ML17251A094
| ML17251A094 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/18/1988 |
| From: | Snow B ROCHESTER GAS & ELECTRIC CORP. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8805250146 | |
| Download: ML17251A094 (14) | |
Text
OCHESTER GAS AND ELECTRIC CORPORATION
~
S9 EAST PVENl'C, ROCI E TER.
V Y May 18, 1988 Mr. William T. Russell Regional Administrator U. S. Nuclear Regulatory Commission Region I
475 Allendale Road King of Prussi a, PA,19406 Subjec t:
Inspection Report 50-244/88-04 Notice of Violation R.E.
Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Russell:
In accordance with NRC Inspection Report 88-04 which stated:
"As a result of the inspection conducted on February 22-26, 1'988, and in accordance with the "General Statement of Policy for NRC Enforcement Actions",
10 CFR 2, Appendix C, the fol lowing violation was identified.
10 CFR 50.55a(g) states that ASME Code Class I, Class 2,
and Class 3
components shal 1 meet the requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code and Addenda.
The facility inservice inspection program states that the facility will meet the requirements of Section XI, 1974 Edition through Summer 1975 Addenda with guidance form,Section XI, 1977
- Edition, Summer 1978 Addenda.
ASME Section XI, 1977
- Edition, Summer 1978 Addenda invokes ANSI N-.45. 2. 6, 1973 for the qualification of personnel performing the visual examination VT-2, VT-3, and VT-4 and states that the practical examination shall be performed using parts representative of the Owner's plant.
ANSI N-45.2.6, '973 s'tates that a file of records of personnel qualifications shal 1
be maintained, and shall contain records of pas t per formance his tory.
Contrary to the above:
During the period from February 22, 1988 to February 26,
- 1988, personnel qualification records of QC Personnel certified by the licensee to Level II VT-2, VT-3, and VT-4 visual inspection did not contain records of past performance history, and the practical examination was not performed using parts representative of the Owner's plant."
the fol lowing is provided in response.
During the conduct of the inspection, discussions with the inspector indicated that the ability and capability (qualifications) of the Quality Control inspectors certified to ASME Section XI, VT2, VT3, and VT4 were not in question and that no immediate corrective action steps were necessary.
This violation identifies two specif ic deficiencies in the qualification program for Quality Control inspectors to ASME Section XI
- VT2, VT3, and VT4 examination methods.
The first deficiency identifies the lack of sufficient detail in the qualification records for the inspectors qualified with respect to past performance history.
Quality Control inspectors qualified to VT2, VT3, and VT4 will have their qualification records updated to reflect the time spent in the performance of activities such as receipt inspection of pressure retaining components and piping support materials, inspections and surveillance of plant systems and components during maintenance and testing activities, and inspections and surveillance conducted during and following modification activities such as seismic upgrade and pre-service leakage examinations.
Documentation of this performance as additional basis for certification will be provided.
Administr a tive procedure A-1002, Gualification of Inspection Personnel, wilI be reviewed and revised as necessary to assure future Quality Control inspector's qualifications for visual. examination methods will be in accordance with the ASME Code,Section XI.
The second def iciency identifies the lack of a
practical examination which utilized parts representative of the plant during the Quality Control inspectors qualification training.
While a
review of other plant records indicated that plant specific components were utilized during the training
- program, a
practical examination utilizing these.
same parts was not administered as part of the qualification process.
The reason for, this violation is based on a difference in the interpretation of paragraph IWA-2300 of the ASME Section XI.
RG5E interprets the code to mean that subparagraph (c) of IWA-2300 applied
.to the qualification of personnel to VT2, VT3, and VT4 and therefore based their qualification on ANSI N-45 ~ 2 ~ 6 as
required by this subparagraph.
It should be noted that future editions of the ASIDE Code wil 1 be eliminating the visual examination method from the text and relying on ASNT-TC-1A for many
- reasons, not the least of which is the interpretation differences raised by paragraph IWA-2300.
- However, RG8<E intends to provide corrective action for this violation.
Practical visual examinations for VT2, VT3, and VT4 examination methods utilizing parts representative of the plant will be conducted for Quality Control inspectors qualified to VT2, VT3, and VT4.
Their qualification records will be updated to reflect this examination.
The date when ful 1 compliance wil 1 be achieved will be December 31, 1988 upon the completion of the ac tions described above.
Very truly yours, Bruce A.
Snow Superintenden t Nuclear Production xc:
U.S. Nuclear Regulatory Commission (Original )
Documen t Con tro 1 Desk Washington, DC 20555
AC CRIZRATED DISIMBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:8805250146 DOC.DATE: 88/05/18 NOTARIZED: NO DOCKET g
FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATION.
SNOW,B.A.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION RUSSELL,W.T.
Region 1, Ofc of the Director
SUBJECT:
,Responds to violations noted in Insp Rept 50-244/88-04.
DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR /
ENCL i SIZE: 3 TITLE: General (50 Dkt)-Insp Rept/Notice of VioTation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
I 05000244 RECIPIENT ID CODE/NAME PD1-3 PD INTERNAL: AEOD NRR MORISSEAU,D NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC 15-B-18 RES/DRPS DEPY RNAL: LPDR 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
RECIPIENT ID CODE/NAME STAHLE,C DEDRO NRR/DLPQ/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 0
BERMAN,J REG 02 G
1 FILE 01 NRC PDR COPIES LTTR ENCL 2
1 1
1 1
1 1
2 2
1 1
1 1
1 1
1 1
1 1
A Sj A
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 23 ENCL 23
ROCHESTER GAS AND ELECTRIC CORPORATION
~ 89 EAST AVENUE, ROCHESTER, N.Y.
14649-000'C'LC>~044'~cicosc,sc 5 "6 2700 May 18, 1988 Mr. Mi 1 liam T. Russell Regional Administrator U.S. Nuclear Regulatory Commission Region I
475 Allendale Road King of Prussia, PA 19406
Subject:
Inspection Report 50-244/88-04 Notice of Violation R.E.
Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Russell:
In accordance with NRC Inspection Report 88-04 which stated:
"As a result of the inspection conducted on February 22-26,
- 1988, and in accordance with the "General Statement of Policy for NRC Enforcement Actions",
the fol lowing violation was identified.
10 CFR 50.55a(g) states that ASME Code Class 1, Class 2,
and Class 3
components shall meet the requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code and Addenda.
The facility inservice inspection program states that the facility wil 1 meet the requirements of Section XI, 1974 Edition through Summer 1975 Addenda with guidance form Section XI, 1977
- Edition, Summer 1978 Addenda.
ASME Section XI, 1977
- Edition, Summer 1978 Addenda invokes ANSI N-45.2.6, 1973 for the qualification of personnel performing the
'isual examination VT-2, VT-3, and VT-4 and states that the practical examination shall be performed using parts representative of the Owner's plant.
ANSI N-45.2.6, 1973 states that a file of records of personnel qualifications shall be maintained, and shall contain records of past performance history.
8805250146 880518 PDR ADOCK 05000244 0
Contrary to the above:
During the period from February 22, 1988 to February 26,
- 1988, personnel qua 1ification records of QC Personnel certified by the licensee to Level II VT-2, VT-3, and VT-4 visual inspection did not contain records of past performance history, and the practical examination was not performed using parts representative of the Owner',s plant."
the fol Iowing is provided in response.
During the conduct of the inspection, discussions with the inspector indicated that the ability and capability (qualifications) of the Quality Control inspectors certified to ASME Section XI, VT2, VT3, and VT4 were not in question and that no immediate corrective action steps were necessary.
This v'iolation identifies two specif ic deficiencies in the qualification program for Quality Control inspectors to ASME Section XI
- VT2, VT3, and VT4 examination methods.
The first deficiency identifies the lack of sufficient detail in the qualification records for the inspectors qualified with respect to past performance history.
Quality Control inspectors qualified to VT2, VT3, and VT4 will have their qualification records updated to reflect the time spent in the performance of activities such as receipt inspection of pressure retaining components and piping support materials, inspections and surveillance of plant systems and components during maintenance and testing activities, and inspections and surveillance conducted during and following modification activities such as seismic upgrade and pre-service leakage examinations.
Documentation of this performance as additional basis for certification will be provided.
Administrative procedure A-1002, Qualification of Inspection Personnel, will be reviewed and revised as necessary to assure future Quality Control inspector's qualifications for visual examination methods will be in accordance with the ASME Code,Section XI.
The second deficiency identifies the lack of a
practical examination which utilized parts representative of the plant during the Quality Control inspectors qualification training.
While a
review of other plant records indicated that plant specific components were utilized during the training
- program, a
practical examination utilizing these same parts was not administered as part of the qualification process.
The reason for this violation is based on a difference in the interpretation of paragraph IWA-2300 of the ASME Section XI.
RG&E interprets the code to mean that subparagraph (c) of IWA-2300 applied to the qualification of personnel to VT2, VT3, and VT4 and therefore based their qualification on ANSI N-45 ~ 2.6 as
it
required by this subparagraph.
It should be noted that future editions of the ASNE Code will be eliminating the visual examination method from the text and relying on ASNT-TC-1A for many
- reasons, not the least of which is the interpretation differences raised by paragraph IWA-2300.
- However, RB8<E intends to provide corrective action for this violation.
Practical visual examinations for VT2, VT3, and VT4 examination methods utilizing parts representative of the plant will be conducted for Quality Control inspectors qualified to VT2, VT3, and VT4.
Their qualification records will be updated to reflect this examination.
The date when full compliance wilI be achieved will be December 31, 1988 upon the completion of the actions described above.
Very truly yours, Bruce A. Snow Superintendent Nuclear Production xc:
U. S. Nuclear Regulatory Commission (Original )
~
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Document Control Desk Washington, DC 20555
F 1