ML17262A796
| ML17262A796 | |
| Person / Time | |
|---|---|
| Site: | Ginna |
| Issue date: | 03/24/1992 |
| From: | Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17262A794 | List: |
| References | |
| 50-244-92-02, 50-244-92-2, NUDOCS 9204030024 | |
| Download: ML17262A796 (34) | |
See also: IR 05000244/1992002
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Inspection Report 50-244/92-02
License: DPR-18
Facility:
R. E. Ginna Nuclear Power Plant
Rochester
Gas and Electric Corporation (RGB')
Inspection:
Inspectors:
January,
19 through March 9, 1992
T. A. Moslak, Senior Resident Inspector, Ginna
E. C. Knutson, Resident Inspector, Ginna
D. C. Lew, Project Engineer, Branch 3
Approved by:
W.J
s, hi, Reactor Projects Section 3B
INSPECTION SCOPE
Date
Plant operations, radiological controls, maintenance/surveillance,
security,
engineering/technical
support, and safety assessment/quality
verification.
INSPECTION OVERVIEW
Op
yy 'y
p
dH
'p,
Pgigd
pd
at hot shutdown conditions.
The licensee aggressively pursued the causes of the trips which
were related to a possible main generator voltage regulator malfunction and to a main
feedwater pump trip, respectively.
~dhl
y
1
I:pdpdgdypMy
radioactive material released
through unmonitored steam flow paths.
M inten nce/ urveillance:
Power was reduced to permit plugging of leaking main condenser
tubes.
Effective management
involvement minimized the period of reduced power operation.
En ineerin /Technical S i
rt: Deficiencies in engineering support identified during a
Service Water System Operational Performance Inspection have resulted in apparent
violations of regulatory requirements in the areas of design control and Final Safety Analysis
Report updating.
'F204030024
920326
ADOCK 05000244
8
TABLEOF CONTENTS
VERVIEW
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TABLE OF CONTENTS
1.0
PLANT OPERATIONS.......... ~...................
1.1
Operational Experiences
1.2
Control ofOperations...........................
1.3
Loss of Main Generator Excitation Voltage/Reactor Trip
1.4
Reactor Trip Resulting From Loss of "A" Main Feedwater Pump
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2.0
RADIOLOGICALCONTROLS ..........,............
2.1
Routine Observations .........................
2.2
Radioactive Material Release Accountability for Unmonitored.
Discharge Paths
3.0
MAINTENANCE/SURVEILLANCE
3.1
Corrective Maintenance
3.1.1
Main Condenser Circulating Water Tube Leaks
3.1.2
Nuclear Instrument Power Mismatch Bypass Switch
Replacement
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Routine Observations ....................
3.2
Surveillance Observations
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SECURITY
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5.0
ENGINEERING/TECHNICALSUPPORT
5.1
Service Water System Operational Performance Inspection (50-244/91-
01)
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6.0
6.2
6.3
6.4
6.5
6.6
SAFETY ASSESSMENT/QUALITY VERIFICATION
6.1
Licensee Action on Previous Inspection Findings .............
6.1.1
(Closed) Unresolved Item (50-244/90-31-03) Implementation of
Long Term Corrective Actions....................
6.1.2
(Closed) Unresolved Item (50-244/89-80-06) Evaluation of Site
Contingency Procedures
Related to Fire Fighting
Periodic Reports.................................
Licensee Event Reports (LERs)..................,.....
Plant Operations Review Committee Meetings....... ~... ~...
Material Procurement Program Review ............,......
Quality Assurance/Quality Control (QA/QC) Subcommittee Meeting
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7.0
ADMINISTRATIVE~
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7.1
Backshift and Deep Backshift Inspection
7 ~2
Exit Meetmgs
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DETAILS
1.0
PLANT OPERATIONS
1.1
Operational Experiences
The plant operated at approximately 97% power for most of the inspection period.
On
February 3, 1992, in response
to a load dispatcher's
request, power was reduced to permit
repair to an off-site sub-station.
Since a substantial power reduction was required, power
was further reduced to 47% to support plugging main condenser
tubes.
Upon completing
repairs, a power escalation began.
Coincident with increasing electrical load, the main
turbine tripped when the main generator lost excitation voltage.
In response,
operators
attempted to manually stabilize the plant at no-load conditions but a reactor trip occurred
when the "A" steam generator reached
the low-low level setpoint (17%).
Following
extensive evaluation to determine the cause for the turbine trip, the plant resumed full power
operations on February 10th.
On February 20, 1992, power was redqced to 48% in response
tube
leakage.
Five condenser
tubes were plugged and power was returned to 97% on February
22, 1992.
On February 29, 1992, an automatic shutdown of the "A" main feedwater pump occurred
due to low seal water differential pressure,
resulting in low-low (17%) "A" steam generator
water level and a subsequent
reactor trip. Following review of the trip and completion of
repairs, the plant was restarted
and full power reached
on March 3, 1992.
1.2
Control of Operations
Overall, the inspectors found the R. E. Ginna Nuclear Power plant to be operated safely.
Control room staffing was as required.
Operators exercised control over access
to the
control room.
Shift supervisors consistently maintained authority over activities and provided
detailed turnover briefings to relief crews.
The inspectors reviewed control room log books
for activities and trends, observed recorder traces for abnormalities,
assessed
compliance
with Technical Specifications, and audited selected safety-related
tagouts.
During normal
work hours and on backshifts, accessible
areas of the plant were toured.
No inadequacies
were identified.
1.3
Loss of Main Generator Excitation Voltage/Reactor Trip
Event Overview
During offsite power distribution system switchgear testing on February 3, 1992,
RGB'dentified
a problem with a main line transformer breaker at one of its off-site substations.
Work area isolation for corrective maintenance
on this breaker required deenergizing one of
Ginna's primary transmission circuits, which consequently limited station power output to
2
60%.
Operators commenced
a controlled power reduction at 10:45 AM to support the off-
site maintenance.
Since a significant power reduction was already required, station
management
reduced power to less than 50% to support plugging main condenser
tube leaks.
Due to small magnitude voltage oscillations experienced while adjusting voltage early in the
load reduction, operators placed the main generator voltage regulator in manual control.
This eliminated the voltage oscillation problem, and power was stabilized at 47% at
approximately 2:00 PM on February 3, 1992.
47% reactor power was selected based on
maximizing power production during the main condenser
maintenance,
while maintaining a
3% margin below the reactor protection system setpoint for an automatic reactor trip due to a
main turbine trip (P-9 permissive).
During this period of reduced power operation, the licensee conducted main turbine trip and
stop/intercept valve testing.
To prevent short-term variations in steam flow, as a result of
testing, from producing reactor power oscillations due to automatic rod motion, the rod
control system was placed in manual control for the duration of this testing.
I
At about 10:15 PM, the Control Operator (CO) made a routine small adjustment to main
generator voltage.
Preparations
were in progress to commence the last in the series of main
turbine tests when, at 10:20 PM, the "Generator Lockout Relay" annunciator energized.
This indicated that the main generator output breakers
had opened in response
to a loss of
generator excitation voltage and that the main turbine had tripped.
As anticipated, no reactor
trip occurred because power was less than the 50% turbine trip/reactor trip setpoint.
The
steam dump system actuated to reduce average reactor coolant system (RCS) temperature to
its no-load value of 547'F.
The steam generator water level control system fully opened the
feedwater regulating valves to raise steam generator water levels and ensure an adequate
heat
sink for the reactor.
Despite operator actions to manually coordinate power reduction, RCS
pressure control, and steam generator water level control, a reactor trip from 23% power
occurred at 10:25 PM when the "A" steam generator low-low water level trip setpoint (17%)
was reached.
Following the reactor trip, operators proceeded
to stabilize plant conditions in hot shutdown.
As RCS cooldown continued, an automatic feedwater header isolation occurred due to low
steam generator water level coincident with low RCS average temperature.
This in turn,
caused
an automatic startup of the auxiliary feedwater (AFW) system, including both motor
driven pumps and the steam turbine driven pump.
Although the system operated
as
designed,
operators noted rapid oscillations of 30 to 40 gpm in turbine driven AFW pump
flow. Since both motor driven AFW pumps were operating normally, the turbine driven
pump was shut down from the main control board (MCB) after approximately three minutes
of operation.
At 10:29 PM, in response
to lowering pressurizer level due to the continuing RCS cooldown,
the Head Control Operator shut the main steam isolation valves (MSIVs) as pressurizer level
reached 6%.
This action initially arrested
the cooldown at approximately 534'F and
pressurizer level began to increase due to charging pump operation and RCS heatup.
However, approximately
13 minutes later, operators noted that the RCS was again cooling
down at approximately 0.5'P/minute.
At that point, control room personnel noted that the
"A" MSIV was not fully seated
as indicated on the MCB. The Auxiliary Operator was
dispatched
to check the position of the "A" MSIV and reported that it was shut by local
valve position indication. At 10:52 PM, approximately 23 minutes after the control switch
had been placed in the "close" position, the "A" MSIV indicated shut by MCB indication.
At 11:15 PM, both steam generator atmospheric relief valves (ARVs) automatically opened
due to high steam generator pressure
as a result of the RCS heatup.
Primary plant conditions
were subsequently
stabilized at no-load temperature
using one motor driven AFW pump and
the ARVs for decay heat removal.
Corrective Actions
Anal
is of imulator Re ul
In an attempt to verify that operational guidance provided to operators for future operations
at just below 50% reactor power was adequate,
the training department used the plant
simulator to repeat the trip scenario with varying degrees of operator interaction.
Although
the results did not definitively identify an optimum mode of operation for avoiding a reactor
trip, they did support that automatic control modes for the rod control and feedwater
regulating valve control systems provided the greatest margin to reaching a trip setpoint.
Results of these simulator runs were disseminated
to operations personnel for information but
no procedure changes
were appropriate.
The inspector considered this effort to be a positive
initiative by the licensee, both in terms of attempting to identify vulnerabilities in the
response
to the actual trip, as well as in providing future operational guidance.
"A" M IV Slow
losure
With plant conditions stabilized in hot shutdown, the "A"MSIV was cycled several times to
verify its operability.
On the first three attempts, the valve rapidly (within a matter of
seconds) went to a nearly full shut position (as indicated by local position indication) and
then stopped.
On subsequent
cycles, the valve went fully shut in less than five seconds.
A similar slow closure of the "A" MSIV following a reactor trip occurred on September 26,
1990.
In response
to that event, the licensee performed an analysis of the adequacy of MSIV
operation.
The MSIVs are Atwood and Morrill30-inch swing check valves which employ an
air actuated piston for opening and a spring for closure.
Closure is also assisted by gravity
(the disc drops from a horizontal position to close) and, ifpresent,
steam flow from the
associated
In that analysis, RG&E concluded that frictional force developed
by the packing on the disc pivot may be sufficient to overcome the force of the closure
spring and prevent full closure under low- or no-flow conditions; however, they further
concluded that these valves would fully shut under design basis accident conditions, and
therefore functioned satisfactorily.
Details of the analysis are presented
in Inspection Report,
50-244/90-19.
Failure of the "A" MSIV to fully close during the September 26, 1990 event
was attributed to the combination of packing friction and low differential pressure
across the
disc; its ultimate closure was attributed to increased differential pressure which resulted when
steam to the turbine driven auxiliary feedwater pump (which taps off upstream of the MSIV)
was secured.
Slow closure of the "A" MSIV during the February 3rd trip was similarly
attributed to the combination of packing friction and low differential pressure.
In response
to the past slow closure experienced
on September 26, 1990, the licensee
committed to performing several actions to evaluate and improve MSIV performance.
During the 1991 refueling outage, many of these items were completed with some scheduled
to be performed during future outages.
During the 1992 refueling outage, the "A" MSIV
will undergo a major inspection and both valves willbe repacked with a different type of
packing material in an attempt to reduce packing friction. In accordance with Technical Specification 4.7, MSIVs are tested during each refueling outage under no flow and at no
load conditions, to verify that they close upon signal within five seconds.
Through review of
test records,
the inspectors confirmed that the valve met this criteria.
Since at power
conditions affected valve performance,
(he inspectors willcontinue to follow licensee efforts
to improve MSIV performance
as an unresolved item that requires further review and
evaluation (50-244/92-02-01).
Turbine Driven Auxilia
F
water P m
On February 4, 1992, the turbine driven auxiliary feedwater pump was started in accordance
with the monthly performance test procedure (PT-16M-T) in an attempt to identify the source
of the flow oscillations that occurred following the reactor trip. Upon startup, significant
steam leakage was observed in the area of the throttle block.
Subsequent
investigation
revealed the source to be the seating surface between the throttle block and the turbine
casing.
The pump had been considered operable until this point because,
in spite of the flow
oscillations, it was still capable of delivering flow in excess of the technical specification
requirement.
Repair of the throttle block steam leak, however, made the pump inoperable
and placed the licensee in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> technical specification action statement.
The throttle
block was removed and the gasket replaced.
This eliminated the steam leak, however, rapid
flow oscillations were still present when the pump was again started.
Pump operation was
recorded on video tape; subsequent
evaluation of this record revealed the cause of the
oscillations to be a loose linkage in the throttle mechanism.
Specifically, a stop nut on a
threaded rod had worked loose, thereby allowing for travel within the linkage.
The linkage
was tightened and operational testing was completed satisfactorily.
The pump was declared
operable on the afternoon of February 4, 1992.
As interim corrective action for the loose stop nut, the licensee instituted a four-hour
verification of its position.
Permanent corrective action to lock the position of the stop nut is
being developed.
Main
enerat r Volta e Re ulat r
RG&E undertook a thorough examination of the main generator voltage regulating system.
This troubleshooting involved both static and operational testing, and was extensively
supported by corporate engineering,
as well as the vendor and an independent
test laboratory.
All other trip-related plant deficiencies had been satisfactorily addressed
by the afternoon of
February 5. While voltage regulator troubleshooting continued, a reactor startup was
conducted on the evening of February 5.
Power escalation was halted at approximately 2%
rated thermal power, pending resolution of the main generator voltage regulator problem.
By the afternoon of February 6, 1992, shutdown troubleshooting was completed.
However,
despite a comprehensive effort, no single cause had been identified for the loss of generator
excitation.
A plan was developed to return to power operation without the voltage regulator
problem identified.
This plan included:
system monitoring at key points in the circuitry
using chart recorders to provide both real-time and historic information; continuous electrical
engineering support for the operations department; hold points during power ascension
for
evaluation of system performance;
and specific instructions to operations personnel regarding
actions to be taken for malfunction or failure of the voltage regulator.
Startup and Power Ascension
A reactor startup was commenced
on the evening of February 5, 1992.
The inspectors
observed portions of the reactor startup, conducted in accordance with Operations Procedure
0-1.2, "Plant Startup from Hot Shutdown to Full Load," revision no. 110, effective
December
12, 1991.
Operations were generally well controlled, and clear, concise
communications between supervisors and operators were observed.
On one occasion,
a
.
procedural step sequence
deficiency was encountered
which stopped operations until a
procedure change was processed.
Criticality was achieved at 10:55 PM on February 5, 1992.
Power was increased
to
approximately 2% and then stabilized for improvement in steam generator water chemistry.
The main generator was closed on the grid at 10:04 PM on February 6, 1992.
No
abnormalities were noted during main generator operations with manual control of the
voltage regulator.
When voltage regulation was shifted to automatic, small magnitude
voltage oscillations were immediately evident.
Voltage regulation was promptly returned to
manual control.
On the recommendation of the Westinghouse representative,
an adjustment
was made to the automatic voltage regulator damping circuit. This eliminated the voltage
oscillation problem, and power escalation to 30% commenced at 12:03 AM on February 7,
1992.
Upon achieving steam generator water chemistry specifications, power escalation
resumed and full power was achieved at 7:50 PM, February 10, 1992.
There were no
further problems with main generator voltage regulation during the remainder of the
inspection period.
The augmented monitoring of voltage regulator components
remains in
place.
Cl
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1.4
Reactor Trip Resulting From Loss of "A"Main Feedwater Pump
During operations at approximately full power on February 29, an automatic shutdown of the
"A" Main Feedwater (MFW) pump occurred due to low seal water differential pressure
(d/p).
Operators responded by manually reducing turbine load and starting all auxiliary
feedwater pumps.
Rod control and feedwater control systems were in automatic at the onset
of the transient and remained so throughout.
In spite of prompt, correct operator actions, the
reactor tripped at 1:46 PM, approximately two minutes after loss of the MFW pump, due to
low level (17%) in the "B" steam generator.
Following the reactor trip, operators stabilized the plant in hot shutdown.
The MSIVs were
subsequently
closed to control RCS cooldown; both valves were fully closed within seconds
of the close order.
The extensive RCS cooldown caused by the reactor trip from high
power, combined with the rapid introduction of feedwater, resulted in a decrease
in
pressurizer level below the indicating range.
The pressurizer did not fully drain, as indicated
by reactor vessel water level indicating system (RVLIS) remaining at 100% and no step
decrease
occurring in RCS pressure
(both of which would indicate steam bubble formation in
the reactor vessel).
Pressurizer
level indication was regained after approximately five
minutes as a result of RCS heatup and charging pump operation.
The minimum RCS
pressure during the transient was approximately 20 psig above the automatic engineered
safeguards
features actuation setpoint of 1750 psig.
The inspector was in the main control room at the time of the reactor trip. The response of
the control room operators
was observed to be highly professional.
In light of the slow
closure of the "A" MSIV on February 3, 1992, the inspector also verified, by local position
indication, prompt closure on this occurrence.
The inspector noted no procedural or
performance deficiencies during response
to the transient and transition to operations in hot
shutdown.
The cause of the main feedwater pump trip was found to be a buildup of corrosion products
in the seal water d/p switch high pressure
sensing line, combined with leakage from an
associated
compression fitting; this flow restriction and leak path caused the high pressure
side of the d/p switch to depressurize,
producing the alarm and trip.
Corrective action
included blowing down the high and low pressure
sensing lines, replacing leaking
compression fitting and associated
tubing, and replacing the d/p switch.
In addition, the "B"
MFP seal water d/p switch sensing lines were blown down and proper switch calibration was
verified. A contributor to the reactor trip was the fact that the delay time between receipt of
the low seal water d/p alarm and the MFP trip was only five seconds.
This problem had
been previously addressed
before the trip occurred, and a modification to extend the time
interval to one minute had been approved for accomplishment during the upcoming refueling
outage.
As a result of this trip, the modification was completed prior to resuming full power
operations.
8
7
Startup commenced
at 3:32 AM on March 1, 1992 and criticality was achieved at 5:18 AM.
No significant difficulties were encountered
during the startup and power ascension.
Operations at approximately full power were resumed on March 3, 1992.
2.0
RADIOLOGICALCONTROLS
2.1
Routine Observations
The inspectors periodically confirmed that radiation work permits were effectively
implemented, dosimetry was correctly worn in controlled areas and dosimeter readings were
accurately recorded,
access
to high radiation areas was adequately controlled, and postings
and labeling were in compliance with procedures
and regulations.
Through observations of
ongoing activities and discussions with plant personnel,
the inspectors concluded that
radiological controls were conscientiously implemented.
No inadequacies
were identified.
2.2
Radioactive Material Release Accountability for Unmonitored Discharge Paths
4
Following the reactor trip of February 3, increasing iodine concentrations in RCS coolant
samples indicated that some small fuel rod cladding leakage had developed.
Although small
in magnitude, the inspector was concerned that accurate radioactivity release estimates were
being made, since known steam generator (SG) tube leakage existed (approximately 60 cubic
centimeters/minute
total) and normal decay heat removal was by discharging steam through
the SG atmospheric relief valves, which is an unmonitored release path.
The licensee
responded by developing a release estimate.
The inspector determined that radioactivity
release estimates for routine unmonitored steam releases
are not routinely performed.
This
will remain an open item pending evaluation of the licensee's actions to address
this concern
(50-244/92-02-02).
3.0
MAINTENANCE/SURVEILLANCE
3.1
Corrective Maintenance
3.1.1
Main Condenser Circulating Water Tube Leaks
At 12:10 AM on February 20, 1992, a main condenser circulating water tube leak developed
in the 1B2 water box.
The first indication that a leak had developed was an annunciator
alarm for the all-volatile treatment (AVT) system, which indicated high condensate
conductivity.
Chemical analysis confirmed that elevated sodium concentrations
existed in the
"B" condenser hotwell and both steam generators.
From the relative concentrations of ionic
impurities and sample point locations, further analyses indicated the source of contamination
to be lake water leaking into the 1B2 water box.
Steady-state impurity concentrations
indicated that the leakage rate was approximately 30 gallons per minute.
Although the
condensate
polishing demineralizers removed most of the ionic impurities, they were not
designed to accommodate
a leak of this magnitude.
A 10%/hr power reduction was commenced at 1:38 AM to support placing the "B"
condenser out of service for repairs to the 1B2 water box.
The rate of power reduction was
subsequently
reduced because
the boric acid addition rate was limited by in-progress
maintenance
on the chemical and volume control system (CVCS). Normal letdown was taken
out of service the previous day to support a valve replacement.
A smaller capacity, excess
letdown. system,
was in operation.
Power was stabilized at 45% at approximately 8:30 AM.
The licensee held a management
meeting at 8:30 AM to establish an integrated plan for
maintenance
on the condenser waterbox, the CVCS valve replacement,
and any related
corrective maintenance.
As a result of this meeting, the scope of maintenance activities were
clearly defined, priorities were established,
and management
responsibility for specific
actions associated
with each maintenance action were positively identified.
The inspector
considered this to be a positive management initiative which had resulted from PORC
discussions of lessons learned from the February 3, 1992 forced outage.
Due to the large size of the circulating water leak, the licensee gave extensive consideration
to the possibility that increased
backpressure
due to air leakage into the condenser
once the
waterbox was drained might require the main turbine to be tripped.
As a result, isolation
and draining of the 1B2 waterbox was well planned and closely monitored.
Backpressure
remained sufficiently low to allow continued turbine operation throughout the waterbox
maintenance,
and close management
involvement allowed immediate resolution of operational
concerns which could otherwise have resulted in a turbine trip.
Corrective Actions
A variety of techniques were used to identify leaking circulating water tubes in the 1B2
waterbox.
Infrared thermography was used on initial waterbox entry and was successful in
identifying two leaking tubes.
Use of thermography for identification of tube leaks was a
new technique; although initially successful, difficultywas encountered with condensation
on
the camera lens due to high humidity in the waterbox.
One tube leak was identified by
covering the tube sheets with plastic wrap; condenser vacuum translated through the leak
caused
the plastic wrap over the leaking tube to rupture.
Two additional leaks were
identified and plugged, one using the helium tracer gas technique, and the other during eddy
current inspection of tubes adjacent the leaking tubes.
There was no obvious pattern to the leaking tubes, such as would be expected ifthe cause
had been mechanical impingement.
RG&E concluded that one of the leaking tubes was
probably the major contributor and had failed suddenly; the other four were minor
contributors and had existed prior to the problem.
The cause of the failures could not be
conclusively determined,
although tube vibration was considered likely,
Other corrective maintenance
observed by the inspector during the period of reduced power
operation included replacement of the CVCS nonregenerative
heat exchanger inlet drain valve
(2232) (Work Order No. 9122368).
Through attendance
at the pre-job briefing, review of
9
work package documentation,
and observation of craft activities, the inspector concluded that
this maintenance
was properly controlled with good coordination between the working groups
involved.
3.1.2
Nuclear Instrument Power Mismatch Bypass Switch Replacement
On January 28, 1992, the inspector observed corrective maintenance performed on the
nuclear instrument system (NIS) power mismatch bypass switch for nuclear instruments N-41
and N-43.
The switch was replaced because it was causing erratic signals from the nuclear
instruments to the automatic rod control system.
This deficiency was identified during
troubleshooting of an intermittent problem with the rod control system,
as discussed
in
inspection report 50-244/91-29.
Overall, the maintenance activity was performed effectively. The technician's
communications
and conduct were formal and professional.
Appropriate test equipment and
tools were staged and readily available.
The inspector verified that test equipment was
calibrated, administrative approvals were obtained prior to starting work, quality control hold
points were established
and implemented,
the replacement
switch was properly certified and
controlled, and technical specification requirements were not violated by this evolution.
Control room operators were informed and cognizant of the maintenance activity.
The briefing which was conducted prior to the start of the maintenance activity was
constructive.
Good interactions were noted among the personnel involved.
As a result of
this briefing, several enhancements
to the procedures
were identified, including clarification
of Quality Control (QC) verification requirements in TSR No.92-019, "NIS Power
Mismatch Bypass Switch Replacement,"
more detailed work step descriptions,
and addition
of a work step to ensure residual voltages were eliminated to prevent incorrect readings..
These procedural changes
and clarifiications were appropriately reviewed and implemented
through a Procedure Change Notice, PCN 92T-0045.
During the maintenance activity, the inspector noted an inconsistency between the
maintenance procedure, M-57.5, "Replacement of NIS Power Mismatch Bypass Switch," and
the corporate engineering procedure, EE-35, which provides specifications for soldering
activities including material specifications for consumable items.
Although the QC procedure
used during the maintenance activity referenced Procedure EE-35, no material specifications
for the solder and flux were included in the maintenance procedure.
No procurement
tracking or control of soldering materials was noted.
Through interviews with licensee
personnel, it was identified that the flux had a one year shelf life, yet flux had not been
ordered through material procurement for several years.
In discussions with Material Procurement personnel,
the lack of solder specifications in the
plant's procurement process
had been identified approximately three weeks prior to the
maintenance activity. The material specification was being developed at the time of the
maintenance activity and has since been completed.
The licensee determined that the solder
Cl
10
used during the maintenance activity conformed to the specification and was acceptable.
Based on the fact that flux does not become a permanent component of soldered joints and
that soldered joints are inspected prior to acceptance,
the licensee concluded that material
specifications for flux were not necessary.
The licensee stated, however, that the flux would
be controlled through their consumable program to ensure that the shelf life is not exceeded.
The pre-job briefing and discussions were thorough and effective.
During this briefing,
participants identified enhancements
to the maintenance procedures
and followed the
appropriate procedural guidelines to implement the changes.
Inconsistency,
however, was
noted in material specifications and acceptance
criteria during the soldering portions of the
evolution (refer to section 6.5).
These inconsistencies
were appropriately addressed
by the
licensee.
3.2
Surveillance Observations
Inspectors observed portions of surveillances to verify proper calibration of test
instrumentation,
use of approved procedures,
performance of work by qualified personnel,
conformance to Limiting Conditions for Operation (LCOs), and correct system restoration
following testing.
The following surveillance was observed:
Periodic Test (PT) 9.1.17, Undervoltage Protection - 480 Volt Safeguard Bus 17,
revision 2, effective date December
10, 1991, observed on February 12, 1992.
No unacceptable
conditions were identified.
4.0
SECURITY
4.1
Routine Observations
During this inspection period, the resident inspectors verified that x-ray machines and metal
and explosive detectors were operable, protected area and vital area barriers were well
maintained, personnel were properly badged for unescorted or escorted
access,
and
compensatory
measures
were implemented when necessary.
Site modifications are in
progress to upgrade site security systems.
No unacceptable
conditions were identified.
5.0
ENGINEERING/TECHNICALSUPPORT
5.1
Service Water System Operational Performance Inspection (50-244/91-201)
During the period from December 2nd through December 20th, 1991, a Service Water
System Operational Performance Inspection was conducted by the Special Inspection Branch
of the Office of Nuclear Reactor Regulation.
The results of this effort were documented
in
'
11
Inspection Report 50-244/91-201.
Based on a review of the report by the NRC staff, several
items were identified as violations of NRC requirements.
Details of these findings are
provided in Appendix A. In summary, the violations are:
1.
Design reports, calculations, and analyses were not properly controlled, verified, and
accepted
as required by 10 CFR 50, Appendix B, Criterion III, "Design Control"
(50-244/91-201-01).
2.
The Final Safety Analysis Report was not accurately updated to reflect the actual
service water system configuration as required by 10 CFR 50.34(b) and 10 CFR 50.71(e) (50-244/91-201-11).
3.
Pre-operational
test results were not reviewed to compare current system operation
and configuration to the original design basis as required by 10 CFR 50, Appendix B,
Criterion III, "Design Control," and Criterion XI, "Test Control" (50-244/91-201-14).
Additionally, the following items are considered
unresolved pending further staff review to
ascertain whether each is an acceptable item, a deviation, or a violation:
Reanalysis of the service water system hydraulic model and application of its results
~
~
to the system (50-244/91-201-02).
Evaluation of the safety classification of the "A" spent fuel pool heat exchanger
(50-244/91-201-04).
Assessment of the single failure of a service water pump discharge check valve
(50-244/91-201-07).
Establishment of the appropriate service water system low pressure setpoint
(50-244/91-201-12).
Evaluation of the controls to assure that redundant equipment willnot be taken out of
service while companion equipment is undergoing surveillance testing (50-244/91-201-
15).
The staff acknowledges
actions of RG&E to include other weaknesses
and areas for
improvement identified in Inspection Report 50-244/91-201 into the RG&E Commitment and
Action Tracking System to assure formal resolution of these matters.
Regarding the inclusion of the appropriate number of operable service water pumps in the
Ginna Technical Specifications, it is the NRC staff's understanding
that an analysis will be
submitted for NRC staff review.
Pending staff review of this analysis,
an interim
administrative control has been established by RG&E requiring that three (3) service water
pumps be operable and, ifless than three pumps are operable, a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limiting condition
12
for operation would be entered until a third service water pump is restored to operable status,
or the reactor will be placed in hot shutdown within the next six hours and in cold shutdown
in the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
RG&E's progress in addressing
these issues willbe evaluated in future NRC inspections.
6.0
SAFETY ASSESSMENT/QUALITY VERIFICATION
6.1
Licensee Action on Previous Inspection Findings
6.1.1
(Closed) Unresolved Item (50-244/90-31-03) Implementation of Long Term
Corrective Actions
This item remained open pending the implementation of long term corrective actions taken in
response
to the temporary disabling of Engineered
Safeguard Features instrumentation in
December
1990.
In response
to the violation, RG&E itemized 29 long term actions that
would be taken to prevent recurrence.
'through review of relevant documentation and
discussions with licensee representatives,
the inspector determined that these items are being
appropriately addressed.
As a final action, the licensee's Nuclear Safety Audit and Review
Board will meet on March 10-11, 1992, and perform a review of the effectiveness of these
corrective actions.
The inspectors had no further concerns on this matter.
6.1.2
(Closed) Unresolved Item (50-244/89-80-06) Evaluation of Site Contingency
Procedures
Related to Fire Fighting
This item remained open pending the establishment of an action plan to delete fire fighting
plans and strategies from site contingency procedures
and reformat this information.
Through discussions with the site fire protection engineer and review of relevant
documentation,
the inspector determined that an action plan has been developed.
Fire
brigade site contingency procedures
are now going to be incorporated into a fire response
plan.
In order to ensure consistencies
in the fire response plan and address configuration
management
considerations,
a fire response plan task management
manual is being drafted.
This manual willprovide the technical basis of the fire response plan, the plan task
description, a writing and drafting guide, and a milestone schedule.
Full development is
scheduled for completion by December 31, 1992.
The inspectors had no further questions on
this item.
6.2
Periodic Reports
Periodic reports submitted by the licensee pursuant to Technical Specification 6.9.1 were
reviewed.
Inspectors verified that the reports contained information required by the NRC,
that test results and/or supporting information were consistent with design predictions and
performance specifications,
and that reported information was accurate.
The following
reports were reviewed:
8
13
Monthly Operating Reports for January
1992
Semiannual Radioactive Effluent Release Report (July - December,
1991)
No unacceptable
conditions were identified.
6.3
Licensee Event Reports (LERs)
LERs submitted to the NRC were reviewed to determine whether details were clearly
reported, causes were properly identified, and corrective actions were appropriate.
The
inspectors also assessed
whether potential safety consequences
were properly evaluated,
generic implications were indicated, events, warranted onsite follow-up, and applicable
requirements of 10 CFR 50.72 were met.
The following LERs were reviewed (Note: date indicated is event date):
92-001
Component Failure in Containment Radiation Monitor Causes
Containment
Ventilation Isolation (January 5, 1992)92-002
Feedwater Transient, due to Loss of Main Generator Excitation Induced
Turbine/Generator Trip, Causes Low-Low Steam Generator Level Reactor
Trip (February 3, 1992)
The inspector concluded that the LERs were accurate and met regulatory requirements.
No
unacceptable
conditions were identified.
6.4
Plant Operations Review Committee Meetings
On January 29, 1992, the inspector observed a scheduled Plant Operational Review
Committee (PORC) meeting.
Areas reviewed included plant operations events,
modifications, procedure changes,
corrective action reports, and limiting conditions for
operations.
The PORC adequately
met the intent and purpose of the meeting.
The technical specification
requirements for an adequate quorum and items for review were satisfied.
Thorough reviews were noted during the meeting.
For example, discussions
on a main
feedwater pump room ventilation problem were thorough.
Although the PORC recognized
that this was a non safety-related equipment, they nonetheless
determined that it was
necessary
to track the issue in the corrective action report to ensure that a related issue of
nuisance alarms for control room operators
as well as the problem itself were resolved.
The
PORC demonstrated
its commitment to address problems from a safety focus rather than
strictly a compliance focus.
14
The inspector also observed
a scheduled PORC meeting on February 13, 1992, and PORC
post-trip reviews on February 5 and 29, 1992.
6.5
Material Procurement Program Review
As a result of some inconsistencies
noted during a maintenance activity in the material
specifications for soldering material (Section 3.1.2), the inspector reviewed the plant's
material procurement area to determine ifthese inconsistencies
reflected a programmatic
weakness.
The licensee is in the process of revising and improving their program.
This effort has
included development of commercial dedication specifications for safety-related
components,
controls for consumable items, and consistency between Plant Material Procurement,
Corporate Engineering, and Construction requirements.
The licensee has completed a
significant portion of the component specifications for commercial items.
Two commercial
grade dedication plans, Crane Valve Co. gate valves (Evaluation No.91-057) and globe
valves (Evaluation No.91-087), were reviewed and determined to be thorough.
These
dedication plans included detailed critical parameters for the components
as well as the bases
for these parameters.
The licensee has prioritized the importance of each component, and is
continuing to develop specifications,
as well as identifying additional components which may
require specifications; an example is the solder material described in Section 3.1.2 of this
report.
At the end of the inspection period, the specifications for solder had been completed.
II
The licensee has prioritized and made good progress in the control of consumable items and
the items maintained by other plant work groups.
For example, the solid state drawers,
modules, and power supplies which are kept by the Instrument and Controls (1&C) group
have been controlled by Maintenance Procedure M-71.2, "Module Rework/Test Procedure."
The procedure requires that these modules cannot be placed into operation unless Quality
Control has accepted
the material.
Most consumable items have been returned to the stock
room for control.
The oversight of the soldering flux was partially attributed to review of
material in the I&C shop.
All shops, however, had been reviewed.
The Material
Procurement group intends to review all items in the I&C shop which should address
any
other potential deficiencies.
The licensee has recognized that the procurement specification and processes
between the
plant and Corporate Engineering and Construction have inconsistencies,
Efforts are
continuing to identify the inconsistencies
and develop resolution for inconsistencies.
Overall, the licensee has made significant progress and improvements in the material
procurement area.
The order of problems to be addressed
appears
to be properly prioritized
and weaknesses
in the program have been identified and are appropriately being addressed.
Deficiencies identified with the solder material did not indicate a programmatic problem.
15
6.6
Quality Assurance/Quality Control (QA/QC) Subcommittee Meeting
On January 29, 1992, the inspector attended the quarterly meeting of the RG&E corporate
QA/QC subcommittee.
The inspector observed that the meeting was well attended by plant
and corporate management.
Discussions were open and candid on the nature and status of
audit findings, with good participation by all members.
The inspector had no questions on
these matters.
7.0
ADMPGSTRATIVE
7.1
Backshift and Deep Backshift Inspection
During this inspection period, backshift inspection was conducted on February 5, 1992.
Deep backshift inspections were conducted on the following dates:
January 25, February
17,
23, 29, and March 1, 1992.
7.2
Exit Meetings
At periodic intervals and at the conclusion of the inspection, meetings were held with senior
station management
to discuss the scope and findings of this inspection.
The exit meeting for
inspection report 50-244/92-02 was held on March 13, 1992 with the following individuals
attending:
Name
Title
Thomas Moslak
Edward Knutson
Robert Mecredy
Joe Widay
Thomas Marlow
Richard Marchionda
Andy Harhay
Steve Adams
Paul Gorski
Clair Edgar
. Paul Wilkens
Mike Lilley
Jeff Wayland
Ron Jaquin
Matt Clark
Terry White
Jack St. Martin
Tom Harding
Tom Plantz
Fred Mis
Don Filion
Sr Resident Inspector-NRC
Resident Inspector-NRC
Vice President,
Ginna Nuclear Production-RG&E
Plant Manager-RG&E
Superintendent,
Ginna Production-RG&E
Superintendent,
Support Services-RG&E
Mgr. HP & Chemistry-RG&E
Mgr. Technical Services-RG&E
Mgr. Mech. Maintenance-RG&E
Mgr. Electrical Maintenance/I&C-RG&E
Mgr. Nuclear Engineering Services-RG&E
Mgr. Nuclear Assurance-RG&E
Reactor Engineer-RG&E
NS&LEngineer-RG&E
NS&LEngineer-RG&E
Operations-RG&E
Corrective Action Coordinator-RG&E
Modification Support Coordinator-RG&E
Planning and Scheduling-RG&E
Health Physicist-RG&E
Radiochemist-RG&E