ML17251A182
| ML17251A182 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/27/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Snow B ROCHESTER GAS & ELECTRIC CORP. |
| Shared Package | |
| ML17251A184 | List: |
| References | |
| EA-88-154, NUDOCS 8808030384 | |
| Download: ML17251A182 (10) | |
See also: IR 05000244/1988010
Text
ACCELERATED
DISI'RIBUTJON
DEMONSTRATION
SYSTEM
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8808030384
DOC.DATE: 88/07/27
NOTARIZED: NO
DOCKET
g
FACIL:50-244 Robert
Emmet Ginna Nuclear Plant, Unit 1, Rochester
G
05000244
AUTH.NAME
AUTHOR AFFILIATION
RUSSELL,W.T.
Region 1, Ofc of the Director
RECIP.NAME
RECIPIENT AFFILIATION
SNOW,B.A.
Rochester
Gas
& Electric Corp.
SUBJECT: Discusses
Insp Rept 50-244/88-10
on 880516-20
& forwards
& proposed imposition of civil penalty.
DISTRIBUTION CODE:
IE14D
COPIES
RECEIVED:LTR I
ENCL J
SIZE:
3
'ITLE:
Enforcement Action Non-2.790-Licensee
Response
NOTES:License
Exp date in accordance
with 10CFR2,2.109(9/19/72).
05000244 '~
RECIPIENT
ID CODE/NAME
PDl-3 LA
STAHLE,C
RGN1
RNAL: LPDR
INTERNAL: AEOD/DOA
DEDRO
NRR/DREP/EPB
10
NUDOCS-ABSTRACT
OE LIEBERMAN,J
FILE
03
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
RECIPIENT
ID CODE/NAME
PD1-3
AEOD/DSP/TPAB
NRR/DOEA/EAB 11
NRR/PMAS/ILRB12
OE FILE
01
RK~ggg~
02
RGN2/DRSS/EPRPB
NRC PDR
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
- D
D
I
D
S
A
TOTAL NUMBER'F COPIES
REQUIRED:
LTTR
18
ENCL
18
July 27,
1988
Docket No.
50-244
License
No.
EA 88-154
Rochester
Gas
and Electric Corporation
ATTN:
Hr. Bruce A.
Snow
Superintendent
Nuclear Production
49 East Avenue
Rochester,
14649
Gentlemen:
Subject:
NOTICE OF VIOLATION AND PROPOSED
IMPOSITION OF CIVIL PENALTY
(NRC Inspection
Report
No. 50-244/88-10)
This refers to the
NRC inspection
conducted
on
May 16-20,
1988 at the Robert
E.
Ginna nuclear
power plant, Ontario,
The inspection report was sent
to you on June
10,
1988.
During the inspection,
two vi'olations of NRC
requirements
were identified.
On June
24,
1988,
an enforcement
conference
was
conducted with you and members of your staff to discuss
the violations, their
causes,
and your corrective action.
The violations, which are described
in the enclosed
Proposed
Imposition of Civil Penalty,
involved (1) the failure to perform
Inservice Testing (IST), as required, of four check valves designed
to mitigate
the consequence
of an accident;
and.(2)
the failure to perform
a full-stroke
exercise
as part of the test of thirteen other check valves in other safety
related
systems
designed to mitigate the consequence
of an accident
Mith respect
to the first violation, the
NRC is concerned that two valves in
the
steam
s'upply line for the turbine driven auxiliary feedwater
pump,
as well
as two main feedwater line check valves,
were not included
on your list of
valves
and
pumps requiring Inservice Testing.
Apparently, the functions of
these
valves were not adequately
understood
by engineering
personnel
when this
list was compiled.
When these
four valves were subsequently
tested
following
NRC identification of this violation, one of the valves in the
steam
supply
line did not function as required.
Specifically, the valve was binding in
that the disc would remain in the position to which it was forced when
operating
the counter weight arm.
As a result, if the turbine driven Auxiliary
Feed Mater (AFM) pump is assumed
to be operating
in conjunction with a main
steam line break,
some of the
steam
from the intact steam generator
would be
diverted from the auxiliary feedwater
pump to the break.
Furthermore,
as described
in Violation B in the enclosed
Notice, several
other
check valves in safety related
systems,
although included
on the list of
valves requiring Inservice Testing,
were not properly tested
in that the valves
were not full-stroke exercised,
as required.
Apparently, engineering
personnel
380 030384
880727
ADOCK 05000244
0
OFFICIAL RECORD
COPY
PKG GINNA 7/22 - 0001.0.0 ~(
07/25/88
'
Rochester
Gas
and Electric Corporation
did not fully understand
the
ASNE requirements
for full-stroke testing of the
As a result, test procedures
were deficient,
and personnel
performing these tests
were
unaware of these deficiencies.
The
NRC recognizes
that the
IST program at Ginna
has generally
been well
managed,
as indicated in the surveillance
section of the revised Systematic
Assessment
of Licensee
Performance
(SALP) report sent to you on Hay 12;
1988.
Furthermore
the
IST problems identified during this inspection did not involve
any pumps,
nor did they involve any valves other than check valves.
Never-
theless,
the importance of assuring operability of check valves through proper
testing
was communicated
to all licensees
in
NRC Information Notice No. 86-01,
issued
on January
6,
1986,
as well as
INPO Significant Operating
Experience
Report
(SOER)
No. 86-03,
issued
on October
15,
1986,
as
a result of check valve
failures at
San Onofre in .November
1985 that resulted in a significant opera-
tional event at that facility.
However,
adequate
action was not taken
by
RGEE
at that time to determine
whether
any check valves deficiencies existed at
Ginna.
These violations demonstrate
the need for (1) better understanding
by
engineering
personnel
of the
IST program
and its related requirements,
including
thorough understanding'of
ASIDE Code requirements,
and (2) prompt and responsive
actions
upon issuance
of NRC or
INPO notifications to ensure potential
safety
issues
are promptly and effectively resolved.
To emphasize
these
needs,
I have
been authorized,
after consultation with the Director, Office of Enforcement,
and the Deputy Executive Director for Regional Operations,
to issue the enclosed
Notice of Violation and Proposed
Imposition of Civil Penalty in the amount of
Fifty Thousand Dollars ($50,000) for the violations described
in the enclosed
Notice.
In accordance
with the "General
Statement
of Policy and Procedure for
NRC Enforcement Actions,"
10 CFR Part 2, Appendix
C (1988) (Enforcement Policy),
the violations described
in the enclosed
Notice have
been categorized
in the
aggregate
as
a Severity Level III problem since they involved multiple examples
of inadequate
or insufficient tests of check valves.
The base
value of a civil penalty for a Severity Level III violation or problem
is $50,000.
A basis exists for 50% mitigation of the base penalty in view of
your prior good enforcement history in the area of surveillance testing,
as
evidenced
by a Category I SALP rating in this area during the last three rating
periods.
Full
100% mitigation based
on this factor is inappropriate
since the
root cause of the violation was inadequate
engineering
support,
which received
a Category II SALP rating during the last rating period, which was the first
period that engineering
support
was evaluated
as
a separate
area.
Furthermore,
a basis exi sts for 50% escalation
of the civil penalty in light of your prior
notice, via
and
SOER 86-03, of the
need
to adequately test operation of check valves.
Therefore,
on balance,
no
adjustment
to the civil penalty
amount is appropriate.
The other escalation
and mitigation factor in the enforcement policy were considered,
and
no
adjustment
based
on these other factors is considered
appropriate.
You are required to respond to this letter and should follow the instructions
specified in the enclosed
Notice when preparing
your response.
In your
OFFICIAL RECORD
COPY
PKG GINNA 7/22 " 0002.0.0
07/25/88
Rochester
Gas
and Electric Corporation
response,
you should document the specific actions
taken
and any additional
actions you plan to prevent recurrence.
After reviewing your response
to this
Notice, including your proposed corrective actions
and the results of future
inspections,
the
NRC will determine
whether further
NRC enforcement
action is
necessary
to ensure
compliance with NRC regulatory requirements.
In accordance
with Section
2.790 of the NRC's "Rules of Practice,"
Part 2,
Title 10,
Code of Federal
Regulations,
a copy of this letter and its enclosure
will be placed in the
NRC Public Document
Room.
The responses
directed
by this letter and the enclosed
Notice are not subject
to the clearance
procedures
of the Office of Management
and Budget as required
by the Paperwork
Reduction Act of 1980,
Pub.
L. No.96-511.
Sincerely,
Original Signed
Bp
NILLMN T. RUSSELL
William T. Russell
Regional Administrator
Enclosure:
Notice of Violation and Proposed
Imposition
of Civil Penalty
cc w/encl:
Harry H. Voigt, Esquire
Central
Records
(4 copies)
Director,
Power Division
State of New York, Department of Law
Public Document
Room (PDR)
Local Public Document
Room (LPDR)
Nuclear Safety Information Center
(NSIC)
NRC Resident
Inspector
State of New York
OFFICIAL RECORD
COPY
PKG GINNA 7/22 " 0003.0.0
07/25/88
'
Rochester
Gas
and Electric Corporation
bcc w/encl:
Region I Docket
Room (with concurrences)
Management Assistant,
DRMA (w/o encl)
DRP Section Chief
Robert J.
DRSS
SECY
J. Taylor,
DEDRO
J.
Lieberman,
J. Allan, RI
D. Holody,
RI
J. Goldberg,
Enforcement Directors, RII-III
Enforcement Officers,
RIV-V
T. Murley,
F.
Ingram,
J.
Bradburne,
CA
E. Jordan,
B. Hayes,
S. Connelly,
OIA
P.
Robinson,
R. Cunningham,
D.Nussbaumer,
OGP/SP
OE File (3 copies
= ltrhd)
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R. Benedict,
B. Clayton,
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