ML17309A521

Responds to Violations Noted in Insp Rept 50-244/93-06 on 930310-0422.Corrective Actions:All Hot Work Activities Associated W/Ewr 5275 Stopped & Fire Protection Personnel Will Treat All Filter Media as Combustible

ML17309A521
Person / Time
Site:	Ginna
Issue date:	07/14/1993
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9307220016
Download: ML17309A521 (4)

Text

ACCELERATED DOCUMENT DISTRIBUTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

.CCESSION NBR:9307220016 DOC.DATE: 93/07/14 NOTARIZED: NO DOCKET ACIL:50-'244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 UTH.NAME AUTHOR AFFILIATION ECREDY,R.C. Rochester Gas & Electric CorP.

RECIP.NAME RECIPIENT AFFILIATION JOHNSONiA.R. Project Directorate I-3

SUBJECT:

Responds to violations noted in Insp Rept 50-244/93-06 on 930310-0422.Corrective actions:all hot work activities associated w/EWR 5275 stopped & fire protection personnel will treat all filter media as combustible.

DZSTRZBUTZON CODE: ZEOZD COPZES RECEZVED:LTR 3 ENCL 0 SZZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vio'lation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 PD JOHNSON,A INTERNAL: AEOD/DEIB AEOD/DSP/ROAB AEOD/DSP/TPAB AEOD/TTC DEDRO NRR/DORS/OEAB NRR/DRCH/HHFB NRR/DRIL/RPEB 0 NRR/DRSS/PEPB NRR/PMAS/ILPB2 OE DIR

~ELLE> 02 NRR/PMAS/ILPBl NUDOCS-ABSTRACT OGC/HDS1 RES/HFB RGN1 FILE 01 EXTERNAL: EG&G/BRYCEgJ.H. NRC PDR NSIC NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE IVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 {EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL

IIAla ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER N. Y. 14649-0001 ROBERT C MECREDY TELEPHOkE Vice PieIident AREA CODEVI6 546 2700 Cinna Nvcieac Produciion July 14, 1993 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 oi Violation NRC Inspection Report No. 50-244/93-06, dated May 14, 1993 R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Johnson:

During an NRC Inspection conducted on March 10, 1993 to April 22, 1993, 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:

"Measures shall be established to assure, that conditions adverse to quality, such as failures...defective materials and equipment, and nonconformances are promptly identified-and corrected."

Contrary to the above, as of March 19, 1993, no measures had been established to assure that the roughing filters to the Containment Recirculation Fan Cooling System were properly maintained free of accumulated combustible materials.

(1) the reason for the violation, or, if contested, the basis for disputing the violation:

Rochester Gas & Electric Corporation accepts the violation. We acknowledge that a fire occurred in these filters on March 19, 1993. As a point of clarification, the components referred to as "roughing filters" are more properly characterized as demisters or moisture separators, with individual media pads installed to perform the moisture separation function. These pads

'also filter out larger materials in the air flow, but not as their primary function.

The existence of a residue on the demisters had not become a concern, in the past, since this residue had not impaired the results of monthly tests that are conducted to measure mass air flow through the HEPA filters, and thus had not been recognized as detrimental to the operability nor to the combustibility of the demisters.

93072200ih 9'307i4 PDR ADOCK 05000244 8 PDR CZ~f+ P~-TPPgg, Pg~

Inspection Report 50-244/93-06 Page 2 of 3 In preparation for welding and grinding work performed as part of EWR 5275 (Replacement of

, the Containment Recirculation Fan Coolers) (CRFCs), fire protection measures were implemented, including shielding the demisters and HEPA filters from the work area, with Sil-Temp and Herculite. During welding and grinding activities on March 19, 1993, a spark breached the shield boundary, and a fire ensued. The consequences of the fire were exacerbated by the presence of an oily residue on the demisters.

Subsequent to the fire, a sample of the demisters was analyzed. The analysis determined that the oily residue on the demisters was a combination of Reactor Coolant Pump (RCP) oil (type DTE 25 NOCO), resulting from normal RCP operations, and silicone based lubricating oil. This, residue resulted in the demisters being combustible.

Review of the event determined that the shielding installed as protection for the work activities of EWR 5275 was insufficient. Although the NRC inspector concluded that pre-job fire prevention measures were implemented as required, additional conservative measures could have been specified, which would have prevented the fire.

(2) the corrective steps that have been taken and the results achieved:

The immediate corrective action was to stop all hot work activities associated with EWR 5275 on the CRFCs, until the situation could be evaluated. The evaluation was conducted, including additional methods to enhance the fire protection afforded to the CRF demisters. Due to the configuration of the work area for work in progress, the only demisters which could be fully removed were those for the "B" CRF. At the direction- of Fire Protection personnel, these demisters were removed, and the demisters for the "A", "C", and "D" CRFs were completely encapsulated with Sil-Temp. When these demisters were completely encapsulated, the work area was re-inspected by Fire Protection personnel. The work area was also required to have a pressurized water fire extinguisher stationed with the fire watch. (Previous requirements had specified a CO2 extinguisher only. A CO2 extinguisher was found not to be effective for this type of fire hazard.) The fire permit was amended to include these requirements, and then was reissued, and hot work activities were resumed.

As part of the original work scope for EWR 5275, the existing demisters were replaced with new demisters upon completion of the CRFC replacement work. They were replaced prior to April 18, 1993. Plant heatup above cold shutdown occurred after this date, during the 1993 refueling and maintenance outage.

Inspection Report 50-244/93-06 Page 3 of 3 (3) the corrective steps that will be taken to avoid further violations:

Existing plant procedures will be enhanced to provide inspection criteria for visual inspection of the demisters for combustibility. Visual inspections will be conducted and documented on a monthly basis, in accordance with these enhanced plant procedures. These procedures will contain inspection criteria which will consider the recommendations from the manufacturer of the demisters and from a consultant experienced in nuclear safety-related ventilation system testing. This criteria will also incorporate the applicable portions of ANSI-N510, 1989 edition (for consistency with industry standards). When the established criteria is not satisfied, corrective actions will be taken in accordance with the Maintenance Work Control System.

Generic concerns for filters installed in other plant systems have been identified, and will be addressed by programmatic enhancements. These'nhancements will be tracked by CAR 2076.

Fire Protection personnel will, in the future, treat all ventilation filter media as combustible when specifying fire protection measures. Fire Protection personnel will specify appropriate fire protection measures in the "Special Precautions" section of the Fire Permit.

'4) the date when full compliance will be achieved:

Full compliance has been achieved, with the replacement of the demisters during the 1993 outage, and with the conservative measures Fire Protection personnel will use in treating ventilation filter media as combustible. In addition, Rochester Gas and Electric commits to performing inspections of the demisters using these enhanced procedures, by August 15, 1993.

Very truly yours, 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 U.S. NRC Ginna Senior Resident Inspector RCM/ams