ML17250B025

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Notice of Violation from Insp on 890626-30 & 0717-0824. Violation Noted:Station Procedures Not Established to Reflect Mods for Two Mods Accomplished During 1989 Annual Refueling Outage.Summary of Enforcement Conference Encl
ML17250B025
Person / Time
Site: Ginna 
Issue date: 10/18/1989
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17250B024 List:
References
50-244-89-18, NUDOCS 8910270044
Download: ML17250B025 (39)


Text

ENCLOSURE 1

NOTICE OF VIOLATION Rochester Gas and Electric Corporation Docket No. 50-244 R.

E. Ginna Nuclear Power Plant License No.

DRP-18 During the inspection conducted on June 26-30 and July 17 - August 24, 1989 and in accor'dance with the "General Statement of Policy and Procedure for NRC En-forcement Actions,"

10 CFR Part 2, Appendix C (Enforcement Policy), the fol-

'owing violations were identified:

A.

10 CFR 50Appendix B, Criterion III, and the Ginna Quality Assurance Manual, Section 3, require that measures be established to control design changes and that procedures or documents be prepared or revised to reflect modifications.

Contrary to the above, for two modifications accomplished during the 1989 annual refueling outage, station procedures were not established to re-flect modifications in the following cases.

1.

Safety Injection System valve line-up procedures were not modified to require that the system recirculation valves be throttled to 80/o shut in accordance with a recirculation flow modification change developed during post-modification testing.

2.

The procedure for operation of ATWS (Anticipated Transient Without Scram) Mitigation System Actuation Circuity (AMSAC) did not include appropriate reset requirements and resulted in a plant trip when the AMSAC system was placed in service during post-outage plant opera-tion.

This is a Severity Level IV violation (Supplement I).

B.

Technical Specification 6.8. 1 requires that written procedures for sur-veillance'and test of safety-related equipment be established, imple-

mented, and maintained.

Contrary to the above, on May 18, 1989, during the Plant Safeguard Logic

Test, the test procedure was not implemented, in that the bistables were placed in trip (a condition not stated nor authorized by the procedures),

and an unanticipated safety injection signal resulted'his is a Severity Level V violation (Supplement I).

Enclosure 1

C.

10 CFR 50, Appendix B, Criterion XVI and the Ginna Quality Assurance Manual, Section 16, require prompt correction of conditions adverse to quality.-

Contrary to the above, corrective actions for failing to perform weekly rodding of boric acid tank level bubbler tubes on October 21, 1988 were inadequate to prevent recurrence on June 1,

1989..

This is a Severity Level V violation (Supplement I).

D.

. Technical Specification

3. 1.5. 1. 1 requires, with reactor coolant system temperature greater than 350 degrees Fahrenheit, one system sensitive to radioactivity, shall be in operation.

Contrary to the above, on June 16,

1989, the reactor coolant system tem-perature was greater than 350 degrees Fahrenheit, no listed leak detection system sensitive to radioactivity was in operation, and the compensatory action of drawing and analyzing a grab sample of the containment atmos-phere at least every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was not accomplished.

This is a Severity Level IV violation (Supplement I).

Pursuant to 10 CFR 2.201, Rochester Gas and Electric Corporation is required to submit to this office, within thirty days of the date of the letter which transmitted this Notice, a written reply including: (1) the reason(s) for the violation if admitted, (2) the corrective steps which have been taken and the results

achieved, (3) the corrective steps which will be taken to avoid further violations; and (4) the date when full compliance will be achieved.

Where good cause is shown, consideration will be given to extending this response time.

The reply directed above is not subject to clearance by the Office of Management and Budget under the Paperwork Reduction Act of 1980, PL 96-511.

ENCLOSURE 2 ENFORCEMENT CONFERENCE MEETING

SUMMARY

I.

Introduction On October 3,

1989, an enforcement conference was held -in the Region I office in.King of Prussia, Pennsylvania to discuss problems related to the 1989 refueling outage an subsequent operations.

The most significant issue was the adequacy of controls over modifications.

II.

Meetin Attendees NRC J.

Dyer, Region I Coordinator, Office of the Executive Director for Operations D. Holody, Enforcement Officer,.Region' A. Johnson, Project Manager, Office of Nuclear Reactor Regulation J.
Johnson, Chief, Proj'ects Branch No. 3, Division of Reactor Projects (DRP),

Region I

W.

Kane, Director,

DRP, Region I E.

McCabe, Chief, Reactor Projects Section 3B,

DRP, Region I

'. Perry, NRC Acting Senior Resident Inspector, R.

ED Ginna Nuclear Station Rochester Gas and Electric RGEE R. Baker, Electrical Engineer.

T. Harding, Modification Support Coordinator J.

Hauber, Manager, Substation Engineering-R. Mecredy, General
Manager, Nuclear Production R. Smith, Senior Vice President J.

Widay, Superintendent, Ginna Production P. Wilkins, Director, Nuclear Engineering Services III. Meetin Presentation and Discussion After the introduction of personnel and opening remarks by the

NRC, Rochester Gas and Electric responded to NRC Special Inspection Report No. 50-244/89-18.

The potential enforcement items tabulated in Enclo-sure 2 of 89-18 were specifically addressed.

For each

issue, the licensee addressed the root cause and the corrective actions taken or planned:

Additionally, the licensee summarized the general management concerns and safety significance of the problems.

During the licensee's presentation, NRC personnel asked questions to clarify the licensee's positions on specific issues.

A copy of the licensee's handouts for the meeting is enclosed as Attachment 1.

Enclosure 2

IV.

Conclusions RG&E was responsive to the safety concerns expressed by. the NRC.

The NRC concluded that the licensee provided sufficient information to evaluate the potential enforcement items in accordance with enforcement guidance and regulatory requirements.

No Notices of Violation were recommended for the -intermediate range detector high level trip setpoints being incor-rectly set or for the late waste gas decay tank release.

These two items had minimal safety/environmental significance, and corrective actions were acceptable.

Additionally, no Notice of Violation was deemed appropriate for the control over work on electrical power distribution equipment.

-The proposed additional controls over work on this equipment were assessed as acceptable.

V.

Attachments The licensee's handout at the enforcement conference is attached to this summary as noted in the discussion in Section III'

Agenda

'RG&E/NRC Meeting October 3, 1989 Special Inspection 89-18 ENCLOSURE 2

ATTACHMENT 1 I

Introduction II Modification Controls R. Smith P. Wilkens/T. Harding/R. Baker III Electric Power System Maintenance IV Safeguards Logic Test V

Boric Acid Storage Tank Level VI RCS Leak Detection VII Conclusions J.

Hauber J.

Widay J.

Widay J.

Widay R. Mecredy

Overview of Modification Process Conceptual to Construction P.C. Wilkens Testing to Turnover T.L. Harding AMSAC Example R.A. Baker Improvements,to Process T.L. Harding

Overview of,Modification Process

.Control of Activities Use of LE, CE, RE Interfaces for Operation Input Modification Follow Group

ENGINEERING WORK REQUEST ROCHESTER GAS &, ELECTRIC CORPORATION EWR NQ. 4815 ORIGINATING DEPT.

NO, 4 9 Maintenance Dept.

JDB TITLE Gonna Pea)oemunce Eva(uat~on (30 CHARACTERS MAXIMUM)

Puu(

Gocokj 71-979 DEPARTMENT NAME SCOPE OF WORK:

STUDY X

DESIGN PROCUREMENT OTHER DESCRIPTION OF PROBLEM:

REPRESENTATIVE IN STAL LAT ION PROCEDURE REVIEW DRAWING REVISION PHONE R.E.

Gonna Station

~nub~t~tg to neach 1004

{',u(C pocvec opecat~on

~oriocv~ng 1988 ce(ue8.ng outuge..

RECOMMENDED ACTION:

Detecm~ne afoot cause 8 F, C P, I V 8 9 8 F,'P 9 1988 TARGET DATE:

APPROVED BY:

1989 outage.

Ac DUNT No To be peovi ded DEPART T SUPERINTENDENT ASSISTANT CHIEF ENGINEER ENGINEERING DEPT.

PRIORITY NO.

APPROVAL TO PROCEED:

8/C Vd>>>

8"=I)):

tK(2):

ORH EE(3):,

NE(4) l GUTASE)

FRIHS 90 CEl BN LEl FORECAST INSERVICE: 05/90 SCOPES INSTALL NNITORIHS INSTRU(KHTATION OH RHR RPP AHD NTN, PPCS READOUT A)(D TRENDING.

NO.

HILESTM EST/ACT ACT 4

5 6

7 8

9.

10ll 13 14 15 16 17 18 20 21 22 23 24 26 27 28 29 30 CC)KEPTUAL OESISH USER REVIE(( " CGXEP DESIB(

DEESIBN CRIT.- FREP.h APPROVE SAFETY M.YS.

FM'.h APPROVE U ER CQ".BiTS PRE FEC APPRV

'USER APPROVAL(PNC APPROVAL)

E+.h PROC FE(1ST iK ()F HCH)

ENSIHEERED FRX(RE}(EHTS B(S iMnICES PURCHASE KDS BID PACKAGE CGNSTRXTIGN CQTKMTS PLANT C(8%?(IS CONST.

COST EST.

SUBMITTAL CONST.

P.E. (1ST N GF NMH)

CeaIRXTIGH WeV, ORDER FRELIHINARY CONST.

SO%9K c DRAFT 49K PRXEOSK DRAFT SH PROCE(QK DES ISN VERIFY/IHTSRTD ASS'HT CONSTRUCTION PNXASE PREM TEST SFEC IFICATIK INTESRATED P/2 NEI)(QK S.H.

PROCEDURES CRITICAL'TERIALS OH SITE CONSTRUCTION START CONSTRXTIGN CON'LETE PREM.

TESTINS GKLEIE I~ICE JOB CLOSE OUT 07+2-89

+

27-SEP-89 a

27-ScP-89

+

04;GCT-89 +

IHCT-89 +

(8W-89 +

02-GCT-89 +

3HKT-89 +

2HCT-89 w

31-OEC-89 +

26-JAN-90 a 26-JAN-90 a 26-JAH-90 a 02-FEDOS

+

28-FEB-90 a

Z~ )pf 05-JAH-90 a 05-JAH-90 +

12-FEB-90 +

15-FEB-90 a 26-JR' 01-%-90 +

pi-HAR-90 +

Ib-tQR-90 a 30-HAR-90 a 25-APR-90 +

~Y-90 a 02-NY-90 +

07-JUR) 1 re le 3

re 4

re 5

le 6

le 7

re 8

re 9

re 10 re 11 ce 12, le 13 ce 14 re 15 re lb ce 17

'ce 18 le 20 re 21 re 22 re 23 ce 24 le 25 re 26 ce 27 ce 28 le 29 le 30 re LAST UPDATED'9~M BY: RGBERTA %LAHAH REHARKSl a denotes change since last run date

September 7,

1989

SUBJECT:

Conceptual Design -

EWR 4892 "Midloop Instr.

Enhancements" TO 0 Tom Harding Back round Problem Descri tion:

Decay heat removal design weaknesses have been identified as a result of plant incidents during reduced RCS inventory.

In the Diablo Canyon event in April of 1987, both trains of decay heat removal were lost when the,RCS was drained.

EWR 4892 is a modification to meet requirements in NRC Generic Letter 88-17 "Loss of Decay Heat Removal".

GL 88-17 requires that Ginna Station have "the capability of continuously monitoring DHR system performance whenever a

DHR system is being used for cooling the RCS".

At this t~,

monitoring of the Ginna RHR system consists of local temperature and pressure indications on each train, and control board indications of total RHR flow and "A" heat exchanger inlet temperature.

Conce tual Desi This modification will install new instrumen-tation to monitor RHR system performance on the Plant Process Computer Syste3e (PPCS).

Such monitoring meets NRC commitments regarding "midloop operation" - normal cooldown with reduced RCS inventory.

To improve monitoring during midloop operation, the following new instruments will be installed in each RHR train:

1.

Suction Pressure Transmitter 2.

Suction Temperature Transmitter 3.

Discharge Flow Element 4.

Discharge Plow Transmitter 5.

Motor Lead Current Transformer These four parameters (pressure, temperature, flow and motor current) will input to the PPCS for calculation of NPSH display and trending.

The Mechanical Engineering Group will provide the necessary calculation to the Computer Group.

New instrumentation vill not add any new control functions or new modes of operation.

Electrical Sin le Line Dia ram:

See lower portion of attached Diagrams A and B..

Mechanical P t' Dia ram:

See upper portion of attached diagrams A and B

ROCHESTER GAS AHO ELECTRlC CORtORATlOH ENG.

OEPT.

STAT le:

QIMMA zoe:

EWR 4892'IDLOOP INSTR.

ENHANCEMENTS COHcEp Toad R R ~ '3$

OATE'/7 /89

~

tACE +

OFf HAOE IV: RXL PPGS PT PT (Hag)

(H78 Hea'~

Exchange NBN

)

RHR Pump NB N EE

(~a,e)

Loop K'otleg (W4)

PPc,s PPcc FT (NEu)

~---PPce Heat Exch.

NAN Loop 8, Coldleg PT PL (Ngg)

L---- PPC5

)

RHR Pump NAN FK (KeW FT'NEW)

<-- PP C5 480V Bus 16 480V Bus 14 CT'eau)

F'PCS CT (M~V)

-- Ppt'.5 200 RHR Pump NB" 200 RHR Pump NAN pRoPO5ED RHR EQUIPMENT

Znte~ffice Correspondence Gfnna Statf on September 15, 1989 Sub)ect:

EVR - 4892 Mid Loop Instrumentation Enhancements To:

Modification Follow Group Members Modificati on Follow'roup has been formed to support the acti vities associated vith ERR - 4892.

The folloving personnel have been assigned to this group:

Lead Liaison Engineer Operations R

6 T Training Health Physics C

QuaEfty Control The prime purpose of the modification follov group is to reaain cognizant of all design and installation work.

A general list of modification follow group responsibilities is attached along vith a copy of the conceptual design.

Please reviev thfs information at your earliest convenience.

This modification involves the installation of the folloving new instruments in each RBR train:

1)

Suctf on pressure Transmi tter 2).

Suctfon Temperature Transmitter 3)

Discharge Flov Element 4)

Discharge Flow Transmitter 5)

Motor Load Current Transformer The modificatf on follow group res ponsi bilities vill be closely coordinated vith the folloving people:

Responsible Engfneer Construction Engineer The account number to be used for this modification is:

0-00-1-322-0 0-8 9-9-753 8 13NZ-RR-T50796

OUTLINE OF RESPONSIBILITIES EWR 4892 Lead Liaison En i eer and Back-u Liaison En ineer

/

Coordinate Modification Follow Group efforts.

Coordinate writing of SM,procedures.

Follow the construction sequence as performed by Plant or Project personnel on a daily basis.

Review overall design and constructi on for plant safety and reliability.

Review and coordinate processing of the Design Criteria and Safety Analysis.

Coordinate information exchange between Modification Follow Group members.

Direct pre-op, start-up, and operational testing of completed modification.

Ensure that all procedure and drawing changes are completed as required prior to PORC turnover.

Review Design Criteria and Safety Analysis.

Review the SM procedure for operati onal and impact on other systems.

Identify and assist the Operations section in writing'ew line-up and operating procedures (T,

O, etc.).

Identify minimum Operator training needed.

k Change valve index.

Write the holding and tie-in sections of the SM procedure.

Assist in writing SM procedures if required.

Review plant procedures for possible changes.

Review design outputs for testability, including IST program.

Provide input and review SM installation and test procedures.

Provide installation or testing assistance as needed.

Perform hydrostatic test.

Perform fire system functional test.

OUTLINE OF RESPONSIBILITIES PAGE 2

~Ta'~

Review Design Criteria and installation requirements.

Develop training plan.

Train individual groups, as

needed, prior to and foll,owing turnover to Ginna Station.

Health Ph sics Review SM procedure for Health Physics concerns.

Identify the need for training of H. P. personnel.

I & C Review design for preventive and corrective maintenance.

Collect, review, and file information on instrumentation and controls for new instrumentation.

Identify and assist

-I&C Department in writing calibration procedures for new instrumentation.

Review terminati ons performed by I&C shop deemed necessary by SM procedure.

Identify the need for spare parts.

uali t Control Review SM procedure for Quality Control concerns.

Res onsible En eer Review overall design with Modification Follow Group.

Supply information (manual s, specifications, etc. )

from vendors to the Modification Follow Group (through the Liaison Engi neer).

Coordinate between vendors and Ginna Station training, spare

parts, etc.

needed for proper operation of the system.

Constructi o En eer Supply informati on Modification Follow Provide approximate Follow Group.

on construction activities to the Group.

construction dates to the Modification 13N1-RR-T500796

MODIFICATION TESTING 1)

TURNOVER FROM THE MODIFICATION PROJECT TO STARTUP TESTING IS BASED ON THE FOLLOWING:

A)

THE WORK PROCEDURES ARE SIGNED OFF TO DOCUMENT COMPLETION OF WORK.

B)

A FIELD WALKDOWN HAS BEEN COMPLETED BY THE CONSTRUCTION ENGINEER AND QUALITY CONTROL.

C)

A PUNCHLIST (A PART OF THE MODIFICATION PROCEDURE)

ZS PREPARED OF THE OPEN FCRs,

NCRs, AND MINOR INSTALLATION ITEMS.

D)

A REV1EW OF THE MODIFICATION STATUS ZS PERFORMED BY THE LIAISON ENGINEER AND LEAD TEST SUPERVISOR.

2)

TESTING IS PERFORMED USING PORC APPROVED PROCEDURES, WHICH HAVE BEEN COORDINATED BY THE LEAD TEST SUPERVISOR WITH INPUT FROM THE MOD1FZCATION FOLLOW GROUP.

3)

TESTING ZS PERFORMED BY A TEST GROUP SUPERVISED BY THE LEAD TEST SUPERVISOR AND CONSISTING OF INDIVIDUALSFROM OPERATIONSl INSTRUMENT AND CONTROLi RESULTS AND TESTi ELECTRICIANS'IPE FITTERSl HEALTH PHYSICS'IRE AND SAFETYi OR MECHANICS AS REQUIRED BY THE SPECIFIC TESTING.

4)

TESTING IS PERFORMED FOLLOWING THE REVIEW AND APPROVAL OF THE SHIFT SUPERVISOR AND OPERATZNG STAFF.

5)

THE RESPONSIBLE ENGINEER AND THE CONSTRUCTION ENGINEER ARE INVOLVED WITH ANY PROBLEMS ARISING DURING TESTZNGi AND WITH REVIEWING THE TEST RESULTS.

6)

THE QUALITY ASSURANCE GROUP PERFORMS AN AUDIT OF MODIFICATION TESTING ACTIVITIES DURING THE-ANNUAL REFUELING OUTAGE.

MODIFICATION TURNOVE 1)

THE LIAISON ENGINEER DETERMINES ZF THE CONFIGURATION CONTROL DRAWINGS HAVE BEEN UPDATED'ND IF NOT ISSUES

'INTERIM AS BUILT DRAWINGS.

2)

A REVIEW OF THE STATUS OF ITEMS ON THE MODIFICATIONMANAGEMENT FORM ZS PERFORMED BY THE LIAISON ENGINEER.

3)

TURNOVER FROM THE MODIFICATION PROJECT OR STARTUP TESTING TO THE PLANT MANAGEMENT SHALL BE BASED ON THE FOLLOWING:

A)

ALL TESTING (IF REQUIRED BY MODIFICATION) ZS COMPLETED, AND TEST RESULTS EVALUATED.

B)

C)

UNREVIEWED SAFETY QUESTIONS OR TECHNICAL SPECIFICATION CHANGES'F ANY'AVE BEEN RESOLVED'HE, PUNCHLIST ZS EVALUATED BY PORC TO DETERMINE WHETHER ANY ITEM WOULD PRECLUDE SAFE OPERATIONS D)

THE STATUS OF THE FOLLOWING ITEMS.(AS LISTED ON THE MODIFICATIONMANAGEMENT FORM) SHALL BE EVALUATEDBY PORC:

NEW OR REVISED PROCEDURES INTERIM CONFIGURATION DRAWINGS TRAINING OF PLANT PERSONNEL MAINTENANCE AND TEST PROGRAMS S PARE PARTS E)

PORC SHALL RECOMMEND TURNOVERi BASED ON THIS EVALUATIONi TO THE PLANT MANAGER.

4)

FOLLOWING TURNOVER OF A MODIFICATION, A NOTIFICATION ZS MADE TO PLANT AND CORPORATE PERSONNEL.

5)

THE QUALITY ASSURANCE GROUP PERFORMS AN AUDIT OF MODIFICATION TURNOVER AND MODIFICATZON FOLLOW GROUP ACTIVITIES PRIOR TO/AND DURING THE ANNUAL REFUELING OUTAGE.

MODIFICATION MANAGEMENT FORM 1.

EWR

Title:

Responsible Engineer Construction Engineer Liasion Engineer 1

C Modification Follow Group Members:

2.

PROCEDURE CHANGES a.

New Procedures Pro osed Sco e

Assi ned To Suggested Com letion Date Tracking Date Com leted

b. Existing Procedures Procedure Number Assi ned To Suggested Com letion Date Tracking/

Date Com leted

3

~

SCHEDULE CHANGES Activit Proposed F e enc Suggested Tracking/

Date Com leted ISI Surveillance Maintenance Testing Calibration Inspection 4.

DRAWING CHANGES Controlled Drawin T

e Suggested Com letion Date Tracking/

Date Com leted 5.

VENDOR MANUALS Pro osed Sco e

Assi ned To Trackin Vendor Manual Coordinator (VMC)

Separately Tracked by VMC 6.

TRAINING Pro osed Sco e

Assi ned To Tracking/Date

~

Com leted Operators-Preoperational Training-L. Hubbard Operators-Detailed Others (I&C, R&T, HP, etc.)

Training-L. Hubbard

7.

OTHER ACTIVITIES Activit Assi ned To.

Suggested Com letion Date Tracking/

Date Com leted Locked Valves Valve Index Component Labeling Valve Labeling NPRDS Update EEQ File Update UFSAR Update Spare Parts Transferred Spare Parts Updated Snubber List Update Spring Hanger List Update Equipment Data Sheets Completed:

Liaison Engineer, EWE Date:

Reviewed:

Modification Support Coordinator Date:

'PROGRAMMATIC CHANGES 1)

ENSURE ALL OPERATIONAL INFORMATION IS ISSUED THROUGH CONSTRUCTION TO ASSURE THAT ALL INFORMATION IS FORMALLY PROCESSED THROUGH THE DOCUMENT CONTROL PROCESS.

2)

REVIEW ALL SYSTEM COMPONENTS TO'E USED DURING TESTING.

3)

THE LIAISON ENGINEER SHALL REVIEW AND FORWARD ALLMODIFICATION DESIGN CHANGES THAT MAY AFFECT OPERABILITY OR MAINTAINABILITY TO THE MODIFICATION FOLLOW GROUP MEMBERS.

4)

PROCEDURE CHANGES AND NEW PROCEDURES MAY ONLY BE PRODUCED BASED ON CONTROLLED DESIGN INPUTS AND DOCUMENTS ISSUED FOR CONSTRUCTION.

A REVIEW HAS BEEN COMPLETED OF ALL MODIFICATION EFFECTED PROCEDURES FOR THE 1989 OUTAGE.

5)

MODIFICATIONTRAINING PACKAGES MAY ONLY BE BASED ON CONTROLLED DESIGN INPUTS OR DOCUMENTS ISSUED FOR CONSTRUCTIONS ZN ADDITION THE TRAINING GROUP MAY REQUEST THE RESPONSIBLE ENGINEER TO REVIEW THE TRAINING PACKAGE.

A REVIEW HAS BEEN COMPLETED OF ALL MODIFICATION TRAINING FOR THE 1989 OUTAGE.

6)

THE MODIFICATION FOLLOW GROUP SHALL PERFORM A FINAL REVIEW OF THE COMPLETED MODIFICATION PACKAGE PRIOR TO PORC TURNOVER TO VERIFY THAT ANY ZN-PROCESS DESIGN CHANGES OCCURRING DURING MODIFICATION INSTALLATION AND TESTING HAVE BEEN FULLY REFLECTED IN PLANT PROCEDURESi TRAININGi AND PROGRAMS')

OPERATIONS MANAGEMENT SHALL VERIFY THAT THEY ARE READY TO ACCEPT THE MODIFICATION PRIOR TO PORC TURNOVER.

8)

THE LIAISON ENGINEER SHALL REVIEW ALL REQUIRED PROCEDURE CHANGES'EW PROCEDURES'ND OPERATOR TRAINING RESULTING FROM A MODIFICATIONS TO VERIFY THAT THEY ARE CONSISTENT WITH DESIGN INTENT, PRIOR TO PORC TURNOVER.

THE ENGINEERING AND STATION. ADMINISTRATIVE CONTROL PROCEDURE CHANGES WILL BE IN PLACE AS OF NOVEMBER lg 1989.

ANY MODIFICATIONS PRESENTED TO PORC FOR TURNOVER PRIOR TO NOVEMBER 1,

1989 SHALL HAVE STEPS INSERTED INTO THE MODIFICATION PROCEDURES TO DOCUMENT THE REVIEWS BY THE MODIFICATION FOLLOW GROUPS THE LIAISON ENGINEERS AND BY THE OPERATIONS DEPARTMENT.

AMSAC MODIFICATION PROCESS GINNA STATION JULY 1986 RG&E COMMITTED TO INSTALL AMSAC SYSTEM IN ACCORDANCE WITH 10CFR50.62 AT GINNA STATION DURING 1989 OUTAGE AUGUST 1987

RG&E SUBMITTALS TO NRC COMMITTED TO PROVIDE AND APRIL 1988 SPECIFIC AMSAC FEATURES AT GINNA STATION APRIL 1988 AMSAC DESIGN CRITERIA AND SAFETY ANALYSIS COMPLETED MAY 1988 AMSAC MOD FOLLOW GROUP FORMED AMSAC CONTRACT AWARDED TO FOXBORO FIRST AMSAC MOD FOLLOW GROUP MEETXNG 16 PAGE HANDOUT MAY 1988 THRU FEB 1989 AMSAC MOD FOLLOW GROUP MEETINGS AT LEAST ONCE A MONTH JULY 1988 FINALIZED LOCATION OF MANUAL BYPASS SWITCH IN AMSAC. LOGIC DEC 1988 ONE WEEK TRAINING ON GINNA AMSAC AND FOZBORO SPEC 200 MICRO FOR TEN I&C TECHNICIANS FEB 1989 AMSAC FACTORY ACCEPTANCE TEST AT FOXBORO-EI GHT RG &E REPRESENTATIVES WITNESSED FUNCTIONAL TESTING OF GINNA AMSAC APRIL 1989 AMSAC TRAINING FOR OPERATIONS PERSONNEL APRIL/MAY 1989

AMSAC INSTALLATIONAT GINNA STATION END MAY 1989

AMSAC PRE-OPERATIONAL TESTING COMPLETE JUNE 1, 1989 PLANT ASCENDING IN POWER WITH AMSAC IN "BLOCK" -AMSAC BYPASS SWITCH PLACED TO "ARM" AT APPROX.

40-TURBINE LOAD AMSAC HAD NOT BEEN RESET FOLLOWXNG COMPLETION OF PRE-OP TESTING AMSAC ACTUATED RESULTING,IN TURBINE TRIP.,

AFW START, AND REACTOR TRIP

SUMMARY

OF EVENT 89-82 o

Upon closing the generator breaker on 5/30/89 to bring the generator on line, the breaker immediately tripped o

Relay targets recorded on secondary pipe cable differential o

Cause traced to open CT inputs o

Open inputs located on a sliding link terminal deck in a junction box mounted on the GSU o

Prior to

event, ESD Maintenance Crew was working on this equipment o

Work consisted of cleaning all connections on the decks in the junction box o

Maintenance Crew was instructed to remove wires and position links in order to clean, one at a time, then return to original position o

While Maintenance Crew did not specifically recall leaving links

open, most probable cause was this activity

H29iQ

~

~

~ ~

,r j

ELECTRICIAN UALIFICATION o

Formal training program for progression from Helper to First Class Electrician o

Classroom Training Safety Rules and Practices Use and Care of Handtools Low Voltage Testing Fundamentals of Electricity Electrical Diagrams Mark Up Training Operator Training Maintenance Manual o Detailed maintenance and test procedures for each type of high voltage equipment o

Field Training Personal Protective Equipment Portable and stationary electric tools Solvents Soldering Perform proper maintenance practices for each type of high voltage equipment o

Each step in progression signed off by classroom Instructor or Foreman o

Typical duration to reach first class ~ 6 years

GSU MAINTENANCE PROGRAM o

Scheduled Routine Maintenance Test Interval Gas Space Test Oil Test Complete Diagnostic Inspection 6 mo.

6 mo.

1 yr.

Power Factor Ratio Test Inspect and Test Auxiliaries (Cooling Equipment,

Gauges, Alarms, etc.)

o Maintenance Prompted by Periodic Inspections Ginna Electricians inspect GSU weekly ESD Electricians inspect at 6 mo. intervals ESD Maintenance Engineer inspects in preparation for annual shutdown work o All maintenance activities coordinated by ESD Maintenance Engineer

GSU MAINTENANCE PROCEDURES o

ESD Maintenance Engineer prepares draft work outline Reviewed By:

ESD Manager Engineering ESD Manager Administrative Services ESD Manager Field Services ESD Coordinator Field Forces o

Revised Work Outline Issued to:

ESD Manager Administrative Services ESD Manager Field Services ESD Coordinator Field Forces ESD Field Person In Charge o

ESD Maintenance Engineer informs ESD shutdown coordinator of activities and durations ESD Shutdown Coordinator develops schedule for all T&D Division activities and submits to Ginna Shutdown Planners o

ESD Maintenance Engineer conducts pre-job meeting with ESD field personnel involved Step by step walk through of work outline

GSU MAINTENANCE PROCEDURES CONT.

o On site, prior to starting work ESD Field Person In Charge notifies Ginna Electrician. Foreman of activities Ginna Electrician Foreman informs Plant Shift Supervisor who authorizes work to begin o

During performance of

work, ESD Maintenance Engineer makes periodic inspections and is on-call should his assistance be required o

ESD Maintenance Engineer reviews all test reports prior to re-energization o

Upon completion of work, ESD Field Person In Charge notifies Ginna Electrician Foreman Ginna Electrician Foreman informs Plant Shift Supervisor

CORRECTIVE ACTIONS o

OBJECTIVE Pr'ovide more stringent controls on sliding link terminals associated with plant and offsite'ower systems ACTION When sliding link terminals are operated in the performance of maintenance on the power transformers at Ginna, all equipment at Station

13A,

/

or the Circuit 751 position at Station 204:

The ESD Field Person In Charge shall record the as found and as left position of each link which was operated on the Maintenance Inspection and Test Report.

The Maintenance Inspection and Test Report shall be returned to the ESD Maintenance Engineer for review and file.

CONCLUSIONS

1. Work was performed by trained, experienced personnel.
2. Work was controlled via documented work plan.

3.

Work was authorized by Plant Shift Supervisor.

4.

An additional level of assurance is being provided for future

/

maintenance work.

Item 43 - Safeguards Logic Testing I. Background Information Technical specification requirements Procedural controls PT-32.1 ",Plant Safeguard Logic Test A or B Train" Test group responsibilities Logic 'actuation description ZZ.

Summary of Event Step 6.9.2 "Simulate pressurizer pressure to 2100 psig

( 30 ma) for P-429, P-430 and P-431" Procedural intent IZZ. Corrective Actions Taken or Planned to Prevent Recurrence Review of other applicable test procedures Revision of PT-32.1 Operational review of event

Item 44 - Boric Acid Level Sensing Lines I. Background. Information Technical specification requirements Pre'vious occurrence October 21, 1988 II. Summary of Event Licensee identified Contributing causes III. Corrective Actions Taken or Planned to Prevent Recurrence Additional independent checks instituted Long term actions

Item 45 Leakage Monitoring I. Background Information Technical specification requirements System description II. Summary of Event Licensee identified Calibration activities/Return to service III. Corrective Actions Taken or Planned to Prevent Recurrence Procedure revisions Operator awareness