IR 05000244/1988001
| ML17251A991 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/21/1988 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A990 | List: |
| References | |
| 50-244-88-01, 50-244-88-1, GL-81-21, IEB-87-002, IEB-87-2, NUDOCS 8803290226 | |
| Download: ML17251A991 (22) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-244/88-01 Docket No.
SO-244 Licensee No.
DPR-18 Priority Category C
Licensee:
Rochester Gas and Electric Co'rporation 49 East Avenue Rochester, New York Facility:
R.
E. Ginna'uclear Power Plant Location:
Ontario, New York Dates:
Inspectors:
January 24 - March 6, 1988 C.
S.
Mar schall, Senior Resident Inspector, Ginna N.
S. Perry, Resident Inspector, Ginna Approved by:
C. J.
Cowgill ief actor Projects Section 1A Date Ins ection Summar
Areas Ins ected:
Routine inspection by the resident inspectors of station activi-ties including followup of open items, plant shutdown for refueling, refue'ling activities, safety system walkdowns, operational safety verification, surveillance, maintenance, physical security, radiation protection, onsite followup of events, LERs, facility modification, Fitness for Duty, Natural Circulation Cooldown, Fas-tener Testing, Reactor Vessel Overpressure Protection, and periodic reports.
This inspection involved 338.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> by the inspectors which included 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of back-shift inspection coverage and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of weekend and holiday inspection coverage.
Results:
A violation was identified for which no Notice of Violation will be issued on procedural non-compliance in section 10 (Review of Radiation Controls).
Section 8 discusses a possible indication of weakness in conducting post-maintenance tests of safety-related equipment, and the lack of a station policy for timeliness of post-maintenance testing.
A need for additional attention to housekeeping is dis-cussed in section 6 (Operational Safety Verification).
SINS items MPA B-66 (Natu-ral Circulation Cooldown)
and A-26 (Reactor Vessel Overpressure Protection)
were reviewed for closeout in sections 16 and 17, respectively, and an unresolved item concerning a licensee commitment was identified in section 17.
8803290226 SS0322 PDR ADOCK 05000244
DETAILS 1.
Persons Contacted During this inspection period, the inspector s held discussions with and in-terviewed operators, technicians, engineers and supervisory level personnel.
The following people were among those contacted:
wJ
- D R.
W.
- R. A.
- T. A.
- T. A.
- J. T.
- T. R.
"B. A.
- S.
M.
"J. A.
R.
E.
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 St. Martin, Station Engineer Schuler, Operations Manager Snow, Superintendent Nuclear Production Spector, Superintendent Ginna Production Widay, Technical Manager Wood, Supervisor Nuclear Security 2.
- Denotes persons present at Exit Meeting on March 7, 1988.
Followu on Previousl Identified Items (Closed)
Inspector Followup Item (87-2S-01):
Failure to follow procedures.
Alignment marks have been permanently affixed to the valve/block assemblies of valves 897 and 898 to indicate proper block positioning; these were the only two valves identified as being blocked in the described manner.
Addi-tionally, administrative procedure A-1402 was revised to provide more detailed information for further installations.
The inspectors reviewed the above corrective action, found it adequate to control the activity and had no fur-ther questions.
3.
Review of Plant 0 erations At the start of the inspection period, the plant was at 83K power and coasting down for the annual refueling and modification outage.
On February 5, 1988, operators shut the plant down from 72K power for the outage.
While subcriti-cal and driving the shutdown rods into the core, a reactor trip occurred due to high counts when the source range detectors energized.
Refer to paragraph 11 for more details on this event.
Licensee outage activities included the following:
74 Steam generator tubes were plugged; no sleeving was done.
= Repairs were made to 'B'ain Steam Isolation valve.
Three tubes were plugged in the 'B'losed Cooling Water (CCW) heat exchanger.
'A'eactor Coolant Pump (RCP) seal inspection.
Boric Acid system piping upgrad Low Pressure turbine No.
2 was replaced.
Piping modifications were performed on the Emergency Diesel Generator Fuel Oil Transfer system.
An unusual event was declared for one hour on February 10, 1988, when a
potentially contaminated worker, who fell in containment, was transported to a hospital.
From February 22 to February
a team inspection, from NRC Region I, was conducted.
At the end of the inspection period, the licensee was in cold shutdown, and making preparations for startup
~
Refuelin Activities During the refueling, inspectors verified that testing and operability veri-fication of refueling-related equipment and fuel handling operations were performed as required by Technical Specifications (TS) and licensee admini-strative procedures, plant conditions and staffing were maintained as required by TS, and good housekeeping and loose object control were maintained in the refueling and spent fuel areas.
i
'.
Although the licensee uses a contractor to perform the refueling operations, the inspectors noted that the refueling Senior Reactor Operators (SROs) were very knowledgeable about all aspects of the refueling operation and meticulous about housekeeping in the refueling area.
The licensee's program and procedures were effective in controlling and con-ducting refueling activities.
En ineered Safet Featur e ESF S stem Walkdown A complete walkdown of the accessible portions of the Residual Heat Removal (RHR) system was performed to verify its operability.
The inspector verified the licensee's lineup matched plant drawings and the as-built configuration.
Although inspectors observed several valves that had no labelling or were labelled with uncontrolled operator aids, no equipment conditions or items that might degrade plant performance were identified.
6.
0 erational Safet Verification On a daily basis, inspectors observed shift turnover and conduct of operation in the control room.
Operators were consistently alert, professional in per-forming-their duties and were cooperative and knowledgeable when questioned by the inspectors.
Housekeeping varied considerably during the course of the outage.
During outage preparations housekeeping began to decline.
After a memo was issued by the Station Superintendent, housekeeping improved in general.
However, instances of temporary cables suspended from safety-related piping and fire detection equipment, unsecured gas bottles, litter on horizontal surfaces, unsecured cabinets, unattended tools, and workers climbing on safety-related equipment were common-place.
As the outage drew to a close, a considerable
effort was made to remove dirt, debris and unnecessary equipment from,con-tainment in conformance with the goals stated by the Station Superintendent.
Although containment closeout had not yet been accomplished at the end of the inspection period, significant improvement in housekeeping was noted by the inspectors.
Despite the attention housekeeping received at the conclusion of the outage, more attention to improved housekeeping throughout the outage is warranted for fire protection and personnel safety considerations, and good engineering practice.
7.
Monthl Surveillance Observation The inspectors observed portions of the surveillance test procedures listed below to verify that test instrumentation was properly calibrated, approved procedures were used, work was performed by qualified personnel, Limiting Conditions for Operations were met, and the system was correctly restored following the testing.
The following surveillance activities were observed:
PT-2.2, Residual Heat Removal system, revision 39, effective date June 1,
1987, observed February 2,
1988.
Section 8 contains a detailed dis-cussion of this observation.
PT-1, Rod Control System, revision 23, dated November 11, 1987, observed on February 4,
1988.
Licensee controls and procedures were adequate to insure that surveillance activities were conducted in accordance with license requirements.
8.
Monthl Maintenance Observations The inspector observed portions of various safety-related maintenance activi-ties to determine that redundant components were operable, that these activi-ties did not violate the Limiting Conditions for Operation, required admini-strative approvals and tagouts were obtained prior to initiating the work,,
approved procedures were used or the activity was within the "skills of the trade", appropriate radiological controls were implemented, ignition/fire prevention controls were properly implemented, and equipment was properly tested prior to returning it to service.
MWR 88-1546: Installation and removal of jumpers in controls of
'B'mergency Diesel Generator (EDG), controlled by Non-Conformance Report (NCR) G88-168, observed March 4, 1988.
The electrician performing the work was knowledgeable of the work being performed.
He was a first class electrician and had considerable experience as an RG&E electrician.
When maintenance supervisory personnel were asked to produce documentation, of the electrician's training and qualification, it was stated that the documentation existed at the RG&E Schlegel. Road office, and would take some time to produce.
An additional example of training records which were not immediately available is discussed below (see M-11. 15, this
paragraph).
Technical Specifications (TS) 6.3 and 6.4 require that station personnel be qualified and trained in accordance with ANSI N18 ~ 1-1971.
Because the licensee was not able to confirm that workers were qualified to perform safety-related maintenance before the work was started, the two instances described indicate a potential weakness which requi res increased licensee attention.
Inspectors will review licensee documentation of qualification and training of maintenance personnel in a future inspection.
MWR 88-1514:
M-37.20, Inspection and Maintenance of Main Steam Isolation Valves 3516 or 3517, revision 16, dated March 1, 1987, observed March 1 and 2, 1988.
No violations were identified during observation of this activity.
MWRs86-558, 87-1111, 88-1068, 88-1222:
M-37.24A, Main Steam Safety Valve Inspection and Maintenance, revision 11, dated August 1, 1986, observed March 1 through 3, 1988.
After two main steam safety valves were torqued, the licensee found that an incorrect (too high) torque value was used.
The licensee contacted the vendor'nd it was determined that the studs'ield stress was not challenged; the studs were relaxed and retorqued to the correct value.
An incorrect torque value was applied because an inappropriate reference chart was used.
The licensee replaced the chart with the correct, one and torqued the remaining safety valves.
The licensee also stated that future corrective actions would be tracked via the Corrective Action Request (CAR) process.
The inspectors will follow the licensee's corrective actions.
M-ll.15:
Pumps Inspection/Maintenance, Re-vision 10, dated June 20, 1986, observed February 2, 1988.
Maintenance on the 'B'HR pump consisted of a an alignment check of the motor to-pump coupling, a lube oil change, and the post-maintenance test, PT-2.2, performed by the Results and Test department and witnessed by the me-chanics who performed the maintenance.
After all test data was obtained, Results and Test personnel stopped the pump.
Neither the mechanics nor the Results and Test personnel acknowledged that the pump oil level had not yet stabilized.
When the inspector brought this to the attention of the licensee, the pump test was rerun to verify a stabilized oil level.
Additionally, the 'A'HR pump was rerun to verify a stabilized oil level, as its oil was changed on the previous day.
The licensee was unable to supply documentation of qualification and training of maintenance per-sonnel performing the'RHR maintenance.
As discussed above, this appears to be a weakness in the licensee's program to comply with the Technical Specification commitment to ANSI N18. 1-1971.
The inspectors noted that the RHR post-maintenance test was performed promptly following completion of maintenance.
It was previously noted (see Inspection Report 50-244/87-29) that post-maintenance testing on safety-related equipment is not always promptly performed.
The Station
Superintendent stated that no policy exists on performing post-mainten-ance testing promptly; however, he woul'd re-evaluate the need to have a policy.
The failure of maintenance or test personnel to recognize that oil level was still decreasing prior to securing the RHR pump during post-mainten-ance testing could indicate a weakness in the licensee's ability to pro-perlyy return safety-related equipment to service following maintenance.
Failure to perform post-maintenance testing in a timely manner is con-sidered poor engineering practice.
9.
Ph sical Securit Review The inspectors made observations to verify that selected aspects of the sta-tion physical security program were in accordance with regulatory requirements, including the physical security plan and approved procedures.
In particular, inspectors observed personnel access control to ensure con-formance with the physical security plan and regulatory requirements.
Per-sonnel searches were monitored to confirm that equipment and controls were adequate and effective.
In addition, licensee control of entry and exit for vital areas and controlled access areas was observed for conformance with physical security plan and regulatory requirements.
Licensee procedures and controls are considered adequate to meet regulatory requirements.
10.
Review of Radiation Controls The inspectors reviewed selected aspects of the licensee's radiological pro-tection program to verify that the stations policies and procedures were in compliance with regulatory requirements.
Several inconsistent practices were observed by the inspectors.
One example was taping of protective clothing (PCs).
Radiation protection management stated that PCs were required to be taped for all workers inside containment and elsewhere in high radiation or contaminated areas.
Some workers were observed in these areas without taped PCs while other workers, whose activi-ties were controlled by.the same Radiation Work Permits (RWP) or Special Work Permits (SWP),
had taped their PCs.
Not all RWPs or SWPs for work inside containment required taping.
Health physics technicians presented conflicting information on the requirements for taping.
In addition, postings of con-taminated and high radiation areas were confusing.
Some high radiation post-ings had masking or duct tape over the word "high" with no apparent control of the use of tape.
Instructions were written on the postings in grease pencil or on adjacent pieces of masking tape.
These details were identified to the licensee and will be monitored for corrective action in future inspec-tion reports.
Failure to comply with procedural requirements to tape protec-tive clothing-as stated on RWPs and SWPs is considered an additional example of the violation contained in inspection report 50-244/88-02, and no violation will be issued.
NO YIOLATION (50-244/88-01-01).
The failure to comply with procedures and lack of control over postings appear to indicate a lack of attention to radiological controls.
Onsite Followu of Plant Events On February 5,
1988 at 6:57 P.M.,
a reactor trip occurred due to high counts on both source range detectors.
The plant was being shutdown at the time of the trip; the reactor was subcritical and operators were inserting the shut-down bank.
The trip occurred when the source range detectors re-energized, ll at 5x10 amps on the intermediate range detectors.
When the source range detectors re-energized, they were failed high, causing a reactor trip.
The licensee replaced both detectors and later found the cause of the failure to be poor and dirty lead connections.
The new connections have been covered to prevent corrosion or dirt from entering.
No violations were identified.
Licensee Event Re orts LERs The LERs submitted to the NRC were reviewed to determine whether the details were clearly reported, the causes properly identified and the corrective actions appropriate.
The inspectors also determined whether the assessment of potential safety consequences had been properly evaluated, whether generic implications were'ndicated, whether the event warranted on site follow-up, whether the reporting requirements of 10 CFR 50'2 were applicable, and whether the requirements of 10 CFR 50.73 had been properly met.,
(Note: the dates indicated are the event dates)
The following LERs were reviewed and found to be satisfactory:
87-008, 12/23/87, Inoperable safeguards circuit breakers due to zero clearance between Amptector actuator and breaker trip bar causes possi-
'ilityof common mode failure.
No unacceptable conditions were identified.
Review of Faci lit Modification The Boric Acid system piping upgrade modification was reviewed to verify that components were installed in accordance with the approved design.
This was accomplished by observing work in progress, reviewing portions of the licen-see's Quality Assurance (QA) program, reviewing inspection records and related documents, a'nd determining whether work performed by contractors was properly controlled by the licensee.
Licensee programs were determined to be adequate to control modification of
,the Boric Acid system pipin l,
14.
Fitness for Dut The inspector examined records and data relating to the experience associated with the licensee's fitness for duty program.
Information was provided to the Region as requested in RI TI 88-01.
No violations were identified.
15.
Fastener Testin The licensee program for receipt inspection of safety and non-safety fasteners was reviewed to determine what characteristics were inspected.
Procedures for issue and control of fasteners were also reviewed.
Results of these re-views were compared with the licensee's response to NRC Bulletin 87-02.
The licensee's response accurately reflects fasteners receipt inspection, control and issue as documented i'n the procedures listed below:
Bell Power Generation Service Group (BPGSG)
RIP-G-007, Revision 1, ef-fective date June 17, 1985, (Receipt Inspection Plan) for ASTM/ASHE Bolts and Fasteners.
BPGSC RIP-G-008, Revision 2, effective date September 4,
1986, Receipt Inspection Plan for ASTM/ASME Nuts and Washers.
Rochester Gas and Electric (RG&E) A-701, Revision 10, effective date June 10, 1986, Receipt and Acceptance of Materials/Parts.
RG&E A-801, Revision 9, effective date October 22, 1987, Control of Ac-cepted Material, Parts and Components at Ginna Station.
RG&E gCIP-77, Revision 1, effective date May 17, 1985, Inspection and Acceptance of Fasteners.
As discussed in Inspection Report 50-244/87-29, the inspector participated in the selection of samples as required in IE Bulletin 87-02.
The licensee's program and controls for fasteners are accurately reflected in the Rochester Gas
& Electric response to IE Bulletin 87-02.
16.
Natural Circulation Cooldown SIMS Item MPA B-66 As required by Inspection and Enforcement Manual (IEM) Temporary Instruction (TI) 2515/86, inspectors reviewed implementation of the licensee's training program and the provisions of procedures that deal with control of natural
~
circulation cooldown, to insure conformance with their commitments in response to Generic Letter (GL) 81-21.
Interviews of three licensed operators indi-cated thorough familiarity with the events at St.
Lucie Unit 1, and the cause of the events.
Operators indicated that natural circulation cooldown situ-ations were frequently exercised in the simulator.
Lesson plans on heat
Cl
transfer, accident analysis and Emergency Operating Procedures (EOPs)
were reviewed to insure adequate training on reactor vessel upper head bubble pre-vention and mitigation.
Although the licensee's response to GL 81-21 indicates that licensed operators were trained on operating procedure 0-2.4, Natural Circulation Cooldown from Hot Shutdown to Cold Shutdown, on October 15, 16 and 17, 1981, documentation of the training could not be located.
The Training Manager affirmed comple-tion of the training in 1981.
Training on EOP FR-1.3, Revision 1,
~Res onse to Voids in Reactor Vessel Head, lesson plan RMC01C, Revision '1, Post Acci-IIT, i i I,
a detailed explanation of the requirements of natural circulation cooldown, the procedure necessary to achieve it, and symptoms of vessel head voiding.
The licensee plans to include lesson plan ROP02S, Revision 1, Natural Circu-lation Cooldown from Hot Shutdown to Cold Shutdown, which reviews procedure 0-2.4, Revision 34, in cycle one of licensed operator requalification training, beginning March 14, 1988
'he procedures and training reviewed are effective with respect to meeting the requirements of Generic Letter 81-21.
This TI is closed.
Reactor Vessel Over ressure Protection - SIMS Item A-26 The inspectors reviewed the licensee's design, administrative controls and procedures, training and equipment modifications, and surveillance areas associated with the reactor vessel overpressure protection system.
Most of the equipment comprising the reactor vessel Overpressure Protection System (OPS)
was installed during the 1978 refueling outage.
The inspectors noted that the Office of Nuclear Reactor Regulation, in a safety evaluation attached to an April 18, 1974 letter from the Division of Operating Reactors to Rochester Gas and Electric (RG&E) found the design of the OPS to be acceptable.
It was noted that RG5E 'participated as a member of the Westinghouse user's group formed to support the effort to prevent overpressure transients.
The inspectors reviewed the licensee's procedures and determined that steps
'xist to minimize the effects of a temperature difference between the steam generators and the reactor vessel while in the cold shutdown or hot shutdown mode.
Procedural steps exist to restrict the number of high-pressure safety injection 'and charging pumps operable during low-temperature overpressure conditions.
Additionally, operators are alerted on the operation of the OPS in the applicable procedures.
Although procedures in general limit the time the plant should operate in the water-solid condition, no specific steps for this purpose were identified.
In a letter from RGKE to the NRC dated October 15, 1976, the licensee stated,
"...procedures will be changed to minimize the time during which the plant is in the water-solid condition.. This will be done by requiring the pres-surizer to be vented and partially drained during extended periods at cold
C
shutdown."
The inspectors were unable to identify the specified procedure change,.and licensee personnel contacted were unfamiliar with such a change.
This item remains unresolved pending further review in a future inspection report.
UNRESOLVEO ITEM (50-244/88-01-02).
In general, the plant-installed system appeared to be in accordance with the plant license.
The following procedures were reviewed:
0-1. 1, Plant Heatup from Cold Shutdown to Hot Shutdown, revision 87, effective date August 13, 1987.
0-2.2, Plant Shutdown from Hot Shutdown to Cold Condition, revision 72, effective date November 18, 1987.
0-2.3, Plant at Cold Shutdown, revision 13, effective date February 15, 1986.
0-2.3.2, Filling and Venting the Reactor Coolant System, revision 27, effective date March 31, 1987.
0-7, Alignment and Operation of the Reactor Vessel Overpressure Protec-tion System, revision 14, effective date October 15, 1987
'he inspector reviewed licensed operator training records and verified that lesson plans and personnel records showed that operators received training concerning low temperature overpressure events, and on the operation and maintenance of the OPS.
Procedures require that the reactor vessel overpressure protection system bistables have been functionally tested within 31 days of placing the OPS in service.
Additionally, instrument and control technicians perform a monthly surveillance which verifies the operability of the OPS.
Three alarms on the main control board alert the operator to a potential impending overpressure event.
The inspectors also found that Ginna Station has no automatic isolation fea-ture on the Residual Heat Removal pump suction valves which could potentially isolate the relief valves, and the Reactor Protection System was found to have no blocking signals which could potentially prevent the pressurizer power operated relief valves from opening.
Overall, the inspectors found the licensee's technical specifications, proce-dures, and training to be comprehensive with no violations identified during the review.
This TI is considered close.
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 inspectors.
This review included the following considerations:
the reports contained in-formation required by the NRC; 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 inspectors:
Monthly Operating Report for January 1988.
The report was considered adequate to meet regulatory requirements.
~E" N
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 informa-tion subject to
CFR 2.790 restrictions.