IR 05000244/1990003

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Insp Rept 50-244/90-03 on 900221-0323.Violations Noted. Major Areas Inspected:Operations,Radiological Controls, Maint/Surveillance,Security,Engineering/Technical Support & Safety Assessment/Quality Verification
ML17261B056
Person / Time
Site: Ginna Constellation icon.png
Issue date: 04/16/1990
From: Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17261B053 List:
References
50-244-90-03, NUDOCS 9004250290
Download: ML17261B056 (80)


Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

Report No:

Licensee:

Faci 1 ity:

Dates:

Inspectors:

Approved by:

50-244/90-03 License No.

DPR-18 Rochester Gas and Electric Corporation (RGIEE)

R.

E. Ginna Nuclear Power Plant February 21 through March 23, 1990 C.

S. Marschall, Senior Resident Inspector, Ginna N.

S. Perry, Resident Inspector, Ginna J.

T. Yerokun, Reactor Engineer, DRS CLe. 0, ~6ggc

~ql oleo E.

C.

McCabe, Chief, Reactor Projects Section 3B Date SCOPE This inspection report documents routine and reactive inspections, during day and backshift hours, of station activities including: operations; radiological controls; maintenance/surveillance; security; engineering/technical support; and safety assessment/quality verification.

FINDINGS Overall, safe facility operation was found.

A concern for the appropriate identification of discrepant conditions for resolution was raised.

(Details

and 3.1)

The inspectors identified one violation of security plan requirements and one unresolved item.

The unresolved item concerns non-safety-significant errors in the Final Safety Analysis Report (FSAR) and Ginna Technical Specifications (TSs).

Additionally, two licensee identified, non-cited violations were noted.

These non-cited violations concern separate problems in the fire protection program.

9004250290 900418 PDR ADOCK 05000244 lg PDC

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EXECUTIVE SUMMARY Plant 0 erations:

During plant shutdown for refueling, a trip occurred on a

source range detector failure with the reactor already subcritical.

Operator responses were timely and appropriate.

Operations supervision was good during and after the trip.

Also, operators were thoroughly knowledgeable concerning plant computer problems.

There were two non-cited licensee-identified fire protection violations.

Radiolo ical Controls:

Housekeeping was good overall, but some clutter was evident.

After accompanying radiation protection personnel on a weekly plant tour, the inspectors concluded that the standards for such tours should be raised and that discrepancies should be documented and communicated to the cognizant manager.

The manager of chemistry and health physics committed to pursue improving such communications.

Maintenance/Surveillance:

Overall, maintenance was well planned and was accom-plished by knowledgeable technicians, and surveillance was thorough and well controlled.

Inspectors observed Residual Heat Removal system surveillance, weekly cleaning of the boric acid storage tank level sensing lines, and turbine overspeed trip testing.

Containment Integrated Leak Rate Testing was reviewed by a regional inspector.

The knowledge of technicians involved in module re-placement and calibration of nuclear instrumentation was very good.

Several discrepancies were found in the calibration procedures and uncontrolled labels were observed in instrument cabinets, The licensee corrected the procedures, and will review the program to upgrade labels.

Discrepancies noted by the NRC were known to the technicians, but it was not clear that the technicians'on-cerns were known to management.

Continued management attention to worker con-cerns appears warranted.

~Securit

An access control violation was identified by the inspectors.

Ginna security managers presented an aggressive program to upgrade security hardware and improve security staffing and organization.

En ineerin and Technical Su ort:

Acceptable Emergency Diesel Generator (EDG)

start logic was found.

A non-safety-significant error in the Updated FSAR and Technical Specifications concerning bypass of non-essential EDG trips is un-resolved.

The inspectors asked RG&E to review the adequacy of the EDG start logic testing performed each cycle.

Safet Assessment/ ualit Verification:

Completed actions from the Ginna Nuclear Concerns List of 1988 show overall success in achieving goals.

For two concerns, substantial progress had been made but the inspectors were unable to ascertain the licensee's basis for judging the items to be complete.

On March 6, RGKE met with NRC Region I to present a comprehensive configuration management program expected to be completed in four years.

That program in-dicates a substantive management commitment to more comprehensive maintenance and engineering suppor ~ Q

~ lp TABLE OF CONTENTS PAGE 1.

Operations (71707).....

1, 1 Control Room Observations.

1.2 Fire Protection....

2 2.

Radiological Control (71707)

3.

Maintenance/Surveillance (62703, 61726, 70323)

3. 1 Maintenance Observations...........,.....,....,.......,.

3.2 Surveillance Observations 3.3 Review of Containment Integrated Leak Rate Test (CILRT).

4.

Security (71707)................

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4.1 Secur ity Improvements Program.........

4.2 Access Control..

4.3 Violation 50-244/89-08-02 (Closed).

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Engineering/Technical Support (37700, 71707).....

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5. 1 Bypass of Nonessential Diesel Generator Trips (TI 87-04)

5.2 Unresolved Item 50-244/89-04-04 (Closed)...

6.

Safety Assessment/Quality Verification (71707, 90713, 92701).

6.1 Evaluation of,Tool Dropped in the Boric Acid Storage Tan 6.2 Inspection of Completed Nuclear Concerns List Actions...

6.3 Periodic and Special Reports..

6.4 NRC -

RGCE Management Meeting.

7.

Administrative.

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10 7. 1 Summary of Facility Activities 7.2 Exit Meeting (30703)............................

7.3 Licensee Responses to NRC Correspondence.........

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DETAILS 1.

Plant 0 erations 1.1 Control Room Observations The inspectors reviewed control room log books to obtain information concerning trends and activities, and observed recorder traces for abnormalities.

The inspectors verified correct alignment of selected engineered safety feature valves and breakers, and portions of the containment isolation lineup.

The inspectors verified, compliance with plant technical specifications and audited selected safety-related tagouts.

All accessible areas of the plant were toured and plant conditions and activities in progress were observed by the in-spectors with no inadequacies identified.

Control room staffing was adequate and operators exercised control over access to the control room.

Operators adhered to approved procedures and understood the reasons for lighted annunciators.

Shift turnovers were adequate to address necessary information.

The inspectors concluded that the R.

E. Ginna Nuclear Power Plant had operated safely and in conformance with license and regulatory requirements.

Among the operations documents reviewed were:

Ginna Station Event Report (A-25. 1) Number 90-09, concerning computer logs out of service.

Ginna Station Event Report (A-25. 1) Number dirty switch contact in Delta T ci rcuitry.

Ginna Station Event Report (A-25.1) Number unlocked high radiation area.

90-10, concerning 90-11, concerning Ginna Station Event Report (A-25. 1) Number 90-13, concerning flow transmitter out of calibration, Ginna Station Event Report (A-25. 1) Number 90-14, concerning flow transmitter out of calibration.

Ginna Station Event Report (A-25. 1) Number 90-15, concerning overflow of recycle evaporator feed tank.

Ginna Station Event Report (A-25. 1) Number 90-16, concerning failed heat trace transformer.

Ginna Station Event Report (A-25. 1) Number 90-17, concerning erroneous fire alar Ginna Station Event Report (A-25. 1) Number 90-18, concerning inadequate fire watch tour.

Ginna Station Event Report (A-25. 1) Number 90-19, concerning incorrect fire watch tour.

Ginna Station Event Report (A-25. 1) Number 90-20, concerning chlorine analyzer out of calibration.

Ginna Station Event Report (A-25. 1) Number 90-21, concerning ammonia analyzer out of calibration.

Ginna Station Event Report (A-25. 1) Number 90-22, concerning burned service water pump.

Ginna Station Event Report (A-25. 1) Number 90-23, concerning broken boric acid cleaning rod.

Ginna Station Event Report (A-25. 1) Number 90-24, concerning computer logs out of service.

Ginna Station Event Report (A-25. 1) Number 90-25, concerning erroneous main control board alarm.

Ginna Station Event Report (A-25. 1) Number 90-26, concerning addition of sulfuric acid to boric acid batch tank.

Ginna Station Event Report (A-25. 1) Number 90-27, concerning source range detector failure.

Each Ginna Station Event Report was reviewed to insure plant person-nel took appropriate corrective action and observed the appropriate Limiting Conditions of Operation.

No inadequacies were identified.

On two occasions during the inspection period, operators experienced difficulty accessing the plant computer when the computer was engaged in another task.

On each occasion, the inspector questioned the operators concerning the log entry; operators were thoroughly knowl-edgeable of the cause of the computer problem and had initiated ac-tion to effect short-term corrective action and long-term resolution.

Computer personnel are exploring the feasibility of a provision which would allow the operators to force accessibility of the computer in an emergency.

During the plant shutdown on March 23, 1990, source range detector N31 failed (after the plant was made subcritical),

causing a reactor trip on high flux.

Operators were performing the shutdown using Operating Procedure (0)-2. 1, Normal Shutdown to Hot Shutdown, Revi-sion 59, effective March 23, 1990.

The trip was immediately apparent to the operators, who responded by performing the required steps in

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~ 'b Emergency Procedure (E)-0, Reactor Trip or Safety Injection, Revision 10, effective July 21, 1990, before continuing with the shutdown.

The inspectors observed control room activities during this part of the shutdown and concluded that operator actions were performed in a timely manner.

Throughout the shutdown, operations supervision was actively involved in overseeing control room activities.

The inspec-tors noted particularly good management oversight during and after the reactor trip.

1.2 Fire Protection On February 25, 1990, the standby auxiliary feedwater building fire detection instrumentation was inoperable and a fire penetration seal in the auxiliary feed pump area was degraded, Technical Specifica-tions 3. 14. 1. 1 and 3. 14.6. 1 required the establishment of an hourly

'ire watch patrol.

The shift supervisor discovered that these hourly fire watch tours were not being performed as required.

The shift supervisor immediately assigned an auxi liary operator to tour the areas on an hourly basis and notified the Fire and Safety Department.

Security personnel routinely tour these spaces on an hourly basis.

However, routine security tours do not necessarily result in an entry into these areas at least once per hour.

Security computer records indicated that, in some instances, more than one hour had elapsed between entries.

Plant management determined that this was a viola-tion of Ginna Technical Specifications and was reportable under

CFR 50.73.

To prevent recurrence, routine security tours will no longer be used to take credit for required fire watch tours; a dedi-cated person will be used.

A Notice of Violation was not issued for this event because: it was licensee identified; it was of minor safety significance; it was re-ported properly; immediate corrective measures were appropriate; acceptable actions are being taken to prevent recurrence; and no pre-vious violations were identified for which licensee actions would have prevented this occurrence.

(50-244/90-03-01)

On February 26, 1990, during a shift turnover meeting, fire watch personnel discovered that a required hourly inspection was performed for the wrong area.

An hourly fire watch was immediately established for the required area.

In this case, the fire detection systems for the "A" and "B" battery rooms had been disconnected to support modi-fication work.

Technical Specification 3. 14. 1. 1 requires inspection of these areas at least once per hour.

For approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, hourly inspections were conducted for the "A" and "B" emergency diesel generator rooms instead of the battery rooms, due to personnel error

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During that 5-hour period, security personnel entered the battery rooms 10 times, but credit was not taken for fire watch inspections because of the management deci sion on February 25, 1990 (see discus-sion above).

Plant management determined that this was a violation

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of Ginna Technical Specifications and was reportable under

CFR 50.73.

To prevent recurrence, fire watch personnel will be issued individual assignment cards with the sequence of areas to inspect.

Also, the handwritten notes previously used to update the fire system status board will be replaced with printed stickers.

A Notice of Violation was not issued for this event because: it was licensee identified; it was of minor safety significance; it was re-portedd properly; immediate corrective measures were appropriate; acceptable actions are being taken to prevent recurrence; and no pre-

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vious violations were identified for which licensee actions should have prevented this occurrence.

(50-244/90-03-02)

2.

Radiolo ical Controls The inspectors periodically confirmed that radiation work permits (RMPs)

were effectively implemented, that dosimetry was correctly worn in con-trolled areas and dosimeter readings were accurately recorded, that access to high radiation areas was adequately controlled, and that postings and labeling were in compliance with procedures and regulations.

On March 5, the inspector accompanied a radwaste health physics (HP) engi-neer and an HP foreman on a tour of the auxiliary building.

The tour, required by Administrative Procedure A-54.6, Health Physics Tour, Revision ll, effective March 24, 1989, is performed weekly to observe general appearance and potential radiation, security and fire hazards, to check for outdated procedures and calibrations, and to verify that areas are properly posted and barricaded as required by station procedures.

Overall, management attention to good housekeeping and radiation protec-tion practices was evident.

However, rolls of tape and other consumable supplies were left in random locations throughout the plant, and trash cans for clean and contaminated waste were labelled with hand-lettered pieces of masking tape., The radwaste HP engineer performing the inspec-tion indicated that:

some clutter was acceptable; most clutter was left by personnel from other departments; managers from other departments did not conduct tours; and it was not his job to police the activities of other departments.

The inspector concluded that the observed standards for acceptable house-keeping were too low.

In addition, the radwaste HP engineer did not docu-ment discrepancies, such as his perception of the lack of management tours by other departments, and raise them to an appropriate level of management for a corrective action decision.

The inspector discussed the results of the tour with the manager of chemistry and health physics; the manager committed to pursue improved communication of management practices to the workers and of worker-identified weaknesses to managemen I

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3. 1 Maintenance Observations The inspectors observed portions of various safety-related mainten-ance activities to assess whether:

redundant components were oper-able; activities did not violate limiting conditions for operation; personnel obtained required administrative approvals and tagouts be-fore initiating work; personnel used approved procedures or the acti-vity was within the "skills of the trade;" worker s implemented appro-priate radiological controls and ignition/fire prevention controls; and equipment was tested properly prior to returning it to service.

Portions of the following maintenance activities were observed:

Calibration Procedure (CP)-36, Intermediate Range N36 Calibra-tion and/or Maintenance, Revision 16, effective June 23, 1989, observed March 15, 1990.

Instrumentation and control (IEC)

technicians replaced a failed power supply module under main-tenance work order 9000448.

The inspector concluded that the technicians were very knowledgeable and that the work was done in a professional and methodical fashion.

Also, the inspector concluded that, although the technicians had not used a meter to check for voltage on the cables, sufficient care was taken in handling the cables to avoid personal injury.

However, the in-spector noted a mixture of controlled and uncontrolled jack labels on various modules associated with the intermediate range nuclear instrument.

CP-35, Intermediate Range N35 Calibration and/or Maintenance, Revision 14, effective June 23, 1989, observed March 22, 1990.

I&C technicians calibrated N35 in preparation for the plant shutdown on March 23.

A significant amount of uncontrolled labelling was evident in the relay room.

The 18C technicians stated that the labels were included in an upgrade program, and the room is scheduled to receive engraved labels after the 1990 outage.

During the calibration the inspector noted that the procedure required adjustments to N35 using the logarithmic meter face for indication.

Several of the settings required accuracy greater than the technicians could achieve using the meter face.

For example, step 5. 13.5 required adjustment of a potentiometer until the indication on the N35 meter face was

E-11 (+/- 1%).

Increments on the meter face are 4 E-ll, 5 E-ll, 6 E-ll, and so on.

The tolerance of 1% requires an adjustment between 4.95 E-11 and 5.05 E-ll.

The 18C technicians agreed that the required tolerance could not be discerned on the meter face.

Technical support management indicated the procedure weakness was the result of a practice carried over from calibration of the power range instruments which use a linear scale and, prior

to the end of the inspection period, had corrected the procedure with values from the technical manual which can be read on the meter face.

The inspector also noted that the technicians were careful to inform operators prior to taking any action which caused an alarm condition; however, CP-35 did not contain provisions or requirements for this notification.

The inspector concluded that the practice of alerting operators prior to an alarm con-dition is a good practice; the IEC supervisor indicated that this practice will be incorporated into maintenance procedures through the maintenance procedure upgrade project (PUP).

Overall, the maintenance activities were well planned and accomplished by knowledgeable technicians.

The discrepancies noted by the inspec-tor were known to the technicians; however, it is not clear the tech-nicians'oncerns were known to management.

The inspector concluded that continued management attention to insure that workers elevate their concerns appears to be warranted.

3.2 Surveillance Observations Inspectors observed portions of survei llances to verify proper cali-bration 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 surveillances were observed:

Periodic Test (PT)-2.2M, Residual Heat Removal System Monthly, Revision 0, effective date February 9,

1990, observed March 3, 1990.

PT-21, Cleaning Boric Acid Tank Level Sensing Lines, Revision 11, effective date March 2, 1989, observed March 22, 1990.

Turbine Systems Operating Procedure (T)-18C, Turbine Overspeed Trip Test, Revision 14, effective date November 8, 1989, ob-

, served March 23, 1990.

No inadequacies were identified during performance of the surveil-lances.

The cleaning of the boric acid tank level sensing lines on March 22, 1990 was carefully performed by qualified technicians.

Independent verification of valve positions was correctly performed and documente a)

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3.3 Review of nGinna Containment Inte rated Leak Rate CILRT Test Re ort-

~Na 1989 The inspector reviewed the licensee's May 1989 CILRT results docu-mented in accordance with 10 CFR 50, Appendix J, Paragraph V.B.

These results were summarized in a technical document-entitled

"Reactor Containment Building Integrated Leak Rate Test" and were attached to the licensee's letter dated October 18, 1989 to the NRC.

The report contains a test summary and general test description, pre-sentation of test results, and other data such as description of plant and computer software, and data analysis techniques, The Mass Point calculation method of ANSI/ANS 56.8-1987 was utilized, This method is acceptable per

CFR 50, Appendix J.

The purpose of the test was to demonstrate that leakages through the primary containment building and systems penetrating the containment do not exceed that allowed by plant technical specifications.

The test was conducted with containment isolation valves and containment pressure boundaries in their post-accident positions.

The contain-ment met the leakage criterion in the "as-left" condition.

The "as-found" criterion was also met.

The test was followed by a successful verification test.

Results are presented below:

A.

T e

A Test Parameters 1.

2.

3.

Test Method Calc.

Method Test Duration:

Stabilization Test Period Verification Test Pressure Absol ute Mass Point 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 24 hours 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 35.8 psig (Reduced)

B.

Test Results

~wt 5 /da 3.

5.

Maximum Allowabl e Leak Rate (Lt)

Acceptance Criteria 0.75Lt

"As-Found" Measured Leak Rate

"As-Left" Measured Leak Rate Conclusion 0.1528 0.1146 0.0463 0.0463 Acceptable

The inspector performed independent calculations of the containment leakage rates and concluded that the containment has met its accept-ance criteria for leakages in both the "as-left" and "as-found" con-ditions.

4.

~Secur1t During this inspection period, the resident inspectors verified x-ray machines and metal and explosive detectors were operable, Protected Area (PA) and Vital Area (VA) barriers were well maintained, personnel were properly badged for unescorted or escorted access, and compensatory meas-ures were implemented when necessary.

4. 1 Securit Im rovement Pro ram On March 7, 1990, Ginna security 'management briefed the inspectors on hardware upgrades and changes in manning and organization which have recently been accomplished or are proposed.

The improvements address items identified in NRC inspections, and indicate that RG&E is com-mitted to a program to upgrade security at Ginna and address discre-pancies identified by the NRC.

4.2 Access Control A violation of security plan requirements for access controls occurred during this inspection period.

Details are contained in Appendix B to this report's forwarding letter.

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Violation 50-443/89-08-02 Closed This violation was for an inadequately secured vital area barrier.

The inspectors concluded that licensee corrective actions were effec-tive, and that the barrier now meets the requirements of the Ginna Security Plan and regulatory requirements.

5.

En ineerin /Technical Su ort 5. 1 B

ass of Nonessential Emer enc Diesel Generator EDG Tri s

The inspectors reviewed the detailed logic for diesel engine trips to follow-up on a potentially generic issue wherein emergency diesel engine nonessential protective trips are not bypassed on loss of power.

The following wiring diagrams were reviewed:

33013-1986, Metering and Trip Flow Diagrams, Emergency Diesel Generator 1B.

33013-710B, Diesel Generator 1B Elementary Wiring Diagra sl

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The following documents were reviewed:

Ginna UFSAR, Section 8 '

8.3.

Ginna Technical Specification 4.6. 1.

RSSP-2.2, Diesel Generator Load and Safeguard Sequence Test, Revision 36, effective June 5,

1989.

Nonessential emergency diesel generator trips are bypassed during a

Loss of Coolant Accident (LOCA), i.e.,

a safety injection signal, but not during a Loss of Offsite Power (LOOP) transient.

The nonessen-tial trips are:

reverse power, overcurrent, and local stop (pushbut-ton).

The bypass feature is required to be verified at least once per 18 months by Ginna Technical Specifications and is tested during performance of RSSP-2.2 during the annual refueling outage.

The diesel engine trip logic is designed to assure reliable operation of the emergency diesel generator; logic channels are powered from sepa-rate reliable sources with sufficient isolation devices to prevent a

single failure from disabling both diesel generators.

Region I Tem-porary Instruction 87-04 is closed.

During inspection of the emergency diesel generator trip logic, the inspectors noted an error in the Ginna FSAR and Technical Specifica-tions.

Both documents state that diesel generator trips are auto-matically bypassed upon loss of voltage on the emergency bus and/or a safety injection actuation signal.

The wiring diagrams indicate that the trips are bypassed on a safety injection actuation signal only.

RG5E engineering indicated that the discrepancy would be cor-rected.

This item is unresolved pending correction of the Ginna FSAR and Technical Specifications.

(UNR 90-03-04)

The inspectors compared Ginna Technical Specification (TS)

EOG sur-veillancee requirements with Standard Technical Specification (STS)

surveillance requirements.

Ginna TS 4.6. l.d requires that each EDG be demonstrated operable once each 18 months by verifying auto-start from normal standby on a simulated LOOP in conjunction with a Safety Injection (SI) test signal.

STS 4.8. 1. 1.2 requires that each EDG be demonstrated operable once each 18 months by verifying auto-start from normal standby on a simulated LOOP by itself, on an Engineered Safety Feature (ESF) signal without LOOP, and on a simulated LOOP in conjunction with an ESF signal.

Ginna TSs do not require verifying auto-start on a

LOOP by itself or on an ESF actuation without a simu-lated LOOP.

In view of the design purpose of the emergency diesels, Ginna management committed to include verification of closure of the LOOP and SI start contacts in the surveillance procedure for diesel auto-start on LOOP in conjunction with an SI signa ah

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5.2 Unresolved Item 50-244/89-04-04 Closed Failure of fire door closure.

In response to the repeated failure of the fire door to automatically close completely, plant management posted a continuous fire watch to ensure door closure.

A minor modi-fication was proposed to install alarm contacts on the door to alert security personnel if the door fails to close.

The long term action is a major modification to eliminate the pressure differential across the door and is scheduled for the spring of 1991.

The inspectors concluded that the corrective actions in place adequately assure door closure.

6.

Safet Assessment/

ualit Verification I

6.1 Evaluation of Tool Dro ed in the Boric Acid Stora e Tank On March 8, 1990, during cleaning of the boric acid tank level sens-ing lines, the cleaning tool broke and part of it fell into the tank.

The part which fell into the tank was a stainless steel rod approxi-mately 3/8 inch in diameter and 90 inches in length.

Based on review of a safety evaluation, the Plant Operations Review Committee con-cluded that operation could continue since the rod would remain in the tank and could not cause damage to or affect operation of any component.

The inspectors reviewed the evaluation and determined that the results were adequate.

Plant personnel plan to recover the rod during the annual refueling outage.

6.2 Ins ection of Com leted Nuclear Concerns List Actions In January 1989, at a management meeting between Rochester Gas and Electric and NRC Region I, RG&E presented a list of more than eighty nuclear concerns.

Prior to conclusion of the meeting, RG&E committed to select items from the concerns list for accomplishment prior to the end of 1989.

On December 4,

1989, RG&E presented a list of the seventeen items which had been selected for action and completion during 1989.

Thirteen of the items are considered complete by the licensee.

The resident inspectors reviewed licensee actions for each of the thirteen items to assess RG&E management effectiveness.

The thirteen items inspected were:

Administrative Procedure Training Procedure Adherence Reinforcement

CFR 50.59 Reviews Maintenance Work Planning/Control Interim g Determination Program In-Service Inspection (ISI) Program Review Piping and Instrumentation Drawing (P&ID) Walkdowns In-Service Testing Valve Test Program 10 Year ISI Program Primary Heat Exchanger Inspection

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Chemical Control Program Operational Experience Review P&IOs Most concerns substantially predated the existence of the Nuclear Concerns list; detailed action plans had previously been created and were implemented in 1989.

There were two notable exceptions in the areas of administrative procedure training and procedure adherence reinforcement.

RG&E management did not establish a clear concern or a plan of action for these two concerns.

RG&E has periodically en-countered procedure adherence problems during 1989 and 1990, and the inspectors observed that a clear realization of the procedure adher-ence mandate is not yet evident at all levels of the licensee's or-

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ganization.

Overall, however, manag'ement was successful in achiev-ing intended goals.

6.3 Periodic and S ecial Re orts Qi 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 whether the reports contained information re-quired by the NRC, the test results and/or supporting information were consistent with design predictions and performance specifica-tions, and the reported information was valid.

The following reports were reviewed:

Monthly Operating Reports for January and February 1990

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6.4 NRC -

RG&E Mana ement Meetin On March 6, 1990, RG&E management met with NRC Region I management in the NRC Region I offices to discuss RG&E configuration management initiatives and program status.

RG&E presented a schedule for the program extending through 1994 along with the resources needed to implement the program.

The program is expected to be time consuming

,and labor intensive.

Project commitments include:

a Q-list in 1990, upgraded calibration procedures in 1990, upgraded maintenance proce-dures in 1992, and a probabi listic risk assessment (PRA) in 1992.

Handouts from the management meeting are attached.

7.

Administrative 7,1 Licensee Activities At the start of the inspection period the full power.

On March 19, 1990, the coast annual refueling outage began.

Operators plant on March 23, 1990 at 9:00 a.m..

At rator was taken off-line, and the turbine plant was at approximately down preceding the 1990 began shutting down the 5:31 p.m., the main gene-Qas,overspeed trip tested

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successfully at 5:35 p.m..

At 6:04 p.m.,

as an operator was insert-ing shutdown bank rods with the reactor subcritical, a reactor trip occurred due to high flux on source range detector N31.

The source range detectors had automatically re-energized and N31 failed, caus-ing the trip.

At the close of the inspection period, maintenance personnel had not determined the root cause of the fai lure.

The plant is scheduled to be shut down for 37 days.

Hajor outage activities include:

annual refueling, 'B'eactor coolant pump re-placement, steam generator tube plugging and sleeving, 'B'irculat-ing water pump overhaul, midloop instrumentation upgrade, and a major valve preventive maintenance effort.

7.2 Licensee Res onses to NRC Ins ection Re orts The NRC received RG&E responses ( 1-31-90, 2-23-90) detailing correc-tive and preventive actions for the violation identified in Inspection Report 50-244/89-16 and for the continuing weakness identified in Inspection Report 50-244/89-15.

These actions will be examined during future inspections.

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~Ei fI At periodic intervals and at the conclusion of the inspection, meet-ings were held with senior station management to discuss the scope and findings of this inspectio ~

rEB-22-1998 89: 29 FRY RGS E ENG INEER 1 HG 49 EAST TO PLANT P. 82 RQGE/HRC Meeting March 6, 1990 eon% iguxati.on Managenent Xntxoduction CM Pxogzamg Implementation

$ Status Schedule 8 Resources WU.kens/Sm&h Kennedy Meter 10 nd.n.

20 min.

Program Support CM Information System D16CQ6810D

RGKE GONFIGURATION MANAGEMENT REGION I PRESENTA ION MARCH 6, 1990

RG&E CONFIGURATION MANAGEMENT RGLE/NRC MEETING MARCH 6, 1990 INTRODUCTION CM PROGRAM STATUS 4 IMPLEMENTATION KENNEDY 20 MIN.

SMITH/WILKENS 10 MIN.

SCHEDULE 8. RESOURCES

. MEIER/KENNEDY 15 MIN.

PROGRAM SUPPORT DISCU SSION PIEDE OPEN 5 MIN.

Beg Ion I P res e n tat lo n - 3/6/90

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RG8 E CONFIGURATION MANAGEMENT ORIGINS

~ INDUSTRY EXPERIENCE

~ SYMPTOMATIC PROBLEMS IDENTIFIED Internal INPO NRC

~ LIST OF MANY ISSUES LIMITEDRESOURCES

~ RGRE ORGANIZATION & PEOPLE CHANGING

~ LICENSE/LIFE EXTENSION Region I Presentation - 3/6/90

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RGS.E CONFIGURATION MANAGEMENT NUCLEAR MISSIONS STATEMENT/GOALS DEVELOPMENT OF DIVISION STRATEGIES Configuration Management Corrective Action Program Engineering Maintenance Management Effectiveness Materials Management Procedures Public/Personnel Safety Quality Effectiveness Region I Presentation

- 3/6/90

RG8 E CONFIGURATION MANAGEMENT CM OVERSIGHT TASK FORCE P. Wilkens (Chairm'an)

J. Widay L. Phillips T. Marlow G. Meier C. Anderson D. Piede M. Shaw G. Wrobel Engineering Station Production Divisional Services Station Support Training Quality Assurance Production Systems 8 Servic Procurement Nuclear Safety 8 Licensing CM Project Manager M. Kennedy Engineering Region I Presentation

- 3/6/90

RGS.E CONFIGURATION MANAGEMENT INDUSTRY SURVEY PSEUD.G Davis-Besse PGE Region V Utilities SCE INPO NUMARC EXTERNAL SUPPORT ATESI ACT Associates CYGNA NUS Gilbert/Commonwealth IBM CONCLUSION Effective CM Implementation Approach is Organization Specific Region I Presentation - 8/6/90

RGKE CONFIGURATION MANAGEMENT RGKE ASSESSMENT BY ATESI RG8 E vs. "INDUSTRY EXPERIENCE" RECQMMENDATIQN SUMMARY Establish Tighter Control for Configuration Changes Enhance Availability Qf Information Consider More Formal Control on Safety Significant and Balance of Plant work Activities Complete Walkdowns In-Progress to Establish Configuration Baseline Focus QA to Resolve Programmatic Issues Region I Presentation

- 3/6/90

RGB E CONFIGURATION MANAGEMENT KEY ELEMENTS OF CONFIGURATION MANAGEMENT

~

BASELINE CONFIGURATION

~

DESIGN BASIS CONFIGURATION CHANGE CONTROL

~

INFORMATION ACCESS Region I Presentation

- 3/6/90

RGS.E CONFIGURATION MANAGEMENT PROGRAM ELEMENTS BASELINE CONFIGURATION DESIGN BASIS CHANGE CONTROL INFORMATION ACCESS P&ID Upgrade Electrical Drawing Upgrade Vendor Manual Project DBD Project Setpoint Verification Project Safety Classification Project Work Control Improvements Procedure Updates By Projects Document Control Improvement CM Information System Region I Presentation - 3/6/90

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RGRE CONFIGURATION MANAGEMENT CM OVERSIGHT TASK FORCE - Est. 1st QTR '89

- PROGRAM DIRECTION & OVERSIGHT CM POLICY STATEMENT-Issued 2nd QTR '89

- POLICY: DEVELOP A COMPREHENSIVE INTEGRATED P ROGRAM

- ORGANIZATION

- OBJECTIVES CM PROGRAM PLAN - Issued 2nd QTR '89

- GOALS AND OBJECTIVES

- MANAGEMENTAND ORGANIZATION

- SCOPE CM ACTION PLAN - Issued 3rd QTR '89

- TASK DESCRIPTIONS

- INTEGRATED SCHEDULE Region I Presentation - 3/6/90

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RG&E CONFIGURATION MANAGEMENT SCOPE SELECTION CRITERIA SYSTEMS, STRUCTURES AND COMPONENTS

- SAFETY RELATED

" SAFETY SIGNIFICANT

- RELIABLE/ ECONOMIC POV/ER GENERATION LEVEL OF DETAIL

- MAINTENANCEREPAIR/REPLACE PRACTICES

- PROCUREMENT PRACTICES

- ENGINEERING DESIGN/ANALYSIS NEEDS Reglan I Presentation - 3/6/90

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RGLE CONFIGURATION MANAGEMENT

~ PROGRAM CONSIDERATIONS Data Integrity/Quality Expedite Availibilityof Output RG8E (Hand-on) Management Commitments Budget Resources

~ CONCLUSIONS integrate Projects Develop Composite Schedule Monitor/Control Schedule Accountability RegIon I Presentation

- 3/6/90

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RG&E CONFIGURATION MANAGEMENT PROJECT INTEGRATION & SUPPORT SEQUENCE

~ STANDARD NAMES 5 ID NUMBERS

~ AS-BUILT DATA P8 ID WALKDOWN ELECTRICAL WALKDOWN

~ SYSTEM FUNCTIONS 8 BOUNDARIES Q-LIST

~ DETAILED EQUIPMENT INFORMATION VENDOR MANUALS SETPOINT VERIFICATION

~ PROCEDURES

~ DESIGN BASES DOCUMENTATION

~ RECONCILIATION Region I Presentation

- 3/6/90

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S I I FI ED SYSTEM SCHEDU E

APRIL AUOUST DECEHBER APRZL

) 2 tSTANDARD HOHEHCLATURE SYS 01

!

PLAIDS BYSTEH 01 STANDARD NONEHCLATURE 8Y8 02

- - - - - - - X PLAIDS SYSTEN 02

- - - - -'

- -X ECCDa BYSTEH 01 X

0-LIST SYSTEH 01 ECCDs SYSTEN l2 Q-LIST - 8YSTEN S2

SYSTEM GROUPS SYSTEM GROUPS FINISH APPROX.

EVERY 4 MONTHS VENDOR HANUALS SYS 01 X

VENDOR HANUALS SYS 02 X

SETPOIHT VERIFICATZOH SYS

X HAIHTEHANCE PROCEDURES SYS 01 X

SETPOIHT VERIFICATIOH 8YS N2 NAIHTEHANCE PROCEDURES SYS 02 RECONCILE CPa, OPs, TEST PROC SYS Nt RECONCILE CPS'Pep TEST PROC SYS 82 X


X DESIGN BASIB DOCS SYS 01 X

DESIGN SABIS DOCS SYS Og X

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RGKE CONFIGURATION MANAGEMENT SEQUENCE OF SYSTEMS

~ SAFETY RELATED

~ SAFETY SIGNIFICANT

~ RELIABLE/ECONOMIC POWER GENERATION RegIon I Presentat ton - 3/6/90

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RGRE CONFIGURATION MANAGEMENT SYSTEM GROUPS 1 8 2 SYSTEM GROUP N Reactor Coolant System Residual Heat Removal Safety Injection System Auxiliary Feedwater Containment Spray System SYSTEM GROUP 02 Reactor Protection System Engineered Safety Features Actuation System Chemical and Volume Control System Service Water

'omponent Cooling Water Primary Containment System Steam Generator System Region I Presentation - 3/6/90

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RGLE CONFIGURATION MANAGEMENT PROGRAM CONTROLS L ACCOUNTABILITY

~ SCHEDULE DEVELOPED

~ ADVISE NRC OF SIGNIFICANT SCHEDULE CHANGES

~ PROGRESS MEASURED BY DELIVERABLES

~ QUALITY OF DELIVERABLES MONITORED BY PROJECT

~ MONTHLY REPORT OF PROGRESS TO CM OVERSIGHT TASK FORCE BY PROJECT

~ SCHEDULE MILESTONES WILL BE INTEGRATED INTO EMPLOYEE JOB PLANS Region I Presentation

- 3/6/90

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RG&E CONFIGURATION MANAGEMENT LEVEL I SCHEDULE RegIon I Presentation -3/8/90 1969 1991 1993 1994 3Jan 11eeeeeeeeeeeeee Ecco FGRAoE pRGGRah 38Jul 3Jsn 24Jul zaeeeeeoeeseeeee asapr lseeeeeeeeeeeeeo pczo SSep zsoeeeeeeee Ct-LIST PROJECT 13eeeeeeeeeeeeee 3Jul 14eeeeeeeee ROGRAN To INCL csee vENooR Tsc 120sc NAINTe PROCEDURES UPGRA 8888 SETPOINT VERZFZCA 28Msy E DATA RECONCILIATION ICAL NAHUAL PROGRAN ZON PROGRAN

CAL PRO+

RECONo 12Jul 36sy 19Jul 3Jsn 16eeeeoeeeeeeees cat.z 2Jsn 22888 2oct 6Jun 17eeeeeeeee 28Jul ATION PROCEDURES eseeeeeeee CNZS 2Jsn 22918 8888 DoBoo DEVELOPENE 6Dec eeeeeeeeee CNIS FzNAL YSTEH ( COHPUTER 18Jul 23Feb ARDWARE 8 PROGRAN)

21Nov 17Jul leOct 6Hov 23eeeeeeeee esse aoNzNzsTRA 2Jsn a4eee eeeeeeeeee oocu aseeeeeoeee esse CONHZTNEHT aseeeeeesee esse zHozvzouaL 26Fab 31eseeeeeeeseeee ON PROCEDURES HT CONTROL ENHANCEHENT 29Msy CTZON TRACICIHG LANT EVALUATION PLEX 1Jun 26Au 14Fab ansy 3aeeeeeeeeeeeeee yoRx coNTRoL saup 33eeeeeeeee 8888 RECONCILIATION (D 6+Doe TOTAL Sco E)

18Au 17apr SSap 34eeesseeee sees CHANGE coN OL 14Dac 14Jul 3see e

$ 9.3 Million

$ 12.3 Million

$ 9.7 Million

$ 9.1 Million

$ 10.0 Million

$ 7.9 Million

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RG8cE CONFIGURATION MANAGEMENT INTEGRATED SCHEDULE IMPACT ON COMMITMENTS PROJECT COMMITMENT IMPACT COMMENTS Q-List Maintenance Procedures 08/90 12/92 None 07/94 Safety Related and Safety Significant Done First Calibration Procedures IPE/PRA 07/90 09/92 None None Setpoint Verification Integrated with Other CM Projects Region I Presentation - 3/6190

RGRE CONFIGURATION MANAGEMENT 1990 ACTIVITIES

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Q-LIST System classification complete All Q components identified Process for continuing classification in place

~ P&IDs Work off punchlist

~ Electrical Drawing Upgrade Issue electrical system drawings necessary to support first two system groups

~ Vendor Manual Project Complete inventory of manuals Control process improved Upgraded manuals for first two system groups Region I Presentation - 3/6/90

RGRE CONFIGURATION MANAGEMENT I 990 ACTIVITIES(CONT)

~ Calibration Procedures (exclusive of setpoint verif.)

Rewrite and upgrade complete

~ Setpoint Verification Method developed, pilot project initiated

~ Maintenance Procedure Upgrade Pilot project complete

~ Schedule Integrated systems approach'implemented and updated Region I Presentation - 3/6/90

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CONFIGURATION MANAGEMENT INFORMATION SYSTEM DUANE L. PIEDE, MANAGER PRODUCTION SYSTEMS AND SERVICES

TO PROVIDE AN EFFECTIVE, INTEGRATED INFORMATION SYSTEM TO SUPPORT THE ENHANCED CONFIGURATION MANAGEMENT PROCESSES OF THE NUCLEAR DIVISIO CMIS ALL INFORMATION CREATED OR USED IN THE VARIOUS CONFIGURATION MANAGEMENT PROCESSES ARE POTENTIALLY WITHIN THE SCOPE OF CMIS.

THOSE PORTIONS OF CM INFORMATION WHICH WILL BE INCLUDED IN A COMPUTER BASED INFORMATION SYSTEM WILL BE DETERMINED BASED ON THEIR SHARABILITY, CRITICALITY, AND ECONOMIC BENEFIT ENGINEERING DESIGN BASIS ACTUAL PLANT CONFIGURATION PROCEDURAL AND PROCESS CONTROLS INFORMATION SYSTEM

INFORMAL CQNTROLS GROUP-LEVEL CQNTROLS MANUALMETHODS LIMITED AUTQMATION POCKETS QF DATA DUPLICATED INFORMATION PAPER-BASED FORMAL CONTROLS DIVISIQN-LEVELCONTROLS AUTOMATED APPROACH EXTENSIVE AUTOMATIQN SHARED DATABASE INTEGRATED INFORMATION ON-LINE ACCESS

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CMIS MAXIMUMUSER PARTICIPATION IN DEVELOPMENT AND TESTING TRANSPARENT COMPUTER ENVIRONMEN-COMMON LOOK AND FEEL TO USERS LOGICAL, INTEGRATED, RELATIONAL DATABASE-PC-LIKE RESPONSE HIGH DATA INTEGRITY ACCESS SECURITY SOFTWARE (UALITYASSURANCE BUILTIN

CMIS FORMATION OF CMIS PROJECT TEAM BUSINESS PROCESS MODELING-HARDWARE AND SOFTWARE STANDARDS INTEGRATION OF ONGOING CM PROJECT DATA

2 MEMBERS R ENGINEERING PLANT TI MATERIALS MANAGEMENT CORPORATE INFORMATION SYSTEMS DIVISION SYSTEMS AND SERVICES (UALITYASSURANCE CM PROJECT TRAINING

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BASIC ELEMENTS OF:

1.

WHAT IS~

2.

WHAT SHOULD BE~

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WHAT TO DOY 4.

HOW TO DO IT~

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BUSINESS MODELING Corporate Goals 6 Rjoctiros hdustry Practice Currant Business Oper'aliens WHATlS l

Qmaat Business Practices model Corporate Goals 6 Objectives ladustrg Practice Fuaclloaal Analgllcal maaagemeat Team Cost Benefit Oal Pro ooo4 Solutions WHAT SHOULD BE Hell.

Oeslred Business Practices model Cmyorato Goals 6 Ob eclipse 6 Budget k'.".tQ hformatloa 9gstems Architecture Plea Hegulatorg I

Functional managomoat Analgllcal Team

lndustrg Specialists

~Slat fla WHAT TO DO Prioritised Ageada H slat ion el melhodologg Te chai eel Options Executive Analglical management Team Changes to Desired Business madel 6 ISA Plan HOW TO DO 1T Stral ~glc Plan Project Plea Schedule Aaalglical Toonl

I dustrg Specialists Fuaclional management information Sgstoms management

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BASIC BUILDING BLOCK 1.

DATA INPUTS 2.

DATA OUTPUTS 3.

CONTROLS 4.

SUPPORTS

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4-DIMENSIONALPROCESS MODELS ARE:

INTUlTlVELY UNDERSTANDABLE (USER OWNS THE MODEL'S CONTENTS)

2.

COMPLETE 3.

TRANSFORMABLE CONTROL Controls on Doing the Process DATA Data Consumed PROCESS Data Produced DATA Who Or What Does the Process SUPPORT

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DEFINEON 0 PLNG 4[89 1(99 PHASE

q9tj (mt,j PHASE 3 CORE SYFEM PROJECT INTEGRATION 4(@1

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