ML17309A448

Responds to NRC 900717 Ltr Re Violations Noted in Insp Rept 50-244/90-80.Corrective Actions:Westinghouse Drawing E-2508 Approved & Issued to Central Records

ML17309A448
Person / Time
Site:	Ginna
Issue date:	08/16/1990
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9008230153
Download: ML17309A448 (13)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM V. ~ 4 1

REGULATORY XNFORMATION DIS'1 RIBUTION SYSTEM (RXDS)

ESSION NBR:9008230153 DOC.DATE: 90/08 /16 NOTARIZED: NO DOCKET g CIL:50-244 Robert Emmet Ginna Nuclear Pl ant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas 6 Electric Corp.

RECIP.NAME RECIPIENT AFFILXATION MARTIN,T.T. Region 1 (Post 820201)

SUBJECT:

Responds to NRC 900717 ltr re violations noted in Insp Rept

~50-24 iSO-SO.Corrective actions: CR issued.

D DISTRIBUTXON CODE: A001D TITLE: OR COPIES RECEIVED: LTR l Submittal: General Distribution ENCL g SIZE:

S NOTES:License Exp dat.e in accordance with 10CFR2 i 2 109 (9/19/72) 05000244 RECIPIENT COPIES RECIPIENT COPIES XD CODE/NAME LTTR ENCL D CODE/NAME LTTR ENCL PD1-3 LA PD~ -3 PD D JOHNSON,A D

INTERNAL: NRR/DET/ECMB 9H NR /DOEA/OTSB11 NRR/DST 8E2 NRR/DST/SELB 8D NRR/DST/SICB 7E NRR/DST/SRXB 8E NUDOCS-ABSTRACT OGC/HDS2 01 RES/DSIR/EIB RNAL: LPDR NR PDR NSIC D

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONT CT THE DOCUMENT CONTROL DESK, ROOM P l-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL

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///I///II ROCHESTER GAS AND EI.ECTRIC CORPORATION o ZE 89 EAST AYENUE, ROCHESTER NY. 14649-0005 i/ocr 51r Tc ROBERT C MECREDY 1ELEPHONE Vice P/erldenl AREA CODE 718 546 2700 Clnno Nudeo/ P/eduction August. 16, 1990 Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Subject:

Response to Noti'ce of Violation Inspection Report 50-244/90-80 R.E. Ginna Nuclear Power Plant Docket Number 50-244

Dear Mr. Martin:

Your letter dated July 17, 1990, from Mr. Robert M. Gallo, Chief Operations Branch Division of Reactor Safety Transmitting, Enclosure 1, Appendix A, Notice of Violation, identified two (2) violations, one with two examples.

The following provides a reply to those violations pursuant to 10 CFR 2.201:

Restatement of Violation in art Technical Specifications Section 6.10.2 requires that records and drawing changes be retained for the duration of the Facility Operating License. Station Procedure A-603 states: 1) All as-built drawings listed in Table 1 shall be received by the Central Records Specialist for distribution; and 2) As a minimum, one copy of each document shall be retained by the Central Records Specialist in accordance with the requirements of Reference 2. 1. (Reference 2.1 is Procedure A-1701, Ginna Records).

Contrary to the above, no copy of Westinghouse drawing E-2508, for the N-31 Source and Intermediate detector before and after the recent modification that added a drainage hole to detector housing WL-23785, was being retained by the Central Records Specialist during the April 1990 team inspection.

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Page 2 50-244/90-80 August 16, 1990 2 10CFR50.59(a)(2) specifies, in part, that a proposed change to involve an unreviewed safety question if,

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shall be deemed a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created.

10CFR50.59(b)(1) specifies, in part, that the licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that these changes constitute" changes in the facility as described'n the safety analysis report. These records must include a written safety evaluation which provides the basis for the determination that the change, test, or experiment does not involve an unresolved safety, question.

Station Procedure 301.1, Station Modification classification and Review, Steps 3.2.2 and 3.2.3 describe modifications as:

1) a change which involves a component change (vendor product improvement or user initiated) and 2) changes to...

structures ... which affect performance requirements...

A. Contrary to the above, the use of a building identified in the Updated Final Safety Analysis Report, Figure 1.2-1, Ginna Station Plot Plan, as a storage building, was changed to include long term storage of radioactively contaminated equipment without completing a written safety evaluation which provided the bases for the determination that the use of this building for contaminated storage does not involve an unresolved safety question. Contaminated equipment had been stored in this building from at least 1983 until April, 1990. t B. Contrary to the above, As of April 20, 1990, Work Order 90-21224 replaced the original N-31 Source Range Detector, without drain holes, with a new housing, with drain holes, without completing a written safety evaluation which provided the basis for the determination that. the modification does not involve an unreviewed safety question. The nuclear instrument system source range is described in the Updated Final Safety Analysis Report, Section 7.7.3.2.1.

Page 3 50-244/90-80 August 16, 1990 Reason for Violation 1 Rochester Gas and Electric acknowledges that Westinghouse drawing E-2508 for the N-31 source and N-35 intermediate detector including before and after modification revisions were not being retained by the Central Records Specialist. However, Procedure A-603, "Control of As-Built Drawings and Design Documents", Table listed only Controlled Configuration Drawings (CCD) and did not1 include Westinghouse drawings such as E-2508. Procedural direction for processing vendor drawings received by Ginna Station as a result of Station originated procurement did not exist, whereas drawings received as a result of Engineering originated procurement are controlled by QE-606, "Receipt, Control and Distribution of Drawings and,Aperture Cards".

Corrective Ste s Which Have Been Taken and Results Achieved Westinghouse drawing E-2508 referenced in WO number 90-21224 has been reviewed by Nuclear Engineering Services. Drawing E-2508, Revision 0, applies to the excore neutron detector housing assembly now installed in the N-32/N-36 well. The drawing has been approved and has been issued to Central Records.

A revised Westinghouse drawing E-2508, Revision 3, has not yet been received by RG&E. Westinghouse (reference letter RGGE-90-562, May 8, 1990) has advised that "Revision 3 is being generated to reflect the design changes incorporated with drilling a hole in the bottom of the assembly...and will be transmitted once it been updated by the manufacturer and review/approved by Westing-has house." Westinghouse has informed RGGE that a revision to drawing E-2508 will be transmitted in the near future.

Once received, this drawing will be reviewed for approval and distributed per QE-606.

The Corrective Ste s Which Will Be Taken To Avoid Further Violations A Nuclear Engineering/Records Management Ad Hoc Group has been formed to analyze various document control issues. An analysis of the vendor drawing review and approval process, as well as the document control management of vendor drawings, is underway.

Changes to plant and engineering have been drafted and are under committee review.

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Page 4 50-244/90-80 August 16, 1990 Additionally, a preliminary assessment of past work related to vendor drawings has begun. This assessment will be continued within the Ad Hoc Group charter responsibilities.

The Date When Full Com liance Will Be Achieved Revisions of A-606, "Drawing Change Request" and QE-606, "Receipt Control and Distribution of Drawings and Aperture Cards" to provide specific direction for processing vendor supplied drawings will be completed by December 20, 1990.

Reason for Violation 2 Exam le A RGGE agrees with the violation as stated above, in that no docu-mented safety evaluation existed for the use of a storage building for storage of contaminated equipment. In the mid 1970's, a pole barn was constructed on the southwest corner of the site for concrete mixing and storage. During the 1980-1981 time frame, a concrete floor with an installed drain was constructed, in preparation for storage of equipment. In September of 1982, the building was, used for 'he storage of packaged contaminated equipment. A historic search through past PORC meeting minutes indicates no documented safety analysis exists for the conversion of this pole barn structure into a contaminated storage building.

Corrective Ste s Which Have Been Taken Immediately upon the detection of moisture inside the Radioactive Material Storage Area (RMSA), actions were taken to eliminate the possibility of rainwater induction. The overhead roof vents were bolted closed, and the drain was covered to prohibit potential releases. RGGE has performed a 10CFR50.59 safety evaluation for the storage of contaminated equipment inside the RMSA. This PORC approved safety evaluation determined that no unreviewed safety question exists from the 'storage of contaminated material inside this building.

Corrective Ste s Taken To Avoid Further Violations RG&E believes that the lack of a 10CFR50.59 safety evaluation documentation for the conversion of the RMSA to a radioactive contaminated storage building is an isolated event. Current work process control A-1603 series procedures and modification process control A-300 series procedures provide administrative controls

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Page 5 50-244/90-80 August 16, 1990 to ensure a 10CFR50.59 evaluation be performed for any changes to the facility which are not a direct one-for-one replacement.

These guidelines would prohibit the installation or conversion of a building addressed in the UFSAR without a documented, approved 10CFR50.59 safety evaluation.

Date When Full Com liance Will Be Achieved RGSE is currently in full compliance of 10CFR50.59(a)(2) and 10 CFR50.59(b)(1) since a documented safety evaluation for the use of the RMSA as a storage building for contaminated storage has been performed and approved by PORC.

Reason for Violation 2- Exam le B RGGE agrees with the Violation 2B as stated above, in that a modified Source/Intermediate Range (S/IR) detector housing assembly was procured and installed without evidence of the proper reviews being completed and documented by RG&E Engineering.

In-depth investigation indicates that the root cause of this incident was inadequate and ineffective notification of modifica-tions to the licensee by the supplier Westinghouse NSID.

Corrective Ste s Which Have Been Taken and Results Achieved Immediate corrective actions taken to address the non-documented modification included:

1~ Initiation of Nonconformance Report (NCR)90-140.

2 ~ Evaluation of the nonconformance (modification) by RGGE Engineering. The modification was determined to be a conservative enhancement to =the S/IR assembly. Therefore, the NCR disposition was "use-as-is".

3 ~ 10CFR Part 21 reporting was evaluated and determined not applicable due to the "use-as-is" disposition of NCR 90-140.

4 ~ Completion of a 10CFR50.59 evaluation in conjunction with disposition of the referenced NCR.

Page 6 50-244/90-80 August 16, 1990 5 ~ Initiation of RG&E correspondence (Podlena to Hofscher) dated April 23, 1990, requesting the safety evaluation, reason for exclusion from the bulletin and other information relating to the S/IR assembly. The response to the RG&E correspondence was generated and forwarded'o RG&E May 8, 1990.

Corrective Ste s Which Will Be Taken to Avoid Further Violations Virtually all of the corrective actions to prevent recurrence of situations similar to this had been implemented, as enhancements to the procurement process, prior to performance of Inspection 90-80. The enhancements included:

l. Formation of a Procurement Engineering Group which is responsible for technical review of items prior to procure-ment.

2. Revision of Ginna Station Administrative Procedure A-301, "Preparation and Disposition of Technical Staff Requests".

3. Implementation of Ginna Station Administrative Procedure A-305, "Technical Staff Engineering Evaluations".

4. Revised/clarified vendor procurement requirements.

The Procurement Engineering Group was established to evaluate all spare/replacement parts procured by Ginna Station prior to procurement. This review is performed to assure:

1. Proper nuclear safety classification of the item.

2. Correct quality and technical requirements are delineated on the purchase requisition.

3. Any changes from the original design specification are formally evaluated and documented.

revision of A-301 provided the methods for Procurement i'he Engineering to identify vendor initiated design changes to Technical Engineering for classification. Additionally, this revision established the Technical Staff Engineering Evaluation (TSEE) as a method to disposition a Technical Staff Request (TSR) which is classified as an equivalency evaluation.

The implementation of A-305 provided Procurement Engineering with the procedural guidance to perform Technical Staff Engineering

Page 7 50-244/90-80 August 16, 1990 Evaluations for TSR's classified as "equivalency evaluations" by Technical Engineering. These changes provided concise methods to assure that vendor initiated changes are identified, evaluated and documented prior to item procurement.

As previously mentioned, the vendor procurement requirements were clarified/revised prior to the performance of Inspection 90-80.

Clarification of the impact this has on procured items follows:

Many of the procurement requirements imposed on vendors are identical. Therefore, it is useful to code as many of the standard requirements as possible and reference them to specific items in the computer used to generate the purchase requisition. This was a standard practice long before the formation of the Procurement Engineering Group. However, many of the coded requirements were unclear or lacked sufficient instruction. All the standard procurement requirements were revised and brought under strict control of Procurement Engineering in mid 1989. The result has been clear and concise procurement documents.

Date When Full Com liance Will Be Achieved Based on the corrective actions performed, RG&E achieved full compliance on disposition and 10CFR50.59 evaluation of NCR 90-140 on April 9, 1990.

Very truly yours, c

Robert C. Mecredy xc: U.S. Nuclear Regulatory Commission Document Control Desk (Original)

Washington, D.C. 20555 NRC Senior Resident Inspector - Ginna Station

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