IR 05000244/1997010

Insp Rept 50-244/97-10 on 970908-1013.No Violations Noted. Major Areas Inspected:Operations,Including Licensed Operator Requalification Program,Maint,Engineering & Plant Support, Including Emergency Preparedness Program

ML17264B117
Person / Time
Site:	Ginna
Issue date:	11/21/1997
From:	Doerflein L NRC (Affiliation Not Assigned)
To:
Shared Package
ML17264B116	List: IR 05000244/1997010 ML17264B115
References
50-244-97-10, NUDOCS 9712010367
Download: ML17264B117 (48)

Text

U,S. NUCLEAR REGULATORYCOMMISSION

REGION I

License No.

DPR-18 Report No.

50-244/97-10 Docket No.

50-244 Licensee:

Facility Name:

Location:

Rochester Gas and Electric Corporation (RGRE)

R. E. Ginna Nuclear Power Plant 1503 Lake Road Ontario, New York 14519 Inspection Period:

September 8, 1997 through October 13, 1997 Inspectors:

P. D. Drysdale, Senior Resident Inspector C. C. Osterholtz, Resident Inspector J. M. D'Antonio, Operations Engineer D. A. Silk, Senior Emergency Preparedness Specialist Approved by:

L. T. Doerflein, Chief Projects Branch

Division of Reactor Projects 97i20f03b7 97ii2i PDR ADQCK 05000244

EXECUTIVE SUMMARY R. E. Ginna Nuclear Power Plant NRC Inspection Report 50-244/97-10 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support.

The report covers an 5-week period of resident inspection.

In addition, it includes the results of announced inspections by a regional emergency preparedness program inspector, and an licensed operator examiner.

~Oerations The Ginna plant was operated at full power through most of the inspection period. A power coastdown commenced late in the period prior to the impending refueling outage.

Operator performance observed throughout the inspection period was generally good; however two examples of weak configuration controls were observed when reactor makeup water was inadvertently drained into the waste holdup tank.

Control room operators performed well while troubleshooting the inadvertent discharge; however, it was apparent that personnel errors and potentially inadequate maintenance contributed to these events.

The licensee's intention to conduct training on configuration control deficiencies and maintenance practices were appropriate.

This will be an inspector follow-up item (IFI 50-244/97-10-01).

The licensee took appropriate corrective actions to address the inadvertent actuation of the fire deluge system for the turbine-driven auxiliary feedwater pump. Additionally, the security department's investigation which determined that the actuation was unintentional was prompt and thorough.

The licensed operator requalification program, examination materials, and the licensee's conduct of examinations were satisfactory.

The operating crew'and all individuals passed their requalification examinations under both the NRC and the licensee's grading.

Conflicting cautions in the emergency operating procedure for transfer to cold leg recirculation had not been appropriately addressed.

Although the cautions were incorporated from generic industry-wide procedures, the licensee's approach to the conflict was atypical and depended upon situation-specific evaluations.

The licensee was training operators to evaluate the degree to which they should comply with one caution, and excessive use of evaluator judgement in grading procedure tasks in Job Performance Measures (JPMs).

This item remains unresolved (URI 50-244/97-10-02)

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Overall, the receipt inspection of new fuel was thorough and well controlled.

The records completed by a quality control inspector were complete and accurate.

Licensee Event Report (LER)97-003, Revision 1, was submitted to provide additional information pertaining to the licensee's discovery that all four high steam flow inputs to the main steam isolation circuitry were inoperable.

The additional information provided in the revision appropriately supported the analysis and corrective actions described in LER 97-003. This LER was closed (LER 97-003, Revision 1).

Executive Summary (cont'd)

Maintenance Observed maintenance activities were performed in accordance with procedure requirements.

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

Good personnel and plant safety practices were observed.

The as-found and as-left test data met the expected performance values and the specified acceptance criteria stated in the Updated Final Safety Analysis Report.

The procedures used were

'urrent and properly followed.

Limiting Condition for Operation (LCO) maintenance was successfully performed on the B-residual heat removal (B-RHR) pump. A good post-maintenance test critique identified areas for improvement, which included the addition of an LCO work coordinator.

The licensee's decision to maintain increased monitoring of the 8-RHR pump to evaluate escalated vibration was appropriate.

~En ineerin The licensee adequately evaluated the potential for a loss of RHR injection capability for a loss of coolant accident (LOCA) in MODE 4 operations.

The safety evaluation written to support modification of the emergency core cooling system (ECCS) configuration adequately evaluated the capability of the safety injection (Sl) hot leg flow paths to provide sufficient cooling flow during the injection phase of a MODE 4 LOCA.

The classroom training for system engineers on the new vendor technical manual (VTM)

program was very good.

The topics covered adequately addressed the new program requirements.

The instructor was effective in relaying VTM program information and encouraging audience participation.

Two independent assessments of the licensee's maintenance rule program were thorough and timely. Several program deficiencies were identified and appropriately incorporated into a program action plan for completion by mid January 1998.

The licensee continued to maintain a very good emergency preparedness (EP) program.

The emergency response facilities, personnel, procedures, instrumentation and supplies were maintained in a high state of readiness.

The licensee's 1997 EP audit apparently did not address or evaluate drills and exercises as stated in 10 CFR 50.54(t). This was considered an inspector follow-up item (IFI 50-244/97-010-03).

Despite not specifically evaluating drills and exercises during the 1997 audit, the audit was of sufficient scope and depth to effectively assess the EP program, and the audit contained numerous recommendations to enhance the program.

The audit was thorough and the report was useful to licensee management in assessing the effectiveness of the EP progra TABLEOF CONTENTS EXECUTIVE SUMMARY

TABLEOF CONTENTS IV I. Operations

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Conduct of Operations......

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01.1 General Comments...................................

01.2 Summary of Plant Status

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05.2 Requalification Examination Administration Practices...........

05.3 Training Feedback System

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05.4 Remediation Practices Quality Assurance in Operations 07.1 Nuclear Safety Audit Review Board (NSARB) Quarterly Meeting 07.2 New Fuel Receipt Inspection...... ~... ~................

Miscellaneous Operations Issues.............

08.1 Operator Action Times and Procedure Cautions..............

08.2 (Closed) Licensee Event Report (LER)97-003, Revision 1: Bistable Instrument Setpoint (Plus Instrument Uncertainty) Could Exceed Allowable Value, Causes a Condition Prohibited by Plant Technical Specifications.........................

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E2 Engineering Support of Facilities and Equipment E2.1 Residual Heat Removal Capability in MODE E5 Engineering Staff Training and Qualification E5.1 Vendor Technical Manual Training

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Table of Contents (cont'd)

P1.1 P1.2 P1.3 Response to Actual Events.........

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Effectiveness of Licensee Controls in Identifying, Resolving and Preventing Problems

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EP Procedures and Documentation........

P3.1 Nuclear Emergency Response Plan and Implementing Procedures Staff Training and Qualification in EP.. ~........

P5.1 Emergency Response Organization Training Program EP Organization and Administration... ~...........,...

P6.1'mergency Preparedness Organization..................

Quality Assurance (QA) in EP Activities P7.1 QA Audits of EP Activities Miscellaneous EP Issues.............................

P8.1 Updated Final Safety Analysis Report (UFSAR) Inconsistencies

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P8.2 (Update) IFI 50-244/96-01-03:

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. 27 ATTACHMENTS Attachment 1 - Partial List of Persons Contacted

- Inspection Procedures Used

- Items Opened, Closed, and Discussed

- List of Acronyms Used

- Emergency Plan and Implementing Procedures Reviewed

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: 1) tours of the accessible areas of the facility; 2) 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; 3) verification of engineered safety feature (ESF) system operability; 4) verification of proper control room and operator shift staffing; and 5) verification that logs and records accurately identified equipment status or deficiencies.

01.2 Summar of Plant Status The Ginna plant was operated at full power through the inspection period until 8:50 a.m. on October 11, 1997, when power coastdown operations commenced prior to the impending refueling outage.

Operator performance observed throughout the inspection period was generally good.

On September 8, 1997, leakage from the C-charging pump packing 'reached its administrative limit of 0.5 gallons per minute (gpm) ~ Packing replacement had been originally scheduled for after the refueling outage.

However, the licensee appropriately decided to perform this maintenance prior to the refueling outage, and the pump packing was replaced on October 9-10, 1997.

On September 12, 1997, a main drive shaft sheared on the B-traveling screen, apparently from fatigue failure. The shaft was successfully repaired and the B-traveling screen was returned to service on September 20, 1997.

From September 15 through September 17, 1997, improved technical specification (ITS) limiting condition for operation (LCO) maintenance was successfully performed on the B-RHR pump to replace a leaking shaft seal and to modify the pump's component cooling water (CCW) piping (see section M2.1).

On September 18 and 19, 1997, inadvertent primary coolant discharges of to the waste hold up tank (WHUT) occurred on consecutive days.

Personnel error and weak configuration control contributed to these discharges (see section 02.1).

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

Individual reports are not expected to address all outline topic On October 6, 1997, a flange gasket failed on the bottom of the all volatile treatment (AVT) acid tank causing an unisolable leak of sulfuric acid.

The licensee drained the tank and replaced the gasket, and no significant effects occurred in the plant. The licensee maintained good hazardous boundary controls during the repairs.

The AVTtank was returned to service on October 10, 1997.

On October 9, 1997, during preparations for the upcoming refueling outage, contract personnel inadvertently actuated a fire alarm and the automatic water deluge system for the turbine driven auxiliary feedwater (TDAFW) pump (see section 02.2).

On October 12, 1997, the B-feedwater regulating valve (B-FRV) bypass piping developed a significant through wall steam leak, apparently caused by jet impingement.

Following discovery, operators immediately isolated both bypass valves.

The failed section of bypass piping was last inspected in 1992 during installation of the advanced digital feedwater control system (ADFCS). The licensee indicated that a temporary modification would be performed on the bypass piping so the bypass valves could be available for the plant shutdown.

The licensee also indicated that permanent repairs to the bypass piping would be performed during the upcoming outage.

On October 13, 1997, reactor coolant system (RCS) letdown control valve (PCV-135) failed to automatically control letdown flow when operators attempted to shift letdown from 40 gpm to 60 gpm to increase purification flow in preparation for the refueling outage.

Troubleshooting by instrumentation and control (IthC)

personnel revealed a faulty relay in the automatic control circuitry for the valve.

The relay was replaced, and the valve was tested satisfactorily and returned to service the same day,

Operational Status of Facilities and Equipment 02.1 Inadvertent Dischar e of Primar Coolant to the Waste Hold U Tank WHUT a ~

Ins ection Sco e (71707)

The inspectors reviewed the circumstances surrounding the inadvertent discharge of letdown water to the WHUT on consecutive days.

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Observations and Findin s On September 18, 1997, while performing a valve lineup for resin replacement on the B-deborating demineralizer, approximately 280 gallons of primary letdown water was inadvertently discharged into the plant's WHUT. Control room operators recognized that the discharge was occurring after noting a decreasing level in the volume control tank (VCT), and the initiation of automatic primary coolant make up.

Operators restored the system lineup to normal to stop the discharge.

An auxiliary operator then noted that valve V-214 (B-letdown mixed bed demineralizer backwash drain valve to the WHUT) had a deficiency tag attached to it dated July 31, 1997,

and which read "Unable to determine if valve is fully closed.

Handwheel continues to spin." V-214 is normally operated remotely with a reach rod to minimize radiation exposure from the resin tank.

The licensee concluded that a flow'ath was established from the letdown system through V-214 when valve V-1610B (CVCS ion exchangers drain header isolation valve to the WHUT) was opened as part of the demineralizer maintenance.

Closer inspection of V-214 revealed that a failed bushing prevented the valve from fullyclosing.

The licensee generated an ACTION Report (97-1447) to address the issue.

The inspectors were concerned that operations personnel had not previously identified (e.g., with a hold tag, operator workaround, etc) the potential flow path when the V-214 deficiency was originally identified in July. The licensee indicated that operator training would b'

held on identifying potential configuration control problems before they occur, using this event as a case study.

The licensee also stated that they intended to repair V-214 during the upcoming refueling outage.

During the following day (September 19, 1997), another inadvertent discharge of approximately 700 gallons of reactor makeup water (RMW) into the WHUT occurred while performing a resin bed flush of the B-deborating demineralizer.

Control room operators utilized RMW piping and instrumentation drawings (PSIDs) to troubleshoot the system configuration and determined that valve V-1128A (RMW inlet isolation valve to the boric acid evaporator) was not fullyclosed.

This valve provided a flowpath to the boric acid evaporator feed tank, which subsequently overflowed to the auxiliary building sump tank. The sump tank water was then automatically pumped to the WHUT. The valve utilized an internal rubber diaphragm to prevent boric acid corrosion. -Also, the valve stem utilized lock nuts to prevent the rubber diaphragm from being crushed when the valve was manually closed.

Closer inspection of V-1128A revealed that the locknuts were misadjusted and the valve could not be fullyclosed.

The locknuts were subsequently readjusted to allow full valve closure.

The inspectors questioned the licensee',s maintenance practices for adjusting the locknuts, or for performing periodic inspections of these valves.

The licensee generated an ACTION Report (97-1451) to address the issue.

Conclusions The inspectors concluded that personnel errors contributed to the inadvertent discharge of reactor makeup water into the WHUT that occurred on September

and 19, 1997. The inspectors also concluded that control room operators performed well while troubleshooting the inadvertent discharge that occurred on September 19, 1997.

The licensee's intention to conduct training on configuration control deficiencies was appropriate; however, this item willremain an inspector follow-up item pending NRC review of the effectiveness of the training

'(IFI 50-244/97-10-01).

02.2 Inadvertent Actuation of the Fire Delu e S stem for the Turbine Driven Auxiliar Feedwater TDAFW Pum a 0 Ins ection Sco e (71707)

The inspectors reviewed the licensee's response to an inadvertent actuation of the fire deluge system for the TDAFW pump.

b.

Observations and Findin s On October 9, 1997, at approximately 11:20 a.m., Nuclear Power Services (NPS)

contractors inadvertently actuated the fire alarm and automatic water deluge system for the TDAFW pump.

The contractors were removing nearby piping insulation in preparation for the upcoming outage.

The plant fire brigade responded immediately to the fire alarm, and security personnel initiated an investigation for possible tampering, Security's investigation concluded that the alarm was inadvertently actuated when the contractors were passing an insulation bag across a railing in the vicinity of the fire alarm, and that the actuation had been unintentional.

Approximately 600 gallons of water was discharged, mostly in and around the TDAFW pump and its supporting lube oil system.

Operators declared the TDAFW pump inoperable, which placed the plant in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO (3.7.5.A). The licensee inspected all electrical junction boxes and panels located in the area.

A small quantity. of water was found inside the switch cover of the actuator for valve MOV-3996 (TDAFW pump discharge block valve); however, this water was easily removed, and it was apparent that no water had entered the actuator gear box.

The inspectors verified that no other equipment in the area (motor-driven auxiliary feedwater pumps, control rod drive system power cabinets and motor-generator sets) appeared to be affected by the deluge.

The licensee dried the TDAFW pump lube oil AC and DC motors with forced air, then inspected and satisfactorily meggar checked both motors.

Following the licensee's investigation, the TDAFW pump was satisfactorily tested and declared operable on October 10, 1997.

C.

Conclusions The inspectors concluded that the licensee took appropriate corrective actions to address the inadvertent actuation of the fire deluge system for the TDAFW pump.

Additionally, the security investigation which determined that the actuation was unintentional, was thorough and promptly performe Operator Training and Qualification 05,1 Licensed 0 erator Re uglification Examination aO Ins ection Sco e (71001)

The inspectors reviewed all examination materials for the week of the inspection, written examinations for the prior two weeks, and two written examinations from 1996.

b.

Observations and Findin s The licensee's sample plan was reviewed to determine whether the comprehensive written exam and the annual operating exam adequately covered the areas trained on during the requalification training period, and met the requirements of 10 CFR Part 55 "Operators'icenses,"

Subpart 59, "Requalification."

No discrepancies were found.

The inspector noted that the licensee had provided a "spare" job performance measure, which was for use if necessary to avoid redundant performance of a task which might be observed in a simulator-scenario.

Written Examinations The written examinations reviewed were at an appropriate cognitive level. The inspector considered that 2 of 40 questions for the examinations administered during the week of September 15, 1997, should be modified due to easily discarded distractors.

The inspectors determined that the licensee's procedures allowed up to 75% of examination question overlap from one week to the next, and that the actual practice was to allow up to 70% overlap.

This relatively high percentage of overlap could tend to diminish the assurance of examination security and validity; the inspector's review of this concern did not identify any evidence of examination compromise.

Simulator Scenarios The inspectors reviewed one simulator scenario administered to an operating crew after the examination began, and three other simulator scenarios administered during the examination.

The first scenario was reviewed to ensure none of the malfunctions or elements used in developing that scenario were subsequently used in any of the scenarios administered during the requalification exam.

None of the malfunctions or elements were reused.

All of the scenarios were reviewed using the Simulator Scenario Review Checklist of Appendix A to NRC Inspection Procedure (IP) 71001. The scenarios and sets met the qualitative and quantitative attributes of the checklist and were generally acceptabl However, a problem was noted in one scenario where the only instrument failure was a steam generator level that failed high.

Since the Ginna plant has a digital feedwater control system (ADFCS) which automatically swaps to an alternate channel, this failure resulted in no adverse plant response for the crew to mitigate.

This was not acceptable as the only instrument failure, because it provided no means of evaluating the control manipulation skills of the operator.

The inspectors discussed alternate means of simulating appropriate failures in the event the simulator could not directly model digital feedwater control malfunctions.

Job Performance Measures JPMs The inspectors reviewed six JPMs that were administered in the 'plant and simulator using the JPM Quality Checklist of Appendix A to NRC IP 71001.

The inspectors noted several instances in two JPMs where the licensee's determination of critical steps was inappropriate.

Specifically, "verify" steps in the procedure had been categorized as critical, and some important procedural cautions had not been categorized as critical. The specific instances were discussed with the licensee's training representatives.

None of the inappropriate categorizations adversely affected the evaluation of the operators.

C.

Conclusions The examination materials were generally acceptable and appropriate.

The licensee demonstrated good planning by including a spare JPM in the examination package to avoid potential duplication of simulator events, 05.2 Re uglification Examination Administration Practices a 0 Ins ection Sco e (71001)

The inspectors observed examinations and tests in progress, and interviewed operating personnel to assess the licensee's effectiveness in conducting written examinations and operating tests to ensure operator mastery of the requalification training program content.

Also, the inspector reviewed the licensee's resolution of an evaluation miscue discovered while conducting a prior week's examination.

b.

Observations and Findin s Written Examinations All individuals passed the written examinations.

There were no discrepancies between the NRC's and the licensee's grading.

Simulator Scenarios The inspectors observed one operating crew in three scenarios.

The crew performed well in all scenarios with minor errors.

The licensee's evaluations were

appropriate, starting with a discussion of critical tasks and then moving to other items.

Appropriate management involvement was demonstrated by participation of the operations manager in the evaluation.

JPMs The following items were noted during administration of JPM No. J006.006,

"Transfer ECCS to Cold Leg Recirculation," on the simulator:

Initially, the simulator was not properly setup to provide the correct feedback to the operators; specifically, a failure of valve MOV-850A (RHR pump suction from containment sump B) to stroke open.

Initially, this malfunction was set up having the RED OPEN light for the valve fail to illuminate even though the valve actually stroked open.

This confused one of the operators when he saw the GREEN CLOSE light for MOV-850Ago out at about the same time the close light for MOV-850B (RHR suction from the containment sump A) went out. The inspector pointed this out to the simulator operator.

On subsequent administration of the JPM, MOV-850Awas prevented from stroking.

Step 15.0 of the JPM (Step 6.c. of the procedure) required the operators to

"STOP C Sl PUMP AND PLACE BOTH SWITCHES IN PULL STOP."

One operator did not place the switch for Bus 16 in PULL STOP as required.

This was a critical step in the JPM, but this error was not noted by the JPM evaluator, The inspector pointed out the error to the JPM evaluator after the JPM was completed.

As a result of what the licensee considered to be conflicting precautions in-procedure ES-1.3, "Transfer to Cold Leg Recirculation," the JPM evaluator applied different grading standards (not identified in the JPM) to different individuals who took different actions in response to a refueling water storage tank (RWST) lo-lo level alarm.

The conflicting precautions stated:

1)

"Injection flow to the RCS shall be maintained at all times," and 2) "Any pumps taking suction from the RWST should be stopped upon reaching the RWST lo-lo level alarm." The licensee trained the operators to evaluate the specific situation as a crew in order to decide how to operate the ECCS pumps.

One examinee did not shut off all pumps, while another examinee left them running at the lo-lo level.

For the first examinee, the evaluator stated that he would have failed the individual if he did not restart the pumps in accordance with criteria in the procedure foldout page.

For the other examinee, the evaluator would have failed the individual if he did not shut off pumps before they cavitated.

Given the manner in which the licensee trained and the statements of the evaluators, the inspectors agreed with the grading of these individual U date IFI 50-244 97-09-01:Weaknesses in JPM Cuin Techni ues The inspectors reviewed the licensee's resolution of a problem where a senior reactor operator (SRO) failed a JPM involving an evaluator miscue.

The evaluator initiallymiscued the examinee that his operation of a throttle valve had produced the desired response, even though he had turned the valve in the wrong direction.

The operator failed this JPM and his examination.

When an operator at the Ginna Station fails an examination, the licensee conducts a License Review Board (LRB) to determine the appropriate remediation.

In this instance, the licensee determined that because the evaluator did not recognize his miscue until the operator was attempting to perform the next procedure step, this may have contributed to the failure. Accordingly, the licensee invalidated the JPM, remediated the individual, and administered another JPM that involved throttling. The examinee passed that JPM.

In reviewing the LRB minutes and interviewing the evaluator, it appeared to the inspector that the evaluator had adequately recovered from the miscue, since the examinee returned to the throttle valve in question and continued to operate it in the wrong direction.

However, the inspector determined that the JPM still did not provide adequate cues in that the evaluator was unable to tell the examinee which way system pressure was moving in response to his actions, and only told him that pressure was "less than 60 psig" on the relevant gage.

Since the operator knew which valve to operate, and where to check for system response, the inspector did not consider the fact that the candidate turned the valve in the wrong direction to be a critical error.

If properly cued, the operator could have corrected his actions.

Another aspect of this issue was instructor preparation time and JPM validation.

The inspector determined that the licensee validated JPMs prior to each examination by a walkdown, with one instructor acting as the evaluator, and another as the examinee.

In this instance, the lack of adequate cuing was not identified.

Instructors interviewed stated that when acting as evaluators, they generally have a least a week to review JPMs prior to their administration, but that sometimes they may not see the material until the day of the examination.

Although no evaluator was expected to think of every potential error for every JPIVI step, the inspector noted that ensuring adequate preparation time may help avoid similar difficulties in the future.

Conclusions The inspectors agreed with the licensee's evaluation that the crew and all individuals passed their examinations, with three individuals failing one JPM, but passing overall. The degree to which evaluator judgement was used in place of a clearly identified task standard for evaluation of the ES-1.3 JPM was not appropriate.

The standards should be written into the JPM to correctly state management expectation The licensee appropriately resolved discrepancies in an operator's examination that occurred primarily as a result of weaknesses in an evaluator's cuing techniques.

Pending further inspector review of the licensee's administration'of JPMs and evaluator cuing techniques, this item will remain open (IFI 50-244/96-09-01).

05.3 Trainin Feedback S stem a.

Ins ection Sco e (71001)

The inspectors assessed the effectiveness of the process for revising and maintaining the licensed operator training program up-to-date, including the use of operator feedback.

b.

Observations and Findin s The inspectors reviewed samples of several methods for eliciting feedback, including classroom evaluation forms, instructor feedback forms, and forms filled out be operations supervisors and managers observing crew and instructor assessments.

The inspector also reviewed the Nuclear Training Work Request Program.

A training work request (TWR) could be initiated by anyone at the Ginna Station for several reasons, including a performance error, or through student and instructor feedback.

A TWR should be forwarded to the applicable training supervisor and an acknowledgement letter then sent to the initiator. A copy of the completed TWR should also be routed to the initiator. This broad-based approach appeared to be an appropriate means for soliciting feedback.

C.

Conclusions The licensee had several means of capturing training needs and incorporating them into the training program.

The TWR system was a good means to identify and track training issues in a broad-based manner.

05.4 Remediation Practices aO Ins ection Sco e (71001)

The inspectors reviewed the licensee's remediation of examination failures and poor performance from the last annual examination through the completion of the examination administered during the week of September 15, 1997.

b.

Observations and Findin s No failures of operating personnel had occurred during the current or prior annual examinations.

The inspector selected five instances of individuals with weekly exam grades that indicated remediation was required.

In all five cases, documentation was available for the appropriate remediation and retake exam The inspectors noted that although all individuals passed the exam observed during the inspection, the licensee remediated the unsuccessful portions'immediately following a morning crew critique that included re-performing missed JPMs.

C.

Conclusions The licensee performed appropriate remediation in accordance with training procedures.

A very proactive approach was displayed in remediating areas of poor performance prior to returning personnel to on-shift duties, even where the overall examination results were acceptable.

Quality Assurance in Operations 07.1 Nuclear Safet Audit Review Board NSARB Quarterl Meetin a e Ins ection Sco e (71707)

The inspector attended the NSARB meeting for the third quarter of 1997 and reviewed the board's agenda items presented for evaluation.

b.

Observations and Findin s The NSARB held a quarterly board meeting on September 24 and 25, 1997, to review recent plant performance and issues related to plant safety during the current quarter (June through September 1997). The board secretary confirmed that a minimum quorum of members were present; however, the board acknowledged that less than the normal complement of outside members were in attendance.

During the meeting, particular attention was paid to the preliminary results of the design basis and architect/engineer (A/E) inspection recently conducted (June-August 1997) by the NRC Office of Nuclear Reactor Regulation (NRR). The board also conducted a focused and in-depth discussion of the causes and corrective actions associated with recent NRC enforcement for deficiencies in the station's vehicle barrier system.

Other agenda items presented for the board's evaluation included the operational status of the plant over the current quarter, three licensee event reports (LERs), an overview of major activities planned for the 1997 refueling outage, the current status of the licensee's Maintenance Rule program, and the results of the QA/QC and PORC Subcommittee meetings held during the current quarter.

Overall, the presentations made to the board, and its evaluation of agenda items were detailed and comprehensive.

However, the inspector noted and pointed out to the board members that the review of LER 96-009, Revision 2, "Leak Outside Containment Due to Weld Defect," was not thoroughly discussed when initially presented.

Revision 2 was written to correct NRC identified errors contained in Revision 1 pertaining to the potential consequences of the subject leak following a design basis large break loss of coolant accident (LOCA). The corrections contained

in Revision 2 were incorrectly presented to the board as self identified by RGSE.

In addition, the inspector noted that an ACTION Report had not been written to address the errors in Revision

~ The board members subsequently discussed in more detail the differences between the two revisions, and the importance to the problem identification process of accurately capturing non-self identified findings by outside groups.

The board also requested that an ACTION Report be initiated and that a follow-up review be conducted at the next scheduled board meeting.

The board also initiated other new action items that included follow-up assessments on 1) the effectiveness of corrective actions to previous NRC and RG&E identified deficiencies, 2) 'a formal Maintenance Rule program review and evaluation, and 3) a review of the licensee's effectiveness in communicating risk significant systems to plant workers during the 1997 refueling outage.

At the end of the formal discussions, the board chairman requested a critique and feedback from the board members.

With the exception of the inadequate LER review,'the members indicated that their discussions and evaluations were thorough.

The board again re-emphasized to themselves the importance of having as many outside members present as possible since their presence was considered an essential factor in the board's overall effectiveness.

The board concluded that a concerted effort was needed to schedule its meetings when more outside members are available.

c.

Conclusions The inspectors concluded overall that the NSARB held good discussions on well developed topics, and performed good oversight of plant activities.

Most presentations, made to the board were informative, except for the presentation of one LER revision.

The inspectors concluded that this problem may have been avoided if both Revisions 1 5 2 of the LER 96-'009 were included in the board's review packages.

The critical questioning normally provided by the outside members was missing at this meeting, and may have contributed to the shallow review of the LER.

07.2 New Fuel Recei t lns ection a0 Ins ection Sco e (60705)

The inspector observed receipt inspection activities for the new fuel assemblies that will be installed for the next operating cycle.

b.

Observations and Findin s The licensee received four separate shipments of new reactor fuel on September 23, 25, and 30, and October 2, 1997. A total of 41 new assemblies were delivered with ten assemblies in each of the first three shipments, and eleven assemblies in the last shipment.

On September 23 and October 2, 1997, the inspector observed the licensee unpack the assemblies, place them into temporary storage in the new

fuel preparation area (NFPA), perform a detailed visual examination of each assembly, and then transfer each assembly into the spent fuel pool (SFP).

While unpacking the new bundles, an RG5E quality control (QC) inspector verified that accelerometers in the shipping containers had not been tripped, and that the containers and assemblies had not been damaged during shipment, The QC inspector conducted detailed visual examinations to verify each assembly's identification numbers, lack of physical damage or distortion of all fuel pins, cleanliness and lack of foreign material, and overall physical condition.

Licensed operators transferred each bundle from the temporary holding rack into designated storage locations in the SFP racks.

One operator was being trained for this evolution. The inspector verified that the local criticality monitor (R-5) adjacent to the SFP and NFPA has remained in continuous operation since receiving the first shipment of new fuel. During all fuel receipt inspection activities, the NFPA was under constant surveillance by cognizant licensee personnel, and remained locked at all other times.

The QC inspector documented the results of his examinations.

The NRC inspector reviewed these documents after all receipt inspection activities were complete.

The documentation was complete and accurately reflected the independent verifications of fuel bundle numbers and storage locations performed by the NRC during the receipt activities.

C.

Conclusions Overall, the receipt inspection of new fuel was thorough and well controlled.

The documentation reviewed was complete and accurate.

No notable discrepancies were identified on any of the new bundles.

Miscellaneous Operations Issues 08.1 0 erator Action Times and Procedure Cautions lns ection Sco e (71001)

The inspectors reviewed operational issues regarding evaluation of operators to assumptions in the Updated Final Safety Analysis Report (UFSAR) for a steam generator tube rupture (SGTR) and conflicting precautions in an emergency operating procedure (EOP), which were raised during the inspection.

b.

SGTR 0 erator Action Times The inspector reviewed Ginna's UFSAR to determine the assumed operator action times for offsite releases, and questioned the licensee on how these times were incorporated into operating crew evaluations.

The UFSAR assumed that the ruptured steam generator could be isolated in ten minutes, or before steam generator refill to 33% of the narrow range level, and that break flow could be isolated within one hour.

The licensing department had issued a memorandum to the training department in April 1989 to incorporate the response times into

operator training.

However, as of this inspection, the ten minute/33% criteria for a SGTR had not been incorporated into this training scenario.

The licensee had a one hour criteria as two discrete critical tasks, i.e., to 1) depressurize the reactor coolant system, and 2) to terminate safety injection flow, both within one hour of the rupture.

Training department management acknowledged that not incorporating the ten minute/33% criteria was an oversight, and indicated that a review would be made to determine how that occurred.

A SGTR scenario was run in the current examination, and the operating crew apparently could have met the ten minute criteria if they had been aware of it. At ten minutes into the scenario, feedwater to the ruptured steam generator had be'en isolated, and the control room foreman (CRF) requested permission to shut the main steam isolation valve (MSIV). In this instance, the shift supervisor told the CRF to wait until he reached the appropriate step in the procedure.

The operations manager stated that existing operations procedures allowed such "pull forward" steps to be performed with the appropriate permission.

It appeared to the inspectors that exceeding the time limits on the simulator was primarily an awareness issue, and not a question of operators'ctual ability to operate the plant in accordance with the accident analysis assumptions.

The training department stated they would develop SGTR scenarios which evaluate a crew's ability to meet all criteria.

ES-1.3 Conflictin EOP Cautions Procedure ES-1.3, "Transfer to Cold Leg Recirculation," contained two conflicting caution statements.

The caution prior to step 1 stated that "Injection flow to the RCS shall be maintained at all times." Another caution prior to step 6 stated that

"Any pumps taking suction from the RWST should be stopped upon reaching the RWST lo-lo level alarm." These are not Ginna-specific cautions, but were incorporated directly from the emergency response guideline (ERG) background documents.

The inspectors noted that other nuclear facilities have not perceived a

conflict with these caution statements, but consider that the second caution overrides the first. RGSE had considered this question, and was training operators to evaluate how fast RWST level is dropping, versus how much longer it would take to complete the ES-1.3 transfer valve lineup; and to then determine whether or not to leave one or more ECCS pumps running based upon that evaluation.

To support this approach, the licensee had determined that ECCS pumps willcavitate at closer to 5% RWST level, which is well below the lo-lo alarm setpoint (15%). The inspectors were concerned that the licensee was training personnel to do something other than what the procedure specifically called for, and that too much discretion may have been allowed by the evaluators (see section 05.2, "JPMs").

At the time of this inspection, the licensee was aware of the conflicting c'autions, and was evaluating whether to lower the RWST alarm setpoint or to modify the procedure and operating practices.

However, before the final resolution of this concern is developed, the licensee's procedure should state what crews are expected to do.

In addition, these expectations should be stated in the applicable JPM, or other evaluation tool, based upon the procedure requirements.

The

operations manager stated that the ES-1.3 conflict would be resolved in approximately 60 days.

C.

Conclusions The licensee overlooked an accident analysis assumption regarding operator action times in response to a SGTR.

However, the operating crews should be capable of performing these actions within the required time limits once they are incorporated into the training scenarios, and training is conducted.

The licensee's current practice of requiring an operating crew to use judgement in the degree to which they willcomply with the caution prior to step 6 of procedure ES-1.3, appeared to impose on them an unnecessary real-time decision making 'task.

This will remain an unresolved item pending further review of the licensee's actions to pursue this issue (URI 50-244/97-10-02).

08.2 Closed Licensee Event Re ort LER 97-003 Revision 1: Bistable Instrument Set oint Plus Instrument Uncertaint Could Exceed Allowable Value Causes a

Condition Prohibited b Plant Technical S ecifications LER 97-003, Revision 1, was submitted on September 29, 1997, to provide additional information pertaining to the licensee's discovery that all four high steam flow inputs to the main steam isolation circuitry were inoperable (see IR 50-244/97-09 and 50-244/97-06).

The inspectors considered that the additional information provided in the revision appropriately supported the analysis and corrective actions described in LER 97-003. This LER is closed (LER 97-003, Revision 1).

II. Maintenance M1 Conduct of Maintenance M1.1 Observations of Maintenance Activities a.

Ins ection Sco e (62707)

The inspectors observed portions of plant maintenance activities to monitor plant equipment against its maintenance rule (10 CFR 50.65) performance criteria; to verify that the correct parts and tools were utilized, that the applicable industry

'odes and ITS requirements were satisfied, that adequate measures were in place to ensure personnel safety and prevent damage to plant structures, systems, and components, and that the licensee properly verified equipment operability upon completion of post-maintenance testing.

b.

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

Seal replacement on the B-RHR pump observed on September 15-17, 1997 (see section M2.1).

Corrective maintenance on the B-traveling screen observed on September 15-20, 1997.

c.

Conclusions The inspectors concluded that the observed maintenance activities were performed in accordance with procedural requirements.

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

Good personnel and plant safety practices were observed during the maintenance work, M1.2 Observations of Surveillance Activities a.

Ins ection Sco e 61726 The inspectors observed selected surveillance tests to verify that approved procedures were in use and procedure details were adequate, that test instrumentation was properly calibrated and used, that ITS surveillance requirements were satisfied, that testing was performed by qualified and knowledgeable personnel, and that test results satisfied acceptance criteria or were properly dispositioned.

b.

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

PT-16Q-T, "AuxiliaryFeedwater Turbine Pump - Quarterly," observed on September 10 and October 10, 1997 (see section 02.1).

PT-16Q-B, "AFW Pump B - Quarterly," observed on October 7, 1997. The inspector noted that the pump's recirculation line successfully passed its performance criteria (see IR 50-244/97-06).

PT-2.2Q, "Residual Heat Removal System - Quarterly," observed on September 17, 1997, for the B-RHR pump following corrective maintenance (see section M2.1).

c.

Conclusions The inspectors confirmed that the procedures used were current and properly

'ollowed, and that the shift supervisor properly authorized all surveillance work to proceed. The licensee verified the qualifications of all surveillance test personnel involved in the tests.

The as-found and as-left test data met the expected performance values and the specified acceptance criteria stated in the Updated Final Safety Analysis Repor M2 M2.1

Maintenance and Material Condition of Facilities and Equipment B-RHR Pum Limitin Condition for 0 eration LCO Maintenance

Ins ection Sco e (62707)

The inspectors reviewed the licensee's maintenance activities to replace the shaft seal and to modify the component cooling water (CCW) piping for the 8-RHR pump.

b.

Observations and Findin s On September 15, 1997, the B-RHR pump was removed from service to replace its shaft seal and to modify its associated CCW piping to install pipe union connections.

Gland seal replacement was performed to repair a minor seal leak that had developed, and the CCW modification was performed to make pump installation and removal activities less restrictive.

Inboard horizontal vibration on the pump had also been in the alert range since August, 1996, requiring increased surveillance activity. The licensee also intended to perform an inspection of the pump for any contributor to the increased vibration. This maintenance required entry into LCO 3.5.2,A., which required the B-RHR train to be returned to service within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The licensee therefore scheduled two shifts of maintenance personnel to perform the work continuously until completed.

The pump was removed from the RHR pump room and lifted to the upper level of the auxiliary building, where adequate space was provided to perform the maintenance.

A contamination tent was installed in the auxiliary building upper level to provide proper contamination boundary controls for the work area.

The shaft seal replacement was successfully completed on the morning of September 16, 1997. The pump was returned to the RHR pump room and was ready for reinstallation at 7:00 a.m.

During replacement, maintenance personnel noted a "cutwater" (deformity) on the B-RHR pump suction side vane which might have contributed to the increase in pump vibration. The licensee generated an ACTION Report (97-1433) to address the issue.

Maintenance personnel hand filed the cutwater down, reinstalled the pump, and performed the CCW piping modification. The licensee subsequently performed periodic test PT-2.2Q, "Residual Heat Removal Pump Quarterly," on the pump.

The test results indicated that all pump vibrations had increased, and that vertical vibrations were now also in the alert range.

On September 17, 1997, the licensee reviewed the PT data and determined that the escalated vibrations were not an operability concern, since a significant margin existed between current vibrations in the alert range and the required action range.

The licensee considered that some air bubbles may still be present in the pump.

Maintenance personnel also noticed that a union leak had developed in the modified CCW piping. The licensee decided to replace the union to repair the leak, vent the pump, and rerun PT-2.2Q prior to declaring the pump operable.

The union was successfully replaced, the pump was vented, and PT-2.2Q was rerun that afternoon.

Allvibration levels decreased somewhat; however, both the pump

inboard vertical and horizontal vibration levels were slightly in the alert range.

The licensee indicated that the 8-RHR pump would remain on an increased surveillance schedule for further evaluation.

The pump was returned to service at approximately 8:30 p.m. on September 17, 1997.

On September 22, 1997, the inspectors attended a critique that maintenance personnel conducted to determine possible areas for improvement on conducting LCO maintenance, based on the information obtained from the B-RHR pump maintenance.

The licensee concluded that the addition of a work coordinator to the maintenance teams would have appreciably improved performance in that several unnecessary time delays could have been prevented.

The individuals who performed the maintenance. indicated that the administrative requirements associated with the maintenance paperwork could have been delegated to a coordinator, and that would have allowed the actual maintenance to be performed" more expeditiously.

A work coordinator could also have prevented a delay in running PT-2.20 which lasted nearly one hour, due to the hoses required for pump venting not being readily available at the work site.

C.

Conclusions The inspectors concluded that LCO maintenance was successfully performed on the B-RHR pump.

The licensee conducted a good post-maintenance test critique and identified areas for improvement, which included the addition of a work coordinator to LCO maintenance activities to improve the timeliness of maintenance.

The licensee's decision to maintain increased monitoring of the B-RHR pump to evaluate escalated vibrations was considered appropriate.

III. En ineerin E2 Engineering Support of Facilities and Equipment E2.1 Residual Heat Removal Ca abilit in MODE 4 Ins ection Sco e (37551)

The inspectors reviewed the licensee's response to the discovery that'the residual heat removal (RHR) system may be susceptible to thermal shock and subsequent inoperability if a loss-of-coolant accident (LOCA) should occur while in operating MODE 4.

b.

Observations and Findin s On April 6, 1997, the licensee generated an ACTION Report (97-0575) to address possible RHR operability concerns following industry concerns for Westinghouse pressurized water reactor (PWR) vulnerability to a loss of coolant accident (LOCA) in operating MODE 4. The ITS requires that both high and low head safety injection be available in MODE 4 (350 F ) average RCS temperature ) 200 F). Should a

LOCA occur while RHR cooling is in service between 350 F and 260'F, the RHR piping could be susceptible to thermal shock and subsequent inoperability due to the relatively cold refueling water storage tank (RWST) that would be routed to the RHR piping following realignment of the system for safety injection. The cold RWST water could flash to steam when contacting the hot suction piping and hot water already in the RHR system, and result in a loss of injection capability due to steam binding in the RHR pumps.

During normal plant cooldowns the RHR system can be aligned to the reactor coolant system (RCS) when its temperature is 6350 F.

Although a MODE 4 LOCA is an accident outside Ginna's design basis, the Westinghouse Owners Group guidelines still recommended that its potential be evaluated.

The licensee completed a safety evaluation (SEV-1107) to evaluate MODE 4 emergency core cooling system (ECCS) configurations.

The SEV evaluated changing ECCS configuration in MODE 4 by having the high pressure A-and 8-safety injection (Sl) hot leg flow paths available for use below an RCS temperature of 350 F. This flow path for primary injection had previously not been utilized, and could relieve the RHR system from being needed for primary coolant injection should a LOCA occur in the vulnerable temperature range of 350-260 F.

The RHR system would still be available for the recirculation phase of LOCA in MODE 4.

The SEV also indicated that there would be no ITS changes required to perform this modification. However, the ITS basis would have to be revised to redefine acceptable injection configurations and to clarify that the RHR ECCS function is required only for the recirculation phase of a MODE 4 LOCA, Finally, the SEV indicated that the ability of plant operators to reconfigure the SI system to provide hot leg injection had previously been evaluated.

Since operators had already been trained in using the proposed Sl configuration for mitigating the loss of RHR while operating with reduced RCS inventory, it was already demonstrated that the alignment could be achieved before fuel damage would occur following a LOCA.

The SEV was awaiting review by the plant operations review committee, and a change to the ITS bases was in progress at the end of the inspection period.

Conclusions The inspectors concluded that the licensee adequately evaluated the potential for a loss of RHR system injection capability should a LOCA occur while in MODE 4. The safety evaluation performed to modify the ECCS system configuration to alleviate the problem successfully determined the capability of the Sl hot leg flow paths to provide adequate flow during the injection phase of a MODE 4 LOCA, and that the RHR ECCS function is required only for the recirculation phase of a LOCA while in MODE Engineering Staff Training and Qualification E5.1 Vendor Technical Manual Trainin at Ins ection Sco e (37551)

The inspectors attended vendor manual program classroom training for system engineers.

b.

Observations and Findin s On September 19, 1997, the inspectors attended classroom training for system engineers on the new vendor technical manual program.

The topics covered included use of the licensee's computer tracking system for vendor manual status, procedures to implement a revision to a vendor manual, components included and excluded from the program, and quality controls for vendor manual requirements.

The system engineers in attendance actively participated in the discussion.

A written handout addressing the training topics was distributed to the audience.

C.

Conclusions The inspectors concluded that the observed classroom training for system engineers on the new vendor technical manual program was good.

The topics covered adequately addressed the new program requirements.

The instructor was considered effective in both relaying information and encouraging audience participation.

The written handout adequately reflected the topics covered.

E7 Quality Assurance in Engineering E7.1 Maintenance Rule Ex ert Panel Meetin s ao Ins ection Sco e (37550,62706)

The inspector attended the quarterly meeting of the licensee's maintenance rule (10CFR50.65) expert panel held on October 3 and October 10, 1997 b.

Observations and Findin s During 1997, the licensee contracted two outside agencies to perform independent assessments of its maintenance rule (MR) program.

These assessments were performed after the licensee had assigned a new maintenance rule program coordinator.

LCM engineering performed a detailed review in July 1997 of ten maintenance rule systems using NRC IP 62703, "Maintenance Rule." A report was provided in August 1997 which.identified several program strengths, with many findings and concerns expressed in approximately 250 observations.

RGRE subsequently contracted ERIN engineering in September 1997, to perform an additional maintenance rule program review and to develop an action, plan for

program improvement.

The expert panel reviewed the action plan and made specific recommendations on how to address the identified deficiencies.

In addition, the panel reviewed the current quarter's performance and acceptance criteria for the plant computer system and determined that it should be placed into maintenance rule category (a)(1).

The board also concluded that the emergency battery lighting and radiation monitoring systems should remain in the (a)(1)

category until all components can successfully pass three surveillance periods.

The panel removed the emergency diesel generators from the (a)(1) category to successful performance over three surveillance periods.

,C.

Conclusions The inspectors concluded that the independent assessments were thorough and

.

provided useful input for program improvement.

The assessments were conducted at an appropriate time. The program deficiencies identified were properly supported and incorporated into an aggressive action plan with all items due for completion by mid January 1998. The panel effectively reviewed the performance of the EDGs, plant emergency lighting, and radiation monitoring system and appropriately changed their quarterly performance ratings.

IV. Plant Su ort P1 Conduct of Emergency Preparedness (EP) Activities P1.1 Res onse to Actual Events Since the last EP program inspection (March 1996) there have been no events for which the licensee had to make an emergency declaration.

Therefore, there was no assessment in this area.

P1.2 Effectiveness of Licensee Controls in Identif in Resolvin and Preventin Problems a.

Ins ection Sco e (82701)

The inspector reviewed the licensee's process for identifying, tracking and resolving EP-related issues.

b.

Observations and Findin s The licensee utilizes several sources for identifying problems or issues which include training feedback, drill and exercise evaluations, Quality Assurance (QA) audits, NRC inspections, and issues self-identified by the EP staff. The inspector assessed

. the items in the tracking system to be appropriately prioritized and were resolved (or scheduled to be resolved) in a timely manne The system was effective in trending and identifying broad-based issues.

For example, a licensee review of drills and exercises detected a trend in incorrect classifications and this caused the licensee to conduct a root cause analysis.

The inspector assessed the analysis as very thorough, and good corrective and preventive measures were taken to address findings. The corrective actions were effective as there were no classification issues identified by the NRC during the June 11, 1997 exercise.

In another example, the licensee has monitored and trended the test results of the automated system used to activate the emergency response organization (ERO) and has worked with the vendor to improve the notification process.

The licensee is testing the system monthly (versus quarterly)

to ensure that the system performs in a very reliable manner on a consistent basis.

There had been several discrepancies with the system; however, the causes were the fault of the vendor (i.esoftware changes).

The licensee planned to review the vendor's process control system to ensure reliable service.

The inspector assessed the licensee's corrective actions for this issue to be thorough and methodical to ensure a timely activation of their ERO.

The inspector observed one example, of poor response to an NRC identified issue which impacted EP. Approximately six weeks prior to this EP program inspection, an NRC inspector raised the issue of potential inaccuracies in meteorological (met)

data readouts in the control room. The inspector was informed by the radiation protection group (who is responsible for the maintenance of the met tower) that no action had been taken to confirm or refute the accuracy of the met tower data readout in the control room. The licensee had only verified the met tower instrumentation had been recently calibrated and had investigated the initial suspected cause of the inaccuracies (line loss).

The initial investigation indicated that line losses were not associated with the inaccuracies; however, inaccurate data could have potentially affected the protective actions recommended to offsite officials, The inspector determined that the licensee's initial assessment of this issue was not timely or thorough.

C.

Conclusions Based upon the review of selected items, the inspector concluded that the licensee generally identifies, tracks, and resolves items in an effective manner to enhance the EP program.

P1.3 Offsite Interface (82701)

The inspector reviewed the types and quality of information made available to the public regarding radiological emergencies.

The telephone book inserts and calendars provide the required information for the public in the event of a radiological

'emergency.

The licensee distributed surveys to solicit feedback from the public regarding emergency information to improve content or format. The inspector assessed the licensee's performance in this area as very goo P2 Status of EP Facilities, Equipment, Instrumentation and Supplies P2.1 Emer enc E ui ment Available in the Plant and EP Facilities a.

Ins ection Sco e (82701)

The inspector conducted an audit of emergency equipment in the control room, the operations support center (OSC), the technical support center (TSC), the survey center, and the emergency operations facility (EOF). Documentation of equipment surveillances conducted during 1996 and 1997 was reviewed for completeness and accuracy.

b.

Observations and Findin s The equipment sampled at each of the facilities was present as indicated by the equipment checklists.

Radiological survey instruments at the facilities were all within their calibration period.

The proper revisions of the emergency plan (the Plan) and implementing procedures were present and readily available at all of the facilities. The inspector reviewed the equipment surveillance documentation for the past year and determined that it was completed as required and that all discrepancies were resolved in a timely manner.

The inspector also reviewed documentation to verify that the licensee conducted the required siren surveillances during the past year.

During the last EP program inspection, a calibration source in an EOF locker was located near TLDs for survey team members and the inspectors questioned this arrangement and the effect that the source would have on the TLDs. During this inspection, the source was wrapped in a lead blanket at the bottom of the locker while the TLDs were stored at the top of the locker. The inspector had no further question regarding this issue.

c.

Conclusions The facilities and equipment were determined to be in a very good state of operational readiness.

Surveillances were performed as required and discrepancies were resolved in a timely manner.

P3 EP Procedures and Documentation P3.1 Nuclear Emer enc Res onse Plan and lm lementin Procedures a0 Ins ection Sco e (82701)

The inspector assessed the process that the licensee used to review and change the Nuclear Emergency Response Plan (NERP) and emergency plan implementing procedures (EPIPs).

Recent EPIP changes were reviewed to assess the impact on the effectiveness of the EP progra b.

Observations and Findin s

The inspector assessed the 10 CFR 50.54(q) review (effectiveness review) process for EPIP changes performed by the licensee.

The review checklist was thorough in that NRC requirements, as well as commitments in the Plan, were checked.

The inspector reviewed several recent EPIP change reviews and had no questions.

The licensee has a committee (versus an individual) which reviews procedure changes from a broad-based perspective.

The inspector also verified that the Plan was receiving the required annual review.

The inspector had conducted an in-office review of recent EPIP changes (see Attachment 1) ~ Based upon the licensee's determination that the changes did not decrease the overall effectiveness of the NERP and after limited review of the changes, the inspector determined that no NRC approval was required, in accordance with 10 CFR 50.54(q).

Implementation of these changes will be subject to inspection in the future to confirm that the changes have not decreased the overall effectiveness of the NERP.

c.

Conclusions Based upon the review of recent EPIP changes and a review of the licensee's procedures addressing EPIP changes and reviews, the inspector concluded that this area was well implemented.

P5 Staff Training and Qualification in EP P5.1 Emer enc Res onse Or anization Trainin Pro ram ar Ins ection Sco e (82701)

The inspector reviewed records, procedures, and the licensee's requirements to evaluate the licensee's ERO training program.

b.

Observations and Findin s The inspector reviewed the training records of 20 newly qualified and requalified ERO members.

All individuals had received the required training. The inspector sampled other ERO members and verified that their qualifications were current.

Selected ERO members had also participated in a drill or exercise biennially as required.

The inspector verified that the required drills were being conducted for medical, radiation monitoring, and post accident sampling.

The inspector verified that the licensee was tracking and fulfillingdesignated drill/exercise objectives on a timely basis.

The inspector reviewed'several exercise reports from 1996 and the exercise report of the June 11, 1997 full-participation exercise.

The reports were balanced in that positive and negative comments were recorded.

Overall, the reports were self-critical with an emphasis on program improvemen The inspector verified that the licensee had conducted required training for offsite support entities.

Emergency action level training was provided for the state and county officials while appropriate training was provided for local media, fire, ambulance and hospital personnel as required.

c ~

Conclusion The licensee conducted emergency response training as required.

The inspector concluded, based upon the licensee's successful implementation of the training program and the overall good performance during the June 11, 1997, NRC evaluated exercise, that training has been effectively implemented.

p6 EP Organization and Administration P6.1 Emer enc Pre aredness Or anization a 0 Ins ection Sco e (82701)

The inspector reviewed the licensee's EP organization to determine what changes had occurred since the last program inspection and if those changes had any adverse effect on the EP program.

Observations and Findin s Since the last program inspection in March 1996, there had been no change to the EP staff or management chain.

The corporate nuclear emergency planner (CNEP)

had not acquired any additional duties which would be a distraction from implementing and maintaining the EP program.

In recent months, the department

'anager responsible for EP had been part-time pursuing licensed operator training to acquire experience in plant systems and operations.

He was soon to be assigned full-time to license training and will be replaced by one of his department heads.

His replacement has been a regular attender at the monthly EP Milestone Committee that reviews and tracks all EP-related issues, and is a TSC Coordinator who has been a member of the ERO in various positions during his 29 year career with RGSE.

This replacement will be in place for only one year until the department manager returns from license training. The inspector had no questions concerning these changes.

The CNEP successfully monitored and maintained the ERO staffing such that all key positions were at least three persons deep.

The inspector verified that no large scale licensee reorganizations or down-sizing had occurred which impacted the ERO.

The ERO has remained basically stable in the key positions since the last program inspection.

Since the last EP program inspection, the licensee had developed and used department guidelines.

These guidelines ensured that the routine activities performed by the EP staff were recorded and used as checklists for the completion of various activities, The inspector determined this to be a good initiativ C.

Conclusions The inspector concluded that the pending management changes for the EP department are reasonable and that the ERO had remained basically stable with sufficient staffing for key positions.

P7 Quality Assurance (QA) in EP Activities P7.1 QA Audits of EP Activities a ~

Ins ection Sco e (82701)

The inspector reviewed the 1996 and 1997 QA audit reports and interviewed the lead auditor to assess the effectiveness of the audits of the EP program.

b, Observations and Findin s The inspector reviewed the 1996 and 1997 audit reports and audit checklists.

The reports and the checklists were generally thorough.

Auditors identified discrepancies and made recommendations for improvement of the EP program.

There were no repeat issues in the sequential audits as the EP group satisfactorily resolved audit issues.

The lead auditor informed the inspector that EP expertise from other licensees comprised the audit teams and made worthwhile contributions to the audit effort. The inspector verified that offsite officials were sent copies of the audit report section pertaining to the licensee's interface with offsite agencies and that the reports were distributed to the appropriate licensee management.

The inspector determined that the 1997 audit and checklist apparently did not address or evaluate the areas of drills and exercises as stated in 10 CFR 50.54(t).

The auditor and other licensee personnel acknowledged that the audit did not specifically address the evaluation of drills and exercises.

However, the licensee considered QA personnel (and other personnel independent of the EP group),

involved as drill and exercise evaluators, satisfied the requirement.

Furthermore, the licensee stated that QA personnel on various review boards and committees evaluate these areas while reviewing and tracking drill and exercise-related activities, issues, and reports, The inspector acknowledged the licensee's statement.

The fact that drills and exercises were reviewed in 1996 but not during the 1997 audit indicated a potential trend in a reduction of the scope of the audits.

This will be considered an inspector follow-up item (IFI 50-244/97-010-03).

C.

Conclusions Despite not specifically evaluating drills and exercises during the 1997 audit, the audit (and other licensee reviews) were of sufficient scope and depth to assess the EP program and contained numerous recommendations to enhance the program.

The audits were thorough and the reports were useful to licensee management in assessing the effectiveness of the EP progra P8 Miscellaneous EP Issues P8.1 U dated Final Safet Anal sis Re ort UFSAR Inconsistencies Since Section 13.3 of the UFSAR does not provide specific EP requirements, the inspector compared several licensee activities to the Plan.

The inspector reviewed Section 7 of the NERP, Maintaining Nuclear Emergency Preparedness, and determined that the licensee was implementing its commitments as stated.

Discrepancies observed in the previous EP program inspection (PORC's role in recovery, discrepant organization charts, and procedure for and the exercise of the assessment facility) had been addressed and resolved by the licensee.

P8.2 U date IFI 50-244 96-01-03: Call-out drills During the March 1996 EP program inspection, it was determined that the licensee had conducted three quarterly call-out drills without fullysatisfying all of the intended objectives.

In each drill, there was a different reason for not meeting the drill objectives.

In one, certain responders exceeded the one hour goal by several minutes and in the others, portions of the telephone tree were not completed due to a miscommunication and an individual failing to follow procedures.

The inspectors did not consider these failures to be individually significant, but were concerned that the licensee continues to be unsuccessful in meeting objectives for this drill. The licensee planned to implement an automated system to notify the responders in a more timely and reliable manner.

During this inspection, the inspector reviewed licensee progress in this area.

The licensee's primary ERO notification system was an automated system that paged the one-hour responders and called the entire ERO via telecommunications methods.

(The licensee utilized a telephone tree as a backup notification method.)

Since the system was implemented in early 1997, the licensee and the system vendor have revised and improved the system based upon test results.

The licensee has and will continue to conduct monthly testing (versus quarterly) of the system until they are satisfied.

Although the licensee's response to the system's tests has generally been very good, problems have occurred with the system that are the responsibility of the vendor (i.e., software or telephone switching equipment changes).

The licensee plans to conduct a review of the vendor's process control system.

The inspector concluded that the automated system was a significant improvement over the telephone tree notification method in terms of the eliminating human error and procedural implementation problems.

However, because of some continuing minor problems, this item willremain open pending the results of an unannounced licensee response drill using the automated system later in 199 V. Mana ement Meetin s

X1 Exit Meeting Summary The EP program inspection results were presented to the licensee on September 12, 1997, and the operator requalification results were presented on September 19, 1997. After the entire inspection period was concluded, the resident inspectors presented the overall results to members of licensee management on October 16, 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 identifie ATTACHMENTI PARTIALLIST OF PERSONS CONTACTED R. Carroll B. Flynn C. Forkell D. Filion G. Graus A. Harhay J. Hotchkiss R. Jaquin G. Joss F. Maciuska R. Marchionda N. Meaker F. Mis P. Polfleit R. Ploof J. Smith J. Widay T. White G. Wrobel Technical Training Manager Primary Systems Engineering Manager Electrical Systems Engineering Manager Radiochemist INC/Electrical Maintenance Manager Chemistry & Radiological Protection Manager Mechanical Maintenance Manager Nuclear Safety and Licensing Results and Test Supervisor Operations Training Manager Production Superintendent Sr. License Instructor Principle Health Physicist Emergency Preparedness Manager Secondary Systems Engineering Manager Maintenance Superintendent Plant Manager Operatioris Manager Nuclear Safety 5 Licensing Manager INSPECTION PROCEDURES USED IP 37551:

IP 40500:

IP 61726:

IP 60705:

IP 62707:

IP 64704:

IP 71001:

IP 71707:

IP 71750:

IP 82701:

Onsite Engineering Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Surveillance Observation Preparation for Refueling Maintenance Observation Fire Protection Program Licensed Operator Requalification Program Evaluation Plant Operations Plant Support Operational Status of the Emergency Preparedness Program

Attachment I

~Oened IFI 50-244/97-10-01 URI 50-244/97-10-02 IFI 50-244/97-10-03 Closed LER 97-003, Revision

ITEMS OPENED, CLOSED, AND DISCUSSED Weak configuration control Conflicting cautions in procedure ES-1.3 Scope of licensee's 10CFR50.54(t) reviews Bistable Instrument Setpoint (Plus Instrument Uncertainty)

Could Exceed Allowable Value, Causes a Condition Prohibited by Plant Technical Specifications Discussed IFI 50-244/96-09-01 IFI 50-244/96-01-03 In Plant JPM Cuing Techniques Licensee progress on ERO activation method LIST OF ACRONYMS USED ADFCS A/E AFW ALARA ASME CCW CFR CNEP CVCS CW ECCS EDG EPIP ERO ESF IFI IP IR ITS JPM LCO LER LOCA Advanced Digital Feedwater Control System Architect/Engineer Auxiliary Feedwater As Low As Reasonably Achievable American Society of Mechanical Engineers Component Cooling Water Code of Federal Regulations Corporate Nuclear Emergency Planner Charging and Volume Control System Circulating Water Emergency Core Cooling System Emergency Diesel Generator Emergency Plan Implementing Procedure Emergency Response Organization Engineered Safety Feature Inspector Follow-up Item Inspection Procedure

Inspection Report

'mproved

Technical Specification

Job Performance Measure

Limiting Condition for Operation

Licensee Event Report

Loss of Coolant Accident

Attachment

I

MOV

MDAFW

MSIV

NRC

NRR

NSARB

OSC

PCV

PORC

PT

pslg

PWR

QA

QC

RCA

RCS

RGSE

RHR

RWST

SEV

Sl

SRV

SGTR

TDAFW

TWR

UFSAR

WHUT

Motor-Operated Valve

Motor-Driven Auxiliary Feedwater

Main Steam Isolation Valve

Nuclear Regulatory Commission

Nuclear Reactor Regulation

Nuclear Safety Audit and Review Board

Operations Support Center

Pressure

Control Valve

Plant Operations Review Committee

Periodic Test

pounds per square inch gage

Pressurized Water Reactor

Quality Assurance

Quality Control

Radiologically Controlled Area

Reactor Coolant System

Rochester Gas and Electric Corporation

Residual Heat Removal

Refueling Water Storage Tank

Safety Evaluation

Safety Injection

Safety Relief Valve

Steam Generator Tube Rupture

Turbine-Driven AuxiliaryFeedwater

Training Work Request

Updated Final Safety Analysis Report

Waste Holdup Tank

Attachment

I

EMERGENCY PLAN AND IMPLEMENTINGPROCEDURES REVIEWED

Procedure

No.

Procedure Title

Revision

EPIP 1-0

EPIP 1-5

EPIP 1-7

EPIP 1-11

EPIP 2-2

EPIP 2-5

EPIP 2-6

EPIP 2-11

EPIP 2-12

EPIP 2-13

EPIP 3-6

EPIP 5-4

EPIP 5-7

EPIP 5-10

Nuclear Emergency Response

Plan

Ginna Station Event Evaluation and Classification

Notifications

Accountability of Personnel

Survey Center Activation

Obtaining Meteorological Data and Forecasts

and

Their Use in Emergency Dose Assessment

Emergency Dose Projection - Personal Computer Method

Emergency Dose Projection - Midas Program

Onsite Surveys

Offsite Surveys

Iodine and Particulate ActivityDetermination from

Air Samples

Corporate Notifications

Emergency Plan Implementing Procedure

(EPIP)

Training Program

Emergency Organization

Emergency Response

Data System (ERDS)

24

5

8

8

12

29

16

~