ML17250B072
| ML17250B072 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/17/1989 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8911280454 | |
| Download: ML17250B072 (22) | |
Text
get./&RATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SSION NBR:8911280454 DOC.DATE: 89/ll/17 NOTARIZED: NO DOCKET IL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 UTH.NAME AUTHOR AFFILIATION MECREDY.,R.C.
Rochester Gas
& Electric Corp.
REC1P.NAME RECIPXENT AFFILIATION RUSSELL,W.T.
Region 1, Ofc of the Director
SUBJECT:
Responds to NRC 891018 ltr re violations noted in Insp Rept 50-244/89-18.Corrective actions:procedures revised.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
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ROCHESTER GAS AND ELECTRIC CORPORATION
~ 89 EAST AVENUE, ROCHESTER, N.Y. 146490001 TCLCP<ONL aaai cocr. 7ie 546 2700 November 17, 1989 Mr. William T. Russell Regi onal Administrator U. S. Nuclear Regulatory Commission Region 1'75 Allendale Road King of Prussia, PA 29406
Subject:
R.E.
Ginna Nuclear Power Plant Notice of Violation and Enforcement Conference (Speci al Inspection No. 50-244/89-28)
Dear Mr. Russell:
Your letter of October 18,
- 1989, from Mr. William F.
Kane transmitting Enclosure 1, Notice of Violation, identified four (4)
Violations A, B, C,
and D.
S ecial Ins ection Re ort 50-244 89-18 Enclosure 1
Notice of Violation A states in art:
A.
10 CFR 50, Appendix B, Criterion III, and the Ginna Quality Assurance
- Manual, Section 3,
require that measur es be established to control design changes and that procedures or documents be prepared or revised to reflect modifications.
Contrary to the
- above, for two modificati ons accompli shed during the 2989 annual refueling outage, station procedures were not established to reflect modifications in the following cases:
Safety Injection System valve Iine-up procedures were not modified to require that the system recirculation valves be throttled to 808 shut in accordance with a recirculation flow modification change developed during pos t-modifica ti on testi ng.
8911280454 891117 PDR ADDCK 05000244 G
PNU
Page 2
50-244/89-28 November 2.7, 1989 2.
The procedure for operation of ASS (Antici pated Transient Without Scram)
Mitigation System Actuation Circuity (AMSAC) did not include appropriate reset requirements and resul ted in a plant trip when the AMSAC system was placed in servi ce during post-outage plant operation.
Rochester Gas and Electric concurs that in the cases
- stated, the applicable procedures were not properly developed and/or revised.
These items were previ ously submit ted via LER 89-007 and LER 89-004 respectively.
Reason For The Violation 2.
A flow indication anomaly occurring during final system acceptance testing of the modified Safety Injecti on System recirculation line led to the new valves being throttled approximately 808 shut in order to achieve required flow to the reactor vessel under accident condi tions.
Prior to this point in the modi fication process all relevant existing plant procedures had been reviewed against the designed and installed modification configuration, and pertinent procedure changes were initiated.
The failure to make required changes to the Safety Injection System valve line-up procedures resulted from the modification change during startup testi ng, and was a resul t of not performing a
second review of all relevant procedures prior to the modifica-tion turnover to the plant by the cognizant plant personnel.
This second review should have been performed to verify that all the plant procedures did represent t'e system status at turnover.
During the ascension to power following the annual refueling outage the recently installed ALPS Mitigati.on System Actuati on Circui try (AMSAC) was maintained in the manual block mode to verify actual plant parameters.
Following a verification of Control Room indications for the AMSAC Systems as specified in Operating procedure 0-2.2, "Plant Startup From Hot Shutdown to Full Load",
the AMSAC System was placed in AUTO mode.
This resulted in an immediate turbine trip with reactor trip, due to an actual AMSAC trip signal from its output relays being blocked while in the manual block mode.
The remote from the Control Room AMSAC indications, which would have alerted the Operations personnel to the AMSAC system not being reset, were not discussed in the operating procedure.
This missing information was the result of changes to the existing procedures being made using a preliminary modification logic sketch that was later superceded.
Page 3
50-244/89-ZP November 17, 1.989 Corrective Ste s Which Have Been Taken The procedures associated with the two modificati ori s in question were reviewed at the time of the discovery of their inaccuracies and changes were immediately made to correct them.
Subsequent to those
- changes, following a safety inj'ecti on flow test with recalibrated flow transmitters, it was determined that the S. I. recirc valves were not requi red to be throttled.
The relevant procedures-associated wi.th the S.I.
modi fication were then corrected to list the full open position.
A review was also completed of all plant procedures affected by modifications installed during the 1989 outage to verify -that all changes to-those procedures were technically and operationally correct.
Additionally, all existing individual modification installa-tion and test procedures which have not been turned over to the plant have been revised to include addi tional review steps by cognizant plant modification groups and by the Operations Depart-ment prior to the modificati on being presented to the Plant Operations Review Committee for use.
These reviews include the activities associated with Items 4, 5, and 6 below.
Corrective Ste s Which Will Be Taken To Avoid Further Violations Administrative control procedures which govern the planning,
- review, install ati on, and turnover of modifications to the Station have been revised to include the following changes:
Requiring the review and forwarding of all modification design changes that may affect operabi lity or main-tai nabi lity to the cognizant Plant Modification Review Group.
2.
3 ~
4 ~
5.
Requiring that all procedure changes and new procedures resulting from a
modification be produced based on controlled design input and output documents.
Requiring that all modification training be based on controlled design input and output. documents.
Requiring that a Modification Review Group perform a
final review of the completed modification package following testing and prior to PORC turnover to verify tha t any in-process design changes occurring during modification installation and testing have been fully reflected in plant procedures',
- training, and programs.
P Requiring that Operations Department management verify that they are ready to accept the modification for use prior to PORC turnover.
Page 4
50-244/89-28 November 2'7, 2989 Corrective Ste s Which Will Be Taken To Avoid Further Violations (conti nued) 6.
Requiring that the cognizant Plant Modification Liaison Engineer review all required procedure
- changes, new procedures and operator training resulting from a
modificati on to verify that they are consistent with design inputs and design outputs and reflect design intent, prior to PORC turnover.
Date When Full Com liance Will Be Achieved Full compliance was achieved with the PORC review of revised administrative control procedures, A-302. 2 "Station Modification Planning Control" and A-301.3 "Station Modification Installation and Acceptance",
effective November 26, 2989.
S ecial Ins ection Re ort 50-244 89-28 Enclosure 2
Notice of'iolation' states in art:
B.
Technical Specification 6. 8. 2 requires that written procedures for surveillance and test of safety-related equipment be establi shed, implemented, and maintained.
Contrary.to the
- above, on May 28,
- 2989, 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.
Rochester Gas and Electri c concurs with the finding as
- stated, that an activity not authorized by a
procedure was performed.
This item was previously submitted via. LER 89-003.
Reason For The Violation The plant was in cold shutdown for refueling which required simulated signals to perform PT-32.2 "Plant Safeguards Logic Test "A" and "B" Trains".
Step 6.9.2 directed the I/C Technician to "Simulate pressurizer pressure to approximately 2200 psig (- 30 mA) for P-429, P-430 and P-431".
Page 5
50-244/89-18.
November 17, 1989 Reason For The Violation (conti nued)
The I/C Technician manually
" tripped the four bistables on
~
PT-429 (high pressurizer
- pressure, unblock S.I., low pressure S.I.,
and low pressure reactor trip) inserted the simulator leads and adjusted the signal to approximately 30 mA (- 2100 psig).
He then untripped the bistables.
When he tripped the bistables for PT-430 (high pressurizer
- pressure, unblock S. I., low pressure S.I.,
and low pressure reactor trip) the S.I.
was automati cally unblocked due to the two of three logic for unblocked S.I.
(PT-429 and PT-430).
At the same time S.I. actuation occurred due to PT-430 low pressure bistable being tripped and PT-431 still being at zero pressure.
This provided two of three channel logic on low pressurizer pressure.
I/C personnel, in the performance of calibration procedures, are trained and directed. by procedure to trip bistables prior to injecting simulated signals.
Without specific directions to,the
- contrary, the I/C technician followed the same standard practice while performing PT-32.1, resulting in the inadvertent safety injection.
Corrective Ste s Taken and Results Achieved After the cause of the event was identified, the system was reset by removing the pressurizer channel P-430 low pressure safety injection bistables from the trip mode thus terminating the safety injecti on actuating signal.
The I/C personnel were instructed on the 'proper -method of si mulati ng si gnals and PT-32.1, "Plant Safeguard Logic Test -- "A" or "B" Trains" was then properly completed.
Corrective Ste s Which Will Be Taken To Avoid Further Violations The Results and Test Department has been assigned responsi-bility for reviewing appli cable Periodic Test (PT) procedures which require use of simulated signals to perform the test.
The procedures are being evaluated for both on-line and shutdown conditions.
To date, they have determined that no procedure improvements are required for on-line conditions.
- However, they are continuing to review and establish improved instructions to provide clearer direction for methods of si mulati ng si gnal s including direction for bistable proving switch positioning while testing during shutdown conditions.
During plant operations at power, plant parameters are such that si mulated si gnal s are not required.
During
- shutdown, simulated signals are necessary to clear reactor protection and safeguard logic trip signals to permit functional tests to be performed.
Page 6
50-244/89-29 November 27, 2989 Date When Full Com liance Will Be Achieved Corrective Action Report 2,959, Action Item 4 is tracking the procedural improvement activity with a task completi on date of Wednesday, January 3, 2990.
S ecial Ins ection Re ort 50-244 89-18 Enclosure 2
Notice of
-Violation C States in art:
C.
10 CFR 50, Appendix B, Criterion XVI and the Ginna quality Assurance
- Manual, Section 26, 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 bubbl er tubes on October 22, 1988 were inadequate to prevent recurrence on June 2,
2989.
Rochester Gas and Electri c concurs that corrective action taken was inadequate to prevent recurrence.
Reason For The Violation Corrective action resulting from the missed rodding of boric acid tank level bubbler tubes on October 22, 1988, included placing the activity on the Maintenance Weekly Scheduling System to ensure planning and scheduling for the activity occurred each
,week.
The day of the week was changed from Friday to Thursday to permit completion by I/C personnel and review for compliance by Results and Test personnel within the permissible deviation time frame to prevent exceeding seven days
+
258 as required by Techni cal Specifications.
During the 2989 outage, the maintenance scheduling system was discontinued during the period that Outage Scheduling System scheduled maintenance activities to coordinate with the overall outage.
program.
The maintenance scheduling system did not resume until the week of June 25, 2989.
Additionally, during the
- outage, frequent bubbl er rodding was required as corrective maintenance at the request of Operations.
Confusion resulted in acceptabili ty of taking credit for the corrective action rodding when it was required on days other than the normal ly schedul ed Thursday.
For exampl e, the bubbler syst'm tubes were rodded three times the week before the missed activity and three
- times, the week after the missed activity.
Page 7
50-244/89-18 November 17, 1989 Corrective Ste s Taken and Results Achieved 1.
Direction and agreement to, perform PT-21 every Thursday regardless of when performed for Corrective Maintenance.
2 ~
3.
Results and Test tracks performance of PT-21 on a published monthly schedule for periodic tests due that month'.
The Maintenance Schedul er provides the I/C Foreman a
monthly look ahead schedule which includes weekly preventive maint-enance activi ties, including PT-21.
The I/C Foreman pl'aces PT-21 on the weekly look ahead maintenance
- schedule, and on Wednesday, the daily look ahead maintenance schedule (when Thursday is a holiday, PT-21 is scheduled for and performed on Wednesday).
Results and Test Planning representative, who participates in the afternoon maintenance scheduling meetings, performs a
completion check on Thursday afternoons to ensure PT-21 was completed (Wednesday afternoon schedule meeting if Thursday is a holiday).
4.
PT-21 was added as a
scheduled activity in the Outage Computer Systems for outage activity scheduling.
5.
A PCN was initiated by Operations to 0-6. 11 to provi de a
check off for PT-21 in weekly surveillance checks.
Operations has been recruested by a
memo placed in the Operations Plan to notify Results 6 Test and/or I/C if PT-21 has not been performed each Thursday.
Corrective Ste s Which W'ill Be Taken To Avoid Further Violations EVR-4770 was initiated. to develop and install a
new boric acid storage tank level monitoring system to replace the existing bubbler type, and
- thus, remove the need for weekly rodding of bubbler tubes as preventi ve maintenance.
This modification is presently scheduled for the 1991 Refueling Outage.
Date When Full Com liance Will Be Achieved Full compliance has been achieved with weekly bubbl er tube rodding being performed each week since June 08, 1989.
Page 8
50-244/89-.29
~
November 17, 1989
\\
S eci al 1'ns ction Re ort 50-244 89-18 Enclosure 1
Notice of Violation D states in art:
D.
Techni cal Specification 3.1.5. 1. 1 requi res,,
with reactor coolant system temperature greater than 350 degrees Fahren-hei t, one system'ensitive to radioactivity, shal l be in opera tion.
Contrary to the above, on June 16, 1989, the reactor coolant system temperature was greater than 350 degrees Fahrenheit, no listed leak detection syst'm sensitive to radioactivity was in operation, and the compensatory'ction of drawing and analyzing a
grab sample of the containment atmosphere 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.
Rochester Gas and Electric Corporation concurs that Technical Speci ficati ons were violated as stated.
This item was previ ously submitted via LER 89-006.
Reason For The Violation RMS Channels R-10A,
- R11, R22 were taken out of service to perform calibration and maintenance on R-11 in accordance with procedure CP-222, "Calibration and/or Maintenance of RMS Channel 11 (Containment Particulate) ",
on June 14, 1989 at 1004
- EDST, a
required once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> grab sampl e of containment air was taken at 2005 EDST on June 14, 1989.
RMS Channels R-10A, R11, R-22 were returned to service at 2629 EDST on June 15, 1,989.
It was determined at 0004 EDST on June 1,6, 1989, that the RMS R-10A, R-21, and R-22 wer e not properly aligned to sampl e con tai nment atmosphere.
- Instead, they were sampling local ambient air.
When the condition was identi fied during performance of 0-6.13, "Daily Surveillance
.Log", at 0004 EDST on June 16,
- 1989, the Control Room Operators aligned the monitors to sample contain-ment.
They then performed PT-27.2, "Process Radiation Monitors R-11 R-22 Iodine Monitors R-10A and R-20B" and decl ared the system operable at 0335 EDST on June 16, 1989.
As the inoperability of RMS R-10A, R-11, and R-22 was unknown at t'e
- time, a grab sample was 'not taken prior to 2005 EDST on June 15, 1989.
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit for a grab sample was exceeded for the time period from 2005 EDST June 15, 1989 until 0335 EDST June 16,
- 1989, when the system was declared operable.
Page 9
50-244/89-/8 November 17, 1989 Reason For The Violation (conti nued)
Procedural inadequacy and personnel error were determined to be the cause of operati onal acceptance of a misali gned sampl e valve.
The procedural inadequacy was due to CP-211,
'!Calibration and/or Maintenance of RMS Channel 1.1 (Containment Parti culate",
not providing direction and requiring sign-off to properly restore sample alignment after completi on of calibration and/or mai nt-enance.
The personnel error was due to lack of attention to detail by the Control Room Operator when performing independent verification of the return to service of RMS R-1,1. monitor per A-52.4, "Control of Limiting Conditions for Operating Equipment".
The personnel error was the resul t of cogni tive
. error (i. e.,
Operator failed to recognize that the RMS monitors inlet was from local ambient air rather than the containment atmosphere).
Corrective Ste s Taken and Results Achieved Upon discovery, Control Room Operators ali gned the RMS monitors to sample containment air and then, to functionally test the monitors, per PT-17. 2, "Process Radi ati on Monitors R-11, R-12, Iodine Monitors R-10A and R-10B", prior to decl ari ng the monitors operable.
Corrective Ste s Which Will Be Taken To Avoid Further Violations Calibration Procedure CP-211, "Calibration and/or Maintenance of RMS Channel 11 (Containment Particulate",
CP-210A, "Calibration and/or Maintenance of RMS Channel R-10A (Contai nment Iodine) ",
and CP-212, "Calibration and/or Maintenance of RMS Channel R-12 (Containment Gas) ", have been revised to add system restoration instructions with independent verification.
'dditional 1y, the Operations Manager sent a
message to all
- Operator, and Shift Supervisors to ensure that all Operations personnel continually focus attention to details of good opera-tions.
Date When Full Com liance Will Be Achieved Full compli ance was achieved when the system was decl ared operable at 0335 EDST on June 16, 1989, and when revised procedures were issued for use as follows:
CP-211 July 05, 1,989 CP-210A July 13 1989 CP-212 July 13 1989
Page 10 50-244/89-1P November 17, 1989 ualit Assurance Or anization Effectiveness The letter transmitting the Notice of Violation and Enforce-ment Conference Meeting Summary requested that. the response address actions taken or plarmed to assure effecti veness of the Quality Assurance Organization and of the independent verification process.
Quality.issues were discussed at the Enforcement Conference on October 3,
1989.
An addi tional presentation was made to the,NRC Staff on October 24, 1989, in the Region I Office.
At that
- time, the plans and focus of the Quali ty Performance/Quality Control Organization were discussed, including the relationship to Enforcement Conference issues.
Plans to improve effectiveness 'include:
o Ensuri ng that Quali ty Control is represented on - all Modification Follow Groups and that participation is continued throughout the entire modification process.
o Participation by Quality Control in dai ly maintenance planni ng meetings.
o Use of performanced based surveillances to assess the integrated functional adequacy of processes, including modificati ons.
o Additional attention to the modification turnover process will be directed through enhanced QA/QC review.
Further ways to supplement the Quality Organization input to and oversi ght of activities will be pursued to improve Quali ty Performance Effectiveness.
Very truly yours, Robert-C.
Me General Manager Nuclear Production xc: '.S.
Nuclear Regulatory Commission (Original)
Document Control Desk Washington',
D. C.
20555 NRC Senior Resident Inspector Ginna Station
T