ML17254A542
| ML17254A542 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/30/1985 |
| From: | Bettenhausen L, Bissett P, Dragoun T, Ebneter S, Napuda G, Shaeffer M, Wen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17254A539 | List: |
| References | |
| 50-244-85-04, 50-244-85-4, NUDOCS 8509100110 | |
| Download: ML17254A542 (39) | |
See also: IR 05000244/1985004
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-244/84-04
Docket No.
50-244
License
No.
Licensee:
Rochester
Gas 5 Electric Co.
49 East Avenue
Rochester
14649
Facility Name:
R.
E. Ginna Station
Inspection At:
Ontario and Rochester,
Inspection
Conducted:
February
5-15,
1985
Inspectors:
Paul Bissett,
Reactor
Engineer
ate
Thomas
Drag
n,
a iatio
Specialist
PWR-RPS,
EPRPB,
DRSS
date
eorg
Napuda,
Lead Reactor
Engineer
Michael Schaeffer,
Reactor
Engineer
ate
date
Peter
Wen, Reactor
Engineer
date
Lee H. Bettenhausen,
Chief,
Operations
Branch,
Branch
date
Approved by:
S.
D. Ebneter,
Director,
Division of Reactor Safety
d te
EI509f00110 860830
ADOCN, 05000240
8',
PDR:
TABLE OF CONTENTS
1.0
Inspection
Summary
1. 1
Summary
1.2
Inspection Objectives
1.3
Inspection
Findings
1.4
Persons
Contacted
~Pa
e
2.0
Maintenance
2. 1
Mechanical
Maintenance
2.2
Electrical Maintenance
2.3
Instrumentation
and Control Activities
5
8
11
3.0
Surveillance
3. 1
Operations
3.2
Results
and Test Group
3.3
Reactor Engineering
12
13
14
16
4.0
Radiological
Controls
equality Assurance
Program
5. 1
Audits and Vendor Surveillance
5.2
equality Control
5.3
Warehouse Activities
16
19
19
21
22
6.0
Other Organizations
and Activities
6.1
Offsite Safety
Review Committee
6.2
Engineering
Support
6.3
Trending
and Reporting
7.0
Management
Meetings
22
22
23
23
~y
1. 0
SUMMARY AND INTRODUCTION
1
~ 1
Ins ection Summar:
Ins ection
Conducted
Februar
5-15
1985
Re ort No. 50-244/85-04
I
d:
i
t
i
A
T
maintenance activities and
such related activities
as quality control,
quality assurance,
radiological protection
and engineering
support.
The
inspection
involved 397 hours0.00459 days <br />0.11 hours <br />6.564153e-4 weeks <br />1.510585e-4 months <br /> onsite
by six region-based
inspectors.
Results:
One violation was identified (fai lure to accomplish preventive
maintenance
reviews
on valves).
Three weaknesses
were found (documenta-
tion of maintenance activities,
slow implementation of maintenanch train-
ing programs
and deficiencies
in the control
and calibration of measuring
and test equipment).
Three notable strengths
of licensee
programs
were
identified (a strong
commitment to ALARA, thorough
and safety-conscious
reviews
by the Nuclear Safety
and Review Board and e'xperienced,
well-
qualified plant staff members).
1.2
INSPECTION OBJECTIVES
This inspection
involved
a multidisciplinary examination of maintenance
and surveillance activities.
In each functional
area
inspected,
the con-
duct of act'ivities, the qualification of staff members,
the interactions
with other functional areas,
the development of and adherence
to work
procedures
and the documentation
and analysis of trends
and data
were
examined.
Mechanical, electrical
and instrument/control
maintenance
and
surveillance activities conducted
by operations
and results
and test
personnel
were selected
for inspections
Personnel
were interviewed; pro-
cedures
were reviewed
and examined in use;
on-going activities were
inspected;
and,
documents,
training data,
and qualifications were reviewed.
The information gathered
was then
assembled
by inspection
team
members
to
obtain the basis for an operational
assessment
of the conduct of
maintenance
and surveillance at Ginna Station.
1. 3
INSPECTION FINDINGS
Safety-related
maintenance
is performed expeditiously
and
conscientiously
by well-qualified personnel.
(Strength)
Recordkeeping
in several
areas of maintenance
- Maintenance
Work
Requests,
maintenance
history files and closeout of quality control
surveillance
findings - is incomplete
and not timely.
(Weakness)
Preventive
maintenance
for rotating equipment
and for valves
was
being controlled,
performed
and documented.
However,
the review
functions of A-1015 for valves were not being done.
(Violation)
A well-defined training program for maintenance
staff has
been
developed,
but has not been
implemented.
(Weakness)
Calibration
and control of mechanical
measuring
and test equipment
was adequate.
Discrepancies
in the calibration procedures
were
noted.
Several
discrepancies
in the calibration
and control of
electrical
measuring
and test equipment were identified.
(Weakness)
Reactor trip breaker testing
was performed with no difficulties.
Plant personnel
were familiar with procedures
and results.
However,
there
was
no procedural
requirement for trending data
as
had been
committed to in a licensee letter.
(Unresolved
Item)
Information exchanges,
meetings
and informal communications
were
observed
to be viable and effective.
Test result data
and trending information was readily available to
Results
and Test staff.
Outage radiation exposure
planning is thorough,
although
accomplished
informally.
A strong
commitment to radiation safety
and
ALARA is evident.
(Strength)
Acceptability of audit finding invalidations for the triennial fire
protection audit will be examined
by NRC.
(Unresolved
Item)
Onsite inspection
and surveillance
exceeds
QA program requirements.
Nuclear Safety Audit and Review Board overviews are thorough,
detailed,
well-planned
and competent.
(Strength)
An ambitious flow diagram
upgrade
program using
a computer-based
drawing and data
base
system is nearing completion.
This is one
measure of strong engineering
support for plant activities.
Trending, analysis
and reporting for station
events
done under
supervision of the Operational
Assurance
Engineer are thorough
and
provide useful outputs.
Deficiencies in reporting of data for the Nuclear Plant Reliability
Data System
have
been
recognized
and are being addressed.
In sum, the team found maintenance
and surveillance activities at
Ginna Station to be conducted
by an experienced,
well-qualified staff
through
a thorough
and controlled management
system.
Some minor
deficiencies
in review of preventive maintenance,
recordkeeping
and
record handling
and responses
to quality control reports
were identi-
fied in the course of this inspection,
as well as the notable
licensee
strengths
mentioned
above.
PERSONS
CONTACTED
~C. Anderson,
QA Manager
J.
Bodine, Administrative Manager
"L. Boutwell, Maintenance
Manager
- C. Edgar,
18C Supervisor
- D. Fi lkins, Manager
HP 5 Chemistry
- J. Hutton, Mechanical
Engineer
- R. Kober, V.P. Electric and
Steam Production
- J. Larizza, Operations
Manager
"T. Marlow, Steam Generator
Project Manager
- R. Mecredy,
Manager Nuclear Engineering
- K. Nassauer,
QC Inspection
Supervisor
"C. Peck,
Nuclear
Assurance
Manager
"J. St. Martin, Station
Engineer
'T. Schuler,
Maintenance
Manager
"B. Snow, Superintendent
Nuclear Production
- S. Spector,
Assistant Superintendent
- W. Stiewe,
QC Engineer
NRC
- W. Cook, Senior
Resident
Inspector
The personnel
identified with a asterisk(~)
attended
the exit interview
on February
15,
1985.,
Other managers,
supervisors,
corporate
and plant
personnel
were contacted
during the course of the inspection
as
activities involved their areas.
2.0
MAINTENANCE
The Maintenance
Manager is responsible
for the overall conduct of
maintenance activities.
Fifty-three persons
assigned
to various
sections carry out these activities.
Maintenance activities at the Ginna station are conducted
by three func-
tional disciplines:
mechanical,
electrical
and instrumentation
and control
(I&C). These three disciplines
and the functional
and administrative
controls governing their activities were reviewed for conformance
to
applicable
codes,
standards
and procedures.
The paragraphs
which follow document
the inspector's
review of each of
these disciplines
and their integration into the operation of Ginna
station.
Procedure
A-1603, rev.
6, establishes
the system for initiating, priori-
tizing, scheduling
and controlling corrective maintenance.
Any person
can
initiate a Maintenance
Work Request
(MWR) and Trouble Report.
The Shift
Supervisor or his designee
reviews
MWR's to assess
impact
on plant opera-
tions, assigns
a sequential
number
and indicates
approval of the
MWR.
The
Maintenance
Manager or his designee
establishes
priority for the work and
assigns
the work group.
The work group supervisor is responsible
for the
coordination
necessary
to perform the work and to complete
the post-per-
formance activities.
This coordination
includes Shift Supervision,
a
Special
Work Permit or Radiation
Work Permit, Quality Control,
and Results
and Tests,
as applicable.
The inspector
reviewed the
MWR's initiated in 1985,
the
MWR's outstand-
ing from 1984 and
a random
sampling of completed
MWR's to assess
the
quantity of corrective maintenance,
priority and timeliness for safety
related work and the coordination before
and after work performance.
Approximately 4000
MWR's are initiated each year.
415
MWR's had been
initiated between
January
1 and February
7,
1985.
Several
of these
were
rewritten from previous
(1983)
MWR's as
a result of maintenance
super-
vision's annual
review as mandated
by section 3.5.2 of A-1603.
Of the
415
MWR's issued to date in 1985, only 6 were safety-related.
These
were
properly prioritized.
Informal communication
between
operations
and
maintenance
personnel
usually results
in work completion
contemporaneous
with MWR initiation for operational
or safety-related
work.
A review of
outstanding
(1984)
MWR's yielded about 600;
many of these
require plant
shutdown to accomplish
and are
scheduled
for the
1985 refueling outage.
Others are completed work, according to various supervisors
interviewed,
but administrative
review is not yet complete.
A review of 45 in-process
MWR's awaiting the Maintenance
Manager's
closeout,
the final step in the
MWR process,
showed
a typical time of
1 month from initiation to closeout
and 3-7 days
from initiation to work completion,
except that safety-
related work is completed
the day of initiation unless deferred until
plant conditions permit the work.
While no problems
were evident regarding safety-related activities,
the
large
number of open
and incomplete
MWR's, (several
hundred),
and the
tenuous tracking
system for MWR's contributes,
with other problems
identified later in this report,
to an assessment
of untimely and
incomplete
recordkeeping
for plant maintenance activities.
MECHANICAL MAINTENANCE
Mechanical
maintenance activities include preventative
and corrective
maintenance
for pumps,
piping and supports
and valves.
The majority of
work is accomplished
by the mechanical,
pipe
and day/night maintenance
shops.
Each of these
shops
has
an assigned staff headed
by a
shop foreman.
The foremen report to the Mechanical
Maintenance
Supervisor.
Mechanical
maintenance activities were reviewed to ensure that
safety-related
work is conducted
in accordance
with approved plant
procedures.
Maintenance activities are
cont, rolled through the
use
of administrative
(A) procedures
describing
programs
and controls
and
maintenance
(M) procedures
giving detailed work instructions.
Corrective
maintenance,
either safety or non-safety-related,
is initiated by use of
the
MWR.
The inspector
reviewed several
hundred
MWR's to verify
completeness
and ascertain
the extent of safety-related
maintenance.
It
was evident
from this review that the majority of safety-related
mainte-
nance is routine scheduled
preventative
maintenance
(PM)
~
Administratively, mechanical
PM activities are governed
by A-1010,
Mechanical
Preventative
Maintenance
Program;
A-1011,
Equipment Inspection
Period
and Lubrication List; A-1015, Three Month Lubrication and Mainte-
nance
Inspection;
A-1020, Valve Preventative
Maintenance
Program;
and
A-1021, Safety
and Relief Valve Testing
Program.
The conduct of safety-
related maintenance,
whether preventative
or corrective, is controlled
through the
use of detailed
procedures.
The inspector
reviewed the per-
formance of several
maintenance activities completed during 1984.
These
included major/minor inspections of pumps;
removal
and installation of
seismic pipe supports;
installation of valve packing'; inspection
and
testing of valves;
and inspection of heat exchangers.
Within each proce-
dure, certain provisions are to be met prior to commencing or continuing
work. These provisions include:
~
Quality Control(QC) notification prior to start
~
Limiting Conditions for Operation evaluation
(A-52.4)
~
Equipment Tagging (A-1401)
~
Health Physics
work permit issued if applicable
~
QC hold points
~
Notification of Results
and Test group for possible
post-maintenance
testing
~
Replacement
part,s, if necessary
(A-801)-
~
Housekeeping
and cleanliness
requirements
For those
maintenance activities reviewed
by the inspector,
a sampling of
procedural
provisions
was reviewed to verify that all work had
been
completed
as required.
The inspector
found all work to be complete
and
well documented.
The Results
and Test
(R&T) group performs post-maintenance
testing
following completion of maintenance
on safety-related
equipment
in
order to verify equipment operability and develop baseline
operating
characteristics.
No safety-related
mechanical
maintenance
was conducted
during this inspection,
so the inspector
was unable to observe
post-main-
tenance testing.
All procedures
reviewed
had adequate
provision for
0
hi
'
post-maintenance
testing.
The inspector did observe
the monthly survei l-
lance test
and transfer of operations for the component cooling water
pumps.
The inspector
noted that
R&T personnel
performed the test in
accordance
with a current approved
procedure,
with an issued
Radiation
Work Permit
(RWP) and with a
gC inspector present.
Appropriate super-
visory reviews were performed following completion of the test.
A review of calibration
and control of measuring
and test equipment
(M&TE)
used
by mechanical
maintenance
personnel
was performed to verify the
adequacy of the
M&TE program in the conduct of maintenance
and adherence
to applicable
procedures.
Torque wrenches
are maintained,
controlled and
calibrated
by the mechanic
shop.
All other
M&TE, i.e., micrometers,
vernier calipers, etc.,
are calibrated
by gC, but assigned
to individuals
within the various mechanical
shops; it is the responsibility of these
individuals to maintain
and control the instruments.
The inspector
reviewed the
1984 usage
log and calibration records for torque wrenches
and noted that torque wrenches
were always tested for acceptability prior
to use.
Other areas verified were:
storage
and labeling of test equip-
ment; certification records for calibration of test equipment,
including
torque wrench
bench tester;
test equipment
denoted
as
used in various
completed
M-procedures calibrated
when in use.
The inspector witnessed
calibrations
by gC for several
inside
and outside micrometers,
depth
micrometers
and vernier calipers.
All calibrations
were performed using
appropriate
approved
procedures.
A number. of problems with the control
and calibration of meausuring
and
test equipment
were identified in the licensee's
audit 84-05:SB conducted
in the spring of 1984.
Corrective actions
on several
of these
problem
areas
had
been
taken
and others
were under way at the time of this
inspection.
One of these,
a major revision to procedure
A-1201, Calibra-
tion and Control of Measuring
and Test Equipment,
was
made
and approved in
January,
1985.
During the witnessing of calibrations,
the inspector
noted
several
discrepancies
between
A-1201 and the individual calibration procedures
(CP's).
The CP's in question
include
CP 80.0,
80. 1, 80.2, 80.3, 80.4,
81.0
and 81. 1.
The discrepancies
included incorrect or deleted
references
and incorrect equipment classifications.
These discrepancies
and other
minor problems with the CP's were discussed
with the
gC Supervisor.
This
supervisor
was
aware of the problems
and of the
need to review and correct
the CP's.
The fact that this had not been
accomplished
at the time of
this inspection contributes to assessment
of a weakness
in control
and
calibration of M&TE as further discussed
later in this report.
The maintenance
history program is described
in procedure
A-1705 '
review of files kept for this program
showed that the procedure
was
complied with in that the Maintenance
Manager determined
those entries to
be made.
The usefulness
of the existing history file is very questionable
because
of these observations:
the last inspection
noted for the manip-
ulator crane
was 2/22/79 but the crane
had since
been
used for several
refuelings;
the history for safety injection
pump
1C only covered
the
interval 4/22/75 to 10/30/81; entries for snubbers
ranged
from 5/7/75 to
8/30/83.
In contrast,
selected
entries
in pump histories
were current.
The
'l
L
out-of-date entries
and the sheer bulk of these files make it difficult to
place reliance
on this history information for trending or tracking.
This
is regarded
as another
example of weakness
in maintenance
recordkeeping.
Procedures
A-1010 and A-1020 outline the preventive maintenance
program
for rotating equipment
and for valves.
The inspector
reviewed these
procedures
to verify that inspection
frequencies
had been established,
desired
maintenance
was being performed
and this work was being adequately
documented.
Discussions
were held with the responsible
foremen,
the
mechanical
maintenance
supervisor
and the maintenance
manager
regarding
their involvement by scheduling,
supervising
and reviewing the
PM program.
Documentation of completed
PM'
is accomplished
by using appropriate
pro-
cedures
and/or annotating
equipment history cards.
A computerized
main-
tenance
tracking
and scheduling
system
(COMMS) is in trial use
and will
eventually document the
PM program.
During reviews of the scheduled
and completed
PM on valves
and discussion
with foremen
and supervisors,
the inspector
determined that many aspects
of A-1015 were not being accomplished.
The Maintenance
Supervisor
was
not performing the procedurally required monthly schedule
reviews to
ensure that scheduled activities were being accomplished
nor was
he
reviewing the program annually for improvements,
changes
or updates.
Valve inspections
were not being done within the inspection intervals
specified
by the procedure.
Failure to adhere
to an approved
procedure is
a violation (50-244/85-04-01).
The mechanical
maintenance
section is made
up of well-qualified and experi-
enced personnel.
A well-defined training program
has
been developed,
but
has not yet been fully implemented.
Management control
and coordination is
accomplished
formally through
a weekly interdepartmental
meeting
among the
discipline foremen
and supervisors
and informally through
many other means.
With the exception of the
PM program for valves, identified as
a violation
above,
mechanical
maintenance activities are accomplished
as
scheduled
and
are well controlled through the
use of detailed
maintenance
procedures.
Weaknesses
in maintenance
recordkeeping
(Inspector
Followup Item
50-244/85-04-04)
and calibration
and control of measuring
and test equip-
ment were noted.
2.2
ELECTRICAL MAINTENANCE
The Maintenance
Manager is responsible
for electrical
maintenance.
Performance
of day-to-day activities is supervised
by the IEC/Electrical
Supervisor
and the
shop foremen. Staffing of this activity was reviewed by
the inspector
and appeared
adequate
to handle
the work load.
Electrical
maintenance
personnel,
including the foreman,
had documented
evidence of
training and qualification appropriate
to their function.
The inspector
assessed
performance
of these activities by observation
of work in
progress,
review of completed
work and discussions
with workers
and
supervisors.
These activities were directly witnessed:
~
Calibration
and maintenance
of the turbine-driven auxiliary feed-
water
pump discharge
flow loop 2032;
performance of CP-2032,
rev.
3.
~
Performance
of PT-5. 10, rev.
25,
Process
Instrumentation
Reactor
Protection
Channel Trip Test (Channel
1).
~
Periodic testing
and maintenance
of the security emergency
diesel
generator
per PT-12.3,
rev.
5.
Each of these activities was performed in accordance
with adequate
procedures.
1
In performing IEC/Electrical maintenance activities,
review is required
for failure analysis
and reporting (A-25.2). These reports
are initiated
by IKC/Elect staff any time that
a failure is identified in a safety-
related activity.
Mhen
a failure report is generated
in this manner,
it,
is evaluated
by the
18C supervisor
for appropriate corrective action.
The
inspector
reviewed these failure reports:
Item:
FQ-619
Function:
power supply,
comp.
cool
loop 619
Failure:
voltage out of
tolerance
Corrective Action:
replacement
RMS R-2
.
LT-2044
TT-401
power supply
A level
Tave
Ch
1 dual
current
source
HV below spec
failed high
capacitors
5
replacement
ordered,
replaced
replaced
parts
These specific reports
and
a sampling of about
50 others
generated
in the
period 1982-1985
were reviewed by the inspector for adherence
to the
administrative
procedure,
proper identification of failures
and
use in
trending failures.
No problems
were identified.
No trends
were observed.
The inspector
reviewed the use of M&TE by electrical
maintenance
personnel
to verify adherence
with procedure
A-1201.
The results of this review
were:
Digital multimeter Fluke model
8200A, s/n 75949,
was not on
a shop
recall list for February
1985 as required
by section
3. 1.2.3 of
A-1201.
This discrepancy
was corrected during the inspection.
Digital multimeter
HP mode 3466A, s/n
15926,
was not calibrated
on
its mi lliamp range.
Section
3. 1.2.5 of A-1201 requires
labels to
indicate restrictions.
Upon questioning,
licensee staff were aware
of the restriction
and
showed the inspector
the restriction label.
Cl
,>1
10
~
AMP electrical
crimping tool, s/n B-43,
was noted to be past
due for
calibration.
The due date
was 11/24/84
as penciled in Scotch tape
on
the tool handle, with no calibration date.
The inspecto}
examined
the
electrical tool calibration log maintained
by the
R&T group
and noted
seven
crimping tools were listed as missing:
B-2, B-9, B-ll, B-43,
B-47, B-51,
and B-52.
The inspector
informed this group that
he found
B-43.
No explanation
could be given to determine
what circuits may
have
been
crimped with the tools listed as missing.
~
Multi-Amp test set
model
CB-7150,
s/n
18553,
was identified by
surveillance
not to have
been calibrated.
Corrective Action Report
(CAR) 1595 dated
10/24/84 stated that the test set
had not been
calibrated
since
purchase
in 1971.
The inspector
reviewed the cali-
bration report generated
by the vendor as part of this corrective
action.
The calibration
was done
on 1/23/85. llhile the vendor found
the test set out of tolerance
as found,
an analysis of the
as found
and as left values
performed
by the inspector concluded that the
'ifferences
were not significant (maximum
3% on one range).
The inspector
noted
no case of performance of safety-related activity
performed with improperly calibrated
instruments.
However,
the discre-
pancies
noted above,
along with those
noted elsewhere
in this report,
result in an assessment
of weakness
in the oversight
and control of M&TE.
In following QC surveillance of electrical activities,
the inspector
reviewed Quality Control Surveillance
Report
(QCSR) 85-0013 which
described cutting of a ring tongue terminal attached
to alarm bistable
PC-937 A/B used for control
room annunciation if pressure
transmitter
PT-937 failed. This transmitter is one of two measuring
Accumulator Tank 2
pressure.
The
QCSR was dated
1/18/85
when
QC witnessed
performance
of
The 1&C/Elec maintenance
foreman
who dispositioned
the
QCSR did
not recommend
any corrective action.
QC rejected this disposition
and
generated
Nonconformance
Report G-85-013 dated
1/28/85 requesting
a cor-
porate engineering disposition.
The engineering disposition
was "use
as
is" on the basis that Specification
EE-29, rev.
6 dated
12/20/83,
states
that
a ring tongue terminal shall
be used unless
an alternate
tongue is
approved
by engineering.
The inspector questioned
the specific applica-
tion and examined
the installation in the presence
of a licensee
repre-
sentative
in the relay room cabinets
in order to verify that the Ll hot
leg on the bistable
was for annunciation
only and that
a separate
power
supply fed the loop for PT-937
so that the accumulator
pressure
channel
would function as designed
in event of loss of L1. This was verified by
the inspector
and satisfied his question.
The inspector
reviewed procedure
M32.2, rev. 4,"DB-50 Reactor Trip Circuit
Breaker Inspection,
Maintenance
and Test" to verify that the testing
provisions of NRC Generic Letter 83-28,
"Required Actions Bases
on Generic
Implications of Salem
ATWS Events",have
been
implemented at Ginna.
Review
of the completed
procedures
and discussions
with responsible
staff
revealed
no difficulties in performing this maintenance
and testing.
However,
the licensee's
response
letter dated
11/4/83 stated that trending
the performance of the reactor trip breakers
started with the
1983
refueling outage.
Staff members
were familiar with test results
and
trends,
but there
was
no procedural
requirement for trending.
Since the
procedure
is being revised to incorporate other
NRC comments
regarding
vendor owners'roup
recommendations,
an Unresolved
Item (50-244/85-04-02)
results until all commitments
are incorporated
in plant procedures.
Control
and availability of vendor manuals,
vendor information and
use of
this information in maintenance
and procurement activities was reviewed
by the inspector.
No discrepanices
were identified.
2.3
Corrective
and preventive I&C/Electrical maintenance activities were
performed
by experienced,
adequately
trained, qualified personnel.
Pro-
cedures
used
were adequate
for controlling activities. guality control
hold points were established
where required,
observed
and documented.
Additional problems in calibration
and control of measuring
and test
equipment
were noted, further substantiating
the assessment
of weakness.
( Inspector
Followup, Item 85-04-05).
INSTRUMENTATION AND CONTROL ACTIVITIES
Under the Maintenance
Manager,
the
ILC Supervisor is responsible
for
overall supervision of the
I&C group
and the plant electrician group.
Each
group
has
a forema'n responsible
for the
group's activities.
The inspec-
tor noted that the staffing level in the
I&C group is adequate,
with
twelve regular technicians
reporting to the
I&C foreman
and three
temporary helpers reporting'irectly to the
I&C Supervisor;
the group has
a very low turnover rate.
Training provided by the licensee
was primarily
vendor-information oriented.
The inspector
lear'ned that plant systems
training for the technicians
is planned;
the individuals expressed
a
desire for this training, particularly if it emphasizes
reactor control
and protection.
The inspector
selectively followed up on the licensee's
review of IE
Reliance
on Mater
Level Instrumentation with a
Common Reference
Leg, to determine
the adequacy of review and incorpora-
tion of operating
experience.
This information notice was handled through
the plant's task assignment
system
and jointly reviewed
by I&C and Opera-
tions staffs.
The conclusion
reached
by these
groups that
no similar event
is likely to occur in this plant was forwarded to the Assistant Superin-
tendent.
Based
on document review and discussions
with cognizant
personnel,
the inspector determined that the review was timely and
technically sound.
The inspector
observed
on-going
I&C calibration
and surveillance
activities to verify the following:
~
Required
procedures
were available,
in use
and followed.
,X,tt
4+
t
Cl
12
~
Special test equipment
was calibrated
and in use.
~
Test prerequisites
were met and initial conditions were
pr operly observed.
~
Technical
content of procedures
was adequate
to result in
satisfactory
component or system calibration
and test.
Calibration,
maintenance
and surveillance tests
observed
in addition to
those previously noted included:
~
CP-2019, Calibration and/or Maintenance of Turbine Driven
Pump Discharge
Pressure
Loop 2019
The inspector
noted that these activities were being performed in
accordance
with approved
procedures
by qualified personnel
using
calibrated
instruments.
CONCLUSIONS
Maintenance
is performed
by an experienced,
well'-qualified staff who follow
approved
procedures.
A well-defined training program for this experienced
staff has
been developed,
but not fully implemented.
(Inspector
Followup
Item 50-244/85-04-06).
One instance of failure to adhere
to
a procedure
for preventive maintenance
of valves
was noted.
A procedural
weakness
in
trending reactor trip breaker test results
was in the process
of being
addressed.
Maintenance
Mork Requests
and other documents
were complete;
however
a large
number were outstanding
and administrative closeout
was
slow, leading to an assessment
of weakness
in documentation
of maintenance
activities.
This assessment
is further borne out by the incompleteness
and out-of-date entries
in the maintenance
history file.
Problem areas
were also noted in the calibration
and control of measuring
and test equip
ment, but no safety-related
work appeared
to be affected
by these
problems.
3.0
SURVEILLANCE
Various groups perform surveillances
depending
upon the type needed.
Several
surveillance activities
have
been discussed
in preceeding
sections
of this report.
The performance
type of surveillance
(PT series)
is
scheduled
by the
R&T group in accordance
with the time interval specified
in Technical Specifications
(TS).
This schedule
is then transmitted to
the appropriate
groups through the weekly plant interface meeting.
The
R&T
Supervisor
has the overall responsibility to ensure that all
PT survei 1-
lance tests
are properly performed,
evaluated
and documented.
Operational
survei llances
such
as daily thermal
power calculation,
nuclear
instrumen-
tation response
and reactor coolant
system
(RCS) leak rate are conducted
by operations
personnel.
Observation of conduct
and discussion
of methods
and results
in the areas of Operations,
Results
and Tests
and Reactor
Engineering
were carried out by the inspector during this inspection.
13
3.1
OPERATIONS
The safe
and efficient operation of the plant is the primary responsi-
bility of the Operations
Manager,
who reports directly to the Assistant
Superintendent.
An Operations
Supervisor
provides the manager with a
comprehensive
day-to-day review of plant activities.
There are five
shifts in plant operations,
with one shift rotating into the office for a
six-month in-office duty schedule.
Activities and interfaces affecting
maintenance
were discussed
with various
members of the operating staff by
the inspectors
All shift supervisors
interviewed stated that they were given very good
support
from the maintenance
group.
The normal
channel
for requesting
maintenance
work is the
MWR (A-1603).
However,
when
a problem necessi-
tates
expedited solution,
informal methods
are also
used.
An example oc-
curred during this inspection.
On February
6,
1985, at about
4: 15
pm,
minutes before the regular quitting time, the control
room operator
noted
that the Tavg circuit exhibited erratic behavior which caused
unwanted
control rod motion,
an alarm
on Tavg deviation
and
an increase
in charging
pump speed.
The
IEC group was notified by telephone
and quickly responded.
The cause
was identified as
a bad switch contact
and was corrected
by
about 6:30
pm when the plant returned to normal operation.
Discussion with
the
IKC foreman revealed that
no followup paperwork
was generated
in this
case
because
a similar problem occurred earlier in the week and it was
being tracked with MWR 85-374.
The inspector
observed
plant operations
during the course of the inspec-
tion.
Control
room and shift manning were observed for conformance with
TS and administrative
procedures.
Various alarm conditions which were
acknowledged
were discussed
with shift personnel
to verify that the rea-
sons for the alarms
were understood
and corrective action, if required,
was being taken.
The inspector
reviewed results
and performance of several
operational
sur-
veillancee
procedures.
S-12.4,
"RCS Leakage Surveillance
Record Instructions",
rev.
15, describes
methods
for
RCS leak rate determination.
These consist
of radiation monitoring of containment air particulate
and radiogas,
humi-
dity in containment,
containment
pump actuation
and
RCS system inven-
tory.
Indication of leakage
by any monitoring method exceeding
a pre-de-
termined value constitutes
a significant increase
in leak rate.
Operators
are then required to initiate action per procedure
S-12.2
and report the
results
through the Operations
Manager to the Plant Operations
Review Com-
mittee
(PORC).
The inspector
reviewed
a two-month sample,
October
1 to
November 30,
1984,
and noted that there were
47 S-12.2 reports
(33 due to
R-11 radioparticulate,
2 due to R-12 radiogas,
4 due to
pump actuations
and 8 due to humidity) which triggered
a significant leak rate investiga-
tion. In none of these
cases
was there
a true
RCS leak.
Much operator time
was diverted to performing and documenting
these
unwarranted
investigation's.
I
I
14
The inspector
reviewed the
system inventory method
used in S-12.4 for
technical
adequacy.
The accuracy of the current method is adequate if it
is employed with no change
in pressurizer
level
and Tavg for a reasonable
test duration.
None of these conditions are given as precautions
or
limitations in the procedure.
Interviews with operations
personnel
indicate that they are
aware of the limitations and
have not experienced
difficulty in executing
the procedure
when the unit was in steady state
conditions.
There were times,
however,
when the test
had to be repeated
to meet acceptance
criteria, especially
when
power level
was changed.
The licensee
is in the process
of evaluating data obtained
from these
tests
in an effort to improve the procedures
and reduce
the
number of
unwarranted
leak rate investigations.
During control
room observation,
the inspector
noted that level indication
from both accumulator
tanks
was irregular.
Both accumulators
were exper-
iencing leaks.
The leak pathway is believed to be through the liquid fill
isolation valves,
V-835A and B, into the 3/4" safety injection test line
and then through the test line safety relief valve SRV-887 to the Pressur-
izer Relief Tank (PRT).
The inspector
made
independent
observations
and
calculations to verify that the inventory loss
from the accumulators
is
approximately
equal
to the
PRT inventory gain.
TS limits for accumulator
water volumes are
maximum,
82% and minimum ,50%.
Alarm setpoints
are
high,
75% and low,
57%.
As a result of existing leakage,
the accumulators
have to be charged
about twice per shift.
The inspector
noted that the
charging operation
was conducted
in accordance
with procedure
S-16. 13.
This problem was initially identified in May,
1984
and described
on MWR's
84-1351
and 84-1411;
these
MWR'
were still open at the time of this
inspection.
The rate of leakage
and the conduct of the charging operation
were familiar to maintenance
and operations
personnel
interviewed.
The
leakage
problem is being closely monitored
by operations
and maintenance
personnel.
Repair of the valves is scheduled
for the March,
1985 refuel-
ing outage.
The inspector
found that the plant was operated
by highly knowledgeable
personnel
in a concientious
manner.
Key positions
in the operations
group
are held by very experienced staff; most
have worked with the plant for
more than
10 years.
Information exchanges
include weekly discussion
sessions
and circulating memoranda for operations
personnel.
No unaccep-
table conditions were identified.
3.2
RESULTS
AND TEST
GROUP
The
R8T Supervisor is responsible
for all
TS surveillance
items.
Surveillance
schedules
are disseminated
at weekly plant interface
meetings.
There are
seven test technicians
in the group.
The
Supervisor reports to the Technical
Manager.
The inspector
verified that all test personnel
are qualified as
Level II inspectors
in
accordance
with procedure
A-1102.
Through staff discussions
and test
observations,
the inspector
determined that test personnel
were
know-
ledgeable
in their areas
of performance.
The inspector
observed
portions of these
surveillance
tests,
both
in the field and in the control
room:
~
PT-37.8,
1A 5 1B Vapor Container Auxiliary Filter Fans
Mass
Air Flow Check,
performed
February 6,
1985
~
PT-2.3. 1, Post Accident Charcoal Filter Dampers,
performed
February
6,
1985
~
PT-16, Auxiliary Feedwater
System,
performed
February
13,
1985
Reviews of the completed tests
were conducted
by the
R&T Supervisor.
The
inspector
found the tests
and post-test
reviews to be adequate.
While observing
PT-16, the inspector noticed that the manual isolation
valve,
V-4345,
from the service water line was closed
and padlocked;
how-
ever,
the Piping and Instrumentation
Drawing 33013-545,
rev.
3,
showed
a
normally open valve
on
a controlled copy dr awing.
In discussion with
control
room operators,
the inspector
learned that there is awareness
of
this information conflict.
The operations staff relies
on procedure
A-52.2. 1, "Inventory of Locks and Keys", rev.
4 for the proper locked
valve positions
and not on
PAID drawings.
A major drawing update
and
revision effort is nearly complete;
the inspector
examined
a draft P&ID
for the auxiliary feedwater
system,
33013-1237,
rev. 0,
and noted that the
correct, position is
shown for valve V-4345.
The drawing update
program is
discussed
elsewhere
in this report.
The inspector
had
no further
questions.
In the course of reviewing open
MWR's, two similar reports - 84-1351 dated
5/15/84 and 84-1411 dated 5/22/84 - identified a similar problem.
The
inspector ascertained
that the problem identified, possible
leakage
on the auxiliary feed
pumps,
was identified
as industry wide at
the time.
The approach
used at Ginna was to revise
Procedure
PT-16,
the
monthly surveillance test
to include
an additional
step 6.6. 18 to check that all discharge
piping returned to ambient temper-
ature at the conclusion of the surveillance.
The inspector verified in a
quarterly
sample that Revision
41 which contained this step
was performed
on 7/2/84, 8/6/84 and 9/14/84 and the step
was initialed and checked.
Maintenance
and Results
and Test staff interviewed were familiar with the
problem and solution.
On further inquiry, the inspector ascertained
that
the open
MWR's were in the possession
of the mechanical
maintenance
foreman,
who wanted to assure
himself during the March 1985 outage that
no
further problems
were associated
with these
check valves before closing
out the MWR's.
The inspector
had
no further questions.
Another function of the
R&T group is trending of test results to analyze
performance
and identify adverse
trends.
The inspector
reviewed
log-books
on valve stroke time tests,
plots of pump performance
data,
logs of containment penetration
leakage data,
monthly summaries of total
containment
leakage
and the reports of performance
of the program for
16
leakage
reduction outside containment.
The logs and plots noted
acceptable
ranges for the various parameters
and were kept in
a neat
and
logical manner which made it a simple task to identify adverse
trends.
The inspector
noted
no adverse
trends
in this review.
3.3
REACTOR ENGINEERING
Core performance
evaluation is the primary responsibility of the Reactor
Engineer.
He reports to the Technical
Manager.
The inspector
reviewed
several
aspects
of core performance.
Measured
values of the reactivity
anomolies plot maintained
since the beginning of this fuel cycle are in
good agreement
with predicted values.
The plant is now near its predicted
End-of-Cycle
(EOC) fuel burnup
and is undergoing
coastdown.
As of
February
12,
1985,
the cycle burnup value is 8660
MWD/MTU.
The reload
safety analysis
covers
burnup
up to 9700
MWD/MTU.
The coastdown
operation
is conducted
according to operations
procedure 0-6.2, Plant Operation
During Coastdown,
rev.
2.
Average
Tavg during this coastdown is planned
to decrease
about
3~F below T-reference.
A thorough study of plant
behavior resulting
from Tavg reduction
was conducted
on September
23,
1982
by actually reducing
Tavg by 15'F in a test.
The test demonstrated
no
operational difficulties.
During the course of this inspection,
control
room parameters
were
observed;
these
were closely monitored
by the operators
and printed
on the
trend typer.
Tavg was maintained within the intended
range.
Through
discussi,ons
with the reactor engineer
and control
room operators,
the
inspector determined that the plant staff was knowledgeable
in the
technical
issues
associated
with coastdown operations'o
deficiencies
were noted.
CONCLUSIONS:
No problems
were noted for the survei llances
observed
and reviewed.
The
Operations,
Results
and Test
and Reactor Engineering staff who performed
these
survei llances
were knowledgeable,
experienced
and qualified.
A
viable information exchange
process
was observed,
as well as
good working
relationships with the maintenance
staff.
A large
number of leak rate
investigations
per procedures
S-12.4 were identified by the plant staff
and discussed
in detail with the inspector;
evaluation
and possible
revision of procedures
is underway.
Trends of test results
were available
and analyzed appropriately
by Results
and Test Staff.
Control
Room opera-
tions were conducted
in conformance with regulatory requirements
and pro-
cedures.
4.0
RADIOLOGICAL CONTROLS
The Manager of Health Physics
(HP) and Chemistry is the responsible
manager for radiological controls.
He is
a member of the Plant Operations
Review Committee
(PORC).
In this capacity,
he participates
in the review
of safety-related
work and changes
to safety-related
procedures.
He also
participates
in station planning meetings
such
as daily and Outage
Planning meetings.
From these interactions,
the Manager of HP is made
17
aware of ongoing
and planned work.
The Manager
and the department staff
are well experienced
and highly qualified. All key positions are filled.
Turnover of personnel
has
been very low at all levels.
During the planning stages
for outages,
a major function of the station
radiation protection organization
is to provide reviews of planned work
for radiation exposure minimization (ALARA).
As specific work is
scheduled,
the
ALARA coordinator
arranges
for a formal review by the
committee.
As the planning
and workload are developed
from these
analyses
and reviews,
the
HP staff arranges
for additional technician
support
and
material
and equipment
such
as protective clothing and radiation
survey
instruments
to support the outage.
The corporate
Health Physicist,
a position recently filled, is not
currently involved in outage
planning,
although
a large part of the outage
work involves modifications determined
by corporate
engineering.
The
corporate
HP has provided corporate
management,
including the Nuclear
Safety
And Review Board
(NSARB) with information reg'arding HP-related
performance
during past outages
and with impacts of regulatory changes.
The inspector
noted that
a position description for the corporate
HP had
not yet been developed.
The
HP department
'does not provide training for outage workers; this is
provided
by the Training Department.
The steam generator
repair group
provides its
own extensive training, including practical
work on two
mockup
for workers assigned
to the testing
and repair of
the
A separate
building and staff are dedicated
to this
effort.
Other training in support of the
HP program
and outage prepar-
ations is determined
and provided by the Training Manager.
The Training
Department
provides this training at the Training Center adjacent to the
stat,ion.
The inspector
noted from review of reports
and records that, until the
year
1984,
accumulated
worker exposures
had been higher than average for
pressurized
water-reactor facilities.
A notable
change
occurred in 1984
when the exposure total
(380 man-Rem)
was less .than
40% of the exposure
total for 1983 (960 man-Rem).
The licensee
has been, trending
and analy-
zing the exposure
data.
The licensee
has concluded that most of the
personnel
exposure is associated
with two major outage activities,
steam
generator
inspection
and repair
and installation of seismic restraints
inside containment.
The sharp drop in exposure
from 1983 to 1984 was
attributed to the completion of major portions of these activities which
began
in 1977.
Further sizeable
decreases
in cumulative exposure
are not
anticipated.
An exposure
estimate
made prior to the
1983 outage
indicated that all work
scheduled for the
channel
head could not be completed.
As
a result,
the licensee
performed
a chemical
decontamination
of the
B
using the
London Nuclear process.
An initial reduction
factor of 10 was obtained.
The dose rates
measured
during the
1984 outage
indicate that the radiation levels
have increased
only slightly.
The
18
result of the decontamination
was
a significant reduction in personnel
exposure
during work on the
The licensee
has not
decontaminated
the
and
has
no current plan to do so.
Discussions
with the
steam generator repair group revealed that
an
aggressive
search
is underway to identify exposure
reduction techniques.
Several
of these
have
been identified, but there is no firm plan to
implement these
in the
1985 outage.
Funding for purchase
of a steam
generator
head
manway bolt detensioner
apparently
has
been
approved,
but
the equipment
has not yet been ordered.
A plan to purchase
a robot mani-
pulator
arm in 1986
has
been discussed.
Several
designs
have
been
reviewed
and experiences
of others
have
been
sought,
but
no selection
has
been
made.
The capital outlay associated
with this equipment is
a major
concern to the licensee
and has led to slow and cautious
progress.
Discussions with maintenance
foremen
and engineering
personnel
indicated
that
no major changes
to present practices
in order to reduce
exposure
were anticipated.
The widespread belief held by sev'eral
groups
was that
most work improvements
have already
been
incorporated
into procedures
and
practices
and that only experienced
workers are
used in radiation exposure
situations.
An estimate for th'e expected
exposure for the
1985 outage
scheduled
to
begin in early March was not available.
This was due,
in part, to the
fact that
a firm schedule
of outage work was not completed.
An Outage
Coordinator
was designated
during the inspection to oversee
outage
work
planning
and control of work during the outage.
However, this was done
only three
weeks prior to the outage.
Corporate
engineering direction of
their portion of the outage work schedule
was not firm and further re-
direction was possible.
The inspector
expressed
concern that the brief
time remaining
may not allow completion of thorough
ALARA reviews or the
implementation of the
recommended
ALARA controls.
The ALARA coordinator
advised that reviews were completed for work, although the jobs were not
yet scheduled.
If specific jobs are postponed
to the next outage,
the
ALARA review would be filed until needed.
Work that was not reviewed would
be controlled by withholding issuance
of a Radiation
Work Permit
(RWP).
The inspector
noted that the
ALARA committee consists
of supervisors
from
several
groups,
including HP.
This permits
a good exchange
of information
regarding
the work.
Cooperation
and coordination
between
the various groups
was excellent.
All supervisors
interviewed were knowledgeable
of the
HP requirements
and
displayed
a good understanding
of the
ALARA concept.
The
HP Manager
, his
staff and the
ALARA coordinator were fully knowledgeable
of the status of
outage
planning,
including ongoing changes.
There
was
much informal com-
munication
between
groups.
Formal information such
as the outage
schedule
was generally
sparse
and outdated
due to rapid and frequent changes.
A review of procedures
showed that all repetitive maintenance
is controlled
by procedure.
These
procedures
contain hold points that ensure
the
necessary
radiological precautions
are taken.
Due to this good control,
Ji
h
19
only new maintenance
and non-recurring
work are afforded
a formal
review.
Changes
in scope that occur while a job is in progress
due to
unanticipated
situations
are controlled by issuance
of a Procedure
Change
Notice (PCN).
HP personnel
participate
in the review prior to issuance
of
a
PCN to ensure that the radiological controls are adjusted
or an
rereview is performed.
During an outage,
foremen are provided the
exposure
status of their personnel
on
a weekly basis.
Post-job reviews are conducted
by the
ALARA committee to review exposure
estimates
which were in error by 25% or more
and also
by maintenance
personnel
to document
any lessons
learned.
Significant concerns identified
during the post-job reviews are brought to the Post-Outage
Review meeting.
Any improvements
or suggestions
are documented
for use during subsequent
outages.
CONCLUSIONS:
Outage radiation exposure
planning at Ginna station 'is competent
and
thorough,
although
much is accomplished
on
an informal basis.
Workers
will be protected
adequately
by the various controls that are in
placebo
All levels of management
exhibit a strong
commitment to radiation safety
and the
ALARA program.
The various
programs
and procedures
receive
frequent attention in order to identify areas for improvement.
Channels
of communication
and cooperation
to effect changes
are very good.
These
excellent indicators are
somewhat
shadowed
by
some complacency
and accep-
tance of current levels of personnel
exposure
rather than setting
improvement goals
and
ALARA target reductions.
The review of station
safety
programs
by NSARB are rigorous.
5.0
QUALITY ASSURANCE
PROGRAM OVERVIEW
The Manager of Quality Assurance
reports
through the Chief Engineer to
the Senior
Vice President
Operations.
The Manager of Quality Assurance
and his staff are located at the corporate
engineering offices.
In addi-
tion,
a Nuclear Assurance
Manager
on the staff of Ginna Station oversees
the work of the onsite Quality Control Engineer
and his group.
There is
also
an interface with Project Quality Control inspectors
who do on-site
inspections
of contractor
work.
The inspection
reviewed efforts of all of
these
groups
and their interfaces with maintenance
and surveillance
activities.
5.1
AUDITS AND VENDOR SURVEILLANCE
The Quality Assurance
(QA) group has
been delegated
the responsibility
to
conduct those audits required
by 10CFR50,
Appendix B, and
TS.
These
responsibilities
include evaluation
and surveillance of suppliers
and
vendors
and also trending of quality program elements.
20
The group consists
of a
QA Manager
and four
QA inspectors,
with one vacant
position.
The manager
stated that recruitment is ongoing to fill the
vacancy.
The
QA inspector hired within the past year has
been attending
training cour ses to fulfillhis auditor qualification requirements.
The
remainder of the staff are
long term employees
who had completed
these
requirements.
There are
no formal refresher training programs
and
none
are anticipated.
The experience
level
and training provided meet
program commitments.
The
1985 audit schedule lists two semiannual,
three triennial
and forty
annual
audits.
The matrix format of the schedule
also identifies organi-
zations to be audited (Engineering,
Purchasing,
Service Contractors,
Ginna Station)
and the functional activities to be audited within those
organizations.
The
1984 audit schedule
was similarly constructed.
Vendors are evaluated prior to their classification
as suppliers of
certain products. Evaluations of acceptable
vendors
are
done biennially and
an onsite audit of each acceptable
vendor is conduct'ed triennially.
The vendor audit schedule lists seventeen
audits for 1985.
Vendor sur-
veillances
are conducted
as
needed.
Participation
in and
use of the
industry
CASE audits represents
the basic tool for vendor evaluation;
considerable
use of consultants
is made to conduct the
CASE audits.
The majority of audits were conducted
by one person
and averaged
three
days. It was noted that the
QA Manager
was designated
lead auditor for 12
of the scheduled
1985 internal audits
and would participate
in a number of
others,
in addition to his managerial
duties.
Checklists
were standar-
dized, but
showed evidence of slight modification from year to year.
The
seven audit checklists
reviewed in depth
by the
NRC inspector
ranged
from
marginal
adequacy
to comprehensive
overviews.
Examples of the former were
85-04
CA, Corrective Actions,
and 84-08
CA, Maintenance Activities; these
checklists did not provide guidance
or instruction to the auditor to
sample
both existing
QC Survei llence
Logs for the status of open findings
nor an adequate
sampling technique for maintenance activities.
As a
consequence,
the auditor failed to identify a buildup of open
QC survei 1-
lance findings (see Section 5.2.2)
and to note the deficiencies
in per-
formance of
PM on valves (Section
2. 1) since only 8 pumps were
sampled
from a potential
population of 5000 specific maintenance activities.
On
the other hand, checklists
and manual
tracking matrices for audit of TS
requirements
assured
that each individual
TS item would be
sampled during
a given time period.
The failure of the corrective action audit described
above to identify the
backlog
and buildup of open
QC surveillance findings indicated that the
actions described
in the licensee's
August 9,
1984 response
to Item A of
the Notice of Violation attached
to the
NRC
Region I letter of July 16,
1984 were not fully effective. This noncompliance
(50-244/84-13-01)
remains
open for further review of the effectiveness
of the proposed
corrective action.
(t}
21
In the course of reviewing audit 84-30
SB, Triennial Fire Protection,
the
inspector
noted that many of the findings were invalidated by the
Manager during his review of the audit.
Upon questioning,
the manager
stated that the auditor did not understand
the relief requests
made to
for exception
and relief from certain requi rements
in this area.
The
acceptability of these invalidations is an unresolved
item (50-244/85-
04-03)
and will be examined
in a future
NRC inspections
Trend analysis
conducted
by the
QA group, including the formal report, is
quantitative only.
No effort is made to present
analyses
or statements
of
significance of trends.
On the whole, the
QA group meets its functional
and performance
respon-
sibilitiess.
5.2
QUALITY CONTROL
The onsite
group assigned
the inspection
and surveillance
or monitoring of
ongoing activities is designated
Quality Control
(QC).
Six plant
inspectors (five contract,
one
RG5E) report to the Plant
QC Supervisor.
Four contracted
Project
QC inspectors
report to
a Project
QC (contractor)
Supervisor.
Both supervisors
report to the Plant
QC Engineer.
Plant
inspectors
generally overview operational activities, while Project
inspectors
generally overview contract work, mostly modification activi-
ties.
The Plant
QC Supervisor
reviews qualifications
and interviews
contractor
inspectors prior to their acceptance
for onsite
QC work.
He
also administers testing for certification as required
by the
QA program,
schedules
and coordinates
supplementary
training for inspectors.
All QC
inspectors
have taken
or are
scheduled
to take the licensee's
onsite
Systems
Course.
Supplementary
in-house
inspection
courses
and offsite
third party courses
are regularly provided to
QC inspectors.
A review of
several
inspector qualification folders indicated extensive
experience,
formal classroom training,
and proper certification, obtained for the most
part by examination.
A more formalized training program is under develop-
ment.
Plant
QC regularly conducts
surveillances
of ongoing activities. Project
QC conducts
surveillances
of contractor site
QA and
QC activities.
Plant
work procedures,
including maintenance
procedures,
are reviewed
by QC;
these
procedures
include inspection points.
There are also
a number of
instances
where licensee
witness or inspection points
have
been inserted
into contractor work procedures.
Approximately 120
QC hold points
have
been completed to date in addition to more than
1000
QC surveillances.
Deficiencies identified by these
survei llances
and inspections
are docu-
mented
and tracked for corrective action
on
QC Surveillance
Reports
(QCSR).
If the deficiency is significant, it can
be escalated
to
a
Corrective Action Request
(CAR) and resolved
by the mechanism of station
procedure
A-1601.
Review of the Plant
QC Surveillance
Log identified an
open backlog of over 50 QCSR's,
some dating to 1983.
The
NRC inspector
reviewed all open
QCSR's to ascertain their significance
and the effec-
tiveness of this corrective action
system.
The review yielded
12
QCSR'
22
of some safety significance;
these
were presented
to the licensee
to
determine
status prior to conclusion of the inspection.
The documented
status of all of these
reports (e.g.,
work orders written,
CAR's being
resolved,
engineering
requests
formulated) were reviewed in depth
by the
inspector
and it was determined that actual
or proposed corrective actions
had been
adequate
and timely.
The apparent
inattention to gCSR responses
was discussed
with licensee
management;
this management
had already
identified the problem and provided
a recent
procedure
change that estab-
lishes
response
times for gCSR's.
The large backlog
and
the lack of
attention to timely closure of gCSR's
are further indicators of the weak-
ness
in completion of maintenance
and surveillance
admi ni strative docu-
ments in
a timely manner,
as noted previously in Section
2.
5.3
WAREHOUSE ACTIVITIES
One of the in-plant storage
areas
was toured to determine that adequate
environmental,
cleanliness,
access,
shelf life and traceabi lity controls
had been
implemented.
The area
was temperature
controlled, clean,
locked
and not overcrowded.
Identification was
on items *and their location was accurately controlled
by the inventory log (a sample).
Several
items subject to deterioration
(i.e. shelf life) were
sampled
and found to be included in the shelf life
program.
Practices
in this particular area
were
deemed
to be in accordance
with gA
Program requirements.
CONCLUSION:
The onsite inspection
and surveillance effort exceeds
the licensee's
program requirements,
particularly in areas
such
as inspector training and
qualification and inspection
scope
which includes non-safety-related
activities.
Lack of gCSR closeout contributes
to an assessment
of a weak-
ness
in timely documentation.
6.0
OTHER ORGANIZATIONS AND ACTIVITIES
6.1 OFFSITE
SAFETY REVIEW COMMITTEE
The Nuclear Safety Audit and Review Board
(NSARB) has the responsibility
to per form the corporate
overview function as established
in TS.
Member-
ship of the Board comprises
senior plant and corporate
managers.
This is
supplemented
by outside consultants
who have extensive
experience
and
expertise
in specific areas.
The personal
secretary
to the Vice President - Production
assembles
docu-
ments requiring Board review.
This secretary
forwards these
to the Board
members
and performs the other administrative duties associated
with the
Board's operation.
The Board members
review the information packages,
request additional
information and communicate with others.
The
NSARB
k
II
y,,
'gl
, ~ '
23
Secretary,
the Plant
gC Engineer,
develops
the meeting
agenda
and performs
other administrative duties.
No procedures
have
been formalized to des-
cribe these
functions.
Further,
the
NSARB charter
has not been
reviewed
nor updated
since
issuance
in 1978.
The inspector attended
a portion of a regularly scheduled
NSARB meeting.
The agenda
and the report were formatted to coincide with the responsi-
bilitiess
set forth in TS.
The agenda identifies the subjects
and the
speakers.
Individuals making technical
presentations
were identified and
scheduled.
Board members
were well prepared
and did participate
in dis-
cussions.
Technical
presentations
were well planned
and
used effective
visual aids.
This Board is executing its responsibilities
in an agressive
and competent
fashion.
However,
review of TS audit activities is not
so thorough
as
the Board's
involvement in other areas.
In sum, this Board is performing
in a manner that is
a strength of the licensee.
6.2
ENGINEERING SUPPORT
The inspector discussed
engineering
support with maintenance
supervisors
and
members of the onsite
and offsite engineering staff.
The engineering
personnel
were knowledgeable
of projects
supporting
Ginna.
Their involve-
ment fell into one of three categories
- support of ongoing maintenance
and operations,
modifications to meet regulatory requirements
and modi-
fications to improve plant performance.
Examples of all three types were
discussed.
One major project which touches
on all three categories
is the
computer-based
plant drawing and diagram program.
This project was in the
final stages
of verification with implementation
planned
upon restart
from
the March 1985 refueling outage.
The computer
based
drawings will replace
the original plant drawings at that time.
Some of the capabilities
demonstrated
to the inspector
included the uniformity of nomenclature,
lettering and symbology,
the design
and specification detail maintained
in
the computer data
base for components
such
as valves
and the ease of
revision under
a carefully controlled change
system.
Drawings were
available within minutes
from the computer plotter; it is planned to have
a plotter at the Ginna site
as well as the existing
one in the engineering
offices.
The inspector also
reviewed the drawing verification program
being conducted
by the Operations
Department.
An example of the detail
available is noted in Section
3.3 above.
6.3
The inspector
noted that there
was considerable
communication
between
the
engineering
department
and various Ginna Station staff which included
frequent meetings
on issues of interest engineering
reviews
and
recommen-
dations for events at Ginna and other plants.
TRENDING AND REPORTING
The Operational
Assurance
Engineer
(OAE) and Shift Technical Advisors
(STA) have
a responsibility to review the
many reports
and events
and
analyze
these for patterns
and trends.
Such items
as the A25.4 Post-Trip
Review, A52.4 Technical Specification Limiting Condition for Operation
Evaluation,
A25. 1 Plant Events,
Operations
Department
Reports
and Sur-
veillances
are gathered
reviewed,
analyzed
and reported
in a monthly
summary prepared
by an
STA and reviewed
and approved
by the
OAE.
The
inspector
reviewed several
of these
and noted that they were thorough.
The many leakage
investigation reports
per Procedure
Sly 2 identified by
the inspector
and discussed
in Section 3.3 were previously identified in
these
trend analyses;
the
OAE has
recommended
a review and change
in the
threshold for initiation of leakage
search to reduce, the
number of
unwarranted
leakage
investigations.
The review and analysis
done by this
group is technically adequate
and useful.
7.0
The inspector
reviewed the licensee's
data input to the Nuclear Plant
Reliability Data
System
(NPRDS) with the
NPRDS coordinator.
There were
approximately
2400 entries
made to NPRDS.
It was recognized
in December,
1984 that
a major effort would be
needed
to obtain
and enter
the addi-
tional
2500 items
needed
to bring the
system current
and meet commitments
in this area.
A staffing increase
to 5 persons
has been
approved;
2 are
presently at work, one is expected
soon
and two more have
been
approved.
The coordinator is required to submit monthly status
reports to the Vice
President'nd
Senior
Vice President.
The effort under way is designed
to
meet
a commitment of being
up to date with NPRDS entries
by October,
1985.
CONCLUSIONS:
The Offsite Safety Review Committee is
a strength of the licensee
in the
depth
and competence
of its reviews.
Strong engineering
support is evi-
dent
and closely integrated with maintenance,
operations
and modifica-
tions.
Nuclear assurance
trending
and analysis is thorough
and useful.
Deficiencies in reporting
NPRDS data were recognized
and efforts to reduce
the backlog
and
become current are underway.
MANAGEMENT MEETINGS
A meeting
was held
on February
5,
1985 to introduce the inspection
team
and to identify the
scope of the inspection.
Preliminary results of the
inspection
were presented
to station
management
on February 8,
1985.
An
exit management
meeting
was conducted
on February
15,
1985 to present
the
findings of the inspection.
Participants
are identified in Section
1.3
of this report.
No written material
was given to the licensee
in the
course of the inspections