IR 05000244/1990002
| ML17261B003 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/07/1990 |
| From: | Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261B000 | List: |
| References | |
| 50-244-90-02, 50-244-90-2, NUDOCS 9003160304 | |
| Download: ML17261B003 (21) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
INSPECTION REPORT 50-244/90-02 License No.
Licensee; OPR-18 Rochester Gas and Electric Corporation 49 East Avenue Rochester, New York Facility:
Dates:
Inspectors:
Approved by:
R.
E. Ginna Nuclear Power Plant January 9 through February 20, 1990 C.
S. Marschall, Senior Resident Inspector, Ginna N.
S. Perry, Resident Inspector, Ginna H. I. Gregg, Senior Reactor Inspector, Region I, ORS E.
C.
McCabe, Chief, Reactor Projects Section 3B el v/90 Date
~Summa r
~Sco e:
Routine inspection of operating activities, radiological controls, maintenance, surveillance, security, and periodic and special reports.
There were 186 hours0.00215 days <br />0.0517 hours <br />3.075397e-4 weeks <br />7.0773e-5 months <br /> of inspection, including 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of backshift inspection and
hours of deep backshift inspection.
~Findin s:
Overall, the plant operated safely.
A violation of 10 CFR 50 Appen-dix B and the Ginna guality Assurance Manual was identified involving failure to promptly correct inadequate check valve position verifications (see Detail 3.d).
Ten open items were closed, one unresolved item was opened to collec-tively address previ ous open items on procedure adherence ( see Detail 4).
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TABLE OF CONTENTS PAGE 1.
Persons Contacted.....
2.
Summary of Operations.
3.
Functional or Program Areas Inspected................................
a.
b.
C.
d.
e.f.
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h.l.
Plant Operations (71707).....
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Engineering Safety Feature System Walkdown Radiological Controls (71707)............
Maintenance (62703).
Surveil lance (61726)
Security (71707)....
Licensee Sel f-Assessment Capability (40500)
Periodic and Special Reports (90713).......
Written Reports of Nonroutine Events (90712 (70710)
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4.
Follow-up on Previously Identified Items (92701, 92702)..............
4. 1 Fission Oetector Control and Accounting....
4.2 In-Service Testing.
4.3 Procedure Step Not Performed......
4.4 Check Valve Position Indication........
4.5 Procedure Adherence....
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5.
Exit Interview (30703).....
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DETAILS 1.
Persons Contacted During this inspection, the inspectors held discussions with various lic-ensee personnel, including plant operators, maintenance technicians and the licensee's management staff.
2.
Summar of Plant 0 erations At the beginning of the inspection, the plant was at full power.
On January 14, 1990, power was reduced to approximately 48K in order to iden-tify and plug leaking main condenser tubes.
Seven tubes were plugged and the plant was returned to full power early the 'following day.
The plant remained at full power for the rest of the inspection.
3.
Functional or Pro ram Areas Ins ected Plant 0 erations (71707)
Control room staffing was adequate and operators exercised control over access to the control room.
Operators adhered to approved pro-cedures and understood the reasons for lighted annunciators.
The inspectors reviewed control room log books to obtain information con-cerning trends and activities, and observed recorder traces for ab-normalities.
Shift turnovers were found adequate to address neces-sary information.
The inspectors verified correct alignment of selected engineered safety feature valves and breakers, and portions of the containment isolation lineup.
All accessible areas of the plant were toured and plant conditions and activities in progress were observed by the inspectors with no inadequacies identified.
The inspectors reviewed compliance with the technical specifications and audited selected safety-related tagouts.
Among the-operations documents reviewed were:
Ginna Station Event Report (A-25. 1) Number 90-1, steam generator blowdown flow instrumentation.
Ginna Station Event Report (A-25. 1) Number 90-3, repairs on service water piping.
Ginna Station Event Report (A-25. 1) Number 90-4, calibration of the chlorine analyzer.
Ginna Station Event Report (A-25. 1) Number 90-5, calibration of the ammonia analyzer.
Ginna Station Event Report (A-25. 1) Number 90-6, converter YM-110.
Ginna Station Event Report (A-25. 1) Number 90-7, service water return line from a standby auxilia
'ine room cooling unit.
concerning concerning weld concerning concerning concerning flow concerning the ry feedwater
Ginna Station Event Report (A-25. 1) Number 90-8, concerning a
heat trace alarm.
Ginna Station Event Report (A-25. 1) Number 90-12, concerning the fire protection system satellite station B.
Inspectors reviewed each of the above A-25. 1 reports to insure the plant personnel took appropriate corrective action and observed the appropriate Limiting Conditions of Operation.
No inadequacies were identified.
The inspectors concluded that the operational activities observed were conducted safely and in conformance with NRC require-ments.
b.
En ineered Safet Feature S stem Walkdown (71710)
The inspectors performed a complete walkdown of the accessible por-tions of the standby auxiliary feedwater system.
The inspectors con-firmed that the lineup procedures matched the P&IDs (piping and in-strument drawings)
and the as-built configuration.
The following procedures were reviewed:
System Operating Procedure (S)-30.5,
"Standby Auxiliary Feed-water Pump, Valve and Breaker Position Verification," Revision 27, effective December 29, 1989 Operating Procedure (0)-6. 13, "Daily Surveillance Log," Revision 55, effective December 29, 1989 C.
The following P&IDs were reviewed:
33013-1238, Standby Auxiliary Feedwater, Revision
33013-1250, Station Service Cooling Water, Revision
Several valves were found inadequately labelled on the P&ID.
There is no safety significance associated with the inadequate labelling since these valves are root valves for local indication only and are normally closed.
The discrepancies were provided to plant personnel.
No conditions which might degrade plant performance were identified.
Radiolo ical Controls (71707)
The resident inspectors periodically verified that radiation work permits (RWPs) were effectively implemented, that dosimetry was cor-rectly worn in controlled areas, that dosimeter readings were accu-rately recorded, that access to high radiation areas was adequately controlled, and that postings and labeling were in compliance with procedures and regulation The inspectors verified compliance with the following procedures:
HP-5. 1, Area Radiation Survey, Revision 30, effective October 20, 1988..
HP-5.2, Posting of Radiation Areas and Container Labeling, Re-vision 9, effective December 8, 1987.
A-1. 1, Locked High Radiation Areas, Revision 21, effective December 1,
1988.
No inadequacies were identified, d:
Maintenance (62703)
The inspectors observed portions of various safety-related mainten-ance for operability of redundant components, adherence to limiting conditions for operation, obtaining of required administrative appro-vals and tagouts before initiating work, use of approved procedures or the activity 'being within the "skills of the trade,"
implementa-tion of appropriate radiological controls and ignition/fire preven-tion controls, and proper testing of. equipment prior to returning it to service.
Portions of the following maintenance were observed:
Maintenance procedure (M)- 37.96,
"Valve Packing Gland AdJUst-ment on Manual QA Safety Related Valves," Revision 3-, effective 2-18-89, observed 1-18-90.
Calibration Procedure (CP)- 211, "Calibration and/or Maintenance of Radiation Monitoring System (RMS) channel R-11 (Containment Particulate),"
Revision 12, effective 11-17-89, observed 2-14-90.
The inspectors noted that, in response to a concern identified in NRC inspection report 50-244/89-17, procedure M-37.96 had been changed to insure that components made inoperable for maintenance pass post-maintenance testing before maintenance is performed on redundant com-ponents.
In addition, the procedure had been changed to require re-moval of maintenance identification tags, used to identify the loca-tion of a deficiency, after the deficiency has been corrected.
Maintenance personnel discovered that fittings required to install a
replacement part for RMS channel R-11 were not included by the manu-facturer, and therefore could not complete maintenance of R-11 on 2-14-90.
The inspectors considered the presence of a maintenance
'upervisor to audit the maintenance of R-11 a positive step toward increasing assurance of quality in maintenance activities.
The in-spectors also noted that more thorough preparation for maintenance of R-11 could have uncovered the lack of fittings prior to commence-ment of wor Survei 1 1 ance (61726)
Inspectors observed portions of surveillances to verify proper cali-'ration of test instrumentation, use of approved procedures, perform-ance of work by qualified personnel, conformance to limiting condi-tions for operation, and correct system restoration following test-ing.
Portions of the following survei llances were observed:
Periodic Test (PT)-12. 1, "Emergency Diesel Generator 1A," Revi-sion 50, effective October 20, 1989, observed January 19, 1990.
PT-16Q, "Auxiliary Feedwater System - Quarterly," Revision 0, effective January 25, 1990, observed January 25, 1990.
No inadequacies were identified during performance of the surveil-lance on the 1A emergency diesel generator.
The surveillance on the auxiliary feedwater system was a quarterly surveillance which requires additional testing not normally performed during the monthly surveillance.
Ginna personnel recently separated the original procedure into 2 procedures, one for the normal monthly test and one for the more extensive quarterly test.
Though nearly identical to the original procedure, this procedure was being per-formed'or the first time as a separate quarterly procedure.
The inspectors observed the testing on the "A" motor-driven and tur-bine-driven auxiliary feedwater pumps locally, and the testing on the
"B" motor-driven auxiliary feedwater pump from the main control room.
The inspectors noted oversight by technical support management and a
quality control inspector.
No inadequacies were identified during performance of the surveillance on the "A" and "B" motor-driven auxiliary feedwater pumps.
During performance of the surveillance on the turbine-driven aux-iliaryy feedwater pump, the procedure required that the steam admi s-sion check valves be verified closed by local observation.
The in-spectors noted that personnel performing the test fulfilled this re-quirement by looking up and marking the position of the external operator arm against something in the background.
In December 1989, (see inspection report 50-244/89-17),
the inspectors concluded that this position verification was inadequate, and brought this to the attention of plant management; this was left as an unresolved item.
In May 1988, one of the major findings from a special NRC inspection (see 50-244/88-10),
was that the turbine-driven auxiliary feedwater pump steam admission check valves were omitted from the IST testing program.
One of these valves was subsequently found to be inoper-able.
Since May 1988; Quality Assurance has not conducted an audit to verify implementation of an effective inservice test of the steam admission check valve On January 26, 1990, plant management agreed that the required posi-tion verifications were inadequate to verify that the valves were positively closed.
They committed to verify the full open and ful-1 closed positions by manually stroking the valves using the external operator arm during the quarterly surveillance, until a better indi-cation of valve position is instituted.
The inspectors witnessed the first manual stroke of the check valves on January 26, 1990.
Both valves moved freely from the as-found full closed position to the full open position indicating that they were operable, However, when one of the check valves was stroked using the external operator arm it became evident that the arm could move independently of the valve; the arm was attached to the valve shaft using two locknuts, and was not positively connected to the valve shaft.
Mechanics repositioned the operator arm and tightened the locknuts, and Ginna management concluded that both check valves were operable.
The inspectors ques-tioned whether the external operator arm could be used as a reliable indication of valve position.
The licensee has a proposed system modification which will provide additional valve indication scheduled for completion by September 1,
1990.
Based on monthly observation of partial stroking, disassembly and inspection accomplished during the 1989 refueling outage, and manual exercising on January 26, 1990, Ginna management concluded the valves have been fulfillingtheir design requirements since they were added to the IST program.
The inspectors asked RGhE to provide written justification for check valve operability for 1988 and 1989; this justification had not been received by the end of the inspection period.
CFR 50 Appendix B, Criterion XVI and the Ginna Quality Assurance Manual, Section 16 require prompt correction of conditions adverse to quality.
The inspectors informed Ginna management of the inade-quate verifications of the positions of the steam admission check valves for the turbine-driven auxiliary feedwater pump in December 1989.
On January 25, 1990, the inspectors observed plant personnel inadequately verifying the positions of the steam admission check valves.
This is a violation (50-244/90-02-01).
The valves were disassembled and inspected during the 1989 refueling outage, were partial stroked on a monthly basis, and were manually exercised to verify operability on January 26, 1990.
Therefore, it appears that the valves have been capable of performing their design functions since testing was initiated in 1988.
~Secur1t (71707)
During this inspection period, the resident inspectors verified x-ray machines and metal and explosive detectors were operational, Pro-tected Area (PA) and Vital Area (VA) barriers were well maintained,
access control during security turnover was adequate, personnel were properly badged for unescorted or escorted access, and compensatory measures were implemented when necessary.
No inadequacies were identified.
Licensee Self-Assessment Ca abilit (40500)
The inspectors attended a Nuclear Safety Audit and Review Board (NSARB)
QA/QC Subcommittee meeting on January 24, 1990, and an NSARB on January 30, 1990.
In both meetings, there was a good exchange of information and comments between members.
In one case, the quality of QA/QC and surveillances was questioned due to fewer findings in 1989 as compared to 1988.
The justification given for fewer findings was improved work in the field.
The inspectors noted that this jus-tification was'provided without support and was not further ques-tioned by the NSARB. It was concluded that this was an instance where NSARB questioning could have been more thorough.
Overall, how-ever, all board members actively participated in discussions and re-views performed were in depth.
NSARB members were well qualified and knowledgeable.
Contracted members toured the plant on January 29, 1990 and expressed a desire to become more actively involved in acti-vities, especially subcommittees.
Periodic and S ecial Re orts (90713)
Upon receipt, periodic and special reports submitted by the licensee pursuant to Technical Specifications 6.9. 1 and 6.9.3 were reviewed.
This review included the following considerations:
reports contained information required by the NRC; test results and/or supporting in-formation were consistent with design predictions and performance specifications and reported information was valid.
The following report was reviewed:
Monthly Operating Report for December 1989.
Written Re orts of Nonroutine Events (90712)
Written reports submitted to the NRC were reviewed to determine whether details were clearly reported, causes properly identified and corrective actions appropriate.
The inspectors also determined whether assessment of potential safety consequences had been properly evaluated, generic implications were indicated, events warranted on-site follow-up, reporting requirements of 10 CFR 50.72 were applic-able, and requirements of 10 CFR 73 had been properly met.
The following LER was reviewed (Note: date indicated is event date):
Cl'89-016, (Revision 01),
"Due to a Design Deficiency The Failure of the SI Block/Unblock Switch Could Render Some Automatic Actu-ation Features of Both Trains of SI Inoperable,"
November 17, 1989.
The report met regulatory requirements.
Rochester Gas and Electric (RG&E) concluded that
CFR 21 reporting requirements did not apply to the SI switch design deficiency, since the switch was originally installed in 1969 and
CFR 21.21(a)(2)(ii) states that the effec-tive date of 10 CFR 21 reporting requirements were deferred until January 6,
1978.
RG&E made a voluntary
CFR 21 report, however.
Based on guidance provided by the NRC Office of General Counsel, the inspectors informed Ginna technical support management that the
CFR 21.21 reference to, January 6,
1978, was intended to require submission of reports after that date.
CFR 21 does require a re-port for contemporary discovery of a deficiency predating January 6,
1978, provided the other conditions for reportability are met.
4.
Follow-u on Previousl Identified Items (92701, 92702)
4.1 Fission Detector Control and Accountin (Closed) Violation (50-244/86-20-01):
Failure to establish written material control and accounting procedures for all special nuclear material (SNM) bearing"fission detectors.
In 1987 the licensee im-plemented a procedure, RF-46, Special Nuclear Material Physical In-ventory,"which requires annual inventory of all SNM bearing detec-tors.
The inspectors reviewed procedure RF-46 and the inventories conducted for 1988 and 1989 to verify SNM bearing detectors had been included in the annual inventories.
The inspectors concluded licen-see corrective actions adequately assured control of SNM bearing fis-sion detectors.
4.2 In-Service Testin (Closed) Violation (50-244/88-10-01):
Valve omissions in In-service Testing (IST) program and inadequate testing of check valves.
In response to the violation, the licensee performed an intensive review of all aspects of the IST program, including program implementation and responsibility for control of the program.
As a result of the review, major changes were made and the responsibility for control of the program was transferred from the guality Assurance group to the Engineering Department, Further changes were made in developing and implementing procedure changes and imposing additional testing to adhere to ASME Section XI requirements.
New Program submittals, cur-rently Interim Change H, and relief requests were submitted for valves that cannot be tested during plant operation.
The program and
'elief request submittals are presently being reviewed by NRC head-quarter The licensee has taken corrective actions to disposition each of the specific identified violation issues and has included appropriate check valve, testing in accordance with ASIDE Section XI requirements and generic letter 89-04 guidance.
The licensee has also reviewed all safety-related system valves to assure that appropriate valves are in the program.
The inspectors reviewed each of the licensee's responses to the specific violation issues and verified that the licensee's corrective actions were sati sfactory.
In the case of om'i ssions=of periodic testing of check valves in the IST program (valves 3504B and 3505B, and valves 3992 and 3993), the inspectors verified.that the periodic testing of these valves has been included in the test program.
In the case of those check valves identified as not being full flow stroke exercised (valves 9627 A&B, 862 AKB, 710 AhB, 854 AEB,. and 867 AEB), the inspectors verified that relief requests have been prepared which describe the bases for the relief and the alternate testing or disassembly of representative valves on a rotational basis.
The licensee has improved personnel knowledge of IST through visits to other utilities and exchanging information.
Additional improve-ments were made in performance of independent assessments of 'the pro-gram and in providing more technical. expertise for audits of the IST activities.
This item is closed.
4.3 Procedure Ste Not Performed (Closed)
Unresolved item (50-244/89-16-02):
Procedure step signed as completed but not performed.
The licensee's investigation determined that this was due to misunderstanding of the sign-off requirements.
Inspector review of the results of the licensee investigation identi-fied no inadequacies.
The inspector concluded that no falsification was involved in this case.
4,4 Check Valve Position Indication (Closed)
Unresolved item (50-244/89-17-02):
Adequacy of check valve position indication.
A violation (50-244/90-02-01)
concerning ade-quacy of check valve position indication, opened in Detail l.e of this report, will track RG5E corrective actions; therefore, this item is administratively closed.
4.5 Procedure Adherence (Open) Unresolved item (50-244/90-02-02):
Procedure adherence.
This item is administratively opened to track corrective actions for all open items pertaining to procedure adherence.
The following open, items pertaining to procedure adherence are therefore administra-tively closed:
50-244/88-05-01, 50-244/88-08-02, 50-244/88-16-01, 50-244/88-16-,02, 50-244/89-16-01, and 50-244/89-18-06.
I,
5.
Exit Interview (30703)
The inspectors met with senior plant management periodically and at the end of the inspection period to discuss inspection scope and finding I 0