IR 05000244/1987021

Insp Rept 50-244/87-21 on 870831-0904.No Violations Noted. Major Areas Inspected:Review of Licensee Action on Previously NRC Identified Concerns,Followup of Generic Ltr 83-28,Item 4.1 & Qa/Qc Interfaces

ML20235U138
Person / Time
Site:	Ginna
Issue date:	09/29/1987
From:	Dev M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17261A629	List: IR 05000244/1987021
References
50-244-87-21, GL-83-28, NUDOCS 8710130377
Download: ML20235U138 (8)

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U.S. NUCLEAR REGULATORY COMMISSION REGION-I Report N /87-21 Docket N License No. DPR-18 Licensee: Rochester Gas and Electric Corporation 49 East Avenue Rochester, New York 14649 l

l Facility Name: R.' E. Ginna Nuclear Power Plant Inspection At: Ontario, New York Inspection Cond d: gust 34)- O ptember 4, 1987 ..

Inspector: / E & /L M. Dev, P.E., Reactor Engineer, DR N8 !8[

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Approved by: .

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N.Blumberg,[hfef, Operations .Section, date Operations Branch, DRS /

Inspection Summary: Routine unannounced inspection on August 31 - September 4, 1987 (Report No. 50-244/87-21).

Areas Inspected: Review of the licensee action on previously NRC identified concerns, followup of GL 83-28 Item 4.1 (Vendor Recommended Modification to Reactor Trip Breakers), and QA/QC interface Results: No violations were identifie l 8710130377 PDR 871002 9 ADOCK 05000244, G PDR

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A DETAILS -l 1.0 Persons Contacted Rochester Gas & Electric (RG&E) - Ginna Nuclear Power Plant

• J. Bodine, Nuclear Assurance Manager D. Filkins, Manager, Health Physic and Chemistr ;

J. Hotchkiss, Modification Manager i (- R. Marchionda, Training Manager

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T. Marlow, Maintenance Manager

• R. Mecredy, Director, Engineering Services G. Meier, Division Training Manager T. Meyer, Superintendent Ginna Support Services T. Schuller, Operation Manager i

• M. Shaw, Administration Service Manager )

• B. now, Superintendent, Nuclear Production

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• S. Specter, Superintendent, Ginna Production

• Stiewe, QA Engineer t

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• J, St. Martin, Station Engineer '

• J. Widay, Technical Manager

• Denotes those attended the exit meeting on September 4, 1987..

The inspector also contacted licensee's other' technical and administrative personnel during this inspectio l l

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2.0 Licensee's Actions on Previous NRC Concerns (Closed) Violation (50-244/87-10-01): This item pertains to the I licensee's failure to complete the biennial review of the station j procedures, and the discrepancies identified in the licensee's design  !

control and review progra ;

The licensee issued procedure change notices (PCNs) to incorporate the station review for the overdue station procedures. A procedure master j index has been established, and a schedule which provides for coordination and timely review of these procedures has been develope ;

The licensee conducted an engineering training session for engineering personnel which reemphasized the regulatory requirements for review and  !

approval of the station engineering design documentation. The engineer-ing staff who prepared and reviewed the Field Change Requests (FCRs'),

3258A-12, 3258-13 and 3258-16, in question, and their cognizant. manager were reminded of the licensee's Quality Assurance commitments. The licensee reviewed these FCRs and dispositioned the discrepancies promptl !

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The inspector' reviewed the documentation which supported the licensee's ,

actions and determined that they were adequate and complete. This item is close (Closed) Violation (50-244/87-10-03): This item pertains to the licensee's failure to protect 3/4" stainless steel Schedule 80 piping j from damage and deterioration while in storag {

l The licensee quality control personnel conducted an inspection and i verification of the affected pipe and scrapped all potentially degraded- )

material. A protective covering was provided.for the remaining pipe )

inventories. Also, a daily work day inspection'of the pertinent storage )

area is conducted to assure adequacy and effectiveness of the protective 1 measures for the stored material The inspector walked down the storage area and verified that the j licensee's protective measures were adequate. This item is close (Closed) Unresolved Item (50-244/86-02-06): This. item pertains to the licensee's program deficiencies related to updating vendor manuals and )

informatio l The licensee contracted the services of a consulting Company l to update the station vendors manuals and information. A computer based i

" SEEK" program has been established which provides for control, I availability and update status of vendor manuals and information. The I licensee has also established and implemented administrative procedure A-605, " Vendor Manual Control Program," which delineated scope and responsibility for control, distribution, use, maintenance and revision of vendors manual The inspector discussed the vendor manual program with the licensee's j cognizant individuals and verified through sampling that the program was effectively implemented (see Attachment - 1 for vendor manuals).

Based on the above review, the licensee's action is considered complet This item is close (Closed) Violation (50-244/83-23-01): This item pertains to the  !

licensee's failure to properly complete the station modification (SM)

procedures for the Post Accident Sampling System (PASS) Modificatio >

The licensee instituted a training session for the individuals conducting l quality control activities of plant modifications, including all liaison i l engineers, to emphasize the limit and authority of any individual to delete or cross out test steps, as delineated in the station administra-tive procedure The licensee's responsible engineer, notwithstanding, .

had modified the order of the test steps due to the sequence of construc-tion activities, and to accommodate the particular status of the system  ;

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modification. Currently, revisions to the procedures have taken place and )

administratively approved which clearly delineate the completion of those )

test steps duplicated elsewhere or altered by the revision,- or established as "Not Applicable".

The licensee also implemented a "Six Point Modification Improvement Program" to properly coordinate and enhance the station modification process including PASS. The licensee has subsequently reassessed this improvement program by monitoring the modification process used during the 1 1984 outage. The reassessment concluded that installation, testing and l startup of all modifications occurred without compromising plant safety; {

and the exchange of information between designers and construction, opera- -

tion and the maintenance personnel was effective. The reassessment also identified proposed changes to the Modification Improvement Program which were subsequently implemente {

i The inspector reviewed the implementation of the licensee's corrective j action and determined that the licensee's action was adequate. This item ?

is close (Closed) Violation (50-244/83-23-03): This item pertains to the )

licensee's failure to properly review the completion of installation and testing procedures, and associated nonconformance reports prior to system l i turnover to Operation l The licensee initiated Corrective Action Report (CAR) 1509 to review the station modification (SM) procedure format to determine its ability to ,

document deficiencies and follow up test steps. The licensee also formu- )

lated a "Six Point Modification Process Improvement Plan" to properly coordinate and enhance the station modification process including PAS Accordingly, associated administrative procedures were revised and updated to define roles and responsibilities of the Modification Follow Group (MFG),- Liaison Engineer, Construction Engineer and Responsible Enginee Procedures were also established to formalize the Startup Testing Program, !

and to control the turnover proces In letter dated January 27, 1984, the licensee stated that the test program for PASS was carried out under the direct supervision of the !

Respons!.ble Engineer and the test results were evaluated by the cognizant l plant personnel. PASS was. declared operable on July 15, 1984 to the ex- !

tent necessary to meet the regulatory requirements. Minor system changes and startup testing were continued only to optimize system performanc l With the implementation oF the Modification Process Improvement Plan, the I licensee assigned the responsib111ty for conducting modification testing to the Lead Test Supervisor under the cognizance of the Test Coordinato ,

These individuals verify that the test plan is followed, and the as-sociated procedures are implemented and adhered to in accordance with the licensee's administrative requirement '

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The licensee developed and conducted training to ensure that the'indivi-duals performing quality control activities related to plant modifications are properly trained and indoctrinated. The Plant Operations Review Committee members were also reinstructed on the nature of control and ]

responsibilities related to the review of the plant modification j The inspector reviewed the licensee's actions, including training of the I plant modifications staffs and determined that the licens0e's response was adequate and complete. This item is close .0 Generic Letter 83-28, Salem ATWs Followup - Item I I

The US NRC issued Temporary Instruction 2515/91 on April 6, 1987, which I intended to verify the satisfactory completion of action required in l Item 4.1 of GL 83-28 concerning vendor recommended modifications for reactor trip breaker ,

The licensee had reviewed the Westinghouse correspondence concerning the j Ginna 08-50 reactor trip breakers, and identified two recommended modifications. Accordingly, the first modification, " Replacement of Undervoltage Attachments on Breakers in Reactor Trip Switchgear" in 1 accordance with the Westinghouse document NCD-Elc.-18, dated December 17, l 1971, was completed in 1972. The second modification was accomplished by i removing the unused Overcurrent trip breakets in May, 198 In order to provide for the reactor trip system reliability and on-line l

functional testability, the licensee instituted Engineering Work Request (EWR)-3698, " Reactor Trip Diverse Trip Modification." This modification provided an additional automatic reactor trip feature through the shunt -

trip attachment (STA) concurrent with the undervoltage trip attachment l

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(UVTA), on a required scram signal. Accordingly, the reactor trip relays in the Reactor Protection System were internally connected and wired to the reactor trip coils. The modification also upgraded the shunt trip attachment and its associated control circuitry. In addition, test switches were added to the zirconium guide tube circuitry to facilitate the independent testing of UVTA and ST ,

The main control board was j modified to incorporate bypass breaker position indication. Finally, the bypass breakers were interlocked using a cell switch to preclude the closure of both breakers concurrently. The modification installation and l

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the associated operational testing were conducted in accordance with the approved station procedures. The work was completed in subsequent refueling outages during 1985, 1986 and 198 The inspector reviewed EWR-3698 and associated installation and test procedures, and as-built drawings (see Attachment - 1) and determined I that the licensee's action for GL 83-28, Item 4.1 was complet I i

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. QA/QC Interfaces The Ginna QC group under the cognizance of the Nuclear Assurance Manager conducts all station quality controlled activities including initiation of corrective action reports _(CARS), assigning and followup of ' action items, surveillance and monitoring of operational activities, surveillance and witnessing of safety-related construction and modification activities, and receiving inspection of safety-related procurement. The QC group has recently been reorganized and currently staffed with six QC technicians, one QC engineer, and a QC Supervisor reporting to the Nuclear Assurance Manager. Discussion with the cognizant QC individual indicated that the i staf fing is adequate based on-the existing work load. The management intends to increase staffing during refueling outages or any major modi-fication activities.

l The corporate QA organization conducts audits to verify adequacy and effectiveness of the licensee's compliance to the regulatory requiremen The inspector reviewed a draft QA audit report, for the licensee's !

corrective action program, conducted during July 28 - August 20, 198 The audit was thorough and had identified five concerns in the area in-cluding procedural compliance, training and certification of QC personnel and 10 CFR 21 related deportability. The station management was found t be very responsive to these concern .0 Management Meetings  !

l Licensee management was informed of the scope and purpose of the inspection at the entrance interview on August 31, 1987. The inspector J discussed with the licensee's representatives the licensee's protracted action to resolve NRC identified violation (50-244/83-23-03) related to Post Accident Sampling System. The inspector also stated concerns i regarding the prolonged action to implement vendor recommended reactor l trip breaker modification conducted through the refueling outages of 1985, 1986 and 1987. In both these cases, the licensee's action was determined to be slow. The findings of this inspection were discussed and presented to the licensee management during the exit meeting on September 4,1987, (see paragraph I for attendees).

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At no time during the inspection was written material provided to the licensee by the inspector. The licensee did not indicate that proprietary information was involved within the scope of this inspection.

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a Attachment - 1 1 Documents Reviewed 1.0 Procedures / Reports:

A-605, Vendor Manual Control Program, Rev. 1, September 18, 1986

SM-3698*1, Reactor Trip Breaker Upgrade, Rev. O, March 7, 1985 !

i SM-3698*2, Reactor Trip Breaker Preoperational.lesting, Rev. O, March 28, !

1985 j SM-3698 4, Reactor Trip Bypass Breaker Modification Testing, Rev. O, lj March 10, 1986 '

EET-11, Preoperational Test Specification, Reactor Trip Breaker Diverse Trip Modification, EWR-3698, Rev. 3, March 28,1985 l l

EE-29, Equipment Specification for the Installation, Inspection and l Testing Detail for Electrical Equipment Cable and Raceway, Rev. 6, l February 16, 1984

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J EC-57, Installation Specification. - Reactor Trip Breaker Upgrade, Rev. O, !

February 1, 1985 j NRC Safety Evaluation Report for GL 83-28, Salem ATWS Events for Ginna Nuclear Power Plant, Dated April 10, 1986 2.0 Vendor Manuals:

000000800 Modification Instruction for 30 inch steam stop valve - l Atwood & Morrill Company j l

8316 8316A Installation and Maintenance Instruction for 3 Way I Diaphram Solenoid Valve - Automatic Switch Company l

, 000001103 Mansfield & Green Pneumatic Dead Weight Tester Model RK Pressure Tester - Amertek Incorporated 3.0 Draft Audit Report Audit No. 87-39:08, Ginna Station Corrective Action Program Implementation Evaluation conducted during July 28 - August 20, 1987 4.0 Design Documentation Drawing 33013-673, Reactor Breaker Schematic, Rev. 5 sheets 1, 2 and 3

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Drawing CD-2A1, Reactor Coolant Saturation Margin Monitoring System Rack 1, Rev. 6 (Foxboro Company)

Drawing CD-11, Reactor Coolant Saturation Margin Monitoring System Rack 2, Rev. 6 (Foxboro Company)

Drawing RL-1A, Rack Loading Diagram, Rack 1 (Foxboro Company)

Drawing 10904-205, Zirconium Guide Tube Interlock Internal Wiring Detail, Rev. 5 Drawing 10904-343, Test Switch Detail, Rev 0 Drawing 10904-351, Indication Light Cutout Detail, Rev. O Drawing 10904-357, Indicating Light Wiring Diagram, Rev. O Drawing 10905-308, Reactor Trip Bypass Breaker, Elementary Wiring Diagram, Rev. 2 i

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