ML17263A936
| ML17263A936 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/09/1995 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9502150373 | |
| Download: ML17263A936 (13) | |
Text
AND ROCHESTER GASANDELECTRIC CORPORATION
~ 89 EASTAVENUE, ROCHESTER, N. V IrI649-000I ARG4 CODE 7I6 5'.2700 ROBERT C. MECREDY Vice President Nvdeor Operolions February 9, 1995 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson PWR Project Directorate I-3 Washington, D.C. 20555
Subject:
Reply to a Notice of Violation NRC Inspection Report 50-244/94-27-01, dated January 10, 1995 R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Johnson:
During NRC inspections conducted'on November 22 to December 31, 1994, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
n10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part: "Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
"Contrary to the above, as part of a modification to the Service Water system to upgrade the C-Service Water pump discharge check valve, V-4603, performed during the period September 29 - October 4, 1994, work instructions contained in station modification procedure SM-5284B.2, "C-Service Water Pump Check Valve 4603 Modification," did not include appropriate quantitative or qualitative acceptance criteria to ensure that the previously in-use expansion joint between the C-Service Water pump discharge and V-4603 would fit properly following completion of the check valve modification. As a result, installation caused the expansion joint to be stretched by an amount that was in excess of the manufacturer's maximum allowable value, which subsequently caused the pressure retaining capability of the expansion joint to be degraded."
PAGE 2 (1) the reason for the violation, or ifcontested, the basis for disputing the violation:
Rochester Gas 8r, Electric Corporation (RGB) accepts the violation and offers the following information which contributed to the violation.
The activities involvingreplacement ofcheck valve V-4603 contributed to the violation.
The replacement of the check valve was not expected to alter the face-to-face flange dimensions at the expansion joint (SSW04).
Therefore, the planning package for the modification did not consider the need to specify quantitative or qualitative acceptance criteria for the expansion joint.
During earlier activities related to replacement of the expansion joints for the "A"and "B" Service Water pumps during the 1994 outage, nonconforming conditions were identified, and documented on a Nonconformance Report (NCR).
However, the corrective action rework resulting from this earlier NCR were not recognized as applicable to future work. This was a missed opportunity to convert the lessons learned fromthe "A"and "B"expansion jointconditions intoupgraded technical process controls for the "C" Service Water expansion joint work. It is noteworthy to mention that the design allowable elongation of this expansion joint is 3/8 inch, a small fraction of the overall length of the expansion joint, which is between approximately ten inches.
(2) the corrective steps that have been taken and the results achieved:
Upon discovery ofthis condition, the manufacturer was consulted. Based on evaluations and subsequent field inspection by the manufacturer, it was concluded that degradation that occurred did not affect system operability. However, the design maximum pressure-retaining capability had been compromised, though the joints were stillable to meet the service requirements ofthe Ser vice Water system. This condition was then documented as a nonconforming condition on NCR 94-128, and was justified for interim use, based on the manufacturer's assessment.
A replacement expansion joint, designed to the specific flange-to-flange dimensions, was procured.
RGB elected to replace the joint upon receipt of the newly procured expansion joint. After replacement on December 28, 1994, the expansion joint was within the manufacturer's installation criteria, including full elongation capability.
PAGE 3 (3) the corrective steps that willbe taken to avoid further violations:
A new maintenance procedure (GMP-11-1441) is being developed.
GMP-11 01 willprovide instructions for installation ofthe Service Water pump discharge expansion joints, including quantitative or qualitative acceptance criteria.
The controls for installation of the new check valve for the "D" Service Water.
pump discharge (the remaining unmodified pump discharge check valve) will include engineering controls for the installation of the expansion joint, as an integral part of the modification.
The modification procedure will contain appropriate acceptance criteria for the expansion joint.
An investigation will be performed to assess similar applications of expansion joints in the plant, and willinclude an evaluation of engineering, procurement, vendor issues, work package preparation, alignment ofmanagement expectations with predetermined acceptance criteria, and administrative controls.
The objective ofthis investigation is to identifythe need forquantitative or qualitative acceptance criteria for other applications.
'echanical maintenance personnel willbe trained on new procedure GMP-11 01, prior to use.
the date when full compliance will be achieved:
Full compliance with the configuration of the "C" SW pump expansion joint was achieved on December 28, 1994, when the replacement joint was installed.
Full compliance with quantitative or qualitative acceptance criteria for Service Water system expansion joints willbe achieved withthe approval ofprocedure GMP-11-14-01.
This procedure will be approve'd prior to completion of the 1995 outage.
Very ly Yours, o ert C. Mecred XC:
Mr. Allen R. Johnson (Mail Stop 14D1)
PWR Project Directorate I-3 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna USNRC Senior Resident Inspector
PRIORITY (ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:9502150373 DOC.DATE: 95/02/09 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 JOHNSON,A.R.
Project Directorate I-3 (PD1-3)
(Post 941001)
SUBJECT:
Responds to NRC 950110 ltr re violation noted in insp rept 50-244/94-27 on 941122-1231.Corrective actions:replacement expansion joint,designed to specific flange-to-flange dimensions procured
& installed on 941228.
DISTRIBUTION CODE: IEOID COPIES RECEIVED: LTR ENCL g SIZE: 5 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response DOCKET N
05000244 NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
05000244 RECIPIENT ID CODE/NAME PD1-3 PD INTERNAL: AEOD/DEIB AEOD/SPD/RRAB DEDRO NRR/DISP/PIPB NRR/DRCH/HHFB OE DIR RGN1 FILE 01 EXTERNAL: LITCO BRYCE,J H
NRC PDR COPIES LTTR ENCL 1
1
,1 1
1 1
1 RECIPIENT ID CODE/NAME JOHNSON,A AEOD/SPD/RAB AEOD/-TgC
+PILE CENTEEEI 02 NRR/DORS/OEAB NUDOCS-ABSTRACT OGC/HDS3 NOAC COPIES LTTR ENCL 1
1 1
1 1
1 1
YOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE! COYTACTTHE DOCL'i!EYTCONTROL DESK. ROOM Pl-37 (EXT. 504-2083 ) TO ELIXII.'PATE YOUR NAME PROil DISTRIBUTION,LISTS I:OR DOCL'MEY.'IS YOU DOY "I' L'ED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 18 ENCL
7 4ND ROCHESTER GASANDELECTRIC CORPORATION
~ 89 EASTAYENUE, ROCHESTER, N.Y. 17I6d9-0001 AREA CODE 7I65'700 ROBERT C. MECREDY Vice President Nvcleor Operotions February 9, 1995 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson PWR Project Directorate I-3 Washington, D.C. 20555
Subject:
Reply to a Notice of Violation NRC Inspection Report 50-244/94-27-01, dated January 10, 1995 R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Johnson:
During NRC inspections conducted on November 22 to December 31, 1994, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure forNRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
"10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part: "Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
"Contrary to the above, as part of a modification to the Service Water system to upgrade the C-Service Water pump discharge check valve, V-4603, performed during the period September 29 - October 4, 1994, work instructions contained in station modification procedure SM-5284B.2, "C-Service Water Pump Check Valve 4603 Modification," did not include appropriate quantitative or qualitative acceptance criteria to ensure that the previously in-use expansion joint between the C-Ser vice Water pump discharge and V-4603 would fit properly following completion of the check valve modification. As a result, installation caused the expansion joint to be stretched by an amount that was in excess of the manufacturer's maximum allowable value, which subsequently caused the pressure retaining capability of the expansion joint to be degraded."
9502150373 st50209 PDR ADOCK 05000244 9
>(~~I ly
PAGE 2 (1) the reason for the violation, or ifcontested, the basis for disputing the violation:
Rochester Gas Bc Electric Corporation (RGtkE) accepts the violation and offers the following information which contributed to the violation.
The activities involving replacement of check valve V-4603 contributed to the violation.
The replacement of the check valve was not expected to" alter the face-to-face flange dimensions at the expansion joint (SSW04).
Therefore, the planning package for the modification did not consider the need to specify quantitative or qualitative acceptance criteria for the expansion joint.
During earlier activities related to replacement of the expansion joints for the "A"and "B" Service Water pumps during the 1994 outage, nonconforming conditions were identified, and documented on a Nonconformance Report (NCR).
However, the corrective action rework resulting from this earlier NCR were not recognized as applicable to future work. This was a missed opportunity to convert the lessons learned fromthe "A"and "B"expansion jointconditions into upgraded technical process controls for the "C" Service Water expansion joint work. It is noteworthy to mention that the design allowable elongation of this expansion joint is 3/8 inch, a small fraction of the overall length of the expansion joint, which is between approximately ten inches.
(2) the corrective steps that have been taken and the results achieved:
Upon discovery ofthis condition, the manufacturer was consulted.
Based on evaluations and subsequent field inspection by the manufacturer, it was concluded that degradation that occurred did not affect system operability. However, the design maximum pressure-retaining capability had been compromised, though the joints were still able to meet the service requirements ofthe Service Water system. This condition was then documented as a nonconforming condition on NCR 94-128, and was justified for interim use, based on the manufacturer's assessment.
A replacement expansion joint, designed to the specific flange-to-flange dimensions, was procured.
RGBcE elected to replace the joint upon receipt of the newly procured expansion joint. After replacement on December 28, 1994, the expansion joint was within the manufacturer's installation criteria, including full elongation capability.
PAGE 3 I
(>)
the corrective steps that will be taken to avoid further violations:
A new maintenance procedure (GMP-11-14-01) is being developed.
GMP-11 01 willprovide instructions forinstallation of the Service Water pump discharge expansion joints, including quantitative or qualitative acceptance criteria.
The controls for installation of the new check valve for the "D" Service Water pump discharge (the remaining unmodified pump discharge check valve) will include engineering controls for the installation of the expansion joint, as an integral part of the modification.
The modification procedure will contain appropriate acceptance criteria for the expansion joint.
An investigation will be performed to assess similar applications of expansion joints in the plant, and willinclude an evaluation of engineering, procurement, vendor issues, work package preparation, alignment ofmanagement expectations with predetermined acceptance criteria, and administrative controls.
The objective ofthis investigation is to identifythe need forquantitative or qualitative acceptance criteria for other applications.
Mechanical maintenance personnel willbe trained on new procedure GMP-11 01, prior to use.
(4) the date when full compliance will be achieved:
Full compliance. with the configuration of the "C" SW pump expansion joint was achieved on December 28, 1994, when the replacement joint was installed.
Full compliance with quantitative or qualitative acceptance criteria for Service Water system expansion joints willbe achieved with the approval ofprocedure GMP-11-14-01.
This procedure will be approved prior to completion of the 1995 outage.
Very ly Yours, o ert C. Mecred XC:
Mr. Allen R. Johnson (Mail Stop 14D1)
PWR Project Directorate I-3 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna USNRC Senior Resident Inspector