ML17250A885

Responds to NRC 890428 Ltr Re Violations Noted in Insp Rept 50-244/89-04.Corrective Actions:Existing Info Assembled & Performed Confirmatory Addl Analyses to Demonstrate That Operability of Replacement PORV Block Valves Assured

ML17250A885
Person / Time
Site:	Ginna
Issue date:	07/12/1989
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8907240194
Download: ML17250A885 (18)

Text

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'tttI";"i.l)t>"7,"i~Plllfifll ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649-0001

>El,t>>>>O>>E A+EA CODE ~l4 546 2700 July 12, 1989 U.S. Nuclear, Regulatory Commission Region I Attn: Thomas T. Martin, Director Divisinn n f Reactor Sa fether 475.Allendale Road King of Prussia, PA 19406

Subject:

Inspection Report 50-244/89-04 and Notice of Violation (PORV Block Valve Replacement)

R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Martin:

By letter dated April 28, 1989, the NRC provided RG&E with the results of Inspection No. 50-244/89-04. Appendix A to that letter consisted of a Notice of Violation related to the extent of documentation addressing operability qualification of replacement PORV block valves. RG&E was requested to respond, within 30 days, and provide a written statement or explanation in reply to the Notice, including (1) the reasons for the violation, (2) corrective steps which have been taken and the results achieved, (3) corrective steps which will be taken to avoid further violations, and (4) the date the full compliance will be achieved. The Notice further s A.a v>-d iEAai I wAAere good cause is shown cons3.ueration would be given to extending the response time.

Pertinent information regarding additional documentation supporting operability qualification of the replacement PORV block valves, as requested by the NRC inspector, was submitted on May 3, 1989. This was found to be acceptable, as stated in the NRC response, dated May 18, 1989. Since key RG&E personnel were fully engaged in completing the Spring 1989 Refueling Outage and its associated modification activities, and since the technical issues concerning the valves had been resolved, RG&E requested, by letter dated May 26, 1989, that an additional 45 days be allowed for our formal response to the Inspection Report and Notice of Violation.

In accordance with 10 CFR 2.201, RG&E provides Attachment I to this letter as our reply. to the Notice of Violation contained in Appendix A to NRC Inspection Report 50-244/89-

04. The reply admits the violation and provides the explanatory information requested in the Notice of Violation.

Very truly yours, Robert C. Mecr dy General Manager Nuclear Production JCMN054 Attachment xc: U.S. Nuclear Regulatory Commission (original)

Document Control Desk Washington, D.C. 20555 Allen R. Johnson (Mail Stop 14D1)

Project Directorate I-3 Washington, D.C. 20555 Ginna Senior Resident Inspector

8 0

ATTACHMENT I Violation NRC Inspection Report No. 50-244/89-04, Appendix A, identified the following violation:

"10 CFR 50, Appendix B, Criterion III requires that measures be established to assure that applicable regulatory requirements...are correctly translated into specifications, drawings, procedures and instructions." It further requires that, "design changes, including field changes shall be subject to design control measures commensurate with the original design."

"Contrary to the above, the licensee's Design Criteria and Safety Analysis for the PORV block valve replacement to be performed during the 1989 refueling outage did not address operability qualification of the replacement-., valves.

Operability qualification of PORV block valves was a NUREG-0737 Item (II.D.l) committed to by the licensee as confirmed in Commission Order dated July 10, 1981."

RG&E admits to the violation.

Reason for Violation The PORV Block Valve Replacement project Design Criteria document (Revision 0, dated January 22, 1986) sets forth the requirements for operability qualification. It references NUREG-0737,Section II.D.1, EPRI report NP-2541-LD, "EPRI/Marshall Electric Motor'-

Operated Valve (Block Valve) Interim Test Data Report" and NRC IE Bulletins 81-02 and 85-03. These referenced documents were reviewed when the project was initiated, and were consulted, periodically during the conceptual design, detailed design,, and.

procurement phases. Other sections of the Design Criteria (1.1.1, 1.1.2, 1.2.2, 1.3.2, 3.0, 4.0, 7.1, 8.1, 8.2,,13.1 and 13.2) also emphasize the anticipated service of the new PORV block valves.

The RG&E Safety Analysis for this project (Revision 0, dated January 22, 19861 specifically considers decreases in reactor coolant inventory, including inadvertent opening of a PORV. The Design Criteria document discussed above is specifically referenced in the Safety Analysis. The Design Criteria and the Safety Analysis constitute the project design input and address valve operability.

In the Design Criteria and Safety Analysis for this modification, RG&E did consider valve and operator operability requirements, and did reference NUREG-0737; Item II.D.1, as well as the EPRI-Marshall tests (Report NP-2541-LD). However, . RG&E did not explicitly require that operability calculations supporting conformance to the EPRI-Marshall test results be generated.

RG&E did, however, explicitly address the subject of valve/operator qualification on the installation drawing for this modification.

This was done by requiring conformance with our MOVATS commitments.

RG&E considered that, based on extensive industry interaction with the NRC regarding the acceptability of MOVATS as commitment a means of defining acceptable valve/operator operability, our to

MOVATS superseded the commitment to NUREG-0737 as embodied by the EPRI-Marshall test results. (Note that Ginna-specific NRC acceptance for the use of MOVATS was provided by NRC correspondence, Carl H. Berlinger to William F. Kane, dated March 22, 1989.)

The omission of calculations demonstrating conformance to the EPRI-Marshall test results, using what RGEE considered to be an acceptable (and superior), alternative means of defining acceptable valve/operator operability, is considered the reason for the violation.

Corrective Ste s Taken and Results Achieved Corrective steps taken to resolve the issues involved in the notice of violation have consisted of assembling existing information and per forming conf irmatory additional, analvses tn demonst at th t operability of the replacement PORV block valves is assured,. This information was transmitted to the NRC by letter, dated May 3, 1989.

Satisfactory results have been achieved. By letter dated May 18, 1989, the NRC Region I staff found the additional information to be comprehensive and responsive to their concerns .regarding operability of the subject valves. No changes to the valve/operator were required as a result of this additional verzf ication.

Corrective Ste s to Avoid Future Violations All references in Design Criteria documents which contain licensing commitments will be explicitly evaluated and justification for differences, such as superseding requirements, will be placed in the modification work package. This will be accomplished revision of Procedure QE-301, "Preparation, Review and Approval by of Design Input Documents".

Date When Full Com liance Will Be Achieved August 15, 1989.

ggcELERATED DISSIBUTl05 DEMOBSTRAT105 SYFI FM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8907240194 DOC.DATE: 89/07/12 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas 6 Electric Corp.

RECIP.NAME 'ECIPIENTOfc', AFFILIATION MARTIN,T.T. - Region 1, of the Director

SUBJECT:

Responds to NRC 890428 ltr re violations noted in Insp Rept

/

50-244 89-04.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General E (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License 'Exp date in accordanc'e with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 PD 1 1 JOHNSON,A 1 1 INTERNAL: AEOD 1 1 AEOD/DE I IB 1 1

1 1

AEOD/TPAD 1 1 DEDRO NRR SHANKMAN,S 1 1 NRR/DEST DIR 1 1-NRR/DLPQ/PEB 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB, 10 2 2 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE IEBERMAN,J 1 OGC/HDS2. 1 1

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~RG FILE 02 01 1

1

. 1 1

RES MORISSEAU,D 1 1 EXTERNAL:, LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOXK 'IQ ALL RZDS" REXXPZZÃIS'l PXZASE HELP US 1X) REMCE HASTE! CXMlRCT ~ IXXXIMEÃZCONZK)L DESK, LTSTS H3R DOCUMEMZS YOU IXN~T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23

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ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649-0001 TCLCPiiONC A%CA CODC 7le 546.2700 July 12, 1989 U.S. Nuclear Regulatory Commission Region I Attn: Thomas T. Martin, Director Division of Reactor Safety 475 Allendale Road King of Prussia, PA 19406

Subject:

Inspection Report 50-244/89-04 and Notice of Violation (PORV Block Valve Replacement)

R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Martin:

By letter dated April 28, 1989, the NRC provided RG&E with the results of Inspection No. 50-244/89-04. Appendix A that letter consisted of a Notice of Violation related to

'o the extent of documentation addressing operability qualification of replacement PORV block valves. RG&E was requested to respond, within 30 days, and provide a written statement or explanation in reply to the Notice, including (1) the reasons for the violation, (2) corrective steps which have been taken and the results achieved, ('3) corrective steps which will be taken to avoid further violations, and (4) the date the full compliance will be achieved. The Notice further stated that, where good cause is shown, consideration would be given to extending the response time.

Pertinent information regarding additional documentation supporting operability qualification of the replacement PORV block valves, as requested by the NRC inspector, was submitted on May 3, 1989. This was found to be acceptable, a's stated in the NRC response, dated May 18, 1989. Since key RG&E personnel were fully engaged in completing the Spring 1989 Refueling Outage and its associated modification activities, and since the technical issues concerning the valves had been resolved, RG&E requested, by letter dated May 26, 1989, that an additional 45 days be allowed for our formal response to the Inspection Report and Notice of Violation.

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In accordance with 10 CFR 2.201, RG&E provides Attachment I to this letter as our reply to the Notice of Violation contained in Appendix A to NRC Inspection Report 50-244/89-

04. The reply admits the violation and provides the explanatory information requested in the Notice of Violation.

Very truly yours, Robert C. Mecr dy General Manager Nuclear Production JCM~054 Attachment xc: U.S. Nuclear Regulatory Commission (original)

Document Control Desk Washington, D.C. 20555 Allen R. Johnson (Mail Stop 14D1)

Project Directorate I-3 Washington, D.C. 20555 Ginna Senior Resident Inspector

ATTACHMENT I Violation NRC Inspection Report No. 50-244/89-04, Appendix A, identified the following violation:

"10 CFR 50, Appendix B, Criterion III requires that measures be established to assure that applicable regulatory requirements...are correctly translated into specifications, drawings, procedures and instructions." It further requires that, "design changes, including field changes shall be subject to design control measures commensurate with the original design."

"Contrary to the above, the licensee's Design Criteria and Safety Analysis for 0he PORV block valve replacement to be performed during the 1989 refueling outage did not address operability qualification of the replacement valves.

Operability qualification of PORV block valves was a NUREG-0737 Item (II.D.1) committed to by the licensee as confirmed in Commission Order dated July 10, 1981."

RG&E admits to the violation.

Reason for Violation The PORV Block Valve Replacement project Design Criteria document (Revision 0, dated January 22, 1986) sets forth the requirements for operability qualification. It references NUREG-0737,Section II.D.1, EPRI report NP-2541-LD, "EPRI/Marshall Electric Motor-Operated Valve (Block Valve) Interim Test Data Report" and NRC IE Bulletins 81-02 and 85-03. These referenced documents were reviewed when the project was initiated, and were consulted periodically during the conceptual design, detailed design, and procurement phases. Other sections of the Design Criteria (1.1.1, 1.1.2, 1.2.2, 1.3.2, 3.0, 4.0, 7.1, 8.1, 8.2, 13.1 and 13.2) also emphasize the anticipated service of the new PORV block valves.

The RG&E Safety Analysis for this project (Revision 0, dated January 22, 1986) specifically considers decreases in reactor coolant inventory, including inadvertent opening of a PORV. The Design Criteria document discu'ssed above is specifically referenced in the Safety Analysis. The Design Criteria and the Safety Analysis constitute the project design input and address valve operability.

In the Design Criteria and Safety Analysis for this modification, RG&E did consider valve and operator operability requirements, and did reference NUREG-0737, Item II.D.1, as well as the EPRI-Marshall tests (Report NP-2541-LD). However, RG&E did not explicitly require that operability calculations supporting conformance to the EPRI-Marshall test results be generated.

RG&E did,-however, explicitly address the subject of valve/operator.

qualification on the installation drawing for this modification.

This was done by requiring conformance with our MOVATS commitments.

RG&E considered that, based on extensive industry interaction with the NRC regarding the acceptability of MOVATS as a means of defining acceptable valve/operator operability, our commitment to

MOVATS superseded the commitment to NUREG-0737 as embodied by the EPRI-Marshall test results. (Note that Ginna-specific NRC acceptance for the use of MOVATS was provided by NRC correspondence, Carl H. Berlinger to William F. Kane, dated March 22, 1989.)

The omission of calculations demonstrating conformance to the EPRI-Marshall test results, using what RG&E considered to be an acceptable (and superior) alternative means of defining acceptable valve/operator operability, is considered the reason for the violation.

Corrective Ste s Taken and Results Achieved, Corrective steps taken to resolve the issues involved in the notice of violation have consisted of assembling existing information and performing confirmatory additional analyses to demonstrate that operability of the replacement PORV block valves is assured. This information was transmitted to the NRC by letter, dated May 3, 1989.

Satisfactory results have been achieved. By letter dated May 18, 1989, the NRC Region I staff found the additional information to be comprehensive and responsive to their conceins regarding operability of the subject valves. No changes to the valve/operator were required as a result of this additional verification.

Corrective Ste s to Avoid Future Violations All references in Design Criteria documents which contain licensing commitments will be explicitly evaluated and justification for differences, such as superseding requirements, will be placed in the modification work package. This will be accomplished by revision of Procedure QE-301, "Preparation, Review and Approval of Design Input Documents".

Date When Full Com liance Will Be Achieved.

August 15, 1989.