ML17262A617
| ML17262A617 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/30/1991 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9110150004 | |
| Download: ML17262A617 (13) | |
Text
ACCELERATED DISTRIBUTION DEMONSTPA.TION SYSTEM
'r REGULATORY INFORMATXON DISTRIBUTION SYSTEM (RXDS)
CL ESSXON NBR:9110150004 DOC.DATE: 91/09/30 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFXLIATION MECREDY,R.C.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPXENT AFFILIATION HODGES,M.W.
Region 1 (Post 820201)
SUBJECT:
Responds to violations
& deviations noted in EDSFI Rept 50-244/91-80.Corrective actions:setpoints
& tolerances specified in Procedure PR-1.1 revised to allow adequate margin to Tech Spec limit.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72) 05000244 RECIPXENT ID CODE/NAME PD1-3 PD INTERNAL: AEOD AEOD/DSP/TPAB NRR HARBUCK,C.
NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DST/DXR 8E2 NUDOCS-ABSTRACT OGC/HDS 1 RGN1 FILE 01 EXTERNAL EG&G/BRYCEiJ ~ H NSIC COPIES LTTR ENCL 1
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1 RECIPIENT XD CODE/NAME JOHNSON,A AEOD/DEIXB DEDRO NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 OE DFILE 02 NRC PDR COPIES LTTR ENCL 1
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D NOTE TO ALL"RIDS" RECIPIENTS:
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PLEASE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED!
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89 EAST AVENUE, ROCHESTER N. Y. 14649-0001 ROBERT C. MECREDY Vice Presidenc Clone Nuclear Produclion September 30, 1991 TELEPHONE AREAcoDE 7r6 546 2700 U.S. Nuclear Regulatory Commission Attn:
Marvin W. Hodges Director, Division of Reactor Safety 475 Allendale Road King of Prussia, Pennsylvania 19406
Subject:
Reply to Notice of Violation 50-244/91-80-04, Notice of Deviation 50-244/91-80-01,
-02 and EDSFI Inspection Report 50-244/91-80 R.E.
Ginna Nuclear Power Plant Docket No. 50-244
Reference:
Letter M.W. Hodges (NRC) to R.C. Mecredy, (RGE),
"Electrical Distribution System Functional Inspection for Ginna Nuclear Power Station (Report No. 50-244/91-80)", dated August 21, 1991.
Dear Mr. Hodges:
Pursuant to the requirements of 1QCFR2.201 this letter is provided, in response to the Notice of Violation, Notice of Deviation, and Inspection Report transmitted to Rochester Gas and Electric by the above referenced. letter.
Attachment 1 to this letter restates the one apparent violation and two apparent deviations and provides RG&E's responses.
RG&E takes exception to the violation as set forth by the NRC and has presented, information supporting this position in the attachment.
RG&E requests that the NRC reconsider this violation.
RG&E has performed a preliminary review of the inspection report and, in general, concurs with the findings and summaries of actions that we are taking to address these findings.
- However, some minor clarifications to the report are considered necessary and are identified. in Attachment 2.
Should you have any further questions regarding this response, please contact me.
ct' sg r~ Q OO
/ac BJF/185 Ver truly yours, Robert C. Mecredy
~ cI5~g0 ZC 0
~5 4'OOi,s 0 CLU US Nuclear Regulatory Commission (original)
Document Control Desk Washington, DC 20555 Ginna Senior Resident Inspector
ATTACHMENT 1 Res onses to A arent Violation and Deviations RESTATEMENT OF VIOLATION As a result of the inspection conducted on May 6 through June 7,
- 1991, and in accordance with the "General Statement of Policy and.
Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C, (Enforcement Policy)
(1990),
the following violation was identi-fied R.E.
Ginna Technical Specifications, Section 6.8.1, requires that written procedures be established and implemented for surveillance and test activities of safety related equipment.
Procedure PR-1.1, "Protective Relay Calibration 480V Undervoltage and Ground Alarm Scheme for Buses 14,16,17, and 18,", Section 5.3, requires that an I&C/Electrical Equipment Failure (Safety Related)
Report be prepared to evaluate those relays that exceed the calibrated tolerance.
Contrary to the above, on May 22, 1991, no I&C/Electrical Equipment Failure Safety Related Report
- existed, for three undervoltage
- relays, whose as-found dropout voltage settings were below the
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Technical Specification limits.
This is a Severity Level IV Violation (Supplement I).
1.
THE REASON FOR THE VIOLAT10N RG&E agrees that the calibration procedure PR-1.1 requires that an "I&C/Electrical Equipment Failure (Safety Related.)
Report" be prepared to evaluate those relays that exceed the acceptance criteria.
However the "as found," dropout voltages for the undervoltage relays did not exceed the acceptance criteria.
The calibration for which the violation is cited was performed during the 1991 refueling outage.
Prior to the
- outage, calibration procedure PR-1.1 "Protective Relay Calibration 480V Undervoltage and. Ground Alarm Scheme for Buses 14,16,17 and 18" was revised.
Therefore, this was the initial use of the procedure following a revision which changed both the setpoint and calibration tolerance for the relays.
Procedure PR-1.1 was revised when it was discovered that the undervoltage relay dropout setpoints did not allow sufficient margin above the Technical Specif ication limit.
This was reported previously by LER 90-008.
The revised procedure has acceptance criteria for "as found" setpoints of
+ 1 volt from the previous calibration's "as left" setpoint.
Since, in this
- instance, the "as left" setpoints were from the 1990 calibra-tion using the earlier revision of PR-1.1, it was possible to satisfy the
+1 volt criteria of the new procedure with "as-found" settings below the Technical Specification limits. In
, continued.
fact all sixteen undervoltage relays did meet the acceptance criteria, despite the fact that three were slightly below the Technical Specification limit.
.Therefore, the initiation of Procedure A25.2, "I&C/Electrical Equipment Failure (Safety Related)
Report" was not required by procedure for the three relays.
RG&E recognized during the review of PR-1.1 that the "as found" setpoints of the three relays were below the Technical Specifi-cation limit.
However, further formal documentation of this situation was not considered necessary for the following reasons:
v
- 1. The undervoltage system was not required. to be operable at the time of the calibration (cold shutdown mode).
- 2. The root cause of the problem had been previously reported in LER 90-008, and corrective actions to prevent recurrence were already in place.
Given the information provided
- above, RG&E respectfully requests the NRC to reconsider this violation.
'HE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As described in LER 90-008, the setpoints and tolerances specified in procedure PR-1.1 were revised to allow adequate margin to the Technical Specification limit.
The allowable "as left" relay settings in the revised procedure ensures that any settings below the Technical Specification limitwillalso fail the procedure's acceptance criteria and.
that therefore a
"I&C/Electrical Equipment Failure (Safety Related) Report" will be required.
During the Inspection an evaluation for the three "as found" setpoints found below the Technical Specification limits was formally documented by completion of procedure A25.1 "Ginna Event Report".
THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The more nservative setpoints and calibration tolerances of the revised procedure PR-1.1 ensure that any future "as found" setpoints below the associated Technical Specification limits are evaluated and. reported if necessary.
4 ~
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 4/2/91, the date that the revised PR-l.l with the new settings was successfully complet-ed.
At that point, all undervoltage relays were set with adequate margin above the Technical Specification limit to preclude unidentified drift below the limit.
, continued RESTATEMENT OF DEVIATIONS As a result of the inspection conducted on May 6 through June 7,
- 1991, and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C
(1991),
the following deviations were identified:
1.
Ginna Updated Final Safety Analysis
- Report, paragraph.
3.1.2.2.8, specifies compliance with General Design Criteria 17, which
- states, in part, "the onsite electrical power suppl'ies, including the batteries, and the onsite electric distribution
- system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure."
Contrary to the above, before May 21, 1991, tie breaker BT17-18 was in such a configuration that a single fault in its control circuit could cause the breaker to close during plant opera-tion. If this occurs when both emergency diesel generators are running out of phase following a postulated accident, three out of the four emergency buses could be lost, affecting operation of both trains of the onsite electric power supplies.
2.
Ginna Updated Final Safety Analysis
- Report, paragraph 8.3.1.4.2, Separation of Redundant Circuits, states, in part, "All components requiring redundant
- cabling, as well as the cabling for redundant components, have been identified and. the redundant control cables are run separately."
Contrary to the
- above, the 125VDC control circuit conductors from Train A and Train B component cooling water pumps shared the same conductor cables.
REPLY TO DEVIATION 1:
1.
THE REASON FOR THE DEVIATION The bus tie breaker BT 17-18 is an original plant configuration design feature.
Original licensing basis analysis did not consider spurious closure of a 480V breaker from a "hot short" at the closure coil credible.
Redundant interlocks in the breaker control circuitry were provided so that no single failure of a control device would allow closure of the breaker when both buses were energized.
This configuration was considered. to meet the single failure criteria at the time, and review of this during the Systematic Evaluation Program (NUREG-0821, Topic VI-7.C.1) also found it acceptable.
2 ~
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED In response to the concern raised. by the inspection team the tie breaker was withdrawn to the test position.
In this
, continued
- position, a single fault in the control circuit willnot cause the tie breaker to close during plant operation.
Affected plant procedures were revised to reflect this new configura-tion.
3.
4.
THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS Procedural requirements to maintain the breaker in the test position while the plant is operating assure that there willbe no further deviations.
THE DATE WHEN FULL COMPLTANCE WILL BE ACHIEVED Full compliance was achieved when the bus tie breaker BT17-18 was placed in its test position on May 22, 1991.
REPLY TO DEVIATION 2 2.
3.
4 ~
THE REASON FOR THE DEVIATION The component cooling water pump motor control circuitry is original plant design.
Separation criteria was evolving during the time period of plant construction and in many cases was backfit.
Since the circuitry in question is part of a non-safety control feature in a
safety related system it is believed that this discrepancy was missed during review.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Rochester Gas and Electric has initiated work to correct the deficiency in the component cooling water control circuitry during the 1992 refueling outage.
THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS The discrepant 125VDC control circuits willbe separated during the 1992 refueling outage.
In addition, Rochester Gas and Electric has initiated a
study that will identify safety related or engineered safety features systems circuits where current Ginna separation criteria is not met.
Identified deficiencies will be evaluated and corrective actions taken where appropriate.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The redundant component cooling water control circuits are scheduled to be separated during the 1992 Ginna Station refueling outage.
Attachment 2
Clarifications to Ins ection Re ort 50-244/91-80 Inspection Report Statement On page 9, Section 2.4.1, paragraph 3, the Inspection Report states:
"The second discrepancy in the steady-state calculation involved the licensee's incorrect and nonconservative assumption that
'The EDG can be loaded to its two hour rating immediately after it has been loaded to its 30 minute rating'"
Clarification RGKE believes that this sentence should read:
"The
- second, discrepancy in the steady-state calculation involved the licensee's assumption that
'The EDG can be loaded to its two hour rating immediately after it has been loaded to its 30 minute rating,'hich the inspection team believes is incorrect and nonconservative."
Note:
RG&E does not agree that the assumption is incorrect and nonconservative.
Although we concur that the assumption is not in accordance with Regulatory Guide 1.9 nor IEEE Standard 387-1984, the EDGs were purchased long before these
- guides, and were not rated in accordance with these guides.
The ability to load the diesel to its two hour rating immediately after 30 minutes of operation at its 30 minute rating is in accordance with the manufacturer's instructions and was verified during plant startup testing.
Therefore, we feel that the assumption is conservative.
- However, we concur with the conclusion of Inspection Report that the point is moot due to the demonstrated ability to reduce conservatisms in other assumptions of the loading calcula-tion.
Inspection Report Statement On page 10, Section 2.4.2 second. paragraph the Inspection Report states:
"The licensee committed to complete the final dynamic loading analysis, including justification of the unverified.
assumptions, by May 1992."
4
'V
C, continued Clarification
.1 RG&E believes that this sentence should read:
"The licensee committed to complete the final dynamic loading analysis, including justification of the unverified assumptions, with the exception of the verification and validation of the model software,- by May 31, 1992.
The licensee committed to complete the verification and valida-
~
tion of the model software by September 30, 1992."
Inspection Report Statement On page 20, Section 3.2.1 paragraph 7 the Inspection Report states:
"The licensee agreed to correct the value of 10,000 gallons stated in the technical specification" Clarification RG&E believes that this sentence should read:
"The licensee agreed to review the Technical Specification diesel fuel oil requirement, its
- bases, the fuel oil consumption calculation, and the applicable EDG loading calculation to determine if changes or clarifications to the Technical Specification are necessary."
Inspection Report Statement On page 25, Section 3.4 paragraph 8 the Inspection Report states:
"On a long term basis, EWR-4612 was initiated on December 17, 1976..."
Clarification RG&E believes that this sentence should read:
"On a long term basis, EWR-4612 was initiated on December 17, 1986..."