ML17249A182

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Responds to NRC Re Violations Noted in IE Insp Rept 50-244/79-08.Corrective Actions:Procedures 16A & A-52.2 Have Been Revised to Require Valve 878E Be Locked Open During Operation
ML17249A182
Person / Time
Site: Ginna Constellation icon.png
Issue date: 08/28/1979
From: White L
ROCHESTER GAS & ELECTRIC CORP.
To: Brunner E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML17249A181 List:
References
NUDOCS 7910150063
Download: ML17249A182 (6)


Text

'Liililifililklil"'Vlf/lI ROCHESTER GAS AND ELECTRIC CORPORATION III' LliI0 I 00,

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89 EAST AVENUE, ROCHESTER, N.Y. 14649 I.EON O. WHITE. JR.

VICt PRtSIOKNT TtttPHoNt Acth coot 7iII 546-2700 August 28, 1979 Mr.,"Eldon J. Brunner, Chief Reactor Operations and Nuclear.

Support Branch U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Subject:

IE Inspection No. 50-244/79-08 R. E. Ginna Nuclear Power Plant, Unit 41 Docket No. 50-244

Dear Mr. Brunner:

This letter is in response to your August 7, 1979 letter received August 9,. 1979 concerning the inspection conducted at Ginna Station May 1-18, 1979 by Mr. Beckman of your office. Your letter stated that it appeared that two of'our activities were not conducted in full compliance with NRC requirements, as quoted below.

This letter contains information in response to these items.

ITEM A.

"10 CFR 50 Appendix B, Criterion XI Test Control, states, in part, '....test results shall be....evaluated to assure that test requirements have been satisfied.'he Ginna Station Quality Assurance Manual, Section ll, Test Control, Revision 6, Paragraph 3.6.1 states, in part, 'Additional control procedures shall be instituted, as necessary, to assure timely....evaluation of test results.'lant Procedure A-1104, Ginna Station Technical Specifica-tion Surveillance Program, Revision 0, Section 3.3, states, in part, 'The Results and Test Engineer, or designated assistant, shall be responsible for reviewing and evaluating the accuracy of all completed Periodic Tests....'ontrary to the above, on May 9-10, 1979, it was determined that the following Periodic Tests were not properly reviewed in that:

PT-12.2, Emergency Diesel 1B, Revision 10, performed on April 12, 1979, included unacceptable data for engine cooling water pressure Z910150

ROCHESTER GAS AND ELECTRIC CORP.

DATE =August 28, 1979 Mr. Eldon j. Brunner, Chief SHEET NO. 2 which was not identified during post performance procedure review; and PT 16, Auxiliary Peedwater Systems Revision 19, was performed on April 25, 19.79 but the=-test results did not receive timely evaluation in that the required data review and approval was not conducted until May 10, 1979 when the oversight was identified during this inspection and after approximately one half of the required surveillance test interval had elapsed. "

RESPONSE

The Results and Test Supervisor reviewed a portion of the data gathered on April 12, 1979, and, finding an obvious error, he immediately sent it back to the involved shift personnel for correction.

When he later received the corrected procedure, he erroneously considered the review of the data complete and omitted review of the error noted by the inspector.

Immediately after discovery of the unacceptable data a test was performed to ensure the "B" Emergency Diesel Generator was operable.

Allparameters were found to be acceptable.

Proper review of completed test procedures has been discussed with the Results and Test Supervisor.

The test procedure performed on April 2S, 1979 was not reviewed untQ May'0, 1979 as it did not receive priority attention in the press of increased work load and usage of personnel in task force work in connection with the TMIissue.

This condition has been=relieved as the Results and Test Group has recently gained two additional employees.

Timely review wQ1 be aided by using a special provision for receipt of newly completed test procedures.

ITEM B.

"T.S. 6.8. 1 states, in part, 'W'ritten procedures shall be established, implemented and maintained covering the activities referenced below:

a) the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1971....

'egulatory Guide 1.33, Appendix A recommends, in part, that the following safety related activities be covered by written procedures:

'A.3 Equipment Control (e.g. locking and tagging)'nd procedures for Startup, Operation and Shutdown of Safety Related PWR Systems, including 'C.S Emergency Core Cooling Systems.

'ontrary to the above, on May 3, 1979, it was determined that Reactor Plant Systems Operations Procedure S-16A, Safety Injection System Alignment,

I E

ROCHESTER, GAS AND ELECTRIC CORP.

o>Tf Aucfust 28, 1979 To Mr. Eldon J. Brunner, Chief SHEET NO. 3 Revision 14, was not properly established, implemented nor maintained in that it failed to provide instructions for proper positioning of manual valve V-787E, Safety Injection Loop A Cold Leg Injection Throttle Valve.

Further-more, Valve 878E was found to be locked open but was not included in the locked valve list of A-52.2, Control of Locked Valves, Revision 24, as required by Section 3.4 of that procedure.

RESPONSE

Investigation into the cause of this condition has found that in March 1971, when Valve 878E was installed as part of a modification, there were not sufficient Quality Assurance controls in existence to ensure that flow drawings and plant procedures were revised to reflect the modified or as-built configuratioh.

Although RG6E flow drawing was revised to show Valve 878E, S-16A and A-52.2 were not revised.

To correct this situation, S-16A and A-52.2 have been revised to require Valve 878E to be locked open during operation.

To preclude recur-rence, sufficient QA/Administrative controls have been satisfactorily demon-strated to be in effect to ensure timely revision of flow drawings and operating procedures to reflect modified or as-built conditions following station modifi-cations.

The inspection report contains no information that is considered proprietary.

Very truly yours, L. D., White, Jr.