IR 05000244/2005006
| ML053250497 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/21/2005 |
| From: | Doerflein L Engineering Region 1 Branch 2 |
| To: | Korsnick M Ginna |
| References | |
| IR-05-006 | |
| Download: ML053250497 (25) | |
Text
November 21, 2005
SUBJECT:
R. E. GINNA NUCLEAR POWER PLANT - NRC SAFETY SYSTEM DESIGN AND PERFORMANCE CAPABILITY INSPECTION REPORT 05000244/2005006
Dear Mrs. Korsnick:
On October 7, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed a safety system design and performance capability team inspection at your R. E. Ginna facility. The enclosed report documents the inspection finding which was discussed on October 7, 2005, with Mr. David Holm and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspection team reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding of very low safety significance (Green). The finding was also determined to involve a violation of NRC requirements. However, because of the very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at Ginna.
Mrs. Mary In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Lawrence T. Doerflein, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-244 License No. DPR-18 Enclosure:
Inspection Report 050244/2005006 w/Attachment: Supplemental Information cc w/encl:
M. J. Wallace, President, Constellation Generation J. M. Heffley, Senior Vice President and Chief Nuclear Officer P. Eddy, Electric Division, NYS Department of Public Service C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law C. W. Fleming, Esquire, Senior Counsel, Constellation Energy Group, Inc.
P. R. Smith, New York State Energy Research and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority T. Wideman, Director, Wayne County Emergency Management Office M. Meisenzahl, Administrator, Monroe County, Office of Emergency Preparedness T. Judson, Central New York Citizens Awareness Network
Mrs. Mary
SUMMARY OF FINDINGS
IR 05000244/2005006; 09/19/2005 - 10/07/2005; R. E. Ginna Nuclear Power Plant; Safety
System Design and Performance Capability.
This inspection was conducted by five inspectors from the NRCs Region I office and an NRC contractor. One Green non-cited violation (NCV) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation of 10 CFR 50, Appendix B,
Criterion XI, "Test Control," for failure to assure that the station battery test procedure incorporated acceptance limits and that test results were evaluated to assure that the test requirements had been satisfied. During the period 2000-2005, the licensee performed three Technical Specification surveillances on each safety-related station battery to verify the Operability of the safety-related components. The inspection team found that the results from the battery test procedure were not adequately assessed. Test results from this period indicated erratic readings on several battery cells; however, the licensee failed to evaluate the impact these readings had on the Operability of the batteries. In response to the teams questions, the licensee entered the issue into their corrective action program (CAP) and was able to show via subsequent test results that the batteries were Operable.
This finding is greater than minor because it affects the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences as it related to the Procedure attribute. The finding is of very low safety significance because it did not result in a loss of function per existing operability determination guidance. The cause of the finding is related to the cross-cutting area of problem identification and resolution (PI&R). (Section 1R21.3)
Licensee-Identified Violations
None.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Mitigating Systems and Barrier Integrity
==1R21 Safety System Design and Performance Capability (SSD&PC) (IP 71111.21)
1. Inspection Basis
==
The NRC team performed an inspection to verify that the selected safety systems would achieve their design and performance capability. The inspection effort reviewed Ginna's programs and methods for monitoring the capability of selected safety systems to perform the current design basis functions. The scope of the teams inspection also included non-safety-related structures, systems and components (SSCs) that provided functions required to support the selected systems safety functions.
The systems reviewed during this inspection were selected by the inspection team using information from Ginnas and NRCs probabilistic risk analysis models. The models were used to identify the risk significant SSCs in the Mitigating System and Barrier Integrity cornerstones. The inspectors also used a deterministic criteria in the selection process by considering previous SSDPC sample selection, recent inspection history, site problem history, and operational experience. The two systems selected for review were:
- component cooling water (CCW)
- turbine driven auxiliary feedwater (TDAFW)
The inspection included review and examination of support systems, such as electrical power, instrumentation, and related structures and components. The team assessed the adequacy of calculations, analyses, engineering processes, and engineering and operating practices that were used by the licensee to support the performance of the selected safety systems and associated support systems during normal, abnormal, and accident conditions. Acceptance criteria utilized by the NRC inspection team included NRC regulations, the technical specifications, applicable sections of the Updated Final Safety Analysis Report (UFSAR), applicable industry codes and standards, as well as, industry initiatives implemented by Ginnas programs. The team also assessed the licensees ability to monitor the system for age related degradation that could result in the system failing to fulfill its design requirement. A complete list of documents reviewed is included in the attachment to this report.
2. System Needs
a. Inspection Scope
The team inspected the following attributes of the two systems and associated support systems: Process Medium, Energy Sources, Controls, Operator Actions, and Heat Removal. The inspectors verified the above attributes met the requirements and design basis specifications identified in the UFSAR, technical specifications (TSs), licensee commitments, design basis documents, vendor technical manuals and plant drawings.
A complete list of documents reviewed is included in the attachment. The attributes that were verified to meet system requirements are described below:
Process Medium. The team assessed the capability of the TDAFW system to supply water at the required flow rate and pressure to the steam generators (SGs), during normal transients, design basis events (DBEs) and station blackout (SBO) conditions and that sufficient water inventory was available to meet design requirements. The team evaluated the net positive suction head (NPSH) available to verify whether cavitation would occur under expected operating conditions at the minimum condensate storage tank (CST) level. The team also assessed whether vortexing would occur at minimum CST level, to evaluate whether adverse effects from air entrainment could result in pump air bindings and loss of suction flow. In addition, the team evaluated the minimum recirculation capability for the TDAFW pump, to verify whether there was adequate removal of pump heat under low flow conditions and to assess whether there were any adverse effects from strong-pump weak-pump interactions from the motor driven AFW pumps, which shared the common recirculation line.
The team assessed the CCW system to determine whether it would supply the required flow rates and cooling water temperature to the residual heat removal system heat exchangers and pump motor coolers, safety injection pumps, containment spray pumps, and reactor coolant pump seals during normal transients and DBEs. The team evaluated the system design to determine whether there were any adverse effects from strong-pump weak-pump interactions to verify adequate removal of pump heat under low flow conditions. In addition, the team reviewed system interactions with other non-safety significant components cooled by CCW, to assess whether there were any common mode adverse effects.
Energy Sources. The team verified that electric (onsite and offsite power), steam, control power and air supplies for the CCW and TDAFW systems would be available during a DBE or SBO accident; and were adequate to energize/actuate the associated equipment during the accident. For electrical systems, the team reviewed the operating procedures, setpoints for degraded voltage relays, battery capacity, circuit breaker coordination, TSs, and other related calculations. The team verified that control power would be available and capable of supplying the required CCW and TDAFW system loads. The team assessed the systems' redundancy and individual component fail-safe capability to determine whether the loss of a single steam or air supply source could prevent the system from performing its design functions. The team also ensured that hydraulic and pneumatic sources for TDAFW turbine governor and air-operated valves (AOVs) were capable of supplying demanded loads. In addition, the inspectors conducted a walkdown to sample proper air regulator pressures that supply vital AOVs.
Controls. The team reviewed the automatic and manual controls for the CCW and TDAFW systems to assure that the automatic and manual control functions would be available for initiation, control and shutdown actions. Additionally, a review of alarms and indicators was performed to ensure that operator actions could be accomplished in accordance with the design assumptions. The inspectors conducted a walkdown to sample available controls, alarms, and indications required for safe operation.
Operation Actions. The team reviewed normal, abnormal and emergency operating procedures (EOPs) to verify that operator actions for the CCW and TDAFW systems assumed in the design bases could be completed. The team also reviewed those operator actions that were identified by the licensee as risk significant. Additionally, the team verified that operators were able to manually initiate the system, monitor components and system indications, automatically or manually control system functions and shutdown the system. The inspectors conducted a detailed table top review of the operator actions required during an SBO event (ECA-0.0, Loss of All AC Power) with Ginna senior reactor operators (see also Section 1R21.3, Operation).
Heat Removal. The team evaluated whether acceptable environmental conditions would be maintained in the TDAFW room to support system operations, as described in the design basis. Additionally, the team verified that the temperature rise on system components, due to heat generated by the system, was limited such that component temperature qualification was not exceeded.
b. Findings
No findings of significance were identified.
3. System Condition and Capability
a. Inspection Scope
The inspectors inspected the following attributes of the CCW and TDAFW systems and associated support systems: Installed Configuration, Operation, Design, and Testing.
The inspectors verified the above attributes met the requirements and design basis specifications identified in the UFSAR, TSs, licensee commitments, design basis documents, vendor technical manuals, calculations and plant drawings. A complete list of documents reviewed is included in the attachment to this report. The attributes that were verified to meet system requirements are described below:
Installed Configuration. The team performed detailed system walkdowns of accessible portions of the CCW and TDAFW systems to verify whether the installed configurations conformed to design basis requirements and assumptions. The team also walked down CCW and TDAFW support systems (including the control room, CSTs, emergency diesel generators, battery rooms, and electrical distribution motor control centers). The walkdowns focused on the installation and configuration of pumps, motors, valves, piping, and instruments; component material condition; licensee identified deficiencies; the placement of protective barriers; the susceptibility to flooding, fire, or other environmental concerns; physical separation of redundant trains; and provisions for seismic and other pressure transient concerns. The team compared their observations of the current installation configuration of the systems with the design and licensing bases to assure that the system would be capable of functioning during plant transients or accident conditions. Additionally, the team determined if the licensee had identified system deficiencies and entered them into the CAP.
Operation. The team performed a procedure walk-through of selected manual operator actions to confirm that the operators had the ability, access and tools necessary to accomplish actions credited in the design basis. The team assessed whether operating procedure performance was consistent with the design and licensing basis. The inspectors accompanied equipment operators on an infield walkdown to verify adequacy and timing of abnormal operating procedures needed to align alternate cooling to the TDAFW pump and supply backup water supply to the CSTs and TDAFW pump suction.
The inspectors reviewed the active operator workarounds, operator challenges, and operability determinations to assess the aggregate impact on the operators ability to operate the CCW and TDAFW systems as designed. The inspectors also conducted a thorough walkdown of control room instrumentation and control panels to assess CCW and TDAFW system configuration control and material condition.
Design. The team reviewed the mechanical, electrical, and instrumentation design of the CCW and TDAFW systems to assess whether the systems and subsystems would function as required under design conditions. This review included the design basis, design changes, formal and informal design assumptions, calculations, boundary conditions, and hydraulic and electrical system models, as well as selected modification packages. Instrumentation was reviewed to verify appropriateness of applications and setpoints, based on the required equipment function. Additionally, the inspectors performed limited independent calculations and analyses in several areas to verify the reasonableness of the design values. For the TDAFW system, the independent checks included NPSH, minimum CST level, and time available for manual operator action to swap suction sources from the CST to safety-related service water (SW).
For the DC system, the team reviewed DC system drawings and calculations to verify the adequacy of the capacity of the station batteries and the capability of the DC system to support the TDAFW system during a DBE or SBO. The inspectors walked down the DC system to verify that the installed conditions and equipment lineups matched the conditions and assumptions as described in the design documentation. The inspectors also reviewed and discussed DC modifications to verify that the licensee adequately maintained the DC system design and licensing bases.
Testing. The team reviewed selected periodic test records, including inservice tests (ISTs), post maintenance tests, and calibration tests. The inspectors assessed the tests adequacy by comparing the test methodology to the scope of the required testing or the maintenance work performed. The inspectors compared the test acceptance criteria to system calculations, drawings, and procedures to verify the test demonstrated that the tested components satisfied the applicable design and licensing bases and TS requirements, and were capable of performing their intended safety functions. The inspectors reviewed the recorded test data to determine whether the acceptance criteria were satisfied. The inspectors also reviewed test results to ensure automatic initiations occurred within required times and tolerances, and that testing was consistent with design bases information. In addition, the inspectors directly observed portions of the quarterly TDAFW system surveillance (PT-16Q-T) on October 5, 2005, to independently verify adequacy of controls, indications and performance characteristics of the system.
The team verified that circuit breaker maintenance for vital components was adequately performed in accordance with vendor documents. Inspectors observed CCW pump motor breaker maintenance and verified that Amptector testing techniques were in accordance with vendor recommendations. The inspectors also interviewed personnel and reviewed documentation to assess the adequacy of surveillance testing to monitor the capabilities of the DC system.
b. Findings
Introduction.
The team identified a Green NCV regarding the licensees failure to assure that the station battery TS surveillance procedure results demonstrated that the station batteries were Operable.
Description.
In 1999, Ginna developed a new testing process that used new instrumentation to measure and record voltages for TS required battery testing. This setup included calibrated and non-calibrated components which feed into a computer that used a data acquisition program (LabView). In 1997, the LabView setup was evaluated and qualified through the Software Quality Assurance process for safety significant applications. The licensee performed a retest of the setup prior to the 1999 battery testing. The inspectors reviewed the 2000, 2003, and 2005 battery tests for both the A and B station batteries to evaluate the surveillance results.
In 2000 and 2003, the licensee performed the testing on the station battery as required by the TS. The inspectors found that the data recorded by the test device and recorded in the test surveillance forms showed erratic voltage results for cell 56 for the A and B batteries. This data indicated significant cell degradation. The inspectors determined that Ginna personnel did not recognize the data as erratic or problematic. Specifically, Ginna personnel made no mention of the erratic data in the test documentation, they did not initiate a corrective action report, and they did not evaluate the erratic data.
Additionally, the 2003 test results were used to determine overall battery voltage. This result was used by the licensee as the basis for satisfactory completion of the surveillance and Operability of the Batteries.
In 2005, during the surveillance, the B battery exhibited erratic results for cell 16, but had acceptable readings from cell 56. The A battery testing results indicated that 23 of the 60 cells produced erratic data. Ginna technicians noticed the erratic data and decided to continue the test using alternate means to measure the obvious erratic cells.
However, they did not confirm that the data for the remaining cells was accurate. In response to the teams questions, Ginna was able to show the inspectors, using subsequent testing data, that the battery cells were Operable and entered the issue into their CAP.
Analysis.
The inspectors determined that Ginnas failure to set proper acceptance criteria and evaluate erratic testing data for TS surveillances, over a five-year period, constituted a performance deficiency. Traditional Enforcement does not apply because there were no actual safety consequences, impacts on the NRCs ability to perform its regulatory function, or willful aspects to the violation. This finding was more than minor because, if left uncorrected, this finding would result in a more significant safety concern because the licensee test equipment provided data that could not be used to detect a degraded battery cell and the finding affects the Mitigating Systems cornerstone objective of ensuring availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences as it relates to the procedure quality attribute. This finding was evaluated using phase 1 of the SDP and was determined to be of very low safety significance (Green) because it did not result in a loss of function per existing operability determination guidance (NRC Inspection Manual Part 9900 Technical Guidance, dated 9/26/05). The inspectors found that this finding was related to the cross-cutting element of PI&R because Ginna did not identify the erratic indications in 2000 and did not document or resolve them when they recurred in 2003 and 2005.
Enforcement.
10 CFR 50 Appendix B, Criterion XI, Test Control, states, in part, that testing required to demonstrate that SSC will perform satisfactorily are performed with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents and that test results be evaluated to assure that the test requirements have been satisfied. Contrary to the above, invalid test results from the station battery test were used to confirm operability of this SSC from 2000 to 2005. Because this finding is of very low safety significance and has been entered into Ginnas CAP (CR 2005-5383), this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy:
NCV 05000244/2005006-01, Inadequate Battery Test Procedure Resulted in Use of Inaccurate Test Instrumentation.
4. System Components
a. Inspection Scope
The inspectors selected several risk significant components in the CCW and TDAFW systems to ensure equipment at the component level met design requirements. The components selected for detailed review included:
C TDAFW pump C
CCW pumps "A" and "B" C
Main feedwater check valves V-3992 and V-3993 C
Main steam supply check valves to TDAFW CV-3504B and CV-3505B C
CCW heat exchangers "A" and "B" C
CSTs "A" and "B" C
TDAFW pump discharge flow control valves AOV-4297 and AOV-4298 C
Alternate SW return lines from CCW heat exchangers
- TDAFW turbine governor (Woodward PGD type with differential servomotor)
- SG narrow range level instrument inputs to AFW initiation logic The inspectors inspected the following attributes of the CCW and TDAFW components:
Component Degradation, Environmental Qualification, Equipment Protection, Input/Output, and Operating Experience (OE). The inspectors verified the above attributes met the requirements and design basis specifications identified in the UFSAR, TSs, licensee commitments, design basis documents, vendor technical manuals, calculations and plant drawings. A complete list of documents reviewed is included in the attachment to this report. The attributes that were verified to meet system requirements are described below:
Component Degradation. The team reviewed Ginnas maintenance, operations, and engineering procedures to determine how potential age related degradation of selected components were monitored and identified. The team assessed the licensees criteria for component and/or component material replacements to verify whether corrective actions were scheduled and performed prior to exceeding a component's qualified service life. Additionally, the team verified whether deficiencies which could potentially reduce the life expectancy of the components; such as flow induced vibrations, fouling due to silt, and microbiological corrosion in heat exchangers; were appropriately identified, evaluated, and corrected.
Environmental Qualification. The team assessed whether the CCW and TDAFW components were qualified to operate under normal and design basis accident environmental conditions. The team reviewed design information, vendor specifications, and industry OE; to identify temperatures, pressures, humidity, and radiation levels that the components were exposed to while installed in the system. The inspectors compared the results to evaluate whether the components were qualified to operate within their expected environments.
Protection. The team assessed the CCW and TDAFW system components to determine whether they were adequately protected from external events, natural phenomenon (including cold weather), and other hazards; such as high energy line breaks, fire, floods, or missiles. The team reviewed design information, vendor specifications, and industry OE to assess whether the system components were adequately protected from those hazards. The inspectors also reviewed the basis for no hydrogen detection in the battery rooms and the acceptability of the bounding conditions.
Input/Output. The team reviewed selected TDAFW and CCW system component inputs and outputs (e.g., water flow, electrical voltage, and control air pressure) to determine whether they were appropriate for the selected component during normal and accident conditions. The team reviewed design information, specifications, and documentation to ensure that system components were adequately protected from those hazards identified in the UFSAR that could impact their ability to perform their safety function.
The team also verified that safety and non-safety related signals, where applicable, were properly identified and adequately separated.
Operating Experience. The team reviewed the licensees assessment of extent-of-condition for Ginna issues and applicable industry OE to verify whether insights from issues in similar systems had been appropriately evaluated for the CCW and TDAFW systems. The inspectors also reviewed the Ginna Licensee Event Reports (LERs) since 1999 for insights into potential issues or recurrent problems associated with the TDAFW and CCW systems.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
5. Systems Sample Review
a. Inspection Scope
The team reviewed a sample of CCW and TDAFW system issues that were identified by the licensee. The team also reviewed the operator work-around log, active operability determinations, Maintenance Rule (a)(1) systems, TDAFW and CCW system health reports, and selected condition reports (CRs). The team assessed the licensees problem identification thresholds, and evaluated the effectiveness of the licensees prioritization and corrective actions, related to design or qualification issues for the CCW and TDAFW systems. In addition, CRs written on NRC identified issues during the inspection were reviewed to verify whether there was adequate problem identification in the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the attachment to this report.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
The NRC presented the inspection results on October 7, 2005, to Mr. D. Holm and other members of Ginnas staff. The inspection team verified that this inspection report does not contain proprietary information.
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- P. Bamford, Acting Director - Reliability Engineering
- M. Bauman, Electrical Engineer
- A. Butcavage, Engineer
- D. Dean, Shift Manager
- T. Fouts, Shift Foreman
- M. Gallaway, Maintenance Manager
- D. Garofoli, Performance Testing Supervisor
- J. Guider, Instrumentation Engineer
- T. Harding, Senior Licensing Engineer
- D. Holm, Plant Manager
- J. Jackson, Electrical Engineer
- G. Joss, Inservice Test Program Engineer
- J. Jones, Instrumentation & Controls Engineer
- S. Kimbrough, Risk Assessment Engineer
- M. Milly, Director - Balance of Plant Engineering
- J. Pacher, Primary Systems and Reactor Engineering Manager
- R. Schmidt, Performance Testing Technician
- P. Swift, Electrical Systems Director
- R. Whalen, Manager Nuclear Engineering Services
- G. Wrobel, Nuclear Safety and Licensing Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000244/2005006-01 NCV Inadequate Battery Test Procedure Resulted in Use of Inaccurate Test Instrumentation. (Section 1R21.3)