Text

Discusses Insp Rept 50-244/96-08 on 960722-26 & 0806-09 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000
	ML20132H066
Person / Time
Site:	Ginna
Issue date:	12/13/1996
From:	Miller H; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mecredy R; ROCHESTER GAS & ELECTRIC CORP.
Shared Package
ML20132H070	List: ML20132H066; ML20132H079;
References
	EA-96-282, NUDOCS 9612270128
	Download: ML20132H066 (5)
	v • d • e

- - - - - - . .

I

f$ [*g UNITED STATES

[ g NUCt. EAR REGULATORY COMMISSION

% ;E REGloN 1

%

% /[ 475 ALLENDALE ROAD

KING oF PRuSstA, PENNSYLVANIA 194061415

l

December 13, 1996

EA 96-282

Dr. Robert C. Meeredy

Vice President, Ginna Nuclear Production

Rochester Gas and Electric Corporation

89 East Avenue

Rochester, New York 14649

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -

$100,000 (NRC Inspection Report No. 50-244/96-08)

Dear Dr. Mectedy:

This letter refers to the NRC special inspection conducted on July 22-26,1996, and

August 6-9,1996, at the Ginna Nuclear Power Station, for which exit meetings were

conducted on August 9, and October 4,1996. The purpose of this inspection was to :

independently evaluate your Motor Operated Valve (MOV) program procedures, I

calculations, and test results (associated with NRC Generic Letter (GL) 89-10, " Safety-

Related Motor Operated Valve Testing and Surveillance") that you had completed in July ,

1995. Based on the inspection, violations of NRC requirements were identified, as

described in the inspection report that was sent to you on October 25,1996. On

November 13,1996, a predecisional enforcement conference was conducted with you and 1

members of your staff to discuss the apparent violations identified during the inspection, j

their causes, and your corrective actions. ;

Based on our review of the inspection findings, and information provided during the l

conference, two violations are being cited and are described in the enclosed Notice of '

Violation and Proposed imposition of Civil Penalty (Notice). The violations involve the

failure to adequately validate design inputs for the Residual Heat Removal (RHR) system

core deluge valves, as well as the failure to adequately correct this condition following its

identification. An outdated and unjustified 0.3 valve factor (a friction coefficient used in

predicting operating thrust requirements) was assumed when calculating the performance

capability of those valves. As a result, you failed to identify that the valve motor actuators

were undersized, and you also failed to adequately verify that the valves would operate

under design basis conditions. Further, although opportunities existed to identify and

correct this condition adverse to quality sooner, you failed to do so.

The RHR core deluge valves are normally closed,6-inch, Velan flex wedge gate valves

located in the containment structure in two parallellines that discharge into the reactor

l vessel. The valves are required to open upon receipt of a safety injection signal to allow

the injection of water from the RHR system into the reactor vessel. The valves also serve

a pressure isolation function as one of the two pressure barriers between the 2235 pounds

per square inch (psi) reactor coolant system and the 600 psi-rated RHR system. Failure of

these two valves to operate, when needed, would significantly degrade the ability of the

9612270128 961213

PDR ADOCK 05000244

G PDR

, _ _ _ _ _ _ _ . _ . . - . _ _ - _ _ _ . - _ . _ _ _ _ . _ _ _ _ _ _ _ . . _ _ . _ _ . _ . _

t

-

j .

4

'

Rochester Gas and -2-

. Electric Corporation

l,

.

'

Iow pressure Emergency Core Cooling System to meet the core cooling requirements

outlined in 10 CFR Part 50, Appendix K. By using the 0.3 valve factor in your calculations

of the thrust requirements for those valves, as part of your analysis in response to Generic

Letter 8910, you did not assure that the valves were capable of performing their intended

j safety function.

!

)

'

The NRC believes that prior opportunities existed to identify and correct this condition, and

to perform appropriate analysis of the valves' capabilities. For example, in April 1995,

j prior to June 28,1995 (the date you committed to complete your Generic Letter 89-10

program), the NRC conducted an inspection of your MOV program. At that time, the NRC

9 inspectors informed your staff that the design inputs for the coro deluge valves needed to

,

be justified (as noted in NRC Inspection Report 95-06) because the 0.3 valve factor being

j used in the calculations was unusually low compared to similar valves in the industry.

Notwithstanding that prior notice, you did not adequately validate the valve design inputs,

t

'

even though in-situ test results of similar MOVs at Ginna suggested valve factors as high

as 0.57. Rather than consider how those test results could affect the core deluge valves, _

l you continued to use the outdated 0.3 valve factor contained in your engineering

j procedures as a basis for determining that the valves would operate as intended.

!

in addition, when statically ratesting the core deluge valves after maintenance during the

l April 1996 refueling outage, you identified that the valves had inadequate margin under

j design conditions. Specifically, you found that the amount of thrust developed in the

i

motor actuators for these valves under degraded voltage conditions was significantly less

than the amount needed to open the valves. Despite the obvious discrepancy between the 1

required and availeble thrust values, you considered both RHR core deluge valves to be J

j operable based on a 1993 " stall test" performed on one of the valves at 100% voltage !

l which indicated that valve would develop more thrust than required. However, this !

! conclusion was inappropriate because the stall test has not been demonstrated to be an !

! accurate preuiction of valve performance under fluid flow and degraded voltage conditions.

i-

l Notwithstanding those prior indications raising questions regarding the operability of the

[ core deluge valves under design basis conditions, appropriate action was not taken until

l the NRC performed a more recent Generic Letter 89-10 MOV closeout inspection.

!

Independent NRC calculations performed for the RHR core deluge valves indicated the

valve motor actuators were undersized. As a result, you shut down the plant on August 3,

1996, and modified the valves, increasing the thrust capability.

! ;

i- Subsequent to the inspection, you conducted significant additional testing and re-analyses

i of the valves and concluded that the valves were, in fact, operable prior to the

j modifications in August 1996. You noted at the enforcement conference that this

l conclusion was based on considerable reanalysis and testing of the valves' capabilities.

.

For example, dynamometer testing of the previously installed motors was recently

performed, and this testing demonstrated a motor output capability in excess of the design

j rating. In addition, in-situ testing indicated that, at this time, the actual stem friction

coefficients for these valves were lower than previously assumed. After factoring these

.

!

f

4

,- ,- - _ , - . . - -

- . - -

,

'

!

-

!

,

1-

Rochester Gas and -3-

Electric Corporation

i

empirical findings and other more realistic assumptions into your calculations, including re-

{ analysis of the dynamic design pressures during, an accident scenario, you concluded that

these valves were capable of opening in a design basis condition. Notwithstanding your

>

contentions, the NRC maintains that uncertainty exists as to whether these valves would

l have opened in a design basis event prior to the modifications made after your shutdown in

August 1996, although further NRC review is not warranted since the modifications have

been completed.

i

in any case, the NRC is concerned that you had not performed an adequate analysis and

verification of the valves' capabilities prior to August 1996, despite the indications, as

i noted herein, that improved analysis was warranted. Given the regulatory significance and j

. duration of these problems, and the significant impact on plant safety if these valves would 1

, not function as intended, the violations described in the Notice have been categorized in l

the aggregate as a Severity Level lll problem in accordance with the " General Statement of j

l

'

Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.

These findings demonstrate the importance of management taking appropriate action to

assure that (1) design inputs for safety-related components are adequately analyzed, and

appropriately verified; and (2) indications of adverse conditions, including inadequate

i analysis, are promptly identified and corrected.

l

, in accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000

'

1 is considered for a Severity Level ill violation or problem ~ Your facility has been the ,

subject of escalated enforcement action within the last two years (namely, a Severity Level !

lil violation without a civil penalty was issued on January 13,1995, for violations of 10 l

CFR Part 26 (EA 94-254). Therefore, the NRC considered whether credit was warranted

for /denti// cation and Conective Action in accordance with the civil penalty assessment

process in Section V1.B.2 of the Enforcement Policy. Credit is not warranted for

/dentification because the violations were identified by the NRC. Credit is warranted for i

i~ Conective Actions because your corrective actions, once the violations were identified by

the NRC, were considered prompt and comprehensive. These actions, which were

, discussed during your presentation at the conference, include, but are not limited to: (1) ;

'

with respect to the specific core deluge valves, replacement of the motor, changing of the

gear ratio, and plans to drill the wedges during the 1999 full core offload; (2) verifying that *

the design inputs for the remaining valves in the Generic Letter 89-10 program were valid;

, (3) modifications to other MOVs in the Generic Letter 8910 program during the current

j

"

outage, including, as needed, drilling of discs, change out of motors, rebuilding of .

actuators, and changing of gear ratios; (4) revision to the Generic Letter 89-10 program

manual to ensure that expectations concerning MOV testing are fully understood and

i testing is performed in a consistent manner; (5) training of your engineering staff to ensure '

,

more critical assessments of your design inputs; and (6) evaluation of Quality Assurance

j oversight of the MOV program.

,

i Therefore, to emphasize the importance of proper analysis of design inputs, and prompt

i

correction of adverse conditions, and in accordance with the civil penalty assessment

j process, a base civil penalty in the amount of $50,000 would normally be issued in this

case. However, I have been authorized, after consultation with the Director, Office of

i

. -- , . .- . . - . .

. - - . . . _ -. - - -

,

.

Rochester Gas and -4-

Electric Corporation

Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional

Operations and Research, to exercise discretion and increase the civil penalty amount to

$100,000 in this case. The NRC is taking this discretionary action because of: (1) the fact

that the condition existed for an extended duration, with prior opportunities for

identification of the problem; and (2) the unacceptability of your staff not taking

appropriate steps to verify adequate design margin for the valves, given the importance of

the RHR core deluge valves to plant safety and despite the NRC questioning the validity of

using a 0.3 valve factor in April 1995, which demonstrated that there was substantial

unesr:ainty with respect to the valves' operability.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response in your response, you should document

the specific actions taken and any additional actions you plan to prevent recurrence. In

your response, you should also address your actions to ensure that opportunities to

identify existing problems are promptly recognized so that appropriate corrective actions

are taken. After reviewing your response to this Notice, including your proposed corrective

actions and the results of future inspections, the NRC will determine whether further NRC

enforcement action is necessary to ensure compliance with NRC regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its enclosure, and your response will be placed in the NRC Public Document Room (PDR).

l

Sincerely, l

-

,

'

ert J. Miller

. Regional Administrator

Docket No. 50-244

License No. DPR 18

Enclosure: Notice of Violation and Proposed imposition of

Civil Penalty

cc w/ encl:

R. Smith, Senior Vice President, Customer Operations

Central Records (7 Copies)

P. Eddy, Director, Electric Division, Department of Public Service, State of New York

State of New York, Department of Law

N. Reynolds, Esquire

F. William Valentino, President, New York State Energy Research and Development

Authority

J. Spath, Program Director, New York State Energy Research and Development Authoritv

._. - . . . _- - .. - ._. .. . - . . - .

1

o'

e

.

Rochester Gas and Electric

Corporation

DISTRIBUTION:

PUBLIC

SECY '

CA

JTaylor, EDO

JMilhoan, DEDR

JLieberman, OE

HMiller, RI

FDavis, OGC

FMiraglia, NRR

RZimmerman, NRR

Enforcement Coordinators

RI, Ril, Rlli, RIV

BBeecher, GPA/PA

GCaputo, 01

DBangart, OSP

HBell, OlG

EJordan, AEOD

OE:Chron

-C,2 - r

DOCS

DScrenci, PAO-RI

l NSheehan, PAO-R1

LTremper, OC

Nuclear Safety Information Center (NSIC)

NRC Resident inspector - Ginna

I

l

,

.

1

[

??000n T2 lf I

\

l

ML20132H066

Text

Navigation menu

Search