ML17261A767
| ML17261A767 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/24/1987 |
| From: | Blumberg N, Dudley N, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261A765 | List: |
| References | |
| 50-244-87-27, NUDOCS 8801200382 | |
| Download: ML17261A767 (16) | |
See also: IR 05000244/1987027
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-244/87-27
Oocket No.
50-244
License
No.
OPR-18
Licensee:
Rochester
Gas
and Electric Corporation
49 East Avenue
Rochester,
Facility Name:
R.
E. Ginna Nuclear
Power Plant
Inspection at:
Ontario,
Inspection
Dates:
October
26-30,
1987
Inspectors:
W. Oliveira, Reactor
Engineer
rz -P
-Z'ate
N. Oudley,
Sen or Operations
Engineer
//~3
g 7
date
Approved by:
N. Blumberg,
C ief, Operational
Programs
Section,
Operations
Branch,
ORS,
RI
date
Ins ection
Summar
Routine
unannounced
inspection
on October 26-30,
1987
(Report
No. 50-244/87-27)
Areas Ins ected:
Licensee's
actions
on previous
NRC concerns
and the drawing
control
program.
Results:
One violation (paragraph
3.5) was identified for licensee's
failure
to identify and correct the cause of errors
on Piping and Instrumentation
Drawings.
sso>20ossa
ssoios
ADOCK 05000244"-
8
DETAILS
1.0
Persons
Contacted
"C. Anderson,
Quality Assurance
Manager
"J. Bodine,
Manager,
Nuclear Assurance
"D. Bryant, Quality Assurance
Engineer - Operations
"B. Carroll, Training Coordinator,
Licensing
"R. Davis, Quality Assurance
Engineer
"W. Faustuferri,
Technical Staff Engineer
- A. Jones,
Staff Assistant to Superintendent
- G. Link, Manager, Electrical Engineering
Design
"R. Mecredy, Director, Engineering Services
"J. St. Martin, Station Engineer
- K. Nassauer,
Quality Control Supervisor
"J. Neis, Technical
Section
Engineer
- T~ Schuler,
Operations
Manager
"R. Smith, Chief Engineer
"S. Spector,
Superintendent,
Ginna Production
E. Voci, Mechanical
Engineer
- J. Widay, Technical
Manager
United States
Nuclear
Re viator
Commission
"T. Polich, Senior Resident
Inspector
"N. Perry,
Resident
Inspector
- Denotes
those attending
the exit meeting.
The inspector also contacted
other administrative
and technical
personnel
during the inspection.
2.0
Licensee's
Actions on Previous
NRC Concerns
2. 1
(Closed)
Inspector Follow Item (244/83-19-02):
Drawing Control
Due to the untimely issuance
of drawing revisions,
a large backlog
of Engineering
Work Requests
(EWR) existed which resulted
in a
cumbersome
system for print usage,
since operators
were required to
review all outstanding
EWRs applicable to a print prior to using the
print.
The inspector
reviewed the number of outstanding
EWRs and the
recommendations
made
by the licensee's
Drawing Update
Task Force.
As
a result of the recommendations,
requirements
were established
for
the timely incorporation of drawing changes.
There
has
been
a reduc-
tion in the number of outstanding
EWRs.
This item is closed.
2.2
(Closed)
Inspector
Follow Item (244/85-06-04):
Drawing Control
The Station
Document Control
Room did not track outstanding
modifications
on "non-controlled" drawings.
As
a result, station
personnel
might not have
had drawings which accurately reflected
as-built conditions for up to 30 days after
a modification was
completed, if the drawing was not a controlled document.
2.3
The inspector
reviewed the recommendations
made by the licensee's
Drawing Update Task Force.
As a result of the recommendations
additional drawings,
which were previously "non-controlled," were
included in the controlled drawing system.
The inclusion of the
drawings into the control
system appears
to provide
a means of
ensuring timely incorporation of EWRs and the availability, of
as-built drawings.
This item is closed.
(Open) Inspector Follow Item (244/83-23-02):
Modification Process
Weaknesses
existed in the station modification process
which
included unsigned
procedural
steps,
incomplete review signatures,
and untimely supervisory
reviews.
The functional test of the
pH
meter
had been accepted
even
though the accuracy specified in the
Design Criteria had not been satisfied
when
a
pH of 10 was used
as
the standard.
2.4
The inspector
reviewed
a sample of the Station Modification (SM)
procedures
that were not previously reviewed.
The facility's reviews
were completed
and the procedures
have
been
submitted to Central
Records.
The inspector
sampled
and reviewed
1987
SMs relative to
improving the timely sign off, turnover
and supervisory
review.
The
sign off, turnover and supervisory
reviews averaged
one month as
opposed
to one year for 1983
SMs.
The licensee,
however,
has not
resolved the specific issue of the acceptability
of the results of
the
pH meter functional test.
This item remains
open.
(Closed)
Inspector
Follow Item (244/83-26-01):
Training Program
Timely rev'iew of on-shift work assignments
had not been conducted
and
a program did not exist for evaluation of instructors.
The inspector
reviewed Operator Training Guideline
No.
OTG-4,
Individualized Instruction, which was issued
on October 20,
1987.
The procedure
requires that
a cover sheet
be completed for each
student
when
a training assignment
is issued.
The cover sheet
shows
the date the assignment
is due
and the date the assignment
is reviewed
in the classroom.
The inspector
conducted
a review of selected
individuals'raining records to evaluate
proper completion of the
assignment
cover sheets.
In most cases,
the facility review signa-
tures
were
made
soon after the completion 'of the classroom
reviews.
The inspector
reviewed Training Administrative Procedure
T.R.5.3,
Rev. 3, Instructor Observation,
issued
February
19,
1987.
The
procedure
provides
a program for student
feedback
and evaluation
of instructors.
All instructors
are required to be evaluated
by
their supervisors
annually
and have
been evaluated at least
once in
1987.
Steps
are being taken
by the training supervisors
to establish
a long range
schedule for instructor evaluations.
Student
feedback
forms are collected,
and reviewed
by the corporate training depart-
ment and
a report is i ssued
which may recommend further evaluation of
an instructor.
A formal program for evaluation of instructors is in.
place
and effectively monitors the quality of the training being
provided.
This item is closed.
2.5
(Open) Inspector Follow Item (244/84-06-01):
Effectiveness of the
Quality Control
(QC) Organization
The licensee
had committed to improve the Plant
QC Department's
effectiveness
in the followup of plant activities.
The licensee
does not expect to have its improvement
program fully
implemented until mid 1988.
The inspector
reviewed the following
actions which have
been
taken or are planned:
QC staff was reduced
from twelve to six personnel
in June
1987.
The reduction of the
QC staff is also discussed
in
NRC
Inspection
Report 50-244/87-26
Project (modification)
QC and plant
QC have
been
merged together
and
now report to the
QC supervisor
Operations
QC position
has
been
approved
and will be
established
QC inspectors
are receiving Auxiliary Operator training to
understand
the plant systems,
the training will be completed
by
the
end of December
1987
QC is developing
a
QC inspector training program using
guidelines
QC is having interface meetings with plant sections,
e.g.,
Maintenance,
Operations
and Health Physics,
to prepare for the
Outage
scheduled
in February
1988.
This item remains
open pending full implementation of the program,
and
a review by NRC as to its effectiveness.
2.6
(Closed)
Inspector
Follow Item (244/86-16-02):
Drawing Control
Inconsistencies
existed in the labeling of locked valves
on Piping
and Instrumentation
Drawings (P&IOs), and were identified to the
licensee
in Inspection
Report 50-244/86-16
issued
on November 3,'986.
These identified inconsistencies
on the
P&IDs had not been corrected
by April 1987.
The failure to correct the inconsistencies
and ad-
ditional discrepancies
were identified to the licensee
in Inspection
Report 50-244/87-08
issued
on Nay 26,
1987.
The inspector
reviewed the accuracy of the
P&IDs as detailed in
Paragraph
3.0.
Numerous
new discrepancies
on the
P&IDs were
identified and as
a result
a violation was issued.
Since the
concerns
of inconsistencies
on the P&IDs will be followed as part
of the violation, this item is closed for administrative
purposes.
3.0
Controlled ~Drawin
a
3.1
References/Re
uirements
The following references
and requirements
were
used
by the inspector
to evaluate
the adequacy of the controlled drawing program in general
and the accuracy of the
P&IDs in particular.
10 CFR 50 Appendix B, Criteria III, Design Control
10 CFR 50 Appendix B, Criteria VI, Document Control
10 CFR 50 Appendix B, Criteria XVI, Corrective Action
Safety Guide 33,
1972, Quality Assurance
Program
Requirements
Regulatory
Guide 1.64, Quality Assurance
Requirements
for the
Design of Nuclear
Power Plants
Section
17, Quality Assurance
Program Requirements
for Nuclear
Power Plants,
Corrective Action
Paragraph
9, Quality Assurance
Requirements
for
the Design of Nuclear Power Plants,
Corrective
Action
Technical Specifications, Section 6.8,
Procedures
3.2
Documents
Reviewed
The following procedures
were reviewed
by the inspector.
QE-303, Preparation,
Review and Approval of Engineering
Drawings issued
07/01/86.
gE-323, Preparation,
Review,
and Approval of Computer 'Assisted
Drawing Program
(CAOP) Piping and Instrument
Drawings,
issued
11/18/85.
gE-324, Preparation,
Review and Approval of Drawing Change
Requests,
issued
11/18/86.
gE-316, Preparation,
Review and Approval of Field Change
Requests,
issued 01/23/87.
A-603,
Control of As-Built Drawings and Design Documents,
issued Ol/29/87.
A-606,
Drawing Change
Requests,
issued 02/21/87.
3.3
Details of the Review
In order to assess
corrective actions for problems which had been
identified in previous inspection reports,
the inspector
conducted
a
review of selected
PKIDs to ensure as-built conditions were documented
and that locked valve positions
were properly annotated.
The review
was limited to the
PKIDs and not other drawings since
an upgrade
program
had been
completed for the
PKIDs in January
1987.
3.4
~Fkndfn
s
The licensee's
Drawing Upgrade Task Force,
which had been established
by the licensee
to study the problems concerning control drawings,
presented
recommendations
to the Chief Engineer
in an inter-office
correspondence
dated October 31,
1986.
As a result of the recom-
mendations priority was assigned
by the licensee
to upgrade
the
P@IDs by establishing
target dates for completing three
phases
of a
P8 ID upgrade
program.
The last phase of the
P&ID upgrade
program was
completed
by January
7,
1987.
Revised
procedures
for controlling
changes
to the P&IDs were completed
and issued
by January
23,
1987.
The inspector
conducted
a partial walkdown of two systems
to verify
that selected
PAID drawings represented
as-built conditions.
The
walkdown inspection guidelines,
provided in the Task Management
Manual
Fluid System Diagram Upgrade
document
were used
as guidance.
The
following discrepancies
were noted:
PAID 33013-1248, Auxiliary Cooling Spent
Fuel
Pool Cooling, did
not include the flange for the discharge
connection to the
temporary
gas stripper feed
pump even though the flange for the
suction connection to the
pump was included
on the drawing.
PAID 33013-1262,
Safety Injection and Accumulators (SI), did not
show the heat tracing
on the
RWST supply line.
Ill
P&ID 33013-1262,
Safety Injection and Accumulators (SI), did not
include the test connection
on the SI
pump suction line from the
Boric Acid Storage
Tanks.
The inspector
compared
the drawings for six systems
against
procedure
number A-52.2, Control of Locked Valve and Breaker Operation.
Both
the drawings
and the procedure
are controlled documents.
The follow-
ing discrepancies
were identified.
The throttle position for V-769 was not the
same
on the drawing
and in the procedure.
The representation
for throttled valves
V-769 and
V-7640&C was
inconsi stent
on two different drawings.
Valve V-804 is shown
as throttled in the procedure
and the
drawing does not contain
a note
on throttle position
as it
does for other throttled valves
on the drawing.
Valve V-547 is listed as closed in the procedure
and
open
on the
drawing.
Valve V-1826 is included in the procedure
as locked and is not
indicated
as locked
on the drawing.
The inspector
noted additional
cases
of a lack of drawing control
during the review of the P&IDs.
In one case,
the inspector
was
unable to determine
which Drawing Change
Requests
(DCRs) were still
outstanding.
The Main Control
Room
DCR log and the Operations
Department
DCR log indicated over
a dozen outstanding
DCRs associated
with the
The inspector
was able to determine that three of
these outstanding
had been incorporated
onto the P&IDs.
The
Central
Record
DCR log indicated four outstanding
OCRs associated
with the P&IDs. It was impossible to determine
from the Engineering
Department
DCR log which DCRs were associated
with the P&IDs, however
the Engineering
Department
stated that there
was only one outstanding
DCR associated
with the P&IDs.
In a second
case,
an error was identified by Central
Records
in the
incorporation of a
DCR onto
a print.
The error was addressed
in a
letter from the Engineering
Department to Central
Records
on August
12,
1987,
and involved adding the letter "A" to a valve number.
However,
no change
has
been generated
for over 60 days.
In contrast,
the facility was able to incorporate errors identified by the
inspector in two days.
Central
Records is following the guidance
provided in A-606 and the Engineering
Department is following the
guidance in gE-324.
As
a result,
no change
has
been
made to correct
the error.
J
In a third case,
a drawing was found that contained
a sticker
which
required the user to reference
an
EMR prior to use.
The
EWR which
was referenced
had
been closed out.
There does
not appear to be
a
control
system to assure all drawings initially affected
by an
EMR
are either replaced or reviewed
once
an
EWR is closed out.
The Chief Engineer stated that
no guality Assurance
audit has
been
conducted
by the facility to evaluate
the effectiveness
of the
upgrade
program.
3.5
Conclusion
The licensee
has
completed
a major upgrade
program for the
P&IOs and
judged the
P&IDs ready for review.
A small
sample of P&IDs were
reviewed for accuracy.
The inspector identified numerous errors
and
inconsistencies
in all areas
that were reviewed.
Similar errors
had
been identified by the
NRC in Inspection
Reports
50-244/87-08,
50-244/86-18,
and 50-255/86-16.
The licensee
has failed to effectively implement
a program to ensure
P&ID drawings reflect as-built conditions,
to ensure
P&IOs drawings
are in agreement with controlled procedures
and to ensure
drawing
changes
are adequately
controlled.
The type and
number of errors
found on the
P&IDs represent
recurring deficiencies for which inade-
quate corrective action
has
been taken to determine
the cause
or to
correct
the problem.
The above findings are contrary to the correc-
tive actions requi red by 10 CFR 50 Appendix B, guality Assurance
Criteria for Nuclear
Power Plants, Criteria XVI; ANSI N45.2. 11-
1974Property "ANSI code" (as page type) with input value "ANSI N45.2. 11-</br></br>1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., guality Assurance
Requirements
for the Design of Nuclear
Power
Plants,
Section
9;
and Ginna guality Assurance
Manual Section
16.
This is
a violation (50-244/87-27-01).
4.0
Mana ement Meetin
s
Licensee
management
was informed of the scope
and purpose of the inspec-
tion at the entrance
interview on October 26,
1987.
The findings of the
inspection
were discussed
with licensee
representatives
during the course
of the inspection
and presented
to licensee
management
at the exit inter-
view (see
Paragraph
1 for attendees).
At no time during the inspection
was written material
provided to the
licensee
by the inspector.
The licensee did not indicate that proprietary
information was involved within the scope of this inspection.