IR 05000244/1990005
| ML17250B170 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/22/1990 |
| From: | Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17250B168 | List: |
| References | |
| 50-244-90-05, 50-244-90-5, NUDOCS 9005300216 | |
| Download: ML17250B170 (98) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No:
Licensee:
Faci 1 ity:
Dates:
Inspectors:
50-244/90-05 Rochester Gas and Electric Corporation License No.
DPR-18 R.
E. Ginna Nuclear Power Plant March 24 through May 7, 1990 C.
S. Marschall, Senior Resident Inspector, Ginna N.
S. Perry, Resident Inspector, Ginna R.
S. Barkley, Project Engineer, Region I, DRP A.
R. Jo nson Pr je t Ma ager, NRR
/
Approved by:
jlor E.
C.
McCabe, Chief, React r Projects Section 3B SCOPE Date Routine and reactive inspection (207.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> including 17 backshift and 10 deep backshift hours) of operations, radiological controls, maintenance/surveillance, security, engineering/technical support, and safety assessment/quality verification.
RESULTS Safe facility operation was observed.
A significant effort by Radiological Controls management was noted in response to higher than normal personnel con-taminations, and significant improvement was observed in the control of modifi-cations.
(Details 2.2 and 5.3).
One non-cited violation was noted concerning a personnel error which caused an inadvertent Safety Injection actuation'
maintenance foreman, in an effort to expedite activities being conducted in the elevated temperatures within con-tainment, neglected to consult a procedure and thereby directed technicians to close the wrong valve.
Six Temporary Instructions, two violations, and two unresolved items were closed.
~A endix:
RGrLE Handouts. from 4/29/90 Mid-Cycle SALP Meeting 3 005343()2$ $
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PDC:
4 N
OVERVIEW Plant 0 erations:
The plant remained shut down for refueling and maintenance during much of the period.
Mid-loop operation was carefully controlled.
On May 6, 1990, the reactor was diluted to criticality.
Startup proceeded without incident through May 7, 1990, when the generator was placed on the grid.
Radiolo ical Controls:
Management response to a higher than projected number of personnel contaminations in March 1990 was analytical, logical and effec-tive.
Action to cope with a work slow-down by contract Health Physics tech-
'icians showed the ability to continue outage activities with minimal impact.
Maintenance/Surveillance:
On May 5, 1990, Safety Injection Actuation occurred when hasty instructions caused the wrong instrument to be isolated.
In response to inspector observations concerning notification of annunciator actions, the inspectors were provided copies of the writer's guide and the procedure valida-tion checklist for the new, upgraded calibration procedures.
Loose torque switch mounting hardware was documented during MOV (motor-operated valve)
inspections and RG&E made an appropriate industry notification.
In general, outage maintenance and surveillance were well planned and were accomplished by knowledgeable personnel.
~Securit:
The inspectors reviewed additional information on Fitness-For-Duty training.
Corrective actions for weaknesses identified in NRC Inspection Reports 50-244/90-03 and 90-04 were found to be effective.
Picketing on two occasions was peaceful and orderly.
En ineerin /Technical Su ort:
RG&E's actions on potential refueling cavity water seal failure and boron dilution events were found adequate.
Control over modification installa'tion and testing incorporated significant improvements resulting from weaknesses identified during the 1989 refueling outage.
Overall, implementation of modifications was well controlled and thoroughly reviewed.
Safet Assessment/
ualit Verification:
A mid-cycle SALP meeting was held on April 25, 1990; RG&E s presentation was well prepared and demonstrated the ability to be constructively self-critical.
RG&E's response to IE Bulletin 87-02 concerning fasteners was appropriate and acceptable.
Controls for stor-age of transient equipment was aggressive and effective, and demonstrated man-agement commitment to safety.
RG&E demonstrated responsiveness to a concern regarding the condition of paint on the containment floor by painting the upper level of containment on short notice at the conclusion of the refueling outage.
Control over the quality of diesel generator fuel oil was found acceptable.
Procedure Adherence Task Force meetings demonstrated a management commitment to resolution of procedure adherence weaknesse CONTENTS Plant Operations (71707, 92701, 60705, 60719)
1. 1 Inspector Observations.
1.2 Violation 50-244/89-18-03 (Closed).
~.
Radiological Control (71707, 92701)..
2.1 Unresolved Item 50-244/89-15-01 (Closed)
2.2 Personnel Contamination.
2.3 Outage Staffing Maintenance/Surveillance (56700, 62703, 61726, 70323, 92701)
~..
3. 1 Maintenance Observations.
3.2 Safety Injection (SI) Actuation.
3.3 Surveillance Observations.........
~....
~....
3.4 Unresolved Item 50-244/88-16-01 (Closed)
Security (71707, 255104)
4.1 Fitness-For-Duty (TI 2515/104)..
4.2 Access Control.
4.3 Picketing of Site Access Road....
~....
4.4 Monthly Meeting with RG&E Security Manager Engineering/Technical Support (37700, 37701, 37828, 71707, 92701, 25566, 25594).
5.1 Refueling Cavity Water Seals (TI 2515/66).
5.2 PWR-Moderator Dilution Requirements (TI 2515/94)
5.3 Control of Modifications 5.4 Violation 50-244/89-18-04 (Closed)
Safety Assessment/guality Verification (71707, 90713, 92701, 90712, 35502, 40500, 25593)
6. 1 Mid-cycle SALP Meeting.
6.2 Fastener Testing (TI 2500/27)
~
6.3 Storage of Transient Equipment (RI TI 87-03)
6.4 Diesel Generator Fuel Oil guality Assurance (TI 2515/93)......
6.5 Periodic and Special Reports.....
~.......
6.6 Written Reports of Nonroutine Events 6.7 Procedure Adherence Task Force 6.8 Submittal of guality Assurance Program Description............
PAGE
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Contents 7.
Administrative (30703).
7.1 Licensee Activities 7.2 Licensee Responses to NRC Inspection Reports.
7.3 Exit Meeting
18
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DETAILS 1.
Plant 0 erations Ins ector Observations Control room activities were reviewed daily.
Control room logs were checked to assess activities and trends.
Recorder traces were observed to check for abnormalities.
Selected safety-related tagouts were audited.
Accessible plant areas were toured, and activities in progress were observed.
The inspectors found that the RE E. Ginna Nuclear Power Plant operated safely and in conformance with license and regulatory requirements.
Control room staffing was adequate.
Operators exercised control over access to the control room, adhered to approved procedures, and under-stood the reasons for lighted annunciators.
During reactor coolant system (RCS) reduced inventory conditions, operators were alert to potential problems which could cause a loss of shutdown cooling.
Operators were found to be well informed on plant conditions.
During fuel unloading and reloading an updated core map was kept in the con-trol room.
No inadequacies were identified.
The inspectoqs verified compliance with the Technical Specifications'n April 25, 1990, while the plant was in cold shutdown, the "A" Emergency Diesel Generator (EDG-A) automatically started, but did not load onto its bus when operators started the "A" Reactor Coolant Pump (RCP-A).
RCP-A was being bumped to facilitate venting and filling of the RCS.
A momentary undervoltage occurred on Buses 14 and 18.
It recurred during subsequent
"-tarts of RCP-A.
The EDG was placed in pull-to-stop to prevent starting.
Preliminary corporate engineering evaluation indicated that the undervoltage occurred as a result of leaving a voltage regulator on the 35KV supply line in automatic operation.
Line voltage had been raised above nominal levels, as was customary.
But, use of a different line configuration apparently caused an oversight involving the voltage regulator.
The oversight was discovered prior to the final RCP-A start and the regulator was placed in manual.
No undervoltage relay actuations were then experi-enced.
However, final licensee review has not yet been completed.
Operators made the reactor critical on May 6, and synchronized the turbine-generator to the grid on Hay 7.
The inspectors observed con-trol room activities prior to rolling of the main turbine, during generator synchronizing, and after synchronization.
During this startup, operators were aware of the potential for problems with steam generator level control and re'actor coolant average temperature due to a positive moderator temperature coefficient, and communicated
s I
.4
changing conditions to each other very well.
Just prior to generator synchronizing, the shift supervisor verified that the operators each knew their. specific tasks and the effect that plant parameters such as steam generator level and average coolant temperature and pressure could have on each other.
Overall, the startup was slow, well-controlled, and without incident.
Among the operations documents reviewed were:
Ginna Station Event Report (A-25. 1) Number 90-28, concerning inoperable check valve CV-528.
Ginna Station Event Report (A-25. 1) Number 90-29, concerning loss of input to Bus 15.
Ginna Station Event Report (A-25. 1) Number 90-30, concerning pressure transmitter out of calibration.
Ginna Station Event Report (A-25. 1) Number 90-31, concerning unauthorized use of TSC PKIDs.
Ginna Station Event Report (A-25. 1) Number 90-32, concerning set screw found in fuel assembly.
Ginna Station Event. Report (A-25. 1) Number 90-33, concerning flow transmitter out of calibration.
Ginna Station Event Report (A-25. 1) Number 90-34, concerning level transmitter out of calibration.
Ginna Station Event Report (A-25. 1)
Number 90-35, concerning pressure transmitter out of calibration.
Ginna Station Event Report (A-25. 1) Number 90-36, concerning unlocked waste gas evaporator room gate.
Ginna Station Event Report (A-25. 1) Number 90-37, concerning results of steam generator eddy current testing.
Ginna Station Event Report (A-25. 1) Number 90-38, concerning pressure instrument out of calibration.
Ginna Station Event Report (A-25. 1) Number 90-39, concerning level switches out of tolerance.
Ginna Station Event Report (A-25. 1) Number 90-40, concerning flow transmitter out of toleranc Ginna Station Event Report (A-25. 1) Number 90-41, concerning auto start of an emergency diesel generator while in cold shut-down.
Ginna Station Event Report (A-25. 1) Number 90-42, concerning primary chemistry error.
Ginna Station Event Report (A-25. 1) Number 90-43, LTOP actuation requiring 30 day report.
Ginna Station Event Report (A-25. 1) Number 90-44, concerning flow transmitter out of tolerance.
Ginna Station Event Report (A-25. 1) Number 90-45, concerning leak in "C" charging pump relief valve.
Ginna Station Event Report (A-25. 1) Number 90-46, concerning unanticipated safety injection during plant heatup.
Ginna Station Event Report (A-25. 1) Number 90-47, concerning broken instrumentation wire.
Each Ginna Station Event Report was.reviewed to ensure plant per-sonnel took appropriate corrective action and observed the appro-priate Limiting Conditions for Operation.
No inadequacies were identified.
1.2 Violation 50-244/89-18-03 Closed This violation documented failure to properly realign radiation moni-tors R-10A, R-ll, and R-12, and failure to properly perform indepen-dent verification.
In response, RGEE added steps to Calibration Procedures (CP)-210A, 211 and 212 to insure proper system restoration and independent veri-fication.
The inspectors reviewed the changes to the Calibration Procedures and deemed the corrective actions sufficient.
2.
Radiolo ical Control The resident inspectors periodically confirmed that radiation work permits were effectively implemented, dosimetry was correctly worn in controlled areas, dosimeter readings were accurately recorded, access to high radi-ation areas was adequately controlled, and postings and labeling were in compliance with procedures and regulation Ci
'
2.1 Unresol ved Itern 50-244/89-15-01 Cl osed This item concerned a licensee identified discrepancy with the cali-bration constant used in the calibration procedure for noble gas effluent radiation monitors R-12A, 14A, and 15A.
The inspector had a
concern regarding the monitors'perability.
Through discussions with RGKE and NRC Region I personnel, the inspectors determined that the change of the calibration constant enhanced the procedure and that the radiation monitors were operable at all times.
2.2 Personnel Contamination Ouring the first week of the refueling outage which began on March 23, 1990, Ginna management noted that 74 personnel contamina-tions had occurred during March 1990.
That was more than twice the 30 projected contaminations.
Health physics personnel analyzed the contaminations by work group and obtained an independent review of the contaminations.
Results of the analysis and review provided health physics personnel with corrective action objectives.
These included specific work groups to be targeted for training, protective clothing recommendations with a significant potential for reducing contaminations, and recommended training based on interviews with workers.
As a result of the corrective actions, contaminations for April 1990 were reduced to 125% of projected.
Further licensee review and analysis is planned so that additional measures can be implemented to reduce contaminations in the 1991 refuel'ng outage.
The inspectors reviewed the analysis and corrective actions and con-cluded that the initiatives to trend and control contaminations aggressively addressed the minimizing of radiation exposures.
2.3 Outa e Staffin From March 26-30, 1990, contractor (General Technical Services)
Health Physics (HP) technicians staged a work slow-down to protest non-union hiring practices.
The slow-down was organized by the International Brotherhood of Electrical Workers.
The inspectors discussed contingency HP planning with the Manager of Chemistry and Health Physics and concluded that a conservative approach to control of work in the radiologically controlled area was employed.
The inspectors noted the presence of an ample number of HP technicians and the availability of several manager s for HP coverage.
HP coverage was continued without the use of excessive overtim JL
3.
Maintenance/Surveillance 3. 1 Maintenance Observations The inspectors observed portions of various safety-related mainten-ance activities to assess:
whether redundant components were operable; activities did not violate limiting conditions for operation; per-sonnel obtained required administrative approvals and tagouts before initiating work; personnel used approved procedures or the activity was within the "skills of the trade;" workers implemented appropriate radiological controls and ignition/fire prevention controls; and equipment was tested properly prior to returning it to service.
Portions of the following maintenance were observed:
Maintenance Procedure (M)-37. 133, Coupling and uncoupling
"Swagelok" Tube Fittings, Revision 0, effective April 30, 1989, observed March 29, 1990.
M-37. 130, Disassembly 5 Reassembly of Pipe Flange Connections B
SI Pump, PS101B Outboard Shaft Stuffing Box Outlet Flange, Re-vision 4, effective February 23, 1990, observed March 29, 1990.
M-11.8K, 1B Reactor Coolant Pump Motor Minor Inspection and Re-moval, Revision 12, effective March 10, 1990, observed April 3, 1990.
Calibration Procedure (CP) I-SI-FL0-924, Calibration of SI Flow Channel 924 Rack Instrument, Revision 00, effective January 12, 1990, observed April 4, 1990.
ECCSD-T-014, MOV Verification Documentation, effective March 3, 1990, observed for MOV 826B.
In response to inspector observations made in NRC Inspection Report 50-244/90-03 concerning operations notification on annunciator actions during calibrations, information was provided to the inspectors con-cerning measures included in upgraded calibration procedures.
The inspectors reviewed portions of the calibration procedure writer'
guide and the procedure validation checklist.
The measures reviewed were assessed as an acceptable means of introducing requirements for notification of the control room.
During the inspection of motor"operated valve MOV-826B, plant per" sonnel documented loose torque switch mounting hardware associated with SMA-type torque switches.
Plant personnel indicated that
MOVs with loose torque switch mounting hardware had been discovered during the 1990 outage inspections and 19 torque switches with loose mount-ing hardware had also been identified during the 1989 outage.
The
e e,
licensee determined that the root cause of the loose hardware was age/vibration, informed the industry via the Nuclear Network, and is evaluating the problem for reportability to the NRC.
With the exception of the Safety Injection actuation discussed below, outage maintenance was well planned, accomplished by knowledgeable personnel, and accomplished in a safe and efficient manner.
3.2 Inadvertent Safet Injection SI Actuation On May 5, 1990, with the plant in hot shutdown, a SI actuation occurred.
The reactor trip breakers were open at the time.
No injec-tion occurred because reactor coolant pressure was greater than pump shutoff head.
All systems responded as expected.
The immediate cause of the actuation was determined to be maintenance personnel incorrectly closing a pressurizer instrumentation valve.
A team of Instrumentation and Controls ( IKC) technicians had repaired a
leaking fitting on the reference leg of pressurizer instrumentation.
As a result of the elevated temperatures limit on stay time, a second team of I8C technicians was standing by to fill and vent the instru-mentation lines.
The first team of technicians repaired the leak more quickly than planned and called the foreman to offer to help with filling the in-strumentation lines.
These technicians did not have the applicable procedure with them.
The foreman, concerned that high containment area temperatures would limit the amount of work done by the second team of technicians, directed the technicians to shut a root valve and described the location of the valve.
But, the foreman did not refer to the procedure and did not supply the valve number, which was stated in the applicable maintenance procedure.
The valve location given to the technicians was incorrect and they closed an isolation valve for a different instrumentation line, causing a pressure trans-mitter to sense a low pressure condition.
Since another pressure transmitter had been removed from service for the leak repair, the necessary two out of three coincidence was met for an SI actuation on low pressurizer pressure.
Ginna Station Administrative Procedure (A)-503, Plant Procedure Ad-herence Requirements, Revision 16, effective May 5, 1989, requires a
copy of the procedure to be at the work location or at the location of the personnel guiding the activity, and the completed procedural steps to be signed off signifying that the action required to be im-plemented has been completed as written'ontrary to the above, on May 5, 1990, the procedure for filling and venting the pressurizer instrumentation was not in the possession of, or signed off by the person guiding the activit 'l\\
Plant management determined that the procedure should have been fol-lowed exactly, that the procedure was written correctly, and no SI actuation would have occurred if the procedure had been followed.
They concluded that the foreman knew he should have followed the pro-cedure, and his failure to do so was due to haste.
The foreman was counselled and the event and its causes were discussed with plant personnel.
To prevent recurrence, maintenance management has empha-sized procedure adherence under all circumstances and plans to re-evaluate and revise the procedure governing procedure adherence through a Task Force recently established by the plant manager (see Detail 6.7)
The inspectors concluded that, although many problems with procedure adherence have been observed in the past, prior corrective actions could not be expected to have prevented this personnel'error.
Task Force actions are not complete and, during the last few months, no other problems have been observed with procedure adherence.
NRC unresolved item 90-02-02 concerning procedure adherence programmatic weaknesses will remain open to track actions of the Task Force.
A Notice of Violation was not issued for this event.
It was licensee identified, of minor safety significance, and properly reported.
Immediate corrective measures were appropriate and actions are being taken to prevent recurrence; and no previous violations for which licensee actions should have prevented this occurrence were identified (50-244/90-05-01).
3.3 Survei1 lance Observations Inspectors observed portions of surveillances to verify proper cali-bration of test instrumentation, use of approved procedures, per-formance of work by qualified personnel, conformance to limiting con-ditions for operation, and correct system restoration following test-ing.
Portions of the following surveillances were observed:
Refueling Shutdown Surveillance Procedure (RSSP)-20,
"8" Emer-gency Diesel Generator Auto-Start Undervoltage Logic Test, Revision 0, effective April 30, 1989, observed March 29, 1990.
RSSP-2.38,
'8'mergency Diesel Generator Trip Testing, Revision 1, effective April 21, 1990, observed April 27, 1990.
RSSP-2.2, Diesel Generator Load and Safeguard Sequence Test, Revision 37, effective April 21, 1990, observed Nay 2, 1990.
During performance of the survei llances on the emergency diesel gene-rator, the inspectors noted that personnel in the control room and at the diesel generator were prepared and well informed.
Proper per-formance of RSSP-2.2 required careful coordination of the safety
l e
injection signal and the loss of bus voltage signal.
Supervisors maintained close control of activities.
When the chart recorder malfunctioned during the first test attempt, the test was immediately repeated to obtain proper documentation.
The timeliness of data review minimized the impact on plant workers.
3.4 Unresolved Item 50-244/88-16-01 Closed NRC Inspection Report 50-244/88-16 questioned performance of mainten-ance activities without the use of PORC approved procedures.
In re-sponse, RG&E committed to use PORC approved procedures for all safety-related maintenance.
Since this concern was identified, in-spectors have repeatedly confirmed the use of PORC approved procedures to control safety-related maintenance.
Based on the RGEE commitment and inspector observations, this item is closed.
4.
~Securi t During this inspection period, the resident inspectors verified that x-ray machines and metal and explosive detectors were operable, Protected Area and Vital Area barriers were well maintained, personnel were properly badged for unescorted or escorted access, and compensatory measures were implemented when necessary.
- 4.1 Fitness-For-Dut TI 2515/104 RGEE's fitness-for-duty training was reviewed in inspection report 50-244/89-17.
At that time, the inspectors were unable to conclude that escorts were trained for recognizing drugs and indications of the use, sale,-or possession of drugs.
During this inspection period, the inspectors reviewed documentation and concluded that training for escorts includes techniques for recognizing drugs and indications of the use, sale, or possession of drugs.
The inspectors had no further questions.
4.2 Access Control During the inspection period the inspectors observed measures to con-trol access to the protected area.
In particular, the inspectors monitored corrective actions for the weaknesses identified in inspec-tion reports 50-244/90-03 and 50-244/90-04.
The inspectors did not observe any additional instances of those weaknesses; RG5E corrective actions were found to be effective.
The inspectors had no further questions on these matter P I
~l
Picketin at Site Access Road On two occasions during the inspection, picketing occurred at the entrance to the plant.
From March 28-29, 1990, approximately twenty employees picketed.
On May 3, 1990, 300-400 members of the Allied Building Trades Council picketed.
In both instances picketing was about non-union hiring by contractors used by RG&E.
Picketing was peaceful on both occasions, and was monitored by RG8E security.
4.4 Monthl Meetin with RG8E Securit Mana er On April 3, 1990, the inspectors met with the RGKE security manager.
The security manager updated the status of the security upgrade pro-ject and security organizational changes.
In addition, meetings of the security upgrade task force, the computer users group, and a
Security-Engineering meeting in response to NRC Inspection Report 50-244/90-04 were discussed.
No unacceptable conditions were iden-tified.
5.
En ineerin /Technical Su ort 5.1 Refuelin Cavit Water Seals TI 2515/66 The inspectors reviewed whether the licensee has identified the worst
credible seal failure and evaluated its consequences.
Bulletin 84-03 was closed in NRC Inspection Report 50-244/84-24.
At that time, the inspector concluded that the cavity water seal used at Ginna, a
Presray PRS 585, is physically different and used in a different con-figuration than was the seal that failed at Connecticut Yankee.
Therefore, 'the consequences of the worst credible seal failure are different than those at Connecticut Yankee.
RG5E demonstrated that,,
based on testing by the seal manufacturer, Presray Corporation, the potential for seal failure at Ginna is minimal.
Leakage rates and final water levels were evaluated with a conclusion that fuel uncovery would only occur if an assembly is in the mast.
In that case operator action is necessary and is detailed in the Refueling Procedure for LOSS OF WATER FROM THE REFUELING CAVITY.
The inspectors reviewed the procedure, found it adequate, and had no further questions.
Temporary Instruction 2515/66 is closed.
5.2 PWR Moderator Dilution Re uirements TI 2515/94 The purpose of the inspection was to verify that all licensee actions with regard to their responses to the NRC Division of Operati,ng Reactors Information Memorandum No. 7,
"PWR Moderator Dilution,"
issued on October 4, 1977, have been complete By letter dated September 26, 1977, the NRC informed the licensee of an operating PWR incident involving unanticipated dilution of reactor coolant system (RCS) boron.
The September 1977 letter requested that the licensee review existing boron dilution analyses to assure that these bound all potential boron dilution events and assess factors which affect the capability of the operator to take corrective action.
The letter further requested the licensee to inform the NRC staff if, based on the results of the analyses, corrective actions are required to preclude the occurrence or mitigate the consequences of postulated boron dilution accidents.
The review of responses from operating PWRs was identified as MPA B-03'.
The licensee responded to the September 26, 1977 letter (including the concerns of the October 4, 1977 Memorandum)
by letter dated January 10, 1978.
That January 1978 letter addressed the potential for boron dilution through inadvertent draining of the spray additive tank to the RCS.
The licensee concluded that:
no single failure could result in reducing boron concentrations in the RCS or RHR system; there is no possibility for any new type of boron dilution accident; and no additional design or procedural corrective actions are required.
By letter January 25, 1979, the NRC requested additional information to include a complete review of all boron dilution mechanisms that could occur at operating PWRs.
RG&E supplemented their analyses in a
response letter of April 30, 1979.
The licensee additionally con-sidered postulated boron dilution changes due to:
( 1) boron dilution from the RCS drain tank; and (2) boron dilution due to resin changes in the purification system.
The licensee concluded that the operator would have the indication and time tn terminate an unidentified boron dilution incident prior to reactor criticality.
On April 3, 1980, the NRC Division of Operating Reactors documented (by memorandum)
a review of the licensee's submittals of January 10, 1978 and April 30, 1979, concerning the potential for unidentified boron dilution incidents.
The NRC conclusion was that the licensee has adequately analyzed the potential for unidentified boron dilution incidents at Ginna and that RG&E's submittals were acceptable.
The inspector concluded that licensee actions with regard to the PWR moderator dilution issues have been completed.
Temporary Instruction 2515/94 is closed.
5.3 Control of Modifications During the refueling outage, the inspectors reviewed selected modifi-cations to insure conformance with applicable regulations, guides and standards'ork in progress was observed to verify that modifica-tions were 'installed in accordance with approved designs, that modi-fications were completed in accordance with Technical Specification
requirements, and that procedures were revised and operator training was conducted consistent with implementation of the modifications.
Modification testing was reviewed to insure pre-test training was conducted, 'test procedures were appropriately reviewed, test results were thoroughly evaluated and reviewed by gA, and testing acceptance criteria were based on design documentation.
The inspectors also audited the modifications against:
A-301.2, Station Modification Planning Control, Revision 6, effective November 2, 1989, and A-301.3, Station Modification Installation and Acceptance, Re-vision 5, effective November 2, 1989.
Among the modifications reviewed were:
SM-3596. 1, 0/G A Pressure Instrument Panel-Mechanical Installa-tion, Revision 0, effective February 22, 1990.
SM-3596.5, D/G A Pressure Sensing Tubing, Tubing Supports, and Mechanical Removals, Revision 0, effective March 11, 1990, Work Order 9021409.
SM-3596.9, 0/G A Instrumentation Panel-Functional Test, Revision 0, effective April 6, 1990, Work Order 9021415.
SM-4230.3, Anticipated Transients Without Scram (ATWS) Mitiga-tion System Actuation Circuitry (AMSAC) Trip Status Modifica-tion, Revision 0, effective May 9, 1990, Work Order 9021539.
SM-4218. 16, Channel Check of Pressurizer Level Transmitter LT-426, Revision 0, effective April 6, 1990, observed May 4, 1990.
SM-4534. 1, Reactor Coolant Pump Motor Oil Level Indicator System Upgrade, Revision 0, effective March 1, 1990.
The inspectors discussed the modification of LT-426 with the liaison engineer and personnel performing the test.
In 1989, LT-426 was in-dicating higher than the other two level instruments.
RG&E's short-term solution was to cross-connect the reference leg of LT-426 to the reference leg of another instrument.
The permanent solution was to reconfigure the LT-426 reference leg during the 1990 annual re-fueling outage.
The inspectors reviewed the testing of the level transmitter and the data obtained, and concluded that modification testing performed on LT-426 was adequate to ensure operability of the level transmitter following reconfiguratio The inspectors reviewed the tubing modifications on emergency diesel generator EDG-B and observed the initial test run of the diesel.
EDG-B tripped on low lube oil pressure shortly after starting.
Plant personnel determined that the trip occurred as a result of failure to adequately fill and vent the new tubing.
Although a number of tubing modifications had been previously performed at Ginna, none had neces-sitated filling and venting as required in this instance.
In this case, post-modification testing revealed the requirement for filling and venting the tubing, and station personnel plan to insure that the requirement is captured in maintenance and modification administra-tive controls.
The inspectors noted that, in response to previously identified con-cerns, the Modification Follow Group and liaison engineer performed a
final review of completed modification packages to insure all modi-fication and design changes were incorporated into plant procedures and training programs.
In addition, Operations verified readiness to accept modifications, and Non-Conformance Reports were dispositioned prior to turnover.
5.4 Overall, implementation of modifications was well-controlled and thoroughly reviewed.
The inspectors noted significant improvement in this area since the 1989 refueling outage.
Violation 50-244/89-18-04 Closed This violation documented configuration control weaknesses which per-mitted implementation of modifications to the Safety Injection system and the AMSAC system without the necessary corresponding changes in procedures and operator training.
As discussed in Oetail 5.3 above, the inspectors reviewed implementation of the modification control changes required by revisions to procedures A-301.2 and A-301.3, and concluded that RG&E corrective actions are adequate to prevent recurrence.
6.
Safet Assessment/ ualit Verification 6.1 Mid-c cle SALP Meetin On April 25, 1990, RG&E management met with NRC management in the NRC Region I offices to discuss Ginna plant performance at a mid-cycle Systematic Assessment of Licensee Performance meeting.
RG&E first presented their self-assessment and status of improvements, followed by questions and comments from NRC personnel.
RG&E's presentation was well prepared and demonstrated their ability to be constructively self-critical.
The meeting handouts are appended to this inspection repor.2 Fastener Testin TI 2500/27 The inspector reviewed RG&E's January 15, 1988 response to Bulletin 87-02.
RG&E identified that, of the 40 safety-related fasteners tested in response to this Bulletin, five did not meet specifications.
In addition, five of the 40 non-safety-related fasteners tested failed to meet specifications.
As a result, an evaluation of each of the fastener deviations was performed.
The evaluations concluded that there was no effect on the safety functioning of the fasteners.
The inspector reviewed RG&E's response to the Bulletin as well as NCRs G-88-001G and G88-256, which tracked the nonconforming condi-tions for two of the fasteners.
The inspector noted that, for safety-related fastener RGE-36, which showed deviations from speci-fication requirements, RG&E found that the fasteners had not been installed in the plant and decided to discard them.
Review of non-safety-related fasteners RGE-52, 53 and 60 revealed that those fasteners were not purchased to gA requirements based on their intended use, but RG&E evaluated the deviations of the fasteners and chose to either discard them or recommend their replacement.
None of the deviations noted by the inspector were indicative of fraudulent material being supplied by a vendor.
The fastener specification deviations noted appeared to be either minor fabrication process deviations or material misclassifications.
No impact on safety-related equipment was evident.
RG&E continues to track the corrective actions taken in response to these fastener deficiencies by Corrective Action Report (CAR) 1830.
RG&E is planning, but has not yet implemented, a sampling program for fasteners to confirm that they meet specification requirements.
Im-plementation is scheduled for June 1990.
In summary, RG&E identified several deficiencies with safety-related and non-safety-related bolting materials, none of which impacted the safety-related functioning of plant equipment.
Fasteners which were identified as deficient were either disposed of, accepted as-is after engineering evaluation of their application or, for the non-safety-related appl,ication of fastener RGE-53, scheduled to be replaced as a
precaution.
In the future, RG&E plans to implement, in accordance with CAR 1830, a random sampling program for fasteners to aid in identifying any future specification discrepancies.
No other actions are planned by RG&E.
To date, the fa'stener discrepancies noted by RG&E have not had safety significance and do not indicate any attempt by vendors to supply falsified bolting materials.
The inspector con-siders RG&E's actions in response to this Bulletin to be appropriate and acceptable.
No other actions beyond RG&E's planned sampling pro-gram for fasteners appears warranted.
Temporary Instruction 2500/27 is close.3 Stora e of Transient E ui ment RI TI 87-03 The inspectors reviewed licensee controls for storage of transient equipment having the potential to adversely affect safety-related equipment.
Among the documents reviewed were:
Administrative procedure A-3. 1, Containment Storage Inspection, Revision 13, effective June 19, 1989.
A-1406, Control of Temporary Modifications, Revision 4, effec-tive July 14, 1989.
Procedure A-3. 1 establishes guidelines for equipment storage require-ments inside containment during reactor operation.
The procedure incorporates provisions to limit equipment stored in containment, and to insure equipment is restrained with a chain or wire rope capable of supporting the equipment's dead weight.
In addition procedure A-3. 1 requires that items stored in containment must be positioned so that they are at least one and,one half times their maximum height from safety-related equipment or equipment important to safety.
The inspectors have consistently noted that the materials stored were very well secured.
Procedure A-1406 provides control over temporary modifications in-cluding restraint of temporary equipment within close proximity to safety-related equipment.
The requirements for restraint of tempor-ary equipment are equivalent to those contained in procedure A-3. 1.
Ouring the outage, the inspectors assessed the effectiveness of pro-cedures A-3. 1 and A-1406.
In particular, the inspectors inspected containment on Ma> 3, 1990, immediately prior to containment closeout on May 4, 1990.
The temporary items observed during the tour were restrained as required by procedure.
The inspectors also noted that, in response to a concern about contamination control, the floors in the upper level of containment were painted, on short notice, immedi-ately prior to containment closeout.
The inspectors concluded that the program for control of transient equipment was aggressive, effective, and demonstrated a management commitment to safety.
In addition, RG5E was responsive to the con-cernn regarding the condition of the paint on the containment floor, and promptly repainted the floor.
Region I Temporary Instruction 87-03 is closed.
6.4 Oiesel Generator Fuel Oil ual it Assurance TI 2515/93 The purpose of the inspection was to verify that the licensee con-trols the quality of diesel generator fuel oil for the plant diesel generators in accordance with their Quality Assurance (QA) Program under
CFR 50, Appendix B.
The inspector's review was sufficient to assure that diesel generator oil is presently included in the RG5E QA Program under
CFR 50, Appendix B requirement Cl h
The inspector reviewed the licensee's QA documents pertaining to the control of purchased items.
In particular, the inspector reviewed RG&E's QA Program for Station Operation, Revision 15, December 28, 1989, Criterion VII; and QA Manual, Revision 19, December 8,
1989, Section 7, entitled Control of Purchased Material, Equipment, and Services.
Both RG&E documents establish the requirements, assign the responsibilities, and describe the system for assuring that items purchased directly through subsuppliers conform to procurement docu-ments.
The diesel generator fuel oil manufacturers, however, do not appear on the RG&E Commercial Grade Suppliers List (CGSL) as a means of achieving dedication of this commercial grade item.
In the case of diesel generator fuel oil, verification of the quality is accom-plished by sampling the purchased source and having it analyzed by a
certified laboratory.
The test results (report) verify conformance to the procurement documents and become the primary method of achiev-ing dedication of this commercial grade commodity used in a safety-related application.
Offsite Stora e
All fuel oil tends to degrade during extended storage.
The degrada-tion, in general, is if two types.
The first, oxidation and poly-merization, results in formation of soluble and insoluble gums.
The second, bacteria growth at the interface of the fuel and any water in the storage tank, results in clumps of bacteria in the fuel.
Both degradation mechanisms lead to fuel filter plugging.
The offsite storage tank facility (receiving storage)
is located at Brooks Avenue.
The purchase order requires'o.
2 diesel oil to meet the ASTM D-975, Standard Specification of Diesel Fuel Oils.
Acquisi-tion of the Na.
2 diesel fuel oil samples for laboratory testing to meet ASTM standards are controlled by RG&E procedures CGIEE 90-001, Attachment B, Revision 1,
and Attachment C, Revision 2, which allow dedication of the entire quantity of diesel fuel oil in the RG&E off-site bulk storage tank farm.
When additional deliveries of No.
diesel fuel oil are received, either the delivery quantity is sampled in accordance with Attachment B, or the whole tank is resampled in accordance with Attachment C:
Currently RG&E uses the Herguth Labor-atories of Vallejo, California, under contract, for sample testing services.
The following tests are performed by the Herguth Labora-tories:
(1) Cetane Number per ASTM D-976; (2) Ash, percent weight, ASTM D-482; (3) Distillation, ASTM D-86; (4) Initial Boiling Point, 10 percent, 50 percent, 90 percent, and end point; (5) Recovery, per-cent; (6) Sulfur, percent weight, ASTM D-2622; (7) Viscosity, ASTM D-445; (8) Carbon Residue, ASTM D-524; and (9) Water and Sediment, ASTM D-1796.
For each sample Herguth Laboratories provides a certi-ficate of analysis for the above information.
All quality documen-tation is attested, by the RG&E Nuclear Assurance and Quality Per-formance Departments, to meet ANSI N45.2-1971 'G&E also performs a commercial grade item engineering evaluation and documents the basis for determination of critical characteristics for acceptanc e Cl
Onsite Stora e - Recei t Ins ection The Quality Control (QC) inspection and acceptance of delivery from the Brooks Avenue fuel farm to the onsite fuel oil storage tanks are controlled by RG5E procedure QCIP-6 (original).
The procedure re-quires a review of the delivery ticket supplied by the truck driver with the shipment to ensure that the correct chemical analysis report issued by Herguth Laboratories is referenced.
The QC inspection re-port documents that the analysis meets acceptance criteria outlined in Technical Specification 4.6. l.c (ASTM 0-975-1978, Table 1) with regard to viscosity, water and sediment.
Also, the report documents that a visual inspection has been performed prior to unloading the truck.
The above documents were reviewed by the inspector and found acceptable.
Onsite Stora e - Technical S ecification Re uirements Technical Specification 4.6. l.c requires verification, at least once every 92 days, that a sample of diesel fuel oil from the onsite fuel oil tank supplying the diesel generator s be within limits recommended by ASTM 0-975, Table 1; when checked for viscosity, water and sedi-ment.
The analysis is performed by the RG&E Chemical/Environmental Laboratory.
The inspector reviewed the report for July 19, 1989, which was acceptable.
No history of receipt of unacceptable fuel is evident.
Temporary Instruction 2515/93 is closed.
6.5 Periodic and S ecial Re orts Upon receipt, periodic and special reports submitted by the licensee pursuant to Technical Specifications 6.9. 1 and 6.9.3 were reviewed.
This review included whether the reports contained information re-quired by the NRC, test results and/or supporting information were consistent with design predictions and performance specifications, and reported information was valid.
The following report was re-viewed:
Monthly Operating Report for March 1990.
No unacceptable conditions were identified.
6.6 Written Re orts of Nonroutine Events 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
Cl e
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 LERs were reviewed (date indicated is event date):
90-001,
"Technical Specification Fire Watch Patrol Established, But Did Not Perform Tour at Least Once per Hour Oue to Personnel Error," February 25, 1990.90-002, "Fire Watch Patrol Performed Technical Specification Hourly Patrol in the Wrong Areas Due to Personnel Error,"
February 26, 1990.90-003,
"Higher Than Normal Count Rate on Source Range NIS, Oue to a Faulty Detector, Causes a Reactor Trip During Source Range Reenergization,"
March 23, 1990.
The reports met regulatory requirements.
The events and corrective actions were reviewed in NRC Inspection Report 50-244/90-03 and were found acceptable.
6.7 Procedure Adherence Task Force In March 1990, the plant manager established a task force to address problems associated with procedure adherence, system alignments, in-dependent verification, and their repetitive nature.
During meetings the focus of the task force members, including plant managers and superintendents, has been on programmatic issues.
In the several meetings held to date, the task force has discussed training improve-ments for administrative procedures regarding procedure adherence and independent verification, and feedback from workers concerning the process.
Current plans are to have revisions out to the appropriate administrative procedures within the next few months.
The inspectors observed that the task force meeting on March 29, 1990 was well attended by plant management.
Discussions were open and candid, with good participation by all members.
The inspectors con-cluded that the Procedure Adherence Task Force meetings demonstrate a
management commitment to resolution of procedure adherence weaknesses.
6.8 Submittal of ualit Assurance Pro ram Oescri tion During this period the licensee submitted Revision 15 of the Ginna Quality Assurance Program (QAP) for review, pursuant to
CFR 50 '4(a)(3).
The revision is being reviewed in the Region I offic la e
7.
Admini strati ve 7.1 Licensee Activities At the start of the inspection period, the plant was shut down for the annual refueling outage; shutdown from full power had been com-pleted on March 23, 1990.
Major outage activities accomplished in-cluded:
annual refueling, 'B'eactor coolant pump replacement, steam generator tube sleeving and plugging, midloop instrumentation upgrade, fuel assembly reconstitution, and a major valve preventive mainten-ance effort.
During fuel reconstitution on April 6, 1990, a small set screw was found in an assembly.
The set screw and four fuel rods damaged by it were removed and the damaged fuel rods were replaced with dummy fuel rods.
On April 14, 1990, during core reloading, a 3.5 inch long bolt was found on the lower core plate.
The bolt was removed from the vessel, and further inspection was conducted with negative re-sults.
These two foreign objects are addressed in NRC Inspection Report 50-244/90-06.
Refueling of the core was completed on April 15, 1990.
On May 5, 1990, with the plant in hot shutdown, an inadvertent safety injection occurred due to personnel error; all systems responded as expected.
The reactor was brought critical on May 6, 1990, and the turbine generator was synchronized to the grid on May 7, 1990.
At the close of the inspection period, operators were slowly raising plant power.
7.2 Licensee Res onses to NRC 'Ins ection Re orts The NRC acknowledges receipt of RG&E's responses (3-26-90, 4-5-90)
detailing corrective and preventive actions for the violations iden-tified in Inspection Reports 50-244/89-17 and 50-244/90-02.
These actions will be examined during future inspections.
7.3 Exit Meetin s
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 inspection.
Additionally, the following NRC exit meetings were held during this inspection period:
50-244/90-04 on March 24, 1990; 50-244/90-06, 90-03, 90-08 and 90-80 on April 20, 199 NRC Meeting April 25, 1990 Mid Cycle SALP Assessment Agenda I. Introduction Smith II. SALP Categories A.
Plant Operations B.
Maintenance/Surveillance C.
D.
E.
F.
G.
Radiological Controls Emergency Preparedness Engineering/Technical Support Security Safety Assessment/Quality Verification Spector Spector Mecredy Mecredy Snow Powell McCoy III. Summary and Conclusions Smith
Operations Evaluation of July 1989 SALP Stren ths Morning Priority Action Required MoPAR daily staff meeting Support of degreed college program Well qualified operators exhibit consistent good performance Human Performance Evaluation System HPES utilization Sixth shift utilization New license training Label program Concerns Inconsistent management oversight and control Housekeeping
.
Independent verification - system alignment Fire protection training Disposition of EOP change requests Positive MTC training Modification training Commitment tracking Label verification Overall Rating of "2"
Operations Current Assessments Stren ths MoPAR daily status books College degree program other sections participating EOPs and implementation dedicated full time SRO Simulator training utilization of normal control room grouping Control room professionalism and control and command New license training HPES system being utilized station wide Develo in Stren ths Housekeeping policy, enforcement and management tours Labeling program and verification Modification training Positive MTC training Communications - guidelines and training Fire brigade training
ortunities for lm rovement Recertification of licensed training programs System lineups and independent verifications
Maintenance/Surveillance Evaluation of July 1989 SALP Stren ths Strengthened management through reorganization Control of outage related maintenance and surveillance Staffing levels Technical competence and pride in performance Control of physics testing Responsiveness to identified weaknesses Operational implementation of IST procedures Concerns Component aging program.
Formal preventive maintenance for off site power sources Programmatic control of preventive maintenance Lack of cooperation with QP organizations Procedure quality and adherence Manual tracking system of outstanding work Q-List IST program omissions Lack of supervisory observations Overall Rating of "2"
Maintenance/Surveillance Current Assessment Maintenance Stren ths Positive attitude of workers
- Long term maintenance strategy
- Continued organizational optimization Develo in Stren ths
- Preventive/predictive maintenance through RCM program
- Post maintenance testing
- Calibration procedures upgrade - in use this outage Performance indicators - involvement in NRC and NUMARC programs Utilization of independent assessments cooperation with quality organization
- Work control system Material Condition of plant equipment
- Equipment history maintenance and utilization
- Staffing implementation particularly in maintenance planning
- Computerize work order tracking system
ortunities for Im rovement
- Maintenance procedure upgrades Maintenance training program Maintenance facilities and equipment Material condition of buildings and structures Items on independent verification/system alignment covered under operations.
- Covered in February 1990 maintenance presentation
Maintenance/Surveillance Current Assessment Supporting Areas Stren ths ISI and secondary erosion corrosion All supporting groups involvement in maintenance strategy develop-ment Spirit of cooperation between Maintenance and all groups (HP, QP, Technical Support)
Develo in Stren ths Procurement technical requirements Commercial Grade Dedication Program IST program control Modification control enhancements continued enhancements expected
ortunities for Im rovement Shelf Life Program Material storage control Check valve position verification
RADIOLOGICAL CONTROLS EVALUATION OF JULY 1989 SALP Stren ths Pretesting to evaluate and screen contract HP technicians Training of radiation workers, particularly practical factors Control of secondary chemistry Implementation of ALARA program in 1988 Weaknesses Timeliness of corrective actions QC surveillance of chemistry activities Management oversight of field activities ALARA planning during 1989 outage Overall Rating of "2"
A
Radiological Controls Actions to Im rove Enhanced ALARA pre-planning with revision to Engineering Procedure QE-310 and through additional formality to ALARA pre job briefings and recommendations Upgraded training to radiological workers through G.E.T.
and to H. P. Technicians Established job coverage guidelines for H.P. Technicians Upgraded and expanded Radiological Incident Report system including ties to the Corrective Action Report system and Training l
Emphasizing the need for increased supervisory presence in the field Established 1990 person-rem and contamination goals, including through Corporate Goals system (Plan 90)
Adding
RG&E H.P. Technicians Strengthened and focused activities of corporate support staff Utilizing outside technical expertise to provide independent assessments Added Chemistry Q.C. position Constructing new Training facility, which will house Environ-mental Laboratory
Radiological Controls Current Assessment Stren ths Continuing strengths from 1989 Management
'and staff focus on importance of good radiological controls practices Results of ALARA planning, to date, in 1990 outage Areas for continued im rovement Need to improve consistency of compliance with upgraded standards of performance Need to evaluate improvements in standards of performance Need to continue to improve management and supervisory oversight of field activities Need to implement corrective actions, e.g.
locked hi radiation area gates
R.E. Ginna Nuclear Power Plant 1990 Skin 8 Clothing Contaminations as of 4/22/90 300 250 200 150 100
Number of Contaminations
10
20
30
40
Week 5052 Actual Estimated 5000 D P M/100c m 2
J
'
e
UPDATED WEEKLY GINNA. STATION EXPOSURE FOR I 990 c/n/go 4N A
N R
E 200 M
100 80. 7%
1 990 GOAL ACTUAL 480 JUN JUL NOV DEC e USlNG OFRCIL DOSE FOR JAN MhR MONTH OF APRIL 1990 OUTAGE GOAL: 440 man-rem OUTAGE R
A ~
N R
N l4 A
maaTE N
~ hClUAL R
E M
295 PAGE 1.)A
ALARA TRACKING ggppp6p B RCP INSULATION
/~++iX>V'gl e
R E
V 20~
15 3
$ 0
0 16.1 E3 ESTIMATE EZl ACTUAL AS OF 4/21
&5
75
65
55
45
30
20
10
0 ALARA TRACKING 9004XX A STEAM GENERATOR WORK 88.9 75.7 IZ3 ESTIMATE I%I ACTUAL AS OF 4/21
J
'!)
L,
ALARA TRACKING $9005XX B STEAM GENERATOR WORK
60
50 M
A
N R
E
M
10
56.17 KS ESTIMATE IZ3 ACTUAL AS OF 4/21
EMERGENDY PREPAREDNESS EVALUATION OF JULY 1989 SALP Stren ths Excellent EP Program Concerns Procedure for iodine sampling Staffing Overall Rating of <<1<<
Emergency Preparedness Actions to Im rove Emergency Preparedness initiatives included in Public Safety Strategy Implementation.
Advance replacement for Corporate Nuclear Emergency Planner selected and in position.
Former Shift Supervisor Will be filling Onsite Emergency Planner position shortly.
Offsite procedures being consolidated into Plant PORC approved Emergency Planning Implementing Procedures (EPIPs)
series.
Event classification procedure (SC-100)
being revised.
Unified designation system for offsite survey team locations being implemented.
Training of all groups coordinated through Division Training.
Assessing use of new Training Center as staging area to reduce OSC congestion.
Developing a Portable Portal Monitor with SAIC for use at Relocation Centers.
Utilizing outside technical expertise to supplement audit Emergency Preparedness Current Assessment Stren ths Dedication of management, EP Staff and all employees in maintaining a high level of emergency preparedness.
Excellent spirit of cooperation with State and Local Governments in maintaining a high level of Emergency Preparedness.
Pro'ects to be Com leted Procedure enhancements.
Onsite Emergency Planner.
Training and preparations for 1990 Exercis I
April 25, 1990 Page
B.A. Snow NRC/RGE MEETING MID-CYCLE SALP II-E ENGINEERZNG AND TECHNICAL SUPPORT RGGE UNDERSTANDING OF JULY 1989 SALP STRENGTHS FORMATION OF SEPARATE CORPORATE NUCLEAR ENGINEER ING DEPARTMENT STAFFING ADDITIONS INNOVATIVE DESIGNS (S/G BUMPERS)
S/G INSPECTION AND SLEEVZNG TECHNICALLY CAPABLE ENGINEERING STAFF CONCERNS ENGINEERING SUPPORT OF IST PROGRAM TRANSFER OF INFORMATION REGARDING MODIFICATIONS TO THE OPERATORS
CFR 50.59 PROCESS TIMELY MODIFICATION PACKAGES ENGINEERING PROGRAMS AND PROCEDURES OVERALL RATING "2"
J
'5
April 25, 1990 Page
B.A. Snow NRC/RGE MEETING MID-CYCLE SALP II-ENGINEERING AND TECHNICAL SUPPORT ACTIONS TO IMPROVE ENGINEERING SUPPORT TO IST FORMALLY ASSIGNED TO MECHANICAL ENGINEERING DEDICATED ENGINEER OVERSIGHT COMMITTEE IMPROVED PROGRAMS/PROCEDURES IMPROVED TURNOVER PROCESS MOD FOLLOW GROUP CHECK AT TURNOVER
- OPERATIONS MANAGER SIGNOFF IMPROVED TRAINING INFORMATION CONTROL
CFR 50.59 PROCESS ORGANIZATIONALTIES, ENG/GINNA INTEGRATING TECHNICAL REVIEWS MAINTENANCE WORK CONTROL/MODIFICATIONS IDENTIFIED TIMELY MODIFICATION PACKAGES IMPROVED ENGINEERING MANLOADED SCHEDULING PROCESS CUT OFF DATES/MGMT APPROVAL ENGINEERING PROGRAMS AND PROCEDURES INTERIM PROCEDURE CHANGES
- NEED PROCEDURE UPGRADE PROGRAM (SCOPE~
SCHEDULEg AND PLAN)
APRIL 25, 1990 PAGE
B.A.
SNOW NRC/RGE MEETING MID-CYCLE SALP II-E ENGINEERING AND TECHNICAL SUPPORT CURRENT ASSESSMENT STRENGTHS CONTINUATION - STRONG TECHNICAL STAFF/STAFFING ADDITION PROGRAM PROGRESSING CONFIGURATION MANAGEMENT WORKING ON INTEGRATED SCHEDULE PER PREVIOUS PRESENTATIONS SIGNIFICANT PROJECTS INCLUDE:
Q-LIST PQIDs ELECTRICAL DRAWING UPGRADE VENDOR MANUAL PROJECT CALIBRATION PROCEDURES SETPOINT VERIFICATION MAINTENANCE PROCEDURE UPGRADE STANDARD NOMENCLATURE PROJECT CMIS
April 25, 1990 Page
B.A. Snow NRC/RGE MEETING MID-CYCLE SALP II-E ENGINEERING AND TECHNICAL SUPPORT STRENGTHS ENGINEERING SERVICES UALITY PERFORMANCE QUALITY PERFORMANCE INDICATORS (SAMPLE ATTACHED)
AFCARs
- CARs
- ECNs FCRs
- IDRs
- NCRs ENGINEERING QUALITY REVIEW COMMITTEE ENGINEER SUPPORT TO SECURITY (TWO ENGINEERS ASSIGNED)
ENGINEERING FORMALLY INCLUDED IN PROCUREMENT PROCESS (COMMERCIAL GRADE DEDICATION)
April 25, 1990 Page
B.A. Snow NRC/RGE MEETING MID"CYCLE SALP II-E ENGINEERING AND TECHNICAL SUPPORT OPPORTUNITY FOR IMPROVEMENT COMMUNICATIONS - ENGINEERING/GINNA INSPECTION REPORT 89-17 PROCEDURE UPGRADE EKDNCES EXISTING SYSTEMS STRESSES TIMELINESS TO IMPROVE COMMUNICATIONS, ON-SITE ENGINEERING PERSONNEL PROCUREMENT SUPPORT PROCEDURES UPGRADE PROGRAM NEEDED OBJECTIVE TO PROVIDE ENGINEERING ASSURANCE DESIGN STANDARDS FOR ENGINEERING DISCIPLINES
NRC/RGE MEETING HID-CYCLE SALP II-E ENGINEERING AND TECHNICAL SUPPORT April 25, 990 Page
B.A. Snow ROCHESTER GAS 8c ELECTRIC CORPORATION NUCLEAR ENGINEERING SERVICES 1 st Quarter, 1 990 Workload Overview CF)
CA I
I Lx LsJ CCI
- >C>O IOO-l Q 50-2D STATU S M INPROCESS ER COMPLETE Al '
- >"-.l~ c"..I-..'r t I
I I=i:F.
I DR NC-'R ENDING 1 ST QTR, 1 990
NRC/RG&E MEETING MID-CYCLE SALP APRIL 25,1990 SECURITY
SECURITY SALP FINDINGS JULY 1989 STRENGTHS EFFECTIVE ONSITE FORCE SUPERVISION OF PERSONNEL-RELATED ASPECTS OF SECURITY PROGRAM STRONG TRAINING PROGRAM GOOD MORALE LOW TURNOVER POSITIVE ATTITUDE TOWARD SECURITY BY PLANT PERSONNEL WEAKNESSES POSSIBLE LACK OF MANAGEMENT OVERSIGHT OF NEED FOR SECURITY SYSTEM UPGPZJ3ES AND MODERNIZATION CONTRACT SECURITY FORCE STAFFING LEVELS PROPRIETARY NUCLEAR SECURITY STAFF LEVEL SECURITY PLAN OUTDATED PHYSICAL SECURITY SYSTEMS AGING VERALL RATING n2n
l
SECURITY REMEDIAL ACTIONS UNDERTAKEN AND ONGOING CONTRACT SECURITY FORCE INCREASED REORGANIZATIONAND INCREASE ZN PROPRIETARY SECURITY STAFF SECURITY PLAN REVISION PHYSICAL SECURITY SYSTEMS UPGRADE ALL CCTV TUBE TYPE CAMERAS REPLACED E-FIELD SYSTEM BEING MODIFIED AND ENHANCED SYSTEM REVIEW AND EQUIPMENT UPGRADE
RISK MANAGEMENT MANAGER T.J. Powell 1 SECRETARY DIRECTOR.SECURITY W.K. Dillon DIRECTOR.CLAIMS DJ. Maher DIRECTOR.INSURANCE G.W. Vanlngen 1 CLERK TYPIST 1 TRAINEE SUPERVISOR NUCLEARPLANTSECURITY R.E. Wood SUPERVISOR INVESTIGATION RA. Stein COORDINATOR NUCLEARSECURITY TRAINING MJ. Fowler NUCLEAR ACCESS AUTHORIZATIONADMINTR.
5J. Eckert INVESTIGATOR THEFT OF SERVICE J.R. Ehrhart. II STAFF INVESTIGATORS THEFT OF SERVICE S.G. Beechey L.E. Maring CLAIMSREPRESENTATIVE BJ. Eitto STAFF INVESTIGATOR R.W. Brown P.W. Sullivan INSURANCE ANALYST L.C. Estep 1 TRAINEE EXEMPT
NON-EXEMPT
TOTALEMPLOYEES
10/1/89 1 FIEI.D INVESTIGATOR 2 CLERK TYPISTS DEPT. //22
SUPERVISOR NUCLEAR PLANT S ECURITY R.E. Wood COORDINATOR NUCLEAR SECURITY TRAINING MJ. 1-osier NUCLEAR ACCESS AUTHORIZATIONADMINTR.
S.J. Eckert 1 TRAINEE 44aa
~
"ONTRAC SECURITY St.PERVISOR CONTRACT TRAINING SUPERVISOR CONTRAC SECURITY OFFICERS UCLEAR SECURITY ORGANIZATION 1/12/90 vLD
SUPERVISOR NUCLEAR SECURITY NUCLEAR SECURITY OPERATIONS COORDINATOR (1) (New)
NUCLEAR SECURITY TRAINING COORDINATOR (1) (Existing)
NUCLEAR ACCESS AUTHORIZATION ADMINISTRATOR (1) (Existing)
SITE SECURITY SUPERVISOR (Contract)
SECURITY TRAINING SUPERVISOR (Con tract)
ACCESS CONTROL CLERK (1) (Existing)
CLERK TYPIST (1) (New)
NUCLEAR SECURITY SYSTEMS SPECIALIST (1) (New)
CONTRACT SECURITY OFFICERS I 8 C
SPECIAL PROJECTS PfRSONNEL
0
Safet Assessment/ ualit Verification RG&E litotes for Mid-Cycle SALP Review April 25, 1990 RG&E Quality Performance Department 4/24/90
Jul 1989 NRC SALP Evaluation of Safet Assessment/ ualit Verification RG&E understanding of July 1989 NRC SALP evaluation:
Stren ths Licensing activities are of high quality (generally timely, technically sound, complete).
Senior management involvement is a strength (for technical issues, promulgation of policy, etc.=-).
A change in corporate philosophy resulted in initiation of programs.
Areas ior Im rovement initiatives to improve quality organization credibility and utilization lost momentum when the QA/QC Director left the company in April 1989.
QA department ineffectiveness was evidenced by poor corrective actions in some instances and failure of audits to identify problems.
QA is not an effective tool of management.
Overall Rating of "2", with comments of concern expressed at August 1989 meeting.
NRC recommended a meeting to discuss RG&E's approach to assure that the quality organization will be effectively used as a management tool (completed October 24, 1989).
Comments Concernin Licensin Activities Durin the SALP Period
0
Continued strength in high-quality and generally timely responses to NRC communications (Rules, Generic Letter, Bulletins, etc.
).
Some Tech Spec revisions took a long time to process at RG&E.
Good communication between Licensing and NRR Project Manager.
Timely coordination of ISI/IST submittals and relief requests.
Continuation of licensing enhancements for better integration of Plant/Engineering:
Q-list Vendor Technical Manuals Integrated Commitment Tracking PRA
The addition of 8 engineers in Nuclear Safety and Licensing (2 by July, 6 conte.ngent upon PSC rate case approval), with 2 working on licensing matters, will allow:
More timely communication between Engineering and Plant staff on potential problem areas (e.g.,
Control Room Switch)
Accelerated license amendment submittals Comprehensive discrepancy resolution system, addressing CM/DBD findings
Actions to Xm rove A Effectiveness Since Ma 1989 o New Quality Performance Department formed ( July 1989 ).
Combined QA/QC department with Materials Engineering and Inspection Services section.
New department manager and site QC manager.
Established two new positions:
Senior Quality Performance Analyst and QC Inspection Foreman.
o Staff expansion plan approved (October 1989).
QA/QC sections to grow from 22 RGGE employees to 41 employees by 1991, with less dependence on contractors.
(Two thirds of the new positions contingent on July 1990 rate case approval.)
RG&E employees in QA/QC now total 25, with 4 additional job offers accepted.
o QA Surveillance program implemented (January 1990).
Increase performance-based monitoring capability, supplementing more structured QC inspection/surveillance and QA audits.
5 pilot QA Surveillances completed in 1989, 15 in first quarter 1990, and goal is 25 per quarter by end of 1990.
o Management/QA communications have improved.
Meetings oi QA/QC Subcommittee to NSARB have improved, with agendas focusing on big issues, better presentations, and distribution of a meeting notebook a week before the meetings.
Department Manager serves on Sr.
VP Production and Engineering Staff, vs. direct report to Presiden Alps
'4
\\
Department Manager has initiated joint management assessments with line management (e.g.,
forced outage critique; management effectiveness of meetings, task forces, and horizon of calendars; and staffing study).
Line management is making more requests of the QA group, particularly to review special issues in audits and survej.llances.
o Line organization/QA working relationships are improving, as QA/QC sections work to go beyond problem identification to become "part of the solution".
Credibility of the organization has increased with new personnel, management endorsement, and the expansion of the organization.
Examples of becoming "part of the solution" working with line organizations:
A QA engineer supported of new site modifications contractor quality program implementation (October 1989).
ii.
A technical coordinator to aid NSARB improvements and administration was assigned from the QA group (October 1989).
iii. The senior quality performance analyst has assisted the line organizations in software development of tracking systems (March 1990).
iv.
A senior-QA engineer was assigned to the maintenance organization for the annual outage (February 1990).
The improvement in working relationships is greatest in the upper levels of the organization, with less impact at the working leve Some Successes in Identif in and Initiatin Fixes to Problems The QA/QC sections personnel take considerable pride in their contributions to improved quality at Ginna.
When asked in a recent survey what were their most significant contributions in the past year, many QA/QC employees described programmatic improvements while others cited problem identification, with some examples of problems uncovered listed below:
Audit by an Associate QA Engineer of ISI program in Fall 1989 uncovered several pressure testing issues needing resolution before the end of the second ten year interval, resulting in retest at this years outage in one instance.
During QC Surveillance of steam generator tube sleeve ultrasonic testing, contract QC inspector noted that one tube was missed, when another was rested twice, resulting in retest and improvements to reduce confusion during shift turnover.
During QC Surveillance of safety-related service water pump repair, contract QC inspector noted use of non-QA material and no weld procedure, which was immediately corrected.
During QC surveillance of diesel generator modification during annual outage, a
QC inspector discovered an omission of independent verification and incomplete leakage testing before turnover to operations for acceptance testing.
A QC inspector, focusing on consumables/chemical controls, noted that the aahesive heat tracing fiberglass tape applied in a modification to the stainless steel boric acid piping had not been qualified for chemical compatibility.
Some QA/QC employee responses praised the efforts of individuals in the line organization who made significant improvements to quality during the past year.
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RG&E View of Safet Assessment/ ualit Verification Effectiveness for the Current SALP Period Stren ths o
Continuing strengths from the previous SALP period are the high quality of licensing activities and the strong involvement of senior management in technical and policy issues.
o The cultural change to embrace "quality" in a broad sense, including more structured control of activities, has been accepted at the manager level and is now gaining wider acceptance in the balance of the experienced, well-qualified organization which formerly relied too much on informal controls.
o Significant improvements have been made to the quality program, including a stronger organization, better communication of issues to management, and more extensive utilization of the organization by management.
Areas for Im rovements o
While self-identification of problems has improved, some issues continue to be identified first by outside agencies.
Examples are:
Control of scaffolding modifications (IR 89-16).
Assuring fire brigade staffing commitments are met (1R-89-14).
Eating in HP counting room (IR 89-23 and INPO 6/89).
Dosimeters worn below waistline (IR 90-01).
o For identified problems, the time and resources required to remedy the problems are sometimes underestimated.
Target completion dates for activities are consequently missed, lowering the credibility of commitments to improvement reflected in the Ginna Strategic Plan and in discussions with outside agencies.
o The quality organization has developed topical analyses of quality performance indicators, but parameters for periodic trending have yet to be selected and routinely distributed for management oversigh NRC MEETING APRIL 25, 1990 MID CYCLE SALP ASSESSMENT CONCLUSIONS
-
GOOD NUCLEAR SAFETY AND OVERALL PLANT PERFORMANCE
- MANAGEMENT COMMITMENT TO PERFORMANCE EXCELLENCE
- POSITIVE CULTURAL CHANGE TOWARD IMPROVEMENT
-
PROGRAMMATIC IMPROVEMENT
- EMPHASIS ON FIRST LINE SUPERVISOR
-
IMPROVXNG TREND QUALITY PERFORMANCE
-
CORPORATE MANPOWER AND FINANCIAL COMMITMENT
- SENIOR MANAGEMENT INITIATIVES 1990
RGKE CORPORATE COMMITMENT TO NUCLEAR QUALITY IMPROVEMENT o
IMPLEMENTATION OF STRATEGIC PLAN A
SI6NIFICANT COMMITMENT TO IMPROVED 6INNA PERFORMANCE o
PROGRAMS INlTIATED INCLUDE:
CON FI6URATION MANAGEMENT Q LIST MAINTENANCE PROCEDURE UPGRADE ADMINISTRATIVE PROCEDURE UPGRADE PLANT BETTERMENT 5G.59 REVIEW PROCESS COMMITMENT TRACKING PROCUREMENT UPGRADE RELIABILITY CENTERED MAINTENANCE o
INCREASED 0 5 M AND CAPITAL EXPENDITURE LEVEL o
INCREASED MANPOMER COMMITMENT TO SUPPORT GINNA
E J
ft
Ginna 08 M Expenditures 1986-1992
Millions of $
50
30
10 1986 1987 1988 1989 1990 1991 1992 March 14, 1990
~ ACTUALS K3 BUDGETED
{Includes 42,43,49 8 50)
with benefits
Qf
Ginna Station Capital Expenditures 1986-1992 Millions of 4
40
20
198 B 1987 1988 1989 1990 1991 1992
~ AGTUALS E2 BUDGETED March 8, 1890
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Nuclear Staff Complement Plan October 1989 July 1991 800 700 600 500 400 300 200 100-610 460 640 545 690 595 Oct
Jul
Jul
W RGRE Employees H Contractors March 26, 1990
V ()
1990 SENIOR MANAGEMENT INITIATIVES o
IMPLEMENT NUCLEAR DIVISION MANPOWER RESOURCE PLAN BY DECEMBER 1990 o
IMPLEMENT 1990 STRATEGIC OBJECTIVES o
ENHANCE CAREER DEVELOPMENT AND SUCCESSION PLANNING WITH NUCLEAR DIVISION SUCCESSION PLANNING EDUCATION AND TRAINING CURRICULUM SUPERVISOR AND PROFESSIONAL SKILLS TRAINING o
ENHANCE QUALITY PERFORMANCE
{QA/QC) EFFECTIVENESS PERFORMANCE BASED SELF ASSESSMENTS NSARS AND OA/QC SUBCONM1TTEE MANAGEMENT EFFECTIVENESS QUALITY PERFORMANCE OPERATION PLAN FOR 1990
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