ML17263A526

Responds to Violations Noted in Insp Rept 50-244/93-21. Corrective Actions:Surveillance Tests Necessary to Verify Load Shedding Capability from Emergency Buses Performed & Procedure Revised

ML17263A526
Person / Time
Site:	Ginna
Issue date:	01/10/1994
From:	MECREDY R C ROCHESTER GAS & ELECTRIC CORP.
To:	JOHNSON A R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9402010169
Download: ML17263A526 (12)

See also: IR 05000244/1993021

Text

ttl'igRP jfpVEZE ROCHESTER GAS AND ELECTRIC CORPORATION

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

ROBERT C MECREDY Vice President@irma Nuclear Production

T Et.E PHONE AREA CODE 71B 546 2700 January 10, 1994 U.S.Nuclear Regulatory

Commission

Attn: Allen R.Johnson Project Directorate

I-3 Document Control Desk Washington, DC 20555 Subject: Reply to a Notice of Violation NRC Inspection

Report No.50-244/93-21, dated December 10, 1993 R.E.Ginna Nuclear Power Plant Docket No.50-244 Dear Mr.Johnson: During an NRC inspection

conducted on October 4, 1993 to October 13, 1993, a violation of NRC requirements

was identified.

In accordance

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

Actions," 10 CFR Part 2, Appendix C, the violation is listed below: "Plant technical specification 4.6.1.e.3.a

requires that at least once per 18 months during shutdown, each emergency diesel generator shall be demonstrated

to be operable by simulating

a loss of offsite power in conjunction

with a safety injection test signal and verifying de-energization

of the emergency buses and load shedding from the emergency buses." Contrary to the above, on October 11, 1993, it was determined

that testing to verify load shedding from the emergency buses was not performed during the 18 month surveillance

testing.(1)the reason for the violation, or, if contested, the basis for disputing the violation:

Rochester Gas&Electric Corporation (RG&E)accepts the violation.

We acknowledge

that plant procedures

did not adequately

test the bus undervoltage

logic, as required by Technical Specification (TS)4.6.1.e.3.(a).

Lettex: Page 2 Subject: Violation Response 93-21-01 Date: January 10, 1994 The reason for the violation, as stated in LER 93-005 (Docket Number 50-244, LER 93-005, dated November 10, 1993)was a mis-interpretation

of TS surveillance

requirements.

The load shedding requirement

of TS 4.6.1.e.3.{a)

was interpreted

as the shedding of non-essential

loads powered from the emergency buses.The shedding of non-essential

loads had been tested by simulating

a safety injection (SI)signal during performance

of procedures

RSSP-2.1 (Safety Injection Functional

Test)and RSSP-2.1A.(Safety Injection Functional

Test Alignment/Realignment), which are performed each refueling outage.The need to verify load shedding capabilities

of safeguards

loads, with undervoltage

and SI present, had not been considexed.

(2)the corrective

steps that have been taken and the results achieved: The immediate corrective

action was to perform the surveillance

tests necessary to verify load shedding capability

from the emergency buses.A procedure change notice (PCN)was developed for each associated

PT-9.1 procedure (monthly surveillance

test procedures

for testing undervoltage

protection

for 480 volt safeguards

busses 14, 16, 17, and 18).Testing was started on October 11, 1993, and was completed on October 12, 1993, within twenty-four

hours of discovery.

Details of this testing and test methodology

are discussed in Attachment

l.(To perfoim this testing, individual

components

were declared inoperable, one at a time, fox brief periods.No more than one component was inoperable

at a given time, and the diesel generators (DGs)were maintained

operable during the entire testing pexiod.)The guidance of NRC Generic Letter{GL)87-09, entitled"Sections 3.0 and 4.0 of the Standard Technical Specifications (STS)on the Applicability

of Limiting Conditions

for Operation and Surveillance

Requirements", was followed.Both the"A" and"B" DGs were available to perform all intended functions throughout

the discovery and surveillance

testing period.This testing demonstrated

end-to-end

operability

of the under-voltage protection

system.It verified undervoltage

signals to safeguards

components, and undervoltage

in conjunction

with SI signal to the Component Cooling'ater (CCW)pumps.Initial testing of the"B" CCW pump undervoltage

/SI trip logic was indeterminate.

At that time, the"B" CCW pump was declared inoperable, until further testing was conducted.

The pump was subsequently

verified to be fully operable, and was returned to service approximately

twelve hours later.The testing conducted on October 11-12, in combination

with the surveillance

tests conducted during the 1993 outage, met the requixements

of TS 4.6.1.e.3.(a), and verified that the safeguards

functions would have performed as required.

Letter: Page 3 Subject: Violation Response 93-21-01 Date: January 10, 1994 RG&E personnel subsequently

reviewed the requirements

of TS 4.6.1, and compared these requirements

with surveillance

proce-dures.No other noncompliances

were identified.

(3)the corrective

steps that will be taken to avoid further violations:

0 A review of Section 4 of the Ginna TS will be performed to ensure that there are implementing

procedures

for every surveillance

required by TS.This review will be completed prior to completion

of the next scheduled refueling outage.Results of a preliminary

review of Section 4 have determined

that there are sufficient

procedural

controls for implementing

Section 4 requirements.

0 0 A review of the identified

implementing

procedures

will be performed to ensure that these procedures

do, in fact, implement the TS requirements.

This review will be completed prior to completion

of the next scheduled refueling outage.Procedures

that verify load shedding capability

will be upgraded to include safeguards

loads, for conditions

of undervoltage

and SI, prior to completion

of the next scheduled refueling outage.(4)the date when full compliance

will be achieved: Full compliance

with TS 4.6.1.e.3.(a)

was achieved on October 12, 1993, at the completion

of surveillance

testing.Very truly yours, Robert C.Mecredy xc: Mr.Allen R.Johnson (Mail Stop 14D1)PWR Project Directorate

I-3 Washington, DC 20555 U.S.Nuclear Regulatory

Commission

Region I 475 Allendale Road King of Prussia, PA 19406 Ginna USNRC Senior Resident Inspector

Attachment

1 PT-9.1 Series Test Details The purpose of this test was to verify undervoltage

safeguards

load shedding capability.

Monthly TS surveillance

testing currently ensures each safeguards

breaker can be stripped from the bus using the trip coil.To verify the undervoltage

stripping capability, all that was necessary was to verify the integrity of the undervoltage

logic contacts and associated

circuitry, to the trip coils.Jumpers were used to simulate SI for the CCW pumps because their breakers trip on undervoltage

coincident

with SI signal.Testing Sequence: 1~Manipulate

test switches and develop an undervoltage

condition using test equipment.

2~Verify auxiliary output relays energize to cause the trip function, initiated by appropriate

operation of the intermediate

digital control logic circuitry.

3~4~5.6.Return test switches to normal and remove test equipment.

Verify component being tested is not, in service.Measure the continuity

of wiring between the undervoltage

auxiliary relays and the breaker switchgear, using DC voltage measurements

to ground.)t Verify normally open output relay contacts using resistance

measurements.

7~8.Locally trip the associated

auxiliary relay and verify proper indicator lamp response and relay contacts indicate closed by resistance

measurement.

Reset the auxiliary relay and verify relay contacts indicate open by resistance

measurement.

9.Repeat steps 1-8 for all four channels (27/X, 27/BX, 27D/X, and 27D/BX).One test anomoly was identified, as noted in the violation response.Relay 86-16B, associated

with the"B" CCW pump breaker, failed to meet the specified resistance

acceptance

criteria.Emergency Maintenance

procedure EM-778 was performed to verify the contact did in fact trip the breaker.After being verified, the contact was reworked by simple burnishing

of exposed contact surfaces.~~~v

~'i 0

ACCELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CCESSION NBR:9402010169

DOC.DATE'4/01/10

NOTARIZED:

NO FACIL:50-244

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

MECREDY,R.C.

Rochester Gas&Electric Corp.RECIP.NAME

RECIPIENT AFFILIATION

JOHNSON,A.R.

Project Directorate

I-3 I SUBJECT: Responds to violations

noted in insp rept 50-244/93-21.

Corrective

actions:surveillance

tests necessary to verify load shedding capability

from emergency buses performed&procedure revised.DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

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

of Vi&o ation Response NOTES:License

Exp date in'ccordance

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

DOCKET 05000244 D$/05000244 RECIPIENT ID CODE/NAME PD1-3 PD INTERNAL: AEOD/DEIB AEOD/DS P/TPAB DEDRO NRR/DRCH/HHFB

NRR/DRSS/PEPB

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i 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/DSP/ROAB

AEOD/TTC NRR/DORS/OEAB

NRR/DRIL/RPEB-

NRR/PMAS/ILPB1

NUDOCS-ABSTRACT

OGC/HDS1 RES/HFB NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1'1 1 1 1 1 1 1 1 1 1 1 D D R D S NOTE TO ALL"RIDS" RECIPIENTS:

D D PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEEDI OTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

t"'l'i"~lliPjt'I

/'l'gjll,"i,",iiel't

I t,/f//IP'(/

ROCHESTER GAS AND ELECTRIC CORPORATION

ROBERT C.MECREDY Vice Ptesident Ctnna Nuetear Ptoduetion

,/net~~~VA~~G ToAtt II F I$Tate~89 EAST AVENUE, ROCHESTER N.Y.14649.OO0'I

TELEPHONE AREA CODE 716 546'2700 January 10, 1994 U.S.Nuclear Regulatory

Commission

Attn: Allen R.Johnson Project Directorate

I-3 Document Control Desk Washington, DC 20555 Subject: Reply to a Notice of Violation NRC Inspection

Report No.50-244/93-21, dated December 10, 1993 R.E.Ginna Nuclear Power Plant Docket No.50-244 Dear Mr.Johnson: During an NRC inspection

conducted on October 4, 1993 to October 13, 1993, a violation of NRC requirements

was identified.

In acccrdance

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

Actions," 10 CFR Part 2, Appendix C, the violation is listed below: "Plant technical specification 4.6.l.e.3.a

requires that at least once per 18 months during shutdown, each emergency diesel generator shall be demonstrated

to be operable by simulating

a loss of offsite power in conjunction

with a safety injection test signal and verifying de-energization

of the emergency buses and load shedding from the emergency buses." Contrary to the above, on October 11, 1993, it was determined

that testing to verify load shedding from the emergency buses was not performed during the 18 month surveillance

testing.(1)the reason for the violation, or, if contested, the basis for disputing the violation:

Rochester Gas&Electric Corporation (RG&E)accepts the violation.

We acknowledge

that plant procedures

did not adequately

test the bus undervoltage

logic, as required by Technical Specification (TS)4.6.1.e.3.(a).gw~I To iQ'.9402010169

940110 PDR ADOCK 05000244 9 PDR

0'

Letter: Page 2 Subject: "Violation

Response 93-21-01 Date: January 10, 1994 The reason for the violation, as stated in LER 93-005 (Docket Number 50-244, LER 93-005, dated November 10, 1993)was a mis-interpretation'of

TS surveill'ance

requirements.

The load shedding requirement

of TS 4.6.1.e.3.(a)

was interpreted

as the shedding of non-essential

loads powered from ,the emergency buses.The shedding of non-essential

loads had been tested by.simulating

a safety injection (SI)signal.during performance

of procedures

RSSP-2.1 (Safety Injection Functional

Test)and RSSP-2.1A (Safety Injection Functional

Test Alignment/Realignment), which are performed each refueling outage.The need to verify load shedding capabilities

of safeguards

loads, with undervoltage

and SI present, had not been considered., l (2)the corrective

steps that have been taken and the results achieved: The immediate corrective

action was to perform the surveillance

tests necessary to verify load shedding capability

from the emergency buses.A procedure change notice (PCN)was developed for each associated

PT-9.1 procedure (monthly surveillance

test procedures

for testing'undervoltage

protection

for 480 volt safeguards

busses 14, 16, 17, and 18).Testing was started on October 11, 1993, and was completed on October 12, 1993, within twenty-four

hours of discovery.

Details of this testing and test methodology

are discussed in Attachment

1..(To perform this testing, indiyidua2.

components

were declared inoperable, one at a time, for brief periods.No more than one component was inoperable

at a given time, and the diesel generators (DGs)were maintained

operable during the entire testing period.)The guidance of.NRC Generic Letter (GL)87-09, entitled"Sections 3.0 and 4.0 of the Standard Technical Specifications (STS)on the Applicability

of Limiting Conditions

for Operation and Surveillance

Requirements", was followed.,Both the"A" and"B" DGs were available to perform all intended functions throughout

the discovery.

and surveillance

testing period.This testing demonstrated

end-to-end

operability

of the under-voltage protection

system.It verified undervoltage

signals to safeguards

components, and undervoltage

in conjunction

with SI signal to the Component Cooling Water (CCW)pumps.Initial testing of the"B" CCW pump undervoltage

/SI trip logic was indeterminate.

At that time, the"B" CCW pump was declared inoperable, until further testing was conducted.

The pump was subsequently

verified,to

be fully operable, and was returned to service approximately

twelve hours later.The testing conducted on October 11-12, in combination

with the surveillance

tests conducted during the 1993 outage, met the requirements

of TS 4.6.1.e.3.(a), and verified that the safeguards

functions would have performed as required.

Letter: Page 3 Subja't: Violation Response 93-21-01 Date: January 10, 1994 RG&E personnel subsequently

reviewed the requirements

of TS 4.6.1, and compared these requirements

with surveillance

proce-dures.No other noncompliances

were identified.

(3')the corrective

steps that will be taken to avoid further violations:

0 0 0 A review of Section 4 of the Ginna TS will be performed to ensure that there are implementing

procedures

for every surveillance

required by TS.This review will be completed prior to completion

of the next scheduled refueling outage.Results of a preliminary

review of Section 4 have determined

that there are sufficient

procedural

controls for implementing

Section 4 requirements.

A review of the identified

implementing

procedures

will be performed to ensure that these procedures

do, in fact, implement the TS requirements.

This review will be completed prior to completion

of the next scheduled refueling outage.Procedures

that verify load shedding capability

will be upgraded to include safeguards

loads, for conditions

of undervoltage

and SI, prior to completion

of the next scheduled refueling outage.(4)the date when full compliance

will be achieved: Full compliance

with TS 4.6.1.e.3.(a)

was achieved on.October 12, 1993, at the completion

of surveillance

testing.Very truly yours, Robert C.Mecredy xc: Mr.Allen R.Johnson (Mail Stop 14D1)PWR Project Directorate

I-3 Washington, DC 20555 U.S.Nuclear Regulatory

Commission

Region I 475 Allendale Road King of Prussia, PA 19406 Ginna USNRC Senior Resident Inspector

Attachment

1 PT-9.1 Series Test Details The purpose of this test was to verify undervoltage

safeguards

load shedding capability.

Monthly TS surveillance

test'ing currently ensures each safeguards

breaker can be stripped from the bus using the trip coil.To verify the undervoltage

stripping capability, all that was necessary was to verify the integrity of the undervoltage

logic contacts and associated

circuitry, to the trip coils.Zumpers were used to simulate SI for the CCW pumps because their breakers trip on undervoltage

coincident

with SI signal.Testing Sequence: 1~Manipulate

test switches and develop an undervoltage

condition using test equipment.

2~Verify auxiliary output relays energize to cause the trip function, initiated by appropriate

operation of the intermediate

digital control logic circuitry.

3~4~5.Return test switches to normal and remove test equipment.

Verify component being tested is not in service.Measure the continuity

of wiring between the undervoltage

auxiliary relays and the breaker switchgear, using DC voltage measurements

to ground.6.Verify normally open output relay contacts using resistance

measurements.

7~8.Locally trip the associated

auxiliary relay and verify proper indicator lamp response and relay contacts indicate closed by resistance

measurement.

Reset the auxiliary relay and verify relay contacts indicate open by resistance

measurement.

9.Repeat steps 1-8 for all four channels (27/X, 27/BX, 27D/X, and 27D/BX).One test anomoly was identified, as noted in the violation response.Relay 86-16B, associated

with the"B" CCW pump breaker, failed to meet the specified resistance

acceptance

criteria.Emergency Maintenance'rocedure

EM-778 was performed to verify the contact did in fact trip.the breaker.After being verified, the contact was reworked by simple burnishing

of exposed contact surfaces.

~l