ML17264B020

Insp Rept 50-244/97-06 on 970630-0803.No Violations Noted. Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support

ML17264B020
Person / Time
Site:	Ginna
Issue date:	09/09/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17264B019	List: ML17264B017 ML17264B020
References
50-244-97-06, 50-244-97-6, NUDOCS 9709160078
Download: ML17264B020 (90)

See also: IR 05000244/1997006

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

License No.

DPR-18

Report No.

50-244/97-06

Docket No.

50-244

Licensee:

Facility Name:

Location:

Inspection Period:

Inspectors:

Rochester

Gas and Electric Corporation (RGSE)

R, E, Ginna Nuclear Power Plant

1503 Lake Road

Ontario, New York 14519

June 30, 1997 through August 3, 1997

P. D. Drysdale, Senior Resident Inspector

C. C. Osterholtz, Resident Inspector

J. C. Jang, Senior Radiation Specialist

Approved by:

L. T. Doerflein, Chief

Projects Branch

1

Division of Reactor Projects

9709ih0078

970909

PDR

ADQCK 08000244

8

PDR

EXECUTIVE SUMMARY

R. E. Ginna Nuclear Power Plant

NRC Inspection Report 50-244/97-06

This integrated inspection included aspects of licensee operations,

engineering,

maintenance,

and plant support.

The report covered

a 5-week period of resident

inspection.

In addition, it includes the results of an announced

inspection by a regional

specialist in the radiological environmental effluent monitoring area.

~Oerations

The licensee was taking appropriate actions toward resolving repeated

problems associated

with the operability of the auxiliary feedwater (AFW) recirculation line air-operated valves.

The AFW system configuration accurately reflected the normal configuration designated

in

plant drawings.

The procedure governing operator workarounds

and operator challenges

included the

appropriate definitions and criteria, and the procedure's flowchart provided good guidance.

The procedure was also an efficient tool to aid the quick and accurate identification of

workarounds

and challenges.

However, the inspectors were concerned that the licensee

had not evaluated

all plant and equipment deficiencies for identification as an operator

workaround or challenge.

The licensee took appropriate actions and correctly implemented the improved technical

specifications for high steam flow bistable inoperability.

The application of LCO 3,0.3 was

brief and the licensee's decision to manually trip the high steam flow bistables effectively

satisfied the improved technical specification requirements.

The licensee's intentions to

evaluate

a new setpoint value and to pursue the necessity of the high steam flow function

with Westinghouse

were appropriate.

Annunciator response

(AR) procedures

gave good guidance for response to abnormal

events.

AR references

and transitions to emergency,

abnormal, and equipment restoration

procedures

were appropriate

and accurate.

Maintenance

Observed maintenance

activities were performed in accordance with procedure

requirements.

Equipment received adequate

post-maintenance

testing prior to its return to

service.

Good personnel

and plant safety practices were observed during the maintenance

work that was completed.

However, the maintenance

activity to replace the bus 14 UV

coil was considered deficient in that the maintenance

had to postponed

due to a

discrepancy with the part number on the replacement

coil.

Surveillance procedures

were current and properly followed, and all surveillance work was

properly authorized.

The as-found and as-left test data met the expected performance

values and the specified acceptance

criteria stated in the Updated Final Safety Analysis

Report.

Executive Summary (cont'd)

The licensee successfully replaced the spent fuel pool weir gate bladder and its leakage

was significantly reduced.

Planned maintenance to seal the bottom of the fuel transfer

canal was appropriately scheduled for completion prior to the next refueling outage.

The licensee's attempts to reduce vibrations in the 8-control rod drive system motor-

generator

(B-MG) set, though unsuccessful,

were considered

positive since no action had

been required.

A system procedure was deficient in that it did not contain guidance on the

use of equipment routinely used to aid in motor-generator

set synchronization,

and a

procedure change was initiated.

The licensee's intention to provide a permanently installed

hardware aid for MG set synchronization was appropriate.

The licensee's vendor manual program was previously deficient in meeting established

program requirements,

and did not satisfy the requirements of 10 CFR 50, Appendix B,

Criterion V, "Instructions, Procedures,

and Drawings."

However,'the overall consequences

of this problem were minor, and the licensee's ongoing corrective actions to resolve the

problem were significant.

This item was considered

a Non-Cited Violation and was closed

(NCV 50-244/97-06-01).

~En ineerin

The operability assessment

following fouling of all four service water (SW) pump strainers

adequately

addressed

pertinent system parameters.

The data obtained from previous

periodic tests substantiated

the licensee's conclusion that pump operability had been

maintained throughout the operability assessment

period.

The licensee's root cause analysis effectively identified the lack of lubrication as a direct

contributor to premature circuit breaker secondary contact failures.

The procedure

changes

made were appropriate to ensure that proper lubrication was maintained.

The

training conducted to enhance

maintenance

worker awareness

of secondary contact

degradation was effective, as evidenced by discoveries of secondary contact degradation

during routine maintenance.

The licensee aggressively pursued discrepancies

in the C- and D-SW pump escalated

discharge pressures.

The licensee's conclusion that the discrepancy was caused by

mispositioned flow transducers

appeared

likely, given the noted variance in actual SW flow

to the component cooling water heat exchangers

from previous tests.

The licensee's

intention to increase the surveillance frequency on the C- and D-SW pumps to further

evaluate flow transducer performance was appropriate.

~

The NRC granted the licensee an exemption from the accidental criticality monitoring

requirements of 10 CFR 70,24.

The NRC concluded that the existing engineered

features

in the new fuel preparation

area (NFPA) that were designed to preclude an accidental

criticality, together with the low probability of such an event and the existing radiation

monitors, constituted good cause for the exemption.

Item URI 50-244/96-12-01 was

closed.

Executive Summary (cont'd)

The licensee met the radiological effluent monitoring program (REMP) requirements

specified in the Offsite Dose Calculation Manual (ODCM), including management

controls,

quality assurance

audits, measurement

laboratory quality assurance/quality

controls for

REMP samples by a contractor laboratory, and the meteorological monitoring program.

The

ODCM was significantly upgraded from previous versions and was properly implemented.

Two weaknesses

were identified and categorized

as inspector follow-up items in the areas

of the environmental thermoluminescent

dosimeter program and meteorological monitoring

system.

(IFI 50-244/97-06-02 and IFI 50-244/97-06-03)

TABLE OF CONTENTS

EXECUTIVE SUMMARY

TABLE OF CONTENTS .....

v

I. Operations

01

02

03

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Conduct of Operations .,

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01.1

General Comments

01.2

Summary of Plant Status ......

Operational Status of Facilities and Equipment ...

02.1

Auxiliary Feedwater

(AFW) System Walkdown and

Recirculation Line Air-Operated Valve Performance......

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02.2

Operator Workarounds and Challenges

02.3

Improved Technical Specification (ITS) Limiting Condition for

Operation (LCO) 3.0.3 Entry for High Steam Flow Bistables

.

Operations Procedures

and Documentation

03.1

Annunciator Response

Procedure

Review

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II. Maintenance ...................

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M1

M2

M8

Conduct of Maintenance

M1.1

Observations of Maintenance Activities............

M1.2

Observations of Surveillance Activities

Maintenance

and Material Condition of Facilities and Equipment

M2.1

Spent Fuel Pool Weir Gate Bladder Replacement ~...

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M2.2

B-Motor-Generator (B-MG) Set Realignment ....

Miscellaneous Maintenance

Issues

M8.1

(Closed) URI 50-244/97-02-02: Vendor Manual Program

Requirements

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III. Engineering

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E8

Engineering Support of Facilities and Equipment .. ~.............

E2.1

Service Water Pump Operability Assessment

Following Strainer

Foullllg

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E2.2

Circuit Breaker Secondary Contact Failure Root Cause Analysis

E2.3

Service Water Pump High Discharge Pressures ............

Miscellaneous

Engineering Issues

E8.1

(Closed) URI 50-244/96-12-01: Criticality Monitor for the New

Fuel Preparation Area ..

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IV. Plant Support

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R1

Radiological Protection and Chemistry (RP&C) Controls...........

R1.1

Implementation of the Radiological Environmental Monitoring

Program (REMP)

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R1.2

Environmental Thermoluminescent

Dosimeter (TLD) Program

and Comparisons of Collocated TLD Results

R2

Status of RP&C Facilities and Equipment

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Table of Contents (cont'd)

R3

R6

R7

R2.1

Calibration of Meteorological Monitoring System and Air

Samplers

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RPRC Procedures

and Documentation ........

R3.1

Review of REMP and ODCM Procedures,

and Audit Reports

RPSC Organization and Administration

R6.1

Review of The REMP Organization and Administration

Quality Assurance

(QA) in RP5C Activities...........,.....

R7,1

Review of Quality Assurance Audit Reports and QA/QC

Laboratory Actiwties

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V, Management Meetings..........,............

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Exit Meeting Summary

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Pre-Decisional Enforcement Conference

Summary

L2

Review of UFSAR Commitments.............

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ATTACHMENTS

Attachment

I - Partial List of Persons

Contacted

- Inspection Procedures

Used

- Items Opened, Closed, and Discussed

- List of Acronyms Used

Attachment

II - Predecisional

Enforcement Conference

List of Attendees

and

Presentation

Slides

Re ort Details

I. 0 erations

01

Conduct of

Operations'1.1

General Comments

Ins ection Procedure

IP 71707

The inspectors observed plant operations to verify that the facility was operated

safely and in accordance

with licensee procedures

and regulatory requirements.

This review included:

1) tours of the accessible

areas of the facility; 2) verification

that the plant was operated

in conformance with the improved technical

specifications (ITS), and appropriate action statements

for out-of-service equipment

were implemented; 3) verification of engineered

safety feature (ESF) system

operability; 4) verification of proper control room and operator shift staffing; and

5) verification that logs and records accurately identified equipment status or

deficiencies.

01.2

Summar

of Plant Status

The Ginna plant remained at full power throughout the inspection period.

All

operator performance observed throughout the inspection period was good.

Operators demonstrated

effective communications

and performed actions in

accordance

with procedural requirements.

On June 30, 1997, air operated valve

AOV-4238 (condensate

recirculation control valve to the B-condenser)

failed open.

The automatic digital feedwater control system (ADFCS) automatically started the

A-standby condensate

pump and no secondary plant transient was observed.

Offsite power was reduced to one source between 12:43 a.m. and 12:32 p.m. on

July 20, 1997, when circuit 751 was lost after an animal climbed a power

distribution pole and caused

a short circuit. This resulted in a loss of power to

safeguards

buses

16 and 17 and generated

an automatic start of the B-emergency

diesel generator

(B-EDG). Operators immediately aligned circuit 767 to provide

power to buses

16 and 17 and then secured the B-EDG. The loss of circuit 751

caused

no primary or secondary plant transients,

and the circuit was realigned to

power buses

16 and 17 after it was restored.

ITS limiting condition for operation (LCO) 3.0.3 was entered for 49 minutes on

July 30, 1997, when the licensee discovered that all four bistables for high steam

flow were inoperable

(see section 02.3).

LCO 3.0.3 was exited after operators

manually placed the bistables in the trip position.

No power reduction was required.

'Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized

reactor inspection report outline.

Individual reports are not expected to address

all outline

topics.

02

Operational Status of Facilities and Equipment

02.1

Auxiliar Feedwater

AFW S stem Walkdown and Recirculation Line Air-0 crated

Valve Performance

aO

Ins ection Sco

e (71707)

The inspector performed

a walkdown of the AFW system and evaluated

performance problems associated

with the motor-driven AFW pump recirculation

line AOVs.

b.

Observations

and Findin s

The motor-driven AFW pump recirculation air-operated valves AOV-4304 (A-train)

and AOV-4310 (B-train) for the motor-driven AFW pumps have repeatedly failed

their periodic test criteria of 1) starting to open with AFW discharge flow between

75 and 100 gallons per minute (gpm), and 2) being full open at 40 gpm (see

Inspection Report (IR) 50-244/97-01).

On July 14, 1997, AOV-4310 also failed to

open during the performance of periodic test PT-16Q-B, "AFW Pump B - Quarterly,"

and the licensee generated

ACTION Report 97-1117 to initiate corrective action.

The operability of the AFW pump recirculation line AOVs do not affect the ability of

the AFW pumps to perform their engineered

safety feature (ESF) function.

However, the pumps could be damaged if the recirculation lines are not available

below a pump flow of 40 gpm.

The unreliability of the recirculation flow path made

a "workaround" necessary for control room operators to ensure that AFW flow

remains greater than 40 gpm (see section 02.2).

On July 23, 1997, the inspector

attended

a meeting between instrumentation

and control (IRC) personnel,

results

and tests (R5T) personnel,

and the AFW system engineer who explored possible

resolutions to the recirculation line AOV problems.

The licensee identified that a

fundamental reason for the AOV failures was that the controllers used to throttle

the valves were pressure

sensing controllers which were calibrated and tested using

AFW pump discharge flow. The licensee concluded that either the AOV controller

test and calibration methods should be changed to be consistent with a pressure

controlled AOV, or that an instrument design change was needed to replace the

pressure

controllers with flow controllers.

However, the licensee felt more specific

information was necessary

prior to making a final recommendation.

The licensee s

planned actions included:

Comparison of AFW discharge pressure

vs. flow to determine ifthe

controller is being used in too small a pressure

range

Diagnostic testing of the valve actuators

Analysis of controller history, maintenance,

and repairs

Reviewing the methods of other utilities for accomplishing AFW recirculation

line testing and flow control

The inspector also performed

a walkdown of the AFW system using the licensee s

piping and instrumentation drawings (PRIDs) to verify all valves in the system were

in their proper position, to check for system leaks, and to ensure that no equipment

conditions existed that might degrade system performance.

No discrepancies

were

noted during the walkdown.

C.

Conclusions

The inspector concluded that the licensee was taking appropriate actions toward

resolving repeated

problems associated with the operability of the AFW recirculation

line AOVs. The actual AFW system configuration accurately reflected the normal

configuration designated

in plant drawings.

02.2

0 erator Workarounds

and Challen

es

a 0

Ins ection Sco

e (71707)

The inspectors reviewed the licensee's

procedures

and implementation controls for

operator workarounds

and challenges.

b.

Observations

and Findin s

The inspectors reviewed administrative procedure A-52.16, "Operator

'orkaround/Challenge

Control." The procedure defined an operator workaround as

"...a long term equipment deficiency that affects a decision making process or

requires additional operator action to compensate

for the condition.

The condition

could have an adverse impact on normal or emergency plant operation ifthe

compensatory

action is not performed."

An operator challenge was defined as an

item that "...willnot in and of itself impact plant operations without compensatory

actions.

These items are normally considered

as a burden to operations..."

Procedure A-52.16 also contained

a flow chart for operations personnel to use for

identifying plant equipment deficiencies as workarounds or challenges.

The licensee

currently had six identified operator workarounds

and nineteen identified operat~-

challenges.

The inspector compared the workarounds

and challenges against the

flowchart procedure criteria and found them to be consistent with procedure

requirements.

The inspector identified two plant deficiencies that appeared to meet the criteria for

an operator workaround.

One deficiency involved the unreliability of the B-AFW

recirculation line AOV (see section 02.1).

The licensee agreed that the AOV's

unreliability represented

a workaround, and subsequently

added the B-AFW

recirculation line deficiency to the workaround list. Another deficiency involved the

reactor vessel level indication system (RVLIS) that required operators to refer to

revised emergency preparedness

implementation procedures

(EPIPs) when

consulting the Ginna Emergency Action Levels (EAL) chart to evaluate an event for

a Site Area Emergency.- The EPIPs were recently revised to add a 9% bias to the

indicated RVLIS level (see IR 50-244/97-05).

The inspector noted that the EAL

deficiency was only tagged on the control room chart, and not on the chart located

in the technical support center.

Based on the inspector's questions,

the licensee

revised the EAL charts in the control room, the technical support center, and the

emergency operating facility to indicate that a RVLIS level of 77% (formerly 68%)

with no RCPs running constituted

a Site Area Emergency for reactor coolant system

(RCS) leakage.

After all the EAL charts were revised, and the control room chart

tag removed, the workaround no longer applied.

C.

Conclusions

The inspectors concluded that the procedure governing operator workarounds and

operator challenges included appropriate definitions and criteria, and that the

procedure's flowchart provided good guidance.

The procedure

also appeared to be

an efficient tool to aid in the quick and accurate identification of workarounds

and

challenges.

However, based upon two examples of deficiencies that were not

formally designated

as operator workarounds, the inspectors were concerned that

the licensee had not evaluated

all plant and equipment deficiencies for identification

as an operator workaround or challenge.

02.3

Im roved Technical S ecification

ITS Limitin Condition for 0 aration

LCO 3.0.3

Ent

for Hi h Steam Flow Bistables

Ins ection Sco

e (71707)

-'The inspector reviewed the licensee's

actions following their discovery that all four

high steam flow inputs to the main steam isolation circuitry were inoperable.

b.

Observations

and Findin s

On July 30, 1997, the licensee entered

LCO 3.0.3 for approximately 49 minutes

when it was determined that all four high steam flow inputs into the main steam

isolation (MSI) circuitry were inoperable.

This was due to the fact that the existing

channel bistable setpoint would not ensure that the ITS "trip allowable

value" (C0,55E6 Ibn ~hr) would be met after incorporation of the setpoint's

uncertainty and drift, even though the setpoints were within the limits of the "trip

setpoint value" specified in the ITS (60.4E6 pounds mass per hour (Ibm/hr)). Since

the ITS did not address the simultaneous

inoperability of all four high steam flow

inputs to the MSI circuitry, the licensee entered

LCO 3.0.3.

High steam flow is just one of three inputs to the MSI circuitry. To obtain an

automatic MSI, high steam flow must be present together with a low average

reactor coolant system

(RCS) temperature

(Tave; K545 degrees fahrenheit

(

F))

and a safety injection (Sl) signal.

This MSI function acts as a back up to the "Hi Hi

Containment Pressure"

MSI function (18 psig), and the "Hi Hi Steam Flow" MSI

- function (S3.6E6 Ibm/hr). The ITS required that the steam flow input to the MSI

circuit have two channels operable

in each steam line. The licensee determined that

'. if all four high steam flow bistables were manually placed in the trip position, then

the high steam flow input to the MSI circuitry would again be operable, since it

would then be performing its safety function for that circuitry. The licensee

subsequently

manually tripped the high steam flow bistables and exited LCO 3.0.3.

In this condition, the plant would receive an automatic MSI with only a low Tave

coincident with an Sl signaI present.

The high steam flow bistables are automatically tripped at 10% power.

Therefore,

at 100% power, they were already in the tripped position when the licensee

manually placed them in trip. The licensee indicated that they would evaluate an

appropriate setpoint value that would ensure that allowable limits would be met.

They also indicated that they planned to pursue with Westinghouse

the actual need

for this circuitry, since it primarily provided a back up function and was not

specifically credited in any accident analysis.

C.

Conclusions

The inspector concluded that the licensee took appropriate actions and correctly

implemented

ITS requirements

regarding high steam flow bistable inoperability,

The

application of LCO 3.0.3 was brief and the licensee's decision to manually trip the

high steam flow bistables effectively satisfied the ITS requirements.

The licensee's

intentions to evaluate

a new setpoint value and to pursue the necessity of the high

steam flow function with Westinghouse

were appropriate.

03

Operations Procedures

and Documentation

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"'03.1 -Annunciator Res onse-Procedure

Review

a.

Ins ection Sco

e (71707)

The inspector reviewed the annunciator response

(AR) procedures

for appropriate

guidance

and for proper referral to pertinent procedures.

-b.

Observations

and Findin s

The inspectors reviewed ten AR procedures

in the control room associated

with

abnormal plant events, including low condenser

vacuum, high steam flow, reactor

coolant pump high vibrations, and low flow to the spent fuel pool.

In all cases

reviewed, the AR procedures

gave guidance consistent with other plant procedures,

and the references

and transitions to emergency,

abnormal, and equipment

restoration procedures,

when warranted by their respective entrance criteria,-were

also included as part of the AR. The inspector also checked local AR procedures

in

the diesel generator rooms and near the AFW pumps to verify that the proper

revisions were provided.

C.

Conclusions

The inspectors concluded that the AR procedures

gave good guidance for response

to abnormal events.

AR references

and transitions to emergency,

abnormal, and

equipment restoration procedures

were appropriate

and accurate.

II. Maintenance

M1

Conduct of Maintenance

M1.1

Observations of Maintenance Activities

a.

Ins ection Sco

e 62707

The inspectors observed

portions of plant maintenance

activities to verify

conformance with the maintenance

rule, that the correct parts and tools were

utilized, that the applicable industry codes and ITS requirements were satisfied, that

adequate

measures

were in place to ensure personnel safety and prevent damage to

plant structures,

systems,

and components,

and that the licensee properly verified

equipment operability upon completion of post maintenance

testing.

b.

Observations

and Findin s

The inspectors observed

all or portions of the following maintenance

work activities:

Bus 14 undervoltage

(UV) coil replacement while performing PT-9.1.14,

"Undervoltage Protection - 480 Volt Safeguard

Bus 14." This work was

initiated on July 10, 1997, but was interrupted and postponed

until the

refueling outage due to a discrepancy with the part number on the

replacement coil. During the pre-job briefing, the inspector inquired as to

how the licensee verified that the part number on the replacement

UV coil

was correct.

The licensee subsequently

discovered that the part number on

the replacement coil had one letter and one number different from the part

number specified in the work order.

The licensee believed that the

replacement coil part was the correct part, but that an administrative

paperwork error had occurred.

The inspectors expressed

concern that a

replacement part with the wrong identification number was staged for the

job and no verification was performed prior to the pre-job briefing. The

licensee generated

an ACTION Report (97-1108) to investigate and correct

the deficiency.

The installed UV coil was still within its calibration

requirements.

Realignment of the B-control rod drive system motor-generator

(MG) set per

procedure M-11.35, "Rod Drive Motor Generator Set - Generator

Maintenance" observed

on July 14, 1997 (see section M2.2),

B-Safety Injection (B-Sl) pump breaker routine maintenance

per procedure

M-32.1.50, "DB-50 Circuit Breaker Maintenance" observed

on July 21,

1997.

The inspector noted that maintenance

workers identified and replaced

several secondary contacts that showed early signs of degradation

(see

.

section E2.1).

c.

Conclusions

The inspectors concluded that the observed maintenance

activities were performed

in accordance

with procedure requirements.

Equipment received adequate

post-

maintenance

testing prior to its return to service.

Good personnel

and plant safety

practices were observed

during the maintenance

work that was completed.

However, the maintenance

activity to replace the bus 14 UV coil was considered

deficient in that the maintenance

had to postponed

due to a discrepancy with the

part number on the replacement coil.

M1.2

Observations of Surveillance Activities

a.

Ins ection Sco

e 61726

The inspectors observed selected surveillance tests to verify that approved

procedures

were in use and procedure details were adequate,

that test

instrumentation was properly calibrated and used, that ITS surveillance requirements

were satisfied, that testing was performed by qualified and knowledgeable

personnel,

and that test results satisfied acceptance

criteria or were properly

dispositioned.

b.

Observations

and Findin s

The inspectors observed portions of the following surveillance activities:

PT-9.1.17, "Undervoltage Protection - 480 Volt Safeguard

Bus 17," and

PT-9.1.18, "Undervoltage Protection - 480 Volt Safeguard

Bus 18,"

observed

on June 30, 1997.

PT-12.2, "Emergency Diesel Generator B," observed

on July 8, 1997.

In

addition to the regular PT, special diagnostic test equipment was installed to

record data for cylinder pressure,

engine vibrations, and diesel cooler service

water flow.

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PT-2.7.1, "Service Water Pumps," observed

on July 17 and July 24, 1997

(see section E2.3).

c.

Conclusions

The inspectors confirmed that the procedures

used were current and properly

followed, and that the shift supervisor authorized

all surveillance work to proceed.

The licensee properly certified the qualifications of all surveillance test personnel

involved in the tests.

The as-found and as-left test data met the expected

., performance values and the specified acceptance

criteria stated in the Updated Final

Safety Analysis Report.

M2

Maintenance and Material Condition of Facilities and Equipment

M2.1

S ent Fuel Pool Weir Gate Bladder Re lacement

aO

Ins ection Sco

e (62707)

The inspector reviewed the licensee's efforts to decrease

spent fuel pool (SFP)

leakage through the weir gate into the fuel transfer canal.

b.

Observations

and Findin s

On July 7, 1997, the licensee replaced the bladder seal in the SFP weir gate in an

attempt to reduce the ongoing leakage into the refueling transfer canal.

This

maintenance

was performed as part of an effort to eliminate a known leak path of

SFP water into the residual heat removal (RHR) pump room through the fuel transfer

canal (see IR 50-244/95-17 and IR 50-244/97-05).

The replacement

bladder had

not been previously used, but was approximately 15 years old. After the

installation, no appreciable

change

in the weir gate leakage was observed.

On

July 8, 1997, the licensee again replaced the weir gate bladder using one that was

recently manufactured,

and the leak rate dropped significantly. The licensee

indicated that they intended to dry out the refueling transfer canal and to apply a

sealant to its metal liner prior to the next refueling outage.

The licensee expected

that the sealant would prevent any water in the transfer canal from leaking into the

RHR pump room.

C.

Conclusions

The inspectors concluded that the licensee successfully replaced the SFP weir gate

bladder in that its leak rate was significantly reduced.

The maintenance

to seal the

bottom of the fuel transfer canal was appropriately scheduled for completion prior to

the next refueling outage.

M2.2

B-Motor-Generator

B-MG Set Reali nment

a 0

Ins ection Sco

e (62707)

The inspector observed

and reviewed the licensee's efforts to reduce vibrations in

the B-control rod drive system motor-generator

(MG) set.

b.

Observations

and Findin s

On July 14, 1997, the inspector observed the licensee perform a realignment of the

B-MG set.

Following review of previous vibration and temperature

checks, the

- licensee noted that B-MG set vibrations had more than doubled since the last

bearing replacement

in February 1997.

Bearing temperature

also increased from

approximately 88

F to 114

F over the same time period.

Vibration and

temperature

readings for the B-MG set were still well within the acceptable

range,

but no such increase had been recorded for the A-MG set.

Engineering personnel

indicated that the vibration peaks noted were indicative of motor-generator

alignment problems and were not related to excessive

bearing wear.

However, if

the MG set continued to operate with the increased vibration, bearing life could be

reduced.

The licensee therefore performed

a realignment to determine if any

variance in the motor-generator

base mounts had developed.

During the

realignment, the licensee noted

a very small amount of variance on the northeast

base mount and made minor adjustments to eliminate it. Once the realignment was

completed,

and the B-MG set returned to service, the licensee took additional

vibration and temperature

readings; however, no decrease

in either vibration or

temperature

was noted.

The licensee indicated that all the data pertaining to the

B-MG set would have to be reevaluated to identify other possible corrective

measures.

Following the realignment, the inspector observed operations

personnel return the

8-MG set to service per procedure

S-1A, "Startup of Rod Drive Motor-Generator

Sets."

The inspector noted that after the B-MG set was running and ready to be

paralleled with the A-MG set, operations

personnel deviated from procedure S-1A

and referred to a written addendum

to the work package.

Using the addendum,

operators opened the B-MG set breaker cabinet and installed a Simpson multimeter

to compare phases between the A- and B-MG sets so that they could be

synchronized

more easily.

Procedure

S-1A contained

a NOTE that indicated MG set

synchronization would occur automatically when the two sources were in phase

once the motor-generator

breaker switch was manipulated.

The inspector inquired

why the Simpson multimeter was necessary for this activity. The licensee indicated

that the "automatic feature" associated

with MG set synchronization

had never

really worked, and that an operator would sometimes have to manipulate the motor-

generator breaker switch as many as a dozen times before "catching" both sources

in phase.

The licensee therefore deemed it more appropriate to install the Simpson

multimeter and to manipulate the MG breaker switch only once.

-The inspector observed that a Simpson multimeter was consistently being used to

perform MG set synchronization,

but that use of the multimeter had not been

incorporated

in'.o procedure S-1A. The licensee indicated that although the Simpson

installation enhanced

the synchronization,

it had not previously been required to

perform the task, and therefore was not incorporated into the procedure.

However,

the licensee also indicated that operating the MG breaker switch multiple times in

order to catch both MGs in phase by chance was not appropriate.

The licensee

initiated a revision to incorporate the Simpson installation into procedure S-1A, and

indicated that a permanent synchronization

aid would be installed during the next

refueling outage.

Conclusions

. The inspector concluded that the licensee's attempts to reduce vibrations in the

B-MG set, though unsuccessful,

were considered

positive since no action had been

required.

Procedure S-1A was deficient in that it did not contain guidance on the

use of equipment routinely being used to aid in MG set synchronization.

The

licensee appropriately initiated a procedure change to include the pertinent steps.

10

The licensee's intention to provide a permanently installed alternative to the

Simpson multimeter for MG set synchronization was also appropriate.

M8

IVIIscellaneous Maintenance Issues

M8.1

Closed

URI 60-244 97-02-02: Vendor Manual Pro ram Re uirements

URI 60-244/97-02-02 was opened

on May 5, 1997, after the inspectors discovered

multiple deficiencies in the licensee's vendor manual program.

Since that time, the

licensee has made significant progress to upgrade this program.

The backlog of

vendor contacts was reduced from over 100 to 50, and the licensee obtained

contracted services to eliminate the backlog and maintain the required vendor

manuals current.

Approximately 150 vendors are currently required to be contacted

every three years, 82 of which are planned to be contacted

in the first year.

Additionally, the licensee developed

a new interface procedure,

IP-RDM-2, "Vendor

Technical Document Change Requests," to establish vendor manual program

responsibilities and requirements.

The procedure was in the final stages of

management

review at the end of the current inspection.

The new program

provided for system engineer ownership of the vendor manuals that apply to their

respective systems.

Accordingly, system engineer training sessions

on vendor

manual program requirements were scheduled

for September

1997.

The inspectors considered that the licensee's vendor manual program was

previously deficient in meeting established

program requirements,

and did not

satisfy the requirements of 10 CFR 50, Appendix B, Criterion V, "Instructions,

Procedures,

and Drawings."

However, the overall consequences

of this problem

appeared

to be minor, and the licensee's

ongoing corrective actions to resolve the

problem have been significant.

Therefore, the inspectors considered this item to be

a Non-Cited Violation in accordance with Section lV of the NRC Enforcement Policy

and is closed. (NCV 50-244/97-06-01)

III~ En ineerin

E2

Engineering Support of Facilities and Equipment

E2.1

Service Water Pum

0 erabilit

Assessment

Followin

Strainer Foulin

a0

Ins ection Sco

e (37551)

The inspectors reviewed the licensee's operability assessment

performed in

response to fouled service water (SW) pump suction strainers.

b.

Observations

and Findin s

The licensee identified that all four SW pump suction strainers were fouled on

April 15, 1997, after divers were dispatched

in the SW pump bay to investigate

a

decrease

in SW header discharge pressure

observed

by control room operators

(see

11

IR 50-244/97-03).

The strainers were cleaned on the same day that the fouling

was identified.

The licensee performed an operability assessment

to determine if the fouled

condition had been severe enough to affect SW pump operability.

The assessment

indicated that the last time all four strainers were inspected

and cleaned was on

May 12, 1996.

On July 15, 1996, the A-SW pump strainer had been inspected

and

cleaned prior to a pump overhaul, and the strainer was found to be approximately

10% fouled.

The A- and B-SW pumps had satisfactorily passed

a performance test on January

23, 1997.

The C-SW pump had been satisfactorily tested on January

10, 1997.

The D-SW pump was also tested on January

10, but its differential pressure was

low in the alert range, and required an increased

surveillance frequency,

Subsequent

tests were performed on the D-SW pump on February 25 and April 3,

1997.

The test results were consistent with the January

10 test.

The licensee

reviewed plant process computer system

(PPCS) data from the time each SW pump

was last satisfactorily tested until April 15, 1997.

The review revealed that no

abnormal changes

in SW pump discharge

pressures

occurred over that period.

The

licensee also reviewed containment recirculation fan cooler (CRFC) SW flow data

over the same interval, and discovered that SW flow had remained steady with no

anomalies.

The licensee concluded that all the SW pumps were capable of fulfillingtheir

required safety-related functions and were operable throughout the assessment

period.

This conclusion was based upon the fact that the D-SW pump was capable

of satisfying its required performance testing as recently as April 3, 1997 (twelve

days before divers entered the SW bay).

The conclusion was also based upon the

review of pump discharge pressure data and CRFC service water flows, which both

indicated continued normal operating values.

Conclusions

The inspectors concluded the that the operability assessment

of all four SW pumps

adequately

addressed

pertinent system parameters.

The data obtained from

previous periodic tests appeared to substantiate

the licensee's conclusion that pump

operability had been maintained throughout the operability assessment. period.

Circuit Breaker Seconda

Contact Failure Root Cause Anal sis

Ins ection Sco

e (37551)

The inspector reviewed the licensee's root cause analysis performed in response to

several noted instances of circuit breaker secondary contact degradation

and

breaker failure.

12

Observations

and Findin s

On November 6, 1996, the licensee identified several damaged

secondary contacts

on a failed Westinghouse

DB-75 output breaker for the B-EDG (see IR

50-244/96-11)

~

On December 12, 1996, the licensee discovered damaged

secondary contacts on a failed Westinghouse

DB-25 supply breaker for the B-SW

pump (see IR 50-244/96-12).

On January 9, 1997, the licensee discovered

a bent

secondary contact on the A-reactor trip bypass breaker.

In all three cases the

breaker contacts were replaced and the breakers were successfully tested.

The

licensee generated

ACTION Report 97-0001 on January 9, 1997, to initiate a root

cause analysis and a corrective action plan for the secondary contact failures.

The licensee contacted Westinghouse

for guidance.

Westinghouse

had

investigated bent secondary contacts in the past and concluded that the

most probable cause was misalignment between the breaker and its cell (see

Westinghouse

Technical Bulletin NSD-TB-91-03-RO). Westinghouse

also

stated that abrasive materials should not be used to clean the contacts to

prevent removing the lubricating silver plating on the contact surface.

This

was contrary to the licensee's maintenance

procedures which had previously

provided guidance to use "Scotch Brite" pads (an abrasive material) to clean

breaker contact surfaces.

The licensee submitted three bent secondary contacts to RGRE's Materials Science

Laboratory for analysis.

The analysis concluded that the contacts had experienced

galling (metal transfer) between the contact mating surfaces,

and that the silver

plating had worn off leaving the underlying copper exposed.

The licensee therefore

concluded that use of Scotch Brite pads had accelerated

metal fatigue on the

contacts and was a direct contributor to their premature failure. The licensee

changed the necessary

preventive and corrective maintenance

procedures to

remove the use of Scotch Brite pads for cleaning silver-plated secondary contacts.

The licensee also conducted training for maintenance

workers to heighten their

awareness

of the problems associated with secondary contact degradation.

During

subsequent

oreventive maintenance

activities, several secondary contacts were

identified by maintenance

personnel to be in the early stages of degradation

and

were replaced.

Conclusions

The inspector concluded that the licensee's root cause analysis effectively identified

a lack of lubrication as a direct contributor to premature secondary contact failures.

The procedure changes

made were appropriate to ensure that proper lubrication was

maintained.

The training conducted to enhance

maintenance

worker awareness

concerning secondary contact degradation was effective, as evidenced by the

subsequent

discoveries of secondary contact degradation

during routine

maintenance.

13

Service Water Pum

Hi h Dischar

e Pressures

Ins ection Sco

e (37551)

The inspector reviewed the licensee's

response to observed

escalated

SW pump

discharge

pressures

during the performance of a routine quarterly surveillance.

Observations

and Findin s

On July 17, 1997, the licensee performed quarterly surveillance test PT-2.7.1,

"Service Water Pumps," on the C- and D-SW pumps (supplying the B-service water

header) to verify pump operability, and to record and track pump vibration and

temperature

data.

The test results indicated higher pump discharge pressures

than

those indicated in previous tests.

The licensee generated

an ACTION Report

(97-1123) to address these anomalies,

The licensee first considered that a probable cause for the pressure

increases

might

be the recent repair of a partially blocked bubbler tube used to measure

level in the

SW inlet bay (see IR 50-244/97-05).

However, this did not appear to significantly

effect the calculation for pump discharge pressure.

The licensee subsequently

discovered that the Controlotron transducers

used to measure flow for the test had

not been reinstalled in the same position after they were last cleaned.

The licensee

subsequently

removed, cleaned, lubricated, and reinstalled the Controlotron

transducers

and reperformed PT-2.7.1 on July 17. That test showed no appreciable

change from the results obtained earlier that day.

The licensee then analyzed the data from both the PTs performed on July 17, and

discovered that total SW flow to the component cooling water (CCW) heat

exchanger

had decreased

approximately 600 gallons per minute (gpm) from

previously performed tests, and that this flow decrease

accounted for the escalated

discharge pressures.

The licensee again performed PT-2.7.1 on July 24, 1997,

paying particular attention to SW flow to the CCW heat exchangers

and the SW

header test flow indication from the Controlotron transducers.

This test resulted in

data that was consistent with tests run prior to July 17. It appeared

the

recalibration of the flow transducers

did have an effect once a period of time had

elapsed following the calibration.

The licensee concluded that the Controlotron transducers

had not operated properly

on July 17 due to their being mispositioned.

However, the licensee was unable to

determine why the recalibration of the transducers

on July 17 did not immediately

result in a change

in the test data.

The licensee stated that the frequency of

surveillance testing for the C- and D-SW pumps would be. doubled, and that the

installed transducers

would remain installed during the increased

surveillance period

to eliminate any relocation error.

c.

Conclusions

14

The inspectors concluded that the licensee aggressively pursued discrepancies

in

the C- and D-SW pump test results that indicated escalated

pump discharge

pressures.

The licensee's conclusion that the discrepancy was caused by

mispositioned flow transducers

appeared

likely, given the noted variance in actual

SW flow to the CCW heat exchangers

from previously run tests.

The licensee's

intention to increase the surveillance frequency on the C- and D-SW pumps to

further evaluate flow transducer performance was appropriate.

ES

Miscellaneous Engineering Issues

E8.1

Closed

URI 50-244 96-12-01: Criticalit Monitor for the New Fuel Pre aration

Area

URI 50-244/96-12-01

was opened

on February 7, 1997, in response to the

licensee's

evaluation of the necessity to have a criticality monitor in the new fuel

preparation

area (NFPA) as required by 10 CFR 70.24, "CriticalityAccident

Requirements"

(see IR 50-244/96-07).

This rule requires that facilities licensed to

possess

greater than 700 grams of Uranium-235 have the ability to detect specific

radiation levels at defined distances from a critical source.

In a letter dated July 16, 1997, the NRC granted RG&E an exemption from the

requirements of 10 CFR 70.24.

The NRC concluded that the existing engineered

features in the NFPA that were designed to preclude an accidental criticality,

together with the low probability of such an event and the existing radiation

monitors installed in accordance with General Design Criterion 63, constituted good

cause for the exemption.

Therefore, this item is closed. (URI 50-244/96-12-01)

IV. Plant Su

ort

R1

Radiological Protection and Chemistry (RP&C) Controls

R1.1

lm Iementation of the Radiolo ical Environmental Monitorin

Pro ram

REMP

a.

Ins ection Sco

e 84750-02

The inspection consisted of:

1) a tour of the environmental sampling stations; 2) a

tour of the REMP analytical measurement

laboratory; 3) a tour of the meteorological

monitoring system and the control room; and 4) a review of the licensee's

compliance with 10 CFR 20, 40 CFR 190, and Appendix

I to 10 CFR 50.

b.

Observations

and Findin s

The inspector toured a milk farm, air sampling stations, and other selected

monitoring stations (i.e., fish, vegetation, water, and thermoluminescent

dosimeters

(TLDs)). Milksamples at the farm were available and all air sampling equipment

15

was operable at the time of the tour.

The inspector also toured the indication and

the control water sampling stations.

The reviewed sampling stations were located

as defined by the offsite dose calculation manual (ODCM).

The inspector noted that the licensee had a contractor laboratory (James A.

FitzPatrick Environmental Laboratory (JAFEL)) and sent all REMP sample media there

with the exception of tritium samples and TLDs. The inspector toured the JAFEL,

and reviewed JAFEL analytical procedures

and measurement

instruments.

The

reviewed JAFEL procedures

were detailed, and easy to follow; and ODCM

requirements

(such as lower limitof detection (LLDs) and action levels) were

incorporated into the appropriate procedures.

The JAFEL had six gamma spectrometers,

two proportional counters,

one liquid

scintillation counter, chemical balances,

refrigerators, freezers,

a sample receiving

area, and sample storage space.

All laboratory equipment was operable at the time

of the tour.

The inspector observed

sample processes

for the licensee's water and

charcoal cartridge samples.

The JAFEL staff followed its procedures for sample

receiving, surveying, logging, and sample preparation.

The inspector also reviewed

analytical methodology, data evaluation, and the staff's adherence

to reporting

requirements.

The inspector noted that the JAFEL staff was very knowledgeable

in

these areas.

The inspector also verified the operability of the meteorological readout devices

located in the Ginna control room and the meteorological tower base station.

The

readout devices and meteorological instrumentations

were operable at the time of

this inspection.

The inspector also reviewed the licensee's compliance with Appendix

I to

10 CFR 50, 10 CFR 20.1301

and 40 CFR 190 (dose limits to the public) using

direct radiation measurement

data (environmental TLD readings).

The measured

doses to the public were well below regulatory requirements.

C.

Conclusion

Based on the above observations

and findings, the inspector determined that the

licensee effectively implemented the REMP as required by the ODCM.

R1.2

Environmental Thermoluminescent

Dosimeter

TLD Pro ram and Com arisons of

Collocated TLD Results

a.

Ins ection Sco

e 84750-02

The inspection consisted of technical evaluations of the licensee's environmental

TLD program based on the following guidance:

1)

Regulatory Guide 4.13, "Performance, Testing, and Procedural Specifications

for Thermoluminescence

Dosimetry:

Environmental Applications."

16

2)

ANSI N545-1975, "Performance, Testing, and Procedural Specifications for

Thermoluminescence

Dosimetry (Environmental Applications)."

The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Monitoring

Network is operated by NRC Region

I to provide continuous measurements

of the

ambient radiation levels around nuclear power plants throughout the United States

during normal operations.

The monitoring results are published in NUREG-0837

quarterly.

One purpose of this program is to serve as a basis of comparison with

similar programs conducted

by individual utilities which operate nuclear power

plants.

Therefore, at least four NRC TLDs are collocated with the licensee's TLD

stations at each nuclear power plant.

During this inspection, the collocated TLDs

measurement

results were used to evaluate the licensee's

measurement

capability.

Observations

and Findin

s

The inspector reviewed the implementation of the licensee's environmental

thermoluminescent.dosimetry

program.

The Radiation Protection/Chemistry

Department had responsibilities to process the environmental TLDs on site.

The

licensee used Panasonic

UD-814AS1 TLDs and the UD-710A TLD Reader.

The inspector reviewed the following procedures to determine their technical

validity:

RP-TLD-ENV-READOUT,

RP-TLD-710A-OPS,

RP-TLD-710A-CAL,

RP-TLD-710A-QC,

CH-ENV-TLD,

"Readout and Report of Environmental TLD."

"Operation of Panasonic

UD-710A TLD Reader."

"Calibration of the Panasonic

UD-710A Automatic TLD

Reader."

"UD-710A TLD Reader QC Check."

"Collecting Environmental and Post Accident TLDs."

During review of the above procedures,

the inspector noted that procedures

RP-TLD.-710A-OPS, RP-TLD-710A-CAL, and RP-TLD-710A-QC described only the

personnel TLD program, and not the environmental TLD program.

For example,

radiation exposures

provided to the "QC" TLDs (300 and 3,000 mR) described

in

procedure

RP-TLD-710A-QC were too high to apply to the environmental TLD

program.

The inspector noted that the licensee did not perform any tests

(e.g., uniformity, reproducibility, moisture dependence,

etc.) described by the

previously mentioned references.

The inspector noted that the licensee determined

the element correction factor (ECF) only once every two years even though ECFs of

the TLDs could change due to harsh environmental conditions, such as heat'and

moisture.

The inspector also noted that the licensee did not use control TLDs to

measure the transit dose, even though the transit time was about 6-7 days, based

on the 1996 and 1997 logs.

The monitoring results of five collocated TLDs were compared

and are listed in

.Table

1 below. Although there were some differences between

NRC and licensee s

programs (such as differing monitoring periods, starting dates of the quarters,

17

monitoring heights, and transit doses); the comparison results were generally in

good agreement, with the exception of the data for the 4th Quarter of 1996.

Table

1

COMPARISONS OF COLLOCATED TLD RESULTS

Unit= mR/90 days for NRC

Unit= mRem/91 days for GINNA

STATION ID

1st Qtr, 1996

2nd Qtr, 1996 (a)

3rd Qtr, 1996 (a)

4th Qtr, 1996

NRC

11

GINNA

31

NRC

15

GINNA 36

NRC

18

GINNA

39

NRC

19

GINNA 40

NRC

28

GINNA

9

12.7%0.6; 4.0 (b)

13.9s3.5

(c)

10.5%0.6; 3.8

13.6 2 3.4

10.8 %0.6; 3.8

14.0 2 3.5

11.2a0.6; 3.9

13.3 a 3.3

13,1 20.7; 4.1

13.3 a 3.4

13.2 20.4

11.7 k 3.0

TLD Missing

11.322.8

12;2a0,3

12.6 a 3.2

11.6 %0.3

11.7 2 2.9

11.8 20.3

1 1.2 2 2.8

13A 20.4

12.6 2 3.2

13.9 a0.4

11.5 R 2.9

12.3 a0.4

12.8 2 3.2

10.8 20.3

11.8 2 3.0

12.9 %0.4

1 1.3 2 2.9

15.0a0.6; 4.0

9.7 2 2.6

14.5 %0.6; 3,9

10.4 a 2.6

13.920.6: 3.9

11.7 %3.0

13.0%0.6: 3.8

10.6 2 2.7

13.720.6; 3.9

10.8 R 2.7

a

ross

xposure

lusted Data

ue to oss o t e

ransit TLD, mR ~ stan

ar

error

-(b)

mR s standard error; total error

(c)

mR a 2 sigma error

The licensee stated that their lower measurement

results for the 4th Quarter of

1996 were due to the transit dose.

Procedure

RP-TLD-ENV-READOUT indicated

that there was no transit dose when TLDs were processed

on-site.

The inspector

indicated that the transit dose (measured

by the control TLDs) should be

incorporated into the environmental TLD program because

the environmental TLDs

were exposed to natural radiation background

or other sources originating from the

plant.

Although the licensee had a capability to measure direct radiation using

environmental TLDs, as shown in Table 1, the inspector determined that the

licensee's environmental TLD measurement

results had the potential to be

unreliable.

The inspector identified the following weaknesses:

~

Environmental TLDs were not tested to demonstrate

their reliability;

~

No transit dose was applied to calculate net exposure;

18

TLD procedures

were written only for the personnel TLD program;

No environmental TLD quality control (QC) program was implemented.

These items will be reviewed in a subsequent

inspection (IFl 50-244/97-06-02).

c.

Conclusions

Based on the above procedure reviews, technical discussions,

and data evaluation,

the inspector determined that the licensee's environmental TLD program lacked

elements that could effect its reliability.

R2

Status of RPLC Facilities and Equipment

R2.1

Calibration of Meteorolo ical Monitorin

S stem and Air Sam

lers

a.

Ins ection Sco

e 84750-02

The inspection consisted of;

1) a review of the most recent meteorological

instrumentation calibration results for wind speed, wind direction, and delta

temperature;

and 2) a review of air sampler calibration data.

b.

Observations

and Findin s

The inspector reviewed the most recent meteorological monitoring system

calibration results for wind speed, wind direction, and delta temperature.

The

reviewed calibration results were within the licensee's acceptance

criteria. The

inspector also verified the operability of meteorological readout devices located in

the control room and the meteorological tower base.

The meteorological

instrumentation was operable at the time of this inspection.

Although calibration results were within the acceptance

criteria and the instruments

were operable, the actual readings

in the control room and at the meteorological

tower base were compared to evaluate system integrity. The inspector compared

the wind speed, wind direction, and temperature outputs of the towers to the

control room panel (strip chart).

The control room panel was designed for

temperature

readings at three levels (33 ft., 150 ft., and 250ft.) while wind speed

and direction were only read for the 33 ft. level. The comparison results were in

good agreement only for the temperature,

as shown in Table 2 below.

Table 2

Comparisons

between Tower Base and the Control Room Readouts

33 feet

Temperature

Control Room

73.3 'F

Wind

Speed

Wind

Direction

Tower Base

(Channels A/B)

Control Room

Tower Base

(Channels A/B)

Control Room

Tower Base

(Channels A/B)

73 4'F/73 3 'F

12 mph

9.1 mph/9.5 mph

300'90'/289's

shown in Table 2, the comparisons of wind speed

and wind direction were not

consistent.

The inspector questioned the IS.C staff regarding

a potential line loss of

the signal between the tower and the control room.

The inspector was concerned

that the 10-degree difference between two readings could impact effective

response

activities in the case of a radiological event, specifically the projected dose

calculations to the public.

The inspector also noted that the height of the sensors for Channels A and B were

about 3 feet apart at the 33 ft. and 150 ft. levels.

This could have resulted in a

discrepancy

in the delta temperature

measurement.

The inspector stated that the

potential line loss of the signal and the licensee's

procedure for determining which

channel to use during normal and emergency operations were categorized

as an

inspector follow-up item (IFI 50-244/97-06-03).

The inspector also'eviewed the licensee's

air sampler calibration procedures

and

records.

Calibration of gas meters was performed according to the specified

frequencies stated in the appropriate procedure.

Results of these calibrations were

within the licensee's specified acceptance

criteria.

Conclusion

Based on the above reviews, the inspector concluded that a potential weakness

existed relative to line losses or other errors leading to discrepancies

between the

meteorological tower and the control room indication.

The air sampler calibration

program was effectively implemented.

20

R3

RPRC Procedures

and Documentation

R3.1

Review of REMP and ODCM Procedures

and Audit Re orts

a 0

lns ection Sco

e 84570-02

The inspection consisted of review of:

1) selected contractor (JAFEL) procedures

for compliance with the licensee's

REMP; 2) the licensee's

1995 and 1996 Annual

REMP reports; and 3) the licensee's

ODCM.

b.

Observations

and Findin s

The inspector reviewed selected contractor's analytical procedures for compliance

with the licensee's

ODCM requirements,

including sample receiving and logging

processes.

The reviewed procedures

were concise and provided the required

direction and guidance for implementing an effective REMP.

The inspector reviewed the Annual Radiological Environmental Operating Reports for

1995 and 1996.

These annual reports provided measurement

results of the REMP

samples around the Ginna site and met the ODCM reporting requirements.

The

reviewed analytical results indicated that all samples were collected and analyzed

as

required by the ODCM. However, the inspector noted that the licensee did not

explain anomalous

changes

or trends in the annual reports.

For example, direct

--radiation measurement

results (TLD data) at the fence (Station ¹13) indicated that

the measurement

result of the 4th quarter of 1996 decreased

by a factor of

approximately three from the 3rd quarter of 1996.

Inspector follow-up revealed

that the licensee moved a trailer (which contained contaminated

materials) from the

vicinity of TLD Station ¹13 to another location.

Also, the licensee measured

a

positive Iodine-131 (I-131) activity (1813 pCi/kg) in a cladophora

(algae) sample at

the radioactive liquid discharge

area in 1995.

Although the measured

I-131 activity

was low (near the LLD value) and did not negatively impact the environment, the

licensee did not explain or provide evaluation of this matter in the annual report.

The inspector noted that the licensee also did not measure

1-131 in the algae sample

in 1996.

The inspector discussed

these matters with the licensee and noted that

the responsible

individual had reviewed the data and concluded that there was no

impact to the environment or to the public. The licensee acknowledged the

importance of evaluating and documenting

anomalous

measurements.

The licensee

stated that the evaluation results for trending or sudden changes would be

described

in the future annual reports.

The inspector reviewed the REMP portion of the licensee's

ODCM, Revision 9,

effective October 1996.

The inspector noted that this ODCM was an improvement

over previous versions,

as noted during the previous inspection (See IR

50-244/97-05).

The inspector noted that the licensee planned to update the ODCM

to include revising sampling location maps.

C.

Conclusion

Based on the above reviews, the inspector determined that:

1) analytical

procedures for the REMP were sufficiently detailed to facilitate performance of all

21

necessary

steps; 2) the licensee implemented the ODCM requirements for sampling,

analyzing, and reporting for the REMP; 3) better evaluation of anomalous

measurements

and data should be incorporated

in the annual report; and 4) the

licensee's

ODCM had improved over previous versions.

R6

RP&C Organization and Administration

R6.1

Review of The REMP Or anization and Administration

a.

Ins ection Sco

e (84750-02)

The inspector reviewed the organization and administration of the REMP and

discussed with the licensee changes

made since the last inspection conducted

in

October 1995.

b.

Observations

and Findin s

The licensee made some changes

in the REMP management

(responsibility of the

REMP sample analyses)

since the previous inspection.

REMP samples were

collected and prepared for shipping by the Health Physics Technician, Health

Physics/Chemistry

Department.

REMP samples were analyzed by a contractor

laboratory (James A. FitzPatrick Environmental Laboratory (JAFEL) since the 4th

quarter of 1996), with the exception of tritium in water and TLDs measurements.

Tritium in water and TLDs were analyzed at the site, All analytical results form the

contractor laboratory were reviewed by the Radiochemist.

c.

Conclusion

The inspector concluded that the changes

did not reduce the REMP philosophy

and/or practices.

R7

Quality Assurance

(QA) in RP&C Activities

R7.1

Review of Qualit

Assurance Audit Re orts and QA QC Laborator

Activities

a.

Ins ection Sco

e 84750-02

The inspection consisted of:

1) a review of the 1996 audit; and 2) a review of

analytical measurements

laboratory QA/QC activities.

b.

Observation

and Findin s

The inspector reviewed the 1996 Quality Assurance Audit Report (Report Number

AINT-1996-0005-NAB). This audit was conducted by quality department personnel

and covered the REMP and other areas, such as radioactive liquid and gaseous

effluent controls.

The inspector noted that the audit team also included other

technical personnel from another utility. The 1996 audit team identified no findings

22

but made two observations to enhance the REMP. The inspector noted that the

scope and technical depth of the audits were sufficient for assessing

the REMP.

The QA/QC program for analyses of REMP samples

is conducted

by JAFEL. The

JAFEL has interlaboratory and intralaboratory QC programs.

The QC program

consisted of measurements

of blind duplicate, spike, and split samples.

The JAFEL

published

a QC report annually.

The inspector reviewed the 1995 annual QC

reports.

Intra/interlaboratory comparisons

of QC data listed in the annual QC

reports were within the JAFEL's acceptance

criteria.

C.

Conclusion

Based on the above reviews, the inspector determined that the licensee met the QA

audit requirement,

and the JAFEL's QA/QC program for the REMP provided

effective validation of analytical results.

V. Mana ement IVleetin s

Exit IVleeting Summary

The inspectors presented

the inspection results from the Radiological Environmental

Monitoring Program (REMP) to members of licensee management

at the conclusion

of that inspection on August 1, 1997. At the end of the inspection period, the

inspectors presented the overall results to members of licensee management

on

August 12, 1997.

The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during the

inspection should be considered

proprietary.

No proprietary information was

identified.

X2

Pre-Decisional Enforcement Conference Summary

On August 5, 1997, a pre-decisional enforcement conference was held with the

licensee in the NRC Region

I office in King of Prussia,

PA, to discuss the vehicle

barrier system issues identified in Inspection Report 50-244/97-08.

The licensee

presentation

included a discussion of the significance, root causes

and corrective

actions for the apparent violations.

A list of attendees

at the conference

and the

presentation

slides used by the licensee are included in this report as Attachment 2.

The enforcement action for the vehicle barrier violations was issued in a letter to the

licensee dated August 15, 1997.

L2

Review of UFSAR Commitments

While performing the inspections discussed

in this report, the inspector reviewed

the applicable portions of the UFSAR that related to the areas inspected.

The

inspectors verified that the UFSAR wording was consistent with the observed plant

practices, procedures

and/or parameters,

with the exception of the follow-up item

IFI 50-244/97-06-03 (Section R2.1).

ATTACHMENT I

PARTIALLIST OF PERSONS CONTACTED

Licensee

D. Fillion

B. Flynn

C. Forkell

G, Graus

A. Harhay

J. Hotchkiss

R. Jaquin

G. Jones

G. Joss

N. Leoni

R. Marchionda

F. Mis

R. Ploof

J. Smith

J. Widay

T. White

G. Wrobel

Radiochemist

Primary Systems Engineering Manager

Electrical Systems Engineering

Manager

I&C/Electrical Maintenance

Manager

Chemistry & Radiological Protection Manager

Mechanical Maintenance

Manager

Nuclear Safety and Licensing

Chemist,

Results and Test Supervisor

Radiation Protection and Chemistry

Production Superintendent

Principle Health Physicist

Secondary Systems Engineering Manager

Maintenance Superintendent

Plant Manager

Operations Manager

Nuclear Safety & Licensing Manager

INSPECTION PROCEDURES USED

'IP 37551:

IP 61726:

IP 62707:

IP 71707:

IP 71750:

IP 92902:

IP 84750:

Onsite Engineering

Surveillance Observation

Maintenance Observation

Plant Operations

Plant Support

Follow-up - Maintenance

Radioactive Waste Treatment, and Effluent and Environmental Monitoring

ITEMS OPENED, CLOSED, AND DISCUSSED

~Oened

NCV 50-244/97-06-01

Vendor Manual Program Requirements

IFI 50-244/97-06-02;

IFI 50-244/97-06-03;

Closed

NCV '50-244/97-06-01

URI 50-244/97-02-02

URI 50-244/96-1 2-01

Environmental TLD Program Enhancement

Potential Signal Loss of the Meteorological Monitoring System

Vendor Manual Program Requirements

Vendor Manual Program Requirements

Criticality Monitor for the New Fuel Preparation Area

Attachment

I

LIST OF ACRONYMS USED

ADFCS

AFW

AOV

CCW

CRFC

ECCS

EDG

EOP

ESF

GPM

HEPA

I&C

IFI

IN

IP

IR

IST

ITS

LCO

mR/hr

MSI

NCV

NOV

ODCM

P&ID

'ORC

PPCS

ppm

PSA

PT

QA

QC

RCA

RCP

RCS

REMP

RHR

RMS

RP

RP&C

RVLIS

RWP

SFP

SG

Sl

SR

SW

Tave

TLD

Advanced Digital Feedwater Control System

Auxiliary Feedwater

Air Operated Valve

Component Cooling Water

Containment Recirculation Fan Cooler

Emergency Core Cooling System

Emergency Diesel Generator

Emergency Operating Procedure

Engineered Safety Feature

Gallons per Minute

High Efficiency Particulate Analysis (filter)

Instrumentation

and Controls

Inspector Follow-up Item

Information Notice

Inspection Procedure

Inspection Report

Inservice Test

Improved Technical Specification

Limiting Condition for Operation

milli-Rem per hour

Main Steam Isolation

Noncited Violation

Notice of Violation

Offsite Dose Calculation Manual

Piping and Instrumentation Drawing

Plant Operations Review Committee

Plant Process Computer System

parts per million

Probabilistic Safety Assessment

Periodic Test

Quality Assurance

Quality Control

Radiologically Controlled Area

Reactor Coolant Pump

Reactor Coolant System

Radiological Environmental Monitoring Program

Residual Heat Removal

Radiation Monitoring System

Radiation Protection

Radiological Protection and Chemistry

Reactor Vessel Level Instrumentation System

Radiation Work Permit

Spent Fuel Pool

Steam Generator

Safety Injection

Surveillance Requirement

Service Water

Reactor Coolant System Average Temperature

Thermoluminescent

Dosimeter

Attachment

I

UFSAR

URI

Updated Final Safety Analysis Report

Unresolved Item

ATTACHMENTII

PRE-DECISIONAL ENFORCEMENT CONFERENCE ATTENDEES

AUGUST 5, 1997

Licensee;

R. Mecredy

T. Marlow

G. Wrobel

L. Sucheski

R. Teed

R. Ploof

R. Novgrad

Vice President - Nuclear Operations

Manager, Nuclear Engineering Services Department

Manager, Nuclear Safety & Licensing

System Engineer, Civil 5 Structural

Supervisor, Nuclear Security

Manager, Balance of Plant System Engineering

Consultant for RGSE

NRC;

L. Nicholson

M. Modes

G. Smith

L. Doerflein

G. Vissing

T. Moslak

R. Rosano

Deputy Director, Division of Reactor Safety

Chief, EP, Safeguards,

5. Incident Response

Branch

Security Specialist

Chief, Projects Branch 1, DRP

Project Manager,

NRR

Project Engineer,

DRP

Senior Project Manager,

NRR

AT

ENT II

VBS ENFORCEMENT CONFERENCE

Agenda

~ Opening Remarks - R. Mecredy

~

Apparent Violation - G. Wrobel

~

VBS Program History 8 Timeline - R. Ploof

~

Vehicle Barrier System - L. Sucheski

~

Cable-Bollard System - L. Sucheski

~

Standoff Distances

- L. Sucheski

~

Long Term Corrective Actions - T. Marlow

~

Concluding Remarks - R. Mecredy

RGAE

8/5/97

I

VBS ENI'ORCEMENT CONJ'ERENCE

Qpewng Remarks

~ Acknowledgment

~ Evolution in Understanding

~ Vehicle SpeedlDirection

~ Comprehensive Corrective

Actions

8/5/97

2

VBS ENFORCEMENT CONFERENCE

Apparent Violation

o

Vehicle Barrier NW, NE, Guardhouse Openings

v

Adequate for high speed.

Slow speed not considered

~

Cable-Bollard System

v'dequate for high speed. Tampering not considered

o

Standoff Distances

v

Characterization as minimUm not appropriate

v

As inspected condition acceptable

RG&E

8/5/97

3

RG&E

1/84

- Installed initial vehicle barrier system

1/94

- EWR 10224 initiated to evaluate vehicle bomb threat

8/94

- Final Rule issued 10CFR 73.55

12/94 - NUREG 6190 Rev 1 volumes I &IIissued

2/95

- RG&E submits summary description of VBS to NRC

6/95

- NRC notifies NEI regarding passive barrier tampering

2/96

- RG&E completes installation of vehicle barrier system

2/96

- RG&E submits revised summary description to NRC

5/96

- RG&E quarterly inspection

8/96

- RG&E quarterly inspection identifies guardhouse opening

1/97. - RG&E quarterly inspection

S/5/97

4

VBS ENFORCEMENT CONFERENCE

Program HI/st~ 8 Timeline

3/97

- NRC issues NUREG errata - 20'enetration ofjersey barriers

4/97

- RG&E initiates EWR to evaluate additional

20'/97

- RG&E quarterly inspection

5/97

- RG&E installs additional jersey barrier guardhouse opening *

5/97

- RG&E initiates corrective action NE & guardhouse openings*

5/97

- NRC Inspection identifies deficiencies

5/97

- Immediate compensatory measures implemented

7/97

- Short term (engineering) corrective actions completed

• Prior to NRC Inspection

RG&E

8/5/97

5

I

~

'0,

S

0 j

~ ~

L

I

VBS ENFORCEMENT CONFERENCE

Vehicle Barrller Northwest Qpening

Understanding the Facts

~

Distance Between End of Bollard 8 Cliff14'

Installed per Drawings

Immediate Corrective Actions

~

Installed Additional Jersey Barriers

8/5/97

7

VBS EXFORCEMEXT CONFERENCE

Northwest Arrangement Sketch

(APPROX.)

STAKED JERSEY

BARRIER

1/3

KE MAX.

2 JERSEY BARRIERS

UNSTAKED, KEYED

TOGETHER TO ACT

AS OBSTACLES.

FENCE

FENCE

RG&E

8/5/91

8

VBS ENFORCEMENT CONFERENCE

Vehicle Barrier Northwest Opening

Significance of the Issue(s)

~ No Actual Consequences

~ Minimum Potential Consequences

v'low Moving Vehicle

v

Double Chain Link Fence with Intrusion Alarm

v

Monitoring with Security Cameras

Distance to Vital Equipment

v'rained Security Force

~ Regulatory Significance

v'ailure to Control Access, but not Easily or Likelyto

be Exploited

8/5/97

VBS EXFORCEMEXT CONFERENCE

Vehicle Barrier Northeast Opening

Understanding the Facts

~

Distance Between End ofBollard 8 Cliff8'

Self Identified

Immediate Corrective Actions

~

Installed Additional Jersey Barrier

8/5/97

10

g

0

~ I

~+~'W~

g g+

a~~~

I

I

I

~

~

VBS ENFORCEMENT CONFERENCE

Vehicle Barrier Northeast Opening

Significance of the Issue(s)

~ No Actual Consequences

~ Minimum Potential Consequences

Slow Moving Vehicle

Double Chain Link Fence with Intrusion Alarm

v'onitoring with Security Cameras

v

Distance to Vital Equipment

v

Trained Security Force

~ Regulatory Significance

v

Failure to Control Access, but not Easily or Likelyto

be Exploited

8/5/97

12

VBS EXFORCEMEXT COXFEREXCE

Vehicie Barrier'arardhouse

Opening

Understanding the Facts

~

Jersey Barrier Opening - 8'

Self identified

Immediate Corrective Actions

~

installed Additional Jersey Barrier

RG&E

8/5/97

13

f

g

P

r

3

i

l

~

k

I

zP

jP

~ I'W

~

~ '

~

VBS ENFORCEMENT CONFERENCE

Vehicle Barrier Guardhouse Opening

Significance of the issue(s)

o No Actual Consequences

~ Minimum Potential Consequences

u'low Moving Vehicle

Double Chain Link Fence with Intrusion Alarm

v

Monitoring with Security Cameras

v'rained Security Force

~ Regulatory Significance

v'ailure to Control Access, but not Easily or Likelyto

be Exploited

8/5/97

15

VBS EXFORCEMEXT CONFERENCE

Root Cause

VEHICLE8

IER OPENINGS

~

Design Assumptions

v

Vehicle Speed 8 Direction

8/5/97

16

VBS ENFORCEMENT CONFERENCE

Cable-Bollard System

Understanding the Facts

~

Cable Supported with Open Hooks

immediate Corrective Actions

~

Installed Metal Clamps

~

Installed Welded Steel Plates Every Other Post

8/5/97

17

Qw

VBS ENFORCEMENT CONFERENCE

Significance of the Issue(s)

CABLE-BOLL

~ No Actual Consequences

SYSTEM

~ Minimum Potential Consequences

Distance to Vital Equipment

v

Time Involved in Tampering

Double Chain Link Fence with Intrusion Alarm

v

Monitoring with Security Cameras

v

Trained Security Force

~ Regulatory Significance

e

Failure to Control Access, but not Easily or Likelyto

be Exploited

8/5/97

18

VBS ENFORCEMENT CONFERENCE

Root Cause

CABLE-BQLLARDSYSTEM

~

Design Assumptions

v

Vehicle Speed

v Use ofHand Tools

~

Evolving Industry Guidance Not Considered

8/5/97

19

VBS E~NFORCEMENT CONFERENCE

Understanding of the Facts

STANDOFF DISTANCES

~

Clarification of Inspection Apparent Violation

v'ubmittal Identified Distances 230'

155'r

Inspection Report Identified 225'

138ctual

Surveyed Distances 224'" 8 152'"

~

Distance Scaled from Construction Drawings

~

Engineering Judgment regarding Degree of Sensitivity

8/5/97

20

VBS ENFORCEMENT CONFERENCE

Immediate Corrective Action

STANDOFF DISTANCES

~

Implement Compensatory Measures

v Place 3 Tractor Trailers 8 4 Jersey Barriers

~

Measured Actual Distances

~

Reviewed Computer Models 8 Assimilated Design

Documentation

~

Analysis Rerun at 200'

100'Acceptable

~

Calculation Reviewed by Independent Expert

8/5/97

21

VBS EXFORCEMEXT CORI'EREXCE

Significance of the Issue(s)

STANDOFF DISTANCES

~ No Actual Consequences

~ No Potential Consequences

v Analysis Confirmed Acceptability of As Inspected

Configuration

~ Minimal Regulatory Significance

155'ersus 152'" - within Tl Guidance

v 230'ersus 224'"

8/5/97

22

VBS ENFORCEMENT CONFERENCE

Root. Cause

STANBOFF INSTANCES

o

Plant Change Process Implementation

v Insufficient Documentation of Engineering

Judgment

8/5/97

23

Cl

Jf

g

J

a

J

I I

I

~

0 ~

a

A ~

a v

I

VBS ENFORCEMENT CONFERENCE

Root Cause Analysis

o Purpose

v'elfCritical Approach

e Comprehensive

~ Method

v Change/Barrier Analysis

- Historical Sequence

Documents

8, Work

- Regulatory 8 Industry Documents

8/5/97

25

S'

VBS EXFORCEMEXT COXFEREXCE

Root Cause Analysis

~

Vehicle Barrier Openings

v'hy didn't designer, technical reviewer or

security identify?

~

Cable Bollard System

v Why weren't hardened fasteners used?

~

Standoff Distances

v'hy wasn't engineering judgment

documented

SI5/97

26

w.

VBS ENFORCEMENT CONFERENCE

Root Cause Analysis

Root Cause Results

~ Imperfect Interpretation ofNRC

Recluiremenfs

~ Failure to Incorporate NRC Guidance into

Design

~ Misapplication ofPlant Change Process

Implementation

$/5/97

27

VBS I;NFORCEMENT CONFERENCE

Lessons Learned

~ Security System

v Increase Knowledge

v Improve Interface

v Clarify Security System Ownership

~ Provide Specific 8 Documented Design

Inputs 8 Assumptions

~ Formally Evaluate Evolving Design

Requirements

8/5/97

28

h

<<

w

VBS ENFORCEMENT CONFERENCE

Long Term Correct//ve Action Focus Areas

~

Security System Ownership

~

Plant Change Process Expectations

~

Training

8/5/97

29

.

VBS ENFORCEMENT CONFERENCE

SECURITY SYSTEM OWNERSHIP

o

Security Plan Revised 8 Submitted - 7/25/97

~

Design Basis Review Completed - 7/31/97

Design Inputs

v'0CFR 73.55

v'inna Sfation Security Plan

e Regulatory Guide 5.44, Perimeter Intrusion Systems

Results

v Compliance Verified -1 ACTIONReport

~

LVeekly VBS Inspecfion by Security Force Established - 8/6/97

~

Quarterly VBS Inspecfion Checklist Developed - 8/15/97

~

Summary Description Revised 8 Submitted - 8/31/97

RG&E

8/5/97

30

c

VBS EXFORCEMEXT CONFERENCE

PLANT CHANGE PROCKSS EXPECTATIONS

~

Revise Plant Change Process - 8/37/97

NRC Non Safety Related Design Changes Require:

v Specific Design Inputs 8 Assumptions

v Testing

v Inspection 6 Measurement

Formal Distrl'bution 8 Tracking ofEvolving

Requirements

~

Implement Results of Plant Change Process Self

Assessment

- /0//7/97.

~

Perform External Assessment Design Criteria - 12/31/97

v Sample ofRegulatory Driven Non Saf-efy Related

Modifications

8/5/97

31

4

c

f

A A

~

~

~ ~

S ~

~

~

o

N ~

~

) a

a

~

~

~

~ ~

VBS ENFORCEMENT CONFERENCE

~ Significance

~ Compensatory Measures

~ Immediate Corrective Action

~ Long Term Corrective Actions

8!5/97

33

'

A. ~

~%g