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| issue date = 09/25/1981
| issue date = 09/25/1981
| title = Forwards Response to NRC 801215 Transmittal of Final SEP Assessments for Topics VI-7.A.3 & VI-10.A.Info Re Concerns Identified in Final Assessments Encl
| title = Forwards Response to NRC 801215 Transmittal of Final SEP Assessments for Topics VI-7.A.3 & VI-10.A.Info Re Concerns Identified in Final Assessments Encl
| author name = MAIER J E
| author name = Maier J
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| addressee name = CRUTCHFIELD D
| addressee name = Crutchfield D
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000244
| docket = 05000244
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:tt llEulllll IHiZ ANO zzgw zw'Im'uit ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y.I4649 JOHN E.MA IER VICE PRESIDENT TCL,EPHONE ARCA cOOK Tld 546-2700 September 25, 1981 Director of Nuclear Reactor Regulation Attention:
{{#Wiki_filter:tt llEulllll IHiZ ANO zzgw zw
Mr.Dennis M.Crutchf ield, Chief Operating Reactors Branch 55 U.S.Nuclear Regulatory Commission Washington, D.C.20555  
      'Im'uit ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. I4649 JOHN E. MA IER                                                         TCL,EPHONE VICE PRESIDENT                                                ARCA cOOK Tld 546-2700 September 25, 1981 Director of Nuclear Reactor Regulation Attention: Mr. Dennis M. Crutchf ield, Chief Operating Reactors Branch   55 gag          '-g);
U. S. Nuclear Regulatory Commission Washington, D.C.               20555                                               1981~ 12 graf Ij~g~ Nlgj


==Subject:==
==Subject:==
SEP Topics VI-7.A.3 and VI-10.A R.E.Ginna Nuclear Power Plant Docket No.50-244<gag'-g);1981~12 graf I j~g~Nlgj
SEP   Topics VI-7.A.3 and VI-10.A R. E. Ginna Nuclear Power Plant Docket No. 50-244


==Dear Mr.Crutchfield:==
==Dear Mr.           Crutchfield:==


This letter is in response to your letter of December 15, 1980, transmitting the final SEP assessments for these two topics to Rochester Gas and Electric.Four items requiring resolution during the Integrated Assessment for Ginna were identified in these assessments.
This letter is in response to your letter of December 15, 1980, transmitting the final SEP assessments for these two topics to Rochester Gas and Electric. Four items requiring resolution during the Integrated Assessment for Ginna were identified in these assessments.               The information in the enclosure should resolve these concerns prior to the Integrated Assessment.
The information in the enclosure should resolve these concerns prior to the Integrated Assessment.
Very truly yours, hn E. Maier Enclosure
Very truly yours, hn E.Maier Enclosure',Sii0020253 8i0925 ,'PDR ADOCK 05000244 P PDR t g 4W i'4l I-j'I h~(q~a li  
',Sii0020253 8i0925
,'PDR ADOCK         05000244 P                           PDR
 
t g         I-i '4l4W j'I
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==Enclosure:==
==Enclosure:==
RG&E Responses to Concerns Identified in the Evaluation and Conclusions of the SEP Assessment for SEP Topics VI-7.A.3 and VI-10.A, 12/15/80
: 1. The  instrumentation strings from sensors thru bistable devices are not response time tested. As a result, the testing required by IEEE Std. 279-1968 Section 4.10 is not satisfied because the response time design basis (IEEE 279-1968 Section 3 (i)) is not verified.
Response:  RG&E does not, at this time perform response time testing of instrumentation strings for the Engineered Safety Feature System. We disagree, however, that the lack of such testing violates the provisions of IEEE 279-1968.
RG&E does perform testing to verify that the final actuated devices are properly operational within the times assumed in the plant design basis. Appropriate test procedures were sent to the NRC with RG&E's trans-mittal of September 10, 1980.
The Ginna design does not conform with the provisions of Regulatory Guide 1.118, "Periodic Testing of Electric Power and Protection Systems."    This regulatory guide was published long after Ginna became operational;  it was thus obviously not considered in the design of the plant. The latest version of Regulatory Guide 1.118 (Rev. 2 published June 1978), states that this regulatory guide ". . . is'being and will continue to be used in the evaluation of submittals in connection with Construction Permit a lications . . ." (emphasis added). The implementation of this regulatory guide does not provide specific provisions for backfitting; it  is not directly applicable to Ginna. RG&E further does not believe that strict adherence to the guidance provided in Regulatory Guide 1.118 is necessary to meet IEEE-279-1968 requirements. RG&E performs periodic tests and calibration on all components of the protection system instrumentation strings, including sensors. Any significant degradation in component response will be identified and corrected by this activity. RG&E is also preparing to implement certain response time testing at the Ginna plant. Ginna Technical Specifi-cations 4.4.6.2 and 4.8.10 require that the response time of each containment isolation function and each auxiliary feedwater initiation function be demonstrated to be within required limits at least once per 18 months. RG&E is presently developing a program to effect this requirement.
It  is considered that the current methodology meets the requirements of this SEP topic. This issue does not need to be considered further within the Systematic Evaluation Program.
1 M
: 2. The  test procedures required the      removal of fuses and installation of jumpers to block      equipment operation and/or to simulate contact closure. The procedures often do not specify the time at which these jury-rigged modifications are removed. This situation is a violation of IEEE,Std.
279-1968 Sections 4.13 and 4.20.
Response:  RGGE  is unclear  as  to how this conclusion  was drawn from a review of the Ginna test procedures.        When the removal of fuses and installation of jumpers to block equipment operation and'/or 'simulate contact closure is required as part of a test procedure, the alignment of this equipment to its original configuration is also specified in the procedure.
If the use of jumper control is needed, when is not directly specified in an approved maintenance, cali-it bration, test, or modification procedure, procedure A-1402, "Bypass of Safety Function or Jumper Control" is used. Installation and removal of any such jumpers is performed by two knowledgeable individuals, one being the job foreman. A copy of this procedure, Rev.
1,  is attached.
RG&E  thus considers the procedures for use of jumpers and fuses  acceptable, and in conformance with IEEE 279-1968.
The  test procedures require that certain      equipment be removed from    service by racking out breakers and by pull to stop switches as well as the use of jumpers and removal of fuses discussed above. These test methods violate Section 4.20 of IEEE Std. 279-1968 because they are not annunciated to the operator in a timely manner such as to provide him with an unambiguous indication of the status of equipment needed to protect the public health and safety.
Response: RGGE requires that, any safety system which is temporarily rendered inoperable due to testing during normal plant operations be monitored by the Ginna "Test Tag Control Program" (Procedure A-1103). A copy of this procedure is included. In addition, any testing, maintenance, or other operation performed on a safety-related piece of equipment at Ginna must be approved by the shift super-visor. Information about the operability of safety-related equipment to control room personnel is thus further assured.      I            I 1
I    I  f4    ~,(
: 4. As  noted in Topic VI-4    we have also discovered
                                    ~
that the .
override of    an automati.c ESF actuation signal    incapacitates the system level manual actuation features.
Response:  This concern    was addressed in letters from John E. Maier (RGEE) to Dennis M. Crutchfield (NRC) dated March 2, 1981 and September 18, 1981.      Resolution of any ad-ditional items is being addressed under SEP Topic VI-4.
2
0 g)NqP, 87/~7loh UHli <<1 COMPL" TED ROCHESTER GAS AND ELECTRIC CORPORATION DATE:-
GINNA STATION T)MF.:-
CONTROLLED COPY NUMBER PROCEDURE  NO.          A-1402                        'REV. NO ~
BYPASS OF SAFETY FUNCTION OR JUMPER CONTROL TECHNICAL REVIEW PORC      4/8/81 Q. A. REVIEW QC REVIEW 0 /2            6 II i'i--        DATE APPROVED FOR USE LANT SUPERIiNTENDENT                                            DATE QA-              NON-QA            CATAGORY  1.0 REVIEWED BY
            'HIS PROCEDURE      COiNTAINS  3    PAGES
j
~,  ~  ~
A-1402:1 A-1402 BYPASS OF SAFETY FUNCTION OR JUMPER CONTROL
==1.0 PURPOSE==
To  control the use of jumper. wires, lifted wire, pulled fuses, use of states blocks, spool pieces, -blank flanges, or other means to bypass, defeat or permit a device to perform or not perform its intended function.
1.2      This procedure does not apply when the functon is altered as part of an approved maintenance, calibration, test or modification procedure, nor does it apply to use of installed switches or buttons.
==2.0      REFERENCES==
2.1      None
==3.0 INSTRUCTIONS==
3.1      The multileaf request form should normally be      initiated  by the Job Foreman by signature on the request form.
3.1. 1  Two  knowledgeable individuals, one being the job foreman, shall concur on the location and clearly describe.        Terminal point locations, wire number, fuse number, or other description shall be used.
3.1.2    The Job Foreman    shall ensure the function    and purpose are  listed.
3.2      The  Shift Supervisor or alternate shall review the request for safety significance and effects on plant operations to determine whether the request should  be approved    or disapproved.
3.3      If approved,  the Shift Supervisor or alternate shall assign      a sequential Request    Ik, preceded by the year (i.e., 80-1).
Implementation shall be    verified  by two knowledgeable individuals.
I 3.4.1    Identification tags shall be attached to the jumper wire, lifted wire, or other device, as appropriate, to clearly identify the device.
NOTE:  If it is not feasible to physically attach the tag to the device, the tag should be fastened in the immediate area.
3.4.2
  ~  ~    Removal  shall  be  verified  by two knowledgeable  individuals;
( ~  ~
            ~
    ~
A-1402:2 The  Official Record shall indicate  when this is performed,  and when it  is removed.
3.6  The  Shift Supervisor shall review the active binder before  a  unit startup to ensure plant requirements are met.
==4.0 RECORDS==
4.1  The multileaf request form original shall remain in the Shift Super-visor's active binder until completed, and then submitted to Central Records.
L 4.2  The  yellow copy shall go to the Job Foreman, and  may be destroyed when completed.
4.3  Jumper  control tag(s) may be destroyed when completed.
~ ~
E  ~ ~ ~              '                                                                      A->402:3
      ~
ROCHESTER GAS AND ELECTRIC RMCRCTTCK PROCCOURC  Al&R GINNA STATION BYPASS OF SAFETY FUNCTION AND JUMPER CONTROL T
JOB FOREMAHT                                  OATEE                          REQUEST  A VERIFIED  BYT JUMPER WIRE    Q      LIFTED WIRE Q        FUSES PULLED  Q          STATES BLOCK    Q        OTHER      Q FUNCTION PURPOSE LOCATIONI SHIFT SUPERYISORT                                      DATE>
                      ~IHSTLLL TIOII                                EE~Y DATE 4 TIME                                  DATE 8 TIME ENTERED IH OfFICIAL LOG;                      KHTERED IH OFFICIAI. LOG; NUMBER OF TAGS ISSUED:                        NUMBER OF TAG REMOVED:
INSTALLED BYT                                REMOVEO BYT YERIF IED  BYT                                VERIFIED BYT
                                                                                                                    ~ I T42 A
0 C ROCHESTER GAS AND ELECTRIC CORPORATION GINNA STATION CONTROLLED COPY NUMBER PROCEDURE        NO.      A-1103                        REV. NO.
TEST TAG CONTROL PROGRAM TECHNICAL REVIEW PORC      3/4/81 QC REVIEW                                                  DATE APPROVED FOR USE LANT SUPERINTENDENT                                          DATE QA    X            NON-QA          CATAGORY 1.0 REVIEWED BY'HIS PROCEDURE      CONTAINS  5    PAGES
A-1103:1 A-1103 TEST TAG CONTROL PROGRAM 1.0    PURPOSE:,
This procedure describes the test control program for surveillance testing and fo'r "special tests on equipment, systems, and structures under the jurisdiction of the Shift Supervisor.
1.2    This procedure'lso provides'a'method for indicating the status of a Nuclear Safety System which is temporarily inoperable because of testing during normal plant operations.


RG&E Responses to Concerns Identified in the Evaluation and Conclusions of the SEP Assessment for SEP Topics VI-7.A.3 and VI-10.A, 12/15/80 1.The instrumentation strings from sensors thru bistable devices are not response time tested.As a result, the testing required by IEEE Std.279-1968 Section 4.10 is not satisfied because the response time design basis (IEEE 279-1968 Section 3 (i))is not verified.Response: RG&E does not, at this time perform response time testing of instrumentation strings for the Engineered Safety Feature System.We disagree, however, that the lack of such testing violates the provisions of IEEE 279-1968.RG&E does perform testing to verify that the final actuated devices are properly operational within the times assumed in the plant design basis.Appropriate test procedures were sent to the NRC with RG&E's trans-mittal of September 10, 1980.The Ginna design does not conform with the provisions of Regulatory Guide 1.118,"Periodic Testing of Electric Power and Protection Systems." This regulatory guide was published long after Ginna became operational; it was thus obviously not considered in the design of the plant.The latest version of Regulatory Guide 1.118 (Rev.2 published June 1978), states that this regulatory guide"...is'being and will continue to be used in the evaluation of submittals in connection with Construction Permit a lications..." (emphasis added).The implementation of this regulatory guide does not provide specific provisions for backfitting; it is not directly applicable to Ginna.RG&E further does not believe that strict adherence to the guidance provided in Regulatory Guide 1.118 is necessary to meet IEEE-279-1968 requirements.
==2.0    REFERENCES==
RG&E performs periodic tests and calibration on all components of the protection system instrumentation strings, including sensors.Any significant degradation in component response will be identified and corrected by this activity.RG&E is also preparing to implement certain response time testing at the Ginna plant.Ginna Technical Specifi-cations 4.4.6.2 and 4.8.10 require that the response time of each containment isolation function and each auxiliary feedwater initiation function be demonstrated to be within required limits at least once per 18 months.RG&E is presently developing a program to effect this requirement.
'inna 2.1                         Quality Assurance Manual, Section 14.
It is considered that the current methodology meets the requirements of this SEP topic.This issue does not need to be considered further within the Systematic Evaluation Program.
2.2    Regulatory Guide 1.47 "Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety System".
1 M 2.The test procedures required the removal of fuses and installation of jumpers to block equipment operation and/or to simulate contact closure.The procedures often do not specify the time at which these jury-rigged modifications are removed.This situation is a violation of IEEE,Std.279-1968 Sections 4.13 and 4.20.Response: RGGE is unclear as to how this conclusion was drawn from a review of the Ginna test procedures.
3.0    INSTRUCTIONS'.1 Description 3;1.1   A              test control program utilizing test tags (See Figure 1) and a test control log (See Figure 2), shall be utilized to provide the status indication and control of systems and equipment involved in the various tests. Valves, switches and other devices included in the test control program shall include:
When the removal of fuses and installation of jumpers to block equipment operation and'/or'simulate contact closure is required as part of a test procedure, the alignment of this equipment to its original configuration is also specified in the procedure.
3.1.1.1 Those major components                positioned out of their normal position for the             duration of'he test.
If the use of jumper control is needed, when it is not directly specified in an approved maintenance, cali-bration, test, or modification procedure, procedure A-1402,"Bypass of Safety Function or Jumper Control" is used.Installation and removal of any such jumpers is performed by two knowledgeable individuals, one being the job foreman.A copy of this procedure, Rev.1, is attached.RG&E thus considers the procedures for use of jumpers and fuses acceptable, and in conformance with IEEE 279-1968.The test procedures require that certain equipment be removed from service by racking out breakers and by pull to stop switches as well as the use of jumpers and removal of fuses discussed above.These test methods violate Section 4.20 of IEEE Std.279-1968 because they are not annunciated to the operator in a timely manner such as to provide him with an unambiguous indication of the status of equipment needed to protect the public health and safety.Response: RGGE requires that, any safety system which is temporarily rendered inoperable due to testing during normal plant operations be monitored by the Ginna"Test Tag Control Program" (Procedure A-1103).A copy of this procedure is included.In addition, any testing, maintenance, or other operation performed on a safety-related piece of equipment at Ginna must be approved by the shift super-visor.Information about the operability of safety-related equipment to control room personnel is thus further assured.I I I I f4~,(1 4.As noted in Topic VI-4 we~have also discovered that the.override of an automati.c ESF actuation signal incapacitates the system level manual actuation features.Response: This concern was addressed in letters from John E.Maier (RGEE)to Dennis M.Crutchfield (NRC)dated March 2, 1981 and September 18, 1981.Resolution of any ad-ditional items is being addressed under SEP Topic VI-4.2 0 ROCHESTER GAS AND ELECTRIC CORPORATION GINNA STATION CONTROLLED COPY NUMBER g)NqP, 87/~7loh UHli<<1 COMPL" TED DATE:-T)MF.:-PROCEDURE NO.A-1402'REV.NO~BYPASS OF SAFETY FUNCTION OR JUMPER CONTROL TECHNICAL REVIEW PORC 4/8/81 QC REVIEW Q.A.REVIEW 0/2 6 II i'i--DATE APPROVED FOR USE LANT SUPERIiNTENDENT DATE QA-NON-QA CATAGORY 1.0 REVIEWED BY'HIS PROCEDURE COiNTAINS 3 PAGES j
3.1.1.2 Those boundary valves which are desired                to remain closed during the             test.
~,~~A-1402:1 A-1402 BYPASS OF SAFETY FUNCTION OR JUMPER CONTROL 1.0 PURPOSE:-To control the use of jumper.wires, lifted wire, pulled fuses, use of states blocks, spool pieces,-blank flanges, or other means to bypass, defeat or permit a device to perform or not perform its intended function.1.2 This procedure does not apply when the functon is altered as part of an approved maintenance, calibration, test or modification procedure, nor does it apply to use of installed switches or buttons.
3.1.1.3 Throttling valves under the control of test personnel.
3.1.1.4 Critical system valves to remain open during the test.
3.1.1.5 Valves placed out-of-normal alignment during verification of interlock functions need not be tagged                if returned to normal position in a minimal amount of time.
NOTE:               This s stem is not to be confused or used in    lace of the regular "Hold" s stem which is for the rotection of   e  ui ment and personnel.


==2.0 REFERENCES==
A-1103:2
:
: 3. 1.2  The. "SAFE GUARDS TRAIN MODE INACTIVE" This section of the   TEST CONTROL LOG SHEET      shall be used to indicate any nuclear safety    systems made inoperable      for more than 1 hour as a result of the related equipment        involved  in a test.
2.1 None 3.0 INSTRUCTIONS:
3.2     Tag  Control Procedure 3.2.1  Prior to the start of the test, the test coordinator (Qualified Test Personnel Level II or III) shall review the Test Procedure with the "STATION HOLDING AUTHORITY" for test tag requirements after receiving permission to perform the test.
3.1 The multileaf request form should normally be initiated by the Job Foreman by signature on the request form.3.1.1 Two knowledgeable individuals, one being the job foreman, shall concur on the location and clearly describe.Terminal point locations, wire number, fuse number, or other description shall be used.3.1.2 3.2 The Job Foreman shall ensure the function and purpose are listed.The Shift Supervisor or alternate shall review the request for safety significance and effects on plant operations to determine whether the request should be approved or disapproved.
3.2.2  All test  tags shall be logged in the Test Control Log by the Test Coordinator with each entry to include the following information:
3.3 If approved, the Shift Supervisor or alternate shall assign a sequential Request Ik, preceded by the year (i.e., 80-1).Implementation shall be verified by two knowledgeable individuals.
EQUIPMENT; POSITION DURING TEST; TEST NUMBER; TEST COORDINATOR; PERFORMED BY; DATE AND DATE TEST PERFORMED; SAFEGUARDS TRAIN MODE INACTIVE (AS APPLICABLE) AND STATION HOLDING AUTHORITY.
I 3.4.1 Identification tags shall be attached to the jumper wire, lifted wire, or other device, as appropriate, to clearly identify the device.NOTE: If it is not feasible to physically attach the tag to the device, the tag should be fastened in the immediate area.3.4.2~~Removal shall be verified by two knowledgeable individuals;
3.2.3  The Test  Coordinator shall assure the first 4 lines of each test tag is complete and indicate the date the tag is placed.
(~~~~A-1402:2 The Official Record shall indicate when this is performed, and when it is removed.3.6 The Shift Supervisor shall review the active binder before a unit startup to ensure plant requirements are met.4.0 RECORDS: 4.1 The multileaf request form original shall remain in the Shift Super-visor's active binder until completed, and then submitted to Central Records.4.2 L The yellow copy shall go to the Job Foreman, and may be destroyed when completed.
3.2.4   Test tags shall be hung at the control switch, valve or other devices.
3.2.4.1 In the event of an error on a test tag or changes in plant condi-tions which require a correction in test tag initial information, the test co-ordinator will be notified. Upon his concurrence, test personnel shall line out the initial information, insert re-quired new information and initial the correction.
3.2.5  At the conclusion of the    test,  and  with the permission of the "STATION HOLDING AUTHORITY",    test tags shall be removed and status recorded in the Test Control Log. For testing during normal operation, "Test Termination" for safety systems tempor-arily inoperable, shall be when switches, valves and other related devices are returned to their pretest position and the system is again made fully operable.
NOTE:    For testing during refueling outages, and       if  at the conclusion of the test    it is agreed to leave    a system in its test alignment for subsequent maintenance or inspection, the "STATION HOLDING AUTHORITY" shall transfer control status of boundary valves from "TEST" to Shift upervisor  >>HOLD>> as  appropriate


===4.3 Jumper===
                                                                                    'A-1103:3 3.3   Test Control Record Retention
control tag(s)may be destroyed when completed.  
                                                                                  ,,i 3.3.1 The Test Control Log is an official record for all test control".
~~E~~~~'A->402:3 ROCHESTER GAS AND ELECTRIC GINNA STATION RMCRCTTCK PROCCOURC Al&R BYPASS OF SAFETY FUNCTION AND JUMPER CONTROL T JOB FOREMAHT VERIFIED BYT OATEE REQUEST A JUMPER WIRE Q FUNCTION LIFTED WIRE Q FUSES PULLED Q STATES BLOCK Q OTHER Q PURPOSE LOCATION I SHIFT SUPERYISORT DATE>~IHSTLLL TIOII DATE 4 TIME EE~Y DATE 8 TIME ENTERED IH OfFICIAL LOG;NUMBER OF TAGS ISSUED: KHTERED IH OFFICIAI.LOG;NUMBER OF TAG REMOVED: INSTALLED BYT YERIF IED BYT REMOVEO BYT VERIFIED BYT~I T42 A 0 C ROCHESTER GAS AND ELECTRIC CORPORATION GINNA STATION CONTROLLED COPY NUMBER PROCEDURE NO.A-1103 REV.NO.TEST TAG CONTROL PROGRAM TECHNICAL REVIEW PORC 3/4/81 QC REVIEW DATE APPROVED FOR USE LANT SUPERINTENDENT DATE QA X NON-QA CATAGORY 1.0 REVIEWED BY'HIS PROCEDURE CONTAINS 5 PAGES A-1103:1 A-1103 TEST TAG CONTROL PROGRAM 1.0 PURPOSE:, This procedure describes the test control program for surveillance testing and fo'r"special tests on equipment, systems, and structures under the jurisdiction of the Shift Supervisor.
operations and shall be maintained in the iMain Control Room.
1.2 This procedure'lso provides'a'method for indicating the status of a Nuclear Safety System which is temporarily inoperable because of testing during normal plant operations.
                                                                      '''''.3.1.1 Completed log sheets  will be  given to Central Records for 'filing.
2.0
3.3.2 Test tags may be disposed of -after procedure steps requiring~them been completed and the "Restored To Service" section of:,the                 'ave Test Control Log has been filled out.
3.4  Plant Emergenc  During Testing 3.4.1 If a plant emergency condition should  develop during a test, and it is, desirable to lift restraints on  a safety system temporarily inoperable because of the test, the Shift Supervisor shall notify                    .
the Test Coordinator to terminate the test and order the valves, switches or devices restored to their normal position.                                   w /


==2.1 REFERENCES==
ROCHESTER OAS ANO ELECTRIC CORPORATION GIHHA STATIOH TEST TAG CONTROL LOG TEST POSITION                  OUT OF SERVICE                              RESTORED TO SERVICE  SAFECUARO TRAIN EQUIPMENT                           FUSES              HOLOINC        'TEST       TEST                                MORE TRACTIVE OFEII CLOSEO   AS REO.       CATE TIME                                       OATE TINE         REMARKS {AS ArrLICAOLEI rULLEO            AUTIIORITT  COOROINATOR    NUMBER
'inna Quality Assurance Manual, Section 14.2.2 Regulatory Guide 1.47"Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety System".3.0 INSTRUCTIONS'.1 Description 3;1.1 A test control program utilizing test tags (See Figure 1)and a test control log (See Figure 2), shall be utilized to provide the status indication and control of systems and equipment involved in the various tests.Valves, switches and other devices included in the test control program shall include: 3.1.1.1 Those major components positioned out of their normal position for the duration of'he test.3.1.1.2 Those boundary valves which are desired to remain closed during the test.3.1.1.3 3.1.1.4 3.1.1.5 Throttling valves under the control of test personnel.
                                                                                                                                  . slnS in.<na
Critical system valves to remain open during the test.Valves placed out-of-normal alignment during verification of interlock functions need not be tagged if returned to normal position in a minimal amount of time.NOTE: This s stem is not to be confused or used in lace of the regular"Hold" s stem which is for the rotection of e ui ment and personnel.
'.NONrFRNANEMT . onrow((oNoATE}}
A-1103:2 3.1.2 The."SAFE GUARDS TRAIN MODE INACTIVE" This section of the TEST CONTROL LOG SHEET shall be used to indicate any nuclear safety systems made inoperable for more than 1 hour as a result of the related equipment involved in a test.3.2 3.2.1 Tag Control Procedure Prior to the start of the test, the test coordinator (Qualified Test Personnel Level II or III)shall review the Test Procedure with the"STATION HOLDING AUTHORITY" for test tag requirements after receiving permission to perform the test.3.2.2 3.2.3 All test tags shall be logged in the Test Control Log by the Test Coordinator with each entry to include the following information:
EQUIPMENT; POSITION DURING TEST;TEST NUMBER;TEST COORDINATOR; PERFORMED BY;DATE AND DATE TEST PERFORMED; SAFEGUARDS TRAIN MODE INACTIVE (AS APPLICABLE)
AND STATION HOLDING AUTHORITY.
The Test Coordinator shall assure the first 4 lines of each test tag is complete and indicate the date the tag is placed.3.2.4 Test tags shall be hung at the control switch, valve or other devices.3.2.4.1 3.2.5 In the event of an error on a test tag or changes in plant condi-tions which require a correction in test tag initial information, the test co-ordinator will be notified.Upon his concurrence, test personnel shall line out the initial information, insert re-quired new information and initial the correction.
At the conclusion of the test, and with the permission of the"STATION HOLDING AUTHORITY", test tags shall be removed and status recorded in the Test Control Log.For testing during normal operation,"Test Termination" for safety systems tempor-arily inoperable, shall be when switches, valves and other related devices are returned to their pretest position and the system is again made fully operable.NOTE: For testing during refueling outages, and if at the conclusion of the test it is agreed to leave a system in its test alignment for subsequent maintenance or inspection, the"STATION HOLDING AUTHORITY" shall transfer control status of boundary valves from"TEST" to Shift upervisor>>HOLD>>as appropriate
'A-1103:3 3.3 Test Control Record Retention 3.3.1 ,,i The Test Control Log is an official record for all test control".operations and shall be maintained in the iMain Control Room.'''''.3.1.1 3.3.2 3.4 Completed log sheets will be given to Central Records for'filing.Test tags may be disposed of-after procedure steps requiring~them
'ave been completed and the"Restored To Service" section of:,the Test Control Log has been filled out.Plant Emergenc During Testing 3.4.1 If a plant emergency condition should develop during a test, and*it is, desirable to lift restraints on a safety system temporarily inoperable because of the test, the Shift Supervisor shall notify.the Test Coordinator to terminate the test and order the valves, switches or devices restored to their normal position.w/
ROCHESTER OAS ANO ELECTRIC CORPORATION GIHHA STATIOH TEST TAG CONTROL LOG EQUIPMENT TEST POSITION OFEII CLOSEO AS REO.FUSES rULLEO CATE TIME HOLOINC AUTIIORITT
'TEST COOROINATOR OUT OF SERVICE TEST NUMBER OATE TINE REMARKS RESTORED TO SERVICE SAFECUARO TRAIN MORE TRACTIVE{AS ArrLICAOLEI
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Latest revision as of 04:45, 29 February 2020

Forwards Response to NRC 801215 Transmittal of Final SEP Assessments for Topics VI-7.A.3 & VI-10.A.Info Re Concerns Identified in Final Assessments Encl
ML17309A195
Person / Time
Site: Ginna Constellation icon.png
Issue date: 09/25/1981
From: Maier J
ROCHESTER GAS & ELECTRIC CORP.
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
TASK-06-07.A3, TASK-06-10.A, TASK-6-10.A, TASK-6-7.A3, TASK-RR NUDOCS 8110020253
Download: ML17309A195 (17)
v • d • e


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'Im'uit ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. I4649 JOHN E. MA IER TCL,EPHONE VICE PRESIDENT ARCA cOOK Tld 546-2700 September 25, 1981 Director of Nuclear Reactor Regulation Attention: Mr. Dennis M. Crutchf ield, Chief Operating Reactors Branch 55 gag '-g);

U. S. Nuclear Regulatory Commission Washington, D.C. 20555 1981~ 12 graf Ij~g~ Nlgj

Subject:

SEP Topics VI-7.A.3 and VI-10.A R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Crutchfield:

This letter is in response to your letter of December 15, 1980, transmitting the final SEP assessments for these two topics to Rochester Gas and Electric. Four items requiring resolution during the Integrated Assessment for Ginna were identified in these assessments. The information in the enclosure should resolve these concerns prior to the Integrated Assessment.

Very truly yours, hn E. Maier Enclosure

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Enclosure:

RG&E Responses to Concerns Identified in the Evaluation and Conclusions of the SEP Assessment for SEP Topics VI-7.A.3 and VI-10.A, 12/15/80

1. The instrumentation strings from sensors thru bistable devices are not response time tested. As a result, the testing required by IEEE Std. 279-1968 Section 4.10 is not satisfied because the response time design basis (IEEE 279-1968 Section 3 (i)) is not verified.

Response: RG&E does not, at this time perform response time testing of instrumentation strings for the Engineered Safety Feature System. We disagree, however, that the lack of such testing violates the provisions of IEEE 279-1968.

RG&E does perform testing to verify that the final actuated devices are properly operational within the times assumed in the plant design basis. Appropriate test procedures were sent to the NRC with RG&E's trans-mittal of September 10, 1980.

The Ginna design does not conform with the provisions of Regulatory Guide 1.118, "Periodic Testing of Electric Power and Protection Systems." This regulatory guide was published long after Ginna became operational; it was thus obviously not considered in the design of the plant. The latest version of Regulatory Guide 1.118 (Rev. 2 published June 1978), states that this regulatory guide ". . . is'being and will continue to be used in the evaluation of submittals in connection with Construction Permit a lications . . ." (emphasis added). The implementation of this regulatory guide does not provide specific provisions for backfitting; it is not directly applicable to Ginna. RG&E further does not believe that strict adherence to the guidance provided in Regulatory Guide 1.118 is necessary to meet IEEE-279-1968 requirements. RG&E performs periodic tests and calibration on all components of the protection system instrumentation strings, including sensors. Any significant degradation in component response will be identified and corrected by this activity. RG&E is also preparing to implement certain response time testing at the Ginna plant. Ginna Technical Specifi-cations 4.4.6.2 and 4.8.10 require that the response time of each containment isolation function and each auxiliary feedwater initiation function be demonstrated to be within required limits at least once per 18 months. RG&E is presently developing a program to effect this requirement.

It is considered that the current methodology meets the requirements of this SEP topic. This issue does not need to be considered further within the Systematic Evaluation Program.

1 M

2. The test procedures required the removal of fuses and installation of jumpers to block equipment operation and/or to simulate contact closure. The procedures often do not specify the time at which these jury-rigged modifications are removed. This situation is a violation of IEEE,Std.

279-1968 Sections 4.13 and 4.20.

Response: RGGE is unclear as to how this conclusion was drawn from a review of the Ginna test procedures. When the removal of fuses and installation of jumpers to block equipment operation and'/or 'simulate contact closure is required as part of a test procedure, the alignment of this equipment to its original configuration is also specified in the procedure.

If the use of jumper control is needed, when is not directly specified in an approved maintenance, cali-it bration, test, or modification procedure, procedure A-1402, "Bypass of Safety Function or Jumper Control" is used. Installation and removal of any such jumpers is performed by two knowledgeable individuals, one being the job foreman. A copy of this procedure, Rev.

1, is attached.

RG&E thus considers the procedures for use of jumpers and fuses acceptable, and in conformance with IEEE 279-1968.

The test procedures require that certain equipment be removed from service by racking out breakers and by pull to stop switches as well as the use of jumpers and removal of fuses discussed above. These test methods violate Section 4.20 of IEEE Std. 279-1968 because they are not annunciated to the operator in a timely manner such as to provide him with an unambiguous indication of the status of equipment needed to protect the public health and safety.

Response: RGGE requires that, any safety system which is temporarily rendered inoperable due to testing during normal plant operations be monitored by the Ginna "Test Tag Control Program" (Procedure A-1103). A copy of this procedure is included. In addition, any testing, maintenance, or other operation performed on a safety-related piece of equipment at Ginna must be approved by the shift super-visor. Information about the operability of safety-related equipment to control room personnel is thus further assured. I I 1

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4. As noted in Topic VI-4 we have also discovered

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that the .

override of an automati.c ESF actuation signal incapacitates the system level manual actuation features.

Response: This concern was addressed in letters from John E. Maier (RGEE) to Dennis M. Crutchfield (NRC) dated March 2, 1981 and September 18, 1981. Resolution of any ad-ditional items is being addressed under SEP Topic VI-4.

2

0 g)NqP, 87/~7loh UHli <<1 COMPL" TED ROCHESTER GAS AND ELECTRIC CORPORATION DATE:-

GINNA STATION T)MF.:-

CONTROLLED COPY NUMBER PROCEDURE NO. A-1402 'REV. NO ~

BYPASS OF SAFETY FUNCTION OR JUMPER CONTROL TECHNICAL REVIEW PORC 4/8/81 Q. A. REVIEW QC REVIEW 0 /2 6 II i'i-- DATE APPROVED FOR USE LANT SUPERIiNTENDENT DATE QA- NON-QA CATAGORY 1.0 REVIEWED BY

'HIS PROCEDURE COiNTAINS 3 PAGES

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A-1402:1 A-1402 BYPASS OF SAFETY FUNCTION OR JUMPER CONTROL

1.0 PURPOSE

To control the use of jumper. wires, lifted wire, pulled fuses, use of states blocks, spool pieces, -blank flanges, or other means to bypass, defeat or permit a device to perform or not perform its intended function.

1.2 This procedure does not apply when the functon is altered as part of an approved maintenance, calibration, test or modification procedure, nor does it apply to use of installed switches or buttons.

2.0 REFERENCES

2.1 None

3.0 INSTRUCTIONS

3.1 The multileaf request form should normally be initiated by the Job Foreman by signature on the request form.

3.1. 1 Two knowledgeable individuals, one being the job foreman, shall concur on the location and clearly describe. Terminal point locations, wire number, fuse number, or other description shall be used.

3.1.2 The Job Foreman shall ensure the function and purpose are listed.

3.2 The Shift Supervisor or alternate shall review the request for safety significance and effects on plant operations to determine whether the request should be approved or disapproved.

3.3 If approved, the Shift Supervisor or alternate shall assign a sequential Request Ik, preceded by the year (i.e., 80-1).

Implementation shall be verified by two knowledgeable individuals.

I 3.4.1 Identification tags shall be attached to the jumper wire, lifted wire, or other device, as appropriate, to clearly identify the device.

NOTE: If it is not feasible to physically attach the tag to the device, the tag should be fastened in the immediate area.

3.4.2

~ ~ Removal shall be verified by two knowledgeable individuals;

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A-1402:2 The Official Record shall indicate when this is performed, and when it is removed.

3.6 The Shift Supervisor shall review the active binder before a unit startup to ensure plant requirements are met.

4.0 RECORDS

4.1 The multileaf request form original shall remain in the Shift Super-visor's active binder until completed, and then submitted to Central Records.

L 4.2 The yellow copy shall go to the Job Foreman, and may be destroyed when completed.

4.3 Jumper control tag(s) may be destroyed when completed.

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ROCHESTER GAS AND ELECTRIC RMCRCTTCK PROCCOURC Al&R GINNA STATION BYPASS OF SAFETY FUNCTION AND JUMPER CONTROL T

JOB FOREMAHT OATEE REQUEST A VERIFIED BYT JUMPER WIRE Q LIFTED WIRE Q FUSES PULLED Q STATES BLOCK Q OTHER Q FUNCTION PURPOSE LOCATIONI SHIFT SUPERYISORT DATE>

~IHSTLLL TIOII EE~Y DATE 4 TIME DATE 8 TIME ENTERED IH OfFICIAL LOG; KHTERED IH OFFICIAI. LOG; NUMBER OF TAGS ISSUED: NUMBER OF TAG REMOVED:

INSTALLED BYT REMOVEO BYT YERIF IED BYT VERIFIED BYT

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0 C ROCHESTER GAS AND ELECTRIC CORPORATION GINNA STATION CONTROLLED COPY NUMBER PROCEDURE NO. A-1103 REV. NO.

TEST TAG CONTROL PROGRAM TECHNICAL REVIEW PORC 3/4/81 QC REVIEW DATE APPROVED FOR USE LANT SUPERINTENDENT DATE QA X NON-QA CATAGORY 1.0 REVIEWED BY'HIS PROCEDURE CONTAINS 5 PAGES

A-1103:1 A-1103 TEST TAG CONTROL PROGRAM 1.0 PURPOSE:,

This procedure describes the test control program for surveillance testing and fo'r "special tests on equipment, systems, and structures under the jurisdiction of the Shift Supervisor.

1.2 This procedure'lso provides'a'method for indicating the status of a Nuclear Safety System which is temporarily inoperable because of testing during normal plant operations.

2.0 REFERENCES

'inna 2.1 Quality Assurance Manual, Section 14.

2.2 Regulatory Guide 1.47 "Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety System".

3.0 INSTRUCTIONS'.1 Description 3;1.1 A test control program utilizing test tags (See Figure 1) and a test control log (See Figure 2), shall be utilized to provide the status indication and control of systems and equipment involved in the various tests. Valves, switches and other devices included in the test control program shall include:

3.1.1.1 Those major components positioned out of their normal position for the duration of'he test.

3.1.1.2 Those boundary valves which are desired to remain closed during the test.

3.1.1.3 Throttling valves under the control of test personnel.

3.1.1.4 Critical system valves to remain open during the test.

3.1.1.5 Valves placed out-of-normal alignment during verification of interlock functions need not be tagged if returned to normal position in a minimal amount of time.

NOTE: This s stem is not to be confused or used in lace of the regular "Hold" s stem which is for the rotection of e ui ment and personnel.

A-1103:2

3. 1.2 The. "SAFE GUARDS TRAIN MODE INACTIVE" This section of the TEST CONTROL LOG SHEET shall be used to indicate any nuclear safety systems made inoperable for more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> as a result of the related equipment involved in a test.

3.2 Tag Control Procedure 3.2.1 Prior to the start of the test, the test coordinator (Qualified Test Personnel Level II or III) shall review the Test Procedure with the "STATION HOLDING AUTHORITY" for test tag requirements after receiving permission to perform the test.

3.2.2 All test tags shall be logged in the Test Control Log by the Test Coordinator with each entry to include the following information:

EQUIPMENT; POSITION DURING TEST; TEST NUMBER; TEST COORDINATOR; PERFORMED BY; DATE AND DATE TEST PERFORMED; SAFEGUARDS TRAIN MODE INACTIVE (AS APPLICABLE) AND STATION HOLDING AUTHORITY.

3.2.3 The Test Coordinator shall assure the first 4 lines of each test tag is complete and indicate the date the tag is placed.

3.2.4 Test tags shall be hung at the control switch, valve or other devices.

3.2.4.1 In the event of an error on a test tag or changes in plant condi-tions which require a correction in test tag initial information, the test co-ordinator will be notified. Upon his concurrence, test personnel shall line out the initial information, insert re-quired new information and initial the correction.

3.2.5 At the conclusion of the test, and with the permission of the "STATION HOLDING AUTHORITY", test tags shall be removed and status recorded in the Test Control Log. For testing during normal operation, "Test Termination" for safety systems tempor-arily inoperable, shall be when switches, valves and other related devices are returned to their pretest position and the system is again made fully operable.

NOTE: For testing during refueling outages, and if at the conclusion of the test it is agreed to leave a system in its test alignment for subsequent maintenance or inspection, the "STATION HOLDING AUTHORITY" shall transfer control status of boundary valves from "TEST" to Shift upervisor >>HOLD>> as appropriate

'A-1103:3 3.3 Test Control Record Retention

,,i 3.3.1 The Test Control Log is an official record for all test control".

operations and shall be maintained in the iMain Control Room.

.3.1.1 Completed log sheets will be given to Central Records for 'filing.

3.3.2 Test tags may be disposed of -after procedure steps requiring~them been completed and the "Restored To Service" section of:,the 'ave Test Control Log has been filled out.

3.4 Plant Emergenc During Testing 3.4.1 If a plant emergency condition should develop during a test, and it is, desirable to lift restraints on a safety system temporarily inoperable because of the test, the Shift Supervisor shall notify .

the Test Coordinator to terminate the test and order the valves, switches or devices restored to their normal position. w /

ROCHESTER OAS ANO ELECTRIC CORPORATION GIHHA STATIOH TEST TAG CONTROL LOG TEST POSITION OUT OF SERVICE RESTORED TO SERVICE SAFECUARO TRAIN EQUIPMENT FUSES HOLOINC 'TEST TEST MORE TRACTIVE OFEII CLOSEO AS REO. CATE TIME OATE TINE REMARKS {AS ArrLICAOLEI rULLEO AUTIIORITT COOROINATOR NUMBER

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