Diesel EnginePerformance, dated 2l23l}gAttachment

A-9NRC lN 2009-29, Potential Failure of Fire Water Supply Pumps to Automatically Start due toa Fire, dated 11124109NRC Regulatory Guide 1 .189, Fire Protection for Nuclear Power Plants, Rev. 2Purchase Order No. 6614401, Diesel Fuel OilTesting, dated 211112LIST OF ACRONYMSABBM Auxiliary Building Basement and MezzanineADAMS Agencyruide Documents Access and Management SystemAFW Auxiliary FeedwaterAPCSB INRCI Auxiliary and Power Conversion Systems BranchBTP [NRC] Branch Technical PositionCCW Component Cooling WaterCDF Core Damage FrequencYCFR Code of Federal RegulationsConstellation Constellation Energy Nuclear GroupCR Condition ReportEDG Emergency Diesel GeneratorElev. ElevationELU Emergency Light UnitEPU Extended Power UPrateFHA Fire Hazards AnalYsisFPP Fire Protection ProgramFPPR Fire Protection Program Reportft FootGinna R.E. Ginna Nuclear Power PlantH2 HydrogenIMC [NRC] Inspection Manual ChapterlN [NRC] lnformation NoticelP [NRC] lnspection ProcedureIPEEE Individual Plant Examination of External EventslR [NRC] Inspection RePortNz NitrogenNEI Nuclear Energy InstituteNFPA National Fire Protection AssociationNRC Nuclear Regulatory CommissionNRR [NRC] Nuclear Reactor RegulationOMA Operator ManualActionPARS Publicly Available Records SystemPCR Procedure Change requestP&lD Piping and lnstrumentation DrawingPRA Probabilistic Risk AssessmentRCP Reactor Coolant PumPRCS Reactor Coolant SYstemRG [NRC] Regulatory GuideRG&E Rochester Gas and Electric [previous licensee]RWST RefuelWater Storage TankAttachment

SDPSERSFPSRASSCUFSARVACVCTVDCA-10INRC] Significance Determination Process[NRC] Safety Evaluation ReportSpent Fuel PoolSenior Reactor AnalystStructures, Systems and ComponentsUpdated Final Safety Analysis ReportVolts Alternating CurrentVolume ControlTankVolts Direct CurrentAttachment