ML17262A916
| ML17262A916 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/29/1992 |
| From: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| Shared Package | |
| ML17262A917 | List: |
| References | |
| NUDOCS 9207080098 | |
| Download: ML17262A916 (6) | |
Text
Docket No. 50-244 gg ~ 9'~992 Dr. Robert C. Mecredy Vice President, Ginna Nuclear Production Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649
Dear Dr. Mecredy:
SUBJECT:
INSPECTION REPORT NO. 50-244/91-80 This refers to your letter dated September 30, 1991, in response to our letter dated August 21, 1991.
In your letter, you disagreed with violation 50-244/91-80-04.
This violation pertains to protective relay settings that drifted below the Technical Specification limit and were not evaluated.
You stated that although the "as-found" dropout voltage settings for the three affected undervoltage relays were below the Technical specifications limitof 103.5 Vac, these dropout voltages did not exceed the acceptance criteria of Procedure PR-l.l.
Also, you stated that evaluation of a similar situation was reported previously to the NRC in LER 90-008, Revision 1, which was issued on August 20, 1990.
However, this information was not given to the inspection team when we identified the issue.
In LER 90-008, you reported that, on May 24, 1990, five of the eight degraded voltage relays might have settings below the Technical specification limit. You also reported that the problem was, subsequently, corrected.
In March 1991, during the 1991 refueling outage, the "as-found" dropout voltage setting of three degraded voltage relays were below the Technical Specification limitof 103.5 Vac.
After reviewing your response, the LER and the new procedure (PR-1. 1), we agree the violation was inappropriately cited against failure to follow procedures.
However, we determined that the corrective action you had implemented as a result of LER 90-008 was inadequate to preclude recurrence of this problem in 1991.
This constituted a violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action." This criterion states, in part, that "Measures shall be established to assure that conditions adverse to quality,...are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition...".
9207080098 920629 PDR ADOCK 05000244 6
Dr. Robert C. Mecredy This issue was discussed during a telephone call on December 27, 1991, between Messrs. T. Marlow, S. Adams, B. Flynn, and P. Swift of your organization and Messrs.
J. Durr, W. Lazarus and L. Cheung of the NRC Region I Office.
Our conclusion that the procedural violation should be withdrawn and that a violation of inadequate corrective action would be issued was conveyed to your staff with all parties concurring.
Subsequently, a package describing your corrective actions for this violation was sent to us for review.
This package contains calibration data sheets which showed that the affected relay dropout voltage setpoints were raised to 104.5V and above.
The package also contains a memo dated April 26, 1991, from P. Swift to S. Adams.
This memo determined that plant operability is not a concern for relay dropout voltage to be slightly below Technical Specification requirements.
We considered your corrective actions for this violation to be adequate.
Therefore, no response to this violation is required from you.
As for the clarification provided in Attachment 2 of your letter, our response is as follows:
a)
Emer enc diesel ene tor stead tate l adin anal si The third paragraph of Section 2.4.1 indicated that, based on Regulatory Guide 1.9 and IEEE Standard 387-1984, the assumptions used were incorrect and nonconservative.
We understand that this Regulatory Guide and IEEE Standard do not apply to Ginna plant.
Therefore, no regulatory actions (violation or deviation) were taken for this issue during the inspection.
In summary, we still believe that our statement in the report is correct.
b)
The commitment date of September 30, 1992, for the completion of the verification and validation of the model software for the diesel generator dynamic loading analysis is acceptable to the NRC.
c)
Diesel enerators fuel oil stora e tank sable volume.
The proposed alternate is acceptable to the NRC.
d)
EDW-4162 initiati n date.
We agree that December 17, 1986, is the correct date instead of December 17, 1976, which is a typographical error.
Your cooperation with us is appreciated.
Sincerely, Marvin W. Hodges, Director Division of Reactor Safety
Enclosure:
Appendix A, Notice of Violation
L iy
Dr. Robert C. Mecredy cc w/encl:
R. Smith, Senior Vice President, Production and Engineering Central Records (4 copies)
Director, Power Division State of New York, Department of Law N. Reynolds, Esquire Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO AllInspection Reports NRC Resident Inspector State of New York, SLO Designee bcc w/encl:
Region I Docket Room (with concurrences)
(w/cy of IFS Forms)
DRS/EB SALP Coordinator J. Linville, DRP W. Lazarus, DRP T. Moslak, SRI - Ginna (w/cy of IFS Forms)
A. Johnson, PM, NRR R. Lobel, OEDO RI:DRS Cheung 06/ /92 RI:DRS Anderson 06/ /92 RI:DRS c uk~
06 2
RI:DRS Hodges 9yl 06$ )/92 OFFICIAL RECORD COPY A:R50-244.LC
Rochester Gas and Electric Corporation Cheung 12/g/91 RIXRS Anderson 12/P/91 RI:DRS Durr 12/ /91 RI:DRS Hodges 12/ /91 OFFICIALRECORD COPY C:R50-244.LC