IR 05000244/1987008

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Insp Rept 50-244/87-08 on 870315-0418.Violations Noted: Operability of Duplicate Valve MOV 860A Not Demonstrated Prior to Ajusting Packing on MOV 860B in Containment Spray Sys & Failure to Maintain Continuous Fire Watches
ML17261A496
Person / Time
Site: Ginna Constellation icon.png
Issue date: 05/21/1987
From: Linville J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17261A492 List:
References
50-244-87-08, 50-244-87-8, IEB-81-01, IEB-81-1, IEIN-84-67, NUDOCS 8706090128
Download: ML17261A496 (18)


Text

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U. S.

NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-244/87-08 Docket No. 50-244 Licensee No.

DPR-18 Priority Category C

Licensee:

Rochester Gas and Electric Corporation 49 East Avenue Rochester, New York Facility Name:

R.

E. Ginna Nuclear Power Plant Inspection at: Ontario, New York Inspection Conducted:

March 15, 1987 through April 18, 1987 Inspector:

Approved by:

T. J. Polich, Senior Resident Inspector, Ginna j~'~li7 J.

C. Lin i le Ch f, Reactor Date Projects ction No.

2A, DRP Ins ection Summar Ins ection on March,15 1987 throu h A ril 18 1987 Re ort No. 50-244/87-08)

Areas Ins ected:

Routine, on-site, regular, and backshift inspection by the resident inspector ( 134 hours0.00155 days <br />0.0372 hours <br />2.215608e-4 weeks <br />5.0987e-5 months <br />).

Areas inspected included:

licensee action on previous findings; review of plant operations; operational safety verification; surveillance testing; plant maintenance; Licensee Event Reports; and review of periodic and special reports.

Results:

In the seven areas inspected, two violations were observed.

Both violations involved failure to comply with Technical Specifications when performing maintenance activities.

Both Operations and Maintenance personnel were involved in these violations (paragraphs 3.b and 6.c).

8706090128 870526 PDR ADOCK 05000244 G

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DETAILS 1.

Persons Contacted During this inspection period, the inspectors held discussions with and interviewed operators, technicians, engineers and supervisory level personnel.

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Bodine, Nuclear Assurance Manager Fi lkins, Chemistry 5 Health Physics Manager Kober, Vice President, Electric and Steam Production Marchionda, Training Manager Marlow, Maintenance Manager Meyer, Superintendent Ginna Support Services Schuler, Operations Manager Shaw, Administrative Services Manager Snow, Superintendent Nuclear Production Spector, Superintendent Ginna Production Vanderweel, Ginna Modifications Project Manager Widay, Technical Manager Wilkins, Manager, Nuclear Engineering Wood, Supervisor Nuclear Security

  • Denotes persons present at Exit Meeting on April 23, 1987.

2.

Licensee Action on Previous Ins ection Findin s

a.

(Open) Inspector Follow-up Item ( 86-16-02)

Drawing Control of Piping and Instrumentation Drawings (PLIDs).

None of the discrepancies noted in inspection reports 86-16 and 86-18 have been corrected to date.

The inspector continues to find errors in the licensee's controlled copies of P&ID.

During this inspection period the inspector identified the following discrepancies:

Two valves are labeled 849F on drawing 33013-1261 The spent fuel pool heat exchanger is labeled as ACAHSF on drawing 33013-1248 and ACA118E on drawing 33013-1250 3.

Review of Plant 0 er ations

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Throughout the reporting period, the inspector reviewed routine power operations.

The reactor was brought to 100% power on March 15, 1987 and has remained at that power throughout the reporting period.

On March 16, 1987, a major portion of the Fire System Detection and Automatic Suppression was found inoperable by the licensee.

The areas affected were the auxiliary building, intermediate building, diesel building, turbine building, containment, and control room. It was determined that this condition had existed for approximately one hour

and twenty minutes.

Technical Specification 3. 14.3. 1 requires con-tinuous fire watches with backup fire suppression equipment to be established within one hour in those areas in which redundant systems or components necessary for safe shutdown could be damaged.

Failing to station such personnel within one hour is an apparent violation of Technical Specifications.

(87-08-01)

The event was caused by a non-licensed operator's failure to follow Procedure SC-3. 16.2.4, "Fire Signaling/Component(s)

Disconnection-Reconnection".

The procedure precautions identify the significance of depressing the "Alarm Off" button and requires a sign-off for depressing and releasing the "Alarm Off" button.

On August 31, 1984, the licensee found the "Alarm Off" button had been depressed for approximately 1S hours as documented in Licensee Event Report (LER)84-010..

This occurrence was documented in Inspec-tion Report 84-19 as a licensee identified violation.

Procedure SC-3. 16.2 '

was modified to include extra sign-offs as a result of that occurrence.

However, the most recent event was not precluded by the licensee's corrective action as the procedure only addressed the reconnection portion and not the disconnection portion of the procedure.

Therefore, a violation is being issued in this case.

4.

0 erational Safet Verification a.

General During the inspection period, the inspectors observed and examined activities to verify the operational safety of the licensee's facility.

The observations and examinations of those activities were conducted on a daily, weekly or monthly basis.

On a daily basis, the inspectors observed control room activities to verify compliance with selected Limiting Condition for Operations (LCOs) as prescribed in the facility Technical Specifications (TS).

Logs, instrumentation, recorder traces, plant conditions, and trends were reviewed for compliance with regulatory requirements.

Shift turnover s were observed on a sample basis to verify that all pertinent information of plant status was relayed.

During each week, the inspectors toured the accessible areas of the facility to observe the following:

General plant and equipment conditions Fire hazards and fire fighting equipment Radiation protection controls Conduct of selected activities for compliance with licensee's administrative controls and approved procedures Interiors of electrical and control panels Implementation of selected portions of the licensee's physical security plan

Plant housekeeping and cleanliness Essential safety feature equipment alignment and conditions The inspector talked with operators in the control room, and other personnel.

The discussions centered on pertinent topics of general plant conditions, procedures, security, training, and other aspects of the involved work activities.

Control Room The licensee continues to upgrade the control room and control board appearance.

During this inspection period new carpet was installed and human factors modifications to the control board (color coded system component labels)

continued.

Additionally, ambient noise level measurements were taken to determine new control board audible alarm se'ttings.

The licensee continues to restrict access to the control board area to Official Business only.

Licensee management removed the radio from the control room in October 1986 and restricted use of the radio to the shift supervisor's office and only as deemed necessary by the shift supervisor.

Auxiliar Buildin Subbasement During a tour of the auxiliary building subbasement on March 18, 1987, the inspector observed a ladder, and various tools and parts on the "A" Residual Heat Removal (RHR)

pump motor.

This condition is a potential missile hazard to the RHR pump.

This area has been identified in the past for poor housekeeping and potential flooding concerns.

Intermediate Bui 1 di n Subbasement Over three quarters of the containment tendon grease sleeve valves are in the trench that surrounds the containment vessel outer wall at the 235 foot elevation of the intermediate building.

The inspector has observed the valves fully or partially submerged in water and/or sludge during tours of this area over the past few months.

The source of the water is ground water that leaks into the area around rusted and corroded sheet piling at the sheet piling/

concrete interface.

The rust from the sheet pi ling and silt carried in by the ground water have combined to form a sludge which accumulates around the tendon grease sleeve valves.

Although a sump pump is installed to drain this area, the constant inflow of ground water and the sludge maintain a minimum level of 4 to 6 inches of sludge and water in thi s area.

This condition appears to have existed for many year The licensee has recently completed three years of data gathering on ground water level.

The data shows that ground water is approximately 10 feet below grade or at the 260 foot elevation and not at bed rock as had been previously assumed.

The inspector has discussed this concern with the licensee's Technical Manager and Superintendent Ginna Production as well as structural engineers from the licensees corporate office.

This item will be reviewed by regional based structural engineers in a future inspection.

5.

Surveillance Testin The inspector witnessed the performance of surveillance testing of selected components to verify that:

the test procedure was properly approved and adequately detailed to assure performance of a satisfactory surveillance test; test instrumentation required by the procedure was.calibrated and in use; the test was performed by qualified personnel; and the test'esults satisfied Technical Specifications and procedural acceptance criteria, or were properly resolved.

b.

During this inspection period, the inspectors witnessed the performance of selected portions of the following tests:

Periodic Test (PT)-2. 1, "Safety Injection System Pumps", effective December 3,

1986.

PT-2.8,

"Component Cooling Water Pump System", effective July 24, 1986; PT-3, "Containment Spray Pumps and NaOH Additive System", effective August 1, 1986..

PT-5.20,

"Process Instrumentation Reactor Protection Channel Trip Test (channel 2 White)", effective February 27, 1987.

PT-12.5,

"Technical Support, Center Emergency Diesel Test", effective November 26, 1984.

No violations were identified'.

Plant Maintenance a.

During the inspection period, the inspector observed maintenance and problem investigation activities to verify:

compliance with regulatory requirements, including those stated in the Technical Specifications; compliance with administrative and maintenance procedures; required QA/QC involvement; proper use of safety tags; qualifications; and reportability as required by Technical Specification The inspector witnessed selected portions of the following maintenance activities:

Maintenance Procedure (M)-40, "Surveillance and Maintenance of Hydraulic Snubbers",

effective February 3, 1986.

M-64. 1, "Periodic Surveillance Troubleshooting and Minor Maintenance of Limitorque Motor Operated Valves", effective February 10, 1987.

On April 10, 1987, whi le performing PT-3, Motor Operated Valve (MOV)

860B Containment Spray Pump "lA" discharge valve stroked open but failed to close.

The valve packing had been adjusted on April 9, 1987 using Ginna Station Maint'enance Work Request Trouble Report 87-2080.

This trouble report initiated on April 8, 1987, identified the valve as

"V-860 Cont Spray Pump A".

The Shift Supervisor reviewed the trouble report and assigned a

routine priority as is specified in Administrative Procedure A-1603,

"Maintenance Work Request And Trouble Report" for packing leaks.

When the trouble report was reviewed by the responsible maintenance person the reviewer marked the trouble report "non-gA".

The valve was later determined to be a gA item and addressed in Technical Specifications'he pipefitter who performed the work did not question the reviewer's decision and adjusted the packing.

No post-maintenance testing was performed after the valve packing was adjusted.

Subsequently, MOV 860B was declared inoperable by the licensee since the valve failed to stroke closed during PT-3.

The licensee had stroked valve 860A prior to initiating repairs to MOV 860B.

Several opportunities existed for licensee personnel to identify this valve was a

MOV covered by Technical Specifications.

Technical Specification 3.3 '.2 requires that prior to initiating repairs to a valve all valves in the system that provide the duplicate function shall be tested to demonstrate operability.

Failure to demonstrate operability of valve MOV 860A prior to packing adjustment is an apparent violation of Technical Specifications.

(87-08-02)

In addition, the licensee failed to perform post maintenance testing after adjusting the packing on April 9, 1987.

The inspector observed portions of Maintenance Procedure M-40 performed inside containment.

This procedure is performed to comply with Technical Specification 4. 14.

The inspector questioned the lack of surveillance on mechanical snubbers that support the same safety related systems as the hydraulic snubber The basis for Technical Specifications 3.13 and 4.14 is to ensure structural integrity of the reactor coolant system and all other safety. related systems is maintained during and following a seismic or other event initiating dynamic loads.

Other than pre-installation testomg, the licensee does not functionally test mechanical snubbers that are used on safety related systems.

In a licensee amendment request submitted in November 1981, the licensee stated that, no equipment was commercially available to functionally test mechanical snubbers and this requirement was omitted from the licensee's proposed testing program.

Further, the licensee stated, a mechanical snubber functional test program would be considered after suitable test equipment became available.

Subsequent submittals in 1983, 1984 and 1985 did not add functional testing requirements for mechanical snubbers.

IE Bulletin 81-01 addressed the surveillance of mechanical snubbers.

When the licensee responded to this bulletin'nly one mechanical snubber was installed.

IE Information Notice 84-67 discussed high failure rates of snubbers during inservice testing.

As reported in the Information Notice all of the mechanical snubber failures were found while conducting functional testing.

The licensee sent 12 mechanical snubbers off-site to Wyle Labs for testing in 1985.

All mechanical snubbers tested by Wyle passed functional testing.

One mechanical snubber was not tested because it was found locked up.

The licensee issued a nonconformance report and dispositioned the snubber as scrap.

The licensee stated verbally that the snubber was able to be stroked when it was returned from Wyle Labs, however, no documentation supports this statement.

The licensee has visually examined 23 mechanical snubbers as part of an annual inspection begun in 1985.

Additionally, on April 17, 1987 the licensee conducted walkdowns and visual inspections on 77 of 79 snubbers outside of containment.

The licensee has concluded that as a result of functional testing prior to installation, the one time testing by Wyle Lab in 1985 and recent visual examinations the mechanical snubbers continue to be operable.

Region I plans to request additional information from the licensee concerning functional testing of mechanical snubbers.

This information is required prior to further NRC action on the licensee's amendment request.

This item will remain unresolved until additional functional testing of mechanical snubbers is conducted and a periodic functional testing program has been implemented.

(87-08-03)

Licensee Event Re orts LERs The inspector reviewed the following LERs to verify that the details of the events were clearly reported, the descriptions of the causes were accurate, and adequate corrective action was taken.

The inspector also determined whether further information was required, and whether generic implications were involved.

The inspector further verified that the reporting requirements of Technical Specifications and station administrative and operating procedures had been met; that the events were reviewed by the Plant Operations Review Committee and that continued operation of the facility was conducted within the Technical Specification limits.

LER 87-001:

Potential Loss of Residual Heat Removal Capability Due to Loss of Normal Fuel Oil Makeup Capability to the EDGs Mhile Offsite Power was Secured for Maintenance.

On February 20, 1987, with all station electrical power being supplied by the "A" and "B" Emergency Diesel Generator s (EDGs)

low fuel oil levels occurred in both EDG day tanks.

The licensee determined three root causes relating to this event:

1) foreign material in the fuel oil system, 2) inadequate design of the fuel oil transfer pump suction strainers and 3) inadequate maintenance practices relating to fuel oil transfer pump suction strainers

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The licensee's corrective actions or proposed corrective actions address foreign material in the fuel oil system and maintenance practices on the fuel oil transfer pump suction strainer.

The inspector will continue to follow the licensee's proposed corrective actions in future reports.

LER 87-002:

Reactor Coolant System Oxygen Concentration Exceeds Technical Specification Limits Due to Personnel Error and Procedural Inadequacy.

On March 6, 1987, it was recognized by the licensee that Reactor Coolant System (RCS)

oxygen concentration limit of

. 1 ppm had been exceeded for 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />.

Technical Specification (TS) 3. 1.6.2 requires corrective action be taken immediately when normal steady state RCS oxygen limits are exceeded.

Further, TS 3. 1.6.4 requires the reactor to be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if RCS oxygen limits cannot be restored.

The licensee identified two root causes:

1) unanticipated oxygen concentration increase in the RCS, and 2) personnel fai lure to recognize RCS oxygen concentration was exceeded for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

.The licensee has revised Operating procedures 0-1. 1, "Plant Heatup From Cold Shutdown to Hot shutdown" and 0-10, "Crevice Cleaning" in response to this event.

The licensee has also made Health Physics and Chemistry Technicians aware of the errors and will include this LER in future trainin '

8.

Review of Periodic and S ecial Re orts Upon receipt, periodic and special reports submitted by the licensee pursuant to Technical Specifications 6.9. 1 and 6.9.3 were reviewed by the inspector.

This review included the following considerations:

the reports contained the information required to be reported by NRC requirements; test results and/or supporting information were consistent with design predictions and performance specifications; and the reported information was valid.

Within this scope, the following reports were reviewed by the inspector:

Monthly Operating Report for February and March 1987.

~Ei At periodic intervals during the inspection, meetings were held with senior facility management to discuss the inspection scope and findings.

Based on the NRC Region I review of this report and discussion held with licensee representatives, it was determined that this report does not contain information subject to

CFR 2.790 restrictions.