ML20024E217
| ML20024E217 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/27/1983 |
| From: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20024E215 | List: |
| References | |
| NUDOCS 8308090439 | |
| Download: ML20024E217 (3) | |
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-s 43 ROCHESTER GAS AND ELECTRIC CORPORATION
- 89 EAST AVENUE, ROCHESTER, N.Y.14649 W
JOHN E. MAIER
.TrttPMoht v.c. pr..=wne 4.c4 caos vic 546 2700 July 27. 1983 Dr. Thomas E.
Murley, Regional Administrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Subject:
I & E Inspection Report 83-13 Notice of Violations Failure to Notify the Maintenance Department that the Containment Equipment Hatch Door Seal Leakrate Exceeded the Maximum Acceptable Administrative Limit and Containment Spray Pumps in Pull /Stop Position Above 200 Degrees RCS Temperature R.
E.
Ginna Nuclear Power Plant,-Unit No. 1 Docket No. 50-244
Dear Dr. Murley:
In accordance with the above subject which stated "As a result of the inspection conducted on May 8, 1983 through June 16, 1983, and in accordance with the NRC E n f o r'c em e n t Policy (10 CFR 2,' Appendix C) published in the Federal Register on March 9,
1982 (47 FR 9987) the following violations were identified:
A.
Criterion V states in part, " Activities affecting quality shall be prescribed'by procedures and shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Periodic Test Procedure (PT)-22.1, Equipment Hatch Door Seal Leakrate Test,. Revision 7, requires that if the leakrate exceeds the maximum acceptable limit of 50 cubic centimeters / minute (cc/ min),
the Maintenance Department is to be notified to make a latch adjustment or replace the door gasket prior to retesting.
8308090439 830002 PDR ADOCK 05000244 g
~
~
Contrary to the above,_d'uring the performance--
of PT-22.1 on March 23, 1983, the -equipment hatch' door ~ seal leakrate exceeded-the maximum acceptable limit of 50 cc/ min; however,-the-Maintenance
. Department was noti notified, or retesting performed.
1:arther, subsequent supervisoryLreview on March 26, 1983. failed to identify that'the acceptance criteria was exce'eded.
B.
Technical Specification 6.8.1 states in_part,-
s
~ " Written procedures shall be established, implemented and maintained..."
Refueling Shutdown _ Surveillance Procedure
( RSS P ) - 2.'1, Safety Injection Functional Test, Revision 21 step 6.1.11.5 requires charging. flow to be secured prior to simulating-
. safeguards signals.
Operating-Procedure (O)-1.lD, Pre-Heatup Plant Requirement Check List, Revision 16, step 5.1.1. 6 -' requires the containment spray-pumps to be operable before-the-reactor coolant-system temperature.is raised above 200 degrees.
Contrary to the above, the following instances of failure to implement procedures were identified:
Du ring _ performance of RSSP-2.1-on June 9,.
'1983 charging flow was not secured _ prior.
to simulating safeguard signals,~resulting in actuation ' of the Overpressure Protection System.
On June 13, 1983 the reactor coolant system temperature was raised above 200 degrees with the containment spray pumps inoperable.
the following is submitted in response.-
Corrective action to address these violations are as follows':-
For. item A, procedure PT-22.1 " Equipment Hatch Door Seal-Leakrate Test" has been changed to further emphasize the
-50 cc/ min maximum acceptable limit.
It should be noted that the actual leakage measured by the March 23, 1983 test was only 58.4 cc/ min which is well below the Technical Specification allowable leakage rate of _.60 La (approximately 22,900 cc/ min).
Additionally, testing personnel have been 4
reminded of the importance.to verify test results are within the acceptance criteria limits and to take_ appropriate action if these limits are exceeded.
Full compliance has already been achieved.
a.
)
o.
s For item D,
a change to Refueling Shutdown Surveillance Procedure (RSSP)-2.1 " Safety Injection Functional Test" has been submitted that-will caution operators and test personnel of the importance to secure charging and letdown prior to simulating a safety injection signal as failure to do so could result in a pressure excurison causing operation of the reactor overpressure protection system.
Full compliance has already been achieved.
Also for item B,
while in the process of changing modes of operation-(Cold Shutdown to Hot Shutdown) the Containment Spray pumps were found to be in the pull /stop position with Reactor Coolant temperature at 207 degrees fahrenheit.
Procedure O-1.lD required that Containment Spray be operable prior to leaving Cold Shutdown ( < 2000F).
The Operators had mis-interpreted and considered the system operable at that time, but placed the pumps in pull / stop to guard against an inadvertent actuation of ' Containment Spray while Personnel were working inside Containment.
Discovery of the situation was made long before this could have created a hazard to the health and safety of the public.
Operating Personnel were reminded of the requirements, and an immediate change in 0-1. lD specifically defines operability and cautions against pumps being positioned such that the system would be rendered inoperable.
Very Truly Yours, John E.
Maier Subscribed and sworn to me on th' 27 of J 1983 a/1 y
vf r-WILLis L.
HULZE NOTARY PUBUC, State of N.Y., Monroe County My Comm ssion Expires March 30,196 i