IR 05000244/1995002
| ML17263A966 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/02/1995 |
| From: | Harrison L, Eugene Kelly, Prividy L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17263A964 | List: |
| References | |
| 50-244-95-02, 50-244-95-2, NUDOCS 9503140040 | |
| Download: ML17263A966 (14) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
DOCKET/REPORT NO.
LICENSEE FACILITY:
DATES:
50-244/95-02 Rochester Gas and Electric (RGKE) Corporation Rochester, New York 14649 Robert E. Ginna Nuclear Power Plant January 9 - 13, 1995 INSPECTORS:
eonar rsvp y, r.
eactor ngsneer Systems Section Division of Reactor Safety S/iles'ate nne-arrison, eac or ngineer Electrical Section Division of Reactor Safety APPROVED BY:
uge e
,
ie Systems e
ion Division f Reactor Safe y SUNNARY: A corporate reorganization established a new onsite engineering support group to administer the details of plant modifications.
Major modifications reviewed were well engineered with good safety evaluations.
The licensee initiated the use of a new plant change review process to improve modifications.
The temporary modification process was working well.
Engineering management evidenced good control of the major items in the engineering work backlog.
The technical staff training program was being effectively implemented.
The system engineers had progressed in their qualification efforts, but significant work remained in this area.
The licensee conducted a thorough self assessment of the corrective actions taken in response to the findings of a 1991 NRC Service Water System Operational Performance Inspection.
9803140040 950303 PDR ADOCK 05000244
DETAILS 1.0 INSPECTION SCOPE The objective of this inspection was to evaluate the engineering organization's performance of various activities, including the development of plant modifications and the identification and technical resolution of problems.
NRC Inspection Procedure 37550, Engineering, was used for inspection guidance.
The inspection was conducted at the Ginna plant to include reviews of the onsite engineering activities since an earlier inspection had emphasized design engineering work at the corporate office.
Areas inspected included reviews of the recent corporate reorganization, plant major and minor modifications, temporary modifications, self and independent assessments of engineering activities, the system engineer program, engineering work backlog, technical staff training, and the operational experience review program.
Also, the inspectors reviewed the status of unresolved item 94-26-01, regarding potential erosion in a throttle valve.
2.0 INSPECTION FINDINGS 2.1 Engineering Reorganization and Wor k Control A corporate reorganization established a new onsite engineering support group effective on November 1,
1994, to administer the details of plant modifications.
This group reports to the corporate engineering organization.
The licensee expects that this reorganization item will enable the system engineering group to develop more quickly, since the system engineers will not be responsible for the details of plant modification work.
A good effort by the licensee in prioritizing engineering work items was observed by the inspector.
The licensee appeared to have reasonable goals established for controlling major engineering work items, including engineering work requests (EWRs), technical staff requests (TSRs),
and vendor technical manual change requests.
2.2 Major Modifications The inspectors reviewed selected EWRs to verify that changes to the station's safety systems were supported by appropriate design criteria, design input requirements, and design analyses.
The inspectors performed this review to confirm that the design changes did not adversely affect the function of safety-related systems.
2.2.1 EWR 45284B Service Mater (SM) and Component Cooling Water (CCW)
Pump Discharge Check Valves The engineering work reviewed by the inspector, in support of this modification, was performed well with some examples as follows.
A thorough search for a better check Valve demonstrated design engineering's initiative to achieve a good long-term resolution to an old problem.
Also, engineering properly analyzed the impact on system performance upon recognizing the higher pressure drop characteristics of the new check valve This modification involved the replacement of the original swing check valves located at the discharge of each SW and CCW pump with nozzle type check valves.
This different design check valve was selected to provide smoother operation during pump startup and tighter shutoff for any idle pumps.
Initial operating experience in both systems has shown that these check valves have performed well in satisfying both of these requirements.
The inspector noted that the nozzle check valves had a larger hydraulic resistance than the original check valves.
The impact of this change on SW system performance had been evaluated as documented in Design Analysis DA-ME-94-101.
The licensee concluded in this analysis that no significant adverse changes were expected on overall SW flow to safety related components during safety injection or recirculation operation.
The inspector also reviewed the post modification test result that demonstrated satisfactory operation prior to return to service.
2.2.2 EWR 45098 Service Water System Butterfly Valve Replacement While engineering's actions regarding the partial completion of this modification were acceptable, the inspectors found that future post-modification testing will be needed to assure an effective resolution of the past valve seat leakage problems.
The licensee had appropriately evaluated the impact of deferring the installation of butterfly valve V4734 until the 1995 refueling outage by updating the modification safety evaluation.
However, the inspectors found that the licensee had not yet completed the post-modification testing for evaluating the combined seat leakage of these butterfly valves in the closed position.
This modification was initiated to replace seven motor-operated SW system butterfly valves that provide isolation to non-essential loads during safety injection and loss of power signals.
The main reason for valve replacement was to minimize seat leakage that was occurring due to cumulative erosion and corrosion on the valve internals from 25 years of service.
At the end of the 1994 refueling outage, only one butterfly valve (V4734 SW isolation for the
"B" CCW heat exchanger)
had not yet been replaced.
The inspector reviewed the licensee's safety evaluation, dated March 31, 1994, that provided the technical basis for deferring the replacement of butterfly valve V4734 until the 1995 refueling outage.
A key technical item in this evaluation involved a discussion of SW system butterfly valve seat leakage requirements.
Based on testing conducted per EWR 10110 in 1993, the licensee had concluded that a combined seat leakage of approximately 500 gpm from four butterfly valves (V4614, 4733, 4734, and 4735), although undesirable, was acceptable.
Since three of these butterfly valves had been replaced during the 1994 refueling outage, the licensee considered the deferral of the modification for valve V4734 to the 1995 refueling outage to be acceptable.
The inspector agreed that this licensee approach in the.safety evaluation was appropriate.
During the review of the post-modification test results, the inspector noted that pressure boundary integrity and valve stroking/timing tests were satisfactorily demonstrated.
However, no seat leakage testing had
been performed for the newly installed butterfly valves.
The licensee indicated that a combined seat leakage test for these valves would be performed after installation of V4734 during the 1995 refueling outage.
The inspector considered this to be adequate.
2.2.3 EWR 85405 - Service Water System Header Access The inspector had no significant comments concerning the installation of this relatively simple modification.
The purpose of this modification was to provide a flanged enclosure at each 20-inch main SW distribution header for inspection and repair of this piping.
The inspector walked down the installation of this plant modification with the system engineer and had no significant comments.
The inspector also reviewed the licensee's inspection report of the internal condition of the underground SW system
"A" header supply piping.
The installation of this modification made this inspection possible.
This was the first such inspection of the underground piping since initial plant construction and the inspection was conducted during the 1994 refueling outage using robotic equipment.
The inspector noted that the licensee's general conclusion from the inspection report was that the overall condition and structural integrity of the piping was acceptable.
This conclusion was based on visual observation that the concrete liner, joints, and fittings associated with the piping were in excellent condition.
Based on these results and the reasonable expectation of similar results for the "B" header, the licensee has no immediate plans for inspecting the "B" SW underground piping in the next refueling outage.
The inspector had no further questions on this topic.
2.2.4 EMR 85364 Residual Heat Removal (RHR)
Pump Pit Level Alarm This modification was developed to replace existing float type level switches in the auxiliary building sub-basement with new environmentally qualified float type level switches.
These switches will provide a high sump level contact alarm output, and initiate RMR sump pump start to support RHR pump operation during the recirculation phase of a loss of coolant accident.
In the event that an RHR pump seal failure occurs during the recirculation phase, a harsh environment'would exist where these switches are located.
The only alarm system available to alert operators of this condition is the existing sump dewatering system.
Consequently, the sub-basement could flood and preclude the RHR pumps from performing their intended safety function.
The replacement level switches require modification to the existing control circuitry of the A and B sump pumps to include a new relay in series with the float switch.
Assumptions presented in the Design Analysis for determination of level switch environmental qualification were properly documented.
Specifically, accident operating time, environment temperature and radiation, and activation energy values were appropriately used.
The environmental qualification of the switches was performed in accordance with EPRI publication,
"A Review of Equipment Aging Theory and Technology," dated September 198.3 Plant Change Review Process The inspectors reviewed the initial use of a new plant change review (PCR)
process by the licensee.
RGKE has enhanced the engineering process for controlling plant configuration changes as part of their Process Upgrade Project.
This engineering process change was described in engineering Procedures EP-2-P-102, Revision 0, "Plant Change Process" and EP-3P-126, Revision 0, "Equivalency Evaluation,"
and was focused primarily on the design phase of a plant modification.
Specifically, the interfaces between design and implementation activities among varied disciplines were enhanced.
The cognizant engineer will identify the design criteria (functional, performance, and operation requirements, design conditions, and personnel requirements),
which establish the other design input requirements.
The inspectors noted that digital interface requirements and software quality assurance considerations were not presented in the Equivalency Evaluation Report (EP-3-P-126, Revision 0) for Equivalent Changes to systems, structures, or components.
These digital considerations were found to be presented in the change input evaluation for other plant changes.
In response to this comment, the licensee now intends to include digital interface requirements into engineering Procedure EP-3-P-126, Revision 0, "Equivalency Evaluation."
The licensee stated that digital considerations for plant changes had been an internal commitment per the 1994-1995 Business Plan.
At the time of this inspection, eight pilot plant configuration changes were being executed using the new PCR process for possible implementation during the upcoming outage.
These pilot modifications will be evaluated and any needed enhancements made following a post-outage self-assessment by the licensee.
Engineering Work Request 5364 discussed above was prepared using the new PCR process.
2.4 Minor Modifications'he inspectors concluded that the use of the Technical Staff Request (TSR)
process was appropriate for the scope of work planned or performed to resolve identified concerns.
Appropriate safety evaluations were conducted for the relatively simple modifications reviewed.
The inspectors also observed an appropriate level o'f management involvement in the TSR process.
Minor modifications are accomplished by TSRs.
The inspectors reviewed several TSRs to verify proper evaluation and disposition of requests for plant changes.
This review included interviews with engineers to assess their responsibilities regarding TSRs.
The following TSRs were reviewed:
~
93-129,
"Manual Air Loader for.AOV-4561";
~
94-117,
"Battery Monitor Cable Replacement";
~
93-094,
"Control Rod Fan Shroud Vibration Switch";
~
90-007,
"Hydrogen Monitor Temperature Readout."
The supervisor of system engineering is responsible for initial screening of TSRs and appropriate routing.
The inspectors verified in discussions with several engineers that plant configuration changes will be resolved by onsite engineering staff.
Other TSRs, such as those involving only procedure changes, will continue to be dispositioned by system engineering staff.
2.5 Temporary Modifications The inspectors found administrative procedures for temporary modifications (THs) were appropriate, and properly implemented.
Installed THs were found not to degrade the design safety function of plant systems.
The inspectors noted appropriate management involvement in controlling the number of open THs.
THs are administratively controlled in accordance with Procedure A-1406, Revision 14, "Control Of Temporary Modifications."
This procedure required plant operations review committee (PORC) approval of all THs prior to installation on safety-related systems and for those installed greater than one year.
The TH coordinator, a member of the recently established onsite engineering group, completes and distributes a monthly open status log of THs to management, and performs a random monthly plant tour to independently monitor for any unauthorized TMs.
Thirty-two temporary modifications were open at the time of this inspection.
The inspectors reviewed six THs and visually observed five THs currently installed.
The design details of the TMs reviewed were acceptable.
Required reviews and approvals were performed.
Based on the walkdown of the five THs, the inspectors determined that the TH tagging, reviews, and approvals were in accordance with Procedure A-1406.
The safety evaluations for THs reviewed were acceptable.
A minor problem was noted regarding three of the TMs reviewed in that they were initially identified by the licensee in the past year as unauthorized THs.
These THs had been installed either during initial plant startup or as a
result oF previously installed plant modifications.
The inspectors noted that the licensee had established several administrative measures in the past to preclude any future installations of unauthorized THs.
For example, the work order control system was rewritten in 1991 to mandate engineering documentation support for work requests.
Procedure A-1603.3, Revision 9,
"Work Order Planning" states this requirement.
In addition, Procedure A-54.4, Revision 29, "Shift Technical Advisor (STA) Plant Tour," requires checks by STAs for unauthorized TMs on a weekly basis.
The inspectors concluded that these controls have since'been effective.
2.6 Self Assessments of Engineering Activities The inspectors observed that licensee guality Assurance (gA) audits and surveillances had been performed on various engineering activities, with no programmatic weaknesses noted.
The inspectors also noted that a thorough self assessment of RG&E corrective actions related to a 1991 NRC Service Water
System Operational Performance Inspection (SWSOPI)
had been conducted recently in December 1994.
The 3-man assessment team included personnel from RGKE, EPRI, and a nearby nuclear facility who were knowledgeable in SW issues.
The inspectors reviewed the RGKE team's report and discussed the findings with the licensee's Hanager of Safety and Licensing, who had arranged for the conduct of this self assessment.
The team concluded that much work has been done, but significant work yet remains.
The licensee's engineering management indicated that the self assessment was helpful in clarifying open items and identifying the action parties to get the remaining open items completed.
For example, a team observation noted an apparent confusion 'of roles and responsibilities for implementing aspects of the licensee's SW System Reliability Optimization Program.
The self assessment team made this observation after discussions with corporate mechanical engineers and site reliability and test personnel.
Another observation noted the lack of final development of SW system heat exchanger acceptance criteria.
The inspectors were informed that the SW system engineer is intended to play a key role in coordinating the resolution of the remaining SW system open items.
A specific operating experience review program open item involved the licensee's review of NRC Information Notice 94-03, which provides the results of several NRC SWSOPIs.
The inspector noted that engineers had performed interim evaluations of this information notice, but a final resolution was still outstanding concerning applicability to Ginna.
2.7 System Engineer Program System engineers have progressed in their qualification efforts, although significant work remains.
The licensee acknowledged that their goal to have system engineers qualified by December 1994 had not been met, but expects this goal to be reached by June.1995.
However, no adverse consequences were identified by the inspector as a result of this training issue.
The licensee established a system engineering group in November 1993.
The duties and responsibilities of system engineers were presented in R.E. Ginna Nuclear Power Plant Systems Engineering Guideline 2.0, Revision 0,
"Systems Engineer Responsibilities,"
dated January 12, 1994.
In discussions with system engineering personnel, the inspectors determined that all required training for the qualification of system engineers had not been completed in that the performance of duties established in Engineering Guideline 2.0 had not yet been implemented.
The inspectors also noted that system engineers had not,fully established performance criteria for monitoring the performance of safety related systems.
For example, the acceptance criteria for monitoring the performance of the SW system heat exchangers had not been fully developed.
The establishment of such performance criteria for systems at Ginna is linked to reliability-centered determinations being developed by the licensee to support the pending maintenance rule described in
CFR 50.6.8 Technical Staff Training The inspectors concluded that the technical staff training program was being effectively implemented to address the identified training needs of the engineering personnel.
The inspectors reviewed the quality and content of the licensee's training information provided to engineering personnel, described in RGKE Procedure TR C.10, Revision 7, "Engineering Support Personnel Training Program."
Engineering personnel receive training classified under three general areas:
orientation training that is required of all engineering support personnel for indoctrination; position specific training that consists of qualification guides for performing specific independent safety-related tasks; and continuing training designed to keep personnel abreast of significant operating and industry information as well as plant physical and procedural changes.
Additional training requirements for systems engineers were presented in the Systems Engineering Guideline 3.0, Revision 0, dated December 8,
1993.
This guideline further defines criteria for the qualification of a Systems Engineer.
The licensee utilizes a Curriculum Committee (CC) to review the training program and ongoing training needs.
The CC was described in Procedure gT 205, Revision 4, "Curriculum Committee Organization And Responsibilities."
The CC consists of both supervisory and non-supervisory personnel from various engineering departments.
The inspectors noted from review of previous CC monthly meeting minutes that improved involvement by site departments was demonstrated.
The inspectors reviewed continuing training topics offered to engineering personnel from 1992 through 1994, and those topics which are planned for 1995.
Topics discussed by the licensee included motor operated valve weak link training, seismic analysis training, and procedures governing the new PCR process.
Future training includes finite element analysis training, inservice inspection training, and environmental qualification course.
The inspectors also reviewed several lesson plans and verified that they included the proper level of information.
The inspectors observed that lesson plans were appropriately organized.
2.9 Unresolved Item 50-244/94-26-01 (Closed)
This concern had been identified based on the potential for valve body/pipe erosion near motor-operated valves (HOV) 738A and B, due to the use of these gate valves for throttling component cooling water (CCW) system flow.
The licensee resolved this issue by performing ultrasonic thickness (UT)
measurements of the pipe wall at piping locations upstream and downstream of each valve and at the body of each valve.
The inspector reviewed the results of the work performed in December 1994.
The minimum wall thickness measured by UT was 0.339 inches, which occurred at a 90'lbow downstream of HOV-738A and was within the manufacturing tolerance for this class of piping.
The minimum required wall thickness for design pressure/temperature considerations is 0.200 inches.
These results are evidence adequate margin for design conditions.
Therefore, this unresolved item is close.0 MANAGEMENT MEETINGS The scope and purpose of the inspection were discussed at an entrance meeting conducted on January 9,
1995.
During the course of the inspection, the inspectors'indings were discussed with licensee representatives.
The inspector met with the principals listed below 'on January 13, 1995, to summarize the preliminary findings.
During the inspection, the licensee indicated that there was no proprietary information involved in the inspection, or expected to be included as part of this inspection report.
oc ester Gas and Electric Com an C. Forkell M. Lilley T. Marlow, J.
Wayland G. Wrobel Manager, Engineering and Computer Support Manager, guality Assurance Superintendent, Ginna Production Manager, Systems Engineering Manager, Nuclear Safety and Licensing U.S. Nuclear Re ulator Commission i
L. Harrison T. Moslak L. Prividy Reactor Engineer, Electrical Section, Region I Senior Resident Inspector, Ginna Station Senior Reactor Engineer, Systems Section, Region I
I