ML17261A589

Responds to Violations Noted in Insp Rept 50-244/87-16. Corrective Actions:Field Personnel Requested to Rept Any Discrepancies Found Using Drawing Change Request Form & Drawing Development Activity Currently in Progress

ML17261A589
Person / Time
Site:	Ginna
Issue date:	08/26/1987
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8709010272
Download: ML17261A589 (10)

Text

REGULATORY INFORMATION DIBTRIBUTION SYSTEM (RIDS) r.'CCESSION NBR: 870901 0272 DOC. DATE: 87/08/26 NOTARIZED: YES DOCKET FAGIL: 50-244 Robert Emmet Ginna Nuclear Planti Unit ii Rochester G 05000244 AUTH. NAME AUTHOR A AFFILIATION OBERON R. M. Rochester Gas h Electric Corp.

RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document 4

Control Desk)

SUBJECT:

Respond to violations noted in Insp R'ept 50-244/87-16.

Corrective actions:field personnel requested to rept any discrepancies found using drawing change request form 5 drawing development activity currently in progress.

DISTRIBUTION CODE: IE01D COPIES RECEIVED: LTR ENCL SIZE:

TITLE: General (50, Dkt)-Insp Rept/Notice of Violation Response NOTES: License Exp date in accordance with 10CFR2i 2. 109(9/19/72). 05000244 REC IP lENT COPIES REC IP IENT CQP IES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDi-3 PD ST*HLE. C t

INTERNAL: AEOD 1 DEDRO NRP, MQR 1SBEAU. D 1 NRR/DOEA DIR I

NRR/DREP/EPB 1 NRR/DREP/RPB 2 NRR/DRIS DIR 1 NRR/PMAB/ILPB

'QE Ni J 1 OGC/HDB2 G FI 'EB DEPY GI RGN1 I F LE 01 ERNAL: LPDR NRC PDR NSl C TOTAL NUMBER OF'OPIES REQUIRED: LTTR 20 ENCL'

ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENVE, ROCHES'fc:P N.K >4e49-000>

ROGER VZ. tCOBER August 26, 1987 TCCC HONt VlCC PRCSlOCttZ Cl.CCTRtC PROV VCTlOtt Attt'A cooc ltt'46.2700 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

Subject:

Inspection Report 50-244/87-16 Notice of Violation R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

Routine Inspection Report 50-244/87-16 Appendix A stated in part:

During the inspection conducted on May 31, 1987 through July 4, 1987, and in accordance with the General Statement. of Policy and Procedure for NRC Enforcement Actions 10 CFR Part 2, Appendix C (Enforcement Policy 1986), the following violation was identified:

Technical Specification 6.8.1 states that written procedures shall be established, implemented, and maintained covering activities referenced in Appendix A of Regulatory Guide 1.33, November 1972.

Appendix A paragraph I "Procedures for Performing Maintenance",

discusses control of modification work.

The licensee's Engineering Procedure QE-303, "Preparation, Review, and Approval of Engineering Drawings & Circuit Scheduled" states:

3.6.2 For those drawings completed by a Draftsman, Design Draftsman, or Engineering Assistant, the drawing shall be checked for format, drafting standards and technical accuracy by a Responsible Engineer. The Responsible Engineer shall sign and date the space in the title block.

3.6.3 The Engineering Manager or Lead Engineer, in those disciplines with engineers so designated, shall review the drawing for compliance with this procedure and technical adequacy and shall approve the drawing by initialing and dating the space provided in the title block.

Contrary to the above, controlled drawing 33013-756, "TSC-Vital Battery Intertie", did not accurately reflect installed fuse clip and wire sizes for all D.C. distribution panels listed on the drawing. This drawing designated "As-built '(EWR 4374)" was initialled by the draftsman, a checker, the responsible engineer, and the Engineering Manager on April 21, 1987.

8709010272 870826 PDR ADOCK 05000244 8 PDR

ROCHESTER GAS AND ELECTRIC CORPORATION SHEET NO.

DATE: August 26@ 1987 2 RG&E agrees with the violation and of fers the following in response to the Notice of Violation and the associated unresolved issue (item 4b) related to the violation:

As stated in the violation, drawing 33013-756 was issued As-built on EWR 4374 consistent with Engineering Procedure QE 303.

The 8th revision of the drawing appropriately reflected the specific modification performed in EWR 4374. The discrepancies noted by the inspector were valid findings, however, they were not related to EWR 4374. Engineering Procedure QE 303 requires that each modification be issued As-built upon completion of the work.

Changes are authorized for only those drawings or portions of drawings that are affected by the specific modification. Errors on unrelated portions of a drawing are corrected if recognized at the time a revision is made. Field personnel are requested to report any discrepancies found using the Drawing Change Request form.

RG&E Engineering began a program to recover the configuration of Class 1E D.C. fusing when discrepancies were discovered during the review of the D.C. system under the Systematic Evaluation Program (SEP) and Appendix R review program. The most likely cause for the finding, as discussed in the notice of violation, can be attributed to the general nature of the original Ginna drawings which are used to describe the D.C. system. Specifically, panel layout drawings are used as a single line diagram with little specific fuse information. In each case where a discrepancy was identified, an evaluation was performed to assess the safety impact of the discrepancy. It wasalsodetermined that the safety functions were assured. Itas wasa minimum, determined that new drawings were required to reflect, fuse sizes and types and to show the interconnections between fuses used in all subsystems.

The drawing development activity is currently in progress along with a complete re-evaluation of all fuses, clips and wire sizes.

Specification EE-100, "D.C. Fuse Requirements", developed for the fuse upgrade program, identifies all the requirements applicable to the Ginna Station D.C. system and encompasses fuses, clip sizes, wire ampacities, fuse testing and design requirements. Configura-tion control is achieved through Ginna Station Procedure A-60, "Control of D.C. System Fuse Size and Coordination", which requires the use of the new configuration control drawings in replacing existing fuses to ensure that the proper fuse type and rating is used. Engineering reviews are currently scheduled to be completed by December, 1987, at which time it is expected that some fuses will be identified for replacement. Since the fuses to be replaced are in operating systems, it is anticipated that two refueling outages will be required to complete the replacement program. This is due, in part, to anticipated scheduling problems associated with removing specific systems from service. Therefore, the replace-ment program should last through the end of the 1989 refueling outage. It is believed that the fuse upgrade program along with existing plant procedures will strengthen configuration control on the D.C. distribution system.

4g ROCHESTER GAS AND ELECTRIC CORPORATION SHEET NO.

DATE: August 26, 1987 3 Part 4b of the inspection report identifies two technical issues that appear to be unresolved. These issues are addressed because they are directly related to the notice of violation. Specifically, a justification for the apparent use of oversized fuses and undersized clips, needs to be provided along with a resolution of the drawing control issue cited by the inspector.

It has been 'established that the safety functions provided by the D.C. system are assured if the fusing system performs four primary functions which at times partially conflict. These functions are listed below in order of priority.

l. Assure that no Class lE load is prevented from performing its safety function by premature fuse opening.

2. Assure adequate coordinated fault protection for all D.C. circuits.

3. Provide short circuit protection on all circuits.

4. Provide overload protection to prevent accelerated aging of cable insulation.

Use of the National Electrical Code Ampacity Tables is not always appropriate for all of these functions. It is necessary to consider each circuit on a case by case basis.

i Eighteen (18) circuits have previously been identified as having oversized fuses. That is, the fuse rating was found to be greater than the current rating of the wire used in the circuit, as specified by the National Electrical Code (NEC) . The NEC was initially selected as a convenient means of specifying wire ampacities because the NEC offers a very conservative approach and would be applicable in all circuits. As noted previously, the NEC is not always appropriate for nuclear plant application. As an alternative, the design criteria associated with the fuse program also allows the use of the analytical methods developed by the

.Insulated Power Cable Engineers Association (IPCEA) to establish the largest ampacities appropriate for specific circuits. In addition, manufacturers ampacity values which lie between the.NEC and the maximum IPCEA values may also be used. Specification EE-100, developed specifically for the fuse upgrade program, has been revised to include ampacity values as recommended by the manu-facturer. It also requires that a specific analysis be performed if the manufacturer's ampacity values are to be extended.

the 18 circuits with apparent oversized fuses are cases where a 40 Most of ampere fuse is used in a number 10 wire circuit. Specification EE-100 shows that a 45 ampere fuse will afford adequate protection in such applications. Therefore, the issue of using 40 ampere fuses on a number 10 wire circuits is technically resolved. The 100 ampere fuse used with a number 10 wire in the Nuclear Sample Panel circuit was not appropriate. This is a misapplication that will be corrected using existing Ginna Station Procedures. The con-

4&

ROCHESTER GAS AND ELECTRIC CORPORATION SHEET NO.

DATE: August 26, 1987 4 sequence of the use of such an oversized fuse is that the circuit could exceed chance, it its 'recommended temperature limit was subjected to a high impedance fault. This could if, in the remote cause accelerated aging of the insulation which would require the replacement of the cable. However, the primary fuse and/or the backup fuse would clear all larger magnitude faults (short circuits) prior to any. physical damage occurring to the system.

The inspector also identified two circuits. that had fuse clips rated less than the fuse sizes 1isted on the drawing. Specifically, a 30 ampere clip was listed on a drawing for use with a 40 ampere fuse. Fuse clips are designed so that they- can only accept fuses rated at the clip rating or less. That is, a 30 ampere rated clip

.can only accept a 30 amperes fuse or a smaller rated fuse. Fuses

. rated 3l amperes through 60 ampere require a 60 ampere clip, etc.

A field verification confirmed that the 40 ampere fuse is mounted in a 60 ampere clip. In all cases, the existing clips have an equal or greater current rating than the fuse. Therefore, there are no adverse operating consequences associated with this finding.

~

All fuse clips shown on existing drawings will be reviewed as part of the upgrade program and corrections made as required. All a'ctivities associated with the proper selection of D.C. fuses and associated components along with a resolution of all associated drawing discrepancies will be completed by the end of the 1989 refueling outage.

Your s "truly.,

Roger W. Kober Subscribed and., sworn to me on this 26th, day of August 1 987 CAROL M. DRYER Yor'k Notary Pnbrw in fhe State of New MONROE COUNTY xc: Mr. William Russell Cornrniaaiorr Errfirea Feb. 28, 19 2P Region I Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

.,T. Polich

,Ginna Resident Inspector