ML091970324

Reply to a Notice of Violation; EA-09-045

ML091970324
Person / Time
Site:	Ginna
Issue date:	07/07/2009
From:	John Carlin Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-09-045
Download: ML091970324 (6)

Text

John Carlin R.E. Ginna Nuclear Power Plant, LLC Site Vice President 1503 Lake Road Ontario, New York 14519-9364 585.771.5200 585.771.3943 Fax John.Carlin @constellation.com 0 iConstellation Energya Nuclear Generation Group July 7, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555 - 0001 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 Reply to a Notice of Violation; EA-09-045

REFERENCE:

Letter from Mr. S. J. Collins (NRC) to Mr. J. T. Carlin (Ginna) dated June 8, 2009, FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING, WITH ASSESSMENT FOLLOW-UP, AND NOTICE OF VIOLATION - R.E. GINNA NUCLEAR POWER PLANT.

This letter provides the R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) response to the referenced letter, which identified a Notice of Violation associated with the implementation of the preventive maintenance program for the Turbine Driven Auxiliary Feed Water Pump governor linkage. The violation involved the inadequacy of the program as evidenced by a failure of the pump to operate properly during a December 2, 2008 surveillance test. Ginna LLC agrees with the violation and has taken corrective steps to prevent further violations.

The attachment to this letter provides the Ginna LLC detailed response to the violation. In accordance

//with 10 CFR 2.201, this response describes the reason for the violation, the corrective steps that have been taken and results achieved, the corrective steps that will be taken to avoid further violations, and the date when full compliance will be achieved.

If you should have any questions regarding this submittal, please contact Mr. Thomas Harding at (585) 771-5219, or via email at Thomas.HardingJr@constellation.com.

Syours,

Attachment:

REPLY TO A NOTICE OF VIOLATION; EA-09-045 cc: S. J. Collins, NRC D. V. Pickett, NRC Ginna Resident Inspector, NRC P. D. Eddy, NYSDPS Z7iii~c5/

ATTACHMENT REPLY TO A NOTICE OF VIOLATION; EA-09-045 R.E. Ginna Nuclear Power Plant, LLC July 7, 2009

ATTACHMENT REPLY TO A NOTICE OF VIOLATION; EA-09-045 NOTICE OF VIOLATION Technical Specification 5.4.1.a, "Procedures," requires, in part, that the applicableprocedures recommended in Appendix A of Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operations)," shall be established,implemented, and maintained. RG 1.33, Appendix A, Section 9(b), states, "Preventive maintenance schedules shall be developed to specify lubrication schedules, inspection of equipment, replacement of such items as filters and strainers,and inspection or replacement ofpartsthat have a specific lifetime such as wear rings." Ginna procedureM-11.5C, "Auxiliary FeedwaterPump Minor Mechanical Inspection and Maintenance",Rev 29 (M-11.5C), which is an 18 month inspection requirementfor the turbine driven auxiliaryfeedwater (TDAFW) pump, contains steps which would have ensured proper cleaning and lubrication maintenance on the governor linkage.

Contrary to the above, during March 2008, licensee's technicians did not perform steps for cleaning and lubrication maintenance on the governor linkage in accordance with procedure M-11.5C. The steps to perform these activities were removed during the maintenance work planning. The subsequent lack of proper lubrication led to the operationalfailure of the TDAFW pump during testing on December 2, 2008.

This violation is associatedwith a White SDPfinding.

II. REASON FOR THE VIOLATION As listed above, an NRC Notice of Violation was issued to R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) for inadequate implementation of the Preventative Maintenance (PM) program for the TDAFW pump governor linkage that led to a failure of the pump to operate properly during a December 2, 2008, surveillance test.

Specifically, on December 2, 2008 with the plant in Mode 1, 100% Reactor Power, the TDAFW pump failed to develop an acceptable recirculation discharge flow rate (39 GPM versus the acceptance limit of > 55 GPM) as recorded during performance of the scheduled surveillance test, PT-16Q-T, "Auxiliary Feedwater Turbine Pump - Quarterly", Revision 05701. Discharge pressure of the pump, observed to be between 600 PSI and 700 PSI, was also noted as being below the normal value of approximately 1400 PSI.

The linkage of the governor control system of the TDAFW pump was exercised and no abnormalities were reported. An abbreviated version of PT-16Q-T that started the pump was performed again. During this performance, all pump parameters such as flow and pressure were within the acceptable ranges. The governor was replaced per Work Order (WO) 20807477.

Upon tuning of the new governor, the governor would not increase the speed of the turbine when the speed dial was turned in a manner to increase the speed, and the turbine was secured.

Examination of the linkage of the governor control system indicated that the TDAFW pump failed to operate properly due to binding of the governor linkage. The linkage was then disassembled, cleaned, lubricated, and re-installed. The abbreviated PT-16Q-T was performed with no pump parameter abnormalities. STP-O-16-COMP-T, "Auxiliary Feedwater Turbine Pump - Comprehensive Test", Revision 00000 was then completed with no pump parameter R.E. Ginna Nuclear Power Plant, LLC July 7, 2009 Page 1

ATTACHMENT REPLY TO A NOTICE OF VIOLATION; EA-09-045 abnormalities and the TDAFW pump was restored to operable status on December 4, 2008 at 10:11 am.

The root cause investigation conducted to address this event identified the following causes:

Root Cause (RC)

• There existed inadequate managerial controls for the level of detail of the preventative maintenance scope, as described in the existing electronically scheduled Repetitive Task (Reptask).

Contributing Causes (CC)

• The Reptask description provided inadequate details of the scope of the work to be performed. This required Planners to research the scope of the PM based on previous work orders. Reptask P300158 supplies vague wording with respect to the specific requirements of the scope of the work to be performed.

" When steps are marked N/A for Reptask work orders, a specific barrier for review does not exist that would ensure the requirements of the Reptask are met.

Steps within M-l I .5C, "Auxiliary Feedwater Pump Minor Mechanical Inspection and Maintenance," to lubricate the linkage of the governor control system were marked not applicable during the performance of work order 20602735 for Reptask P300158. This resulting lack of lubrication contributed to the linkage binding.

• There is no linkage lubrication standard for the mechanics and planners to use to ensure the proper type of lubrication is used and the proper scope of cleaning that should be performed. M- I 1.5C contains the vague and interpretive guidance statement of clean/inspect/lubricate that lacked appropriate details to prevent binding. These vague statements led to lubricant accumulation within the moving parts of the linkage, which contributed to the linkage binding.

iii. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Completed actions include:

1. Immediately after the event, the frequency of surveillance testing was increased; it was run weekly for two tests, every other week for two tests, every four weeks for one test, and then shifted back to a normal quarterly schedule with the system engineer present for each test to observe. No linkage binding issues were observed during testing.

2. The TDAFW pump linkage was disassembled, cleaned, and lubricated using a dry lubricant to ensure freedom of movement of the linkage. Furthermore, the needle bearings within the linkage arms were lubricated and inspected for wear. The spring within the collapsible link was replaced and the interior of the link was cleaned and lubricated. This was completed under troubleshooting per work order 20807477.

R.E. Ginna Nuclear Power Plant, LLC July 7, 2009 Page 2

ATTACHMENT REPLY TO A NOTICE OF VIOLATION; EA-09-045

3. Reptask P300158 was revised to clarify the entire scope within the description of the Reptask. The scope of the Reptask will include the governor oil change and the governor linkage lubrication.

4. A Reptask was created to rebuild the governor of the TDAFW pump on a nine year frequency. The installed governor will need to be sent to Woodward for the rebuild. The governor will be replaced with a spare from stock. NOTE: The governor was removed and sent to the vendor for rebuild. No anomalies were noted, the rebuild was completed and the component was returned to Ginna.

5. A Reptask was generated to perform a major inspection of the relay valve. The first occurrence was scheduled for September 2009, to coincide with the outage; however, a subsequent failure of the TDAFW pump resulted in replacement of the relay valve in May, as it exhibited signs of degradation. An appropriate replacement frequency will be determined based on findings from recent events.

6. A work order has been added to the 2009 Refueling Outage (RFO) scope to replace the needle bearings and pins of the TDAFW control linkage. Also, the linkage bars and the collapsible link shall be inspected and replaced if worn.

7. A Reptask was generated to replace the needle bearings and pins of the governor control system linkage every nine years. This work will align with the turbine major inspection.

IV. Corrective Steps That Will be Taken To Avoid Further Violations

1. Each Preventive Maintenance (PM) work order that was generated and described as a "minor" PM will be reviewed for embedded tasks that were not discussed in the Reptask description. Any deficiencies within the work order will be corrected. The Reptask descriptions will be revised to state the entire scope of the PM.

2. Revisions to MMP-GMO 11-00021, "Turbine Driven Auxiliary Feedwater Pump/Turbine Minor Inspection and Maintenance", (supersedes M-I 1.5C), M-1 1.5K, "Auxiliary Feedwater Pump Turbine Major Mechanical Inspection and Mechanical Overspeed Trip Testing", and CMM-37-19-9519E, "Worthington Turbine Driven Auxiliary Feedwater Pump Hydraulic Governor Control Valve Maintenance for 9519E", are in progress to include direction to clean the linkage, inspect the pins and needle bearings for wear, and lubricate the linkage using a dry lubricant. Also, each M-1 1.5K and CMM-37-19-9519E shall contain guidance for disassembly, inspection, and replacement of the linkage.

3. Revision of CNG-PR-l1.01-1009, "Procedure Use and Adherence Requirements", is in progress to state that the procedure is not applicable to procedures within work order packages. This would prevent steps in Reptask work orders from being marked "Not Applicable", preventing reoccurrence of the scenario in the second contributing cause listed above.

R.E. Ginna Nuclear Power Plant, LLC July 7, 2009 Page 3

ATTACHMENT REPLY TO A NOTICE OF VIOLATION; EA-09-045

4. A review was performed by each System Engineer of the components within their system(s) that require lubrication and the lubrication maintenance practices for each component classified as Critical that has control linkage. Revision of maintenance procedures is in progress to add detail for the lubrication where deficiencies were found.

5. A procedure is being created to give guidance for the lubrication and maintenance of control linkages. This will include the type of lubricant to use and if the linkage needs to be disassembled to ensure cleanliness of the pivot points of the linkage.

6. A process was developed and captured in an engineering guideline for performance of an initial engineering review of Reptaskjob plans to ensure they contain sufficient detail to eliminate the need for planners to interpret the scope of the task. Implementation of this process will begin and continue as all Reptasks are performed the first time.

7. All PMs defined as "minors" that were performed on safety related components since the last RFO will be reviewed. This review will identify whether any required PM was marked "Not Applicable" for work orders defined as minor PMs.

V. Date When Full Compliance Will Be Achieved Corrective actions defined in Sections III and IV are planned for completion by December 15, 2009.

Subsequent to the completion of the Root Cause Analysis Report for the event referenced in Section I, there have been two additional failures associated with this component. Causal evaluation of these events is in progress and is providing additional insights that may impact the causes and corrective actions stated in this document.

R.E. Ginna Nuclear Power Plant, LLC July 7, 2009 Page 4