IR 05000244/2002010

IR 05000244-02-010, on 10/07/2002 - 10/25/2002, R. E. Ginna Nuclear Power Plant; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML023220481
Person / Time
Site:	Ginna
Issue date:	11/18/2002
From:	David Lew NRC/RGN-I/DRS/PEB
To:	Mecredy R Rochester Gas & Electric Corp
References
IR-02-010
Download: ML023220481 (16)

Text

ber 18, 2002

SUBJECT:

GINNA - NRC PROBLEM IDENTIFICATION & RESOLUTION INSPECTION REPORT 50-244/02-010

Dear Mr. Mecredy:

On October 25, 2002, the NRC completed a team inspection at the R. E. Ginna Facility. The enclosed inspection report documents the inspection findings, which were discussed with you and members of your staff during an exit meeting conducted on October 25, 2002.

The inspection was an examination of activities conducted under your license as they related to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved withing the problem identification and resolution programs. However, during the inspection, several examples of minor problems were identified, including conditions adverse to quality that had not been entered into the corrective action program, narrowly focused Action Report evaluations, and some ineffective corrective actions.

In accordance with 10CFR2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web-site at http://www.nrc.gov/reading-rm/adams.html (the Public Reading Room).

Sincerely,

/RA/

David C. Lew, Chief Performance Evaluation Branch Division of Reactor Safety Docket No. 50-244 License No. DPR-18 Enclosure: Inspection Report 50-244/02-010 cc w/encl:

Dr. Robert

SUMMARY OF FINDINGS

IR 05000244/02-010; on October 7 - 25, 2002; R. E. Ginna Nuclear Power Plant; biennial baseline inspection of the identification and resolution of problems.

The inspection was conducted by two regional inspectors and one contractor. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Identification and Resolution of Problems The team concluded that, in general, problems were properly identified, evaluated, and corrected. The licensees effectiveness at problem identification was acceptable overall.

However, the NRC identified several minor deficiencies which were not identified or entered into the licensees corrective action system. While some minor exceptions were noted, the licensee adequately prioritized and evaluated problems that were entered into the corrective action program. Corrective actions, when specified, were generally implemented in a timely manner.

Licensee audits and self-assessments were found to be adequate. On the basis of interviews conducted during this inspection, workers at the site felt free to input safety findings into the corrective action program.

No findings of significance were identified.

ii

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Effectiveness of Problem Identification

(1) Inspection Scope The inspection team reviewed the procedures describing the corrective action process at the R. E. Ginna Nuclear Power Plant. The team reviewed a sample of action reports (AR) and deficiency tags to determine the threshold for identification of problems. The team reviewed logs, control room deficiencies and operator work-arounds, system health reports, work orders, temporary modifications, operating experience reviews, and procedures related to specific issues. In addition, the team interviewed staff and management to determine their understanding of the corrective action program. The specific documents reviewed and referenced during the inspection are listed in the attachment to this inspection report.

The team reviewed a sample of quality assurance (QA) audits and surveillances, and departmental self-assessments in the areas of operations, maintenance, engineering, radiation protection, security, emergency preparedness, training, and the corrective action program itself. The review was to determine if assessment findings were entered into the corrective action program, and if the corrective actions were properly completed to resolve identified deficiencies. The team evaluated the effectiveness of the audits and self-assessments by comparing the associated results against self-revealing and NRC-identified findings.

The team conducted several plant walk-downs of safety-related, risk significant areas to verify that observable system equipment and plant material adverse conditions were identified and entered into the corrective action program. The team also attended routine work control and management meetings to understand the interface between the corrective action program and the work control process.

(2) Findings Overall, the licensees effectiveness at problem identification was acceptable. The QA audits were self-critical and generally consistent with the teams findings. However, the team identified several minor deficiencies which were not identified or entered into the licensees corrective action system. Some examples for which the licensee subsequently initiated ARs are as follows.

• The team found an auxiliary operators key ring lying on a structural support near a valve in the B diesel generator room. One of the keys on this ring operated locked valves and breakers throughout the plant. The key ring did not contain security or high radiation area keys, however, this set of keys was not identified as missing for about the one week they were subsequently determined to have been missing. The licensee initiated AR 2002-2272 in response to this discovery, and confirmed the proper alignment of components, as appropriate.

• The team identified that the bend radius for one of the cables associated with the B safety-related battery was smaller than the acceptance limit. This particular cable was notably shorter in length than other battery cables. The operability of the battery was not impacted, however, the configuration did not conform to the design and installation criterion (AR 2002-2283 written).

The team also identified several other minor problems, such as implementation problems associated with the classification and storage of Precursor reports (for events of very low significance that require no investigative or corrective action); a small amount of boric acid on a safety injection system instrument fitting; and the presence of a screen covering the open end of the standby auxiliary feedwater test tank vent, contrary to the associated drawing. Regarding the details associated with the uncontrolled key ring described above, the team identified some broader concerns relative to key control and accountability. Inventory control for this type of key set, as well as other keys controlled by operations, was weak. There were prior individual key control deficiencies that had been identified via ARs (2001-1325 and 2001-1325), but the lack of an effective key control program was not recognized or addressed. As indicated by the noted examples, the team concluded that the licensee exhibited some weaknesses with regard to problem identification.

b. Prioritization and Evaluation of Issues

(1) Inspection Scope The team reviewed the ARs and work orders listed in the attachment to this report to assess whether the licensee adequately prioritized and evaluated the identified problems. This review included the causal assessment of each issue (e.g., a root cause analysis or an apparent cause evaluation); and for significant conditions adverse to quality, the extent of condition and determination of corrective actions to preclude recurrence. The team also evaluated the ARs for potential impact on equipment or system operability, reliability or unavailability.

The team reviewed the backlog of operations, maintenance and engineering issues to determine if issues were properly prioritized, and if individually or collectively, they represented an increased risk due to the delay of corrective actions. The team also reviewed the status and plans to correct equipment problems identified in system health reports and the Maintenance Rule documents. The team attended the daily screening and management meetings to evaluate the licensees ability to assess AR significance and identify if the initial determination of operability and reportability were correct.

The team observed portions of the onsite Plant Operations Review Committee (PORC)and the offsite Nuclear Safety Audit Review Board (NSARB), and reviewed the minutes of past meetings, to determine if the associated reviews were critical of the sites activities.

(2) Findings The team concluded that, in general, the licensee adequately prioritized and evaluated the issues and concerns entered into the AR process. Operability and reportability determinations were accurately performed in a timely fashion. Overall, the root cause analyses reviewed were thorough, determined the root cause and contributing causes, and recommended corrective actions that correlated to the identified causes. As required, corrective actions were generally identified and implemented to preclude recurrence for significant conditions adverse to quality. The overall backlog of issues appeared reasonable and properly evaluated for risk.

Notwithstanding the overall acceptable performance in this area, the team identified some minor instances where the Ginna staff had not properly prioritized or evaluated conditions adverse to quality. These examples are described as follows.

• AR 2002-0613 discussed a plant configuration where three of the five possible make-up paths were isolated from the reactor coolant system (RCS) while in a reduced inventory condition. This issue was previously characterized as a non-cited violation for the failure to follow procedures. During this inspection, the team noted the following with respect to the AR: 1) the event was not considered to be a Significant Condition Adverse to Quality; 2) the AR was prioritized improperly low as a Priority 3 with an evaluation due date in June 2002; 3) the AR was improperly determined to be non-consequential from a human impact consideration; and (4)an Extension Request was submitted and approved to extend the investigation completion date to November 2002, which would be about eight months after the event. The extension basis focused on clarifying the valve line-up procedures; and the safety significance was noted as None as the licensee considered this to be only a refueling outage concern.

The team determined the licensees actions taken to date and planned addressed the specific valve issue and not the human performance nature of why the Work Control Supervisor allowed the tags to be hung. Also, the team judged that the licensees event classification, prioritization, and human impact consideration minimized the potential safety impact. A more appropriate characterization likely would have necessitated a more rigorous and timely root cause analysis. Further, while the AR noted that an apparent cause was to be performed for a human performance event, the evaluation had not been completed as of the time of this inspection. Because the human performance causal analysis was not yet completed in a timely manner, the potential exists that relevant information may not be captured or recalled. Finally, the team considered the original issue to be a Significant Condition Adverse to Quality because it resulted in a reduced number of available make-up sources designed to mitigate the consequences of a draindown event while already in a reduced RCS inventory configuration. Although a similar or repeat occurrence had not resulted due to the ineffective processing and evaluation (including corrective actions) of this AR, the team concluded that the licensees overall response to this condition did not display a conservative safety focus. The licensee initiated AR 2002-2427 to address these concerns.

• In some cases, the priority level was not in alignment with event significance and procedure guidance. For example, AR 2002-2097 involved an equipment problem that resulted in a reactivity excursion (99.5% to slightly greater than 100%) due to an unexpected dilution, but was assigned Priority 4 (trending). Consistent with the guidance provided in procedure IP-NPD-4, Nuclear Operations Group Work Prioritization, it should have been Priority 2 (unexpected reactivity excursion such as a significant dilution). The team concluded that although the priority was incorrect, the licensee adequately evaluated and corrected the associated condition.

The licensee initiated AR 2002-2461 to address the incorrect priority assignment.

• The team concluded that AR evaluations involving human performance appeared less detailed and probing than those evaluations involving equipment performance.

As an example, AR 2002-1809 (diesel generator breaker closed out of phase during testing) emphasized process and procedure weaknesses and enhancements over the potential human performance problems (e.g., self-check techniques, supervisory oversight).

c. Effectiveness of Corrective Actions

(1) Inspection Scope The team reviewed the corrective actions associated with selected ARs to determine whether the actions had addressed the identified causes of the problems. The team also reviewed the licensees timeliness for implementing the corrective actions, and their effectiveness in precluding recurrence for significant conditions adverse to quality. The team also reviewed the non-cited violations issued since the last inspection of the Ginna corrective action program to determine if issues placed in their program had been properly evaluated and corrected.

(2) Findings Overall, the inspectors determined that corrective actions associated with ARs were effective; and as applicable, corrective actions were adequate to prevent problem recurrence (for significant conditions adverse to quality). The team found that, in general, the corrective actions were completed or scheduled to be completed in a timely manner commensurate with the significance of the issue. The team did not identify corrective actions in the backlog of work that represented an adverse impact on safety.

Notwithstanding, the team identified some minor instances where the licensees corrective actions were weak, and examples are described below.

• In a period of less than two years, there were four occurrences where service air header pressure was decreased due to the use of an air-operated vacuum cleaner. This was an undesirable condition that could potentially challenge the instrument air system, which is normally cross-connected to service air and provides motive force for several safety and risk significant systems (e.g., main steam isolation valves and feedwater regulating valves). Some of the licensees corrective actions included various administrative controls to ensure that personnel split the service and instrument air headers (prior to using the vacuum). However, these actions were repeatedly ineffective until the licensee implemented a corrective action to lock the vacuum cleaner, with the key in the control of the Shift Supervisor. The team determined that the use of the vacuum cleaner had not caused a plant transient, and neither the service air nor the instrument air system is safety related. Thus the failure to implement effective corrective actions was not a violation of NRC regulations. However, the lack of effective actions for these occurrences was noteworthy because the condition could have contributed to or caused a plant transient. The licensee initiated AR 2002-2428 in response to these concerns.

• Several ARs have been initiated following NRCs identification of deficiencies associated with tracking equipment unavailability time for the NRC performance indicators (PI). The errors were minor in nature and magnitude, and none of the errors would have changed the affected PI color (threshold). However, the team determined that the licensees actions to date have not been effective in preventing continued errors (AR 2002-2463 written).

d. Assessment of Safety Conscious Work Environment

(1) Inspection Scope During the inspection, the team interviewed plant staff to determine if conditions existed at the site which would result in personnel being hesitant to raise safety concerns to Ginna management and/or the NRC.

(2) Findings No findings of significance were identified.

4OA6 Meetings

a.

Exit Meeting Summary

On October 25, 2002, the team presented the inspection results to Dr. R. Mecredy and members of his staff. During the inspection, no proprietary material was examined or retained by the team.

Partial List of Persons Contacted Items Opened & Closed List of Documents Reviewed List of Acronyms

ATTACHMENT A. PARTIAL LIST OF PERSONS CONTACTED RG&E:

P. Bamford Manager, Operations M. Flaherty Manager, Nuclear Safety & Licensing R. Forgensi Manager, Operational Review J. Germain Operational Review Analysis T. Harding Licensing Engineer J. Hotchkiss Manager, Mechanical Maintenance T. Laursen Manager, Emergency Preparedness & Training Support M. Lilley Manager, Quality Assurance R. Marchionda Department Manager, Nuclear Assessment K. McCarthy Operational Review Engineer R. McMahon Operating Experience Engineer R. Mecredy Vice President, Nuclear Operations T. Miller System Engineer N. Olivia Senior Electrical Engineer P. Polfleit Corporate Nuclear Emergency Planner M. Ruby Licensing Engineer M. Smith System Engineer L. Stavalone Trending Analyst R. Teed Manager - Nuclear Security R. Watts Department Manager, Nuclear Training J. Wayland Manager, I&C/Electrical Maintenance T. White Manager, Balance of Plant Systems J. Zapetis Maintenance Rule Coordinator NRC:

K. Kolaczyk Senior Resident Inspector, Ginna D. Lew Branch Chief, Performance Evaluation Branch, Region I C. Welch Resident Inspector, Ginna B. ITEMS OPENED & CLOSED None 1 of 6 (cont.)

C.

LIST OF

DOCUMENTS REVIEWED

Procedures:

Plant Operations Review Committee Operating Procedure, Rev. 53

AP-RCP.1 Reactor Coolant Pump Seal Malfunction, Rev. 14

AR-AA-3 Alarm Response Procedure - Standby AFW Tank, Rev. 6

AR-B-17 Alarm Response Procedure - Seal Flow, Rev. 12

EP-2-P-0168 Maintenance Rule Monitoring, Rev. 5

FR-C.2 Response to Degraded Core Cooling, Rev. 16

FR-H.1 Response to Loss of Secondary Heat Sink, Rev. 27

FR-I.3 Response to Voids in Reactor Vessel, Rev. 16

GC-76.10 Installation, Testing and Inspection of Wire and Cable, Rev. 5

IP-CAP-1 Abnormal Condition Tracking Initiation or Notification (Action) Report,

Rev. 14

IP-DES-1 Technical Staff Request, Rev. 3

IP-IIT-5 Snubber Inspection and Testing Program, Rev. 1

IP-NPD-4 Nuclear Operations Group Work Prioritization, Rev. 6

IP-NPD-6 Nuclear Safety Audit and Review Board (NSARB), Rev. 4

IP-RDM-3 Ginna Records, Rev. 5

IP-SEP-2 Self Assessment, Rev. 4

IP-SEP-3 Ginna Station Management Observation, Coaching and Tours

Program, Rev. 2

S-16.13 RWST Water Makeup to Accumulators, Rev. 30

T-44.1 Condensate Test Tank for Standby AFW Pumps Filling or Draining,

Rev. 17

A-1603.0 Overview of the Ginna Station Work Control System, Revision 19

A-1603.1 Work Request / Trouble Report Initiation, Revision 14

A-1603.2 Work Order Initiation, Revision 15

A-1603.6 Post Maintenance / Modification Testing, Revision 8

A-1603.8 Work Order Processing for Emergency and/or After Hours

Maintenance, Revision 7

2.12 Inoperability of Equipment Important to a Safety, Revision 41

2.4 Control of Limiting Conditions for Operating Equipment, Revision 119

G-ORS-01 Screening Committee Guideline, Revision 50

IP-CAP-1.1 Operability and Past Operability Determination Checklist, Revision 2

IP-CAP-1.4 AR Extension Request, Revision 1

IP-CAP-1.8 Effectiveness Review Form, Revision 0

IP-CAP-2 Root Cause Analysis for Equipment Failures, Revision 4

IP-CAP-4 Problem Solving, Revision 1

IP-CAP-5 Event Trending Process, Revision 1

IP-CAP-6 10CFR021 Screening, Evaluating, and Reporting, Revision 2

IP-HPE-1 Human Performance Event Evaluation Process, Revision 3

IP-NPD-4 Nuclear Operations Group Work Prioritization, Revision 6

IP-PSH-1 Integrated Work Schedule, Revision 6

IP-PSH-2 Integrated Work Schedule Risk Management, Revision 6

OP-2.3.1 Draining & Operation at Reduced Inventory of the Reactor Coolant

System, Revision 71

SPG-02 Integrated Work Schedule Schedulers Handbook, Revision 11

of 6

(cont.)

Non-Cited Violations:

NCV 2001-06-01 Failure to Perform Flow Rate Determinations as per ODCM

NCV 2001-08-01 Failure to Include Acceptance Criteria in Procedures

NCV 2001-08-02 Failure to Implement MSIV Surveillance Requirement

NCV 2001-09-01 Inappropriate Procedures During Service Water Pump Motor

Replacement

NCV 2001-10-01 Failure to Identify Seismic Issue with Containment Isolation Valve

NCV 2002-02-01 RCS Make-up Flow Paths Were Inappropriately Isolated

NCV 2002-02-02 Improper Source Range Detector Calibration

NCV 2002-03-01 Failure to Control/Evaluate Compensatory Fire Protection Measure

NCV 2002-03-02 Unlocked Technical Specification High Radiation Area

NCV 2002-09-01 Failure to Utilize Mobile Loudspeakers for Transient Population

NCV 2001-09-02 Failure to Correct Equipment & Human Performance Problems

Quality Assurance Audits:

2000-0014-BKS Corrective Action & Operating Experience Programs

2001-0004-DHK Emergency Response Plan

2001-0009-JMT Engineering and Configuration Control Audit

2001-0010-RTD Problem Identification and Resolution Process Audit

2001-0013-TGT Operations Audit

2001-0017-PJH Audit of Ginna Station Technical Specifications

2002-0001-JMT ODCM and REMP Audit

2002-0002-TGT Maintenance Audit

2002-0003-BKS Cooperative Management Assessment Program

2002-0004-RTD Emergency Preparedness Audit

2002-0006-DHK Radiation Protection Audit

Self-Assessments:

2001-0025 Corrective Action Process Effectiveness

2002-0023 Effectiveness of Corrective Actions for Areas for Improvement

Identified During January 2001 Self-Evaluation

2002-0031 Effectiveness Review of Contamination Control During Reactor

Cavity Decontamination

2002-0041 Quality Control Program Preparedness

2002-0042 Self-Assessment of NCV Related to Reduced Inventory

2002-0043 Self-Assessment of NCV Related to the Alert Notification System

of 6

(cont.)

Action Reports: (* Denotes CR generated as a result of this inspection; P denotes a Precursor Report)

1997-1447 2001-1702 2002-0150P 2002-0878 2002-1997

2000-0188 2001-1749 2002-0161 2002-0904 2002-2035

2000-1176 2001-1757 2002-0163 2002-0931 2002-2035

2000-1268 2001-1764 2002-0193 2002-0948 2002-2060

2000-1301 2001-1767 2002-0193 2002-0976 2002-2097

2000-1489 2001-1774 2002-0195 2002-1014 2002-2116

2000-1630 2001-1802 2002-0195 2002-1022 2002-2260

2001-0001P 2001-1840 2002-0237P 2002-1028 2002-2261

2001-0013P 2001-1867 2002-0244P 2002-1028 2002-2271*

2001-0131P 2001-1879 2002-0266 2002-1146 2002-2272*

2001-0141P 2001-1888 2002-0371 2002-1146 2002-2273*

2001-0326P 2001-1921 2002-0371 2002-1149 2002-2277

2001-0393P 2001-1921 2002-0417 2002-1151 2002-2283*

2001-0457P 2001-1943 2002-0421 2002-1151 2002-2286*

2001-0517P 2001-1969 2002-0479 2002-1170 2002-2287*

2001-0676 2001-2091 2002-0492 2002-1202 2002-2288*

2001-0740P 2001-2131 2002-0530 2002-1362 2002-2289*

2001-0783 2001-2140 2002-0530 2002-1508 2002-2290*

2001-0862 2001-2227 2002-0530 2002-1564 2002-2300*

2001-0923 2001-2245 2002-0538 2002-1593 2002-2303*

2001-1070P 2001-2245 2002-0541 2002-1596 2002-2304*

2001-1148 2001-4355 2002-0595P 2002-1634 2002-2308*

2001-1325 2002-0038 2002-0661 2002-1663 2002-2309*

2001-1341 2002-0070 2002-0670P 2002-1753 2002-2311*

2001-1365 2002-0101 2002-0730P 2002-1759 2002-2405

2001-1395 2002-0109 2002-0756 2002-1770 2002-2405*

2001-1465 2002-0126 2002-0766 2002-1809 2002-2411*

2001-1632 2002-0127 2002-0821 2002-1849

2001-1691 2002-0142 2002-0822 2002-1941

Work Orders:

WO-20103571 Repair Lug Crimps on the B Service Water Pump

WO-20103583 Repair Lug Crimps on the A, C, & D Service Water Pumps

WO-20200848 Trouble shoot and repair AOV-371, Indicates Mid-Position but 25%

Open (related to AR 2002-0756)

WO-20201827 Repair A Containment Sump Pump Level Switch (LS-2039)

WO-20202034 Operations Suspects That V-214 Leaks By

WO-20202266 Install PCR 2002-0027, Replace Emergency Siren System

WO-20202387 Reach Rod to V-214 Needs to Be Replaced

of 6

(cont.)

Miscellaneous Documents:

PORC Meeting Minutes for meetings 2001-0041; 2001-0042; 2001-0049; 2002-0004;

2002-0007; 2002-0014; 2002-0021; 2002-0024; 2002-0028; 2002-0035; 2002-0040;

2002-0042; 2002-0045; 2002-0048

Nuclear Safety Audit Review Board (NSRB) Minutes for meetings 243, 244, and 245

Modification PCR-2002-0012, Relocate the Siren Central Control Unit to Ginna

Modification PCR-2002-0027, Replace Emergency Siren System

Temporary Modification 2000-0007, A S/G Blow-down Corrosion Product Sampler,

Rev. 1

Temporary Modification 2001-0012, Temporary SI Accumulator Makeup Pump, Rev. 1

Updated Final Safety Analysis Report

5059SCRN-2002-0524, Replace Emergency Siren System (related to WO-20202266)

Maintenance Department Monthly Performance Indicator Report (i.e. - backlog),

September 2002

Nuclear Emergency Response Plan, Revision 20

ProActive Assessment of Workplace Factors (PAOWF), August 2002

of 6

(cont.)

D. ACRONYMS

ADAMS Agencywide Documents Access and Management System

AFW Auxiliary Feedwater

AOV Air Operated Valve

AR Action Report

CFR Code of Federal Regulations

EDG Emergency Diesel Generator

I&C Instruments & Controls

MSIV Main Steam Isolation Valve

NCV Non-Cited Violation

NRC Nuclear Regulatory Commission

NSARB Nuclear Safety Audit Review Board

ODCM Offsite Dose Calculation Manual

PAOWF ProActive Assessment of Workplace Factors

PARS Publicly Available Records System

PCR Plant Change Request

PI Performance Indicator

PORC Plant Operations Review Committee

QA Quality Assurance

RCS Reactor Coolant System

REMP Radiological Environmental Monitoring Program

RG&E Rochester Gas and Electric Corporation

RWST Reactor Water Storage Tank

SDP Significance Determination Process

TM Temporary Modification

TS Technical Specification

WO Work Order

of 6