ML17309A458

Responds to NRC 910208 Ltr Re Violations Noted in Insp Rept 50-244/90-31 on 901213-910103.Corrective Actions:Dc Distribution Panel Switch Labels Revised to Clarify Switch Load/Function & Addl Checklists Will Be Developed

ML17309A458
Person / Time
Site:	Ginna
Issue date:	03/08/1991
From:	MECREDY R C ROCHESTER GAS & ELECTRIC CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9103210167
Download: ML17309A458 (23)

See also: IR 05000244/1990031

Text

A.L Uj" LCKH AZU ULDLM.DU LAUlN LJZIVBJI.IDLLML

BJlN 3 I 8 LPIVJ.t i REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)i SSION NBR:9103210167

DOC.DATE: 91/03/08 NOTARIZED:

YES DOCKET CIL:50-244

Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH.NAME AUTHOR AFFILIATION

MECREDY,R.C.

Rochester Gasl'lectric Corp.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 910208 ltr re violations

noted in Insp,Rept ,50-244/90=31

on 901213-910103.Corrective

a'ctions:dc

distribution

panel switch labels revised to clarify switch load/function

&addi checklists

will be developed.

DISTRIBUTION

CODE: IEOID COPIES RECEIVED:LTR

ENCL/SIZE:/3 TITLE: General (50 Dkt)-Insp Rept/Notice

of Vio ation Response NOTES:License

Exp date in accordance

with 10CFR2,2.109(9/19/72).

/05000244 RECIPIENT ID CODE/NAME PD1-3 PD INTERNAL: AEOD AEOD/TPAB NRR MORISSEAU,D

NRR/DLPQ/LPEB10

NRR/DREP/PEPB9D

NRR/DST/DIR

8E2 NUDOCS-ABSTRACT

OGC/HDS1 RGN1 FILE 01 EXTERNAL: EGGG/BRYCE, J.H.NSIC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME JOHNSON,A AEOD/DEIIB

DEDRO NRR SHANKMAN,S

NRR/DOEA/OEAB

NRR/DRIS/DIR

NRR/PMAS/ILRB12

RG FIL 02 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D D D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22 A D D

I ROCHESTER GAS AND ELECTRIC CORPORATION

ROBERT C MECREDY Vice Precidenr Cinna Nuclear Producrion

~89 EAST AVENUE, ROCHESTER N.Y.14649-0001

TELEPHONE AREA COOE 71B 646 2700 March 8, 1991 U.S.Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, DC 20555 Subject: Reply to a Notice of Violation NRC Inspection

Report No.50-244/90-31

R.E.Ginna Nuclear Power Plant NRC Docket No.50-244 Dear Sir: This letter is in response to the February 8, 1991 letter from Thomas T.Martin, Regional Administrator, to Robert E.Smith, Senior Vice President, Production

and Engineering, which transmitted

Notice of Violation from Inspection

Report 90-31.In that letter, Violations

A and B were identified.

This letter provides the reply to the Notice of Violation, pursuant to 10 CFR 2.201.RESTATEMENT

OF VIOLATIONS:

During an NRC inspection

conducted between December 13, 1990 and January 3, 1991, violations

of NRC requirements

were identified.

In accordance

with the"General Statement of Policy and Procedure for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C, (1990), the particular

violations

are set forth below: A.10 CFR Part 50, Appendix B, Criterion VI,"Document Control," states in part, that measures shall be established

to control the issuance of documents, such as procedures, including changes thereto, which prescribe all activities

affecting quality.These measures shall assure that documents, including changes, are reviewed for adequacy.9103210167

910308 PDR ADOCK 05000244 PDR~~j,Hi l.e ap U

Contrary to the above, in March 1989, a procedure affecting quality, namely, Procedure M-48.14,"Isolation

of Bus 14 Undervoltage

System for Maintenance, Troubleshooting, Rework and Testing," was changed without an adequate review being performed.

The specific change involved inclusion of a step in the procedure which allowed the disabling of Engineered

Safety Feature Actuation System (ESFAS)instrumentation

while the reactor was in any mode of operation,'ncluding

power.The licensee's

organizational

measures for review, approval, and issuance of this procedure change, including the review by the Plant Operations

Review Committee, did not assure that the change was adequately

reviewed in that it did not identify that implementation

of the procedure change in a mode other than cold shutdown condition would place the plant in a condition that was prohibited

by Technical Specification 3.5.2.B.Technical Specification

6.8.1 requires establishment

of the applicable

procedures

recommended

in Appendix"A" of Regulatory

Guide 1.33, November 1972, (Safety Guide 33)Appendix A,Section I, specifies that maintenance

which can affect the performance

of safety-related

equipment should be properly preplanned

and performed in accordance

with written procedures, documented

instructions, or drawings appropriate

to the circumstances.

Contrary to the above, on December 12, 1990, the licensee failed to adequately

preplan and perform corrective

maintenance

on the A emergency diesel generator undervoltage

circuit card.Specifically, maintenance

procedure M-48.14,"Isolation

of Bus 14 Undervoltage

System for Maintenance, Troubleshooting, Rework and Testing," was used to perform the corrective

maintenance

while the reactor was at 3 percent power during startup.Step 5.5.1 directed personnel to open DC circuit breakers for the A and B safeguards

logic trains which disabled the automatic and manual (push button)sequencing

of safeguards

equipment.

This step was both unnecessary

to perform the required work and inappropriate

for the circumstances

as it disabled the safeguards

sequencing

function at a time prohibited

by plant technical specifications.

Additionally, use of M-48.14 proceeded despite indications

that the procedure was inappropriate.

Those indications

included labels on the DC breaker panels warning of the possible safety injection consequences

and the initiation

of alarm annunciator

L-31,"Safeguards

DC Bus Failure." Violations

A and B are classified

in the aggregate at Severity Level III.(Supplement

1)

REPLY TO VIOLATION A: THE REASONS FOR THE VIOLATION Rochester Gas and Electric (RG&E)concurs that the stated violation occurred.Procedure M-48.14 was changed in March 1989, without an adequate review being performed.

There were two weaknesses

in Ginna's procedure development

and change policy, which resulted in a technically

incorrect procedure being approved.As discussed by RG&E at the Enforcement

Conference

on January 29, 1991, these weaknesses

occurred at the level of the"Responsible

Manager" (RM)review, and in the lack of a multi-disciplinary

review of the proposed change.In March 1989, the procedure development

and change policy did not provide adequate guidance to an RM for.determining

the operational

impact of the proposed change.Consequently, the RM (using existing policy guidance)concluded that the proposed change was"minor" and did not have any operational

impact, since the proposed change added a step that was deleted during the last revision.Therefore, the RM did not require a multi-disciplinary

review.The Plant Operations

Review Committee (PORC), acting on the recommendation

of the RM, did not pursue this classification

in sufficient

detail and recommended

approval of the proposed change.2.THE CORRECTIVE

STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED RG&E personnel, with active participation

by senior management, performed a thorough investigation

of the event, and promptly initiated extensive and comprehensive

corrective

actions.The Senior Vice President conducted a.series of meetings, with PORC members, procedure RMs and all operating shifts to communicate

management

expectations

for maintaining

a questioning

attitude and the need for attention to detail.All plant procedures

were screened for their impact on operability

of safeguards

equipment, resulting in numerous procedures

being placed in a restricted

status, such that.the procedure could not be used without further review (quarantined).

The procedure development

and change policy was revised to require an operational

review of ALL proposed procedure changes, and a structured

procedure review checklist was developed for this'review.PORC and senior management

reviewed the adequacy of these short term corrective

actions, and Quality Performance

department

personnel performed an independent

assessment

of these actions.These actions were completed prior to startup of the plant.

A detailed list of short term corrective

actions (all of which have been completed)

is at Attachment

1.'umerous

corrective

actions that are considered

long term have also been completed.

These completed long term corrective

actions are at Attachment

2.Results of these actions assure a high level of detail and consistency

during the performance

of safety reviews.The need for a questioning

attitude at all times has also been reinforced.

A total of approximately

275 procedures

were quarantined, and these procedures

will remain unavailable

for use until a thorough review for their operational

impact has been performed.

These actions have strengthened

existing barriers (or created new barriers)within the procedure development

and change policy, to assure that procedure changes are adequately

reviewed.THE CORRECTIVE

STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

RG&E personnel have established

a detailed corrective

action plan to strengthen

the procedure development

and change policy.Personnel will be trained on the lessons learned from this event.There will be periodic assessments

of the adequacy of the proposed corrective

actions, and of their continuing

effectiveness.

Ongoing evaluations

will provide opportunities

for changes to or reinforcement

of these actions.The role of the RM in the procedure review process will be clarified.

See LER 90-017 and NRC Inspection

Report 90-31 for additional

discussions

of these long term actions.A detailed list of these proposed corrective

actions, including the current scheduled completion

date, is at Attachment

3.THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED Full compliance

with 10 CFR Part 50, Appendix B, Criterion VI was achieved prior to December 20, 1990.By that date, procedure quarantine

had been completed, and the procedure development

and change policy had been formally changed to require an operational.

review of all-proposed procedure changes.

0 (~

REPLY TO VIOLATION B.1.THE REASONS FOR THE VIOLATION Rochester Gas and Electric.concurs that the stated violation'occurred.

A Human Performance

Enhancement

System (HPES)evaluation

determined

that the following were co'ntributing

causes for the violation:

A.B.There was a lack of a formalized

process for the operational

review of work order packages.Procedure M-48.14 was a PORC approved procedure and was considered

correct by the Planner, Scheduler, and Control Room Foreman.C.D.Procedure M-48.14 had been previously

used by the Planner to successfully

implement corrective

maintenance.(However, the plant was at cold shutdown in that instance.)

Confidence

in the validity of the PORC approved M-48.14 and the Planner's stated previous experience

implementing

M-48.14 outweighed

the Control Room Foreman's questioning

attitude in his decision making to follow the procedure instructions.

In addition, other indications

were inadequate

in informing the operators that use of M-48.14 was inappropriate

under these circumstances:

A.Switch labelling within the DC distribution

panels lacked adequate information

in describing

the switch/load

function.B.Required Actions in Alarm Response Procedure AR-L-31, (Safeguards

DC Bus Failure)were not comprehensive.

l

THE CORRECTIVE

STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The following corrective

steps have been taken to address the contributing

causes: A.RG&E has developed and implemented

a detailed work package review requirement

for Safety Re'lated and Safety Significant

work.This includes work package reviews for technical adequacy, proper isolation/holds, operational

impact, adequate testing, conformance

to technical specifications

and quality concerns.The Technical (Discipline)

and Operational

Reviews are performed utilizing a.detailed checklist to ensure consistency

in the reviews.B.Rochester Gas and Electric Senior Management

has communicated ,their expectations

for maintaining'

questioning

attitude and attention to detail to Operations

Personnel, PORC Members, and Station"planning staffs.C.Selected plant procedure groups were screened for their impact on operability

of safeguards

equipment.

Those requiring changes or additional

information

were quarantined

from use until the changes are completed.

A total of approximately

275 plant procedures

were quarantined.

D.DC Distribution

Panel switch labels were revised to clarify switch load/function.

E.Procedure AR-L-31 (Safeguards

DC Bus Failure)was revised to incorporate

enhanced Required Actions.F.Operations

management

issued formal guidance to the operators, stating management

expectations

for work package review prior to release of equipment to maintenance.

A detailed list of short term corrective

actions (all of which, have been completed)

is at Attachment

1.Numerous corrective

actions that are considered

long term have also been completed.

These completed long term corrective

actions are at Attachment

2.

~'

3~THE CORRECTIVE

STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

Corrective

steps that will be taken to avoid further violations

are oriented toward strengthening

barriers and a more formalized

work package review and approval process.Additional

checklists

will be developed for work package reviews performed by non-Maintenance

personnel.

A detailed list of these proposed corrective

actions, including the current scheduled completion

date, is at Attachment

3.4~THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED Full compliance

with Technical Specification 6.8.1 and Appendix"A" of Regulatory

Guide 1.33, November 1972 occurred on December 20, 1991 with the implementation

of the additional

reviews for Safety Related and Safety Significant

work packages.Very truly yours, Robert C.Mec dy RCM dp Attach.(3)xc: Mr.Thomas T.Martin Regional Administrator

Region 1 475 Allendale Road King of Prussia, PA 19406 Thomas Moslak USNRC Senior Resident Inspector Ginna Station 1503 Lake Road Ontario, NY 14519 Subscribed

and sworn to before me on this 8th day of March, 1991 v'AMES C.McGUIRE NTAAY PUBUC, Stats of Nsat Yctft OuaFOIinhheos

Carly Mf CNtatfaahn

Expha Osc.2tt,$9+4

Page No.'TTACHMENT

1 LIST OF SHORT TERM CORRECTIVE

ACTIONS (THOSE ACTIONS SCHEDULED TO BE COMPLETED IN 1990)ITEM NUMBER DESCRIPTION

OF THE ACTION, WHICH WAS COMPLETED IN 1990.01 02 03 04 05 06 07 08 09 10 12i4 15/Senior Management

to meet with all operating shifts (prior to startup except for one shift)to communicate

management

expectations

for questioning

attitude and attention to detail., Management

to meet with the maintenance

planning staff to communicate

management

expectations

for questioning

attitude and attention to detail.Management

to meet with PORC members and procedure"Responsible

Managers" to communicate

management

expectations

for questioning

attitude and attention to detail.Prepare and issue a more detailed operations

policy on the importance

of following through on procedure concerns.Prepare and issue a policy for station planners on the importance

of identifying

operational

consequences

for planned activities

involving safeguards

equipment.

Involve the Operations

shift in the development

of corrective

actions for the HPES on crew performance.

Perform preliminary

HPES evaluation

for the issue of crew performance.

Perform screening of all plant procedure categories, to determine which categories

require review for quarantine.

Identify all current"M","EM", and"CP" procedures

that could involve safeguards

manipulation, Tech.Spec.'concerns, or A-52.4 concerns.Identify all other current plant procedures

that could involve safeguards

manipulation, Tech.Spec.concerns, or A-52.4 concerns.Based on the results of screening performed, quarantine

any proce'dures

that meet the'riteria

for quarantining.

Independent

check of the identification

of procedures

for quarantining.

Establish interim policy for the review of infrequently

used procedures

as part of the work package planning process.Determine the previous uses of M-48.13 and M-48;14, and identify any other times they were used inappropriately.

Review AR procedures

to ensure the appropriate

level of significance

is imparted, and the appropriate

response to the annunciator

is clearly stated.

Page No.ITEM NUMBER ATTACHMENT

1 LIST OF SHORT TERM CORRECTIVE

ACTIONS (THOSE ACTIONS SCHEDULED TO BE COMPLETED IN 1990)DESCRIPTION

OF THE ACTION, WHICH WAS COMPLETED IN 1990.16 17 18 19 20 22 23 24 25 Revise those AR procedures

that have significant

deficiencies.

Upgrade labelling of the two DC distribution

panels and two individual

DC switches in the Main Control Board.Determine any other AC or DC distribution

panels in the Control Room that require operator/training awareness, and/or upgraded labelling.

Perform immediate read and acknowledge

training on the functions of all DC switches, including SI-A1 and SI-B1, in, the 1A and 1B DC Distribution

Panels.Provide improved direction or additional

requirements

for operational

and pre-PORC review of changes to procedures.

Review the specific training histories and operating experience

of those operators directly involved in this event.PORC review of the adequacy of short term corrective

actions, and evaluation

of readiness for plant startup.Perform a senior management

review of the adequacy of short term actions completed, prior to plant startup.Initiate TCR for training on DC distribution

panels in the Main Control Board.Initiate TCR for long term training requirements.

Page No.ATTACHMENT

2, LIST OF LONG TERM CORRECTIVE

ACTIONS (THOSE ACTIONS SCHEDULED TO BE COMPLETED AFTER 1990 AND ALREADY COMPLETED)

DESCRIPTION

OF THE ACTION, WHICH HAS ALREADY BEEN COMPLETED ACTUAL COMPLETION

DATE Evaluate the safety significance

on accident analyses, for both trains of SI initiation

being disabled.Perform complete HPES evaluation

on the issue of crew performance, and identify recommended

'corrective

actions.Determine the priority and schedule for the corrective

actions resulting from the HPES evaluation

of crew performance.

Management

to meet with any remaining licensed operators, training staff, etc., as needed, to communicate

management

expectations

for questioning

attitude and attention to detail.Conduct training on the planner policy regarding the importance

of identifying

operational

consequences

for planned activities

involving safeguards

equipment.

Provide training on Operations

policy regarding Importance

of following through on procedure concerns, and provide feedback to Operations

management.

Perform Root Cause Analysis of the approval and use of M-48.14 (the PCN process), and identify any failed barriers.Recommend corrective

actions.Perform Barrier Analysis on the work planning process, and identify any failed barriers.Recommend corrective

actions.Review recommended

corrective

actions from the HPES evaluations, and develop a long term action plan to improve the process.Review results of actions.taken, HPES evaluations, and commitments

from LERs90-015, 90-016, and 90-017, and add actions~to this plan.Prepare a detailed action plan for the review and release of procedures

from quarantine.

Notify the industry via NUCLEAR NETWORK of this event.Initiate long term improvements

in the requirements

for review of Maintenance

Work Order packages.NSARB to review the adequacy of the long term Corrective

Action Plan.Issue formal guidance to the operators for management

expectations

for release of equipment to maintenance.

02/22/91'01/28/91 02/04/91 03/05/91 03/08/91 02/15/91 01/28/91 01/28/91 02/04/91 02/12/91 02/04/91 01/11/91 01/16/91 03/05/91 01/29/91

Page No.ATTACHMENT

3 LIST OF LONG TERM CORRECTIVE

ACTIONS (THOSE ACTIONS SCHEDULED TO BE COMPLETED AFTER 1990, AND NOT-YET COMPLETED)

DESCRIPTION

OF THE ACTION GROUP SCHEDULED ASSIGNED'OMPLETION

DATE Evaluate the impact of use of M-48.13/.14

during power operations, for other Technical Specification

concerns.Establish a working group to perform task identification

of infrequently

performed operational

activities.

Develop training for lessons learned from this event.For each Ginna"pre-PORC" group, establish a pre-PORC review checklist or review criteria'or

review of procedures.(This should-'e similar to the review criteria developed for the Operations.

group.)Revise remaining AR procedures

that have deficiencies.

Assess the adequacy of the administrative

controls established

as a result of the event..Evaluate the training conducted for changes to A-503 (Procedure

Adherence), for possible weaknesses

in that training.Notify the NRC of RGRE's policy for declaration

of an event, and of the requirement

to notify the NRC, and to subsequently

evaluate the need to notify the state and counties.MAINT 05/01/91 OPER 06/30/91 TRN-SYSTEM

09/01/91 SGP 07/01/91 OPER OPER 03/31/91 12/01/91 PM-MGMT 04/01/91 TRN-SYSTEM

10/14/91 Evaluate the guidance in the Emergency Plan and EPIP's, for declaration

of an event and/or notification

to the NRC and state~and counties, after the condit'ions

for the event no longer exist.GMNP-EP 05/01/91 Curriculum

Committees

to review the LER's, HPES evaluation, and Root Cause evaluations, for appropriate

incorporation

into training programs.Curriculum

Committees

to review the LER's, HPES evaluation, and Root Cause evaluations, for appropriate

incorporation

into training programs.TRN-GINNA 07/01/91 TRN-MAINT 07/01/91

1tl 0 l'

Page No.ATTACHMENT

3 LIST OF LONG TERM CORRECTIVE

ACTIONS (THOSE ACTIONS SCHEDUL'ED

TO BE COMPLETED AFTER 1990, AND NOT YET COMPLETED'DESCRIPTION

OF THE ACTION GROUP ASSIGNED SCHEDULED COMPLETION

DATE Curriculum

Committees

to review the LER's, HPES evaluation, and Root Cause evaluations, for appropriate

incorporation

into training programs.Clarify the role of the Responsible

Managers in the procedure review process,,to

ensure that the distinction

between"major" and"minor" changes is consistently'pplied, and that 10CFR50.59"consequential" changes are properly evaluated.

Clarify the role of the Responsible

Managers in the procedure review process, to ensure that accountability

for the adequacy and accuracy of procedures

is designated.

Revise procedure A-601 to clarify the role of the Responsible

Managers, and provide reinforcement

of management

expectations

to Responsible

Managers and other appropriate

personnel.

Consult with other utilities, to obtain information

on how they accomplish

similar activities.

Provide a plan to assure the'dequacy of the long term corrective

actions.Perform a review of policies issued (or procedures

changed)as a result of this event, to ensure they are consistent

with previously

existing policies and/or procedures.

Incorporate

the policies for long term improvements

in the Maintenance

Work Order process into formal administrative

controls.Ensure formal guidance is incorporated

into administrative

procedures.

Ensure appropriate

training is conducted on the formal guidance incorporated

into procedures.

TRN-SYSTEM

07/01/91 SGP 04/01/91 SGP 04/01/91 SGP 07/01/91 PM-MGMT 06/01/91 GMNP-MGMT 04/01/91 QC-ADMIN 05/01/91 MAINT 05/01/91 OPER 07/01/91 TRN-GINNA 09/01/91

Page No.ATTACHMENT

3 LIST OF LONG TERM CORRECTIVE

ACTIONS (THOSE ACTIONS SCHEDULED TO BE COMPLETED AFTER 1990, AND NOT YET COMPLETED)

DESCRIPTION

OF THE ACTION GROUP ASSIGNED SCHEDULED COMPLETION

DATE Implement training to all applicable

portions of the nuclear organization.

Implement training to all applicable

portions of the nuclear organization.

Develop a policy for, the use or reference to procedures

to respond to Annunciator

alarms.Conduct follow up evaluations

on the effectiveness

of the short term corrective

actions.Conduct effectiveness

reviews of the long term corrective

actions.Determine the need for added reinforcement

of the short term corrective

actions.NSARB to review the preliminary

results of effectiveness

reviews.NSARB to review the final results of effectiveness

reviews.TRN-GINNA 12/01/91 TRN-MAINT 12/01/91 OPER 09/01/91 PM-MGMT 06/30/91 OAC PM-MGMT 12/01/91 01/01/92 GMNP-MGMT 06/15/91 GMNP-MGMT 01/01/92

't I T