ML17251A471
| ML17251A471 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/27/1989 |
| From: | Eapen P, Gregg H, Moy D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A469 | List: |
| References | |
| 50-244-89-04, 50-244-89-4, NUDOCS 8905110209 | |
| Download: ML17251A471 (14) | |
See also: IR 05000244/1989004
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-244/89-04
Docket No.
50-244
License
No.
DRP-18
Licensee:
Rochester
Gas
& Electric
Com an
49 East Avenue
Rochester
14649
Facility Name:
R.
E. Ginna Nuclear
Power Plant/Cor orate
En ineerin
Office
Inspection At:
Ontario
New York/Rochester
Inspection
Conducted:
March 13-17
1989
Inspectors:
Daniel
T.
oy,
Rea
Engineer
date
Harold
.
regg,
Seni r Reactor
Engineer
d te
Approved by: P..
Eapen,
Chief, Special
est
Program
Section
date
Ins ection
Summar
Routine
unannounced
ins ection
on March 13-17
1989 throu
h A ril 20
1989.
Ins ection
Re ort No. 50-244/89-04
T
T
T
d <<T
T
d
function at the site
and corporate office.
Specific reviews of design
activities,
outage
planned modifications, work backlog,
and project prioritiza-
tion were performed during the inspection.
The inspection also included
observations
of two attended training sessions
and observations
from plant
walkdowns.
Results:
One violation pertaining to
PORV block valve replacement
was
identified.
Three inspection findings were designated
as unresolved
items.
3905110209
390423
ADOCK 05000244
Q
DETAILS
1.0
Persons
Contacted
1. 1
Rochester
Electric and
Gas
Com an
R.
E. Ginna Site Personnel
- S. Adams, Technical
Manager
J.
Bodine, Nuclear Assurance
Manager
"T. Harding, Modification Support Coordinator
- R. Marchionda, Director of Outage
Planning
T. Marlow, Superintendent
Ginna Support Services
"S. Spector,
Plant Manager
Ginna Station
- J. Widay, Superintendent
Ginna Production
Cor orate
En ineerin
Personnel
R. Mecredy,
General
Manager Nuclear Production
- B. Snow, Chief Engineer
G. Voci, Manager,
Mechanical
Engineering
"P.
Wi lkens, Director, Nuclear Engineering
Services
G. Wrobel, Manager,
Nuclear Safety
and Licensing
1.2
U.S. Nuclear
Re viator
Commission
C. Marschall, Senior Resident
Inspector
N. Perry,
Resident
Inspector
"Denotes
those
present at exit meeting
on March 17,
1989.
2.0
Objective
The objective of this inspection
was to review and evaluate
the
engineering
organization
and function at the site
and corporate office.
The review of staffing, personnel
capability,
planned
and completed
activities, project status
and backlog, interface
between organizations
and management
control was included in the inspection plan.
Both site and corporate
engineering
have
undergone
recent organizational
changes.
At the site,
the technical
and modification support groups were
separated
and are
headed
by two new supervisory positions that report
directly to the plant manager.
At the corporate office, nuclear
and
non
nuclear engineering
were separated.
1,
0
Site engineering
is performed
by two groups,
the modification support
group and the technical
group.
Modification support
has
10 engineers,
5 are
RGE and
5 are contract personnel.
Staffing levels
have
remained
constant,
several
personnel
transfers
have occurred,
and the work backlog
remains
high.
This group reviews
and inputs major modification details,
interfaces with corporate
engineering,
and is cognizant
and involved with
the modification installation.
This group also interfaces with mainte-
nance
and the site technical
group.
The other site engineering
group,
the
technical
group,
performs minor modifications,
and operational
trouble report related work.
Present
staffing of this
group is
7 engineers
plus
2 test
and results
engineers
whereas prior
staffing was
4 engineers total.
Corporate
engineering
recently reorganized
as nuclear engineering
services
and consists
of mechanical,
electrical,
nuclear safety
and licensing
disciplines.
The cur rent staff is 72 engineers
and there are
12 newly
approved
vacancy positions.
Prior to the reorganization
the staff was
70
engineers,
of which 20 had
non nuclear functions.
In summary,
the inspector
concluded that the site and corporate
engineering
organizational
changes
implemented
by the licensee
are beneficial
and are
established
to improve responsibility and accountability of nuclear
engineering activities.
Staffing levels at corporate
engineering
have
been substantially
increased
and filling the
12 vacancies will further
improve this organization's
capability,
however,
the current project backlog
remains extremely large.
The staffing increase
in the site technical
group
was viewed positively and their work completion
appears
to be timely.
The
modification support group was
found proficient. and capable
in handling
their assignments,
however, their staff has not increased
and their work
burden is high.
In each of the engineering
areas,
constant
communications
and interfacing were evident
between
the site
and corporate
engineering
functions.
4.0
Review of Major Modifications
Several
major modification project design criteria and safety analysis
details
were reviewed
by the inspector.
These projects were:
Offsite Power Reconfiguration
EWR 4525.
(Permanent
installation
of second station transformer to improve system reliability and
eliminate susceptabi lity of single failure loss of all
AC power.)
Safety Injection
pump recirculation loop -
EWR 3881. (Increasing
the
loop piping size to increase
minimum pump flow and replacement
of
currently blocked
open air operated
valves with environmentally
qualified motor operated valves).
RHR pump recirculation
loop EWR 4675.
(Installing separate
recirculation
loops in response
to
NRC Information Notice (IN) 85-09
and Bulletin (BU) 88-04.
The
BU and
IN described
the problem of two
pumps discharging into
a
common
header resulting in restricted flow
or dead
heading
the weaker
pump).
PORV block valve Upgrade -
EWR 3755.
(Existing Velan gate valve seats
had been
machined
many times and little seat material is left.
The
two PORV block valves are being replaced with Anchor Darling double
disc gate valves).
Review of Desi
n Criteria
The inspector noted that the design criteria was brief in all cases
other than the offsite power reconfiguration which had more detail.
It was determined
the reason
the criteria was brief was that this
was
an initial project document
and precise details of the
modification may not be
known at the time.
The inspector verified
that corporate
engineering
does
document
subsequent
design
reviews
and analysis
and other descriptive
documentation detail is available.
4.2
Safet
Analysis
The inspector
reviewed the safety analysis for each of the above
modification projects.
The inspector
noted that in each
case
the
safety analysis describes
and assesses
the proposed modification
consequences
and concludes with preliminary safety evaluation
statements
reflecting
some of the provisions of 10 CFR 50.59.
The
inspector's
noted that the assessment
and the 50.59 provisions
are not linked and it is difficult to relate the assessment
to the
10 CFR 50.59 provi sion.
For example,
the
RHR recirculation
upgrade
safety analysis
narrates
the intent of the modification and
references
design criteria to show non-adverse
performance.
The
analysis
concludes with individual
10 CFR 50.59 provisions
as being
met.
The inspector
concluded that the analysis
would be improved if
each of the
10 CFR 50.59 provisions
had
a narrative justification.
4.3
PORV Block Valve
Re lacement
The design criteria and safety analysis for replacement
of the two
3" Velan wedge gate valves with two 3" Anchor Darling double disc
gate valves were reviewed during the inspection.
The reason
the valves
are being replaced is to enable
minimum seat
leakage
to be maintained.
Prior seat machinings
have limited the seat
surface available for
further remachining.
However, the design criteria and safety analysis
did not describe
or provide any justification for the operational
qualification of the replacement
valves that are
a different design
and manufacturer
than the original valves.
Operational qualification
of PORV block valves
was specified in
NUREG 0737 as
TMI Action Plan
Item II.D.1,
The licensee
committed to this TMI action plan item as
confirmed in the
NRC Order issued
on July 10,
1981.
The original
Velan valves
had
been qualified for operation
and
a safety evaluation
report for these
valves issued
by the
NRC.
However, at the time of
the inspection it was determined that requirements
relative to oper-
ability of the Anchor Darling replacement
valves
had not been fully
addressed
or documented
by the licensee for the approved modification.
0
Due to concerns of the safety significance of this modification
several
additional
conference
telephone calls were
made
and
some
preliminary information was obtained.
The licensee
was requested
to
provide documentation
demonstrating
that the valves are qualified
for operation prior to restart of the plant.
The failure to adequately
evaluate
operational qualification of the
replacement
PORV block valves is
a violation of 10 CFR 50, Appendix B,
Design Control requirements
(50-244/89-04-01).
5.0 ~P
The planned activities for the refueling outage
scheduled
March 17,
1989
to May 11,
1989 were discussed
with the outage director.
Many major
modifications are planned
since this is
a
10 year ISI outage
and the core
will be unloaded.
Major modifications include:
safety injection and
residual
heat
removal recirculation piping upgrade,
turbine trip system
modification, offsite power reconfiguration,
replacement,
and
blowdown system
upgrade.
Many other
major activities are planned concurrent with the major modification work
and include:
inspection,
"A" reactor coolant
pump motor
replacement,
primary valve maintenance,
high and low pressure
turbine
overhaul,
primary heat exchanger
inspections,
and
many maintenance
related activities.
Outage
plans
and schedule
milestones
were reviewed
by
the inspector
and verification was
made that outage
planning meetings
were effective.
The inspector
concluded that the outage project schedule
was comprehensive
and the planning
and training for the outage
appears
effective.
6.0
Modification Project Prioritization
The inspector
noted that the major project listing contains approxi-
mately 250 projects
and based
on discussions
with engineering
personnel
the backlog continues to increase.
The inspector
was concerned
about
the large project backlog
and its implication that insufficient resources
.may be allocated to major project work,
some of which may have
significant safety significance.
This issue is unresolved
pending
the licensee's
evaluation of the project listing (50-244/89-04-02).
6.2
New Prioritization
S stem
The licensee
has recently developed
a new method of prioritizing
modifications
and other activities.
The
new system considers
the
attributes of safety, operability, regulation, plant improvement,
and corporate objectives
in decreasing
order.
Various elements of
each attribute are rated
and assigned
a numerical
value
and the
aggregate
numerical
value provides the level of priority.
The
higher the total, the higher the priority.
The inspector
viewed the
new prioritization system
as far improved over the old judgmental
approach that had
been
used,
and
a worthwhile licensee effort.
The
inspector
noted that the project prioritization currently in place
for 1989
and
1990 still utilizes the old system.
7.0
Use of PRA Techni
ues
The licensee
has not had any significant
PRA involvement to date.
Two
PRA engineers
were recently hired and the licensee
plans to perform
reliability analyses utilizing plant data.
Currently the licensee
has
not committed to
a schedule of PRA planned activities.
8.0
Trainin
Observations
8. 1
Safet
Evaluations
During the inspection,
the inspector attended
a,10 CFR 50.59 Safety
Evaluation training session
being conducted
by an outside contractor.
The training was well attended
and the inspector considered
the
effort worthwhile.
The inspector also noted that site engineering is
striving to eliminate past
problems of maintenance
performing design
modifications without a safety evaluation.
This is being accomplished
through closer ties
and communications with maintenance
and the
routing of trouble reports
through qC, the maintenance
supervisor,
and maintenance
planner.
Additionally, maintenance
goes over the
details of their work plans at the morning meeting where further
staff review is obtained.
8.2
Maintenance
The inspector
observed
plant personnel
being trained
by Combustion
Engineering
in preparation for the
sleeving during
the outage.
The
mock-up was being utilized and the
plant personnel
were training
on the installation of the sleeving
elevator
and its attachment
to the manipulator
arm.
The inspector
viewed the training as effective,
however,
there
was
a concern that
the trainees
were not in PCs or masks.
The licensee's
representative
stated that this training was preliminary and that later training is
to be done in PCs
and masks.
9.0
Plant Walkdown Observations
Inspections
were
made in the plant of the safety injection pumps
and
blocked
open
AOVs, main steam safety valves,
spent. fuel pool cooling
pump installation,
and feedwater
(FW) piping and
valves.
The inspector
noted
numerous
valves in the turbine building that
had the
appearance
of neglect.
Manual
FW valves
3978
and
3979
had packing leaks,
MOV 3976
and
3977
had packing residue
on the stem,
small valves
1960 and
1961
had considerable dirt and dust inside the yoke posts,
valve 3527 had
a gland leak,
and valve 3872 appeared
to have
some packing extrusion.
The
general
condition of the valves in this area
was evidence of non uti liza-
tion of general
valve maintenance
practice.
This matter is unresolved
pending the,licensee's
evaluation of these
concerns
(50-244/89-04-03).
The inspector
noted problems with the closure capability of fire doors
F13,
14 and
15 in the turbine building at the mezzanine
level
and door S65
in the auxiliary building.
In each
case
the automatic door closer would
not fully close the door.
It was noted that door S65 was
an alarmed door
and personnel
would latch it, however,
in the case of the other doors,
they
were left partially open.
It was noted that several
of these
same doors
were identified as problems in prior inspection report 88-24.
This item
is unresolved
pending the licensee's
evaluation
and correction of the
problem (50-244/89-04-04).
10.0 Unresolved
Items
deviations.
and two in
fl
Unresolved
items are matters
about which more information is required in
order to ascertain
whether they are acceptable
items, violations or
Three unresolved
items are discussed;
one in paragraph
6. 1,
paragraph
9.0.
The inspector
met with the licensee's
representatives
at the conclusion
of the inspection
on March 17,
1989.
During the inspection,
the inspector did not provide any written material
to the licensee.
The licensee
representatives
did not indicate that this
inspection
involved any proprietary information.
14
s
I
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