ML17251A605
| ML17251A605 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/04/1986 |
| From: | Bettenhausen L, Eapen P, Eichenholz H, Kim T, Paulitz F, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A603 | List: |
| References | |
| 50-244-86-02, 50-244-86-2, NUDOCS 8603170341 | |
| Download: ML17251A605 (59) | |
See also: IR 05000244/1986002
Text
U.S.
NUCLEAR REGULATORY COMMISSION
Region I
Report
No.
50-244/86-02
Docket
No
50-244
License
No.
Licensee:
Rochester
Gas
and Electric Cor oration
49 East Avenue
Rochester
14649
Facility Name:
Inspection At:
R.
E. Ginna Station
Ontario and Rochester
Inspection
Conducted:
Inspectors:
H
Dr.
P.
Januar
27
31
1986
K.
E
en,
ief,
QA Section
Team Leader)
g
d te
H.
ic enholz,
i
Resident
Inspector
d te
Kim,
R
'
t
nspector
Trainee
da
e
F.
P. Paulitz,
Reactor
Engineer
date
Approved By:
R.
W. Winters,
Reactor
Engineer
Dr. L. H. Bettenha'usen,
Chief, Operations
Branch,
date
date
Ins ection
Summar
- Routine
announced
ins ection
on Januar
27 - 31
1986
Ins ection
Re ort No.50-244/86-02
Areas Ins ected:
Effectiveness
of Quality Assurance
and Quality Control activ-
ities in Electrical, Mechanical,
Operations,
Instrumentation
5 Controls
and
Health Physics
areas.
The inspection
involved 152 hours0.00176 days <br />0.0422 hours <br />2.513228e-4 weeks <br />5.7836e-5 months <br /> onsite
by 2 region
based
inspectors,
2 resident
inspectors
and
one supervisor.
Results:
Four violations were identified (Inadequate
corrective action for
audit findings applicable to the inspection of lifting rigs for reactor
vessel
head
and internals;
Inadequate
receipt
and traceability of safety related stain-
less
steel wire rope for auxiliary building crane;
Inadequate
independent verif-
ication for safety related electrical circuit schedules;
and use of out-of-cali-
bration meggering device to megger circuit breakers
for component cooling water
system
pump)
and two unresolved
item (correction factors for battery specific
gravity; and programmatic
concerns
in receipt inspection).
- 8SOSl7OS4i
ahOSfl
!
ADOCK OSOOO244
TABLE OF CONTENTS
~Pa
e
1.
Persons
Contacted
2.
Introduction,
Summary
and Conclusion.
3.
Operations
and Instrumentation
5 Control Activities...
4.
Mechanical Activities...............................
13
5.
Electrical Activities
17
6.
Health Physics
and
Chemi stry Activities..
22
'
7.
Licensee Action on Previous
NRC Identified Items.......
8.
Unresolved Items...
~
\\
\\
\\
0
'I
~
~
~
~
~
25
9.
Exit Interview
25
Attachment 1........Details
of the Reactor
Vessel
Head
and Internals
Liftings Rigs Inspection
DETAILS
1.0
Persons
Contacted
Rochester
Gas
and Electric Cor oration
1.2
H. Saddock,
Executive .Vice President
- R. Kober, Vice President,
Electric 4 Steam Production
~ B.
Snow, Superintendent,
Nuclear Production
- S. Spector,
Superintendent,
Ginna Production
T. Meyer, Superintendent,
Ginna Support Services
~
R. Mecredy, Director of Engineering Services
~ R. Vanderweel,
Manager,
Project Modifications
- T. Schuler,
Manager,
Operations
" C. Anderson,
Manager, Quality Assurance
- J.
Bodine,
Manager,
Nuclear Assurance
- T. Marlow, Manager,
Maintenance
- A. Curtis, III, Manager,
Material Engineering
D. Fi lkins, Manager,
Health Physics
5. Chemistry
L. Boutwell, Supervisor,
Maintenance
- E.
Edger,
Supervisor,
Instrument,
Control
and Electrical
D. Gent,
Supervisor,
Results
and Test
K. Nassauer,
Supervisor,
Quality Control
R. Latz,
Foreman,
Electrical
G.
Foss,
Foreman,
Results
and Test
~ D. VanDorn,
Foreman,
Mechanical
Handling Equipment
N. Goodenough,
Engineer,
Project Quality Control
W. Stiewe,
Engineer,
Quality Control
F. St. Martin, Liaison Coordinator
'. Saporito, Materials Engineering
Laboratory
F. Mis, Health Physicist
US Nuclear
Re viator
Commission
~ W. Cook, Senior Resident
Inspector
- Denotes
those present at exit meeting.
2.0
Introduction
Summar
and Conclusions
2.1
Introduction
On February
25,
1985,
the
NRC Systematic Appraisal of Licensee
Per-
formance
assessed
the Quality Assurance
(QA) and Quality Control
(QC)
area for the Ginna Station
as Category
3.
In response
to this as-
sessment,
the licensee
established
a task force to review the area
and provide recommendations
to ensure
continued effectiveness
of QA
and
QC activities at the site.
The task force 'completed
an in-depth
study
and
made the following nine recommendations
in November
1985:
1.
Nake Quality Assurance
Accountable to the Executive Vice
President with Chief Engineer providing day-to-day direction
2.
Establish
a Formal Objective
Program for QA Group
3.
Establish
a Priority System (ie Severity Level) for Audit Findings
4.
Continue
Task Force Overview for QA and
QC as Subcommittee
of
NSARB (the off-site-review committee)
5.
Simplify paper
system
and streamline
reporting
6.
Develop education
and information program
on importance of QA/QC
7.
Formalize the interface
between divisions
8.
Specify responsibility for program
and implementation
9.
Review manpower
requirements
and establish
a program to provide
proper people to do job
The licensee
provided
a status of the implementation of the above
task force recommendations
to a regional
supervisor
and
NRR personnel
on December
4,
1985.
2.2
Pur ose of the Ins ection
The purpose of this inspection
was to assess
the overall effectiveness
of the licensee's
QA and
QC activities with special
emphasis
on the
status
and effectiveness
of the implementation of the licensee's
QA/QC task force recommendations.
2.3
Ins ection Methodolo
The effectiveness
of the licensee's
QA and
QC activities was assessed
by reviewing design
changes,
procedure
changes,
maintenance
and surveil-
lance activities and
QA and
QC overview of various activities.
The
audit findings and
QC surveillance
reports
were also reviewed for
adequacy.
The impact of the licensee's
QA/QC task force recommenda-
tions were reviewed in several
areas.
The findings of this inspec-
tion are detailed in paragraphs
3, 4,
5 and
6 and
summarized
below:
Ly
2.4
Summar
of Findin
s
a.
0 erations
and Instrumentation
& Control
(Paragraph
3)
1.
Reactor
Vessel
Head
and Internals Lift Violation
Reactor
Vessel
Head was lifted on May 1,
1983
and
April ll, 1984 without completely inspecting all critical
welds of the lifting rig prior to lift as required
by pro-
cedures.
Reactor Internals
were lifted in 1983,
1984
and
1985 without completely visually inspecting
the critical
welds of the lifting rig prior to lift.
gA Audits 84-15
and 85-11 identified this concern.
gA Audit 85-11 did not
identify this as
a recurring problem.
Line and
gC personnel
signed off procedure
steps without adequate verification
that the required actions
were complete.
b.
Mechanical Activities
(Paragraph
4)
1.
Safety related stainless
steel
rope for auxiliary building
crane did not have documented traceability for chemical
analysis
and breaking strength.
(Example of a violation)
2.
Calibration services for direct readout
gauges for the hy-
draulic torque wrenches
were procured
from a supplier
who
was not evaluated
by Ginna Station,
General
Maintenance,
guality Assurance
and Electric Meter and Laboratory,
as
required
by the licensee's
gA program.
(Example of a vio-
lation)
Electrical Activities
(Paragraph
5)
1.
Circuit Schedules
(safety related drawings)
were improperly
independently
reviewed
by the originator (Violation).
2.
An out-of-calibration device
was
used to megger test the
'ircuit breakers for component cooling system 'B'ump.
Neither the workers nor the
gC inspector verified the
calibration of the meggering device (Violation).
3.
The battery surveillance
procedure did not provide accept-
ance criteria for level
and temperature
checks.
As
a result,
corrections
to electrolyte specific gravity were not made
(Unresolved Item).
C(
C I
1.
Procedure
steps
for radwaste
shipment 85-84 were signed off
by a health physicist
and not by the worker who conducted
the actual
work.
2.
QC signed off the hold point without verifying the accept-
ance
and accuracy of the instrument readings
obtained
from
the steps
QC witnessed.
2.5
Status of the Licensee's
Initiatives to Im lement
A/
C Task Force
Recommendation
1.
The management initiatives to improve quality of safety related
activities
had been recently developed
from the recommendations
of the
QA/QC Task Force.
2.
As of January
27,
1986,
the following actions
were taken
by the
licensee
Goals
and actions
are developed for the Executive Vice
President
(EVP), Vice President
(VP) and Chief Engineer.
The goals
and Action Plans
are being developed for the mid
management
levels (i.e.,
QA Manager,
Superintendent
etc.).
Reorganization
to relieve the Chief Engineer
from immediate
responsibility for dispositioning corrective action requests
generated
by the
QA manager
who reports directly to the
Chief Engineer.
Better
involvement, control
and overview of QA activities
by
EVP as indicated
by the
EYP's review of recent
QA acti-
vities and audit findings.
Appointment of a
new Nuclear Assurance
Manager to enhance
the effectiveness
and credibility of site
QC.
Hiring of experienced
Contract
QC personnel
to site
staff.
Initiation of back-to-the-basics
training program at working
level to enhance
Quality and safety
awareness
(two sessions
conducted to date).
Implementation of the task force recommendation
to categor-
ize
QA findings in accordance
with the severity level
and
use
these findings for management
decision
making and control.
~i/
2.6.
Conclusions
1.
Enhancement
of
quality and safety
awareness
at the Ginna
Station working level is
a slow process.
2.
The licensee
uses
informal means to arrange
non-destructive
examination of critical welds
on lifting rigs for the reactor
vessel
head
and internals
and to provide technical
information
to the maintenance
mechanics.
3.
The licensee's
data
base
supporting
the Vendor Manual
System
is not controlled in accordance
with licensee's
QA Program
requirements.
4.
The activities for the upcoming outage
appeared
to be unaffected
by the task force recommendations.
3.
0 erations
and Instrumentation
8 Control Activities
The effectiveness
of the licensee's
activities in Operation
and Instrumen-
tation 5 Control Areas
was assessed
by reviewing selected
QA audits, refuel-
ing outage activities
and survei llances tests,
as detailed
below:
3. 1
Audits
In order to determine
the adequacy
and effectiveness
of the license
audits,
two selected
1985
QA audits
were reviewed.
These audits in-
volved Maintenance,
Surveillance,
and Operational activities.
The
purposes
of this review were to:
1) ascertain
the nature
and extent
of the licensee's
auditing effort, 2) determine
the manner
in which
the audit findings were dispositioned,
3) identify to what extent the
corrective actions associated
with the audit findings were tracked
for completion,
and 4) determine
whether identified discrepancies
were repetitive
and
how the licensee
had addressed
this aspect of the
audit.
The details of this review are given below:
Audit 85-07:CA, Ginna Station Maintenance Activities, was performed
during the period of February
12-22,
1985.
All audit findings were
satisfactorily
di spositioned
by the licensee
and the Audit was closed
on July 19,
1985.
There were
no
NRC identified deficiencies
as
a
result of reviewing this audit.
Audit 85-11:JB,
Ginna Station Refueling Activities, was performed dur-
ing the period of March
11 through April 9,
1985.
The
QA manager
was
one of the auditors.
At the time of NRC review, thi s audit was still
open.
There
was only one audit finding.
The Audit Finding Corrective
Action Report
(AFCAR), Finding No.
1, stated that the Reactor
Vessel
Head Lifting Device
(RVHLD) and the Reactor
Vessel
Internals Lifting
Device (RVILD) had not received
an annual
visual inspection of welds
as required
by licensee
Procedure
MHE-1100-1, Inspection
and Mainten-
ance of Special Lifting Devices.
This was identified during
an audit
of activities involving "control of heavy loads".
lj
,O'I
I
'h
,IU <
l
'I
AFCAR Finding No.
1, to Audit 85-11:JB stated:
1) The Material
Hand-
ling Equipment
(MHE) Group's procedure
referenced
above required
two
types of inspections
to be performed at specific intervals for the
RVHLD and
RVILD; 2) The
NOE was completed in 1983, but annual
visual
inspections
of specified welds
on these
two devices
were not performed
as required (only partial inspections
were done
due to inaccessibility
of the welds caused
by 1'ead shielding
and constructions);
3) The
RVILD
was not inspected at all in 1985;
and 4) Since the requirement
went
into effect in 1983,
the
RVHLD and
RYILO have never received
a com-
plete visual inspection of the welds
as required (this is based
upon
a review of completed records).
The audit's
"Recommended
Actions" for disposition of this finding
stated
..."An equitable
understanding
of the requirement for inspec-
tion, together with the scheduling
and maintenance
problems involved,
should
be reached
by the various personnel
concerned.
This under-
standing
should then result in complete
and comprehensive
compliance
with the inspection required."
The audit was transmitted to the
Superintendent,
Ginna Station
and Superintendent,
General
Maintenance
on April 22,
1985 following approval of the audit report by the
Manager,
gA.
On May 3,
1985,
a corrective
action response
to the above
recommenda-
tion was received
by gA.
This response
was prepared
by the cognizant
MHE Foreman
involved in the
1985 inspection
and approved
by the Super-
intendent,
General
Maintenance.
It stated
..."These
inspections
were
not done
as
scheduled
due to
a misunderstanding
of inspection require-
ment's.
Materials Engineering
personnel
have
met with responsible
structural
engineering
personnel
and
have concluded that all inspec-
tion requirements
can
be met with present
equipment configuration.
Therefore,
at the next refueling outage,
these
inspections will be
done."
The stated target completion date for the corrective action
was February
26,
1986.
Based
upon the importance of the
AFCAR finding, and the fact that the
established
target completion date for the corrective actions
was
after the
commencement
of the next Refueling Outage that was scheduled
to begin
on February 8,
1986,
a detailed inspection
was conducted
by
the
NRC to review the licensee's
plans
and schedules
for performing
the required inspections.
The inspector
reviewed all applicable
licensee
procedures
related to the inspections
and the stipulated
sequence
of activities;
and all scheduling related
documents
to ensure
that the inspections
were identified for performance.
Cognizant
licensee
scheduling
and inspection
personnel
were interviewed to
ascertain
that these
personnel
were aware of all stipulated require-
ments
and that the corrective action
was adequate
to preclude recur-
rence.
The following items were identified:
1
0
There were
no formal scheduling
mechanisms
identified by the
Re-
fueling Outage
Planning
Group and the
MHE Group that specifically
identified the performance
of the visual weld inspection or the
required
sequence
of the inspection activity as stipulated in the
applicable
licensee
procedures.
Informally, the
MHE Foreman
had arranged for Nondestructive
Exa-
mination
(NDE) personnel
to perform the weld inspections
on the
RVHLD as
soon
as the containment
was
open for personnel
access
and prior to assembly of the
RVHLD.
Since the disposition for AFCAR, Finding No.
1, for Audit 85-11:JB
was assigned
to the licensee's
General
Maintenance
Organization
the station's
Corrective Action Tracking System did not identify
this item and track it on the Task Assignment
System.
A status
file is maintained
in the office of the Manager,
Nuclear Assur-
ance for each audit report finding that results
in a Task Assign-
ment at the station.
This file and the computerized
tracking
data
base
showed
no information on the above
AFCAR item.
Speci-
fic licensee
action is required to provide adequate
tracking of
corrective actions
assigned
to organizations
outside
Ginna
Station.
The licensee's
action to resolve this issue will be
followed in a future inspection
(50-244/86-02-01).
A licensee
procedure
RF-9. 10,
Head Lifting Rig Operating Instruc-
tion,
Rev.
5 dated July 2,
1984, requires
a visual inspection
by
MHE personnel.
However, this procedure
step is not required
to be signed off.
No corrective action was specified for proce-
dure RF-9. 10 in the response
to AFCAR Finding No.
1,
as this
procedure
would not be used during this refueling outage.
A
contractor-developed
procedure will be used in place of RF-9. 10.
Licensee action is required to assure
that the contractor proce-
dures
adequately
address
the requirements
of all licensee
proce-
dures
applicable to the contacted activity.
This action will
be reviewed in a future
NRC inspection
(50-244/86-02-02).
This concern
was discussed
with cognizant
QA and
QC personnel.
The
Manager stated that the failure to perform the required inspections
of
special lifting devices
was identified in
a
1984
QA audit report.
A
detailed
review was then conducted
by the
NRC of all applicable licen-
sing commitments,
procedures,
and inspection
records that per tain to
the conduct of weld inspections
on the
RVHLD and
RVILD from 1983
through
1985,
as discussed
in Attachment
1 to this report.
10
3.2. 1.
Summar
Ins ection Findin
s Relatin
to Ins ection of the
RVHLD
and
RVILD
The following deficiencies
were identified by the
NRC:
The licensee
was not effective in implementing the commit-
ment in their letter of March 2,
1983 to an annual
inspec-
tion program for special lifting devices.
The weld inspection
requirements
of procedure
MHE-1100-1,
Rev.
0 were not adhered
to by the licensee
during the
1983
and
1984
RVHLD and
RVILD weld inspections.
The
RVHLD weld inspection
requirements
of procedure
MHE-
1100-1,
Rev.
1 were only partially completed
by the licen-
see during the
1985 refueling outage.
Additionally, the
licensee's
activities during this refueling were contrary
to the requi rements of procedure
A-1011, Revision 7.
During the
1983,
1984,
and
1985 refueling outages,
the
gC
hold point in procedures
RF-58,
RF-59,
and RF-60, respec-
tively, to verify the structural integrity checks of RVILO
were complete,
were signed off as complete
when
such checks
were not accomplished
due to
a misunderstanding
of the
requirements
by gC personnel
During the
1985 refueling outage
procedure
RF-60 contained
a requirement that all applicable
steps of procedure
MHE-
1100-1
have
been satisfactorily completed for the
RVHLD and
RVILD.
This requirement
was signed off as accomplished
when in fact it was not fully performed
as required.
The corrective action for a
1984
gA Audit Report was inef-
fective to preclude repetition of a failure to perform in-
spections
of welds
on the
RVHLD and
RVILD as specified in
the licensee's
written commitments to the
NRC and establish-
ed procedural
requirements.
The
1985
gA Audit Report
and
corrective actions did not assure
that the conditions that
lead to this issue
would be corrected
by the licensee.
3.2.2.
Items
1 through
6 constitute
a violation (50-244/86-02-03)
Immediate Actions Taken
b
the Licensee
The following immediate actions
were taken
by the licensee prior
to lifting of the reactor
vessel
head
and internals during the
refueling outage
commenced
on February 8,
1986.
Cl
11
1.
Revise the refueling procedure
and the material
handling
procedure
NHE-1100-1 to require
QC hold point for the
visual inspection of critical welds
on the reactor
vessel
head
and internals lifting rigs.
2.
Train material
handling
and
QC personnel
in their responsi-
bilities for the inspection of critical welds
on the reactor
vessel
head
and internal lifting rigs and the effective dis-
position of identified nonconformances
and audit findings.
3.
Emphasize
the importance of completing all actions prior to
signing off a procedure
step
and the role of QC in verifying
these
actions
by senior licensee
management
to all personnel
involved in the upcoming outage.
Subsequent
to this inspection period,
on February
10,
1986,
the
NRC Senior Resident
Inspector verified that the licensee
had
completed
the above actions.
3.3
Surveillance Activities
The
NRC reviewed selected
Instrumentation
8 Control (IEC) and Opera-
tions related surveillance activities to ascer tain whether these acti-
vities were performed in accordance
with the requirements
of Technical
Specifications
(TS) and implementing procedures
as detailed below:
A review of the current surveillance test
schedule
was conducted.
This document is generated
by the Results'nd
Test
(RET) Supervisor,
who is also responsible
for review and evaluation of the timeliness
and accuracy of completed tests.
Based
upon review of this document,
which captured
the status
of both scheduled
and completed testing,
and discussions. with the
R&T Supervisor, it was concluded that effec-
tive management
controls were in-place to ensure
the timely perform-
ance of required surveillance testing.
The
TS Section 4.0 Surveillance
requirement,
states
that surveillance
intervals
may be adjusted
plus or minus
25%.
Licensee
Procedure
A-1101,
Rev. 8, Performance
of Tests,
Paragraph
3. 1.8.3. 1 states
that
a maximum allowable extension
not to exceed
25% of the surveillance
interval is permissible.
No mention of the
TS restriction of a minus
25% interval adjustment is made in this procedure.
However, both the
plus and minus
25% interval adjustment restrictions
are contained
in
the following procedures
-1) A-1105,
Rev.
19, Calibration and/or Test
Surveillance
Program for instrumentation/Equipment
or Safety Related
Components,
and 2) A-1106,
Rev.
6, Ginna Station Surveillance
Schedule.
Additionally, it was noted that the A-1101 procedure
contains
a licen-
see administrative limit wnich states
that the combined interval for
3 consecutive
surveillances
should not exceed
3.25 single surveillance
intervals.
This condition is not stated
in either procedure
A-1105
or A-1106.
V
1
4
12
Because
the licensee's
procedures
for performance
intervals are not
consistent either
among themselves
or with the
TS, the inspector re-
viewed the implementation of minus
25% interval adjustment limita-
tions with the licensee.
The
R&T Supervisor indicated that
he did
not consider
the
TS specified limitation as applicable
when it became
necessary
to adjust the surveillance
schedule
due to equipment avail-
ability constraints
during plant operations.
The
NRC was not aware
of any specific instances
in which the licensee
did not meet the
minus
25% TS limit on required survei llances.
The licensee
representatives
acknowledged
the above
and stated that
the appropriateness
of a
TS change
request
to address
this concern
will be reviewed.
The only other item in this area requiring licen-
see attention is an apparent
need to provide consistent
instructions
for surveillance testing interval constraints
in procedures
A-1101,
A-1105 and A-1106.
The inspector
reviewed the licensee's
implementation of TS Section
3. 10.2.6 requirement
to verify hot channel
factors against
the limits
provided in Specification
3. 10.2.2 every full power month.
This rou-
tine surveillance
is identified in the Limiting Conditions of Opera-
tions
(LCO) section of the
TS.
NRC review identified no other sur-
veillancee
tests
in the
LCO section of the
TS.
This routine survei 1-
lance is controlled in part,
by procedure
S-15. 1,
Rev.
27,
Flux Map-
ping Normal Procedure.
It was noted that the current Surveillance
Schedule
incorporated
the performance
of the flux mapping per proce-
dure S-15. 1.
However,
procedure
A-1104,
Rev.
10, Ginna Station Tech-
nical Specification Surveillance
Program,
which is used
by the licen-
see to define, categorize,
and list the procedures
that encompass
the
program,
did not include the S-15. 1 in the program.
The
R&T Super-
visor,
when questioned
by the
NRC on this condition, indicated that
this was
an apparent
oversight
and would provide
a procedure
update
to resolve this item.
Other than the minor deficiency identified
above,
the
NRC had
no further questions
or comments
on the licensee's
activity associated
with flux mapping.
A review was conducted of the licensee's
performance of TS Section
4,
Table 4. 1-1, required monthly functional testing of the
Power
Range
Nuclear
Instrumentation
System
Channels
41-44 (PT-6.3. 1 through
PT-6.3.4).
The required monthly functional tests
were conducted
as
scheduled.
The inspector
had
no further questions.
3.4
ualit
Assurance
and
ualit
Control Activities in Surveillance
Area
The
NRC witnessed
the conduct of procedures
PT-6.3. 1 through PT-6.3.4
during back shift and noted that there
was
no
gC involvement
or over-
view of these
routine surveillance
testing activities. It was noted
that these
procedures
did not contain
an "Initial Condition" to con-
tact the
gC Group prior to start of the activity as is the case
in
13
most surveillance
procedures.
As
a result of discussions
with Opera-
tions Department representatives,
the
NRC learned that the
QC Group
does
not witness routine surveillance activities conducted
on the
backshift.
This apparent
lack of
QC coverage
merits further review
by the licensee
management.
4.
Mechanical Activities
In order to assess
the the effectiveness
of the
QA and
QC activities in
Mechanical
area,
the inspectors
reviewed selected
Safety-Related
Procure-
ment,
Survei llances
and Maintenance activities.
The details of this
review are given below:
Procurement
Material Control
and Identification
The licensee's
procurement,
material control
and identification activ-
ities were reviewed to verify that the requirements
of 10 CFR 50, Ap-
pendix
B, Criteria IV, VII, VIII and XII, were adequately
implemented.
The licensee
commitment to these
requi rements i s in Technical
Supple-
ment IV to the operating license.
Technical
Supplement
IV requires:
"Evidence of review and approval of procurement
documents is recorded
on the documents
or on the attached
control form.
The attached
con-
trol form identifies to Purchasing
a procurement
method which will
ensure
that the selected
supplier is capable of providing the item or
service
in accordance
with the requirements
of the procurement
docu-
ments."
"Other off-the-shelf items, that are manufactured
to industry stand-
ards, that are typically utilized in applications other than nuclear,
and for which item acceptance
is based exclusively
on receipt inspec-
tion may be purchased
from sources
other than the approved
suppliers
list.
These other sources
may include the manufacturer
of the re-
placement part, authorized distributor for the manufacturer's
replace-
ment parts
and distributor of catalog
items which satisfy the'guide-
lines of not requiring status
on the approved suppliers list."
"Ginna Station,
General
Maintenance,
Quality Assurance
and Electric
Meter and Laboratory evaluate
the suppliers of inspection, test,
and
calibration services
which they intend to use."
To verify conformance
to the above,
the inspector
reviewed the receiv-
ing operations,
warehouse,
and purchasing activities.
All material arriving by truck is unloaded
and sorted in a small area
of the receiving building.
Here it is sorted
by reference
to the
purchase
order.
Safety-related
material is tagged with a white "Hold
for
QA Inspection" tag
and placed in the
QC inspection
room.
Items
too large for this
room o. that ar rive when the receiving area is
L
1
if
)4k
1f
lt
14
overcrowded
are sent directly to the warehouse
and receiving inspec-
tion is performed there.
It was observed that in the
gC inspection
area all items were tagged.
However,
due to the lack of space,
items
awaiting inspection,
accepted,
and
on hold were not segregated.
The
inspector did not identify any concerns
resulting
from this lack of
adequate
segregation.
4. 1. 1.
Stainless
Wire
Ro
e for Auxiliar
Bui ldin
Crane
(Purchase
Order
Nos:
10205-B-JO
and
NEG 50942)
In reviewing documentation
of recently received material, it was
noted that two coils of stainless
steel wire rope
had been re-
ceived but were not present
in the receiving area.
In reviewing
the documentation
received with the wire rope,
the following was
noted:
1.
Neither the supplier
nor the manufacturer
was
on the qualif-
ied suppliers list.
3.
The certificate
from the manufacturer
stating the product
was
undamaged
referenced
an incorrect, purchase
order number.
The manufacturer's
Test Certificates
(T-10196 dated 5/21/85)
for Chemical Analysis and Breaking Strength
referenced
the
supplier's
purchase
order to the manufacturer.
They did
not have traceability to the product (Heat,
Lot or Serial
Numbers)
or to the licensee's
purchase
order.
Observation of this wire rope in the warehouse
showed that the
only identification was
a reference
to the licensee
purchase
order
on the address
label.
The material
was not identified
with any tags
when observed
by the
NRC inspector.
A "Hold" tag
was attached
during the inspection.
Processing
of the purchase
order
was in accordance
with the
requirements
except that the control
form was not attached
to
any copy of the purchase
order.
It was available,
however.
To determine if the wire rope presently
in use
on the crane
had
been
processed
in accordance
with the requirements,
the inspector
reviewed the documentation
associated
with that purchase
order
(NEG 50942).
Neither the material
supplier
nor the manufacturer
was listed
on the gualified Suppliers List. It should
be noted
that the material
supplier
was not the
same
on P.O.
NEG 50942
as
on P.O.
NG 10205-B-JD but the manufacturer
was.
The following deficiencies
were noted:
1.
There
was
no evidence of purchase
order review and approval
as required
by the Technical
Supplement
IY to the operating
license.
~.
'4
0
2.
No certification was received stating the product was un-
damaged,
as required
by the purchase
order.
3.
The Manufacturer's
Test Certificates
(T-10196 dated 5/21/85,
the
same
number
as received with P.O.
No.
10205-B-JD) for
chemical
analysis
and breakin'g strength
referenced
the sup-
plier's purchase
order number to the manufacturer.
They did
not have traceabi lity to the product (Heat,
Lot or Serial
Number) or to the licensee's
purchase
order.
4.
There
was
no statement that the oil free requirement of the
purchase
order had
been
inspected
at receiving.
4. 1.2.
Calibration Data for Tor ue Wrench
Gau
es (Purchase
Order
NEG 49841)
There
was
no evidence that the vendor
had been evaluated for the
calibration services
provided,
as required
by Technical
Supple-
ment IV to the operating license.
Purchasing
had
no record of
a gA review of this purchase
order prior to placing
and the
vendor was not on the gualified Suppliers List.
The deficiencies identified in the paragraphs
above constitute
a vio-
lation (50-244/86-02-04).
Additionally, these deficiencies
indicate
a weakness
in the licensee's
overall procurement,
receipt
and storage
programs.
The warehouse
is used for storage,
issue of relatively large
par ts
and for stock of items not immediately
needed for issue
from other
issue stations.
Safety-related
equipment is clearly identified with
"Accept" or "Hold" tags.
Only two snubbers
were not segregated
but
were clearly identified.
No attendant
is stationed
in the area.
Access is limited to the receiving
and storeroom
personnel.
This
area
meets
the requirements
of ANSI N45
~ 2.2 for Level
B storage.
4.2
Surveillance
and Maintenance Activities
The inspector
witnessed
part of the final maintenance
check of the
"D" service water
pump.
This operation
was being performed in accord-
ance with Procedure
M11. 10, Revision
14, Major Inspection of Service
Water
Pump.
(}uality Control inspectors
were performing surveillance
inspection during this operation.
Inspector
observations
were as
follows:
1.
The procedure (Mll.10, Revision
14) was available
and being
followed.
2.
Signatures
for opera-ions
were
up to date through the operation
being performed.
16
The
pump repair data
package
was available.
Procedure
M11.10. Revision
14, indicated that the "D" pump
had
been
removed,
repaired
and replaced.
However,
review of the
maintenance
data
package
showed it was the
pump previously
removed
from the "C" loop and repaired that had
been
placed in the "D"
loop.
This was verified by comparing the
pump serial
number
on
the repair data with the
pump installed in "D" loop.
This p'rac-
tice increases
the availability of this safety-related
system
and in case of pump failure, provides
a backup that can
be quickly
installed.
The "Dimension Data Sheet" in the data
package
was reviewed.
This data
sheet listed the impeller, casing ring and bearing
diameters
and clearances.
The following deficiencies
in the
data
sheet
were noted:
There
was
no traceabi lity to the product
measured;
the individual performing the measurements
was not
identified;
and the measuring
devices
used
were not identified.
However,
on the "Fabrication
Route Card" used
by the Maintenance
Repair
Shop contained
the information above for the impeller
and casing.
In his handwritten instructions to the Maintenance
Repair Shop,
the cognizant Maintenance
Engineer specified
a clearance
of
0.012"-0.0)5"
between
the impeller and casing.
The
NRC inspec-
tor interpreted this as meaning 0.012"-0.015"
on each
side (a
difference in diameters
of 0.024"-0.030").
The engineer
and
Maintenance staff both interpreted this as
a difference in dia-
meter of 0.012-0.015 resulting in a clearance
of 0.006 per side.
Reference
to the manufacturer's
drawing confirmed that
a differ-
ence in diameter of 0.012-0.015
was correct.
This informal ap-
proach to specifying dimensions
and tolerances
indicated
a poten-
tial weakness
in the
system
used to provide technical
data to
the individuals performing operations.
The lack of formality in specifying dimensions
and tolerances
and
adequate
documentation
in mechanical
surveillance
and maintenance
records is an unresolved
item (50-244/86-02-04).
4.3
Vendor Manual Control
In paragraph
2.2.2 of the Letter to Director of Nuclear Reactor
Regu-
lation from Vice President,
Rochester
Gas
and Electric Corporation
dated
November 4,
1983 (Subject:
R.
E. Ginna
Nuclear
Power Plant,
Docket
No. 50-244) it states:
f
l,
L~
17
"Within the administrative
computer,
a vendor manual's
data
base exists which contains all of the plant's
vendor
information that is located at the station.
This data
base
will be refined to remove duplicate
and outdated
manuals.
A complete
program of vendor interface will be established
following receipt of the
INPO NUTAC report
on this issue."
When the inspector
asked to see
information from the computer data.
base,
he was informed that it was not being used,
had not been refin-
ed to remove duplicate
and outdated
manuals,
and it did contain irre-
levant information such
as standard
parts catalogs,
drawings
and pro-
cedures.
Additionally, this data
base is not controlled in accordance
with the licensee's
own
QA program requirements.
From the above, it
is apparent
that this data
base is not established
and maintained
in
accordance
with the above
licensee letter.
The licensee
stated that
a consultant
has
been hired to establish
formal vendor manual control.
This consultant is to start work February
3,
1986 with completion
scheduled for the
end of June
1986.
The licensee's
vendor manual
control
remains
unresolved
pending licen-
see action to establish
and maintain
a reliable vendor manual
data
base
~
(50-244/86-02-06)
A previous unresolved
item (50-244/85-04-02)
to incorporate
vendor owner's
group recommendations
into plant
procedures
remains
open.
The observations
in receipt,
surveillance,
and vendor manual control
.
indicate that the licensee's
efforts to enhance
the effectiveness
of
Quality Assurance
and Quality Control activities did not reach day-
to-day activities in the mechanical
area.
5.0
Electrical Activities
Selected
surveillances,
maintenance activities
and modifications were re-
viewed to assess
the effectiveness
of the licensee's
QA and
QC activities
in the electrical
area.
The details of thi s review are given below:
5. 1
Electrical
Survei llances
The safety-related
"A" and "B" battery
systems
were selected
to deter-
mine if the licensee'
electrical
surveillance
program
was in accord-
ance with NRC requirement,
Technical Specifications
and license
com-
mitments.
The batteries
were originally placed in service
17 years
ago.
The
"A" battery was replaced
during the refueling outage of March 1985.
The "B" battery will be replaced
during the upcoming refueling outage
starting
February 8,
1986.
~
'
\\
6g
18
The following documents
were reviewed
or
used
as
a basis for this
inspection:
Final Draft FSAR, dated October
1984,
Section 8.3.2 Direct Current
Power
Systems,
Safety Evaluation Report,
dated October
1983,
section
8.4 Station Battery Capacity Test Requirement,
section 8.5 D.C.
Power System
Bus Voltage Monitoring and Annunciation
Technical Specification,
Appendix
A
to Operating
License
No.
dated
December
10, 1984,section
3.7 Auxiliary Electrical
Systems,
section 4.6 Emergency
Power System Periodic Tests 4.6.2
Station Batteries
Regulatory
Guide
1. 129,
Rev. 1, Maintenance,
Testing
and Replace-
ment of Large
Lead Storage Batteries for Nuclear
Power Plants
which endorses
IEEE STD 450-1975 with certain exceptions.
Station Battery Vendor Technical
Manual
Various Battery Problems,
dated
November
14,
1984
IE Information Notice 85-74, Station Battery Problems
dated
August 29,
1985
Monthly and quarterly Survei llances
per
Procedure
PT-11 before
and after to Battery "A" replacement
Surveillance
Procedure,
PT-10.3, Station Battery "A" Load Tests
before
and after Battery "A" replacement,.
The inspector's
review of PT-10.3 load test for battery "A", prior to
replacement,
noted that terminal voltage
was 106.5 volts after 60
minutes.
This is 1.5 volts higher
than the minimum acceptance
value of
105 volts.
The licensee
noted under the
comment section of the pro-
cedure
"Readings indicate that this schedule
of change
out is con-
sistent with proper
operating practice."
This is an indication of
the licensee's
use of good operating practices.
The licensee
is revising the test procedure
to provide
a
2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> service
test instead of a
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> service test at each refueling outage.
Also
a capacity test will be conducted
every five years.
These tests
are
in accordance
with the latest revision of IEEE standard
450.
This
is another indication of the licensee's
use of good industry practices
and latest technical
information.
~,
I
+1
19
The inspector's
review of the surveillance
procedures
PT-11 listed
above indicated that the licensee
was correcting the specific gravity
readings for neither temperature
deviations
from 77 degrees
F nor
level deviations
from the full electrolyte level.
Correction for
both temperature
and level are specified in the vendors instruction
manual for the
new
batteries.
The level correction
was not addressed
in the old battery vendor instruction manual.
The inspector discussed
this concern with the licensee's
representatives
and the licensee'
representatives
acknowledged
the inspector's
concern.
The load test PT-10.3 requires
the
gC be notified before the test is
conducted.
There are
no gC hold points or signoff within the procedure
to verify if gC personnel
was present during the test.
However, the
data of PT-11 is reviewed
by the Results
and Test Department.
The
test is reviewed by both the Electrical
Foreman
and the Results
and
Test Supervisor.
IEEE Standard
450 specifies
surveillance of battery cell connection
resistance
as
an industry-accepted
good practice for establishing
operability of station batteries.
However, this surveillance is not
included to the Licensee's
program.
The concerns of electrolyte temperature
and level corrections of the
specific gravity and surveillance for battery cell connection resis-
tance together constitute
an unresolved
item (50-244/86-02-07).
5.2
Electrical Maintenance
The inspector witnessed
the maintenance
of the "B" component cooling
pump,
480 volt, breaker to determine if the licensee's
electrical
main-
,tenance
program
was in accordance
with the
NRC requirements,
Technical
Specification
and license
commitments.
The following documents
were reviewed or used
as
a basis for this
inspection:
Final Draft FSAR, Section 8.3. 1. 1.3 The 480-Volt System
Technical Specification, Section 3.7 Auxiliary Electrical
Systems
Electrical Preventive
Maintenance
Program
Procedure
No A-1005,
Revision 0, Effective February
27,
1984 for 1984
Electrical Preventive
Maintenance
Program
Procedure
No. A-005,
Revision
1, Effective date January
11,
1985 for 1985
4
~
'~t
20
DB-25, DB-50,
and
DB-75 Circuit Breaker Maintenance
and Overcur-
rent Trip Device Test and/or Replacement,
Procedure
No. M-32. 1,
Revision 20, Effective date
February
5,
1985 for Standby Auxili-
ary Feed
Pump (dated
March 2,
1985)
and Charging
Pump
1A (dated
March 6,1985).
Nuclear
Power Experience
PWR Electrical
Systems
Ginna
1972 thru
1985
NRC Resident
Inspector Morning Reports
1978 thru 1985
Licensee
Event Reports
1978 thru 1985
There were only 19 electrical failures that required corrective main-
tenance,
including
2 loss of offsite power events,
during
a
13 year
period.
This low need for corrective maintenance
after failure in-
dicated that the licensee's
preventive
maintenance
program was effective.
The
1984 and
1985 electrical
preventive
programs
indicated that the
required maintenance
activities were conducted
as scheduled.
The inspector
observed
during the maintenance
of the "B" component
cooling
pump breaker that both the electrician
and the
gC personnel
failed to verify that the calibration period for the megger which was
used to determine
insulation resistance
of the breaker,
expired
on
April 27,
1984.
The procedure
did not require the measured
value to
be recorded.
It also did not specify the acceptance
criteria for the
resistance
measured.
The licensee
records
indicated that the
above
Biddle Cat.
No.
21805-1,
has
been missing since
1985.
However, this megger
was avai 1-
able for use
in. the auxiliary building.
This megger
was subsequently
removed
from the auxiliary building for recalibration.
A check of the
was
made against
a standard
resistance,
Biddle Cat.
No. 72-6340.
The megger reading
between
1 and
10 megohms
read
15% lower.
This er-
ror is in the conservative direction.
The licensee
procedure for ca-
libration control
exempts
from calibration.
However, the in-
spector
noted that certain
were calibrated periodically.
This
indicates
an inconsistency
in the licensee's
calibration practices.
The omission of the minimum acceptable
resistance
value in procedure
M-32. 1 and the
use of test equipment that was not calibrated
since
1983 collectively constitute
a violation (50-244/86-02-08)
against
the acceptance
criteria requirements
of 10 CFR 50, Appendix B, Crite-
rion V. It should
be noted that the licensee's
overall calibration
and control
program for measuring
and test equipment
was identified
as
a licensee
weakness
in
NRC operational
assessment
team inspection
50-244/85-04.
'X,f e
~ ~s
~6
J
Rw
e
21
Upon identification of this calibration concern
by the
NRC, the per-
sonnel
repeated
the resistance
measurements
using
a meggering unit
whose calibration
was current.
The results
were acceptable.
5.3
Electrical Nodifications
Selected electrical modification activities were reviewed to ascertain
that these activities were in conformance with the requirements
of the
Technical Specifications
and
The electrical modifica-
tions that the licensee
planned for this refueling outage were:
Replace
the "B" safety related battery
and install
a
new 200
ampere
charger
Remove the
115KV lines control
benchboard
from the control
room
and install the Safety Parameter
Display System
Install
new control
panel
for the "A" emergency diesel
generator
in the diesel
generator
room.
Switches
on the panel will provide
electrical isolation
and control during certain fire conditions.
The design
package for the "A diesel
generator
emergency control panel,
EWR 4136,
was reviewed.
The general
design criteria, safety evalua-
tion and drawing were found acceptable.
The inspector
observed
the work associated
with the Replacement
of
115KV Benchboard
Sections,
EWR 4067.
This work
was done by a con-
tractor.
The calibration for termination tools were current.
The
inspector
noted that the wire termination
sheets
(Circuit Schedule)
which were part of the design
change
package
had the
same signature
for both the preparer
and the reviewer.
This is contrary to the
requirements
of procedure
No.
QE303,
Revision 8,
November
12,
1985
"Preparation,
Review and Approval of Engineering
Drawings" for inde-
pendent verification of safety related
design
and construction
draw-
ings
and this is
a violation (50-244/86-02-09).
5.4
A/
C Involvement in Electrical Area
The inspector
observed that
QC personnel
were verifying wiring changes
that were being
made in the control
room,
as part of Engineering
Work Request 4067 for the
115KV benchboard
replacement.
The work activity
and
QC inspection
were being
done
by contract personnel.
Discussions
with the
QC personnel
indicated that they had adequate
work experi-
ence, training and understanding
of job function.
The inspector
also
noted that other contract
QC personnel
were witnessing cable pulling
activities in the relay
room and concluded that the
QC coverage
was
evident.
e
22
As stated previously,
the contract
QC inspector
assigned
to breaker
maintenance
did not observe
the
use of an uncalibrated
This
QC inspector
had previous work experience
in the electrical control
area
and the experience
was adequate
for the
QC inspection function.
However,
the
QC inspector did not use
separate
lists of inspection
attributes
to provide
an independent
auditable
QC record of the main-
tenance activity.
The licensee
QC personnel
received instructions
in
fundamentals
of electrical
engineering.
However, the application of
this theoretical
instruction to routine
QC activities was still being
formulated.
The inspector
reviewed the latest
QC surveillance report for the im-
plementation of procedure,
A 1201,
Instrument,
Control
and Electrical
Maintenance
and Test Equipment
(MME) scheduled recall for calibration.
This audit indicated that the MME was being calibrated
as
shown
on
the schedule.
This was further verified by the inspector
as discussed
in Section
7.0 during the closure of the inspector followup item
50-244/85-04-05.
The findings in paragraphs
5. 1, 5.2 and 5.3 above indicate that the
licensee's
efforts to enhance
the effectiveness
of QA and
QC activi-
ties
have not reached
the day-to-day activities in electrical
area.
6.0
Health
Ph sics
and Chemistr
Activities
To assure
the effectiveness
of Quality Assurance
and Quality Control acti-
vities in Health Physics
and Chemistry areas,
the inspector
reviewed the
following activities:
1.
Routine Health Physics
Surveys
and monitoring
2.
Low level radwaste
shipment
3.
Primary Chemistry analyses
The procedures
and records
reviewed included:
Logs of chemistry
and health physics activities
Procedure
No. PC-1.3,
Revision
16, Daily Chemistry Analysis
Results
Procedure
No.
PC-25. 1. 1, Revision 3, Operation of Post Accident
Sampling
System
under
normal conditions
HP-7.31,
Revision 4. Daily Instrument
Source
Checks
I
~
a '
23
RD-10.4. 1,
US Ecology Radioactive
Shipment
Record
RD-10.6, Revision
16, Shipping of Low Level Radioactive
Waste
RD 10.8,
Compliance
The details of the review are given below:
Routine Health
Ph sics
and Chemistr
Activities
The inspector
reviewed the daily logs of Health Physics
and Chemistry
activities to determine
the problem identification and solution in
these
areas.
The problems identified in each shift were adequately
discussed
and recurring problems were highlighted.
Problems identi-
fied during health physics
surveys
were promptly reported
and forward-
ed for action to the appropriate
organizations
through the initiation
of trouble report.
For example,
on September
9,
1985,
the Health
Physics
survey around the boric acid filters indicated
above
normal
readings.
A trouble report (85-2647)
was issued
on September ll,
1985 and the filters were replaced
on September
18,
1985.
The inspector
noted that the daily Chemistry analyses
were conducted
in accordance
with procedure
PC-1.3
and reported in the daily morning
meeting
by Hanager,
Health Physics
and Chemistry.
The personnel
per-
forming Health Physics
and Chemistry were knowledgeable
in the tech-
nical
and procedural
requirements.
The results
were trended to iden-
tify anomalies.
When anomalies
were detected,
efforts were initiated
to investigate
and correct the conditions that led to the anomaly.
The inspector
noted that
a technician
made
a data entry correction in
the isotopic analysis of the reactor coolant by crossing
out the
wrong entry, entering
the correct entry and initialing in accordance
with the procedure
requirement for such error correction.
Technicians
are solely responsible
for the accuracy of the data taken.
Supervision
reviews the record
and depends
on trend for detecting
errors
and deviations.
The licensee
does
not consider it necessary
to use verification of data
by another technician or gC to minimize
personnel
error.
The health physics
and chemistry personnel
stated
that the activities could be benefited
by the survei llances of know-
ledgeable
gC technicians.
The inspector
noted that
some of the
(}C
technicians
did not verify the adequacy
of the actions
they witnessed
as discussed
in paragraph
6.2 below.
The
gC organization is address-
ing this concern
by recruiting technically competent
technicians
and
providing necessary
training to the existing technicians
to increase
the subject matter expertise.
Cl
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11
0
6.2
Low Level
Radwaste
Shi
ment
The inspector
reviewed activities associated
with shipment
No. 85-84.
.The shipment
was processed
in accordance
with procedure
RD-10.6.
The
required
dose
surveys
were done
by a technician
and witnessed
by a
gC
technician.
However,
the procedure
steps
were signed off by a health
physicist
who was not present
when these
surveys
were made.
The health
physicist stated that his initials indicate that the step
was executed
by someone
under his cognizance.
Similarly, the
gC technician
stated
that his hold point sign-off merely indicates that the action was
com-
pleted
by the technican while the
gC technican
was physically present.
The hold point sign-off does
not assure
the technical
accuracy of the
'survey.
The health physicist stated that
he holds the technician
solely responsible
for the reading.
Neither the health physicist nor
the
gC technician
had any responsibility to verify the accuracy of
the readings
recorded
by the technican.
The
gC supervisor
stated
that
he expected
his technicians
to verify the accuracy of any readings
taken while
QC was present.
However,
in this case,
the
gC technician
stated that
he did not verify the accuracy of the reading
recorded.
The inspector discussed
the matter with licensee
management.
A licen-
see supervisor
stated that they were aware of the lack of technical
knowledge
in some
gC technicians
and they expect to correct this situ-
ation by hiring technically competent
gC technicians
and using "back-
to-the basics" training sessions.
As
a result of a recent
NRC violation and problems identified in low
level radwaste
shipments,
the overall health physics
and chemistry
activities were conducted with noticeable
awareness
to the require-
ments
and attention to details.
A recent technically oriented
gA
audit in health physics
area
was well received; it assisted
the
health physics organization
to realize its weaknesses
and take actions
to strengthen
the weaknesses.
Except for the level of gC involvement
and verification of measurements
taken
by technicians,
the inspector
found the health physics
and chemistry activities to be conducted
in
accordance
with the licensee
procedures
and applicable regulatory
requirements.
No violations were identified.
As in other
areas
of this inspection,
the inspector
noted that the
licensee's
efforts to enhance
the effectiveness
of gA and
gC activ-
ities did not reach the working level.
The Health Physics
and
Chemistry staff acknowledged this observation.
7.0
Licensee Action on Previous Identified Items
Closed
Ins ector Follow Item
85-04-05
Calibration
and Control of
Measurin
and Test
E ui ment
MKTE
The
the
ing
ing
inspector
reviewed
METE as required
by procedure
A-1201 and found that
calibration of those ATE identified in Inspection
Report 85-04 as be-
out of calibrations
were current.
The inspector
reviewed the follow-
calibration test reports:
~
5 ~
~
25
Circuit Breaker Test Set (Mulit-Amp) Model
No.
CB-7150 Serial
No.
18553,
Cal.
1-18-86
Circuit Breaker Test Set (Multi-Amp) Model
No.
CB-8160 Serial
No.
34211,
Cal.
1-18-86
Relay Test Set (Multi-Amp) Model
No.
MS-2 Serial
No., 32471 Cal.
1-18-86
This item is closed.
8.0
Unresolved
Item
Unresolved
items are
items about which more information is required to as-
certain whether they are acceptable,
violations or deviations'nresolved
items identified during this inspection
are discussed
in paragraphs
4.2 and
5.1.
. 9.0
Exit Interview
The inspection
team met with licensee
representatives
denoted
in paragraph
1 at the conclusion of the inspection
on January
31,
1986.
The summarized
purpose,
scope
and findings were presented.
At no time was written mate-
rial provided by the inspector to the licensee.
l,>
~
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1 VPf
"C
ATTACHMENT 1
DETAILS OF THE VESSEL HEAD AND INTERNALS LIFTING RIGS
INSPECTION
Licensin
Commitment
Licensing commitments
due to
NRC concerns
associated
with the issue of Con-
trol of Heavy Loads for Special Lifting Devices,
were
made
by the licensee
in it's letter to
NRC dated
March 2,
1983 which stated that
..."RGKE has
implemented
an inspection,
testing
and maintenance
program to insure con-
tinued compliance with ANSI N14.6-1978.
This program will require visual,
inspections
annually (not to exceed
15 months,
consistent with permissible
intentions for Technical Specification Surveillance).
Nondestructive
exa-
mination of critical welds will also
be done every ten years."
It appears
that the
above licensee
commitments
were to be achieved
by their develop-
ment and implementation of procedure
MHE-1100-1,
Rev.
0.
Additionally,
procedure
A-1011,
Rev.
5,
Equipment Inspection
Period
and Lubricant List,
required the
RVHLD and
RVILD to be inspected prior to refueling.
1983 Refuelin
Outa
e Activit
The licensee's
contractor for refueling developed
procedure
RF-58,
Rev.
0
dated
March 31,
1983 to cover Cycle XII-XIIIrefueling operations.
Step
7.2.30 of this procedure
indicated that the
RYHLD was installed
as per
paragraph
9.2.7,
and
was signed off as being complete
by
a licensee
con-
tractor
on April 28,
1983.
Paragraph
7.2.42 indicated that the reactor
vessel
head lift preparations
were complete
and
was signed off by the
same licensee
contractor
on May 1,
1983.
This was followed by gC Hold
Point No.
1 that referred to the Process
Control Sheet
in paragraph
8.2,
with the hold point attesting that the reactor vessel
head lift prepara-
tions were complete.
The hold point was signed
by
a licensee guality
Engineer
on May 1,
1983.
In procedure
RF-58,
paragraph
8.2, (}uality Assurance
Inspection
Program,
there were
two hold/witness
points that referred to procedure
paragraph
7.2.42.
The first stated that the reactor vessel
head lift preparations
were complete
and
was signed
by a gA representative
on May 1,
1983.
The
second
stated that the structural integrity test of reactor vessel
head
lifting devices
was performed
and results
were satisfactory.
This was to
be signed
by
a
gC representative.
This was also
signed
on
May 1,
1983 by
the
same
gA individual.
Paragraph
9.2.7.A.4 indicated that the step,
lifting of the reactor vessel
head
2 inches,
was completed
and signed off
on
May 1,
1983.
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r,
4'll
e
Attachment
1
Procedure
MHE-1100-1,
Rev.
0 dated
March 25,
1983,
Inspection
and Mainten-
ance of Special Lifting Devices,
required in procedure
paragraph
5. 1.5
"... Inspecting
personnel
shall
use the instructions
and form( s) provided
in this instruction for the inspection of these Lifting Devices."
Proce-
dure paragraph
5.3. 1, required ..."Visual examination, prior to use.
a.
After re-assembly
of the "Reactor
Vessel
Head Lifting Device",
visually examine:
1.
The clevis plate to leg fillet welds at the bottom end of
the legs.
2.
The support lugs to ring girder fillet welds
on the platform.
b.
After checking all bolted connections
on the "Reactor
Vessel
Internal
Lifting Device" visually, examine:
1.
Bottom lugs to top of support plate fillet welds
on the support
plate assembly.
2.
Side lug to support pipe fillet welds
on the support pipe.
3.
Spreader
lug to leg assembly fillet welds."
In addition,
paragraph
5.3.2,
Visual Inspection
Upon Lifting, required the
Rigging Foreman
to perform
a visual inspection of the welds specified in
paragraph
5.3. 1 under load.
According to the procedure,
these
welds were
to be examined for cracks
using dye penetrant
or magnetic particle tests
every
10 years.
A review of the completed
records for the weld inspections
conducted
in
1983 indicated the following:
Prior to the reactor vessel
head lift on May 1,
1983,
the licensee
performed
a visual inspection of the
RVHLD on April 7,
1983.
The
completed
documentation
form for the Inspection of the
RVHLD con-
tained in procedure
MHE-1100-1 indicated that
1) visual inspection
was performed
from the operating level,
and 2) that the
described
in a. 1 and a.2
above
were scheduled
to be performed later
in the outage.
According to the
MHE Foreman,
the visuals were essen-
tially bolting checks utilizing binoculars
from the operating level.
This indicated
a misunderstanding
of the procedure
requirements
by
the
MHE foreman.
The
HDE documentation
for RVHLD showed that
PT inspections
were per-
formed only on the Link Lugs to Sling Assembly welds
on May 12,
1983.
However,
these
welds were not incorporated
in MHE-1100-1 at that time.
~ ~
E
e.
Attachment
1
The above indicates that visual inspections
of specified welds were
not adequately
performed
by the licensee after the reassembly
of the
RVHLD, prior to use of the
RVHLD, and after lifting the
head utilizing
the
RVHLD, as required
by procedure
MHE-1100-1,
Rev.
0.
Regarding
the inspections
performed
on the RVILD, the completed
documentation
form for the inspection of the
RVILD contained
in
procedure
MHE-1100-1 indicated that 1)
a visual inspection
was
performed
from the operating level of bolted connections
on
April 7,
1983
and 2) that the
in b. 1,
b.2 and b.3 above were scheduled
to be performed later during
the outage.
A PT examination
record for the
RVILD documented
that the licensee
performed all weld
NDE inspections
(10 year)
stipulated
in procedure
MHE-1100-1 on May 27,
1983.
Prerequisites
for fuel movement were complete
on May 2,
1983.
This included
removal of the reactor vessel
upper internals uti-
lizing the
RVILD.
The records did not indicate that visual in-
spections
of specified welds were performed
by the licensee
either prior to use or upon lifting of the reactor. upper inter-
nals utilizing the
RVILD, as required
by procedure
MHE-1100-1,
Rev.
0.
As stated earlier,
there
was
a hold/witness point in procedure
RF-58
to confirm that the structural integrity of the
RVHLD was verified
with satisfactory results.
The fact that the hold/witness point was
signed off without comment
suggests
the lack of a proper review and
adequate
understanding
of the requirements
by
QC personnel.
QC did
not review and assure
that the structural integrity verification was
acceptable.
3.
1984 Refuelin
Outa
e Activit
The licensee's
refueling contractor developed
procedure
RF-59,
Rev.
0 dated
March 1,
1984 to cover
Cycle XIII-XIVRefueling Operations.
All reactor
disassembly
procedures
for the
RVHLD structural integrity check were iden-
tical to those
enumerated
above in procedure
RF-58.
During the
1984 re-
fueling outage,
the reactor vessel
head
and the upper internals
were lifted
on April 11,
1984.
As in 1983,
procedure
MHE-1100-1,
Rev. 0,
was to be uti-
lized for the weld inspections
to assure
the structural integrity of the
RVHLD and
RVILD. Therefore, all previously enumerated
requirements
of this
procedure
were applicable during the
1984 refueling outage.
~
~ >
Attachment
1
A review of the records
for the
1984 weld inspections identified the
following:
The form in MHE-1100-1 documenting
the visual inspection prior to
lifting the
RYHLD was signed-off
on March 9,
1984 by a Level II
Inspector
and the
MHE Foreman.
This form indicated that the visual
inspection
was not feasible
because:
1) the support lug to ring
girder fillet weld was not accessible
due to construction inter-
ferences
by an installed platform,
and 2) the clevis plate to leg
fillet welds were covered with lead blankets.
Another note
on the
same
form indicated that the inspection of the
RVHLD had
been can-
celled for the current outage,
and the Level II inspector
was in-
formed of this cancellation
on March 6,
1984.
Weld examination
records further indicated that
a visual examination
was performed
on
RVHLD Link Lugs to Sling Assembly
on March 6,
1984, although this
examination
was not required
by the current procedure.
The records
also
showed that visual
and
PT examinations of clevis plate to leg
fillet welds were performed
on April 12,
1984 after the reactor
vessel
head lift.
As in 1983, specified welds were not visually inspected
by the licen-
see after the reassembly
of the
RVHLD, prior to use of the
RVHLD, or
upon lifting of the
head utilizing the
RVHLD as required
by procedure
MHE-1100-1,
Rev.
0.
The completed documentation
form for the inspection of the RVILD,
which was signed
by the Level II inspector
and
MHE Foreman
on March
7,
1984 indicated that the bolted connections
were inspected
and
found acceptable.
As in 1983, it appeared
that visual inspections of specified welds
were not performed
by the licensee either prior to use or upon lift-
ing of the reactor
upper internals utilizing the RVILD, as required
by procedure
MHE-1100-1,
Rev.
0.
The
QC hold/witness point in procedure
RF-59, to confirm the struc-
tural integrity of the
RVHLD, was as ineffective as in 1983.
However,
a
QA Audit of refueling activities,
84-15:SB conducted
during the
period of March 15,
1984 to May 25,
1984 identified (AFCAR, Finding
No. 2), that the
RVHLD and
RYILD were not properly inspected
prior to
refueling in 1983
and
1984.
Additionally, it was identified that
Hold Point Ho. 2, in procedure
RF-59,
paragraph
7.2.42,
which attest-
ed to the structural integrity of the
RVHLD, was inadequate
in that
procedure
MHE-1100-1 was not correctly utilized to accomplish
the
inspection.
l
)P,
Attachment
1
AFCAR, Finding No. 2, provided the following information:
1) the
MHE
Foreman
confirmed that
RVHLD inspections
could not be performed
as
noted
by Level II inspector
on the respective
form, 2) the inspec-
tions required
by procedure
RF-59,
paragraph
7.2.42,
was to be per-
formed by the
MHE group according to the Maintenance
Manager,
3) the
gC inspector
signing the hold point was not aware that the inspection
in question
was to be in accordance
with procedure
MHE-1100-1 and re-
lated to procedure
A-1011, 4) both procedures
RF-59 and A1011 did not
identify the
MHE Group's responsibility required
by procedure
MHE-
1101-1,
and 5) procedure
RF-59 did not require
an inspection of the
RVILO prior to lifting the reactor vessel
internals.
C
The Audit's "Recommended Actions" suggested
the following:
a
~
Revise procedure
A-1011 to properly address
ten-year
and annual
inspection
requirements
with reference
to procedure
MHE-1100-1
b.
Provide clarification in future
RF procedures
to assure
the
RVHLO and
RVILO inspections
are properly performed prior to
lifting the reactor vessel
head
and internals.
c.
Provide administrative controls to assure
appropriate
Ginna
personnel
are
aware of the status of lift rig inspections.
The recommendations
of the
AFCAR, Finding Ho. 2, of audit 84-15:SB
was assigned
to the Ginna Station organization for corrective action.
Station personnel
responded
with the following corrective actions:
a.
A procedure
change
notice to A-1011 has
been initiated.
This
will address
the
10 year
and yearly inspection
requirements
as
recommended.
A change
has
been drafted to be incorporated
into Cycle XIV-XV
Refueling Procedure
in Section
7
~ 0 "Performance".
The change
will read
as follows "All applicable
steps of procedure
MHE-
1100-1
have
been satisfactorily completed for the
RVHLD and
RVILD."
A note will be added that states
"Completion of MHE
-1100-1 will be verified by appropriate
MHE personnel".
c.
Future
RF procedures will be clarified to provide the necessary
administrative control to assure
that appropriate
Ginna person-
nel are
aware of lifting rig inspections.
"l
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~
4
Attachment
1
It should
be noted that the
gA engineer
who prepared
the Audit Report
84-15:SB provided sufficient details to develop effective corrective
actions.
However, the corrective actions
by the Station were inef-
fective in that:
(1) item c was not implemented
and (2) item b did
not specify that the hold/witness point in paragraph
8.2.2. of the
RF
procedure
should confirm the completion of MHE-1100-1 procedure
steps.
From the above, it is apparent that the finding from Audit 85-11:JB
was
a repeat finding and the licensee's
corrective
measures
were not
effective to assure
that critical welds would be inspected.
4.
1985 Refuelin
Outa
e Activit
The licensee's
refueling contractor developed
procedure
RF-60,
Rev.
0 dated
March 4,
1985 to cover Cycle XIV-XV Refueling Operations.
All procedural
requirements
pertaining to the reactor disassembly
as they relate to the
performance
and verification of the
RVHLD and
RVILD structural integrity
checks
were identical to those
enumerated
above in procedures
RF-58 and
RF-59 for the
1983
and
1984 refueling outage,
respectively,
with the ex-
ception of a
new step 7.2.30a,
which states..."All applicable
steps of
procedure
MHE-1100-1 have
been satisfactory
completed for the Reactor
Ves-
sel
Head Lift Device and
and Upper Internals Lift Device.
Note:
Comple-
tion of MHE-1100-1 will be verified by appropriate
MHE personnel."
This
step
was signed
by the
MHE Foreman
on March 5,
1985.
On March 9,
1985 the
gA Hold Point No.
1 immediately after paragraph
7.2.42
was signed
and it
verified
that the reactor
vessel
head lift preparations
were complete.
(i.e., Structural integrity of reactor
vessel
head lifting devices
was
performed
and results
are satisfactory).
During this outage
Revision
1 to procedure
MHE-1100-1 was used.
This re-
vision of the procedure
required in paragraph
5.3. 1 ..."Visual examination
(annual) prior to use.
( Item numbers refer to weld groups
on respective
figures).
a.
After re-assembly
of the "Reactor Vessel
Head Lifting Device" (Figure
10) tripod assembly
to the lower platform assembly,
visually, examine:
1.
The clevis plate to leg fillet welds at the bottom end of the
legs.
2.
The support lugs to ring girder fillet welds
on the platform.
(Exposed Area)
3.
Link Lugs to Sling Assembly Melds.
b.
After checking all bolted connections
on the "Reactor Vessel
Internals
Lifting Device" (Figure 3) visually, examine:
i>
~i
a
Cl
r
I
Attachment
1
1.
Bottom lugs to top of support plate fillet welds
on the support
plate assembly.
2.
Side lug to support pipe fillet welds
on the support pipe.
3.
Spreader
lug to leg assembly fillet welds.
4.
Leg Assembly Outer Tube to Adapter Welds.
5.
Outer Tube to Guide Sleeve
Welds."
The requirement
to visually inspect the welds while lifting devices
were
under load was deleted
from the current revision of MHE-1100-1.
A review of the records for 1985 weld inspections
indicated:
The reassembly
of the
RVHLD and the reactor
vessel
head lift, were
done
on March 9,
1985.
The Link Lug to Sling Assembly Welds were
visually inspected
on March 5,
1985.
This represents
only 3 of the
9
welds required to be visually inspected.
Therefore, it appears
that
visual inspections
of all specified welds were not performed
by the
licensee either after reassembly
of the
RVHLD or prior to its use
as
required
by procedures
MHE-1100-1,
Rev.
1 and A-1011,
Rev.
7.
The licensee
provided
no records that would indicate that weld
inspections
were performed
on the
RVILD.
As in 1983
and
1984, all critical
RVHLD welds were not visually in-
spected
by the licensee prior to use of the
RVHLD as required
by
procedures
MHE-1100-1, .Rev.
1 and A-1011,
Rev.
7.
The hold/witness
point in procedure
RF-60, to confirm the structural integrity of the
RVHLD and
RVILD, appeared
to be almost
as ineffective as in 1983 and
1984.
QA Audit 85-11:JB
was reviewed
and it had the following
deficiencies:
The
AFCAR did not identify that this was
a recurring finding.
The lack of procedural
adherence
by the
MHE Group was not
addressed
in the recommendations
or corrective actions.
The ineffectiveness
of corrective action for the finding
in 1984 audit was also not addressed.
The continued ineffectiveness
of the
QC hold/witness points was
not addressed
by the
AFCAR.
The
QA organization
opted to rely on
an informal corrective
action statement
and tracking
system for this finding .
The findings detailed
in this attachment
are
summarized
in paragraph
3.2. 1 of the report.
4i uw