ML17261A771

Responds to Violations Noted in Insp Rept 50-244/87-23. Corrective Actions:Nonconformance Repts Being Utilized to Document & Disposition DC Anomalies Not Addressed in Design Analysis to Assure Future Deficiencies Promptly Identified

ML17261A771
Person / Time
Site:	Ginna
Issue date:	01/15/1988
From:	Snow B ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8801210137
Download: ML17261A771 (14)

Text

ROCHESTER GAS AIVD ELECTRIC CORPORATiON ~ 89 EAST AVENUE. ROCHESTER, N.'Y. I-'8~9-9i0:

January 15, 1988 U. S. Nuclear Regulatory Commission Attenti on: Mr. William Russell Region 1'dministration 631 Park Avenue King of Prussia, PA 19406 Subj ect: 1'nspecti on Report 50-244/87-23 Notice of Violation R." E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

Inspection Report 50-244/87-23 stated in part:

As a result of the inspection conducted on September 28 to October 2, 1987, and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions." 10 CFR Part 2, Appendix C (Enforcement Policy) (1986), the following violation vas identified:

10 CFR 50 Appendix B, Criterion XV1'equires measures be establi shed to assure t'hat conditions adverse to quality, such as deficiencies are promptly identified and corrected.

Ginna Station procedure A-1502 Nonconformance reports, Revision 10, Section 3.1.3 and Section 3.4. 6 states "Nonconf ormances (defi ci ency in characteristics) pertai ni ng to operating equipment or equi pment in a standby mode available for operation shall be reported to Ginna Station Superintendent. The superintendent shall evaluate th'e safety .impact of the nonconformance and determine the need and implement any further controls. "

Contrary to the above, on September 29, 1987 the fuse anomalies in Engineering work request 3341 and interoffice memorandum dated March 14, 1986 reported to the station superintendent, were not evaluated for their safety impact. As a result, these deficiencies vere not corrected.

Letter: Page 2 Subj ect: Inspection Report 50-244/87-23 To~ NRC Mr. William Russell Date: January 15, 1988

.RGhE agrees with the violation and offers the following in response to the Notice of Violation:

The fuse anomalies identified in the interoffice correspondence dated March 14, 1986 and May 28, 1986 from Corporate Engineering to the Station Superintendent were not evaluated on an individual

.basis for their safety impact. However, information was revi ewed by the plant staff and at the PlanttheOperations Review Commi t tee (PORC) on June 4, 1986 for generic eval uati on of the 125 volt DC distribution system to assure that the system performed

.as intended.

To ou tline our i ni ti al efforts toward fuse coordination, Gi nna Station administrative procedure A-60, "Control of DC System Fuse Size and Coordination", was developed to provide direction for and control of installed fuses. A program was initiated to generate procedures and implement replacement of the identified Tuse anomalies.

In addition, further engineering reviews were in progress under EWR-3341, DC System Evaluation, to ensure that specific design requi remen ts were establi shed. Implementati on of the ori gi nal fuse anomaly change outs was deferred until complete engineering design reviews were performed and an acceptable test program for qualification of fuses was establi shed.

As a result of Inspection 87-23 and as stated in our October 21,,

1987 letter, the DC fuse discrepancies were re-evaluated, and the documentation of the safety impact was expanded in the form of a Design Analysis. Each specific fuse anomaly was reviewed by the PORC on October 9 pursuant to 10CFR50.59. Based on the results of the detai led evaluati on, the PORC concluded that the discrepancies identified in the Design Analysis did not involve an unreviewed safety question Techni cal Specifications.

or require a change in the plant 's All originally identified anomalies which could be replaced with the plant at power without subj ecting the plant or personnel to safety or operational challenges either as a result of replacement or as a result of post maintenance testing were resolved with the remaining items to be resolved by the end of the 1988 refueling outage.

The DC Fuse Upgrade Evaluati on (EWR-3341) is continuing wi th current scheduled completi on date of January 1.988. Higher a

priority replacements and upgrades, as a result of this evaluation, will be completed by the end of the 1988 refueling outage. We expect the remaining activities to be completed by the end of the 1989 refueling outage.

Letter: Page 3 Subj ect: Inspection Report 50-244/87-23 To NRC Mr. William Russell Date: January 15, 1988 All DC fuses are now part of the configuration control program.

Nonconformance Reports (NCR's) are now being utilized to document and disposition any DC anomali es not addressed in the Analysis as described above. This should assure that any Design deficiencies wi be promptly identified, evaluated,future ll and dispositioned.

We have re-affirmed our policy on NCRis with the plant staff to ensure that any deficiencies pertaining to operating equipment be re ported vi a an NCR to the Station Superintendent and that the Superintendent shall determine the need for and ensure implementation of additional controls on the non-conforming items and shall perform an evaluation of'he safety impact in conjunction with controls on its use.

Full compli ance has been achieved with completi on of the safety

evaluation and the review of our NCR poli cy wi th the plant staff.

Yours truly, Bruce A. Snow Subscribed and sworn to me on this BAS/ams

. 15th day of January 2988

~ LYNN Pobke os

.f(A MONROE COUNTY CK rhe Stare of New York Comness~ Ex pcres Nov. 30, !9~

,xc Ginna Resident Inspector U. S. Nuclear Regulatory Commission (Original)

Document Control Washington, D. C. 20555

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 8801210137 DOC. DATE: 88/01/15 NOTARIZED: YES DOCKET 0 CIL: 50-244 Robert Emmet Qinna Nuclear Planti Unit 1. Rochester Q 05000244 UTH. NAME AUTHOR AFFILIATION OMi B. A. Rochester Qas 5 Electric Corp.

RECIP. NAME "

RECIPIENT AFFILIATION RUSSELL'. Region 1> Ofc of the Director

SUBJECT:

Responds to violations noted in Insp Rept 50-244/87-23.

Corrective actions: nonconformance repts being utilized to document Zc disposition DC anomalies not addressed in design analysis to assure future deficiencies promptly identified.

DISTRIBUTION CODE: IEOID COPIES RECEIVED: LTR I ENCL D SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: License Exp date in accordance with iOCFR2i 2. 109'(9/19'/72). 05000244 RECIPIENT COP IES REC IP IENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDi-3 PD STAHLEI C INTERNAL: AEOD 1 DEDRO 1 NRR MORISSEAU> D 1 NRR/DLPG/PEB 1 NRR/DOEA DIR NRR/DREP/EPB 1 NRR/DREP/RPB 2 NRR/DRIS DIR 1 NRR/PMAS/ILRB 1 RMANi J 1 OQC/HDS2 1 REQ 1 RES/DRPS DIR 1 RGN1 FILE 01 1 EXTERNAL: LPDR NRC PDR NSIC TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL

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RC I R GAS 8 YO ELECTRIC CORPORATION'I o 89 EAST AVEi~lUE, ROCHESTER, IY. Y. I-'849-OCI I

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P*'X, IC o'etgl J'anuary 15, 1988 U. S. Nuclear Regulatory Commission li Attention: Mr . Vi1 am Russell Region I Administration 631 Park Avenue King of Prussia, PA 19406 Subj ect: Znspecti on Report 50-244/87-23 Notice of Violation R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

Inspection Report 50-244/87-23 stated in part:

As a result of the inspection conducted on 'September 28 to October 2, 1987, and in accordance with the "General Statement of Poli cy and Procedure for BRC Enforcement Actions. " 10 CFR Part 2, Appendix C (Enforcement Policy) (1986), the following violation was identified:

10 CFR 50 Appendix B, Criterion XVI'equires measures be'stabli shed to assure that conditions adverse to quali ty, such as defi ci encies are promptly denti fied and corrected.

i Ginna Station procedure A-1502 Nonconformance reports, Revision 10, Section 3. 1. 3 and Section 3. 4. 6 states "Nonconformances (defi ci ency in characteristics) pertaining to operating equipment or equipment in a standby mode available for operation shall be reported to Ginna Station Superintendent. The superintendent shall evaluate the safety impact of the nonconformance and determine the need and implement any further controls. "

Contrary to the above, on September 29,, 1987 the fuse anomali es in Engineering work'equest 3341 and interoffice memorandum dated March 14, 1986 reported to the station superintendent, were not evaluated for their safety impact. As a result, these deficiencies were not corrected.

8801210137 880115 ADQC>4 05000244 r,S ol PDR PDR Q

4 Letter: Page 2 Subj e'ct: Inspection Report 50-244/87-23 Toe NRC Mr. Vi1li am Russell Date: January 15, 1988 RG&E agrees wi th the violation and of'fers the following in response to the Notice of Violation:

The fuse anomalies identified in the interoffice correspondence dated March 14, 1986 and May 28, 1986 from Corporate Engineering to the Station Superintendent were not evaluated on an individual basis for their safety impact. However, the information was reviewed by the plant staff and at the Plant Operations, Review Commi t tee (PORC) on June 4, 1986 for generic evaluati on of the 225 volt DC distribution system to assure that the system performed as intended.

To outline our initial efforts toward fuse coordination, Ginna Station administrative procedure A-60, "Control of DC System Fuse Size and Coordination", was devel oped to provide direction for and control of installed fuses. A program was initiated to generate procedures and implement replacement of the identified fuse anomalies.

In addition, further engineering reviews were in progress under EWR-3342, DC System Evaluation, to ensure that specific design requirements were established. Implementati on of the ori ginal fuse anomaly change outs was deferred until complete engineering design reviews were performed and an acceptable test program for qualification of fuses was established.

As a result of Inspection 87-23 and as stated in our October 22, 1987 letter, the DC fuse discrepancies were re-evaluated, and the documentation of the safety impact was expanded in the form of a Design Analysis. Each specific fuse anomaly was reviewed by the PORC on October 9 pursuant to 10CFR50.59. Based on the results of the detailed evaluation, the PORC concluded that the discrepancies identified in the Design Analysis did not involve an unreviewed safety question or recuire a change in the plant's Techni cal Speci ficati ons ..

All originally identified anomalies which could be replaced with the plant at power without subj ecting the plant or personnel to safety, or operational challenges either as a result of replacement or as a result of post maintenance testing were resolved, with the remaining items to be resolved by the end of the 1988 refueling outage.

The DC Fuse Upgrade Eval uati on (EVR-3342) is current scheduled completion date of Januarycontinuing wi th a 1988. Higher priority replacements and upgrades, as a result of this evaluation, wi ll be completed by the end of the 1988 refueling outage.

expect the remaining activities to be completed by the end of the Ve 1989 refueling outage.

4, O

Letter: Page 3 Subj ect: Inspection Report 50-244/87-23 To- NRC - Mr. William Russell Date: January 25, 2988 All DC fuses are now part of the configuration control program.

Nonconformance Reports (NCR's) are now being utilized to document and disposition any DC anomali es not addressed in the Analysis as described above. This should assure that any Design deficiencies wi l l be promptly identified, evaluated,future and dispositioned.

We have re-affirmed our policy on NCR's with the plant staff to ensure that any deficiencies pertaining to operating equipment be reported via .an NCR to the Station Superintendent and that the Superintendent shall determine the need for and ensure implementation of additional controls on the non-conforming items and shall perform an evaluation of the safety impact in conjunction with controls on its use.

Full compli ance has been achieved wi th completi on of the safety evaluation and the review of our NCR policy with the plant staff.

Yours truly, Bruce A. -Snow Subscribed and sworn to me on this 16th day of January 2988 LYNN . HA CK Notary PoMie in the State ot iVew York MONROF. COUNY BAS/ams Commission Expires Nov. 30, 19@7 I Xco Ginna Resident Inspector U. S. Nuclear Regulatory Commission (Origi nal)

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