IR 05000244/1998011

Insp Rept 50-244/98-11 on 980907-1018.No Violations Noted. Major Areas Inspected:Operations,Engineering,Maintenance & Plant Support

ML17265A458
Person / Time
Site:	Ginna
Issue date:	11/19/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17265A457	List: IR 05000244/1998011 ML17265A455
References
50-244-98-11, NUDOCS 9811240063
Download: ML17265A458 (37)

Text

U.S. NUCLEAR REGULATORY COMMISSION

, REGION I License No.

DPR-18 Report No.

50-244/98-1

Docket No.

50-244 Licensee:

Facility Name:

Rochester Gas and Electric Corporation (RGRE)

R. E. Ginna Nuclear Power Plant Location:

1503 Lake Road Ontario, New York 14519 Inspection Period:

Inspectors:

September 7, 1998 through October 18, 1998 P. D. Drysdale, Senior Resident Inspector C. C. Osterholtz, Resident Inspector L. L. Eckert, Radiation Specialist T. A. Moslak, Radiation Specialist G. S. Vissing, Project Manager, NRR Approved by:

L. T,. Doerflein, Chief Projects Branch

Division of Reactor Projects 98ii240063 9Biii9 PDR ADOCK 05000244

PDR

EXECUTIVE SUMMARY R. E. Ginna Nuclear Power Plant NRC Inspection Report 50-244/98-11 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support.

The report covers a 6-week period of resident inspection, and includes the results of announced inspections by the NRR project manager and regional specialists in radwaste and transportation, and environmental monitoring.

~Oeretinne The human performance evaluation conducted in response to the August 17 inadvertent automatic insertion'of control rods was effective in identifying procedural deficiencies and recommending appropriate inter-departmental communications enhancements.

However, the licensee's overall corrective action response to this event to date, was weak, in that similar recent operational events were not assessed for broader human performance issues and trends.

The quarterly meeting of the Nuclear Safety and Audit Review Board was professionally conducted with good indepth discussions.

The outside board members were active in the discussions and had a positive impact on the board's deliberations, and all members displayed a good questioning attitude.

The independent safety oversight function of the board was successfully accomplished.

Maintenance Controlled procedures were used at maintenance job sites, were up to date, and were properly used by technicians involved in maintenance and surveillance work. The inspectors observed good personnel and plant safety practices.

Equipment tested met the acceptance criteria specified for operability. The acceptance criteria bases reviewed were adequate, with only minor discrepancies noted.

e Maintenance technicians effectively identified problems with the A-service water pump circuit breaker following refurbishment by Westinghouse.

The licensee also displayed a good effort in working with Westinghouse to correct the noted deficiencies.

The preventive measures utilized to avoid inadvertent grounding of lifted leads were ineffective during the installation of a bistable for the boric acid storage tank level instrument.

~En ineerin The licensee had a strong 10 CFR 50.59 determination process in place.

There had been a

noticeable improvement in the quality of the documentation of the bases for evaluating the three criteria for an unreviewed safety questio Executive Summary (cont'd)

The licensee effectively implemented radioactive waste management and transportation programs with an experienced staff who systematically adhered to clearly written and detailed procedures.

Radioactive waste and other radioactive materials shipped during the period of January through September 1998 were properly classified and packaged.

Areas containing radioactive wastes and contaminated materials were properly surveyed, posted, and controlled.

The licensee established, implemented, and maintained an adequate radiation monitoring system program for radiological instrument calibrations and reliability, and performance tracking and trending.

The ventilation system surveillance program was adequate with respect to charcoal adsorption surveillance tests, HEPA mechanical efficiency tests, and air flow rate tests.

The quality control program to validate measurement results for radioactive effluent samples was effective.

The licensee also established and implemented an effective quality assurance audit of the radioactive effluent control progra TABLE OF CONTENTS EXECUTIVE SUMMARY TABLE OF CONTENTS IV I ~ Operations

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Conduct of Operations

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01.1 General Comments Operational Status of Facilities and Equipment 02.1 Summary of Plant Status Operator Knowledge and Performance ~...... ~..........

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04.1 Human Performance Evaluation Following Inadvertent Automatic Control Rod Insertion Quality Assurance in Operations 07.1 Nuclear Safety and Audit Review Board (NSARB) Quarterly Meeting

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08.1 (Open) LER 1998-003: Radon Build-up During Temperature Inversion Results in Actuations of the Control Room Emergency AirTreatment System

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II. Maintenance

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M1 M2 Conduct of Maintenance M1.1 General Maintenance Activities...

M1.2 General Surveillance Activities Maintenance and Material Condition of Facilities and Equipment.....

M2.1 Refurbishment and Reinstallation of the A-.Service Water (A-SW)

Pump Circuit Breaker....

Maintenance Staff Knowledge and Performance M4.1 Instrument Bus Grounded During Bistable Replacement 4.4.6.8

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E2 Engineering Support of Facilities and Equipment E2.1 Re-racking of the Spent Fuel Pool....

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E7 Quality Assurance in Engineering Activities E7.1 Review of 10 CFR 50.59 Reports.,

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R1 R2 R5 Radiological Protection and Chemistry (RPSC) Controls R1.1 Solid Radioactive Waste Processing, Handling, Storage,

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Status of RPSC Facilities and Equipment R2.1 RPSC Facility and Equipment Tours......................

R2.2 Calibration of Radiation Monitoring Systems (RMS) and Flow Rate Monitors

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Staff Training and Qualification in RPSC........................

R5.1 Training for RGSE Staff on Radioactive Waste 14'4

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Table of Contents (cont'd)

R7 R8 Quality Assurance in Radiological Protection and Chemistry Activities... 18 R7.1 Quality Assurance (QA) Audits and Self-Assessments on Radioactive Waste....

. 18 Miscellaneous RPSC Issues...

. 19 R8.1 (Closed) Unresolved Item (URI) 50-244/96-01-05:Ventilation System Surveillance Criteria

~ 19 R8.2 (Closed) IFI 50-244/97-06-02: Environmental Thermoluminescent Dosimeter (TLD) Laboratory Issues

R8.3 (Closed) IFI 50-244/98-08-02:Groundwater Tritium Monitoring... 20 V. Management Meetings... ~...

X1 Exit Meeting Summary

20 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 feature (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.

Operational Status of Facilities and Equipment 02.1 Summar of Plant Status The plant operated at full power with good sustained operator performance throughout the inspection period.

Three separate instances occurred during the inspection period where the control room particulate radiation monitor (R-37) reached its alarm setpoint, actuated the control room emergency air treatment system (CREATS), and caused the control room ventilation system to isolate from outside air.

One instance occurred on September 15, 1998 and two occurred on September 18, 1998.

The first two occurred after an abnormally high accumulation of radon gas in the local air resulted from an air temperature inversion.

Both instances were reported to the NRC in accordance with 10 CFR 50.72.

The licensee determined from a follow-up investigation that the second actuation on September 18 was invalid and w'as therefore not reportable (see section 08.1).

On October 9, 1998, control room operators entered abnormal procedure AP-RCC.1, "Continuous Control Rod Withdrawal/Insertion," when control rods momentarily stepped in during a maintenance activity (see section M4.1)

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 Operator Knowledge and Performance 04.1 Human Performance Evaluation Followin Inadvertent Automatic Control Rod Insertion Ins ection Sco e (71707)

The inspectors reviewed the human performance evaluation completed in response to an event involving inadvertent automatic control rod motion.

Observations and Findin s On August 17, 1998, instrumentation and control (ISC) technicians were concurrently performing three calibration procedures involving the nuclear instruments, the reactor protection system, and the reactor delta flux instruments, that all required the rod control system to be selected to manual vice automatic control.

Control rods stepped in automatically after control room operators placed the rod control system in automatic, but prior to the completion of the turbine first stage impulse pressure portion of the reactor protection procedure.

Mis-communications between the IRC and operations staffs contributed to the rod control system being placed in automatic vice manual.

This event was previously discussed in IR 50-244/98-09.

The inspectors observed that this August 17 event was similar to two other recent operational events involving IRC maintenance activities.

One event involved the inadvertent automatic opening of a pressurizer power-operated relief valve (PORV)

on March 3, 1998, and the other involved an unnecessary adjustment to nuclear instruments on March 17, 1998, after a calorimetric was performed, but prior to the restoration from a calibration of the steam generator blowdown flow transmitters (see Inspection Follow-up Item (IFI) 50-244/98-03-01).

The inspectors noted that each of these events had contributing causes of poor pre-evolutionary briefings and poor communications between the IKC technicians and operators during the conduct of the activity.

The human performance evaluation for the'August 17 control rod automatic insertion event was completed on September 23, 1998, and concluded that the primary cause of the event was the concurrent performance of three procedures all requiring the rod control system to be selected to manual control. The evaluation recommended that the procedure be enhanced with a verification step to ensure that the rod control system was in manual prior to calibrating the turbine first stage impulse pressure.

In addition, the evaluation recommended improved communications between maintenance and operations personnel by pre-identifying critical interfaces and discussing these important interfaces during pre-job briefs and shift turnovers.

The inspectors noted that the human performance evaluation did not include a review of other recent operational events to identify possible broader human performance weaknesses or trends.

This was consistent with the evaluation guidelines, but viewed as a corrective action weakness by the inspector c.

Conclusions The human performance evaluation conducted in response to the August 17 inadvertent automatic insertion of control rods was effective in identifying procedural deficiencies and recommending appropriate inter-departmental communications enhancements.

'However, the licensee's overall corrective action response to this event to date, was weak, in that similar recent operational events were not assessed for broader human performance issues and trends.

Quality Assurance in Operations 07.1 Nuclear Safet and Audit Review Board NSARB Quarterl Meetin a.

Ins ection Sco e (71707)

The inspectors attended the quarterly NSARB meeting on September 30 and October 1, 1998, and evaluated the board's deliberations.

b.

Observations and Findin s The issues on the agenda were discussed in depth and with a questioning attitude by all the members.

The outside members were particularly active in the discussions and stimulated the questions.

All of the members were well prepared for the meeting.

Topics discussed included operational issues, recent plant performance, licensee event reports (LERs), an event investigation report on back leakage from the refueling water storage tank (RWST) into the sodium hydroxide (NAOH) tank, a rod insertion investigation report, license changes, plant changes, NRC inspection reports, quality assurance/quality control assessments and audits and organization changes.

At the conclusion of the meeting, the board chairman requested feedback and meeting critique from the'members.

Several constructive comments and suggestioris were received and noted for improving future meetings.

c; Conclusions The quarterly meeting of the NSARB was professionally conducted with good in-depth discussions.

Topics on the agenda were well developed and thoroughly discussed during their presentation.

The outside members were active in the discussions and had a positive impact on the board.

All members displayed a

probing attitude.

The independent safety oversight function of the board was successfully accomplishe Miscellaneous Operations Issues 08.1 0 en LER 1998-003: Radon Build-u Durin Tem erature Inversion Results in Actuations of the Control Room Emer enc AirTreatment S stem On October 5, 1998, the licensee submitted LER 1998-003 to the NRC following three successive actuations of the Control Room Emergency AirTreatment System (CREATS) causing the control room'ventilation system to isolate from the outside air and to reconfigure to its recirculation mode.

The actuations occurred when a local air temperature inversion, coincident with very little wind, caused a high concentration of radon gas and radon daughter products to accumulate in the air surrounding the plant.

The three actuations occurred on September 4, 15, and 18, 1998, when the GREATS radiation instrumentation for high particulates exceeded 1000 counts per minute (cpm). The licensee made four-hour reports to the NRC in accordance with the requirements of 10 CFR 50.72 for each of the occurrences.

Additionally, a second actuation occurred on September 18, 1998, but the licensee determined that it was caused by an spurious instrument spike, and concluded that the actuation was neither valid nor reportable.

The inspectors discussed these events with an radiation protection (RP) analyst and reviewed the air sample and temperature profile dat'a the licensee obtained soon after each actuation.

All of the air sample data indicated relatively high concentrations of radon and radon daughter products, and an absence of other nuclides which could have originated from inside the plant.

The data was consistent with the gas and particulate concentrations detected by the CREATS instruments, and the air temperature profile supported the licensee's conclusion that a temperature inversion contributed to the high radon concentrations.

The LER included an operational analysis that determined control room operators correctly responded to alarms and entered alarm response procedure AR-E-11,

"Control Room HVAC Isolation." The inspectors observed that the control room ventilation system remained in the recirculation mode. at the end of the inspection period, while further analysis and troubleshooting for potential anomalies in'the CREATS instrumentation was ongoing.

The licensee indicated that a supplement to the LER would be issued by December 10, 1998, to report further results.

Pending NRC review of the supplement, this LER remains open.

II. Maintenance M1 Conduct of Maintenance M1.1 General Maintenance Activities Ins ection Sco e (62707)

The inspectors observed portions of the following 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 maintenarice testing.

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Observations and Findin s W.O. 19803447 5 19803448: Periodic maintenance inspection of C-safety injection pump supply breakers from safeguards buses 14 5. 16; work was performed in accordance with procedure GME-50-02-DBINSPECT,

"Westinghouse DB Breaker Inspection," (observed on September 14, 1998).

W.O. 19802991: Preparation and installation of new fuel storage racks in the spent fuel pool (observed September 17, 23, 1998); Removal of old storage racks and re-rack operations (observed periodically throughout the inspection period).

W.O. 19803841: Inspection and maintenance of the A-Service Water Pump DB-25 circuit breaker after refurbishment by Westinghouse in accordance with procedures GME-50-02-DBINSPECT, "Westinghouse DB Breaker Inspection," and CME 50-02-52, "Westinghouse 480 Volt Air Circuit Breaker, Type DB-25, Service Water Pump A, Bus 18, Position 29C, Maintenance for 52/SWP1A," (observed on September 25, and October 10-14, 1998) (see report section M2.1).

W.O. 19702387: Calibration of RHR bypass flow control valve HCV-626 in accordance with procedure CPI-CV-626, "Calibration of Residual Heat Removal Flow Control Valve FCV-626," (observed on September 28, 1998).

W.O. 19803453: A-RHR pump DB-50 supply breaker inspection in accordance with procedure GME-50-02-DBINSPECT, "Westinghouse DB Breaker Inspection," (observed on September 30, 1998)

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The breaker's performance was sluggish during a low voltage (87 VDC) trip test, and the X-coil contacts did not always makeup at low voltage.

The licensee concluded that a full PM disassembly and inspection was warranted.

W.O. 19803956; A-RHR pump DB-50 circuit breaker refurbishment in accordance with procedure M-32.1.50, "DB-50 Circuit Breaker Maintenance," (observed on September 30, 1998),

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Conclusions The inspectors observed that controlled procedures in use at maintenance job sites were up to date and were properly utilized by technicians involved in the work. The inspectors observed good personnel and plant safety practices during the maintenance work,

M1.2 General Surveillance Activities'.

Ins ection Sco e (61726)

The inspectors observed selected surveillance tests to verify that approved procedures were in use, procedure details were adequate, test instrumentation was properly calibrated and used, technical specifications were satisfied, testing was performed by knowledgeable personnel, and test results satisfied acceptance criteria or were properly dispositioned.

b.

Observations and Findin s The inspectors observed portions of the following periodic test (PT) surveillance activities:

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PT-12.2, "Emergency Diesel Generator B," (observed on September 8 and October 6, 1998)

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PT-3Q, "Containment Spray Pump Quarterly Test," (observed on September 15, 1998).

PT-36Q-D, "Standby Auxiliary Feedwater Pump - Quarterly," (observed on September 22, 1998).

PT-12.1, "Emergency Diesel Generator A," (observed on September 29, 1 998).

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PT-2.8Q, "Component Cooling Water Pump Quarterly Test," (observed October 8, 1998).

The inspectors reviewed the performance data collected by technicians during the surveillance tests, and verified that all equipment met the acceptance criteria specified for operability. The inspectors also reviewed selected acceptance criteria bases (ACBs) that the licensee's performance monitoring group used to document the design basis functional requirements for plant equipment.

ACB 94-033 indicated that EDG lube oil (LO) outlet temperature had an allowable value of 0- 189 degrees Fahrenheit ('F), with the high limit based on vendor recommendations.

However, the inspector noted that the gage for measuring LO outlet temperature had a minimum reading of 30 F, and that having a LO temperature below the service water freezing point was not a credible condition.

The licensee indicated that the ACB for low LO outlet temperature was based on the specifications for the oil, and would be re-evaluated to determine a more realistic minimum valu ACB 97-063 for EDG revolutions per minute (rpm) dated September 5, 1997, stated that "no acceptable range had been determined - obtaining data."

The licensee indicated that an acceptance criteria for EDG rpm would be evaluated and incorporated prior to the next refueling outage.

ACB 95-054 indicated a standby auxiliary feedwater pump (AFW) test flow rate of 200 gpm based on the requirements of "technical specification 3.7.5." However, the ACB.was referring to the old technical specifications that had since been replaced by the ITS. The 200 gpm crite'ria had subsequently been incorporated into the licensee's inservice testing (IST) program.

The licensee indicated that the ACB would be updated to indicate the correct reference.

ACB 94-133 indicated a flow rate of 3000 gpm for component cooling water (CCW)

pumps was necessary to ensure one CCW train can provide minimum flow to mitigate and recover from a loss-of-coolant accident.

The inspectors verified that this value exceeded the Updated Final Safety Analysis Report (UFSAR) minimum requirements for CCW flow.

The inspectors reviewed procedure PT-3Q and noted that the specific acceptance criteria for containment spray system chemical eductor flow (R 38 gpm + 0.1428 RWST level) had been recently revised to address previous NRC concerns over the lack of a correlation between the minimum eductor flow during test conditions using RWST water, versus the minimum flow required during accident conditions where NaOH would be delivered to the containment sump through the eductors (see IR 50-244/98-07).

ACB 98-040 had been revised to reflect the results of a recent engineering analysis which concluded that a more restrictive limit on eductor flow during surveillance testing was necessary because of the large effect of the RWST water level on eductor flow during surveillance testing.

The licensee's design basis records for the CS system were also updated with the current engineering analysis.

The inspectors noted that IST data recorded on the PT-3Q data sheets was taken and reviewed for acceptability by an individual other than the person who signed the data sheet.

The inspectors discussed this situation with the performance monitoring supervisor, who had not yet reviewed the data.

Although technicians normally sign for the adequacy of the data they record, the supervisor indicated that his final review would provide the required certification and signature in this procedure before it was archived as a permanent plant record.

The inspectors verified this practice satisfied the licensee's administrative requirements for certifying IST performance data.

Conclusions The inspectors confirmed that procedures used during surveillance tests were current and properly followed. The equipment tested met the acceptance criteria specified in the procedures for operability. The acceptance criteria bases reviewed were adequate, with only minor discrepancies note M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Refurbishment and Reinstallation of the A-Service Water A-SW Pum Circuit Breaker a.

Ins ection Sco e (62703)

The inspectors reviewed the licensee's actions to restore the failed A-SW pump breaker to service.

b.

Observations and Findin s On August 4, 1998, the licensee sent the A-SW pump breaker to the Westinghouse repair facility in Cheswick, Pennsylvania following an inservice failure where the

.breaker tripped open after momentarily closing upon a demand signal from the control room on July 30, 1998 (see IR 50-244/98-09).

The inspectors had been concerned with the high frequency of Westinghouse DB circuit breaker failures at the Ginna Station, particularly in this instance since neither the licensee nor Westinghouse could determine a root cause for. the failure.

Westinghouse refurbished the breaker and returned it to Ginna Station on September 21, 1998.

However, electrical maintenance technicians inspected the breaker at the station and noted several deficiencies as follows:

1) secondary contacts with the silver coating worn through; 2) a missing "E" clip on the escutcheon plate assembly; and, 3) the breaker's trip mechanism was binding and prevented the breaker from resetting.

On September 30, 1998, an RGSE s'stem engineer accompanied the breaker to Westinghouse's Cheswick, PA facility for correction of these problems.

Westinghouse determined that the binding trip mechanism was caused by an oversized first toggle link. Following replacement of the toggle link and additional repairs, Westinghouse returned the breaker to Ginna on October 6, 1998, where it was satisfactorily inspected and bench tested.

The licensee re-installed the breaker in its cubicle and returned it to service on October 14, 1998, following a satisfactory functional test.

Westinghouse indicated that the oversized. toggle link would be evaluated for a potential 10 CFR Part 21 report.

c.

Conclusions Electrical maintenance technicians effectively identified problems with the A-service water pump circuit breaker following its refurbishment by Westinghouse.

The licensee also displayed a good effort in working with Westinghouse to correct the noted deficiencie IVI4 Maintenance Staff Knowledge and Performance M4.1 Instrument Bus Grounded Durin Bistable Re lacement a.

Ins ection Sco e (62703)

The inspectors reviewed the circumstances surrounding inadvertent automatic control rod motion that resulted from a grounded instrument bus during a maintenance activity.

b.

Observations and Findin s On October 9, 1998, l&C technicians replaced a bistable module for the boric acid storage tank (BAST) level instrument because the installed module had aged and could no longer hold its calibration.

During installation of the replacement module, a ground occurred on the A-instrument bus when a lifted wire slipped out of an IRC technician's hand and momentarily contacted the face of the bistable module.

The momentary ground caused the turbine first stage impulse pressure instrument to spike low, and resulted in a main control board alarm and automatic control rod inward motion of one step.

Control room operators temporarily entered abnormal procedure AP-RCC.1, "Continuous Control Rod Withdrawal/Insertion," in response to the inward rod motion. The effects of this transient on the plant were relatively inconsequential, in this instance.

The licensee replaced the bistable module in accordance with maintenance procedure M-74.1, "Removal and/or Installation of Modules Within Defeated or Out of Service Instrument Loops." The M-74.1 instructions included several steps designed to prevent electrical grounds by directing that'the module face be taped with nonconductive electrical tape.

The ISC technician indicated that the module face had been taped in accordance with M-74.1, but that the wiie went underneath the tape after it slipped out of his hand.

The licensee generated an ACTION Report (98-1472) to evaluate potential human performance issues related to this event.

Conclusions The licensee's preventive measures utilized to avoid inadvertent grounding of lifted leads were ineffective during the installation of a bistable for the boric acid storage tank level instrument.

However, the licensee's effort to investigate human performance issues related to this event was a good initiativ III. En ineerin E2 Engineering Support of Facilities and Equipment E2.1 Re-rackin of the S ent Fuel Pool V a.

Ins ection Sco e (37551)

The inspectors reviewed the engineering modification package for expanding the storage capacity of the spent fuel pool (SFP), and periodically observed operations in and around the pool for re-arranging existing fuel bundles, removing seve'ral existing storage racks, and installing new racks with an improved design.

b.

Observations and Findin s The licensee developed plant change request (PCR)98-098, "Spent Fuel Storage" and Station Modification procedure SM-95-098.1, "Spent Fuel Storage Safety Related Modification," to modify the spent fuel pool (SFP) and increase its storage capacity to accommodate all fuel discharges through the end of the plant's operating license (September 2009). The modification involved relocating some spent fuel assemblies already in the SFP to accommodate the removal of several existing storage racks and the installation of new racks in approximately 1/3 of the total SFP area.

The modification preserved a total of 840 existing storage locations which contained all of the spent fuel currently stored on site.

The new racks contained one area with 337 storage locations for completely spent fuel (i.e., fuel at or above its maximum burnup) and 144 locations for storage of "fresh" fuel (i.e.,

fuel at less than its maximum burnup).

A second new area was designed to contain 248 storage locations only for storing completely spent fuel. Ap'proximately 50 additional locations should be available after the last full core discharge in September 2009.

The modification required several underwater diving operations to remove installed hardware that would interfere with the new storage racks, and to install several shim plates needed to achieve an equal elevation for all of the new racks.

The licensee procured contract services from Framatome Technology International (FTI)'o.

to coordinate the modification work, and to sub-contract services for underwater diving operations.

During the planning phases for the SFP modifications, the licensee had used an estimated'total time of 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br /> to accomplish all underwater work. The total estimated dose for this re-racking work was then estimated to be 2.94 person-REM, by using the average underwater exposure rate of 60 mR/hr for divers during the last SFP re-rack work in 1984. All dives for the current re-racking were limited to a maximum of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 20 minutes to prevent diver fatigu The licensee used administrative procedure A-1.10, "Control of Underwater Diving

'Activities In the Spent Fuel Pool," which required that the licensee and the prime contractor prepare a formally documented dive plan for all manual work by a diver under water.

The procedure also contained specific requirements for planning and controlling the radiological aspects of the underwater work.

The inspectors reviewed the licensee's dive plan written for a dive on October 1, 1998, to remove underwater obstructions (welded bracket and light funnel) on the North wall of the SFP.

The work team performed a pre-job briefing which included a complete review of all dive plan requirements and a detailed discussion of the responsibilities of each crew member, all RP technicians, and all supervisory personnel.

The briefing also included a review of the detailed map from the dive plan that depicted all of the underwater work areas.

Minor modifications were made to the plan for clarification and the final dive plan was approved by the dive supervisor, the RGRE project coordinator, the FTI task leader, and the RG&E lead RP technician.

The inspectors noted that the maximum radiation levels measured in two defined work areas were 150 and 220 mR/hr, respectively.

The total expected dose to a diver in b'oth work areas was estimated at 90 mR. However, a diver who worked in both areas for a total of 75 minutes received an actual dose of 19 mR.

The inspectors also reviewed the dive plan for the October 15, 1998 SFP activities.

The plan contained instructions for removing obstructions on the South wall of the SFP near rack ¹5. The work also involved removing old storage rack shim plates and debris from the SFP floor near the light funnel in the cask laydown area.

Preplanned confirmatory radiation surveys were completed just before the work commenced and caused the work team to re-evaluate the anticipated exposure levels for the diver. The team decided to move several spent fuel bundles out of the peripheral storage locations in rack ¹5 in order to reduce the exposure levels in the work area to as low as reasonably. achievable (ALARA). The highest exposure levels in the work were reduced to 40 mR/hr and the general area level was reduced to approximately 10 mR/hr. The new expected total dose for the diver was 150 mR. The diver worked in this area for approximately 100 minutes and his actual total dose was 6 mR.

The work team accomplished all underwater work with the aid of an underwater

'amera for the support crew, constant radio communications between the diver and the support crew, and remote reading and alarming dosimetry on the diver. The team completed all dives in the SFP on October 15, 1998. The total whole body dose received by the three divers, for all dives in the SFP, was 180 mR (a total of 817 minutes under water)

~ The highest cumulative dose received by a diver was 115 mR, from three separate dives.

The licensee accomplished a "dry" drag test in each new rack as part of its receipt inspection testing.

After installation in the SFP, each new rack was leveled to within ~1/8 inch across both diagonal corners.

A final "wet" drag test was completed inside each storage location to assure that each location was free from

distortion after installation.

The work team took final gap measurements between each of the new racks, and between each peripheral rack along the walls of the SFP liner to verify their final location.

Using an underwater video camera, the team also verified that the cooling flow holes in the bottom region of each storage rack were free from obstruction.

The installation team experienced several minor schedule delays from unanticipated complications with the rigging equipment.

Some delays were also experienced during the layout templating for the new shims used to adjust all new racks to a constant elevation.

However, these complications did not significantly delay the overall schedule, and the work team was able to recover the original schedule to have all work completed by the end of November 1998. At the end of the inspection period, all of the new storage racks installed were accepted for use, and no out of specification conditions had been identified.

C.

Conclusions E7 The inspectors concluded that the licensee's spent fuel pool re-racking operations were well controlled to assure that the modification was installed as designed.

The installation team and support personnel exercised deliberate care to control the

.radiological aspects of the work, and to maintain the final radiation exposures as low as reasonably achievable.

Quality Assurance in Engineering Activities E7.1 Review of 10 CFR 50.59 Re orts a ~

Ins ection Sco e'(37702,37703)

The inspectors reviewed the licensee's administrative procedures used to prepare 10 CFR 50.59 safety evaluations, and also reviewed a sample of safety evaluations completed for recent plant changes.

b.

Observations and Findin s The licensee used interface procedure IP-SEV-1, "Preparation, Review and Approval of Safety Reviews," for activities that constitute changes to the facility or its documented description.

The procedure included instructions for conducting an initial safety review to determine if there was a need to prepare a formal 10 CFR 50.59 safety evaluation.

It also provided guidance for evaluating the safety and licensing consequences of temporary and permanent activities at the facility such as 1) plant configuration and configuration document changes, 2) UFSAR changes, 3)

changes to the plant's design basis or design basis documents, 4) new plant procedures or 'procedure changes, 5) nonconforming conditions, 6) changes to a regulatory commitment, and 7) proposed tests or experiments.

The procedure clearly stipulated that a second party reviewer not having been involved in the change process verify the results of the evaluation.

The inspector considered that the procedure provided clear instructions and was relatively simple to follo Interface procedure IP-SEV-2, "Preparation, Review, and Approval of 10 CFR 50.59 Safety Evaluations," provided instructions for determining whether or not proposed changes 1) involved an unreviewed safety question or change to the Improved Technical Specifications (ITS), and 2) may be implemented without prior NRC approval.

The procedure also required that proposed plant changes be evaluated with respect to original safety considerations of the plant design basis while preserving the Updated Final Safety Analysis Report (UFSAR) and the ITS. The procedure provided the necessary information that was used to evaluate three conditions that define an unreviewed safety question and broke down the three criteria into seven individual elements requiring development.

In general, the procedure was excellent guidance for evaluating proposed plant changes with respect to existing 10 CFR 50.59 criteria.

The inspectors reviewed the licensee's periodic 50.59 report for August 1996 through December 1998. The report indicated that 42 plant modifications did not constitute an unreviewed safety question under the criteria of 10 CFR 50.59. The inspectors reviewed nine safety evaluations listed in the report, as follows:

SEV-1075, Repositioning valves 8808 and 880C SEV-1082, Spent Fuel Pool Cooling System Lower Suction SEV-1084, Reversal of Power and Control Circuits for Pressurizer PORV Block Valves MOVs 515 and 516, PCR 96-114 SEV-1086, Removal of Service Water Pump Remote Control Switches From Control Circuits SEV-1090, Technical Specification Bases Change for Screenhouse Bay Temperature Limit SEV-1099, Pressurizer Safety Valve LVDTPower Supply UFSAR Correction SEV-1103', Vacuum Fill of the Reactor Coolant System SEV-1105, Vacuum Effects on RCS Instrumentation During RCS Vacuum Vent and Fill SEV-1106, Core Exit Thermocouples Display Replacement The above safety evaluations provided thorough and detailed descriptions of the scope of the change activities.

The safety evaluations varied somewhat in the level of detail included in each package; however, each SEV appeared to stand alone without addition'al supporting documentation.

These variations appeared to be dependent upon the individuals performing the evaluations, and the individual reviewers.

However, the safety evaluations generally provided a level of detail commensurate with the change such that an independent reviewer could reach the same conclusions of why an unreviewed safety question was not involved as a result of the proposed changes.

Over the past 18 months, the licensee made noticeable improvements in the quality of the documentation of the bases for making determinations on the three criteria for an unreviewed safety questio Conclusions The licensee had a strong 10 CFR 50.59 determination process in place.

The licensee made noticeable improvements in the quality of the documentation for determinations on the three criteria for an unreviewed safety question.

IV. Plant Su ort Radiological Protection and Chemistry (RP8cC) Controls Solid Radioactive Waste Processin Handlin Store e

and Shi in Ins ection Sco e (86750)

The inspectors reviewed the licensee's implementation of their Process Control Plan (PCP) and associated procedures relative to waste characterization, the development/application of scaling factors, volume reduction efforts, and waste storage.

Shipping records for shipments of radioactive waste and other radioactive materials made during 1998 were also reviewed.

Site tours were conducted and direct observations were made of transportation activities, including receipt inspection of a shipping package used for transporting surface contaminated objects (SCOs) and a shipment of survey instrument calibration sources to a vendor.

Observations and Findin s The PCP was an accurate and complete description of the facility's waste streams, waste sampling/classification methods, and overall waste management practices.

The PCP contained detailed procedures that addressed the licensee's 10 CFR Part

'1 waste characterization sampling methodology.

Appropriate scaling factors were developed for use in determining curie content of hard-to-detect radionuclides.

Relevant data was appropriately applied to the RADMANcomputer code for classifying waste.

The licensee's efforts to reduce radwaste volume generated during routine tasks have been effective with an improving trend noted over the past four years.

Work associated with the spent fuel pool re-racking modification currently in progress added to the overall waste inventory. The licensee was taking appropriate measures to minimize the waste generated during this activity to as low as practical.

The licensee effectively implemented the radioactive waste/material shipping program.

Manifests and supporting documentation were complete and detailed.

The radwaste staff/technicians were experienced and knowledgeable of their responsibilities and of the regulatory requirements.

Up-to-date copies of the applicable NRC and Department of Transportation (DOT) regulations, High Integrity Container/cask certificates of compliance, and receiving facility licenses were well maintained and readily available for revie The inspectors made direct observations of the radwaste staff performing a receipt inspection of a shipping package on September 22, 1998, and preparing a 181 millicurie Cs-137 calibration source for shipment on September 24, 1998.

Personnel followed clearly written and detailed procedures in completing their activities.

Surveys were conscientiously performed, supporting documentation was accurately completed, packages were correctly labeled, and regulatory requirements were met.

C.

Conclusion The radi'oactive waste management and transportation programs were effectively implemented as evidenced by a qualified and experienced staff systematically adhering to clearly written and detailed procedures.

Radioactive waste and other radioactive materials shipped during January through September 1998 were properly classified and packaged.

R2 Status of RPSC Facilities and Equipment R2.1 RPSC Facilit and E ui ment Tours a 0 Ins ection Sco e (86750)

The inspectors made tours of various radwaste and radioactive material storage areas including the Auxiliary Building, the Upper Radwaste Storage Building, the Radioactive Materials Storage Building, and the Contaminated Storage Building to assess the adequacy in controlling radioactive materials.

Observations and'Findin s

The Auxiliary Building, Upper Radwaste Storage Building (URWSB), and the Radioactive Materials Storage Building were well maintained and properly posted, with access appropriately controlled.

Known radioactive waste was properly segregated, and the licensee used a "Green Is Clean" program for "potentially contaminated" materials until final release surveys were completed.

Contaminated equipment stored in the Radioactive Materials Storage Building was properly labeled, and surveys were current.

The inspectors confirmed the accuracy of posted surveys by conducting independent surveys of selected areas and equipment.

Inventories of waste contained in the URWSB were current and complete.

The inspectors considered that housekeeping in the Contaminated Storage Building (CSB) warranted increased management attention.

Access to this area was properly controlled and the area was properly posted as a Radiologically Controlled Area.

However, aisles were blocked with staged material, work areas were congested, and storage cabinets were in disarray.

The licensee's principal health physicist accompanied the inspector on the tour and also observed these discrepancies.

He subsequently initiated an ACTION Report to document and correct the conditions.

Housekeeping in the CSB had improved by the end of the inspectio c.

Conclusions Areas containing radioactive waste and contaminated materials were properly surveyed, posted, and controlled.

Several housekeeping discrepancies were noted.

R2.2 Calibration of Radiation Monitorin S stems RMS and Flow Rate Monitors a.

Ins ection Sco e (84750-01)

The inspector held discussions primarily with the RMS system engineer and radiation protection (RP) staff members.

The inspector also reviewed radiological calibration results for the following effluent/process monitors.

Radiation Monitorin Instruments

~

Spent Fuel Pool Area Monitor (R-5)"

~

Containment Purge Noble Gas Monitors (R-12" and R-12A)

~

Plant Vent Effluent Noble Gas Monitors (R-14 and R-14A)

~

Condenser Air Ejector (R-15 and R-15A)

~

Containment Fan Coolers (R-16)

~

Component Cooling Water (R-17)"

~

Liquid Waste Disposal (R-18)"

~

Steam Generator Blowdown Monitors (R-19)"

~

Spent Fuel Heat Exchanger (R-20A" and R-20B)

~

Turbine Building Floor Drain (R-21)

~

Containment Area Monitors (R-29 and R-30)".

~

Main Steam Line Monitors (R-31 and R-32)

Flow Rate Monitor

~

Plant Vent Flow Rate"

" indicates review of electronic alignment records b.

Observations and Findin s The IRC and RP Departments maintained the responsibility of performing electronic alignments, radiation source calibrations, and functional tests for the above effluent, process, and area RMS instruments; and channel calibrations of the flow rate monitor. The inspectors found the calibration results to be within RGSE's acceptance criteria.

The licensee identified certain RMS instruments as warranting additional attention in accordance with their maintenance rule program.

Several initiatives were planned and were underway to help improve system performanc The inspector's review of licensee RMS calibration data indicated that the electronic calibration methodology for the above monitors was acceptable.

A recent self-assessment was performed that focused on the RMS calibration program.

As of this inspection, cognizant licensee staff had started to address the self-assessment findings.

C.

Conclusions RGKE established, implemented, and maintained an adequate radiation monitoring system program with respect to electronic alignments, radiation source calibrations, system reliability, and tracking and trending.

R5 Staff Training and Qualification in RP8cC R5.1 Trainin for RG&E Staff on Radioactive Waste Ins ection Sco e (86750)

The inspectors reviewed the training of personnel responsible for classifying radioactive waste and preparing radioactive waste/materials for shipment to determine compliance with the requirements of 49 CFR 172, Subpart H and NRC Bulletin 79-19.

Lesson plans and qualification records of selected individuals were reviewed and discussed with training and Radiation Protection 5 Chemistry management.

b.

Observations and Findin s The licensee prov'ided initial training and periodic re-training to personnel responsible for classifying radioactive waste and preparing radioactive materials for shipment.

The training materials were appropriate and consistent with current NRC and Department of Transportation (DOT) regulations.

The licensee's qualification records were current and reflected the training requirements stated in RGSE's procedure RPA-RW-TRNG, "Training and Responsibilities of Individuals Involved in Radwaste Group Activities," Revision 1, dated August 8, 1996.

The licensee provided specialized training to selected individuals on using computerized programs for classifying radioactive waste, applying scaling factors, and generating shipment documentation.

RP personnel were knowledgeable of program attributes and demonstrated good proficiency using the program.

The Radwaste Group has been a stable, experienced organization with no recent personnel changes.

C.

Conclusion Personnel responsible for classifying radioactive waste and shipping radioactive materials met NRC and DOT training and re-training requirement R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Qualit Assurance QA Audits and Self-Assessments on Radioactive Waste Ins ection Sco e (84750, 86750)

The inspectors reviewed the licensee's of inter-laboratory measurement comparisons, and the chemistry laboratory quality control program for radioactive liquid and gaseous effluent samples.

The inspectors also assessed the effectiveness of various management controls through reviews of audits and surveillances performed by the QA Department, internal self-assessments conducted by the Radiation Protection and Chemistry Department and various ACTION Reports regarding radwaste management.

The inspectors also reviewed the management tour program.

b.

Observations and Findin s All inter-laboratory QA measurements were within RGSE's acceptance criteria.

No anomalous trends were noted during a review of quality control charts for gamma and tritium measurements.

The QA Department had been self-critical in evaluating the depth and scope of audits regarding radiation protection department performance.

Following completion of the Radiological Protection, Chemistry, and Radwaste Programs Audit, AINT-1997-0008-NAB,completed in mid-1997, the QA Department concluded that the audit was too broad in scope to provide an in-depth evaluation of the Process Control Plan and radioactive waste management activities.

The licensee initiated ACTION Report 97-1885 and took measures to schedule a

dedicated audit of the Process Control Plan and radwaste activities during the fourth quarter of 1998. To support this effort, a third party technical specialist with expertise in these areas was planning to assist in the audit.

The inspectors considered these to be good actions for improving the quality of the audit process.

Quarterly self-assessments of the Radiation Protection Program's performance were properly focused in the area of managing radioactive waste.

ACTION Reports related to radiological incidents were analyzed to identify human performance issues and trends that could degrade performance.

No adverse trends were evident in controlling contamination or managing radioactive materials for the first quarter of 1998.

The inspectors reviewed nine ACTION Reports generated during the period August 1, 1997 to September 17, 1998, that related to implementation of the radioactive waste management program.

The deficiencies were promptly addressed and corrective actions were appropriate to preclude repetitive occurrences.

Examples include 97-1883, assuring the representativeness of primary resin samples; 98-0142, reducing personnel dose and radwaste when removing water from the cavity seal ring area; and 97-1761, minimizing water directed to the waste holdup tank (WHUT) when hydrolazing component cooling water heat exchangers.

Generally, the problems reported reflected a conservative threshold for initiating ACTION Report Weekly tours conducted by the senior staff and management within the radiation protection department were effective in communicating management expectations regarding minimizing radwaste generation during daily activities.

This formalized program was mandated by administrative procedure A-54.6, "Radiation Protection Tour." Inspection results were widely disseminated, including weekly review by the Plant Operations Review Committee.

Conclusion RG&E implemented an effective quality control program to validate measurement results for radioactive effluent samples.

Problem areas were appropriately identified and satisfactorily resolved through management controls, the problem reporting system, quality assurance audits/surveillances, departmental self-assessments, and frequent in-plant tours by radiation protection management.

Miscellaneous RP&C Issues Closed Unresolved Item URI 50-244 96-01-05:Ventilation S stem Surveillance Criteria NRC Inspection Report 50-244/96-01 noted that control room and auxiliary building ventilation system surveillance tests did not provide a specific acceptance criteria for air capacity.

The licensee subsequently added specific criteria to enhance the surveillance procedures for air capacity testing of the control room and auxiliary building ventilation systems.

The inspectors interviewed cognizant staff, reviewed air capacity tests, and HEPA filter and charcoal adsorption surveillance test results for the control room and auxiliary building ventilation systems.

Recent test results indicated that the two systems performed acceptably as compared to the newly incorporated acceptance criteria.

The inspectors concluded that RG&E had properly established and implemented an adequate ventilation system surveillance program with respect to charcoal adsorption surveillance tests, HEPA mechanical efficiency tests, and air flow rate tests.

The addition of air capacity acceptance criteria has enhanced the overall acceptability of periodic testing and system performance monitoring. The absence of system air capacity acceptance criteria was not contrary to regulatory requirements.

This unresolved item is closed.

(URI 50-244/96-01-05).

Closed IFI 50-244 97-06-02: Environmental Thermoluminescent Dosimeter TLD Laborator Issues After the conduct of NRC Inspection 50-244/97-06,the licensee discovered a data transpositional error that had been largely responsible for the discrepancies between NRC and RG&E environmental TLD results.

The licensee showed the inspector the corrected RG&E environmental TLD data that compared favorably to NRC environmental TLD data.

Additionally, cognizant licensee personnel stated their intent to conduct more frequent element calibration factor evaluations and to

correct for transit dose.

Licensee personnel also enacted changes to TLD program administrative controls procedures.

The inspector noted that differences in personnel and environmental TLD quality control were clearly differentiated in the revised procedures.

These actions adequately addressed the issues pertaining to quality control of the environmental TLD program, and this item is closed.

(IFI 50-244/97-06-02).

R8.3 Closed IFI 50-244 98-08-02: Groundwater Tritium Monitorin The licensee had adapted their effluent and environmental sampling programs to monitor this potential release pathway and had assigned an individual within system engineering to oversee this issue.

Effluent and environmental sampling data

~

indicated that the spent fuel pool pathway was not currently a significant release pathway as defined by Regulatory Guid'e 1.109.

The licensee indicated that spent fuel pool leakage will be considered a potential release pathway if not actually an on-going release pathway, in accordance with Generic Letter 80-10, Contamination of Non-Radiological Systems and Resulting Potential for Unmonitored, Uncontrolled Release to the Environment.

The licensee also plans to continue to monitor spent fuel pool leakage under the Maintenance Rule program.

This open item is closed.

(IFI 50-244/98-08-02)

V. Mana ement Meetin s

X1 Exit Meeting Summary The inspectors presented the results of the effluents monitoring program inspection to licensee management at the conclusion of the inspection on September 18, 1998.

RGSE ackhowledged the findings presented.

The inspectors presented the results of the Radwaste and Transportation inspection on September 25, 1998. At the end of the inspection period, the inspectors presented the overall inspection results to licensee management on October 22, 1998. The licensee acknowledged the findings presented.

The licensee indicated that no materials examined during the inspection should be considered proprietar ATTACHMENTI PARTIALLIST OF PERSONS CONTACTED Licensee B. Flynn C. Forkell G. Graus J. Hotchkiss G. Joss R. Marchionda F. Mis P. Polfleit R. Ploof J. Smith W. Thomson J. Traynor J. Widay T. White G. Wrobel Primary Systems Engineering Manager Electrical Systems Engineering Manager IRC/Electrical Maintenance Manager Mechanical Maintenance Manager Results and Test Supervisor Production Superintendent Principal Health Physicist Emergency Preparedness Manager Secondary Systems Engineering Manager Maintenance Superintendent Manager, Radiation Protection and Chemistry Senior Quality Assurance Analyst Plant Manager Operations Manager Nuclear Safety 5 Licensing Manager INSPECTION PROCEDURES USED IP 37551:

IP 40500:

IP 61726:

IP 62707:

IP 64704:

, IP 71707:

IP 71750:

IP 84750:

IP 86750:

IP 92700:

Onsite Engineering Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Surveillance Observation Maintenance Observation Fire Protection Program Plant Operations Plant Support Radioactive Waste Treatment, and Effluent and Environmental Monitoring Solid Radioactive Waste Management and Transportation of Radioactive Materials Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor'acilities

Attachment I

ITEMS OPENED, CLOSED, AND DISCUSSED

~Oened None Closed URI 50-244/96-01-05 Ventilation System Surveillance Criteria IFI 50-244/97-06-02 Environmental TLD Laboratory Issues IFI 50-244/98-08-02 Groundwater Tritium Monitoring Discussed None ACB AFW BAST CCW cpm CFR CREATS CSB oF DOT EDG ESF FTI gpm HEPA HPES HVAC IRC IFI IP IR IST ITS LER LO LVDT mR mR/hr LIST OF ACRONYMS USED

\\

Acceptance Criteria Basis Auxiliary Feedwater Boric Acid Storage Tank Component Cooling Water counts per minute Code of Federal Regulations Control Room Emergency AirTreatment System Contaminated Storage Building degrees Fahrenheit Department of Transportation Emergency Diesel Generator Engineered Safety Feature Framatome Technology International gallons per minute High Efficiency Particulate Human Performance Evaluation System Heating, Ventilation, and Air Conditioning Instrumentation and Control Inspector Follow-up Item Inspection Procedure

Inspection Report

Inservice Test

Improved Technical Specifications

Licensee Event Report

Lube Oil

linear variable differential transformer

milli REM

milli REM per hour

Attachment

I

NaOH

NRC

NSARB

PCP

PCR

PORV

PT

pslg

QA

RCS

RG&E

RHR

RMS

RP

rpm

RP

RP5C

RWST,

SCO

SFP

SW

TLD

UFSAR

URI

URWSB

VDC

WHUT

sodium hydroxide

Nuclear Regulatory Commission

Nuclear Safety Audit and Review Board

Process

Control Plan

Plant Change Request

Power Operated Relief Valve

Periodic Test

pounds per square inch gage

Quality Assurance

Reactor Coolant System

Rochester Gas and Electric Corporation

Residual Heat Removal

Radiation Monitoring System

Radiation Protection

revolutions per minute

Radiation Protection

Radiation Protection and Chemistry

Refueling Water Storage Tank

Surface Contaminated Object

.Spent Fuel Pool

Service Water

Thermoluminescent Dosimeter

Updated Final Safety Analysis Report

Unresolved Item

Upper Radwaste Storage Building

Volts Direct Current

Waste Holdup-Tank