ML17262A516
| ML17262A516 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/10/1991 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9106180281 | |
| Download: ML17262A516 (7) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM,(RIDS)
ACCESSION NBR:9106180281 DOC.DATE: 91/06/10 NOTARIZED: NO FACIL:50-244 Robert Emmet'Ginna Nuclear Plant, Unit 1, Rochester G
AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION MARTIN,T.T.
Region 1 (Post 820201)
SUBJECT:
Responds to NRC 910509 ltr re violations noted in Resident Insp Rept,.-50-244/91-07JCorrective actions: directive issued to plant personnel reemphasizing hold requirements for providing safe work area for personnel.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR + ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
DOCKET 05000244 D
/'5000244 RECIPIENT ID CODE/NAME PD1-3 PD INTERNAL: AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS1 RGN1 FILE 01 EXTERNAL: EG&G/BRYCE,J.H.
NSIC COPIES LTTR ENCL RECIPIENT ID CODE/NAME JOHNSON,A AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DRIS/DIR NRR/PMAS/ILRB12 E'-
2 NRC PDR COPIES LTTR ENCL 1
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NOTE TO ALL"RIDS" RECIPIENTS D
D PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENI'ONTROLDESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
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ROCHESTER GAS AND ELECTRIC CORPORATION f 7
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89 EAST AVENUE, ROCHESTER N.K 1464g 0001 ROBERT C. MECREOY Vice President Cinna Nuclear Production TELEPHONE AREACOOEPte 546.2700 June 10, 1991
~
- Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pa.
19406
Subject:
Response to Notice of Violation, R.E.
Ginna Resident Inspection 50-244/91-07.
R.E.Ginna Nuclear Power Plant Docket Number 50-244
Dear Mr. Martin:
Your letter dated May 9, 1991 transmitting R.E. Ginna Resident Inspection 50-244/91-07 from John F. Rogge, Acting Chief, Projects Branch 3,
Division of Reactor
- Projects, contains Enclosure 1,
The following provides the requested written reply pursuant to 10 CFR 2.201:
Restatement of Violation in art Technical Specification 6.8.1 requires establishment and implementation of the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972 (Safety Guide 33).
That regulatory
- guide, Appendix A,Section I, specifies that maintenance which can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
R.E.
Ginna Administrative Procedure (A)
- 1401, Station Holding Rules, Revision 25, effective March 25,
- 1991, requires that the Holding Authority properly verify the adequacy of the isolated work area and that the Authorized Person for the hold assure that the equipment is properly isolated and it is safe to proceed with the work.
91061-02-:1 910610 F DF<
ArfOCK <35000244 9
Inspection Report 50-24/91-07 Page 2 of 4 Contrary to the above, maintenance that could affect safety-related equipment performance was not procedurally established and implemented properly on April 2, 1991.
This occurred when Component Cooling Water (CCW) Valve 738B was not assured to be properly isolated, leading to the shutdown of safety-related equipment in the CCW and Residual Heat Removal systems and to the declaration of an Unusual Event.
This maintenance was not properly preplanned and performed in that the Hold Request did not specify that the operators manually backseat the valve, and the Holding Authority (Shift Supervisor) did not properly verify the adequacy of the isolated work area.
Also, the authorized person (requestor) did not assure that the equipment was properly isolated.
Additionally, Main-tenance Procedure (M)-37.116.3, Valve Packing, Revision 0,
effective March 9,
- 1991, for repacking the valve did not require verification that the valve was backseated prior to the start of maintenance.
Reasons for the Violation Rochester Gas and Electric concurs with-the violation as described in the Inspection Report.
Reasons for the violation include:
0 Inadequate procedural direction for the technique of utilizing the valve backseat for pressure boundary isolation.
0 Incomplete information in the hold request identifying the need to use the valve backseat for pressure boundary isolation.
0 0
0 Lack of procedural direction to insure the valve con-figuration provides a backseat, to manually backseat the valve and to subsequently verify that the valve was properly backseated.
Insufficient pre-job briefing of the valve maintenance technician identifying the isolation method to be used.
Inadequate isolation verification by the Job Foreman.
Failure of the Holding Authority to identify the inadequate.isolation.
Inspection Report 50-24/91-07 Page 3 of 4 The Corrective Ste s Taken and Results Achieved A directive was issued to plant personnel from the Ginna Station Superintendents (Production and Support Services) re-emphasizing "Hold Requirements" for providing a safe work area for personnel.
A directive was issued to Operations Personnel by the Operations Manager providing specific instructions on backseating
- valves, including precautions applicable to gate
- valves, globe valves and to motor-operated valves.
Administrative procedure A-1401 "Station Hold Rules" was revised to permit using a valve backseat as pressure boundary isolation for valve packing maintenance, providing the valve is designed with a backseat, and there is no other practical way to create an isolated work area for the maintenance.
The revision also included a
requirement that the valve be tagged in the "backseated" position and that MOVs will be manually backseated after being opened electrically.
Maintenance procedures M-37.116 "Valve Packing for Valves Covered by the Valve Packing Improvement Program (VPIP)", and M-37.116.3 "Valve'acking for QA Safety Related and Safety Significant Valves Not Under the Valve Packing Improvement Program (VPIP)" were revised to.-'equire that when the backseat was used as a pressure isolation boundary, that both the person performing the maintenance and the Job Foreman witness the manual backseating effort.
Additionally, a
Human Performance Enhancement.
System (HPES) evaluation was performed to identify the various causal factors for the incident.
The results achieved were demonstrated by the successful pressure boundary isolation for repair of a weld leak on the packing leakoff line on MOV-700 (RHR/Reactor Coolant Isolation) while on the backseat at hot shutdown later in the outage.
The Corrective Ste s to be Taken to Avoid Further Violations In addition to the corrective actions related above which resolved use of valve backseats as pressure boundary isolation, a
task force consisting of plant personnel from all Departments has been organized to enhance "Station Holding" activities.
Additional meetings are scheduled to determine potential corrective
- actions, resolution of issues and concerns and to prioritize enhancement steps to be taken to reduce isolation boundary violations.
Inspection Report 50-24/91-07 Page 4 of 4 The Date When Full Com liance Will be Achieved
'C Full compliance to Technical Specification 6.8.1 was achieved when the revised procedures M-37.116 and M-37.116.3 became effective April 13, 1991 and when the revised A-1401 "Station Holding Rules" became effective on April 24, 1991.
Very Truly Yours Robert C. Mecred xc:
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk (Original)
Washington, DC 20555 Mr. Thomas Moslak USNRC Senior Resident Inspector R.E. Ginna Nuclear Power Plant 1503 Lake Road
- Ontario, NY. 14519