IR 05000244/1990010
| ML17261B107 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/11/1990 |
| From: | Bessette D, Caphton D, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261B105 | List: |
| References | |
| 50-244-90-10, IEIN-87-004, NUDOCS 9007240159 | |
| Download: ML17261B107 (21) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.:
Docket No.:
50-244/90-10 50-244 License No.:
DPR-18 Licensee:
Rochester Gas 5 Electric Company 49 East Avenue Rochester, New York 14649 Facility Name:
R.
E. Ginna Nuclear Power Plant Inspection At:
Ontario, New York Inspection Conducted:
June 4-8, 1990 Inspectors:
Donald L. Caphton, Senior Technical Reviewer Date Carl H. Woodard, Reactor Engineer
II rgy Date Approved by:
~J D. Bessette, Chief, Operational Programs Section, OP, ORS 7 neo Date Ins ection Summar
Routine Unannounced Ins ection on June 4-8 1990 Ins ection Re ort No. 50-244/90-10 Areas Ins ected:
Review of the licensee implementation of 10 CFR 50.62 pertain-ing to ATWS Rule, QA audit program implementation, the program to assure the quality of emergency diesel generator (EDG) fuel oil and actions taken on previously identified items.
Results:
The licensee completed the ATWS Mitigating System Actuation Circuitry (AMSAC) installation during the 1989 Ginna refueling outage and completed several improvement modifications to the AMSAC during the 1990 refueling out-age.
Within the inspected areas, the AMSAC installation was found to be responsive to the ATWS Rule,
CFR 50.62.
The licensee was found to not have management control and operability requirements established for the AMSAC.
The licensee's program to maintain adequate quality of emergency diesel generator (EDG) fuel oil was inspected and found to be adequate.
Within the area 9A<37240159 9007'L~"
FDR ADGC~
C> 009244 lg r-DC
I
~
reviewed, the licensee's gA audit program implementation was found to be in conformance with commitments and requirements.
No violations were identified; two unresolved items were identified (see para-graph 2.2)
as follows: 1) the verification of AMSAC cable separation at one location, and 2) acceptability of independence between the AMSAC power supply and Class lE circuitr (
DETAILS OF INSPECTION 1.0 Persons Contacted Licensee Re resentatives
"S.
Adams, Technical Manager R. Baker, Electrical Design Engineer (AMSAC Design)
- M. Cauanaugh, Fire Protection Engineer D. Filkins, Manager, Chemistry and Health Physics
-*T. Harding, Modification Support Coordinator L. Hubbard, Laison to Training
- M. Lilley, Manager, Nuclear Assurance L. Smith, Operations Supervisor J. Ostroot, QA Engineer
- J. St. Martin, Corrective Action Coordinator
'J.
Widay, Superintendent, Ginna Production United States Nuclear Re viator Commission USNRC
- C. Marschall, Senior Resident Inspector N. Perry, Resident Inspector
- Indicates those attended the exit meeting on June 8,
1990.
The inspectors also contacted other licensee technical and administrative personnel during the cour se of this inspection.
2.0 Ginna ATWS Rule Im lementation Under
CFR 50.62 IP 25020 2.1
~Sco e
The scope of this inspection was to determine whether the licensee has implemented the ATWS rule requirements per
CFR 50 '2 and to verify the effectiveness of QA/QC applied to the licensee's program to implement the rule.
Paragraph (c)( 1) of 10 CFR 50.62 specifies requirements for Ginna, which is a Westinghouse pressurized water reactor.
The licensee selected a Westinghouse generic design WCAP-10858,
"AMSAC Generic Design Package."
The NRC staff reviewed the Ginna AMSAC and issued a safety evaluation dated March 16, 1989 and found Ginna's method for compliance with the rule acceptable pending completion of several issues.
This inspection verified that the procurement, installation and testing of the Ginna design met requirements.
The inspector reviewed the licensee's specifications and analyses (see reference in Appendix 1), selected drawings, test reports, procurement and
quality documentation, procedures, and operator training records and lesson plans for the AMSAC system and inspected selected portions of the installation.
2.2
~Findin n
At the time of this inspection the Ginna AMSAC system was installed and being operated with the reactor power at approximately 98%.
The system was installed and tested during the 1989 refueling outage.
During the 1990 refueling outage two improvements were made:
( 1)
a status light was installed to indicate AMSAC trip status; and (2) the process computer was modified to indicate when the AMSAC logic has been tripped regardless of the main control board AMSAC manual block switch position.
The AMSAC system and equipment are required to be diverse and independent from the existing Reactor Protection System for tripping the main steam turbine and initiating auxiliary feedwater flow following an accident condition in which feedwater flow is lost.
The inspector reviewed the licensee's design criteria and design for complying with these requirements and then made a walkdown inspection to confirm that the installation of the equipment, cable, and devices in the system met required independence and diversity.
From the three generic NRC pre-approved Westinghouse Owners Group ATWS mitigating logic designs, the licensee chose to use the
"Low Feedwater Flow" option as the basis for the system.
This system utilizes six analog input signals from reactor protection safety-related circuits, four feed-water flow and two turbine first stage pressure signals.
The AMSAC system processes these input signals and provides six digital (relay contact)
output signals into safety-related output logic circuits, two for turbine trip and four to initiate auxiliary feed pump flow.
The inspector confirmed that the licensee utilized existing installed Foxboro M/66BR-OH current repeaters to feed the six input signals into the AMSAC system and to provide the required isolation from the Class 1E circuits.
These current repeaters were previously evaluated and qualified for Class 1E isolation under the licensee's Safety Evaluation Program Topic VII-I.A.
The AMSAC output relay contacts interface with the exist-ing Class 1E turbine trip and AFW control start logic.
For diversity the licensee installed Magnecraft Class 199 No. W199ABÃ-14 electro-mechanical relays.
These relays were qualified on the contact side as Class 1E (documented in a Test Report dated September 28, 1987).
The coil side was not qualified (not a requirement).
The relays were demonstrated to be capable of isolating the maximum credible fault from the coil side to the contact side of the relay.
In addition, the licensee's design/install-ation incorporated AMSAC isolation fuses to isolate the existing Class 1E circuitry from maximum credible cable faults between the AMSAC panel and the Class 1E RA panels/racks.
Based on a review of the licensee's design, selection and diversity of components, Class 1E qualifications of devices
where required, circuit interrupting coordination data, and a visual walkdown inspection of selected portions of the installed AMSAC system, no discrepancies were observed either in the licensee's effective isolation/
separation of the AMSAC circuits from the input/output Class 1E circuits or in the selection of diverse components except as discussed below.
The inspector reviewed the electrical power source for the AMSAC system to determine its adequacy and its independence from Class 1E power sources and systems.
AMSAC requires 120 volt 60 cycle power which is obtained from a static inverter unit which receives its input power from the 125 volt d.c.
2000 ampere hour Technical Support Center (TSC) battery.
The maximum AMSAC load on this battery is 6 amperes.
It is fused for
amperes.
The inspector observed that the nominal load on the TSC battery during this inspection was 225 amperes.
The licensee concluded that the TSC battery has sufficient capacity to carry the AMSAC loads without degradation and it is isolated from the Class 1E systems.
However, the inspector determined that circuitry exists for substituting the TSC battery for either of the two 1200 ampere/hour station batteries via a
locked transfer switch which normally provides isolation between the Class 1E circuitry and the TSC battery which the AMSAC is connected.
When the TSC battery is substituted for either of the station batteries, the AMSAC system then becomes common with Class 1E systems through the power supply.
The inspectors'oncern for the acceptability of independence between the Class 1E RPS systems and the non-class 1E TSC/AMSAC systems when the TSC battery throwover switch is positioned to provide TSC/AMSAC power from either of the Class lE batteries is considered an unresolved item (50-244/
90-10-01).
The inspectors observed AMSAC cable routings from the power inverter to the AMSAC Fox 3 cabinet and both input and output cable routings from the cabinet.
The inspector noted that the cable was run in non-safety related cable trays and conduits.
AMSAC cables were observed to be routed in cable tray No. 372.
However, an observation was made of cable entering and/or leaving non-safety-related cable tray 372 to a'afety-related cable tray No. 23.
The inspectors could not readily determine whether the cables in question were safety-related or not.
As a consequence a deter-mination could not be made of proper electrical separation at this one location.
The licensee agreed to reconfirm that AMSAC cable separation existed for this location.
Pending the licensee's verification of the separation of the AMSAC cable at one location in the cable run, specifi-cally cable tray No. 372, a non-safety-related tray containing AMSAC cable and cable tray No. 23, a safety-related tray, is an unresolved item (50-244/90-10-02).
The inspector particularly noted during the walkdown inspection that the installation workmanship appeared to be neat and reflect quality.
The equipment supports were of seismic grade, though not require ~
'I
I
, The licensee utilized his quality assurance program to meet the intent of Generic Letter 85-06.
This inspector verified quality records, noting that hold points for inspections were documented, calibrated M&TE equipment was used and certificates of conformance for nuclear Class 1E equipment were received.
The inspector identified a discrepancy in the licensee's EWR 4230, Revision 05, dated March 7, 1990, design verification document for the AMSAC.
Step 4. 1. 1 stated discrepancies in sections 3.4.23.
1 have been corrected, however, the discrepancies were not in the referenced step.
The cognizant design engineer initiated a re-review of the design verification document.
The discrepancy identified by the inspector appeared to be an administrative error that did not impact equipment performance adversely.
The inspector identified that the licensee's procedures place the AMSAC system in operation during startup and take the system off line during shutdown of the reactor.
However, the licensee has no procedure to control manual bypassing of the AMSAC during operations.
Neither have the operators been provided training in bypassing the AMSAC during operations between startup and shutdown.
The AMSAC system is not required to be checked daily by operating procedures, as is common for other equipment indicating in the control room.
There is no operational control procedure discussing the AMSAC system.
The inspector also noted that IKC had no'M procedure for calibration of the AMSAC timers'he modification support coordinator stated that the AMSAC timer calibration would be picked up by a procedure prior to the scheduled calibration date.
Although there are no technical specification requirements for the AMSAC operation, the inspector concluded that the above concerns constituted inadequate management controls.
Therefore, the following concerns regarding the AMSAC system are considered an open item:
( 1)
a lack of procedural coverage to control the manual bypass for the AMSAC, (2)
a lack of procedures covering overall operating bases, philosophy, objectives and intent of the AMSAC, (3)
a lack of procedures requiring, for example, daily operator checks of the AMSAC, and (4) training for the operators regarding the foregoing (Open Item 50-244/90-10-03).
2.3 Conclusions The licensee has complied with requirements of 10 CFR 50.62, Requirements for reduction of risk from anticipated transients without scram (ATWS)
events by installing the AMSAC system.
The inspector concluded that, within the sample taken, the installation quality was adequate to meet the regulatory intent to perform its function reliably and independently (from sensor output to the final actuation device)
from the existing reactor trip system, pending resolution of the following two unresolved concerns described above.
Although there were no technical specifications requirements for the AMSAC as was stated in the staff's Safety Evaluation Report dated March 16, 1989, the inspector concluded that the licensee's existing management
controls for the AMSAC were inadequate'he licensee's representative agreed to provide by letter to the Region by July 15, 1990, their intent and plans to provide management controls including operational and admini-strative procedural coverage for the AMSAC system.
3.0 Audit Pro ram Module 40702 3.1
~Sco e
The purpose of this inspection was to assess the implementation of the licensee's audit program.
The inspector interviewed auditors, super-visors, inspected audit and surveillance schedules, reviewed audit check lists and audit reports (see Appendix 1 for references).
3.2
~Findin n
The QA internal audit schedule for 1990 lists 18 audits and the 1990 on-site QC schedule lists 4 areas that receive formal surveillance/audits semiannually.
Technical Specification (TS) 6.5.2.8 specifies audits to be conducted to encompass all provisions contained within the TS and quality assurance program annually.
The inspector verified that the licensee had an audit planning and scheduling matrix to accomplish this TS requirement.
This inspection was focused on audits and surveillances in the areas of procurement, material handling and storage.
The licensee'
goal is for audits and survei llances to become more performance based.
QA issued procedure QA1811,
"Performance Based Surveillance Program," dated January 9,
1990.
The QA manager stated that plans are to have four full-time people working in this program.
Three people are currently on board.
The manager of nuclear assurance also has a performance oriented procedure QCSP-99, Quality Control Surveillance Procedure, Revision 0, dated April 15, 1989, that provides detail check lists used for assessing performance of various areas, for example, mater-ial handling and storage activities.
A scheduled surveillance of material handling equipment and storage/
material storage control QCR Number 90-1270 was completed on June 8,
1990, using QCSP-99I Quality Control Surveillance Procedure.
The audit/
surveillance procedure contained a ten page attribute check list with acceptance criteria, where applicable.
Performance attributes were noted to involve assessments by the auditors.
The audit/surveillance identified twelve unsatisfactory findings and identified several questions for resolution.
The inspector noted the finding that items in storage that have a limited shelf life have expiration dates verified prior to issu-ance, but are not monitored periodically while in storage.
The licensee has previously committed (reference IR 90-09) to develop a
new shelf life program.
The inspector found that the audit/surveillance provided reason-ably comprehensive coverage of the subject area.
A review was made of audit 89-55:RS, Ginna Safety-Related Procurement Activities conducted December 5-8, 1989.
This audit had three findings
and one observation requiring corrective action.
The audit involved 140 manhours of which 15% was observation of in-process activities.
Based upon the rev.iew of the procurement program including its current upgrad-ing, the inspector concluded that the audit provided indepth findings and recommendations.
The audit identified several procurement findings similar to those of the inspector.
The inspector concluded that the audit was making acceptable assessments.
During review of audit check lists the inspector noted that acceptance criteria were not clearly delineated in several cases.
For example, check list for audit 89-52:JO, page 7,
item C.3 stated
"qC ensures that packag-ing of items is adequate for storage..."
and referenced procedure A-1303, paragraph 3.2.2.
However, the referenced procedure did not provide specificity regarding packaging of items, only a general statement.
The resultant audit finding (check list dated 11/22/89) did not reflect an effective finding based on definitive acceptance criteria.
The inspector viewed this to be a weakness.
3.3 Conclusion 4.0 Based on the sample taken, overall the licensee's audit program is being implelnented acceptably and is making valid findings.
Corrective action to audit findings was evident where sampled.
In several isolated cases, however, definitive acceptance criteria were not given in audit check lists for attributes being audited.
Emer enc Diesel Generator EDG Fuel Oil (TI 2515/100)
4.1
~Back round For proper operation of the standby diesel generators, the fuel oil must be of proper quality.
Appendix B to
CFR 50,.as supplemented by Regu-latory Guide (RG)
1. 137, serves as an acceptable basis for licensees to maintain a program to ensure the quality of EDG fuel oil.
In response to recent industry problems, the NRC issued Information Notice 87-04 on January 16, 1987, to alert licensees of potentially significant problems in long-term storage of fuel oil.
This information notice docu-ments the inoperability of an emergency diesel generator due to high concentration of particulates in the fuel oil.
Assurance of the proper fuel oil requires purchasing the correct fuel oil and verification that the fuel oil is proper prior to addition to the storage tanks.
Since fuel oil degrades with time and since external sources contribute contamina-tion, periodic inspection is required to assure continued quality.
An inspection was performed to determine the licensee's program for the procurement, receipt, storage, handling and control of EDG fuel oil to ensure its adequate qualit.2
~Findin
Fuel Oil Procurement Recei t and Stora e
NRC Inspection Report 50-244/90-05 addresses the licensee's program and procedures to ensure fuel oil quality during initial procurement, receipt and'storage, and concludes that they are adequate.
The inspector observed the following additional procedural controls and practices in use to ensure the quality of the stored fuel oil.
" Routine, quarterly three-level sampling/analysis of fuel in the storage tanks to ensure ASTM 0925 requirements.
~
Monthly draining of day tanks bottoms and refilling during test of fuel oil transfer pumps.
~
Annual cleaning of the fuel oil strainers and replacement of the primary and secondary duplex fuel filter elements.
Annual pumping out, cleaning, and refilling of each onsite EDG fuel storage tank and day tank.
This frequent replacement of the fuel oil is used to minimize fuel oxidation and biological contamination/degradation which could occur with long term (multi-year)
storage of fuel oil.
No deficiencies were noted in the licensee's controls to ensure the quality of the stored diesel fuel.
Fuel Filter Clo in NRC Inspection Report 50-244/88-05 addresses the licensee's corrective actions taken to control/prevent strainer/filter clogging in response to NRC Information Notice 87-04.
This report concludes that the actions taken were adequate and were implemented in a timely manner.
The inspec-tor found that the licensee had performed additional evaluations/actions to address the diesel fuel oil clogging issue in their guality Control Information Report 88-960.
No deficiencies were noted EDG Fuel S stem Features The licensee's design, construction and control of the EDG fuel system includes the following features to enhance reliability.
The fuel oil system utilizes dual path, dual element fuel filtration, which is equipped with pressure instrumentation to provide indica-tion/alarm of filter fouling and to permit on-line filter replacement without shutdown of the ED ~
Critical fuel oil system instrumentation was relocated to off-skid panel locations during the current outage and upgraded to achieve seismic qualification.
This instrumentation includes primary and secondary fuel oil filters, differential pressure gages, alarm trans-mitters, fuel oil pressure gage, and day tank level and alarm transmitters.
~
Fuel oil alarms are annunciated in the EDG rooms with local individ-ual alarms and in the main control room on a
common trouble alarm in accordance with ANSI-N195-1976.
4.3 Conclusions The licensee's program for the procurement, receipt, sampling and inspection of the EDG fuel oil is considered to meet the guidelines of Regulatory Guide 1. 137.
The licensee's procedures, controls and system features ensure an adequate supply of proper quality fuel oil to the emergency diesel generators.
5.0 Licensee Actions Taken on Previousl Identified Items Closed Violation 50-244/88-24-01 The licensee had not provided adequate fire protection separation for certain electrical conduits which enclose circuits required for safe shutdown.
Specifically per the licensee (vendor) procedure, certain steam generator pressure indication and charging pump power circuits in conduits were observed to be inadequately wrapped with fire proofing where crossing conduit supports to meet the
CFR 50, Appendix R,Section III.G one hour fire rating requirements.
The licensee's response letter dated January 27, 1989 concurred in the violation, provided root cause analysis for the inadequate fire wraps, stated that the deficient conduits would be wrapped properly to correct the inadequacies, and provided corrective measures implemented to prevent recurrence.
Confirmation of the licensee's corrective actions included the following:
A review was made of the licensee's installation instructions/pr oce-dures which were revised to provide additional details and to assure sufficient insulation wrap margin to prevent recurrence.
A review was made of the licensee's design analyses which establi-shed/implemented analytical methods to evaluate mathematically the performance of all of the various fire wrap configurations.
A review was made of the licensee's walkdown inspection and evalu-ation report of all of the fire wrap configurations/locations to determine those which require rewrap in addition to those identified during the NRC Inspectio $ 0
A walkdown inspection was made of four electrical conduit/enclosure rewraps including the Steam Pressure Indication Conduit.
A review was made of the licensee's documentation reflecting the completion of the rewraps necessary to resolve this deficiency.
Based upon the licensee'
corrective actions taken to provide adequate fire wraps and to prevent recurrence, this violation is closed.
Closed Unresolved Item 50-244/88-24-02:
Testin of Fire Dam ers The subject item was unresolved pending the licensee developing and imple-menting a fire damper test program.
This program is needed to address an identified 10 CFR 21 concern that the dampers may not close under full air flow conditions.
The inspector determined that the licensee has developed and implemented Procedure PT-13.26,
"Testing of Fire Oampers,"
Revision 1, with an effect-ive date of August 15, 1989.
A technical review of this procedure indi-cates that it is adequate for verifying fire damper operability.
The licensee currently is in the process of conducting the initial test of all dampers.
The inspector confirmed that 51 of the 66 dampers have been tested in accordance with this procedure.
The licensee made a commitment to finish the initial test of all dampers by October 1,
1990.
The licen-see has included the periodic retest.of the fire damper s on a rotating basis by testing ten percent each year
. If a damper fails the test, an additional ten percent will be tested for each failure.
Based upon the licensee's implemented damper test program and the commit-ment to finish the initial test of all dampers by October 1,
1990, this item is closed.
6.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are an acceptable item or violation.
One unresolved item is discussed in paragraphs 2.3.
7.0 Mana ement Meetin s
The licensee management was informed of the scope and purpose of the inspection at the entrance interview on June 4,
1990.
The findings of this inspection were discussed with the licensee representatives during the course of this inspection and presented to the licensee management at the exit interview on June 8,
1990 (see paragraph 1.0 for attendees).
At no time during this inspection were written materials given to the licensee.
The licensee indicated that no proprietary information was involved within the scope of this inspectio Appendix
Other References Procedure M-15. 1, A or B Diesel Generator Inspection and Maintenance, Revision
Procedure PT-13.26, Testing of Fire Dampers, Revision
Procedure QM 1316, Sampling ¹2 Fuel Oil and Docomenting Delivery, Revision
Procedure QM 1317, Loading and Delivering ¹2 Fuel Oil for Ginna Station, Revision
Drawing 33013-1239, Diesel Generator P&ID, Revision
Test Report CTP-1077, One Hour Fire Test on 3" Conduit, March 10, 1986 Quality Control Report QCR 89 2199, Fire Damper Testing Quality Control Report QCR 88 960, Diesel Fuel Oil, IN 87-04 Issue Design Analysis EWR 4230, Minimum Conductor Size, Voltage Drop and Circuit Protection for Power and Control Cables, Revision
Safety Analysis EWR 4230, AMSAC, Revision
Design Verification EWR 4230, AMSAC, Revision
Design Analysis EWR 4230, Electrical Separation, Revision
Design Analysis EWR 4230, AMSAC Class lE Isolation, Revision
Design Criteria EWR 4230,,AMSAC, Revision
Design Analysis EWR 3986, Appendix R Fire Wraps, Revision
Design Analysis EWR 3986, Effects of Heat Transfer to Fire Wrapped Conduit Through Conduit Supports During Potential Fires, Revision
Audit No. 89-52:JO Audit No. 89-44:GS Audit No. 89-55:RS Audit of Ginna Material Handling, Storage, and Shipping Activities Ginna Maintenance and Repair Activities Ginna Station Safety-Related Procurement Activities
t
)O
Audit No. 89-17: WS Audit of Engineering Design and Test Activities Quality Control Report 90-1270 Quality Control Report 90-0098 Quality Control Report 90-1263 Scheduled Surveillance of Material Handling Equipment and Storage/Material Storage Control Scheduled Surveillance Records/Document Control Control of Measuring and Test Equipment Scheduled Surveillance