ML17251A122

Responds to NRC Re Violations Noted in Insp Rept 50-244/88-05.Util Corporate Mgt Shares Concern & Will Increase Emphasis in Reaching Resolution

ML17251A122
Person / Time
Site:	Ginna
Issue date:	06/06/1988
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8806130301
Download: ML17251A122 (30)

Text

A,CCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

.I-ESSION NBR:8806130301 DOC.DATE: 88/06/06 NOTARIZED: NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G

AUTH.NAME AUTHOR AFFILIATION KOBER,R.W.

Rochester Gas

& Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION RUSSELL,W.T.

Region 1, Ofc of the Director DOCKET 05000244

SUBJECT:

Responds to NRC 880503 ltr re violations noted in Insp Rept 50-244/88-05.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72)

D 05000244 S

RECIPIENT ID CODE/NAME PD1-3 PD INTERNAL: AEOD NRR MORISSEAUgD 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

1 RECIPIENT ID CODE/NAME STAHLE,C DEDRO NRR/DLPQ/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 OE IEB N,J G

02 RGN1 FILE 01 NRC PDR COPIES LTTR ENCL 2

2 1

1 1

1 1

1 2

2 1

1 1

1 1

1 1

1 1

1 A

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 23 ENCL 23

i

ROCHESTER GAS AND ELECTRIC CORPORATION

~ 89 EAST AVENUE, ROCHESTER.

N. Y'.

June 06, 1988 Mr. William T. Russell, Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

Subject:

Inspection Report 50-244/88-05 Notice of Violation R.E.

Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

Your letter of May 3, 1988 from Mr.

Lee H.

Bettenhausen regarding Inspecti on Report 50-244/88-05 transmi tted the Notice of Violati on, Appendix A,

vhich involved the installation of manvays on the B

Steam Generator.

You stated your concerns regarding the QA/QC area and the continuing shortcomings in our performance in this area.

Rochester Gas and Electric (RG6E)

Corporate management shares your concern and vill increase emphasis in reaching resolution.

The QA/QC Subcommittee vas formed as a result of the Systematic Assessment Licensee Performance (SALP) Report of 1985

and, ve beli eve, has produced significant progress in timely resoluti on to specific problems identified in audi ts and other corrective action processes.

However, there continue to be some lapses in performance.

To address this issue ve will perform a

self assessment, considering basic issues such as organization, reporting structure, QA program philosophy and its implementation.

Any changes identified in this self assessment would be in place by the end of 1988.

The response to the specific violation follows.

3306130301 330606 PDR ADOCK 05000244 0

DCD zoo(

Page 2

Inspection Report 50-244/88-05 tune 06, 1988 Routine 1'nspecti on Report 50-244/88-05, Appendix A, stated in part:

"During the inspection conducted on March 7

April 5,

1988, and in accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions 10 CFR Part 2, Appendix C

(Enforcement Poli cy 1986),

the following violation was identi fied:

Techni cal Specification

6. 8. 1 requires written procedures shal l be establi shed, implemented, and maintained covering activities referenced in Appendix A of Regulatory Guide 1.33,

November, 1.972.

Appendix A, Paragraph I addresses the control of Maintenance.

The Licensee 's Maintenance Procedure M-43. 15. 2, "Install-ation of B

Steam Generator Hot/Cold Leg Primary Manway Covers Utilizing Hydraulic Stud Tensi oner",

requi res, in part, all studs be verified to have exhibited an elongation of 0.0075

+.001 inch (Step 5.21.23),

otherwise, the manway cover tensioning process (Steps 5.21, through 5.21.22) must be repeated.

Contrary to the above, on March 20,

1988, the criterion for manway stud elongation was not met for all studs and although Step

5. 21. 23 was not completed for both covers; remaining steps of the procedure were completed and signed, including:

5.29, Quali ty Control verify that manway installation is complete.

5.30, Notify Control Room that "B"

steam generator hot/cold leg manway installation is complete.

This improper action resulted in the plant being required to

'ool down and retension the bolts on the manway covers."

RG&E agrees with the above violation in that Technical Specification 6.8.1 states that written procedures shall be estab-lished, implemented, and maintained governing activities referenced in Appendix A of Regulatory Guide

1. 33,

November, 1,972.

Steam generator manway instal lati on is considered a

QA activity and thus'nstallation in accordance with the procedure is required.

i

Page 3

Inspection Report 50-244/88-05 t'une 06, 2.988 RGBE concurs wi th the Inspection Report that maintenance personnel di d not comply wi th Procedure M-43. 25. 2, Step

5. 2Z. 23 by not repeating the tensioning process from Step 5.22 through Step

5. 2Z.22.

Our investigation into the root cause is still in progress;

however, based on the results to date we do not believe that lack of cooperation and communication is a root cause.

The root cause analysis which is being performed is evaluating the following criteria:

2 ~

3.

4 ~

5.

6.

7.

8.

9.

History Procedures Communications Human performance Training Administration Immediate supervision Quality Control participation Equipment (Micrometers, ultrasoni c bolt gape)

The status of these areas is presented below.

~Histo Procedure M-43. 25.2 had been utilized for manway stud tensioning eight (8) times prior to the reported incident.

As demonstrated by the attached elongation plots, in each of the previous instal lations there were studs out of the specified tolerance on the high side.

In each

case, a Non-Conformance Report (NCR) was initia ted by QC and in each instance after the Res ponsi ble Engi neer compl e ted hi s cal culati ons, the discrepant stud elongati ons were disposi-tioned "Use As Is ".

In some previous install ati ons, two measurements were taken with micrometer readings being used as verification readings.

On March 20, 2,988, due to a

failure of the ultrasonic bolt measurement

gage, micrometers were used to perform the only measurements.

Procedures An analysis of the procedure reveals that the procedure was technically adequate only for installation and tensioning of the manway studs.

However, subsequent to the reported incident, it has been determined that the procedure is not adequate for re-tensi oni ng.

The procedure is feasi hie only when stud elongati ons are found less than the specified acceptance criteria.

Page 4

Inspection Report 50-244/88-05 t'une 06, 2988 In cases where any of the studs are elongated over the specified

range, re-tensi oni ng coul d resul t in incomplete flexatallic gasket sealing due to possible gasket crush.

Communi cati ons The QC Inspector notified the Fiel d Foreman of discrepant elongati ons on the job site.

Steam Generator Maintenance Supervision and QC Supervision were not notified of the discrepant elongations until both manways were tensioned and the personnel were out of containment.

The QC Inspectors discussed the discrepant elongation measurements with Steam Generator Maintenance Supervision after exiting containment.

The Plant Superintendent'was notified by the QC Engineer the following morning.

Human Performance An assessment of human performance is in progress.

However, discussion to date with participating QC and Maintenance personnel revealed that:

a.

Maintenance personnel beli eved that the one unusually high and one unusually low elongati on measurement on each manway were due to incorrect initial micrometer readings by QC personnel This was based on:

(l) previous experience using the tensioning equipment, (2) numerous mockup training applications, and (3) the use of a micrometer to perform the measurements.

b.

Maintenance personnel, believing in the reliability of their tensioning equipment and procedure, and conditioned by previous NCR "Use As Is" dispositions, concl uded that these out of specification elongations would be dispositioned "Use As Is" and consequently continued on with the procedure.

Co QC inspectors notified the QC Night Shift Inspector when he arrived for the shift

change, of the out of tolerance

readings, after t'e job was compl eted, and signed off the procedure that the manway installation was completed but would not sign the acceptance of the readings (Step 5. 22,. 23).

Cl

Page 5

Inspection Report 50-244/88-05 tune 06, 2988 d.

e.

QC Inspectors di d not realize the significance of the two extreme out of tolerance stud measurements on each manway with respect to plant operations and, therefore, did not request a

QC Engineer to exercise a stop work au thori ty and did not consul t with the QC Engineer until the following day.

Maintenance personnel di d not have a

copy of the procedure in the immediate area (on the steam generator manway platform) and were not checking off steps upon completi on as required by Plan t Administra tive proce-dures.

Steam Generator Maintenance Supervision, also conditioned by previous acceptable NCR disposi tions and disbeli ef of the accuracy of the out of tolerance measurements, di d not contact hi s management or the Responsi ble

Engineer, but notified Operations to proceed with RCS filland vent.

~Trai nin Steam Generator Maintenance personnel were well trained in operation of the hydraulic stud tensioning equipment from numerous appli cati ons on the mockup and previous actual applications during I987 and 1988 AI'BO outages.

The onsite QC Inspectors received refresher training in micrometer use from the Q.C. Engineer that day.

Administration Administrative controls were in place for controlling manway stud installati on and tensioning.

(2)

A Plant Operations Review Committee (PORC) approved procedure was available for use.

(2) Administrative procedures requiring implementation of the Maintenance procedure exist.

(3)

QC surveillance and a

QC hold point (for measurement of elongation) was required by procedure to provide acceptance verificati on.

(4)

A Field Foreman was on the job, and a Steam Generator Supervisor was onsi te to resol ve install ation probl ems, and (5) a nonconformance reporting process to disposition any discrep-ancies found while performing the work activity exists.

Page 6

Inspection Report 50-244/88-05 June 06, 1988 Immediate Su rvision Normal steam generator field supervision for the tensioning activity was involved in performing the tensioning procedure.

Normal steam generator supervision was onsi te coordinating the activity.

Thus, participating plant personnel were exper-ienced and qualified for performing the manway instal la-tion and tensioning process.

ualit Control Parti ci ation QC Inspectors monitored the entire installation procedure and performed the elongation measurements.

They reported the discrepancies to the Steam Generator Field Foreman, and later to the Steam Generator Maintenance Supervisor who did not direct re-tensioning.

E i ment The hydraulic stud tensioning equipment performed as designed.

No oil leaks or other component deficiencies coul d be identified which might account for the extreme stud elongati on discrepancies.

The failure of the ultrasonic bolt measurement gage is seen as contributing to a lack of confidence in the elongati on measurements and resul ted in only a

si ngle measurement of stud elongation.

In summary, RG&E's root cause analysis to date suggests that the installation procedure was not adhered to due to (1) confidence in the equipment and training, (2) a lack of confidence in QC measurements, and (3) an anticipated NCR "Use As Is" disposition.

This evaluation is still in progress.

The cause of discrepant readings has not been pi npoi nted.

One possible cause of t'e extremely low reading may be failure to seat the gear nut properly while tension was being applied.

Possi ble causes of high readings would be higher than standard torque of 120 foot pounds applied to the gear nut during seating or inherent realignment of manway tension due to gasket creep resulting from a lower than normal seating torque on a nearby stud.

Page 7

Inspection Report 50-244/88-05 June 06, 1988 Corrective action taken as specified by the disposition of NCR G-88-224 initiated by QC on March 20, 1988, included draining the RCS and establi shi ng conditions for steam generator manway removal.

The "B" steam generator hot and cold leg manway covers were removed in accordance with procedure M-43.2,.2, "Removal of Steam Generator Leg Primary Manway Cover Utilizing Hydraulic Stud Tensi oner".

The "B" steam generator hot and cold leg inserts were removed using procedure M-43. 2.. 1, "Steam Generator I'nsert Removal B

Steam Generator".

New insert gaskets were installed and inserts were reinstalled using procedure M-43.15, "Installation of Steam Generator Manway Inserts B

Steam Generator".

The manways were then reinstalled using procedure M-43.15.2, "Installa-tion of B

Steam Generator Hot/Cold Leg Primary Manway Cover Utilizing Hydraulic Stud Tensi oner".

Again, the elongation for four (4) studs were slightly out of specifications on the high side.

NCR G-88-231 was initiated and dispositioned "Use As Is" after completion of calculations by the Responsible Engineer.

Correcti ve action to prevent recurrence of this event will include:

a.

Revising procedure M-43.15.2 to assure that elongation measurements found out of tolerance will be evaluated and dispositioned prior to any further work activity.

b.

Emphasize more strongly the requirements of procedure adherence during the Steam Generator Crew Leader Training.

c Evaluate with the tensioner on the mockup to determine if seating torque values are adequate and/or critical.

Determine if gear nut surface inspections and manway cover surface inspections are necessary and/or critical.

d.

Incorporate the resul ts of these evaluati ons into the tensioning procedure, as appli cable.

Full compli ance with these corrective actions will be compl etc prior to the next installation of a steam generator manway.

Page 8

Inspection Report 50-244/88-05 June 06, 2988 Additional corrective action includes:

a 0 Completing the evaluati on of human performance and identify and implement corrective actions.

We will provide a report on this evaluation by September l, 2,988.

b.

Performing the self assessment discussed in the intro-duction to this letter and any changes identified will be completed by t'e end of l988.

Ve truly yours, n~ u Roger W. Kober xc:

U.S. Nuclear Regulatory Commission (Original)

Document Control Desk Washi ngton, DC 20555 C. Marshall, Ginna Resident Inspector at tachments

>>A>> S/g Cold Leg 3/01/87 Dial Indication Tension Pressure 12,000 PSI

• possible high spot on surface Dispose tconed "Usa Ao lo" ACR G-i7-106

. 0125

. 0120

.0115

~ OLIO

.0105

.0100

.0095

.0090 ~

.0085

~~

.0080 Q

~ 0075

.0070

~ 0065

~ 0060 MMW'WWM MMM 'WMMMMMMMMMMMWMMM I

acceptable range 01 02 03 04 05 06 07 08 09 LO LL 12 13 14 15 L6 Bolt

>>A>> S/6 Hot Leg 3/01/87 Dial Indication Tension Pressure 12,000 PSI Dispositioned>>Uhe As la>> NCR G-87-10b

.0115

.0110

.0115

.0105

.0100 8

'.0095

- 0090

.0085

~ 0080 w.0075

~ 0070

~ 0065

~ 0060 I

I I

I I

I WW'WMWMWW&MWMMW 'W W'\\ MW MWMWMMWMMW WMWM'W W MMM I

I I

WMWWMMW&

acceptable range 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 Bolt

"B'/G Cold Leg 3/02/87 Dial Indication Tension Pressure 12,OOO PSI

. 0125

. 0120

. 0115

. 0110

.0105

.0100

.0095

.0090

.0085

.0080

.0075

.0070

.0065

.0060

'W MMMM 'WMMMWMMWMMWW I

acceptable range 01 02 03 04 05 06 07 08 09 10 ll 12 13 14 15 16 Bolt "B" S/G Hot Leg 3/02/87 Dial Indication Tension Pressure 12,000 PSZ Diapaoi tioned "(Pe, As lo" MCR G-87-106

. 0115

.0110

.0115

.0105

.0100

.0095

.0090

.0085 w~

~ 0080

. 0075

~ 0070

. 0065

.0060 I

1 I

I I

l t mmmm' I

l WMMWMW MWWMMMMWMWMMWMWMMWMMW t

acceptabl e range 01 02 03 04 05 06 07 08 09 10 ll 12 13 14 15 16 Bolt g

. 0125

. 0120

. 0115

. 0110

. 0105

.0100

.0095

.0090

. 0085 cn

.0080

~ 0075

.0070

~ 0065

.0060 I

I I

I I

I I

I I

I I

I I

I I

<<A>> Sgg Cold Leg

>~/.g/88 Tension Pressure 12,000 PSI manual micrometer and g ultrasonic readi ngs Diopooi tconad "Uoe, Ao lh<<WCR G-88-147 cce ptabl e range 01 02 03 04 05 06 07 08 09 10 Ll 12 13 14 15 16 Bolt

>>A>> S/G Bot Leg 02/33/88 Tension Pressure 12,000 PSI manual micrometer and g, ultrasonic readings Dihpooc.tioned

<<Uoe, Ah Io" NCR G-88-14T

~ 0115

.0110

. 0115

.OL05

.0100

.0095

.0090

.0085 ~

.0080 F 00?5

~ 0070

. 0065

~ 0060 MWWMM etMWmW I

acceptable range Ol 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 Bolt

B>> S/G Cold Leg J2/24/88 Tensi on Pressure 11,500 PSI

. 0125

. 0120

.0115

~ 0110 F 0105

.0100

.0095

.0090

.0085

.0080

~ 0075

. 0070

.0065

~ 0060 I

I I

I I

I I

I I

I w&'w M W I

I I

manual micrometer and g ultrasonic readi ngs Oiopooc,tioned "Use, Ao lo" ACR G-88-147 cceptable r

e 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 Bolt "B>> S/G Hot Leg 02/24/88 Tension Pressure 11,500 PSI

. 0115

~ 0110

.0115

.0105

.0100

.0095

.0090

.0085 0080 5

.0075 w~

. 0070

. 0065

.0060 I

I I

~ manual micrometer and g ultrasonic readings Diopooiti oned "Use. Ao lo" NCR G-88-147 MWMMMWWMMMWWMMWMMWMWMWMWWMWW I

acceptable range 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 Bolt g

'B>> S/G Cold Leg

.0130

.0125

.0120

.0115

.OLLO

.0105

.0100

.0095

.0090

.0085

.0080

.0075

.0070

.0065

.0060

.0055

.0050

.0045

.0040

.0035

. 0030

. 0025 I

I I

I I

I I

I I

I cr)

)

I I

I I

I I

I I

I Manual Micrometer f3/22/88)

(3/20/88) ceptable nge 01 02 03 04 05 06 07 08 09 10 11 L2 13 14 15 16 BoLC 8

- 3/20/SS - Diepoeitconed "Reuoch" M.'R G-8S-224 x - 3/22/SS - Dispositioned "Lha As lh" ACR G-88-23l

"B S/G Pot Leg

.0100

.0095

.0090

.0085

~.0080

~.0075 0070 w

~. 0065

~.0060 w. 0055

.0050

.0045

.0040

.0035 Manual Micrometer (3/22/88)

(3/20 /88) acceptable range 01 02 03 04 05 06 07 08 09 10 ll 12 13 14 15 16 Bolt 3/20/88 - Dihpoe~ti oned "Rein%" NCR G-88-224 x - 3/22/88 - 04poo~tioned "Use, Ao Io" NCR G-88-23J

I