IR 05000244/1997003

Insp Rept 50-244/97-03 on 970407-0518.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML17264A914
Person / Time
Site:	Ginna
Issue date:	06/09/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17264A913	List: IR 05000244/1997003 ML17264A912
References
50-244-97-03, 50-244-97-3, NUDOCS 9706160213
Download: ML17264A914 (56)

Text

U.S. NUCLEAR REGULATORY COMMISSION REGION I

License No.

DPR-18 Report No.

50-244/97-03 Docket No.

50-244 Licensee:

Facility Name:

Location:

Inspection Period:

Rochester Gas and Electric Corporation (RGSE)

R. E, Ginna Nuclear Power Plant 1503 Lake Road Ontario, New York 14519 April 7, 1997 through May 18, 1997 Inspectors:

Approved by:

P. D. Drysdale, Senior Resident Inspector C. C. Osterholtz, Resident Inspector E. B. King, Physical Security Inspector R. C. Ragland, Radiation Specialist L. T. Doerflein, Chief Projects Branch

Division of Reactor Projects 9706i602i3 970609 PDR ADOCK 05000244

PDR

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EXECUTIVE SUMMARY R. E. Ginna Nuclear Power Plant NRC Inspection Report 50-244/97-03 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support.

The report covers an 6-week period of resident inspection.

In addition, it includes the results of announced inspections by two regional specialists in the areas of physical security and radiological protection.

Operations Overall, the conduct of plant operations was performed well during the inspection period.

Two auxiliary operators (AOs) conducted their rounds in an efficient and competent manner, and in accordance with plant procedures.

Their knowledge of plant system operations was good.

Both the individual watch station turnovers and the crew shift turnovers observed were thorough and conducted in a professional manner.

The operating logs were complete and concise.

The licensee's program for placing administrative holds on plant equipment was good.

Tagouts were hung in accordance with plant procedures.

Control room operators were knowledgeable with the computer database.

The manual and plant process computer system (PPCS) calorimetric calculations were in good agreement.

The control room foreman demonstrated good proficiency in obtaining all the required plant process data and in performing the manual calculation.

The procedures used for both calorimetric methods provided sufficient detail and acceptance criteria to assure that reactor power would be maintained within licensed limits.

Improved Technical Specifications (ITS) training for managers and supervisors was informative and provided valuable clarification regarding ITS implementation and applicability. The licensee's new initiatives to track comments on the ITS and to establish a controlled process for resolving those comments were appropriate.

Maintenance Observed maintenance and surveillance activities were performed in accordance with procedure requirements, and technicians demonstrated good knowledge of the functional requirements of the equipment being tested.

The acceptance criteria in the Updated Final Safety Analysis Report (UFSAR) was consistent with that used in the surveillance tests.

The integrated 12-week work schedule was a positive initiative that made immediate improvements in the effectiveness of interactions and communications between the operating staff and other site work groups.

The administrative controls in place appeared adequate to establish the integrated scheduling program and processes.

The additional efforts now required to plan and schedule maintenance and testing provided for more effective work controls and for minimizing the total time that plant equipment is not available for servic V

Executive Summary (cont'd)

The licensee took aggressive action to determine the cause of a dip in service water (SW)'eader discharge pressure, and took approp'riate corrective actions to clear the SW pump strainers of fouling.

Subsequently, the licensee's identification and response to the C-SW pump discharge pressure drop was also performed well, and the corrective actions taken to resolve strainer trap door problems were effective.

The increased amount of biological growth that has recently appeared in the SW pump bay, and the licensee's decision to perform increased monitoring of the SW pump strainers was considered by the inspectors to be important in maintaining SW system reliability.

Engineering The licensee completed a safety evaluation to support a change to the Improved Technical Specification (ITS) Basis to permit the minimum SW inlet water to drop from 35 F to 32 F,

Also, the operations procedure for daily surveillance logs was changed to direct operators to take manual readings of the screenhouse bay to ensure that temperatures are maintained greater than 32'F.

LER 97-001 was closed.

Plant Support Radiological controls including external dose controls, radiological area controls, and radioactive material and contamination controls were good.

Housekeeping in radiologically controlled areas was very good.

Areas affected by ground water intrusion in the upper radwaste storage facility and the intermediate building sub-basement, were maintained as radiologically clean (non-contaminated)

areas; operating plant equipment was apparently not affected; and excess water in the intermediate building sub-basement was processed as potentially contaminated.

Procedural guidance for conducting termination whole body counts was good, and recent procedural changes were reasonable.

Radiological Protection and Chemistry (RP5C) audits and surveillances were effective in identifying and resolving program weaknesses.

The ACTION reporting system was good in that the threshold for entering items into the system was low, and the system was effectively used to resolve identified problems.

However, computerized reporting capabilities were not fully developed, resulting in some difficulties in searching and trending of radiological deficiency issues.

The corrective actions taken after contaminated equipment was released to DC Cook were reasonable and complete, No similar problems were identified.

Violation 50-244/96-03-02 was closed.

UFSAR discrepancies on the method for laundering protective clothing and for solid waste generation were clarified in a UFSAR update.

Unresolved Item 50-244/96-06-05 was close Executive Summary (cont'd)

I'he Fitness-For-Duty (FFD) program procedure changes did not adversely affect program implementation, and procedure and policy changes were being reviewed, approved, distributed in a timely manner, and properly controlled.

Documentation on file confirmed that FFD training satisfies the requirements of 10 CFR 26 and was being provided. in a timely manner to all persons granted unescorted access.

Random FFD testing was being performed as required by 10 CFR 26 and procedure revisions implemented to address previously identified weakness appeared to be effective.

Management was actively involved in effective program oversight.

An FFD audit was comprehensive in scope and depth; the findings were appropriately distributed and addressed.

The audit program was being properly administered.

The corrective actions implemented to address the two FFD violations were reasonable, complete, and appeared to be effective.

Violations 50-244/96-10-01 and 50-244/96-10-02 were close TABLE OF CONTENTS EXECUTIVE UMMARY S

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Conduct of Operations................

01.1 General Comments 01.2 Overview of Plant Status Operations Procedures and Documentation 03.1 Station Tagout Review..

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03.2 Calorimetric Heat Balance Procedures Operator Knowledge and Performance

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M2 M6 Conduct of Maintenance M1.1 General Comments on Maintenance Activities M1.2 General Comments on Surveillance Activities Maintenance and Material Condition of Facilities and M2.1 Service Water (SW) Pump Strainer Fouling..

Maintenance Organization and Administration M6.1 Integrated 12-Week Work Schedule Equipment

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Miscellaneous Engineering Issues E8.1 (Closed) LER 97-001: Service Water Temperature Less Than Specified Value, Due to Non-Representative Method of Monitoring, Resulted in Condition Prohibited by Technical Specifications o

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R2.1 Housekeeping and Material Conditions RP&C Procedures and Documentation R3.1 Dosimetry Procedure Quality Assurance in Radiological Protection and Chemistry R7.1 RP&C Audits, Surveillances, and ACTION Reports Miscellaneous RP&C Issues R8.1 UFSAR Review R8.2 (Closed) VIO 50-244/96-03-02...............

R8.3 (Closed) URI 50-244/96-06-05

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S3 S5 S7 S8 R8.4 Sample Results From Areas Affected By Steam Generator Biowdown

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R8.5 Status of Efforts to Quantify Fuel Pool Leakage Security and Safeguards Procedures and Documentation S3.1 Program Policies and Procedures

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ATTACHMENTS Attachment 1 - Partial List of Persons Contacted

- Inspection Procedures Used

- Items Opened, Closed, and Discussed

- List of Acronyms Used

Re ort Details I. 0 erations

Conduct of Operations'1.1 General Comments Ins ection Procedure IP 71707 The inspectors observed plant operations to verify that the facility was operated safely and in accordance with licensee procedures and regulatory requirements.

This review included tours of the accessible areas of the facility, verification of engineered safeguards features (ESF) system operability, verification of proper control room and shift staffing, verification that the plant was operated in conformance with the improved technical specifications (ITS) and appropriate action statements for out-of-service equipment were implemented, and verification that logs and records accurately identified equipment status or deficiencies.

Operator performance throughout the inspection period was good.

01.2 Overview of Plant Status The plant remained at full power for most of the inspection period.

A slight drop off in turbine condenser thermal efficiency had been noted in recent months that the licensee attributed to silt and biological growth collecting in the condenser tubes.

In order to avoid a more significant inefficiency at higher lake inlet temperatures during the summer months, power was reduced to approximately 45% on May 16-17, 1997, to clean condenser tubes and water boxes.

During this period, main turbine stop valve testing and maintenance on the 8-main feed pump and the A-condensate booster pump were also performed.

On May 17, 1997, a steam leak occurred on pressure gage PI-6664, moisture separator reheater (MSR) 2A 4th pass level tank pressure.

The MSRs were removed from service and the leak was isolated by locally shutting the instrument root valve to Pl-6664.

Prior to restoration of the MSRs, the licensee identified a broken control relay for air operated valves AOV-3425 and AOV-3425A (steam supply to 1A MSR). The relay was repaired and the MSRs were brought back on line the same day.

Also on May 17, 1997, the Barton gage 477A indicator (B-feedwater flow) stuck near mid-position during the power reduction.

This prevented the licensee from performing a calorimetric heat balance calculation as required by surveillance requirement (SR) 3.3.1.2 of the improved technical specifications (ITS). A calorimetric is normally required once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; however, the SR does not apply below 50% thermal power, and a calorimetric must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after a power increase greater than or equal to 50%.

The Barton gage was recalibrated on May 17, 1997, and a calorimetric was

'Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline.

Individual reports are not expected to address all outline topic performed shortly after the plant reached 50% power during the subsequent power ascension on May 18, 1997.

Operations Procedures and Documentation 03.1 Station Ta out Review a.

Ins ection Sco e (71707)

The inspector reviewed the licensee's program and procedures for placing administrative holds on plant equipment.

b.

Observations and Findin s The inspector reviewed administrative procedure A-1401, "Station Holding Rules,"

and verified that a random sample of tagouts were hung in accordance with that procedure.

The inspector also compared the tagout worksheets against plant piping and instrumentation (PSIDs) drawings to verify proper system isolation, and verified that the components identified on the tagout worksheets were in their proper position and that the tags were hung correctly.

The inspector obtained copies of selected tagout worksheets generated by control room operators from a computer database.

The selected sample of tagged equipment included pressurizer heaters, residual heat removal (RHR) room coolers, auxiliary feedwater (AFW) pump, service water (SW) strainer bypass gates, the B-condensate booster pump, and the A-emergency diesel generator (A-EDG). No missing or inaccurate tags were discovered during the verification. All inspected components and switches were in the position or status indicated on the tag and the tagout worksheet.

No instance was observed where an improper boundary isolation had been utilized.

Both the "hold" (red) tags used to isolate plant components and the "block" (blue) tags used for electrical switchgear clearly identified the component or switch and conspicuously displayed the "DO NOT OPERATE" instruction.

Alltags appeared firmly attached to their respective components, and the tags had been manufactured from sturdy plastic instead of paper to preclude tearing.

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Conclusions The inspector concluded that the licensee's program for placing administrative holds on plant equipment was satisfactory in that no discrepancies were discovered in the tagouts during the system walkdowns, and that the tags were hung in accordance with procedure A-1401. Control room operators were knowledgeable with the computer database and were quickly able to obtain copies of the tagout worksheets.

The construction of the tags was considered excellent in that their sturdy construction minimized the potential for tag degradatio.2 Calorimetric Heat Balance Procedures a 0 Ins ection Sco e

(71707)

The inspector reviewed the procedures used to perform a plant calorimetric heat balance, and compared the manual calculation method with the plant computer calculation to determine if both results were accurate and within required limits.

b.

Observations and Findin s The Ginna Nuclear Plant is limited to a maximum primary plant thermal power of 1520 megawatts (100%), as defined in its license (DPR-18).

The plant's improved technical specifications (ITS) require that the results of the calorimetric calculation be compared to the nuclear instrumentation system (NIS) indication every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

'hen the reactor is at or above 50% power, and adjustments to the NIS are required if the difference exceeds 2%. The licensee normally implements this requirement once each operating shift by performing ITS surveillance requirement SR 3.3.1.2. using the plant's process computer system (PPCS) as the primary method for the calculation.

The computer method has been available since 1987 and uses a pre-programmed steam table subroutine, and selected one-minute averages of plant data inputs from feedwater temperature, pressure, and flow; main steam saturated pressure and flow; and steam generator blowdown temperature and flow to calculate reactor power.

The licensee used procedure 0-6.3, "Maximum Unit Power," for each calorimetric heat balance, which provided detailed instructions for completing PPCS and manual calculations.

For the PPCS calorimetric, plant operators normally input the average feedwater flow data obtained from the Barton gages in each feedwater loop.

However, if the PPCS is unavailable, a fully manual calculation would be performed using plant data taken directly from local instrumentation.

The manual calculation requires interpolation of steam table data in order to obtain accurate saturation temperatures and pressures.

In addition, procedure 0-6.3.1, "Steam Generator Blowdown Correction Factor," must be performed for a manual calorimetric to assure an accurate calculation.

The manual calorimetric is an infrequently performed evolution, but is required knowledge for all licensed operators.

Based on inspector questioning, an off-shift control room foreman (CRF) performed a manual calorimetric on April 24, 1997, using inplant data without the benefit of PPCS information in order to compare the accuracy of the manual and PPCS calculations.

During collection of feedwater temperature data, the CRF discovered that two resistance temperature detectors (RTDs) on the 5B feedwater heater outlet failed to indicate on their local instrument.

This caused the CRF to deviate slightly from the procedure and use the average feedwater temperature data only from the 5A feedwater heater in the calculation.

The CRF initiated a maintenance work request to have the RTD and/or the local instrument repaired, and indicated that portable instrumentation would be used in the event that a manual calorimetric was required under these circumstances.

Soon after all field data was collected, the CRF generated a PPCS calorimetric for later

comparison, then used the field data to perform a manual calculation.

The CRF used approximately one and one-quarter hours to collect data and perform the calculation; however, it appeared to the inspector that if frequent manual calculations were necessary due to unavailability of the PPCS, they would require significantly less time. The manual calculation resulted in 100.0% reactor power and the PPCS calculation resulted in 99.78%.

No subsequent adjustment to the NIS was necessary since they did not deviate from either of these values by more than 0.5%.

The inspector later confirmed (from PPCS data) that the actual differences between the 5A and 5B feedwater heater outlet temperatures was less than 1 degree Fahrenheit ('F), and that this difference would not have a significant effect on the results of the manual calculation.

The inspector further noted that procedure 0-6.3 required that reactor power be reduced if it exceeded 100%, and that an ACTION Report be initiated if either the PPCS or the manual calculation resulted in more than 102% power.

Any power reduction from above 100% required a subsequent calorimetric within two hours.

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Conclusions The inspector concluded that the manual and PPCS calorimetric calculation agreed well with each other. -The control room foreman demonstrated good proficiency in obtaining all the required plant process data and in performing the manual calculation.

The procedures used for both calorimetric methods provided sufficient instruction detail and acceptance criteria to assure that reactor power would be maintained within licensed limits.

Operator Knowledge and Performance 04.1 Auxiliar 0 erator AO Tours Ins ection Sco e (71707)

The inspector accompanied a primary plant AO and a secondary plant AO during routine operational watches.

b.

Observations and Findin s The inspector reviewed procedures A-52.1, "Shift Organization and Responsibilities," 0-6, "Operations and Process Monitoring," and 0-6.1, "Auxiliary Operator Rounds and Log Sheets" to determine the administrative requirements associated with each watch station.

The inspector accompanied a primary plant AO on May 13, 1997, and a secondary plant AO on May 14, 1997.

The primary plant operator's rounds were predominately in the auxiliary building and the secondary plant operator's rounds were predominately in the turbine building.

An additional AO was available on shift to fulfillemergency plan manning requirements and to make outdoor rounds.

The inspector interviewed the operators on some system operations, as well as routine watchstanding practices, and determined that AO's regularly rotate among each of the three watch stations to maintain proficiency in

each area.

Additionally, some AO's are licensed reactor operators and also regularly stand watch in the control room.

Individual watch station turnovers were conducted approximately 30 minutes prior to the regular shift turnover, which provided sufficient time to develop any details regarding plant status, and to answer questions raised by the oncoming watchstander.

During operator rounds, the inspector identified some minor plant deficiencies to the watchstanders.

These included a flow gage that was observed at its maximum range (component cooling water (CCW) to safety injection (Sl) pumps),

inappropriate labeling on some AC power distribution panels, and a temporary modification that had no authorization signature or estimated removal date (battery room's Gaitronics).

Operations personnel indicated that actions would be taken to correct the deficiencies.

The inspector reviewed the logs taken by the operators for accuracy and completion after the shift observations.

N Conclusions With the exception of minor deficiencies noted by the inspector, the observed AOs conducted their rounds in an efficient, competent manner, and in accordance with plant procedural requirements.

Their knowledge of plant system operations was good.

Both the individual watch station turnovers and the crew shift turnovers observed were thorough and conducted in a professional manner.

The operating logs inspected were complete and concise, and contained no identifiable mistakes.

Operator Training and Qualification Im roved Technical S ecification ITS Trainin for Mana ers and Su ervisors Ins ection Sco e (71707)

Based on previous NRC and licensee identified issues regarding implementation of the Improved Technical Specifications, the licensee provided training on the ITS.

'The inspectors attended and evaluated the licensee's training sessions on the ITS for Operations, Maintenance, and Training managers and supervisors.

Observations and Findin s On April 21-22, 1997, the inspectors attended training for managers and supervisors on the use and application of the ITS. presented by Nuclear Safety and Licensing personnel.

The instructor's presentation methodically reviewed the most significant ITS requirements, limiting conditions for operation (LCOs), LCO action statements, surveillance requirements (SRs), and their respective bases.

Plant personnel in attendance were encouraged to ask questions and raise concerns regarding ITS implementation.

Several issues were identified, including unclear ITS

"cascading" requirements, questions on the applicability of some LCO bases, clarifications of NOTEs in the ITS, clarifications of new or changed surveillance requirements, and the implementation of various action statement requirements.

The licensee had initiated a computer database to record and track all ITS concerns

that could not be immediately resolved, and many of the comments raised during the training sessions were recorded in that database.

Most of the ITS was covered during the two-day sessions; however, the licensee expected to schedule one additional day in the future to complete all ITS areas.

Additionally, the licensee identified that a controlled process was not in place for evaluating comments on ITS bases interpretations or for establishing priorities and department notifications regarding their resolution.

The licensee generated an ACTION Report (97-0681) to address this issue.

Conclusions The inspector concluded that the ITS training sessions were informative and provided valuable information to operations personnel regarding ITS implementation and applicability.

The inspectors also concluded that the licensee's efforts to track operators'omments on the ITS and to establish a controlled process for resolving those comments were good initiatives.

II. Maintenance M1 Conduct of Maintenance

'1.1 General Comments on Maintenance Activities a.

Ins ection Sco e 62707 The inspectors observed portions of plant maintenance activities to verify that the correct parts and tools were utilized, the applicable industry codes and technical specification requirements were satisfied, adequate measures were in place to ensure personnel safety and prevent damage to plant structures, systems, and components, and to ensure that equipment operability was verified upon completion of post maintenance testing.

b.

Observations and Findin s The inspectors observed portions of the following work activities:

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Nuclear instrument N35 (intermediate range) troubleshooting and maintenance, observed from May 5-16, 1997.

This maintenance was being performed in response to inadvertent spiking on N35 noted on May 5, 1997.

The instrument drawer was opened so that test equipment could be installed.

Smaller magnitude spiking occurred intermittently, and on May 13, 1997, the licensee replaced N35's isolation amplifier. However, this did not resolve the problem and the original isolation amplifier was reinstalled the next day.

The licensee then reinstalled the test equipment in the drawer, but did not observe any recurrence of the spiking problem.

On May 16, 1997, N35 passed its periodic test, was declared operable, and returned to servic Condenser tube and water box cleaning, observed on May 16, 1997.

This maintenance was performed to clear all condenser tubes and water boxes of biological growth and silt to enhance the heat transfer capability of the condenser and prevent a possible future power reduction due to condenser fouling caused by the debris.

This maintenance involved a power reduction in order to selectively remove the water boxes from service (see Section O1.2). Two water boxes (one on each condenser)

were simultaneously removed from service to enhance secondary plant balancing during the maintenance.

The licensee performed the maintenance using mechanical abrasion, without the use of chemical cleaning.

SW pump bay maintenance activities, observed on May 12, 1997 (see Section M2.1)

c.

Conclusions The inspectors concluded that the observed maintenance activities were performed in accordance with the procedural requirements, and the technicians demonstrated good knowledge of the maintenance requirements for the affected equipment.

The equipment received adequate post-maintenance testing prior to its return to service.

M1.2 General Comments on Surveillance Activities a.

Ins ection Sco e 61726 The inspectors observed selected surveillance tests to determine whether approved procedures were in use, details were adequate, test instrumentation was properly calibrated and used, technical specification limiting conditions for operation (LCOs)

were satisfied, testing was performed by qualified personnel, test results satisfied acceptance criteria or were properly dispositioned, and correct post-test system restoration was performed.

The inspectors also compared the basis for testing acceptance criteria in the Updated Final Safety Analysis Report (UFSAR) with that of the surveillance procedure observed.

b.

Observations and Findin s

The inspectors observed portions of the following surveillance activities:

PT-12.2, "Emergency Diesel Generator B," observed on April 23, 1997.

The test verified that the B-EDG would start from the control room and that its associated feeder breakers to the plant's safeguard buses would shut.

No discrepancies were noted during the test.

PT-12.1, "Emergency Diesel Generator A," observed on May 13, 1997.

This test was identical to PT-12.2 (above) and was performed as a post-maintenance test for the diesel after its bus supply breaker switch in the control room was replaced.

No discrepancies were noted during the tes ~

PT-2.1Q, "Safety Injection System Quarterly Test," observed on April 29, 1997 (C-Sl pump), and on May 1, 1997 (A-and B-SI pumps).

Following the test of the C-pump, Sl system header check valve 878J leaked at greater than the maximum allowed limit of 1.0 gpm.

Consequently, the licensee initiated a temporary procedure change to PT-2.1Q to flush the check valve, to vent the Sl injection header upstream of check valve 878J, and to reseat the check valve under a high differential pressure.

The check valve was successfully seated, but after the A-and B-pump tests, check valve 878J showed leakage of 0.9 gpm.

Since the leakage was within the allowed limit, and no back flow occurs through this check valve since the Sl header, is not normally vented, no further actions were taken.

c.

Conclusions Overall, the inspectors concluded that the observed surveillance activities were performed in accordance with procedural requirements and the technicians demonstrated a good understanding of the functional requirements of the equipment being tested.

The acceptance criteria in the UFSAR was consistent with that used in the surveillance tests, and the data recorded by the technicians reflected that observed by the inspectors.

M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Service Water SW Pum Strainer Foulin a ~

Ins ection Sco e (62707)

The inspectors reviewed the licensee's response to recent problems with the SW pump suction strainers.

b.

Observations and Findin s On April 15, 1997, the licensee sent divers into the SW pump bay to inspect the suction strainers at the inlet of each SW pump.

This dive was performed in response to a noted decrease in SW header discharge pressure from about 59-60 psig to 57-58 psig.

The strainers are shaped like large baskets around the inlet of the pumps, and included a small "trap door" (approximately 10" X 10") at the bottom of the strainer that would open on a high differential pressure to ensure adequate SW pump suction head in case of severe strainer fouling.

The divers discovered a significant amount of fouling around all four SW pump suction strainers with what appeared to be dead fish and biological growth.

Additionally, the trap doors from the C-and D-SW pumps were observed to be partially open.

The divers videotaped the st'rainers with an underwater camera.

The licensee generated an ACTION Report (97-0597) to address this condition.

The licensee also generated a work order (19701429) and mobilized a diving team to clean the strainers.

Strainer cleaning was completed at approximately 4:30 I

on April 15, 1997, and SW header discharge pressure was observed to return to 59-60 psig.

On April 16, 1997, Laboratory and Inspection Services (LIS) performed a post cleaning inspection and confirmed that all four SW pump strainers were clean.

The licensee performed an operability assessment on the SW system.

All four service water pump suction strainers had last been inspected and cleaned during the week of May 12, 1996.

The fouling was not perceived to be abnormal or consequential at that time. Additionally, the A-SW pump strainer was inspected and cleaned on July 15, 1996, during the overhaul of the A-SW pump.

No significant fouling was noted at that time. The licensee reviewed surveillance tests for the SW pumps conducted from the middle of 1996 through January 1997, which indicated a slightly decreasing differential pressure trend for all four SW pumps.

The D-SW pump's differential pressure had been recorded low in the ALERT range (which required increased surveillance monitoring), while the A-, B-,

and C-SW pump's differential pressures remained in the normal range.

The licensee concluded that all the SW pumps were capable of fulfillingtheir re'quired safety related function and were considered to have been operable from the time the SW pumps were last surveillance tested.

The licensee did not consider the open trap doors on the C-and D-SW pumps to be an operability problem at that time. However, they committed to perform routine checks of the strainers by lowering a video camera into the SW pump bay.

On May 11, 1997, at approximately 1:50 p.m. with the B and C-SW pumps running, control room operators received PPCS alarms for low SW header discharge pressure.

SW discharge pressure decreased below normal to approximately 45 psig for about 15 minutes, then increased and stabilized within the normal range (50-60 psig) at approximately 54 psig. At about 11:00 p.m. that same day, the A-and D-SW pumps were started and the B-and C-SW pumps were secured.

SW header discharge pressure increased to 59-.60 psig.

The licensee generated an ACTION Report (97-0754) in response to the unanticipated pressure drop.

On May 12, 1997, the licensee lowered a video camera into the SW pump bay to determine if any abnormal conditions in the pump strainers could be observed.

None of the SW strainers appeared to have any significant blockage or degradation.

The licensee then ran all the SW pumps in various combinations in an attempt to isolate the low discharge pressure problem to a single pump.

All pump combinations exhibited normal SW header discharge pressure except when the C-SW pump was in service, at which time header pressures dipped back to 54 psig.

The C-SW pump was declared inoperable at approximately 5:30 p.m. on May 12, 1997.

On May 13, 1997, testing was performed on the C-SW pump and motor.

Pump vibrations had increased slightly, but were still in the normal range, and the pump motor w'as found to be satisfactory.

On May 14, 1997, divers were sent into the SW pump bay to inspect the suction of the C-SW pump.

The divers discovered that an eel had apparently been drawn through the strainer trap door and into the pump's suction.

About 2/3 of the eel was still in the pump's intake area, and the other 1/3 had apparently been pulverized by the pump's impeller and drawn into the

SW system.

The licensee removed and photographed the eel's remains.

The eel's original length was approximately 5 feet.

During the course of the inspection, the divers needed to fully open the C-SW pump trap door to be able to access the pump mechanism.

During the attempt to open the trap door, the trap door broke off from the bottom of the stainer.

The trap door was then wired in the shut position on the bottom of the strainer.

The licensee generated an ACTION Report (97-0787) in response.

The C-SW pump was then tested satisfactorily, with all pump vibration data returning to previously recorded values.

SW header pressure returned to normal with the C-SW pump running.

However, the licensee maintained the C-SW pump inoperable pending the performance of an operability assessment.

The operability assessment was concluded on May 16, 1997.

The licensee determined that wiring shut the trap door was acceptable as long as the SW pump strainers were routinely inspected.

The licensee indicated that two camera inspections of the SW pump bay will be scheduled at six weeks intervals, and a final determination on inspection frequency will be made based on the results of an additional three and six month inspections.

The C-SW pump was declared operable at approximately 6:00 p.m. on May 16, 1997.

An additional dive was performed on May 20, 1997, and the D-SW pump's trap door was also wired shut.

C.

Conclusions The inspectors concluded that the licensee took aggressive action to determine the cause of the original dip in SW header discharge pressure, and took appropriate corrective actions to clear the SW pump strainers of fouling. The licensee's identification and response to the C-SW pump discharge pressure drop was also considered very good, and the corrective actions taken to resolve the trap door strainer problems were effective.

The licensee's decision to perform increased monitoring of the SW pump strainers was appropriate, and considered important in maintaining SW system reliability with increased amount of biological growth that has recently appeared in the SW pump bay, M6 Maintenance Organization and Administration M6.1 Inte rated 12-Week Work Schedule Ins ection Sco e

The inspector reviewed the licensee's newly implemented integrated 12-week work schedule for maintenance and surveillance activities in the plant.

b, Observations and Findin s For several months, the licensee has planned to revise the process for scheduling and performing maintenance work in the plant.

A new integrated work plan was developed throughout early 1997 to perform maintenance on a "system work week" (SWW) basis whereby most maintenance performed during a given week would be confined to selected plant systems on a 12-week rotation.

The revised

process was intended to 1) improve the coordination and efficiency of work among all plant organizations by consolidating work on specific components, 2) ensure that risks to plant safety are not significantly increased from critical combinations of systems and components being simultaneously out of service, 3) reduce the non-outage work backlog, and 4) reduce the size and age of the corrective maintenance backlog.

The licensee increased the number of individuals and positions within the scheduling organization to manage and coordinate the scheduling process, which involves a nine-week preparation period for each work week.

In addition, specific primary and

.backup representatives from responsible site organizations (Operations, Mechanical and Electrical Maintenance, Instrumentation and Controls, Site Engineering, Radiological Protection and Chemistry, Results and Test, and Performance Monitoring) are to participate in the Schedule Review Group (SRG) meetings for work schedule planning.

Four SRG meetings are conducted each week to scope and plan the seventh, fifth, fourth, and third advance weeks.

A defined planning sequence was designed to fix the final work schedule three weeks in advance.

The licensee accommodates emergent work in the final schedule on a case-by-case basis.

The process also included a follow-up week to review and reschedule activities that were not completed.

On April 14, 1997, the licensee implemented the first system work week.

One notable change under the revised scheduling process was increased interaction and communications between all work groups and the day-shift operations personnel in the control room.

Daily work schedule briefings are now held each morning between the oncoming operations shift, the work week coordinators, and individuals from the various work groups.

The inspector reviewed the two site level interface procedures that establish the program requirements and organization responsibilities.

IP-PSH-1, "Integrated Work Schedule," provided the program description and the scheduling process with a graphic process flow chart.

IP-PSH-2, "Integrated Work Schedule Risk Management,"

provided the administrative controls for evaluating and managing risk associated with the removal of equipment from service.

The procedure outlines an organizational philosophy for on-line maintenance that was designed to minimize the

'ime that equipment is unavailable, and requires that the reliability of equipment remaining in service be evaluated prior to scheduling redundant equipment for maintenance.

ITS-related equipment out of service for longer than 50% of the total time permitted by an LCO action statement requires plant manager approval.

The procedure was designed for risk assessments when the plant is operating, since other existing procedures apply during an outage.

Both procedures were well developed and provided good guidance for the interfacing organizations to accomplish better scheduling and work control, The licensee was currently evaluating the potential impact on the integrated schedule of NRC Information Notice (IN) 97-16, "Preconditioning of Plant Structures, Systems, and Components Before ASME Code Inservice Testing or Technical Specification Surveillance Testing."

The IN identified several unacceptable activities where preconditioning and maintenance was being performed on equipment at various nuclear plants just prior to testing.

The licensee has temporarily suspended plans to lubricate motor-operated valve stems before or during testing.

The licensee has formed an ad-hoc

committee to review all potential preconditioning concerns.

Additional administrative controls may be necessary to assure that the integrated work schedule process does not create these situations.

C.

Conclusions The inspector considered that the integrated work schedule was a positive initiative that made immediate improvements in the effectiveness of interactions and communications between the operating staff and other site work groups.

The administrative controls in place appeared adequate to establish the integrated scheduling program and processes.

The additional efforts now required to plan and schedule maintenance and testing provided for more effective work controls and for minimizing the total time that plant equipment is not available for service.

III. En ineerin E8 Miscellaneous Engineering Issues E8.1 Closed LER 97-001: Service Water Tem erature Less Than S ecified Value Due to Non-Re resentative Method of Monitorin Resulted in Condition Prohibited b Technical S ecifications LER 97-001 was submitted on March 3, 1997, in response to the licensee's discovery on January 31, 1997 that service water (SW) pump suction temperature (screenhouse bay temperature)

had dropped to 34.8 ~F based on a local reading with a hand held instrument.

Permanently installed temperature monitoring equipment indicated greater than 35 F. The ITS Basis for the SW system stated a

minimum service water pump suction temperature must remain with the limits assumed in the accident analysis (R35 F and M80 F).

Control room operators initiated actions to increase the screenhouse bay temperature by providing more condenser outlet discharge water to recirculate back into the screenhouse bay.

Within half an hour the coldest locally measured screenhouse bay temperature had increased above 35'F.

This condition failed to meet the surveillance requirements (SR) of ITS SR 3.7.8.1, thus placing the plant in a condition prohibited by the ITS for approximately half an hour.

The licensee attributed the cause of this event to an improper assumption that permanently installed temperature monitoring equipment downstream of the circulating water pumps was directly representative of screenhouse bay temperature at all locations, and that personnel were unaware that potentially significant amounts of temperature streaming existed in the screenhouse bay.

The licensee's engineering and licensing departments consulted with Westinghouse, who subsequently recalculated the worst case accident conditions assuming a 30 F

service water inlet temperature to limiting plant components.

The results indicated that the lower SW temperature would have a minimal impact.

Since the SW piping de'sign analysis and system design minimum temperature is 32 F, RGRE changed the ITS basis to a minimum SW inlet temperature of 32 F (see IR 50-244/97-01).

The licensee completed a safety evaluation to support the change to the ITS Basis.

Also, operations procedure 0-6.13, "Daily Surveillance Logs," was changed to direct operators to take manual readings of the screenhouse bay to ensure that temperatures are maintained greater than 32 F.

The inspectors considered that the LER adequately described this event and appropriately addressed the root causes and corrective actions.

This LER is closed.

IV. Plant Su ort R1 Radiological Protection and Chemistry (RP&C) Controls Reviews were performed of occupational radiation exposure, Specific areas reviewed included general radiological controls; status of facilities and equipment; the effectiveness of problem identification/resolution systems; and facility conditions versus the requirements in the UFSAR.

R1.1 Radiolo ical Controls a.

Ins ection Sco e (81502)

The inspector performed a review of general radiological controls including external dose controls, radiological boundaries, and contamination and radioactive material controls.

Information was gathered through tours of the auxiliary building, intermediate building, contaminated storage building, and upper radwaste storage facility (URSF); through reviews of procedural guidance and ACTION Reports; and through discussions with cognizant personnel

~

b.

Observations and Findin s

Primary external dose controls included maintaining the health physics control point at the entrance to the radiologically controlled area (RCA), and requiring personnel to sign-in on radiation work permits, obtain electronic dosimetry, and receive health physics briefings prior to entry into the RCA. Radiological survey data was posted at.the RCA entrance and at various areas within the plant.

Doors to areas controlled as locked high radiation areas were appropriately posted and securely locked; and keys to locked high radiation areas were contained in a locked box, and were well controlled by the shift health physics technician.

The inspector also reviewed exposure records for two declared pregnant women, and noted that an administrative exposure limit of 300 mrem had been established, and exposures were maintained well below this limit. Finally, the inspector reviewed as-low-as-reasonably-achievable (ALARA)radiation dose goals established for 1997.

The 1997 ALARAdose goal had been set at 100 person-rem, included the dose anticipated during the next refueling outage, and was determined to be reasonable and challengin Radiological boundaries were well defined, easily observable, and based on a review of survey data, accurately posted.

One minor inconsistency in radiological posting was observed in the waste gas compressor room in that the A-waste gas compressor pump was roped off and posted as having a contaminated pedestal, but did not have tape outlining the pedestal boundary.

Upon notification, health physics supervision performed an investigation and discovered that during maintenance on the A-pump, the pump pedestal had been posted the same as the B-pump for purposes of uniformity; however, the A-pump pedestal was not actually contaminated.

The inconsistent posting/boundary was corrected by removing the

"contaminated pedestal" posting.

The inspector noted that actions taken to correct the posting were appropriate; no violations of NRC requirements were identified.

Radioactive material packages and containers were found to be stored in a neat and orderly condition, and appropriately posted as radioactive material.

This included tools and equipment in the contaminated storage building and waste packages in the URSF.

However, during a tour of the URSF, the inspector noted that a current inventory was not maintained for the facility. Consequently, the inspector reviewed the following documents.

"Radiological Analyses in Support of the Conceptual Design for the Low-Level Radwaste Storage Facility, EWR¹10018," March 10, 1993.

"Safety Analysis for the Ginna Station Radwaste Storage Facility, EWR 3057, Rev. 1, September 11, 1981" Memorandum "Outside Radwaste Storage Building," (proposed storage materials) dated June 9, 1981 Ginna Updated Final Safety Analysis, Section 11.4.1.3 Storage Facilities, Rev. 13 Procedure RP-RAM-PACK-STORAGE, Rev. 0 The inspector noted that the procedural guidance did not specifically require a c'urrent inventory for the building to be maintained.

However, a March 10, 1993, document titled "Radiological Analysis in Support of the Conceptual Design for the Low-Level Radwaste Storage Facility" indicated that 75 curies of gamma emitting nuclides would be the likely bounding upper value for the facility. The inspector inquired how this proposed design limit was maintained if a current inventory was not available.

Health physics supervision stated that procedural guidance required the radiation protection organization to be notified prior to moving packages/container(s)

to their storage location to ensure that radiological controls were not exceeded, and that weekly surveys were performed at the facility. Based on a review of radiological surveys for the facility, the inspector concluded that controls had been effective in limiting radioactivity levels of materials stored in the facility. The inspector will review control measures used to ensure that radioactive material activity limits were not exceeded in the upper radwaste storage facility in a future inspection.

(IFl 50-244/97-03-01).

The inspector noted that the use of a contaminated (tool and equipment) storage btiilding (CSB) located within the RCA, had the potential for minimizing the movement of potentially contaminated tools and equipment across the RCA

boundary and was a good practice.

Radiological survey data also showed evidence of frequent contamination surveys within the plant, and contamination monitoring equipment was present and in good working condition at the RCA exit. The inspector also noted that the health physics staff was closely tracking personnel and area contamination, and had set goals for 1997 (which included the next refueling outage), to limit personnel contaminations to below 80, and to minimize contaminated areas in the auxiliary building and CSB to less than 6,500 square feet.

c.

Conclusion Based on this review, the inspector concluded that radiological controls including external dose controls, radiological area controls, and radioactive material and contamination controls were good.

R2 Status of RP&C Facilities and Equipment R2.1 Housekee in and Material Conditions a.

Ins ection Sco e (81502)

The inspector performed a review of housekeeping and material condition.

Information was gathered through plant tours and discussions with cognizant personnel.

b, Observations and Findin s Overall housekeeping was very good in that aisles and walkways'were clear and free of debris, and fresh paint had been applied in many areas.

The inspector did note some accumulation of dust in corners and crevices, and dust accumulation was identified on some ventilation intakes in the auxiliary building.

Groundwater intrusion was observed in two areas including the URSF, and the intermediate building sub-basement.

The water in the URSF amounted to a puddle of water in the middle of the lower bunker.

A radwaste staff member stated that although a large volume of water had never accumulated, a puddle of standing water was continuously present in the middle of the lower bunker.

The inspector noted that the standing water did not hinder the movement or storage of radioactive material packages, and survey data showed that the area was maintained as a radiologically clean (non-contaminated)

area.

The inspector also directly observed groundwater leaking into multiple locations of the intermediate building sub-basement.

Mineral deposits had collected on several locations of the sub-basement walls, and excess water flowed to the sub-basement moat where it was collected and processed through plant systems as potentially contaminated.

Similarly, survey data showed that this area was maintained as a clean (non-contaminated)

area.

The inspector noted that the sub-basement was not used as a storage area, and it appeared that no operating plant equipment was affected by the ground water intrusio c.

Conclusions Based on this review the inspectors concluded that housekeeping in radiologically controlled areas was very good.

Areas affected by ground water intrusion in the upper radwaste storage facility and the intermediate building sub-basement, were maintained as radiologically clean (non-contaminated)

areas; operating plant equipment was apparently not affected; and excess water in the intermediate building sub-basement was processed as potentially contaminated.

R3 RP&C Procedures and Documentation R3.1 Dosimetr Procedure a 0 Ins ection Sco e (81502)

The inspector reviewed policies and requirements for performing employment termination whole body counts.

Information was gathered through a review of procedure RPA-DOS, "Dosimetry Program Administrative Procedure,"

Rev. 1, and through discussions with cognizant personnel.

b.

Observations and Findin s

Procedural guidance required thermoluminescent dosimeter (TLD) badged individuals to receive a whole body count annually, upon initial entry to Ginna, and in special circumstances such as a suspected inhalation or ingestion of radioactivity.

The inspector noted that procedure RPA-DOS had recently been revised to require an evaluation of the individual's work activities, or receipt of an acceptable entrance whole body count performed at another faclity in the event that an exit whole body count is not performed at the Ginna Station.

c.

Conclusion Based on this review, the inspector concluded that procedural guidance for conducting termination whole body counts was good, and recent procedural changes were reasonable.

R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 RP&C Audits Surveillances and ACTION Re orts a.

Ins ection Sco e (81502)

The inspector performed a review to evaluate the effectiveness of quality assurance surveillances/audits and the station problem identification/resolution program (ACTION reporting system) for correcting radiological deficiencies.

Information was gathered by reviews of quality assurance audits, surveillances, and self-assessments; selected ACTION Report issues; and discussions with cognizant

personnel.

The inspector reviewed four surveillances, two audits, and three self assessments.

Observations and Findin s Audits and Surveillances The overall quality of the audits/self assessments was very good.

Several of the surveillance teams included technical specialists (assessment personnel) from outside of RG&E, and findings/concerns were entered into the ACTION reporting

, system for resolution or tracking.

ACTION Re orts The inspector reviewed a list of radiological control issues entered into the ACTION reporting system and noted that the number had increased from 13 during the last quarter of 1996 to 30 during the first quarter of 1997.

The threshold for entering radiological issues into the ACTION reporting system appeared low as evidenced by the following examples of ACTION Report issues:

a pothole identified in the upper radwaste storage building; excess tool boxes were stored in the RCA; and an outdated procedure was found in a field log book.

The inspector reviewed ACTION Report topics for trends and noted that multiple examples of radiological boundary deficiencies and electronic dosimeter problems were identified.

However, based on a review of selected ACTION Reports, plant tours, and discussions with cognizant personnel, the inspector concluded that special emphasis had been recently directed in these areas to address emerging trends.

The inspector requested several reports from the ACTION reporting system and observed that some difficulties were encountered during computer searches of the system's database.

For example, no standardized method was available for searching and retrieving all ACTION Reports related to radiological controls.

In addition, the system did not appear to lend itself to direct (easy) trending of ACTION Report causes and corrective actions.

The inspector raised the concern that if difficulties were encountered during system searches, then the system may not be fully utilized to resolve program deficiencies or evaluate the effectiveness of corrective actions.

The Technical Assessment Coordinator (TAC) demonstrated that comprehensive information was included in the ACTION reporting system, but acknowledged that system reporting capabilities were not fully developed.

The TAC stated that a multi-disciplinary team had been assembled and assigned to recommend and implement program improvements in order to make the system more useful.

The inspector also reviewed the following ACTION Reports to evaluate the effectiveness of corrective actions.

ACTION Re ort 97-0321:

An excess number of gang boxes, tool boxes, and ca'binets were stored in the radiologically controlled area (RCA). This ACTION Report was written on March 3, 1997 to address clutter, poor housekeeping, and

an increased potential for creation of radwaste and inadvertent release of radioactive material due to storage of excess tools and equipment in various areas of the RCA. The inspector toured identified areas and discussed with cognizant personnel the actions taken to remove excess materials and equipment from plant areas.

The inspector noted that specific areas identified in the ACTION Report were cleared of clutter and stored materials.

This included the hallway to the contaminated storage building (CSB) and the top level and basement of the intermediate building.

The inspector concluded that appropriate actions were taken to address this ACTION Report.

ACTION Re ort 97-0186:

A pothole was identified in the upper radwaste storage building.

This ACTION Report was written on February 3, 1997 to address a

concern that radwaste containers could topple during movement.

The inspector toured the upper radwaste storage area and verified that the pothole had been repaired.

The inspector concluded that appropriate corrective actions had been taken to address the ACTION Report.

c.

Conclusions Based on this review, the inspector concluded that audits and surveillances were effective in identifying and resolving program weaknesses.

The ACTION reporting system was good in that the threshold for entering items into the system was low, and the system was effectively used to resolve identified problems.

However, computerized reporting capabilities were not fully developed, resulting in some difficulties in searching and trending of radiological deficiency issues.

RS Miscellaneous RPRC Issues R8.1 UFSAR Review While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected.

The inspector reviewed selected sections of Chapter 12, "Radiation Protection," of the Updated Final Safety Analysis Report (UFSAR) pertaining to radiological controls to evaluate the accuracy of the UFSAR regarding existing plant conditions and practices.

No UFSAR discrepancies were identified during this review.

R8.2 Closed VIO 50-244 96-03-02: Contaminated equipment released to the DC Cook plant.

The inspector verified the corrective actions described in the licensee's response letter, dated December 12, 1996, to be reasonable and complete.

No similar problems were identified.

R8.3 Closed URI 50-244 96-06-05: UFSAR discrepancies.

Section 11.2.2.19 described the method for laundering protective clothing utilizing a dry cleaning unit. It was observed that the dry cleaning unit had been removed from service and the licensee was using an off-site vendor.

Section 11.4.1.1.1, listed cemented evaporator bottoms as one component of solid waste generated at Ginna.

Cemented M

evaporator bottoms had not been produced since 1990.

In addition, oily wastes were listed as a waste type that was processed on site and it was noted that oily wastes were being shipped offsite for processing.

The inspector verified that the wording in the UFSAR had been updated to reflect actual status of these components.

This item is closed.

R8.4 Sam le Results From Areas Affected B Steam Generator Blowdown During the Spring 1996 refueling outage, the licensee discovered that the steam generator blowdown piping had eroded and washed-out some soil beneath portions of the turbine building basement floor. The licensee performed an evaluation and determined that all plant equipment was well supported by concrete pedestals that communicated directly with bedrock.

The blowdown piping was rerouted and replaced, and plans were made to fillvoid areas with grout.

Prior to grouting, three soil samples were obtained to evaluate potential radioactivity levels and provide documentation for future decommissioning as required by 10 CFR 50.75(g).

Samples were taken of the soil beneath the turbine building floor at the following locations: nine feet west of the flash tank; 50 feet west of the flash tank; and 17 feet south of the main feed water pump room.

The sample obtained 50 feet west of the flash tank had the highest radionuclide activity and the results were as follows:

Sample Results From Areas Affected By Formerly Degraded Steam Generator Blowdown Piping Isotope Cs-137 Cs-134 Activity (yCI/cc)

3. 1 E-7 3.9E-7 NY State Remediation Limit (yCI/cc)

2.7E-7 0.7E-7 Radiological half-life (years)

30.2 2.1 R8.5 Status of Efforts to Quantif Fuel Pool Leaka e

NRC Inspection Report No. 50-244/96-06 summarized several actions, including proposed completion dates, that the licensee planned to take to investigate and minimize fuel pool leakage.

The inspector reviewed the current status of licensee efforts taken to investigate and minimize fuel pool leakage.

The inspector was informed that in order to install a weir gate bladder, it was necessary to remove the weir gate and perform a modification.

Due to concerns associated with heavy loads, the planned modification was delayed until the fall of 1997.

In addition, completion of work to apply an epoxy seal to the bottom of the transfer slot where anchor bolts penetrated the liner had only been partially performed, and its completion had also been rescheduled until the fall of 1997.

Finally, the effort to quantify the fuel pool evaporation rate had been rescheduled to be performed subsequent to the spent fuel pool gate bladder installation and epoxy seal of bottom of the transfer slot. Efforts taken to investigate and minimize fuel pool leakage will be reviewed during future inspection S3, Security and Safeguards Procedures and Documentation S3.1 Pro ram Policies and Procedures a.

Ins ection Sco e (81502)

Determine whether changes to the licensee's FFD policies and procedures, including those to resolve previously identified issues, have not adversely affected program implementation and have been reviewed, approved, distributed and retained as required.

b.

Observations and Findin s and Conclusion The inspector reviewed revisions of the licensee's FFD program procedures made since the last inspection conducted October 1996.

Additionally, the inspector verified that fitness-for-duty procedure FFD-12, "Training Requirements,"

was revised to reflect changes made to the'training program and FFD-8, "Random Test Selection and Notification Process," was revised to provide clarification of the reporting requirements for all persons involved in the random notification process as noted in the licensee's response to a Notice of Violation dated December 20, 1996.

The inspector randomly selected and reviewed FFD procedure manuals listed on the licensee's FFD controlled'istribution assignment sheet to ensure procedural revisions were being properly controlled and distributed.

The inspector found the changes to be commensurate with regulatory requirements.

C.

Conclusion The inspector concluded that FFD procedure changes did not adversely affect program implementation, and procedure and'policy changes were being reviewed, approved, distributed in a timely manner, and properly controlled.

S5 Security and Safeguards Staff Training and Qualification 55.1

~Trainin a.

Ins ection Sco e (81502)

Determine whether changes made to the licensee's FFD training program, as the result of previously identified issues, have been appropriately incorporated into the FFD training program, Verifythat awareness, supervisory, escort, and refresher training has been provided and taken as required.

b.

Observations and Findin s The inspector reviewed revised FFD training lesson plans and tests, and determined that the initial and refresher training programs satisfy the requirements of rule 10 CFR 26.

Based on discussions with FFD supervision, the inspector was informed that all employees will receive supervisory FFD training during annual

general employee training (GET) in addition to awareness and escort training.

Because of past problems associated with tracking supervisory training, such a

practice would ensure that supervisors receive annual refresher training as required by the rule. Additionally, the inspector reviewed training records of licensee and contractor supervisory and non-supervisory personnel to determine whether initial and refresher training was provided and taken as required.

C.

Conclusions Documentation on file confirmed that FFD training satisfies the requirements of rule 10 CFR 26 and was being provided in a timely manner to all persons granted unescorted access.

S7 Quality Assurance in Security and Safeguards Activities S7.1 Random FFD Testin Pro ram a 0 Ins ection Sco e (81502)

The inspector reviewed changes made to the licensee's random FFD testing program, including those to resolve previously identified issues, to determine whether they met regulatory requirements and had not adversely affected the program.

b.

Observations and Findin s The inspector determined, based on a review of FFD medical records, FFD performance data, procedures and discussions with collection facility personnel that the random testing program was effective.

The selection process was random and personnel tested were immediately eligible for selection for another test.

The computer used for random selection was located in a secure area and access was limited to a few designated individuals.

Random testing was being performed on backshift and holidays, and records were kept and maintained in accordance with approved licensee procedures and NRC requirements.

A previously identified weakness associated with the licensee's failure to test an employee selected for random FFD testing was reviewed by the inspector.

To resolve the concern, the licensee revised FFD procedure FFD-8, titled "Random Test Selection and Notification Process;"

and the Plant Manager issued a position statement reiterating the importance of reporting for testing once notification has been made.

C.

Conclusions Random FFD testing was being performed as required by 10 CFR 26 and procedural revisions implemented to address previously identified weakness appeared to be effective based on the inspector's review of testing records and discussions with

collection site personnel.

Management was actively involved in effective program oversight.

S7.2 Audits aO Ins ection Sco e (81502)

The inspector reviewed the licensee's audit reports for the FFD program, since the last inspection, to determine compliance with NRC requirements and whether licensee commitments and corrective actions to resolve identified issues were technically adequate, met regulatory requirements, and were implemented in a timely manner.

b.

Observations and Findin s The inspector reviewed the 1996 combined QA audit of the security, access authorization, and FFD programs, conducted August 27 - October 2, 1996, (Audit No. 1996-0009).

The audit was found to have been conducted in accordance with the NRC-approved physical security Plan and rule 10 CFR 26. To enhance the effectiveness of the audit, the audit team included an independent technical specialist. The audit report identified three deficiencies, two applicable to the FFD program.

One deficiency involved a potential source of dilution water being accessible in the drug testing facility; the second deficiency involved continual observation training. The audit results had been disseminated to the appropriate levels of management.

Based on discussions with security management and a review of the responses to the deficiencies, the inspector determined that the corrective actions were effective.

C.

Conclusions The inspector concluded that the audit was comprehensive in scope and depth, that the findings were appropriately distributed and addressed, and that the audit program was being properly administered.

S8 Miscellaneous Security and Safeguards Issues S8.1 Corrective Action Follow-u a.

Ins ection Sco e (92904)

The inspector reviewed the corrective actions taken for deficiencies related to two FFD violations.

b.

Observations and Findin s The inspector evaluated the follow-up actions noted in the licensee's response to the Notice of Violation dated December 20, 1996.

The two previously identified

~

~

~

s

violations concerned annual supervisory fitness-for-duty (FFD) training and random FFD testing.

The inspector determined that changes to the licensee's FFD program made since the last inspection in October 1996, satisfied commitments to resolve previously identified issues and did not adversely affect the overall operation of the licensee's program.

Closed VIO 50-244 96-10-01:

Failure to Provide Re uired FFD Su ervisor Refresher Trainin Based on a review of FFD training records conducted in October 1996 (see IR 50-244/96-10), the inspector determined that refresher FFD training was not being given on an annual basis and that at least 10 supervisors had not received refresher supervisor training on a nominal 12 month frequency.

Based on the results of the security and safeguards inspection activities reported above, this item is closed.

Closed VIO 50-244 96-10-02: Failure to Test Persons Selected for Random FFD

~Testin i

C.

While reviewing the licensee's FFD random testing program in October 1996 (see IR 50-244/96-10), the inspector determined that the licensee failed to test an employee selected for random FFD who was available on site without a legitimate reason for the employee 'to be excused from testing on the day selected.

Based on the results of the security and safeguards inspection activities reported above, this item is closed, Conclusions Based on reviews of applicable documentation and discussions with FFD management, the inspector determined that the corrective actions implemented by the licensee to address the subject violations were reasonable, complete, and appeared to be effective.

V. Mana ement Meetin s

X1 Exit Meeting Summary An interim exit meeting for the radiological protection inspection was held with the licensee on April 2, 1997.

An interim exit for the security and safeguards inspection was held on May 1, 1997. After the inspection was concluded, the inspectors presented the overall results of all inspection activity during the current reporting period to members of licensee management on May 27, 1997.

The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary, No proprietary information was iddntifie L2 Review of UFSAR Commitments

A recent discovery of a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR description.

While performing the inspections discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected.

The inspector verified that the UFSAR wording was consistent with the observed plant practices, procedure and/or parameters.

Since the UFSAR does not specifically include security program requirements, the inspectors compared licensee activities to the NRC-approved physical security plan, which is the applicable document.

While performing the inspection discussed in this report, the inspector reviewed Section 5.2.1 of the Plan, Revision L, dated March 13, 1996, titled "Unescorted Personnel Access Authorization."

Based on discussions with security supervision and by reviewing applicable documentation, the inspector determined that the licensee has a program in place to ensure that unescorted access within protected and vital areas is limited to authorized personnel who need access to perform their dutie Attachment

PARTIAL LIST OF PERSONS CONTACTED Licensee S. Eckert D.'Filion B. Flynn C. Forkell G. Graus A. Harhay L. Hauck A. Herman N. Hessler J. Hotchkiss G. Joss J. Knorr M. Lilley R. Marchionda F. Mis R. Ploof A, Plummer P. Polfleit J. Smith B, Stanfield R. Teed W. Thomson T. White J. Widay G. Wrobel Nuclear Access Authorization Administrator Radiochemist Primary Systems Engineering Manager Electrical Systems Engineering Manager IRC/Electrical Maintenance Manager Radiological Protection 5 Chemistry Manager Fitness-for-Duty Coordinator Health Physicist Human Resources Group Manager Mechanical Maintenance Manager Results and Test Supervisor Training Development and Evaluation Manager Quality Assurance Manager Production Superintendent Principle Health Physicist Secondary Systems Engineering Manager Medical Services Director Emergency Preparedness Manager Maintenance Superintendent QA Engineer, Independent Assessment Nuclear Security Supervisor Health Physicist Operations Manager Plant Manager Nuclear Safety 5 Licensing Manager INSPECTION PROCEDURES USED IP 37551'P 40500:

IP 61726:

IP 62707:

IP 71707:

IP 71750:

IP 81502:

IP 83750:

IP 92904:

Onsite Engineering Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Surveillance Observation Maintenance Observation Plant Operations Plant Support Fitness-For-Duty Program Occupational Radiation Exposure Follow-up - Plant Support

Attachment

~Oened ITEMS OPENED, CLOSED, AND DISCUSSED 50-244/97-03-01 IFI Review of control measures used to ensure that radioactive material activity limits are,not exceeded in the upper radwaste storage facility. (Section R1.1)

Closed 50-244/96-03-02 VIO Contaminated equipment released to DC Cook. (Section R8.2)

50-244/96-06-05 URI UFSAR discrepancies in Section 11.2.2.19 and Section 11.4.1.1.1. (Section R8.3)

50-244/96-1 0-01, VIO Failure to Provide Required FFD Supervisor Refresher Training (Section S8.1)

50-244/96-1 0-02 VIO Failure to Test Persons Selected for Random FFD Testing (Section S8.2)

AFW ALARA ASME CCW CFR CSB CW d/p ECCS EDG ESF EWR FFD IFI

- IR ISI IST ITS LCO LER MOV mrem NRC LIST OF ACRONYIVIS USED Auxiliary Feedwater As Low As Reasonably Achievable American Society of Mechanical Engineers Component Cooling Water Code of Federal Regulations Contaminated (tool and equipment) Storage Building Circulating Water differential pressure Emergency Core Cooling System Emergency Diesel Generator Engineered Safety Feature Engineering Work Request Fitness-for-duty Inspector Follow-up Item

Inspection Report

Inservice Inspection

Inservice Test

Improved Technical Specification

Limiting Condition for Operation

Licensee Event Report

Motor-Operated Valve

millirem

Nuclear Regulatory Commission

Attachment

NRR

NSARB

PORC

ppm

PT

psl9

QA

QC

RCA

RGS.E

RHR

RP

RP&C

RWP

SEV

Sl

SW

TAC

TLD

UFSAR

URI

URSF

VIO

pCi

Nuclear Reactor Regulation

Nuclear Safety Audit and Review Board

Plant Operations Review Committee

parts per million

Periodic Test

pounds per square inch gage

Quality Assurance

Quality Control

Radiologically Controlled Area

Rochester

Gas and Electric Corporation

Residual Heat Removal

Radiation Protection

Radiological Protection and Chemistry

Radiation Work Permit

Safety Evaluation

Safety Injection

Service Water

Technical Assessment

Coordinator

Thermoluminescent

dosimeter

Updated Final Safety Analysis Report

Unresolved Item

Upper Radwaste

Storage Facility

Violation

microcurie

degrees

Fahrenheit