ML17261A661

Responds to Violations Noted in Insp Rept 50-244/87-23. Corrective Actions:Dc Fuse Discrepancies Reevaluated & Documentation of Safety Impact Expanded in Form of Design Analysis

ML17261A661
Person / Time
Site:	Ginna
Issue date:	10/21/1987
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8711030100
Download: ML17261A661 (18)

Text

ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE ROCHESTER, N.X 14649-0001 II ROBER W. KOBKR vce pAesloeNT pl g>>> ol>>e ecec Twc mooucmoN ~ ~ ei ca rid 5 "6.27CO October 21, 1987 Mr. William T. Russell, Regional Administrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Subject:

DC Fuse Review Program R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

During NRC Inspection 87-23, RG&E developed and initiated several programs related to the DC electrical system. In response to a request from a member of your staff, this letter documents the elements of our program and provides the current status and projected completion dates of each e1ement.

As was previously discussed in our letter of August 26, 1987, RGSE began a program to recover the configuration of DC fusing when discrepancies were discovered during the review of the DC system under the Systematic Evaluation Program (SEP) and Appendix R review program. As described in that letter, all Engineering reviews to resolve discrepancies and to upgrade the DC system coordination were scheduled to be completed by December 1987 and all replacements and upgrades were planned to be completed by the end of the 1989 refueling outage. As a result of Inspection 87-23, the following details have been added to our program:

DC fuse discrepancies have been reevaluated, and the documentation of the safety impact has been expanded in the form of a Design Analysis. Priorities were established based on potential impact on 1E functions. The format, evaluation methodology, and priority system were reviewed with your'-.

inspector. The Design Analysis was for all fuse discrepancies identifiedcompleted on October 7 at that time.

ROCHESTER GAS AND ELECTRIC CORP. SHEET NO. 2 DATE October 21, 1987 Mr. W. T. Russell The Design Analysis was provided to members of plant staff and Plant Operations Review Committee (PORC) for detailed review and the PORC met on October 9 to perform a review of the discrepancy evaluations pursuant to 10CFR50.59. PORC reached the conclusion that the discrepancies identified in the Design Analysis did not involve an unreviewed safety question or require a change in the plant Technical Specifications.

3 ~ A fuse replacement program for all Priority 1 and 2 DC fuse discrepancies was initiated. All discrepancies which could be resolved at power without subjecting the plant or personnel to safety or operational challenges either as a result of the replacement or as a result of required post-maintenance testing were completed by October 9.

Several of these discrepancies were resolved through further inspection, for example by rotating the fuse in the fuse clip such that the size could be observed and documented as being the correct size. As identified in item 13 below, all remaining priority 1 and 2 discrepancies will be resolved no later than the end of the 1988 refueling outage.

4 ~ At the completion of Inspection 87-23, several cabinets containing DC fuses remained to be inspected. Those cabinets which can be inspected during plant operation without subjecting the plant or personnel to safety or operational challenges were inspected by October 12. Those cabinets remaining to be inspected will be inspected no later than the end of 1988 refueling outage. Any discrepancies which may be identified will be addressed as described in item 8 below.

5 ~ Personnel currently involved with DC fuse replacements have been familiarized with plant procedure requirements for fuse replacement (A-60) as well as with the requirement that fuse size and type be observable and verifiable following installation. Personnel installing DC fuses in the future will be familiarized prior to performing these activities.

Other concerns raised by the NRC inspection during Inspection 87-23 have been reviewed, priorities have been established, and schedules for resolution have been set. These are as follows:

a ~ Engineering documents providing direction for installation of fuse clip reducers will be issued by October 30. V'.

Personnel involved in installation of fuse clip reducers will be familiarized with the requirements of item 6.a.

prior to performing the activity.

4 ROCHESTER GAS AND ELECTRIC CORP. SHEET NO. 3 oATE October 21, 1987 To Mr. W. T. Russell c ~ Walkdowns of wiring for size and type will be performed for the main DC system major distribution panels prior to October 30. Schedules for walkdowns for the balance of the DC system are currently being developed and will be finalized by October 30

'e The seismic supports for the B battery have been reexamined and found to be sound with no indication of degradation. An action plan to address this concern will be developed prior to the end of the 1988 refueling outage.

e ~ A voltage regulation study will be performed on the existing DC system by November 30. A voltage regulation study for the reconfigured .DC system resulting from EWR 3341 will be completed prior to issuance of EWR 3341 construction documents (see item 11 below).

f ~ The Design Criteria for EWR 3341 will be revised by October 30 to reflect suggestions made by the NRC inspector.

g. The need for fire barriers in conduit for the purpose of electrical separation will be reviewed and a schedule for any additional actions will be prepared by the end of the 1988 refueling outage.

7. Testing of all DC fuses at the test facility as of October 2 has been completed. Additional DC fuses are being tested as they are provided to the test facility.

8. Nonconformance Reports (NCRs) are being utilized to document and disposition all DC fuse anomalies not addressed in the Design Analysis described in item 1 above.

9 ~ All Priority 3 DC fuse discrepancies (the lowest priority) which can be resolved at power without subjecting the plant or personnel to safety or operational challenges either as a result of the replacement or as a result of required post-maintanance testing will be resolved as quickly as is reasonable while maintaining proper control of all activites and consistent with other plant priorities. All that can be accomplished at power will be resolved by November 30, with the majority of these to be resolved by October 30. Any fuse discrepancies which 'cannot be resolved at power will be resolved by the end of the 1988 refueling outage as describe'd in item 13 below.

ROCHESTER GAS AND ELECTRIC CORP SHEET NO. 4 DATE October 21, 1987 To Mr. W. T. Russell

10. AC motor control center non-motor loads were selected on October 9 for a review of the current as-built configuation.

We expect this review to be completed by November 16 to the extent possible while at power without exposing the plant or personnel to safety or operational challenges.

ll. The DC fuse upgrade program, EWR 3341, will be continued.

All engineering documents will be issued by December 1987, although we expect the majority of the engineering to be completed by November 30. Higher priority replacements and upgrades will be completed by the end of the 1988 refueling outage and we expect the program to be completed by the end of the 1989 refueling outage.

12. All DC fuses are now part of our configuration control program. Following replacements in accordance with EWR 3341, all future changes in DC fuses will controlled through our configuration control program.

13. All DC fuse discrepancies not resolved as described in items 3 and 9 above will be resolved by the end of the 1988 refueling outage.

We believe the program presented above represents responsive approach to the discrepancies previously identified by our internal reviews and by your Inspection 87-23. Please contact us if you desire any clarification or

~ ~

if

~

~

further information is

~

desired for your review.~

Very truly yours, pg~ 644~

Roger W. Kober

REGULATORY INFORMAT'ION DISTRIBUTION SYSTEM (R IDS)

ACCESSION NBR: 8711030100 DOC. DATE: 87/10/21, NOTARIZED: NO DOCKET ACIL: 50-244 Robert Emmet Ginna Nuclear Planti Unit iI Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION KOBERI R. W. Rochester Gas h Electric Corp.

RECIP. NAME RECIPIENT AFFILIATION RUSSELLI W. T. Region 1I Ofc of the Director

SUBJECT:

Responds to violations noted in Insp 50-244/87-23. Corrective actions: dc fuse discrepancies reevaluated Sc documentation of safety impact e'xpanded in form of design ana)gsis.

DISTRIBUTION CODE:

TITLE:

IEOID COPIES RECEIVED: LTR General (50 Dkt)-Insp Rept/Notice of Violation t ENCL Q SIZE:

Response

NOTES: License Exp date in accordance with 10CFR2I 2. 109'(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 PD STAHLEi C lNTERNAL, AEOD 1 DEDRO 1 NRR MOR ISSEAUI D 1 NRR/DOEA DIR 1 NRR/DREP/EPB 1 NRR/DREP/RPB 2 NRR/DR IS DIR 1 NRR/PMAS/ ILRB 1 0 ~BERN NI J OGC/HDS2 1

( FILE RES DEPY GI 1 RGNi FILE 01 1 TERNAL: LPDR 1 1 NRC PDR NSIC TOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL

TO<K 51m l ROCHESTER GAS AND ELECTRIC CORPORATION c 89 EAST AVENLIC, ROCHESTER~ N,'i'. Ig8.Ig-PPPy ROGER W. KOBER "(<1 'Ghf.

VICC PRESIDENT ELECTRlC PAOOUCTiON r ~ C~ r.e ~1<:~6 27CO October- 21, 1987 Mr. William T. Russell, Regional Administrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King. of Prussia, Pennsylvania 19406

Subject:

DC Fuse Review Program R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

During NRC Inspection 87-23, RG&E developed arid initiated several programs related to the DC electrical system. In response to a request from a member of your staff, this letter documents the elements of our program and provides the current status and projected completion dates of each element.

As was previously discussed in our letter of August 26, 1987, RGSE began a program to recover the configuration of DC fusing when discrepancies were discovered during the review of the DC system under the Systematic Evaluation Program (SEP) and Appendix R review program. As described in that letter, all Engineering reviews to resolve discrepancies and to upgrade the DC system coordination were scheduled to be completed by December 1987 and all replacements and upgrades were planned to be completed by the end of the 1989 refueling outage. As a result of Inspection 87-23, the following details have been added to our program:

DC fuse discrepancies have been reevaluated, and the documentation of the safety impact has been expanded in the form of a Design Analysis. Priorities were established based on potential impact on lE functions. The format, evaluation methodology, and priority system were reviewed with your inspector. The Design Analysis was completed on October 7 for all fuse discrepancies identified at that time.

8711030100 871021 PDR ADOCN 05000244 Q PDR

)0

Cll'k ROCHESTER CAS AND ELECTRIC CORP. SHEET HO. 2 DATE October 21, 1987 To Mr.~ W.~ T. Russell

~

2 ~ The Design Analysis. was provided to members of plant staff and Plant Operations Review Committee (PORC) for detailed review and the PORC met on October 9 to perform a review of the discrepancy evaluations pursuant to 10CFR50.59. PORC reached the conclusion that the discrepancies identified in the Design Analysis did not involve an unreviewed safety question or require a change in the plant Technical Specifications.

3 ~ A fuse replacement program for all Priority 1 and 2 DC fuse discrepancies was initiated. All discrepancies which could be resolved at power without subjecting the plant or personnel to safety or operational challenges either as a result of the replacement or as a result of required post-maintenance testing were completed by October 9.

Several of these discrepancies were resolved through further inspection, for example by rotating the fuse in the fuse clip such that the size could be observed and documented as being the correct size. As identified in item 13 below, all remaining priority 1 and 2 discrepancies will be resolved no later than the end of the 1988 refueling outage.

4 ~ At the completion of Inspection 87-23, several cabinets containing DC fuses remained to be inspected. Those cabinets which can be inspected during plant operation without subjecting the plant or personnel to safety or operational challenges were inspected by October 12. Those cabinets remaining to be inspected will be inspected no later than the end of 1988 refueling outage. discrepancies which may be identified will be addressed as Any described in-item 8 below.

5. Personnel currently involved with DC fuse replacements have been familiarized with. plant procedure requirements for fuse replacement (A-60) as well as with the requirement that fuse size and type be observable and verifiable following installation.

will be familiarized priorinstalling DC fuses in the future Personnel to performing these activities.

Other concerns raised by the NRC inspection during Inspection 87-23 have been reviewed, priorities have been established, and schedules for resolution have been set. These are as follows:

a ~ Engineering documents .providing direction for installation of fuse clip reducers will be issued by October 30.

b ~ Personnel involved in installation of fuse clip reducers will be familiarized with the requirements of item G.a.

prior to performing the activity.

48 ROCHESTER GAS AND ELECTRIC CORP. SHEET NO. 3

.DATE October 21, 1987 I To Mr. W. T. Russell c ~ Walkdowns of wiring for size and type will be performed for the main DC system major distribution panels prior to October 30. Schedules for walkdowns for the balance of the DC system are currently being developed and will be finalized by October 30.

The seismic supports for the B battery have been reexamined and found to be sound with no indication of degradation. An action plan to address this concern will be developed prior to the end of the 1988 refueling outage.

e. A voltage regulation study will be 'performed on the existing DC system by November 30. A voltage regulation study for the reconfigured DC system resulting from EWR 3341 will be completed prior to issuance of EWR 3341 construction documents (see item ll below).

The Design Criteria for EWR 3341 will be revised by October 30 to reflect suggestions made by the NRC inspector.

g. The need for fire barriers in conduit for the purpose of electrical separation will be reviewed and a schedule for any additional actions will be prepared by the end of the 1988 refueling outage.

7 ~ Testing of all DC fuses at the test facility as of October 2 has been completed. Additional DC fuses are being tested as they are provided to the test facility.

8 ~ Nonconformance Reports (NCRs) are being utilized to document and disposition all DC fuse anomalies not addressed in .the Design Analysis described in item 1 above.

9 ~ All Priority 3 DC fuse discrepancies (the lowest priority) which can be resolved at power without subjecting the plant or personnel to safety or operational challenges either as a result of the replacement or as a result of required post-maintanance testing will be resolved as quickly as is reasonable 'while maintaining proper control of all activites and consistent with other plant priorities. All that can be accomplished at power will be resolved by November 30, with the majority of these to be resolved by October 30. Any fuse discrepancies which cannot be resolved at power will be resolved by the end of the 1988 refueling outage as described in item 13 below.

ROCHESTER GAS AND ELECTRIC CORP. SHEET NO. 4

. DATE October 21, 1987 To Mr. W. T. Russell

10. AC motor control center non-motor loads were selected on October 9 for a review of the current as-built configuation.

We expect this review to be completed by November 16 to the extent possible while at power, without exposing the plant or personnel to safety or operational challenges.

ll. The DC fuse upgrade program, All engineering documents EWR 3341, will be continued.

will be issued by December 1987, although we expect the majority of the engineering to be completed by November 30. Higher priority replacements and upgrades will be completed by the end of the 1988 refueling outage and we expect the program to be completed by the end of the 1989 refueling outage.

12. All DC fuses are now part of our configuration control program. Following replacements in accordance with EWR 3341, all future changes in DC fuses will controlled through our configuration control program.

13. All DC fuse discrepancies not resolved as described in items 3 and 9 above will be resolved by the end of the 1988 refueling outage.

We believe the program presented above represents responsive approach to the discrepancies previously identified by our internal reviews and by your Inspection 87-23. Please contact us if you desire any clarification or, desired for your review.

if further information is Very truly yours, Roger W. Kober

4)'S