IR 05000244/1988015
| ML17251A333 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/12/1988 |
| From: | Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A332 | List: |
| References | |
| TASK-1.C.5, TASK-TM 50-244-88-15, GL-88-14, IEB-88-009, IEB-88-9, IEIN-88-046, IEIN-88-072, IEIN-88-46, IEIN-88-72, NUDOCS 8810210398 | |
| Download: ML17251A333 (88) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Docket/Report:
50-244/88-15 Licensee:
Faci 1 ity:
Rochester Gas and Electric Corporation R.
E. Ginna Nuclear Power Plant Inspection at: Ontario, New York Dates:
Team Leader:
September 8-22, 1988 James E.
Kaucher, Project Engineer, Technical Support Staff, Division of Reactor Projects Inspectors:
Geoffrey Grant, Senior Resident Inspector, Vermont Yankee Robert Gramm, Senior Resident Inspector, Limerick, Unit 2 James Beall, Senior Resident Inspector, Beaver Valley Richard Laura, Reactor Engineer, RPS 2C James Kottan, Laboratory Specialist, DRSS Joseph Furia, Radiation Specialist, DRSS Carl St le, Pro 'ec ger, NRR Approved By:
Eugen M. Kelly, Chic
,
echnical Support Section Division of Reacto Pr jects Date
~Summar:
The team's findings show relatively few changes'n performance from the previous SALP report although many long-standing concerns are just beginning to be addressed by management reorganizations, establishment of goals and objectives, and self-assessment initiatives.
An over-reliance on experienced personnel and inadequate attention to programmatic formality and administrative controls are evident.
Fun-damental misunderstanding or inattention to basic engineering/technical corner-stones of quality operation such as
CFR 50.59 safety evaluations, Q-List appli-cation and independent questioning or review of design calculations were identified as areas in need of attention.
More aggressive management attention in several areas such as follow through of QA/QC findings, workload management, and sensiti-vity to plant fire protection levels is warranted rather than reliance on long-standing overall station availability as a measure of quality effectiveness.
- Man-agement direction towards more proactive/less reactive attitudes, which shape the rigor of questioning and safety perspective broadly portrayed by RG&E, is needed.
Conclusions from each functional area inspected are summarized in Detail 1.2 Several apparent violations were identified during this inspection (Details 2.3, 3.2, and 4.6) are being addressed separately as part of future NRC resident in-spections.
8810210398 881013 PDR ADOCK 0 000244 PDC
1.0 Overview.
TABLE OF CONTENTS Integrated Performance Assessment Team Inspection at R.
E. Ginna Nuclear Power Plant (Report 50-244/88-15)
PAGE 1.1 1.2 Introduction.
Summary..
2
~ 0 Plant Operations (IP71707, IP71715, IP42700, IP40700).
2.1 2.2 2.3 2.4 2.5 2.6 Scope.
Shift Routine and Control Room Activities Control of Temporary Modifications.
Plant Conditions.....
Administration.
Conclusion (Assurance of Quality)
6
10
3.0 Maintenance (IP62700, IP62702, IP62704, IP62703, IP42700, IP 39701).
3.1 3.2 3.3 3.4 3.5 3 '
Maintenance Program.
Work Observation and Review.
QA/QC Interface.......
Work Schedule and Work Order Backlog........
Maintenance Initiatives.............
Conclusions
13
16
19 4.0 Engineering Support Activities (IP 37700, IP37701, IP37828, IP40703)
4.1 4.2 4.3 4.5 4.6 Scope and Objectives.................
Licensee Initiatives Tank Yolumes............,.
Flow Testing...
Safety-Related Electrical Cable....
Alternate Safe Shutdown.
Conclusions.....
20
22
23
5.0 Chemistry and Effluents (IP84750, IP42700)....-
5 '
5.2 5.3 5.4 5.5 5.6 Organization and Staffing.
Chemistry Operations Technician Training and Retraining...
Quality Assurance and Quality Control Facilities and Equipment Conclusions
26
28
29
I J
~
TABLE OF CONTENTS (CONT.)
PAGE 6.0 Corrective Action Process and Programs (IP35701, IP36700, IP40702, IP40704, IP35502, IP40500, IP42700, IP40703)
6.1 Scope 6.2 Corrective Action Reports (CARs).
6.3 Audit Reports 6.4 Nonconformance Reports....................
6.5 Quality Control Reports..
6.6 Quality Initiatives and Miscellaneous Issues 6.7 Inspector Follow-up Issues....................................
6 '
Conclusions'
.........................
29
31
33
35
7. 0 Flow of Technical Information ( IP42700)
. 7.1 Feedback of Operating Experience.
3?
7.2 Licensee Initiatives and Response to Incoming Correspondence....
7.3 Conclusions..
8.0 Management Meetings (30703)
ATTACHMENT Attachment 1 - Principals Contacted
jw
3
DETAILS 1.0 Overview 1.1 Introduction A Region I team inspection was performed at the R.
E. Ginna Nuclear Power Plant from September 8-22, 1988.
The plant remained at power throughout the inspection.
This team consisted of three region-based inspectors, three resident in-spectors based at other plants, one Project Manager from NRR, and a team leader and manager.
The team reviewed the following areas:
Plant Operations Chemistry Maintenance Engineering and Technica',
Support Corrective Action Programs and gA Dissemination of Technical Information Inspectors held discussions with plant management, plant operators, maintenance and test personnel, and staff engineers as well as other personnel as appropriate.
Team members spent, several days at the cor-porate engineering offices, located in Rochester, New York.
The inspec-tors also observed control room activities, surveillance testing, and maintenance activities.
Plant tour s were conducted to determine the condition of plant equipment, general plant operations, and overall housekeeping.
Each area was given an in-depth review and activity interrelationships were evaluated.
In each of the above areas, emphasis was placed on the following criteria:
Management and staff attitudes Adequacy of staffing and training Station goals Effectiveness in implementation of program and procedures Organizational interfaces Management involvement in work and day-to-day activities Work control guality oversight and self-assessment capability The objective of this inspection of Ginna was to assess the underlying reasons for past performance in key areas as documented in SALP reports.
Based on the team's observations of specific conditions, discussions with licensee representatives, and the perceptions formed thereof, the in-spectors formed conclusions which are described in the following summar i I
I
1.2 Summary The following conclusions and/or recommendations for each functional area assessed are provided, and were discussed in the exit meeting held on September 22, 1988.
1.2.1 Plant 0 erations Operating crews were found to be knowledgeable and their con-duct professional.
The licensee's operator degree program is a strength.
Temporary modifications, including mechanical by-passes and jumper/lifted leads, are performed using a log sheet which contains little or no guidance for performing the work.
This results in safety-related work being performed 'without PORC-approved procedures, and is outside the work that is sur-vei lied by gC (Detail 2.3).
Plant and corporate management, including shift supervisors, are not making an adequate number of plant tours (Detail 2.6).
There appears to be a significant weakness in the understanding and performance of 10 CFR 50.59 safety reviews (Detail 2.3).
The general condition of the auxiliary building was considered unsatisfactory (Detail 2.4).
1.2.2 Maintenance 1.2.3 Several new initiatives, including a major procedure rewrite program and the implementation of a planning group, appear to have merit but are too new to evaluate.
The lack of detail contained within the g-list has been identified as a problem area on numerous occasions and continues to be a root cause for incorrectly classifying components (Detail 3.2).
The maintenance backlog, although not large, is not used as an online management tool and the prioritization scheme used to classify maintenance is out-of-date, not followed, and needs to be updated (Detail 3.4).
Workers were found to be knowl-edgeable and experienced.
gC coverage of in-process work was found to be poor (Detail 3.3).
En ineerin Su ort The engineering staff was found.to be knowledgeable and com-petent.
However, it a'ppears that staff shortages have resulted in weaknesses in the design process (Detail 4.7).
Several significant issues were identified during the conduct of the inspection, namely:
sealing of conduit internals at fire bar-riers (Detail 4.5), availability of Technical Specification-requi red volumes in the condensate storage tanks (Detail 4.3),
and the lack of Appendix R-required fire wrap on conduit sup-ports (Detail 4.6).
.3 1.2.4 Chemistr and Effluents The areas of primary and secondary chemistry was evaluated by, the team to be a strength.
The staff was judged to be compe-tent and enthusiastic..
There appears to be good management support for chemistry in terms of both personnel and capital resources.
Initiatives such as the Steam Generator Reliability Committee are innovative.
The lack of QC surveillance of chemistry activities (Detail 5.5)
was identified as a weakness.
1.2.5 Corrective Action Process and Pro rams The system used to track and control Corrective Action Reports (CAR) is good; however, some CAR's were not resolved in a timely manner (Detail 6.2).
The audits reviewed were of good quality, and recent initiatives to strengthen the audit program by using outside experts to augment the audit team is seen as a strength.
There appears to be a weakness in responding to Audit Finding Corrective Action Reports, in that 5 of 7 re-quiring resolution in June 1988 have not been completed (Detail 6.3).
There is no auditable trail to determine what or when corrective actions are completed for QC findings generated from Quality Control Reports (Detail 6.5).
Resource constraints
, continue to be a concern and the completion of many new and vital initiatives could be affected by capital or personnel limitations (Detail 6.6).
1.2.6 Flow of Technical Information The operational assessment group appears to be well defined and to have adequate administrative control over outside cor-respondence.
Mithin RG&E, two organizations have overlapping responsibilities regarding feedback of technical information and the success of the program is dependent on informal com-munication (Detail 7. 1).
QA/QC does not appear to be involved in monitoring the flow of technical information process.
2.0 Plant 0 erations 2.1
~Sco e
The inspector observed routine operations on all three shifts, witnessed shift turnover activities and noted operator response to alarms, and the use of logs, drawings and procedures.
Several operators were interviewed, as well as line management up through the Operations Nanager.
The in-terfaces between control room personnel and the plant auxiliary operators, other station departmental personnel and the operations administrative
'taff were evaluated for the adequacy of control over routine and planned maintenance and testing activities.
Frequent reviews of component oper-abilityy and alarm status, as determined by walkdowns of the main control
I i
2.2 board, were conducted by the inspector and discussed with operators.
Several tours of plant spaces were performed, with emphasis on safety-related areas, to determine the condition and operability of safety-re-lated equipment.
The inspector also accompanied auxiliary operators on normal rounds.
The inspector attended morning plant status meetings and noted interdepartmental liaison and discussions of problem resolution options.
One plant operations review committee (PORC) meeting was ob-served.
The inspector observed control room activities during a con-trolled downpower operation necessary to repair a leaking heater drain pump.
Two Unusual Events (UEs) were declared by the licensee based on security related events during the inspection period and were reviewed by the inspector.
Programmatic controls over temporary modifications to systems and structures, and lifted leads and jumpers were evaluated.
Station event reports (A-25'), Licensee Event Reports (LERs)
and Cor-rective Action Reports (CARs) were reviewed for adequacy of licensee problem definition, response, corrective actions and subsequent analysis.
Shift, Routine and Control Room Activities The licensee operating shift complement is comprised of a Senior Reactor Operator (SRO) licensed Shift Supervisor (SS),
an SRO licensed Control Room Foreman (CRF),
a Reactor Operator (RO) licensed Head Control Opera-'or (HCO),
an RO licensed Control Operator (CO), three auxiliary opera-tors and a Shift Technical Advisor (STA).
The licensee maintains suffi-cient staffing to support a six shift rotation with three shi.fts on duty, one on training, one on reserve duty and one off duty.
Interviews with operators on shift provided evidence of a well trained staff.
Positive attitudes and good morale were uniformly evidenced at all levels of the shift organization.
Operator knowledge of plant conditions, annunciator status, system tagging and equipment availability was complete, except for one isolated example discussed here.
In response to concerns raised by team inspectors on September 17 concerning Condensate Storage Tank (CST) level, the Station Superintendent directed control room operators to maintain a minimum level in both CSTs greater than 15 feet.
When the inspector reviewed plant status with the HCO shortly after shift turnover on the morning of September 19, the operator was unaware of this tempor-ary standing order or for the need to maintain CST levels greater than 15 feet until the issue was resolved.
The situation was clarified and the operator informed of the requirement during the normal SS shift briefing which occurs shortly after shift turnover.
This was the only instance of a less than fully effective turnover observed by the inspec-tor.
The formality, depth and detail of the turnover process was ob-served,to be a licensee strength.
The practice of performing a post-turnover shift briefing by the SS was rioted to be of particular value in ensuring the shift crew had a complete understanding of plant status, previous shift events and planned evolutions.
Verbal turnovers were well supported by procedural aids such as 0-9, "Shift Relief Turnover - Con-trol Room" and 0-9. 1, "Shift Relief Turnover Auxiliary Operator" which provided checklists for review by the oncoming shift.
Also, 0-6. 13,
"Daily Surveillance Log" provided a good plait status check-off as well as daily surveillance checklist to support effective turnovers.
Operator knowledge of plant conditions was also indicative of quality interfaces with other plant departmental activities in progress.
The inspector noted logkeeping activities and checked the control and availability of logs to be consi stent with the requirements of applicable procedures.
Certain informational books were reviewed and found to ef-fectively communicate management instructions, technical information, and temporary and standing orders.
Discussions with operations personnel regarding utilization of logs and control of reference and informational material revealed a knowledgeable department.
Logs generally supported plant conditions and evolutions.
Although generally in compliance with the guiding procedure, A-20, this log in some instances contained minimal detail of plant events.
The log could contain more information to better support its stand-alone function as an official record.
>Ihile the log maintained by the SS generally includes amplifying information of control room activities, it is not considered the official record.
The general conduct of control room activities was well coordinated and executed.
Operator performance of a controlled downpower necessary to effect repairs to a leaking heater drain pump seal was effectively co-ordinated and supervised by the CRF and SS.
Use of two-way radios be-tween the control room and auxiliary operators appeared to be highly beneficial in supporting effective coordination of operations outside of the control room.
The ability of the control room operators to be in quick and constant communication with the auxiliary operators aids in rapid response to transient conditions.
Control room operator re-sponse tc
.wo security-related events was effective.
Conservative de-claration of Unusual Events in both of these cases was appropriate, well managed and performed in accordance with guidance contained in 0-9.3,
"USNRC Immediate Notification".
Close interaction and mutual support between the operations and security departments was also evident in in-stances where roving security personnel reported off-normal plant condi-tions to the control room, including fire detection panel trouble lights.
One isolated instance of less than fully effective control was noted during the performance of PT-12.2,
"Emergency Diesel Generator 1B", an operability test of EDG 1B.
Step 6.8 of the procedure notes that voltage should buildup to approximately 480 volts within 10 seconds.
During the performance of the test on September 15, the operator had no stopwatch to time the voltage buildup.
Although the voltage appeared to rai se to 480 volts fairly quickly, operator estimation is a poor substitute for an accurate measurement.
Another area of potential ineffective control concerned operation of the containment Hydrogen Recombiner.
The inspector noted during a.plant tour that the recombiners lacked alarm response procedures at the local con-trol panel in the Intermediate Building.
Further investigation deter-mined alarm response procedures had not been developed for the Hydrogen
Recombiners.
Although the recombiners are rarely operated and are in-tended for controlled use in a post-LOCA environment, proper alarm re-sponse procedures are necessary to adequately support operation of this equipment.
2.3 Control of Tem orar Modifications The inspector reviewed the licensee process for initiating, reviewing and implementing temporary modifications.
Applicable procedures were reviewed to evaluate content and quality in support of the modification process.
Several temporary modifications were reviewed to evaluate ad-herence to existing procedures and sensitivity to safety impact.
The inspector noted that several aspects of the current licensee temporary modification process are relatively recent additions to the program.
A review of A-1406. 1, "Installation and Removal of Temporary Structural Features" determined that the procedural requirements and controls placed on temporary modifications of this type were adequate.
Review of auth-orized modifications indicated compliance with procedures was maintained with one possible exception.
Fans located in the screenhouse (intake structure)
used to cool running Service Water pumps had been in place for several years.
Because of the proximity of the fans to the safety-related pumps, they represented a potential seismic hazard.
Procedure A-1406. 1 and A-1406, "Control of Temporary Modifications" imply a tem-porary item located within one and one-half times its height from safety-related equipment requires a restraining mechanism and a safety analysis (10 CFR 50.59) review.
Additionally, A-1406. 1 indicates that if the distance allowances cannot be provided, only one train of safety-related equipment should be affected ai one time.
Contrary to these controls, the fans in the area of the safety-related Service Water pumps were closer than the allowed distance, were unrestrained, affected both trains simul-taneously, were not controlled by procedure and had not been reviewed for potential impact on safety.
Upon identification of the problem by the inspector, the licensee moved the fans to a distance greater than one and one-half times their height away from the pumps.
The inspector reviewed A-1406. 1. 1, "Control of Temporary Lead Shielding" and determined the procedural controls placed on modifications of this nature were adequate.
A review of currently authorized lead shielding modifications determined compliance with procedures.
A review of A-1406.2, "Installation and Removal of Temporary Fluid System Provisions" determined the procedural requirements and controls placed on temporary modifications of this type were generally adequate with one notable exception.
The procedure specifically exempts hose installations unless they join two systems together or bypass a component within a system.
This exemption is considered a poor practice in that it removes from control a wide variety of hose applications that might affect safety.
An example of inappropriate lack of control of a hose was observed by the inspector in the Spent Fuel Pool (SFP).
A leaking weir g'ate between'
the SFP and fuel transfer canal was being compensated by pumping the leak-age back to the SFP.
The uncontrolled hose that accomplished this opera-tion was left i'n place continually and rdpresented a potential siphon pathway, from the SFP back to the fuel transfer canal'.
Although an air gap existed between the SFP surface and the hose end, there was no as-surance this condition would remain acceptable because the installation was uncontrolled.
The licensee maintained that analysis existed that demonstrated a loss of SFP water transfer to the canal (and resultant lowering of SFP level) was not a hazard.
The broader issue was a lack of procedural control of the installation.
Such controls which would have included a review of the analysis to formally determine a hazard did not exist and PORC concurrence that an unreviewed safety question did not existed The licensee resolved the immediate issue by removing the hose from the SFP, kxploring different options for pumping down the transfer canal, and reviewing the issue of broadening procedural control of hoses.
Review of several other current temporary fluid sys em author-izations indicated compliance within the limits of the procedure was being maintained.
A review of A-1402,
"Bypass of Safety Function or Jumper Control" deter-mined that the procedural controls placed on modifications of this nature were not adequate'lso, a review of currently implemented authorizations indicated several problems existed.
The current practice of performing the bypass solely through the use of the authorization form is inadequate, especially in safety-related applications.
Descriptions of equipment, bypass location, installation procedures, post-installation retest, parts required, removal procedures, and post-removal retest are either inade-quate or nonexistent.
guality control involvement in installation ap-pears to be bypassed by use of the authorization form to accomplish the modification.
Several examples of deficiencies in the execution of this type of modification were noted.
Bypasses 88-28, 88-34 and 88-51 removed incore thermocouple inputs from the readout system due to failed thermocouples.
A minimum number of operable thermocouples is required by Technical Specifi-cations (TS).
The incore thermocouple system is described in the Updated Final Safety Analysis Report (UFSAR).
Although the licensee verified the minimum requirements of TSs were met, no safety an-alyses (10 CFR 50.59 review) were accomplished for any of these modifications.
Bypass 88-38 removed the alarm function for the "A" Containment Re-circulation Fan demister drain level'due to frequent alarms.
This system is described in the UFSAR. 'eter indication of the drain level, is routinely monitored.
The system is drained down on average twice daily due to moisture/water accumulation, indicating a possible cooling coil leak exists.
A large failure in the cooling coils could overflow the drain system, but would be detected by increasing
level in Containment Sump "A".
Removal of the early detection feature (alarm) of the drain system is a modification that should have been evaluated under
CFR 50.59.
Bypass 88-31 is a mechanical block of the Safety Injection (SI)
system recirculation system isolation valves in the open position in response to an NRC Information Notice.
Formal directions for the installation are inadequate.
This modification is a reinstal-lation of the original mechanical block performed in mid-1986.
The original PORC evaluation of July 31, 1986 was used as justification for this modification in apparent noncompliance with procedure A-1402.
Bypass 86-54 is an electrical modification that supplements the mechanical block of bypass 88-31.
86-54 is necessary to counter some of the potential effects 88-31 could have on the SI system under certain conditions.
The installation of a bypass switch in 86-54 is poorly di rected and doesn'
specify the type or quali fica-tion of the switch.
The supporting safety evaluation for the com-bined modifications (86-54 and 88-31) is not specific enough regard-ing the need for the electrical bypass and its relation to the mechanical bypass.
Although the licensee's program for controlling temporary modifications appears to be generally adequate (with the'noted exceptions),
execution of the program is weak.
The licensee does not demonstrate a clear under-standing of contr'oiling the installation of modifications in a quality manner.
The licensee does not demonstrate a clear understanding of the safety analysis (10 CFR 50.59) process regarding temporary modifications to safety-related equipment.
2.4 Plant Conditions Detailed inspection tours of plant spaces with emphasis on safety-related areas were performed by the Team.
Tours were made during normal and backshifts and during high and low activity periods."
Items considered during the tours included equipment operability, cleanliness/housekeeping, radiological controls, equipment identification, control of operator aids and fire safety.
The overall Team impression was that the plant pre-sented a cluttered appearance and adequate housekeeping was lacking in several spaces, including safety-related areas.
Of particular note was the overall poor condition of the Auxiliary Building.
Lack. of good housekeeping, clutter, radiological conditions and graffiti combined to create an overall poor impression of several areas inside both the In-termediate and Auxiliary Buildings.
Some safety-related areas, such as the Emergency Diesel Generator (EDG) rooms; Station Battery rooms, Relay Room and Control Room, appeared to be relatively well maintained and presented an overall good condition.
Minor lube oil leaks on the "B" EDG were repaired during the inspection perio During an initial tour of the screenhouse (intake structure)
the inspec-tor noted large fans directed at the two running safety-related Service Water (SW) pumps.
Discussions with the licensee indicated the fans had been in use for years and were directed at whichever SW pump was operat-ing in order to prolong motor life and prevent reaching motor high tem-perature alarms.
As previously discussed in Section 2.3, fan use and proximity to the SW pumps appeared to violate licensee temporary modifi-cation procedures.
Beyond this aspect, however, was the licensee general acceptance of a condition where portable fans were deemed necessary to the proper functioning of safety-related equipment.
The licensee's lack of appreciation of this issue was displayed when the initial response to the inspector concerns was to move the fans a distance greater than one and one-half times their height away from the SW pumps.
Eventually, the licensee secured the fans and commenced a review of the matter.
However, the general use of portable fans was evident throughout the plan
.
Several sets of fans were in operation on non-safety electrical buses 013 and 15 transformers and on the "B" Main Feedwater pump, as well as other plant locations.
As previously noted, conditions in the Auxiliary Building were generally poor.
Uncontrolled hoses and cabling were evident throughout the build-ing.
Where these items originated and terminated was often nearly im-possible to discern.
Housekeeping practices are poor and detrimental to personnel and fire safety.
General trash and debris was evident throughout the upper floor of the Auxiliary Building.
Some of these items partially obstructed ready access to fire fighting equipment.
A leak in the roof that had existed for some time was splashing water within a few feet of a safety-related electrical control center.
Cable tray covers exhibited evidence of being=- used as personnel supports.
Cable tray covers were improperly secured in some cases.
Boric acid crystal buildup in the evaporator rooms resulting from system leaks was significant.
Several areas exhibited uncontrolled operator aids and some graffiti was evident.
The Auxiliary Building is a radiological control area and anti-contamination clothing is required for access.
This re-striction tends to inhibit frequent inspections by supervisory personnel.
The general condition in these spaces is attributable, in part, to a lack of supervisory over sight.
2.5 Administration The Operations Department is comprised of an SRO licensed Operations Manager and Operations Supervisor, an Assistant Operations Supervisor (normally a Shift Supervisor on six month rotation), various rotating special assignments, and a six shift crew rotation.
The licensee has recently implemented the six shift rotation and concurrently shifted to a forward rotation schedule to improve the pattern with respect to cir-cadian (biological) rhythm.
These changes have generally been met with operator acceptance, but are currently considered on a trial basis.
Use
of overtime was limited, controlled, and appeared to meet licensee goals.
The "R" (reserve) shift crew works a day shift and generally supports departmental administration.
This crew is available for control room assistance during periods of increased activity.
The licensee voluntary degree program for operators was considered a
strength.
Begun in 1979, the program has graduated some 25 operators with Bachelor-level degrees in Mechanical Engineering Technology.
Cur-rent enrollment in the program is 22 operators and 10 technicians from other departments.
The program has provided an alternate career oppor-tunity for those operators completing the program.
Past licensed opera-tors who have completed the program have joined other licensee depart-ments, increasing the organizational understanding of plant operations.
Operators support the program and view it as a career enhancement.
Administration of the Operations Department appears to be smooth.
Pro-cessing of required documents appeared to be timely.
The Ginna Station Event Report program (A-25. 1) and Control of Limiting Conditions for Operating Equipment (A-52.4) effectively document and track varying equipment and operational transients and problems and receive an appro-priate level of review.
Operating logs and rounds sheets were generally maintained in accordance with procedural guidance.
Improvements to auxiliary operator logs in response to a March 1988 guality Assurance (gA) audit was in progress.
Changes to the logs should improve the ef-ficiency and effectiveness of operator rounds.
Operations Department response to various internal assessment and corrective action programs appeared to be both adequate and timely.
Although the licensee total Corrective Action Report (CAR) program has many outstanding action-due CARs, Operations Department has very few open required CAR actions.
Corrective actions for Licensee Event Report (LERs),
CARs and other assessments appeared to adequately address issues and correct problems.
2.6 Assurance of ualit Assurance of quality for plant operations was assessed by examining pro-grams, performance and supervisory involvement across a diverse sample of functional areas.
Interviews, programmatic reviews, meeting observa-tions and records reviews were performed to determine the effectiveness of a corporate commitment to quality operations.
The inspector noted no program currently exists for performing (}uality Control (gC) surveillances of operations activities.
The licensee is in the process of developing a program using an SRO licensed operator as a keystone.
A past lack of emphasis in this area should be improved by the new program.
The Operations Manager is currently in the preliminary planning stage for implementation of an Operations Section guality Moni-toring program which will utilize the reserve shift crew in a gC-type capacity.
The program will provide a routine independent review of various operational and administrative practice An internal gA audit of the operations department was performed in March-April 1988.
Review of the audit report indicated a performance-based approach to assessing operating activities was used.
The findings in the report were probing and addressed fundamental issues rather than superficial problems.
The inspector noted the audit discussed some areas that were identified by the team including uncontrolled operator aids and the poor state of housekeeping in the Auxiliary Building.
Management response to some of the findings was timely and effective.,
Other issues are still open and awaiting final corrective actions.
The general character of the audit findings seemed to indicate some deficiencies exist in providing adequate supervisory direction and review of operating activities.
The team observed one aspect of this issue in the apparent lack of supervisory and management tours of the plant.
In one instance, a Shift Supervisor had made only a few cursory tours in safety-related
'reas in the most recent three months and did not tour the Auxiliary Building at all during that period.
Management has been deficient in touring plant spaces.
Senior plant manager s rarely visited the Auxiliary Building in the past year and performed few tours to other safety-related
. areas.
The team noted conditions'in the Auxiliary Building reflected the lack of management involvement.
Material conditions in these areas have existed for a long time and have been the subject of several inter-nal and external assessments.
Continued management acceptance of these conditions illustrates the lack of an effective assurance of quality ap-proach to the problem and a lack of sensitivity to the potential safety impact of the issue.
3.0 Maintenance The Team assessed the station's maintenance policy, as well as the performance of the maintenance activities.
Plant maintenance programs were reviewed to determine their effect on safe operation of the plant.
The impact of the maintenance backlog of safety-related equipment was reviewed.
The inspection included observation of ongoing work, reviews of completed work packages, re-view of station administrative procedures governing the conduct of maintenance, and interviews with licensee staff.
The interface between the maintenance department and other station personnel was observed, as well as the interac-tion with guality Control personnel.
3. 1 Maintenance Pro ram The Maintenance Manager is responsible for the implementation and man-agement of the maintenance organization at Ginna and is under the General Manager of Nuclear Production.
In the latter part of 1987, the mainten-ance department underwent a reorganization that established four chains of command under the maintenance manager; an Instrumentation and Control (IKC) Supervisor responsible for the 18C department, a Mechanical Main-tenance Supervisor responsible for the var'ious trade shops and services, a
new position of Planning and Schedule Director responsible for work scheduling and planning, and a
new position of Maintenance Systems Director responsible for various special projects.
The structure change
of the maintenance department reorganization is completed; however, some vacancies do exist.
The maintenance department has a total of approxi-mately 85 people currently employed.
The last refueling outage ended in March of 1988 and the next refuel outage is scheduled for March 1989.
3.2 Work Observation and Review During the course of the inspection, the unit was at power and there was no major safety related maintenance that could be observed.
Of the main-tenance activities observed by the inspector, two were safety-related.
The following is a brief synopsis of each job observed and procedures reviewed.
The inspector observed a three year Periodic Maintenance (PM) required by Procedure A-1010 (PM schedule for rotating equipment)
on 'A'oric Acid Distillate Pump.
The work was performed by a maintenance shop mechanic and no Quality Control (QC) coverage was required since the pump is classified as nonsafety-related.
The pump is located in the Auxiliary Building and dressing in full anti-C'
was required.
Poor housekeeping practices were evident upon arrival at the work site.
The Health Physics (HP) coverage required the mechanic to clean up approximately one gallon of water on the floor prior to starting the work.
There was a large amount of Boric Acid (BA) residue beneath the BA evaporator in a con-taminated area.
Electrical cables and electrical junction boxes in the work area were coated with BA residue which means that at one time these electrical items were covered with water.
This example of poor house-keeping is an considered electrical, radiological, and corrosive hazard, and was described to the maintenance manager.
The mechanic started the disassembly of the motor to inspect the inter-nals and measure critical clearances such as bearing wear.
The mechanic did not use the procedure and left it in his work bag until questioned by the inspector.
The mechanic was very skilled and had performed this work several times before.
The measuring and test equipment used on the job was verified to be in proper calibration.
The inspector noted two concerns on the hold (isolation) of the pump.
The hold tag nomenclature did not match the label plate breaker description on the BA power panel.
The maintenance department management is evaluating this problem for in-terim corrective action, and stated that the new program of configuration management will eventually resolve these discrepancies in the long term.
The nomenclature discrepancy could have led to personnel hazard or equip-ment damage problems.
The second hold concern was that no apparent mechanical isolation was established for the job.
When questioned by the inspector, the person who prepared the hold could not determine if the pump was properly held.
Research after the fact by the licensee found the hold was indeed proper.
Only qualified personnel should pre-pare holds and prints must be used properly when preparing a hold.
The inspector concluded that more sensitivity towards the hold system is neede Safety-related Corrective Maintenance (CM) on the auxiliary feed pump recirculation valve No.
4310 was observed by the inspector.
This job was pre-planned by the newly formed planning/scheduling department.
The operations department implemented the hold and was aware of technical specification requirements.
The maintenance was performed by the pipe shop mechanics per Procedure M-37. 16.
The CM was the result of valve seat leakage and body to bonnet leakage.
The inspector noted the Main-tenance Work Requests (MWR) were generated in 1984 and 1986, and this example of old outstanding safety related work was found to be an iso-lated case.
The valve was disassembled and the internals were found to be excessively worn and required replacement.
The valve bonnet was taken to the pipe shop where it was repacked and a
new plug and seat were fitted.
The IHC shop removed, rebuilt and recalibrated the air pilot.
QC coverage was'vident 'at the work site.
The procedure was used by the mechanics.
The work procedure lacked detailed work instructions and contained only one QC signoff for cleanliness'ontrol.
The inspector reviewed the QC inspector's surveillance report issued at the end of the job and found it to be adequate.
The IKC and pipe shop mechanics were very experienced and displayed excellent skills of the trade.
Safety-related maintenance on 'B'DG consisting of four individual jobs was observed by the inspectors.
There was only one QC inspector to per-form surveillance checks on all of the jobs.
The maintenance consisted of the following jobs:
JOB REASON Replace 'B'DG Lube Oil (LO)
strainer D/P switch.
'B'DG low oil pressure Agastat change out Licensee identified in response to NRC Notice IE87-66 (non-IE Agastat used in IE application).
Reset LO temperature switches for activation of LO heater and high temperature alarm Bul 1 et i n from EDG manu facturer.
EDG 'B'oom ventilation circuitry.
Calibration of start circuitry.
'A'DG was started and was kept running during this maintenance to com-ply with Technical Specification (TS) limiting condition for operation (LCO) for one EDG being inoperable.
Supervisory personnel were observed checking the status of the work.
The new LO D/P switch was calibrated in the shop prior to installation on 'B'DG.
The inspector questioned why a non-Quality (non-Q) replacement LO 0/P switch was being installed vice a Quality (Q) controlled switch.
The QC inspector based installing a non-Q switch on a Quality Assurance Document Interpretation Request (QADIR) evaluated by offsite engineering.
The inspector did not agree
with this evaluation and raised 'this concern to the Maintenance Manager.
The QADIR was poorly evaluated and was sketchily worded.
A Nonconform-ance Report (NCR) was issued on this Q vs non-Q replacement part problem and is discussed further in Section 3.3
~
Mhen all maintenance was completed on 'B'DG, the hold was cleared and an auxiliary operator aligned 'B'DG per Procedure T-27.2 for post main-tenance testing which consisted of an EDG operability check per TS re-quirementss.
'B'DG was started and was running when the Senior Resident Inspector (SRI) asked the operators in the control room how the NCR on the non-Q switch was resolved.
This was the first time the operators knew of the concern.
Further investigation revealed there was much con-fusion to the actual status of the work'.
Investigation revealed that the NCR (G88-376)
on the switch was incomplete since the disposition was not reviewed and approved.
The concern was that the EDG was going to be declared operable without proper resolution of the LO D/P switch problem.
The inspectors noted management did not possess a questioning attitude or safety perspective towards this issue.
There was a communi-cation breakdown between the maintenance, QC personnel and the operators in the control room.
Control of post maintenance testing of the inlet and outlet mechanical joints to the LO D/P switch was informal and speci-fic documentation did not exist.
The inspector noted no other concerns with the EDG maintenance.
The inspector reviewed PM testing procedures for 1A, 1B and 1C Safety Injection (SI) pumps.
PM procedure M-ll.12.1 was reviewed for 1A, 1B, and 1C SI pump maintenance for each refuel cycle over the last 5 years.
The inspector noted this procedure lacked descriptive work instructions and contained only one QC signoff for cleanliness.
The equipment main-tenance cards for SI pumps in the maintenance shop files were reviewed and were found to be up-to-date.
The inspector noted this was a good source of information, but the cards could use more detail such as re-placement part numbers, etc.
The inspector reviewed the monthly sur-veillancee test data for the 1A, 1B and 1C SI pumps with the Results
Test (RET) group.
The data are tracked on a trend graph and proved to be useful.
The following data are trended; bearing, vibration, pump 0/P and operational inlet pressure.
The R5T group recently found 'C'ervice water pump discharge pressure was below acceptable discharge pressure at required flow.
This was de-termined during increased surveillance periodicity which proved to be successful.
3.3 A/
C Interface The inspector reviewed a biannual audit (88-17) of the maintenance de-partment performed by the QA organization on June 14, 1988.
The audit yielded eight findings and was found to contain good technical depth.
The audit assigned corrective action to the station superintendent and required an initial, interim and final response.
The inspector noted
i
several examples of procedure compliance and procedural inadequacy prob-lems found during this audit of work practices.
The inspector views this audit, as a positive step toward identifying weaknesses in the maintenance department.
The inspector witnessed one of the corrective actions in progress which was a maintenance department worker auditing workers on a
1B EDG Agastat change-out job through the use of an audit checklist (maintenance self-assessment).
There is insufficient guidance and therefore misunderstanding as to the designation of a replacement part/component as quality (Q) or non-Q con-trolled.
This observation is based on several interviews with mainten-ance and QC personnel, and observation of a diesel lube oil strainer differential pressure switch being improperly classified.
Ginna's QA Manual specifies whether or not whol.e systems are
"Q" related but does not desi gnate specific components/parts.
This leads to evaluations on a case by case basis to determine whether or not a specific component/
part, is "Q" or "non-Q" related.
The criteria used to make the evaluation appear to be informal and lack sufficient detail.
The need to establish a "Q" list for components has been recognized by the licensee for several years.
This concern was discussed with the maintenance manager who agreed that further guidance for how to designate
"Q" vs "non-Q" parts is needed.
The inspector witnessed several survei llances performed by QC inspectors and found the survei llances to be satisfactory in regards to existing requirements of the Ginna Quality Assurance Manual.
It appear s that the QC role in maintenance is a passive one.
The work procedures are general and require few QC independent verifications.
The content of surveil-lances performed by QC inspectors vary and are not standardized.
Certain critical elements for like jobs should be independently verified and documented by QC to increase the quality of work.
Inspection of valve seating surfaces is not normally checked during QC surveillance of valve repair unless specifically called for by the maintenance procedure.
This concern was also previously identified by a contractor Audit Report No.
TR-88-73-01 in August 1988.
Work Schedule and Work Order Backlo The process of work scheduling is an effort of the newly formed planning and scheduling group which is divided into the PM and CM groups.
The supervi sory positions are filled by personnel with extensive experience in either operations or maintenance.
PM is determined by three analysts; PM analyst, electrical analyst and IC analyst.
PM is performed without the issuance of a MWR.
The PM group issues a monthly list to the plan-ner/scheduler.
The CM group is subdivided into four disciplinary areas:
pipe shop plan-ner, electrical shop planner, mechanical shop planner and an I&C shop planner.
The preventive to total maintenance ratio is 70 percent.
~
i fA
~
. lh -A ff Yl
is performed through the use of MWR's.
Each MWR is assigned a priority of either:
emergency/urgent,,
routine, planned outage or convenience, as specified per Procedure A-1603, step 3.22.
A weekly maintenance schedule is issued by the supervisory planner/scheduler-who receives input from the PM and surveillance testing groups.
A daily morning management meeting resolves any conflicts between jobs or with plant conditions.
The inspector attended a monthly 1989 outage planning meeting for the maintenance department.
Tracking of procurement parts and issuance of procedures were subjects for the major jobs of the outage.
There was an open exchange of information at the meeting and it was viewed to be an effective management planning tool.
The chairman for this meeting was the director of the planning/scheduling group.
3.4. 1 Work Order Backlo A review of the station's work order backlog was conducted and included discussions with licensee personnel and review of items in the backlog.
The backlog contains outstanding cor-rective maintenance work packages, some of which contain more than one maintenance work request (MWR).
Only work packages in the disciplinary areas of machine shop, pipe shop, electric shop, and l&C shop are tracked.
These discipline areas contain the bulk of safety-related corrective maintenance.
The in-spector noted that there is safety related maintenance outsid'e these 4 disciplinary areas that is not tracked under this sys-tem.
PM is accomplished through the use of work procedures, however, MWRs are not used.for this work.
The newly developed planning/scheduling group has cognizant authorship of the backlog, and is in the early stage of developing an effective system.
Prior to the establishment of the planning/scheduling group there was no formal tracking system used to track the backlog and it was the shops responsibility to ensure the CM was scheduled and performed.
Until recently, it appears the backlog was managed by a few key individuals rather than a for-mal system that functioned as a useful management tool that could be audited by senior management.
The inspector obtained the following statistical data regarding backlog issued from the planning group.
Total work packages (Q & non-Q related) for the 4 disciplinary shops listed above 276 Work packages requiring an outage Safety-related work packages Safety-related non-outage packages 135 of 276 108 of 276 48 of 276
i
These statistics reflect that the backlog of CM work packages is low.
The oldest work packages noted were two years old.
The backlog divides the work packages by outage vs nonoutage, safety-related vs nonsafety-related and a prioritization scale of 1-4 (1 being the most urgent).
The inspector noted the current assignment of prioritization requirements is a weakness and the licensee was already developing a more meaningful pri-oritization scale.
Procedure A-1603 (MWRs), Step 3.2.2 states that priority 2 MWR's "are items which should be corrected in a timely manner.
Attend to these the next working day."
Con-trary to this requirement, most priority 2 MWR's are not com-pleted in this specified time frame.
The licensee committed to issuing a change that will resolve this conflict.
MWR'
are reviewed annually and a
new number assigned, thus the ag'e of the MWRs is not being tracked.
The individual planners and the supervisory planner/scheduler have extensive backgrounds in maintenance or operations.
The formalization of the backlog tracking system is in process and will result in a more effec-tive management tool.
Specific goals of backlog reduction have not been assigned yet.
Review of specific work items listed in the backlog revealed 76/276 packages were awaiting procure-ment of replacement parts or issuance of work instructions.
This tracking process is accomplished manually.
However, after the optimum tracking system is developed, computer software will be modeled and implemented as a long range goal.
3.5 Maintenance'nitiatives There are many initiatives in the planning and implementation stages in the maintenance department.
Several of these initiatives arq long term programs that will result in "formalization" of the work process at Ginna Some of the initiatives are listed below.
Allocate resources to develop a Q-list.
In the interim, two con-sultants are going to be brought in to decide whether or not parts/
components are Q or non-Q related.
The procedure upgrade program (PUP) will develop detailed and de-scriptive wor k procedures and should result in increased quality of safety-related work and also better post maintenance testing.
The maintenance department reorganization that took place in the latter part of 1987 established new positions filled with experienced personnel and should result in wor'k being accomplished in a more controlled and preplanned fashion.
The use of RG5E workers to supplement the work force during outages vice outside group g i
A corrective action report (CAR) meeting was held to determine the cause of confusion concerning the EOG operability status resulting from the identification of a non-qualified part being installed on
DG.
Two actions were generated from this meeting.
First, stricter compliance with Procedure A-1502 (NCR's),
Step 3.2.8 re-quiring a
gC hold to be placed on the components in question to prevent inadvertent installation or use is required.
Secondly, a
procedure change will be issued to require gC to add an additional line item on the existing hold (isolation) sheet in the control room to prevent mark off until the NCR is properly dispositioned.
These corrective actions are viewed to be responsive and positive steps towards improving the work control process.
The "reliability c'entered maintenance" initiative was started ap-proximately I year ago.
Under this new program, an in-depth study is performed on each system to determine root cause and corrective action for recurring problems on the component level.
The initial phase selected 20 of 48 total systems.
The selection process de-termined the initial 20 systems by the use of a "weight" factor taking into account such criteria as safety significance, etc.
3.5. 1 Maintenance Self-Assessment A maintenance self assessment was performed by the maintenance manager of Ginna over a period between I'0/85 and 6/86.
This assessment was reviewed by the inspector and was found to be objective and comprehensive.
Many management tools were used to substantiate the findings such as the performance of a ver-tical and horizontal audit of the work process.
The assessment puts into focus many new programs and initiatives.
Between 6/86 and 6/87, a maintenance improvement plan (MIP) reorgani-zational report, analysis and proposed organizational structure was generated.
Upper management approval of the MIP was ob-tained between 6/87 and 9/87 time interval.
The MIP will be implemented in 3 separate phases.
Phase I was implemented in the latter part of 1987 and primarily focused on the reorgani-zation of the maintenance department structure.
The degree of success of the new initiatives and programs is dependent on increased support by corporate management.
3.6 Conclusions The strength of the maintenance organization is in the experience and technical competence of the working level personnel.
This is supported by direct observation of'work in progress.
Management of the maintenance department appears well focused and is committed to improving weak pro-grammatic areas.
An example of this commitment is the maintenance self assessment.
The recent reorganization of the maintenance department has
I
&
'NA 1v 46 %V N,llA1JA L ~
)
~
4g
\\,
0
'
created a
new planning/scheduling group staffed with experienced people.
When developed in response to the inspector, the backlog in the four dis-ciplinary areas was found to be low. It was apparent that Ginna is sen-sitive to balance of plant maintenance as evidenced by the low number oi plant trips and forced outages.
The creation of a more formalized work process is in progress and will be implemented via the use of many long-term programs.
An increased emphasis on adherence to work procedures and administrative procedures is necessary.
During the implementation of these new programs, tne working level personnel must be kept up-to-date on department poli-cies through the use of increased training.
The backlog is not being fully utilized as an effective management tool.
The role of gC in the work process is neither'aggressive nor completely effective.
Work pro-cedures were noted to be weak, which lead to other problems such as in-formal post-ma'.ntenance testing.
The success of long-term initiatives discussed above is dependent upon concomitant individual and corporate support for their implementation.
4.0 En ineerin Su ort Activities 4,1 Sco e and Ob'ectives The team conducted an evaluation of 'various engineering documents and activities performed by the licensee including plant drawings, design calculations, engineering specificat,ions, design bases, and Appendix R
analyses.
4.2 Licensee Initiatives The licensee commissioned outside contractors to perform a functional review of the auxiliary feedwater (AFW) system and to redesign certain large steam generator (SG) supports.
The AFW review was a good initi-ative intended to re-examine system design'ases and capability.
The SG support redesign effort will allow the replacement of six (of eight total),hydraulic snubbers with rigid structural members.
This design is innovative and the removal of the hydraulic snubbers will avoid the radiation exposure associated with annual maintenance activities.
The licensee is also currently conducting programs to upgrade station draw-in'gs and configuration control.
4.3 Tank Volumes The inspector reviewed the engineering and design bases for certain tanks which are required to have minimum inventories by the safety analysis and the Technical Specifications.
The tanks selected were the emergency diesel generator fuel oil tanks, the boric acid storage tank, the sodium
hydroxide tank, the Refueling Mater Storage Tank (RMST), and the Conden-sate Storage Tanks (CST).
None of the calculations in the design pack-ages showed any evidence of a formal independent review (second check).
The RMST volume calculations were revised during the SEP (1981) review and no significant deficiencies were identified in the calculations for the RWST, the boric acid storage tank or the sodium hydroxide tank.
The diesel fuel oil tank was the subject for a 1979 gA audit (79-11:GS)
which observed that the tank suction tap was 18 inches above the bottom of the tank rendering that portion of the tank unavailable.
The licen-see's corrective acti'on was to raise the required indicated level to assure the required fuel volume was available to the diesel.
The in-spector found no evidence that this observation was extended to other site tanks to check for similar calculation errors.
The calculations involving required CST levels were found to contain major flaws in assumptions.
In a March 28, 1980 letter, the licensee stated 22,500 gallons total inventory in the tanks would provide the necessary supply for the turbine driven AFW pump for plant cooldown.
The calculations assumed a maximum 70 degrees F water temperature as de-livered to the steam generators.
Tank temperatures were 87 degrees F
at the time of the inspection and are generally kept above 70 degrees F to reduce thermal shock and other nil-ductility temperature (NDT) con-cerns.
The effect of the higher temperature water supply would be to increase both the water mass and volume required.
The CST calculations assumed the entire tank volume was available.
Tank drawings and in-situ inspection revealed that the suction centerline was nearly a foot above the bottom of the tank rendering over 1000 gallons in each CST unavailable for delivery.
The suctions at the electric and turbine-driven AFW pumps were found to,be approximately two feet and three feet, respectively, above the bottom of the CST.
With only gravity feed as a water source, this height differential further reduces the CST volume that might be available to the AFW pumps without a net positive suction heat (NPSH) analysis.
The CST calculations neglected both NPSH requirements and the effects of instrument accuracy.
The cumulative effect of these errors is potentially significant.
With level at ten feet in the two CSTs as required by the Technical Specifi-cations, the layout of station components may reduce the water available to below the actual volume required.
These errors were not iden'tified during the contractor conducted AFW study completed earlier in 1988.
At the end of the inspection period, licensee investigation of CST volume requirements, reanalysis of AFW NPSH, and review of the Technical Speci-fications and current procedures were in progress'
Flow Testin The inspector selected three types of pumps which have Technical Speci-fications on minimum flow: the fire pumps, AFW pumps, and containment spray pumps.
The inspec or reviewed the applicable flow testing proce-dures and identified no functional deficiencies.
The fire pumps are tested under full flow conditions by recircing to the discharge canal.
The AFW pumps are also tested under full flow to the steam generators.
The containment spray pumps, however, are normally tested under low flow conditions via a test line with the full flow performance extrapolated from pump curves.
The calibration instruments associated with the pump surveillance tests are controlled under Administrative Procedure A-1105, "Calibration and/or Test Surveillance Program for Instrumentation/Equipment of Safety Related Components."
The inspector reviewed A-1105 and noted that the flow in-
'struments associated with the AFW test were not in the procedure.
Review of the individual procedures showed that the AFW flow instruments had been calibrated within the frequency required for similar devices and the licensee committed to revise A-1105 to include the inst. uments.
4.5 The containment spray flow instrument (FI-933) is listed with a calibra-tion frequency of seven years, with the device being replaced at that time.
Two other instruments have similar directions, both associated with safety injection test line flow (FI-929 and FI-929A).
The design of these instruments is such that they cannot be calibrated in place, but must be sent offsite.
The inspector noted that there should be some technical basis for the long calibration interval.
Licensee investiga-tion was still in progress at the close of the inspection.
Safet -Related Electrical Cable The inspector conducted a walkdown of the major safety-related cable tray routing.
The original electrical design of Ginna did not anticipate later regulatory requirements applied to subsequent plants with respect to cable separation.
The inspector identified several cases where safety-related cable had little or no separation from cable of the other safety train.
Licensee efforts to upgrade the electrical layout are evident with original, non-fire retardant cable sprayed with protective coating near penetrations and certain key cable runs fire-wrapped as they trav-erse other fire areas (see also Section 4.6).
These licensee actions were in response to NRC requirements due to the SEP review and Appendix R.
For the last several years, the licensee has conformed to current industry practice of using fire resistant cable and metal conduit in Ginna modifications.
The licensee is in the process of computerizing cable routing records to facilitate design analysis and to ensure that modifications are routed with what separation is available.
The computer
software is equivalent to current, standard industry practice, but was more difficult to establish at, Ginna than at more recent plants due to the age of the plant.
The inspector noted numerous examples of missing conduit covers, untaped cable ends and open junction boxes.
These items were identified to lic-ensee personnel for correction.
The inspector reviewed licensee proce-dures with respect to these items and confirmed that cable which is cut and retired in place should be taped.
Requirements for internal conduit seals, however, were found to be inconsistent with current NRC guidance.
Ginna was licensed to the criteria contained in Branch Technical Position (BTP) APCSB 9.5-1 which did not specifically address internal conduit fire seals.
Fire barriers were required to be demonstrated intact when penetrated by cable tray or conduit.
In 1979, the licensee created specifications for the installation of in-ternal conduit seals (EE-15, "Service Specification, Ginna Station, Fire Barrier Penetration Seals" ).
This document gave very specific guidance on what constituted an acceptable seal and at what distance no seal was necessary.
This was a good initiative although no test data, mathema-tical analysis or any other technical bases were used.
A year or two after EE-15 was approved, the NRC issued BTP CMEB 9.5-1 which gave speci-fic guidance on internally sealing conduit that was more restrictive than EE-15.
The new BTP was not a license requirement for plants like Ginna which were licensed before 1981.
The licensee did not revise EE-15 and later issued EE-24 ("Services Specification, Ginna Station, Fire Barrier Penetration Seals Installed by In-House Forces" ) which contained criteria identical to EE-15.
EE-24 was subsequently revised twice with the latest version (Rev.
2) approved March 9, 1987 without any changes to the dis-tance or smoke seal criteria.
All plant modifications incorporate one or both of the above specifica-tions, which indicates much of the Ginna conduit is sealed, or not sealed, in accordance with these engineering criteria.
A Topical Report concern-ing internal conduit seals has been submitted by a utility group (which includes the licensee)
to the NRC and is currently under NRC review.
The inspector indicated that a licensee review of both EE-15 and EE-24 would be appropriate after resolution of the issues addressed in the Topical Report.
Alternate Safe Shutdown The inspector conducted a review of two selected engineering aspects of the Ginna alternate safe shutdown design:
the water source for decay heat removal and the routing of power.
The review consisted of system walk-downs, the licensee's Alternative Shutdown Design submittal, engineering specifications and design calculation A
l
<~
t
The normal water source for EDG cooling is the service water system which has four pumps, all located near each other in the Screen House.
The two fire pumps are also located in the Screen House.
The Appendix R loss of Screen House scenario would produce a loss of AC power until water was diverted from the city water main which supplies drinking fountains, condensate makeup, etc. to supply diesel cooling water.
The availability of this offsite water system is not addressed in the Technical Specifi-cations, plant procedures or other documents.
Discussions with licensed plant operators indicated that the loss of the offsite water system was seen primarily as a loss of condensate tank makeup with a need to sched-ule delivery of condensate by truck; some effects on fire fighting were also noted.
In discussions with the licensee, the inspector noted that any unavai 1-ability of this offsite water system constituted a period of plant vul-nerabilityy to the Screen House fire as no means would be readily avail-able to achieve safe shutdown.
The inspector noted plant personnel could recall instances when offsite water pressure had been lost.
Mith the licensee's analysis taking full credit for the offsite water system for certain scenarios, the inspector indicated it would be appropriate to limit plant operation during system unavailability or to implement pre-planned measures to compensate for system loss.
Continued plant opera-tion without measures following a loss of the offsite water system could constitute operating the plant in an unanalyzed condition.
The inspector reviewed the electrical drawings and circuit schedules associated with achieving safe shutdown as required by Appendix R.
Cer-tain conduits containing the necessary circuits were found to be wrapped with a protective material.
The wrap was installed to assure that a
postulated fire in one area would not render inoperable key components located in a different fire area but whose cable physically traversed the area of the postulated fire.
The protective wrap was not applied to the metal supports for the cable.
A review of EWR 3986,
"Design Analysis, Ginna Station, Appendix R Fire Barriers, Conduit Supports Rated Fire Protection Wrap", revealed several areas of weakness.
Little actual analysis was found in EWR 3986; the major assumption of the document was that one class of supports would not fail.
The document considered only the need for the supports to remain intact and did not consider that the exposed metal provided a path for heat conduction to the conduit protected elsewhere by the wrap mate-rial.
Electrical cable can fail if heated above design values.
The failure to address this potential failure mode constitutes a significant weakness.
The document contains no calculations or references to other licensee analyses except the Appendix R submittal.
The EWR considers only fire severity minutes (maximum 13.5)
and takes credit for water suppression systems.
The referenced Appendix R submittal postulates fire duration up to 25 minutes and does not take credit for early automatic suppression
l ~
(I
(Section 3.3. 1.(3)).
Furthermore, the Appendix R submittal commits to providing one hour equivalent protection (per Appendix R,Section III.G.2)
for the cable by wrapping the conduit, and EWR 3986 gives no basis for varying from the one hour commitment.
4.7 Conclusions Overall, the licensee's engineering organization appears to be staffed with dedicated, knowledgeable personnel.
Relatively low staffing (about 45 personnel)
may be one causative factor for the observed weaknesses in analysis and calculation review.
The licensee relies on outside con-tractorss to perform major analysis efforts such as the AFW review and SG snubber replacement study.
Planned increases in licensee staffing in engineering may improve analysis and oversight capability.
Specific weaknesses not yet, fully addressed at the close of the inspection include:
Complete CST volume review and NPSH calculations and document re-view/revision.
Revise A-1105 to include AFW flow devices and address the adequacy of the seven year calibration interval for the containment spray and safety injection flow devices.
Address compensatory measures to be taken upon loss of the city water supply.
Reanalyze the need to wrap the supports for cable trays and conduits wrapped to comply
> ith Appendix R requirements.
5.0 Chemistr and Effluents The objective of this part of the inspection was to assess the licensee's chemistry program, including radioactive effluents, with respect to management and staff attitudes, adequacy of staffing and training, goals and objective, effectiveness of program implementation and work control, organizational in-terfaces, and quality oversight and self assessment.
The specific items re-viewed with respect to the above attributes were: Organization and Staffing, Chemistry Operations, Technician Training and Retraining, equality Assurance and (juality Control, and Facilities and Equipment.
5. 1 Or anization and Staffin The licensee's chemistry program is contained within the Health Physics and Chemistry Department.
Primary system chemistry and radiochemistry as well as effluent and process radiation monitors, post accident samp-ling system, and the radiological environmental monitoring program are under the direction of the Radiochemist.
Primary system sampling and analyses are performed by Radiation Protection Technicians.
These tech-nicians perform both chemistry and health physics tasks.
Secondary side chemistry and related tasks are performed by chemi stry technicians under
the direction of the Secondary Chemist.
These technicians are chemistry technicians only and perform no health physics tasks.
The Secondary Chemist reports offsite to the Supervisor of Power Plant Chemistry in the Research and Science Department.
In fact, the entire secondary chemistry organization is actually part of the Environmental Sciences and Laboratory Services Division within the Research and Science Depart-ment.
Despite this unique organizational structure, the chemistry opera-tion appears to function well.
There are good communications between various members of the department, both laterally and vertically.
Indi-viduals are aware of their responsibilities within the organization and their role as it relates, to overall plant safety.
Staffing appears to be adequate, with small amounts of overtime in the chemistry areas.
The licensee has added or plans to add several new positions to the chemistry organization.
The position of Control Chemist has already been cr'eated and filled.
This position is part of the secondary chemistry group and is actually an Environmental Sciences and Laboratory Sciences Division position.
However, initial plans call for most of the initial effort of this individual to be devoted to Ginna Station activities.
A position of Analytical Chemist has also been created in the secondary plant organization but has not yet been filled.
In response to recent audit findings concerning the licensee's laboratory QA/QC program, the licensee has created the position of laboratory QC Specialist in order to strengthen the laboratory QA/QC program.
The licensee is in the process of filling this position.
In addition, the licensee is adding two more Radiation Protection Tech-nicians to the staff.
The licensee is also considering establishing lead technicians in specific areas.
This is in response to the fact that analytical instrumentation and analyses are becoming more sophisticated and require some degree of specialization.
The inspector noted that the above staffing plans reflect management support for chemistry operations.
5.2 Chemistr Operations The licensee's program for planning and controlling routine chemistry
~
activities is detailed in Procedure MC-1, A List of Sample Chemistry Parameters and Sampling Schedule; and Procedure PC-l. 1, Primary System Analysis Schedule and Limits.
These procedures provide a matrix for tracking the required sampling and analysis frequencies, and listing acceptable limits for results.
Procedure PC-1.3, Daily Chemistry An-alysiss Results, provides the results of daily chemistry analyses to con-trol room personnel.
The inspector noted, however, that some weekly, monthly, and quarterly activities were part of a matrix that was not a
part of any procedure.
Included in this matrix were items such as radio-active effluent sampling and analysis requirements.
The inspector dis-cussed this item with the licensee, and the licensee stated the matrix would be included in a procedure
The licensee has implemented several initiatives in order to maintain secondary plant chemistry controls.
These include a catalytic oxygen removal system as the make-up water system, and a computer based data trending system which is used to record and trend data from various secondary plant monitoring points.
This system provides not only data trending, but also the capacity to analyze an out of specification con-dition and determine corrective action.
The licensee is following cur-rent industry guidelines with respect to maintenance of chemical controls and reduction of impurities in both primary and secondary systems.
in addition, the licensee has formed a steam generator reliability com-mittee.
This is an informal committee which meets approximately every one-two months in order to discuss various aspects of maintaining the steam generators.
Recent discussions have included steam generator chemistry and the addition of boric acid to the steam generators.
The inspector reviewed the minutes of the four meetings held in 1988 to date:
January 6, April 22, June 15, and July 27.
The inspector noted that the distribution list for the meeting minutes included the Senior Vice Presi-dent, Production and Engineering.
The inspector also noted, however, that the minutes did not contain a li,st of attendees.
The licensee stated that future meeting minutes would include a list of attendees.
The commitment to maintaining the integrity of the steam generators through the use of the above initiatives is a noted strength of the licensee's program.
The licensee's routine chemistry activities also include reviews of chemistry data by corporate personnel.
The primary side data are re-viewed by the Corporate Health Physicist, who also has a background in primary side chemistry and radiochemistry, in'the Nuclear Engineering Services Department; and the secondary side data is reviewed by the Supervisor of Power Plant Chemistry in the Research and Science Depart-ment.
Periodic reports are issued by these individuals discussing their review of the data.
The distribution lists for these reports include senior-level corporate management.
5.3 Technician Trainin and Retr ainin The inspector reviewed the licensee's program for technician training and retraining.
The program is detailed in Administrative Procedures A-103. 10, Radiation Protection Technician Training and Responsibility Limits, and A-103. 11, Chemistry Technician Responsibilities and Training, and applicable procedures of the Nuclear Training Manual.
The initial training program consists of formal classroom training in both fundamen-tal subjects and procedures, and on-the-job training in procedures for procedural qualificatio i
The licensee maintains core curriculum committees for bo'th Radiation Protection Technician and Chemistry Technician training programs.
The committees consist of both onsite and offsite (corporate)
individuals with knowledge and experience in the appropriate specific area.
For example, the chemistry core curriculum committee consists of individuals from both the site chemistry organization and the Research and Sciences Department.
The technician retraining program consists of classroom presentations, independent reading, and section meetings.
The licensee has committed to 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year of Radiation Protection'echnician classroom re-training and 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year of Chemistry Technician classroom re-training.
5.4 ualit Assurance and uality Control The inspector reviewed gA audits of the chemistry program as well as gC surveillance activities.
gA audits of the chemistry activities are per-formed by the corporate guality Assurance Department.
Chemistry activi-ties are scheduled o be audited three times per year.
The inspector reviewed audits for 1986, 1987, and 1988 to date.
The inspector noted that these audits were conducted by an auditor using a detailed check list and appeared to be of sufficient thoroughness and scope to ade-quately assess program performance in the areas being reviewed.
In ad-dition, both in-house and contracted personnel, with technical experience in the areas being audited, were part of selected audit teams in order to provide a further assessment of performance.
Audit findings appeared to be of excellent technical depth, and responses to findings are re-quired within a specified period of time.
In reviewing the gC surveillance activities of the Chemistry area, the inspector noted that the only chemistry activities in routine survei 1-lance activities was a surveillance of laboratory measuring and test equipment.
This surveillance as performed, however, selects, at random, instruments from an inventory list maintained for both chemistry and health physics radiation measuring instruments, including survey instru-ments.
The inspector noted that this list contained over 330 items of which the gamma spectrometer was one.
The inspector discussed with the licensee the fact that the gamma spectrometer was used routinely for both inplant and effluent Technical Specification analyses.
The licensee stated thai it appeared that some instruments on the inventory list were of greater significance than others with respect to surveillance activi-ties; on the surveillance procedure would be modified to specifically include the gamma spectrometer.
The inspector further noted that no other chemistry activities were in-cluded in routine (}C surveillances.
Discussions with licensee gC per-sonnel indicated that they were aware of this fact.
Licensee personnel stated that plans to expand the gC staff were underway, and this would include individuals for'gC surveillance activities in the chemistry area".
'4
c
. ~
e
'L,
~
~
A
5.5 Facilities and E ui ment 5.6 The licensee's laboratory facilities consist of a central core of rooms used for a counting room, a controlled area laboratory for primary system chemistry, a nonradioactive laboratory for secondary chemistry, and of-fice space.
Each laboratory contains one fume hood.
Although somewhat crowded, the laboratories appear to be well maintained.
Laboratory sup-plies such as reagents, chemicals, and glassware were in adequate supply.
In addition to standard laboratory instrumentation and state of the art analytical instrumentation including a computer based gamma spectrometry system and two ion chromatographs.
This instrumentation, along with that necessary for the secondary chemistry data trending system, is a clear indication of man"gement support for the chemistry program.
Conclusions The licensee has in place a good chemistry program.
Management commit-ment to and support for the program are evident by the allocation of both capital and personnel resources to this area.
Management and staff at-titudes are good with respect to maintaining chemistry specifications in plant systems in accordance with current industry guidelines.
Staff-ing is adequate with additional staffing planned to support future planned accomplishments.
Organizational interfaces, including corporate oversight and review of chemistry results and initiatives, is good.
gA audit results, such as in the area of laboratory gA/gC, are used to recognize program deficiencies and implement corrective action.
A noted strength of the licensee's chemistry program is the control of steam generator chemistry.
Specifically, this includes items such as the Steam Generator Reliability Committee, the. installation of the cata-lytic oxygen removal system, and the secondary plant data trending system.
An identified weakness was the lack of gC surveillance activities in the chemistry area.
6.0 Corrective Action Process and Pro rams
~Sco e
The team reviewed the licensee programs currently in place at Ginna Sta-tion associated with the implementation of corrective action to address identified problem areas and observed findings.
Samples'ere selected from several programmatic areas where problem identification and imple-mentation of corrective action is performed.
Each of these program areas is discussed in a subparagraph below.
The team members interviewed lic-ensee personnel responsible for management and implementation of the corrective action program areas and reviewed corrective action program documentatio S
)
-~
For the evaluated areas, the team sought to determine the effectiveness of he corrective resolution, review for generic applicability and ap-plication of long term corrective actions to preclude recurrence.
Ex-amples are cited in the following subparagraphs not only to identify the scope of team inspection activities,'but to support the conclusions re-garding the effectiveness of the corrective action program.
6.2 Corrective Action Re orts CARs The team reviewed the resolution of significant conditions adverse to quality resolved on Corrective Action Reports (CARs) generated in accord-ance with administrative procedure A-1601.
The CAR system is utilized to track issues identified on Licensee Event Reports; NRC identified violations; major design deficiencies; applicable INPO SOERs; and other significant issues.
CAR 1851 documented two steam generator tubes that were improperly plugged.
An extensive evaluation was performed on the, human error that occurred.
The inspector reviewed several Human Performance Evaluation System re-ports on other operational errors and found the reports to contain mean-ingful insights.
The ability to perform such an evaluation is a strength of the site organization.
The CARs are reviewed in a multi-disciplinary meeting to ascertain the cause and proposed corrective action plan.
The review of the situation by personnel with diverse expertise will yield a higher probability of determining the appropriate corrective actions required.
The PORC re-views all CARs to assure proper root cause determination and ultimate resolution of all problems.
The CAR group is composed of two individuals that have lead responsibil-ity for handling the CAR program.
An open CAR listing is utilized to track all open CAR action plan items.
A prioritization scheme is em-ployed to identify the ten most safety significant CARs for upper man-agement attention.
The ten CARs are discussed by the QA/QC subcommittee on a continuing basis.
The CARs are factored into the budget process so resources can be scheduled to complete the necessary corrective ac-tions.
A case of inadequate corrective action was noted in review of CARs 1768 and 1576.
A mispositioned alarm button had served to inactivate portions of the fire suppression and detection systems.
It is apparent that a
hardwar e modification to add an indicating light in the control room for system operability would have precluded the second event.
A CAR trend summary report is generated on a monthly basis.
Only five root cause codes are presented.
Without further discrimination of the root cause, upper management cannot gain an understanding of where the real problem areas exist which require attention.
A more refined root cause code routine has been developed, but not yet implemented.
The CAR
i
tracking system appears to be one of the few management tracking systems that captures important outstanding actions and associated completion dates so work can be prioritized by licensee organizations.
The review of CARs yielded information that corrective action implemen-tation has slipped in some instances.
For example, CAR 1397 was origi-nated on August 3, 1982 related to the Safety Injection (SI)
pump bearing temperature limitations.
Engineering Work Request (EWR) 3881 was issued to modify the SI pump recirculation line by the 1985 outage.
This date was slipped from 1986 ultimately to the 1989 outage due to licensee engi-neering manpower limitations.
CAR 1579 was issued in September 26, 1984 related to failures of Westinghouse normally energized BFD relays which was originally disseminated by NRC Bulletin 79-25.
A slow replacement program was instituted and a plant 'trip occurred in July 1986 when an intermediate range high flux trip BFD blocking relay failed to energize.
6.3 Audit Re orts The
.earn reviewed several QA aud':t reports and performed a sample review of Audit Finding Correctiv Action Reports (AFCARs).
The audits are performed by the corporate QA organization of both station and engineer-ing activities.
Special audits including the Safety System Functional Inspection (SSFI)
and the last biannual management audit were also re-viewed.
Additionally, the July 15, 1988 bimonthly audit corrective ac-tion status report was reviewed.
The total quantity of open AFCARs has increased from under 30 one year ago to approximately 50 currently.
The licensee's ability to meet Task Completion Due (TCD) dates in June was not so good in that 5 of 7 com-mitment completions were not met.
Discussions with plant personnel in-dicated higher priority work had displaced the implementation of the planned corrective actions.
Since June, the commitments have not been followed up actively by QA nor have the audited organizations requested a
TCD extension.
The audit program has recently been strengthened by a new approach to utilize outside experts to augment the audit teams.
The feedback from audited organizations indicated this initiative was positively received.
In several cases, audits have been requested by line management, such as the DC system design review and DC fuse configuration verification audits.
This's indicative of an increased confidence level in the audit team capabilities.
The recent performance based audit (88-14:JB) of the operations area was found thorough and contained cogent observations.
The audit reports from the 1986 biannual management audit were reviewed.
The audit scope included the following areas:
the Nuclear Safety Audit and Review Board (NSARB),
QA/QC subcommittee and employee attitudes to-ward the QA program.
The QA/QC subcommittee is composed of five licensee employees at the vice president level.
The audit found the subcommittee
'
g
~
Cl
31'as effectively implementing responsibilities.
The attitude assessment found a dichotomy in that engineering expressed a positive outlook QA played in achieving safety improvements.
Station personnel felt no need for the QA program and stated the QA program does not assist with meeting objectives.
A follow-up audit for the attitude assessment is scheduled for late 1988.
The team reviewed the recent Safety System Functional Inspection (SSFI)
performed by the licensee for the Auxiliary Feedwater (AFW) system.
The SSFI efforts appeared to focus on the areas of operations, maintenance, design change control and the quality assurance program.
However, the depth of the SSFI design review could not be ascertained from the avail-able report.
This was due to the process of deleting some preliminary SSFI findings from the final report, without documenting supporting bases for those decisions, and was considered by the Team to be a poor practice.
However, with the exception of that weakness and the specific omissions described in Detail 4.3 for the CST, the Team concluded that the SSFI was a positive initiative which had resulted in a number of improvements to continued reliability of the AFW system.
6.4 Nonconformance Re orts The team reviewed the NCR program governed by Section 15 of the Quality Assurance Manual and Administrative procedure A-1502.
The NCR program addresses the identification of nonconforming items, the disposition for the deficiency and the disposition implementation of ultimate closeout.
The review included a
sample of currently open NCRs, closed NCRs, the last NCR quarterly trend report and the most recent NCR monthly status report.
The engineering disposition for NCRs G-88-091 and G-86-059 were reviewed.
In the first case, the non-IE Agastat relay was specified to be replaced within six months with a fully qualified relay.
The second example in-volved the replacement of supertanium fasteners on the 1A charging pump power feed with silicon bronze fasteners within one year.
In both cases, the elapsed time to implement the component replacement has exceeded the original engineering time limit.
The replacement due date was not tracked by either quality control or the maintenance organizations.
The review of NCR G-88-018 identified that a steam generator rigid strut mounting plate shim was to be reduced from 1 3/4 inches to 3/4 inches.
The new shim has been procured for future,installation when the replace-ment struts are installed.
-The inspector was informed that the appro-priate design drawings were revised accordingly.
The engineering organi-zation was asked to identify the formal mechanism which insures the necessary engineering document revisions are implemented.
No system appears to be in place beyond informal tracking by the cognizant respon-sible engineer.
Engineering personnel indicated an administrative change would be made to control this situatio I
6.5 The last quarterly NCR trend report was reviewed.
The report identified the average working days required to close an NCR has increased from seven days in 1985 to eighty days in 1987.
This implies that questions regarding plant components are not resolved in a timely a manner.
The licensee discussed the possible effect of receiving inspection NCRs and the methodology utilized to generate the report which may skew the'ime-liness results'o clarifying explanations were provided with the sum-mary report and the effects were not readily quantifiable, After the concern was raised with respect to the excessively long NCR closure time, the site QC group prepared a special analysis on the NCR closure data for the first quarter of 1988.
The average closure time was 15 days for
'he 182 NCRs reviewed.
Corporate QA used a different method to determine NCRs were closed in an average of four days.
The overall trend is en-couragingg and is indicative of closer management, controls over the NCR system.
The quantity of open NCRs has increased from 72 to 95 over the past year.
The inspector inquired whether.a summary report was available which delineated operating plant components with outstanding problems to be resolved.
The monthly NCR status report was not found to effi-ciently provide the requested information.
ualit Control Re orts In accordance with Administrative procedure A-1001, surveillance, in-spection and document review activities can be documented on a Quality Control Report (QCR).
The inspector reviewed several closed Quality Control Reports (QCRs) that documented the identification of an unsatis-factory item.
Code B is assigned to each QCR which identified an item of concern.
The QCRs are disseminated to the appropriate managers for corrective action.
The QCRs do not identify the corrective action taken.
Approximately 1100 QCRs have been issued in 1988.
Audit report 88-04:DH was reviewed which issued an AFCAR regarding the lack of corrective ac-tion documentation for QCRs.
A commitment had been made by QC management that by mid-June a review would be done of all code B QCRs and the manner of processing QCRs would be enhanced..
Those actions have not been im-plemented to date.
QC management indicated further action would be taken on this issue prior to the October NSARB meeting.
During the inspection, the Team identified numerous problems with respect to the Auxiliary Building housekeeping and cleanliness in general.
The inspector reviewed QCRs and ascertained that QC has identified recurring problems with housekeeping, boric acid leaks and RHR system leaks in the Auxiliary Building.
These problems were apparently rectified on a case-by-case basis with no effective management action taken to preclude re-currence.
6.6 ualit Initiatives and Miscellaneous Issues The Team identified that the licensee has recently instituted numerous initiatives to enhance the overall nuclear quality program.
Some of these include: Q-list development; PAID upgrade; electrical drawing
'4
~ i~
upgrade; configuration management program implementation; station proce-dure upgrades; conduct of performance based auditing; consolidated QA and QC initiation of QC operations surveillance; and review of procedural adherence status.
While the scope and intent of these programs appear to be satisfactory, the effectiveness cannot be judged at this point in time since the actions are in-process'n some cases, such as the development of the Q-list, the action appears to have been implemented in an untimely manner.
The station has previ-ously identified the need for a definitive Q-list in early 1986, a re-quest for 1987 funds was made and was not approved based upon a rela-tively low priority assignment by corporate management.
An INPO audit in early 1988 reiterated the need for the Q-list.
The funds were even-tually authorized for 1988 and 1989.
During the course of this inspec-tion, another component was mistakenly classified as non-Q and further serves to amplify the need for the Q-list.
Recently, the capital authorization included funding for several of the quality initiatives identified above.
Of concern is the fact that total licensee revenue will remain constant over the next two years.
If major problems develop or the need for additional quality improvements is identified, senior management will have to carefully analyze unforeseen situations and reallocate resources as necessary.
Some quality initi-atives are also dependent upon increased staff levels to perform the work scope.
There are indications open positions are very difficult to fill which may hamper the implementation of the quality initiatives.
A recurring problem has been recognized by the licensee with respect to procedural adherence.
A tentative action plan has been assembled which includes augmented employer training; review of the procedure change process; establishment of a management policy on procedural adherence,
. and conduct of an employee survey.
A licensed SRO has recently been added to the QC staff.
This individual is charged with the responsibility to develop a viable QC staff to per-form a surveillance role for the operations area.
The QC staff will develop new inspection procedures and receive operator training as re-quired.
This will serve to provide enhanced QC oversight of an important area where only minimal surveillance coverage has been performed to date.
Nuclear Quality objectives are currently under development.
The draft objectives were found to capture important qualitative aspects to use as a basis for assessing personnel performance.
The QA and QC reports to management appear to present information in a piecemeal manner and often cannot be easily interpreted to yield meaning-ful insights.
In particular, summary and trend reports could benefit
~ I~
i
from increased analysis and inclusion of recommended actions to be taken.
The intended approach of Nuclear Assurance is to issue more informative reports so management action can be properly developed.
6.7 Ins ection Follow-up Issues During the conduct of this inspection of the licensee's corrective action programs certain questions, not specifically related to the corrective action process, were raised by the Team, addressed by the licensee and handled as follows:
( 1)
Examination of the A diesel generator identified several instrument tubing runs, associated with the lube oil and fuel oil differential pressure instruments, were taped together and had a channel section taped to the tubing.
The tape had apparently been applied to miti-gate vibration of the tubing.
NCRs88-374 and 88-375 were issued to disposition this concern on the A and B diesel, respectively.
(2)
Examination of the relay room identified an electrical cable im-properly supported from a cable tray.
The licensee investigated the situation and generated trouble report 88-6098.
The cable was determined as a spare and will be scheduled for removal.
(3)
The inspector was present in the control room on July 19 when an Unusual Event was declared due to an electrical equipment failure causing the plant perimeter lighting to be lost.
Appropriate noti-fications were made by the licensee and compensatory measures es-tablished.
(4)
The B battery cells and racks were examined in conjunction with a review of drawing 33013-1120 and the design analysis for EWR 2831.'he adequacy of a bolted connection was questioned on the seismic guide stop assembly.
The cognizant engineering group reanalyzed the connection (EWR 2831, revision 2) and specified a revised fast-ener assembly to ensure proper restraint of the battery cells during a seismic event.
6.8 Conclusions Based upon the areas inspected, examples raised and conclusions formu-lated in the above paragraphs, the following represent strengths and weaknesses associated with the application of the corrective action pro-grams and processes at Ginna station::
Further examples were identified of a lack of questioning attitude by station personnel regarding improperly supported diesel generator instrument tubing runs that were taped together and the existence of a spare cable routed through the relay room.
Both installations have existed for an extensive period of tim ~ sM
a e
~
C~
Some NCR disposition completion dates have not been adhered to in-cluding the replacement of Safety Injection pump power feed termin-ation hardware and replacement of non-IE Agastat relays.
The CAR program is currently coordinated in an effective manner to manage the outstanding issues addressed by open CARs.
Some past corrective actions, such as replacement of Westinghouse BFD relays, were not accomplished in a timely manner.
This concern includes the deferral of a g list development which has contributed to further plant difficulties.
It is a strength that gC has identified numerous instances of house-keeping problems within the Auxiliary Building; however, management has resolved these on a case-by-case basis with no effective long term corrective action.
The philosophy of performance based auditing was effectively demon-strated in a recent audit of operations.
The use of specialists to augment the normal audit team has led to enhanced audit capabili-ties.
Since several quality initiatives, including g-list development, con-figuration management and PE ID upgrades, are in the initial phases of implementation.
The effectiveness of those efforts cannot be assessed at this time.
Upper management will need to closely monitor available resources with respect to the requirements of completing routine work, implementing quality initiatives and correcting newly identified problems.
7.0 Flow of Technical Information Following the TMI-2 accident, all licensed operating plants were to have pro-cedures for feedback of operating experience to plant staffs.
These procedures were to assure that operating information, important to safety, originating both within and outside the licensed organization is continually provided to operations and other personnel.
Included in the flow of information is that such information be incorporated in the training program.
The operating ex-perience assessment function should involve licensee personnel having collec-tive competence in all areas important to safety.
Sources of information come from its own plant operating experience; publications from the NRC and indus-try; industrial assessments, etc.
The total volume is large; consequently, discretion must be used in the dissemination of information to insure prompt action is taken on safety matters.
It is important to minimize the deluge of extraneous information and to achieve a high degree of efficiency by pre-venting the dissemination of premature, contradictory information to the staff.
The Team reviewed the licensee's process and basic procedures for the control of technical information.
Interviews were conducted with key representatives of the licensee's staff that are involved in the assessment of technical in-formatio n s ~A
C v
cubiM c
7.1 Feedback of Operatina Exoerience The review was carried out by determining whether or not procedures were formulated and conducted in accordance with the guideline established in NUREG-0737, I.C.S.
Comments are provided below in accordance with the requirements in NUREG-0737:
7.1.1 Within the RG&E organizational structure, the Chief Engineer and general manager (GM) for Nuclear Production share the re-view responsibilities for safety matters originating fro'm out-side sources or internal events that may require action.
Each organization has developed its own independent recording and tracking system.
Informal discussions and communication serve as the means for eliminating duplication of efforts and develop-ing action plans, if required.
Closure of an item is main-tained within each organization.
Issues that require correc-tive actions and involve expenditure of significant company resources are placed on a Corrective Action Report which be-comes the controlling document.
Each organization has de-
=
veloped procedures for carrying out assigned responsibilities for the control of technical information.
Under the GM for Nuclear Production, the Superintendent of Ginna station has several procedures which deal with the control and dissemina-tion of information within the organization.
Procedure A-1404, describes the handling of all incoming correspondence.
Within the auspices of the Chief Engineer, the Nuclear Engi-neering Services issues Engineering Work Requests for the re-view of correspondence, both internal'and external.
These items are
.racked on a computer and Nuclear Engineering Ser-vices is provided with a record on the disposition of issues.
Informal discussion serves as a means for coordinating the actions taken on the recorded item among the other divisions of RG&E.
7.1.2 Under Procedure A-1404, Operational Assessment Program, all outside correspondence is administratively recorded and screened for applicability to Ginna.
If applicable to Ginna the material is distributed for further evaluation.
Relevant information is assigned to a person or organization for action.
The operational assessment staff tracks the issues to insure closure of all items processed under A-1404.
Except for the initial screening review, their remaining duties on the item is to administratively track the item to closure.
Procedure A-1601, Corrective Action Report provides the re-quirements'o assure that significant conditions adverse to quality are promptly identified, corrected, their apparent course determined and an action plan developed to prevent re-currence.
Conditions adverse to quality may be failures, mal-function, deficiencies (procedural or material) deviations,
~ ~
and repetitive nonconformances.
This procedure provides de-tailed instructions for converting an issue that requires cor-rective measures into plant actions.
There are seven major sections to the procedure with attachments related to the type of reports that may be processed within the organization.
Also, there is a reporting section that calls for summary reports for distribution to senior management levels of the organiza-tion.
There is also a Trend Report prepared each month related to CARS which trends the activities over the previous 16 months.
Procedure A-25', Ginna Station Event Report is a subset of A-25, Report of Unusual Plant Conditions.
The procedure pro-vides a set of instructions for an individual who observes or is aware of an event that may need to be reported to the NRC or higher supervision within the RG5E organization.
Procedure A-601, Procedure Control, provides the instruction for process-ing a request for new procedures; temporary changes, ot permit changes to existing procedures.
Both organizations under the Chief Engineer and GH for Nuclear Production initially receive all correspondence at a central location within its own organization.
Distribution of internal and external correspondence is made to their respective re-cipient based upon the categories of information received.
The initial screening process attempts to promptly place the information in the hands of personnel that could be involved in a potential action or, as a minimum, have an interest in the subject matter since it is related to their job functions.
Formal distribution systems are established for correspondence that require action by the RGKE organization.
Initial screen-ing attempts are made to minimize the routine distribution of extraneous and unimportant information to staff members.
Each organization controls the flow of information to its own mem-bers.
The independence on the control system for information may lead to overlapping of submittals of information to peri-pheral organizations.
Informal discussions are utilized by RGRE as a method for minimizing this potential problem.
The initial screening process and its effectiveness is a key factor in assuring that conflicting or contradictory information is not conveyed to operators or other personnel until a resolution is reached.
Within the CAR system each item requiring correc-tive measures takes into consideration the training aspects associated with the implementation of corrective measure.
Once a year, the operational assessment program is audited.
The audit includes procedure compliance file integrity, and program effectiveness.
The audit includes comments from per-sonnel outside the operational assessment group.
Auditing of
the effectiveness of the overall feedback system for operating experiences is not performed.
The lack of this type of in-spection is considered a serious weakness in the system.
Following the TMI-2 accident of March 1980, all newly-licensed plants are required to establish an onsite independent safety engineering group to perform independent reviews of plant operations.
Nuclear plants licensed prior to this date (such as Ginna) were not requested to have such a group.
Neverthe-less, the reviews of plant operations, not a replacement for PORC or gA, may indicate areas for improving plant safety.
Internal independent reviews of a broad nature, which are usu-ally provided by staff, can therefore contribute to the licen-see's five-year goals.
7.2 Licensee Initiatives and Res onses to Incomin Corres ondence (a)
Corrective Action Re ort Item CAR-1805 Routine 90-day testing of diesel fuel oil was determined, based on initial sample, not to be within Technical Spec',fication viscosity requirements.
Immediate actions were required in order to prevent plant shutdown.
The event was reviewed in the context of procedure A-1601, Corrective Action Report.
As prescribed in the procedures the necessary steps for corrective measures were followed.
Responsi-bilities were designated and the appropriate organization partici-pated in the review.
Training responses were formulated and carried out.
A root cause investigation was made and a
summary report was written as part of the closeout procedure.
(b)
NRC Bul 1etin 88-09 Thimble Tube Thinnin 7/22/88 Operational assessment staff recorded the Bulletin and dispatched copies to appropriate members of the staff.
Within two weeks a
decision was made to establish CAR 1885.
Target dates were estab-lished consistent with the guidance of NRC Bulletin.
An inspection program must be in-place prior to the next fuel outage (March 1989).
A meeting was scheduled shortly after the CAR issuance in order to determine what needed to be done to establish and execute a program.
Assignments and interim target dates have been formulated to achieve ultimate goals for having workable inspection procedures in-place for the outage.
(c)
NRC Information Notice 88-46 Defe'ctive Refurbished Circuit Breakers Preliminary information on the Notice was provided by NRC staff re-lated to a licensee report on defective refurbi shed circuit breakers.
RG&E took the initiative to immediately investigate the impact on Ginna.
Prompt review showed that the questionable circuit breakers
were not incorporated into safety related systems; consequently no CAR was issued.
Investigation is still open pending further results.
Operational assessment system shows item is open, but with appro-priate tracking and control.
(d)
NRC Information Notice 86-72 Failure 17-7 PH Stainless Steel S rin s (e)
The notice was received, documented and assigned to an individual for action.
Prompt review concluded that the issue constituted a
Nonconformance item; consequently the resolution of this followed the RG&E procedures of NCRs.
This item is being controlled and administered in a manner prescribed by procedure.
NRC Generic Letter 88-14 Instrument Air Su
S stem Problems Affectin Safet -Related E ui ment Upon receipt the item was logged in by the operational assessment staff and copies di stributed to interested parties.
A decision was made to follow the issue under CAR.
This required that a meeting take place to initiate a cause investigation under the CAR, as well as the reviews of other pertinent information.
Standard operating procedures are being applied to this Generic Letter.
INPO OE 2771 Failure of Reactor Protection Flux Tilt Controller INPO advised RGKE of a Foxboro controller failure at Prairie Island that may have generic implications.
The operational assessment branch assigned review to maintenance to respond to inquiry.
Re-sponse data was set at 3 weeks from date of receipt.
Copies of material provided to other interested parties.
Response was re-ceived from Maintenance on time within the course of action that would be taken to assure concerns are addressed.
(g)
INPO OE 2777 Feedwater Control System Failure INPO advised RGEE of a failure at Clinton on a
GP Type Agastat Relay.
Response was provided within 5 days that the Ginna station does not have the type of relay in service or in stock, and the issue was closed by the Operational Assessment staff.
(h)
INPO OE 2812 RHR Pum Cavitation INPO advised RGEE that D.
C.
Cook, with fuel removed from the vessel and the upper internals installed, the reactor cavity was being drained when the RHR pump began cavitating with the water level
feet above the reactor vessel.
The investigation was assigned the responsibility for the investigation and to complete the review within 4 weeks.
Response was received by Operational Assessment within 3 weeks that procedures are revised to incorporate suggested preventive action to assure that this incident would no occur at
C'I
(a t
Ginna.
The control documentation followed established procedures to assure timely closure of the INPO report and appropriate copies were provided to all RG&E personnel having a need for such informa-tion.
7.3 Conclusions Two organizations have dual responsibilities for the feedback of tech-nical information throughout RG&E.
Each organization has several proce-dural documents and independent tracking systems to insure that its own responsibilities are carried out in a manner perceived by them to be appropriate and timely.
For each item, one organization is assigned the prime responsibility for resolution and a single person is designated as the coordinator.
In large measure, the effectiveness of the flow of technical information is dependent on the ability of the designated person to establish good informal communication among the many individuals that may be needed to resolve an issue.
Until an issue is judged to require a corrective ac-tion, the flow of information is carried out in an unstructured manner.
It is difficult to ascertain whether or not priorities are established and controlled for issues at this level by senior management.
There is, however, a priority code for nuclear-related activities that embraces expenditure items which should cover most issues.
Regulatory commitments, (Federal, State and local), are automatically established as a priority.
However, there is no formal or established requirement to audit the over-all effectiveness of the information feedback system, and this is con-sidered to be a weakness.
Also, the current systems and procedures are geared to handle near-term situations for plant operations.
Discussions with RG&E management indicate that a corporate tracking system is being examined.
In summary, the current formal and informal systems and procedures are adequate for handling regulatory matters and industry-sponsored issues that need resolution for the near term.
Nevertheless; the ever increas-ing volume of information and feedback requirements, coupled with newly planned initiatives, may seriously impact the proficiency of current operation to effectively feedback operating experience.
8.0 Mana ement Meetin s
Regular meetings were held with senior station management throughout the course of the inspection to clarify and discuss findings and concerns.
An exit meeting was conducted on September 22, 1988.
Attendance at the exit is annotated on Attachment I, Principals Contacted.
Preliminary findings, strengths and weaknesses, and conclusions (as outlined in Detail 1.2, Summary)
were presented at the exi ~ ~
ATTACHMENT 1 PRINCIPALS CONTACTED t~AME COMPANY TITLE
- Charles R. Anderson James C. Bodine
"Duane L. Fi lkins
"Dennis R. Gent
"John Hotchkiss Roger W.
Kober George Linle Richard Marchionda
"Thomas A. Marlow Robert C. Mecredy
- Gary D. Meier Thomas A. Meyer Richard Morrell
"Linda L. Phillips
"Terry R. Schuler Robert E. Smith Bruce A. Snow
- Stanley M. Spector John St. Martin
- Joseph A. Widay Paul Wi lkens
~Robert E Wood George Wrobel RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E RG&E Manager, Quality Assurance Nuclear Assurance Manager Manager, Health Physics and Chemistry Results and Test Supervisor Modification Project Manager Senior Vice President, Production and Manager, Electrical Engineering Ginna Training Manager Maintenance Manager General Manager, Nuclear Production Division Training Manager Director, QA/QC Operational Assessment Manager, Divisional Services Operations Manager Vice President, Production and Engineering Chief Engineer Superintendent, Ginna Station Corrective Action Coordinator Technical Manager Director, Nuclear Engineering Services Supervisor, Nuclear Security Manager, Nuclear Safety and Licensing Engineering
- Present at Exit Meeting
( I~
a 8