ML17264A410

LER 96-001-00:on 950504,inservice Test Not Performed During Refueling Outage.Caused by Inadequate Tracking of Surveillance Frequency.Valve Test Performed & Disassembled. W/960318 Ltr

ML17264A410
Person / Time
Site:	Ginna
Issue date:	03/18/1996
From:	Mecredy R, St Martin J ROCHESTER GAS & ELECTRIC CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-001, LER-96-1, NUDOCS 9603250024
Download: ML17264A410 (8)

Text

CATEGORY 1

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REGULATORY INFOR'>ATION DISTRIBUTION YSTEM (RIDS)

ACCESSION NBR:9603250024 DOC.DATE: 96/03/18 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION ST,MARTIN,J.T Rochester Gas a Electric Corp.

MECREDY,R.C. Rochester Gas a Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 96-001-00:on 950504,inservice test.not performed during refueling outage. Caused by inadequate tracking of surveillance frequency. Valve test performed & disassembled.

W/960318 ltr.

DISTRIBUTION CODE: ZE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 Q RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-1 PD 1 1 JOHNSON,A 1 1 INTERNAL: AEOD /RAB 2 2 AEOD/SPD/RRAB 1 1 1 1 NRR/DE/ECGB 1 1 NR DE 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 RES/DSIR/EIB 1 1 RGN1 FILE 01 1 1 EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE,J H 2 2 NOAC MURPHYiG.A 1 1 NOAC POOREgW. 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 NOTE TO AI,L "RIDSi'ECIPEENTSl PLEASE HELP US TO REDUCE MASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM OHFN 5D-5(EKT 415-2083) TO EL?M?NATE YOUR NAME FROM D1STRKDUT1ON LISTS FOR DOCUMENTS YOU DON'T NEEDI FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

AND CODEX'6 ROCHESTFR GAS AND flf'CfRICCORPORATON ~ 89 FASTAVEIVUF, ROCHESTER, M Y. ld649 ROI ~ ARFA SJ627GO ROBERT C. MECREDY V'ce Prepaid'err Hecfcaf Oocrotioes March 18, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson PWR Project Directorate I-1 Washington, D.C. 20555

Subject:

LER 96-001, Inservice Test Not Performed During Refueling Outage, Due to Inadequate Tracking of Surveillance Frequency, Resulted in Violation of Technical Specification R.E. Ginna Nuclear Power Plant Docket No. 50-244 In accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2) (i) (B), which requires a report of, "Any operation or condition prohibited by the plant's Technical Specifications", the attached Licensee Event Report LER 96-001 is hereby submitted.

This event has in no way affected the public's health and safety.

Very truly yours, Robert C. Mecredy xc: U.S. Nuclear Regulatory Commission Mr. Allen R. Johnson (Mail Stop 14B2)

PWR Project Directorate I-1 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

~50015 q603250024 p60 18 PDR ADOCK 050 PDR 8

NRC FORM 366 U.S. NUCLEAR REOULATORY COMMISSIO APPROVED BY OMB No. 316&4104 (4-SSI . EXPIRES 04/30/96 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH 1HIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS.

LICENSEE EVENT REPORT (LER) REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSINO PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDINQ BURDEN ESTIMATE TO THE (See reverse for required number of INFORMATION AND RECORDS MANAOEMENT BRANCH IT-6 F33).

digits/characters for each block) U.S. NUCLEAR REGULATORY COMMISSION. WASHINGTON. DC 2055~1 AND TO THE PAPERWORK REDUCTION PROJECT ACIUTY NAME III DOCKET NtaNQl (2) PACE f2l R.E. Ginna Nuclear Power Plant 05000244 1 OF6 YlTLE Ie)

Inservice Test Not Performed During Refueling Outage, Due to Inadequate Tracking of Surveillance Frequency, Resulted in Violation of Technical Specification EVENT DATE (6) LER NUMBER (6) REPORT DATE l7) OTHER FACIUTIES INVOLVED (6)

SEOUL ~aON MONTH DAY YEAR FACIUTY NAME OOCKETNUMSER HUSKIER NVhBl FAClUTY NAME OOCKET NUMSEN 05 04 95 96 001 00 03 1 8 96 OPERATINO THIS REPORT IS SUBMITTED PURSUANT To THE REQUIREMENTS OF 10 CFR i: (Check one or mora) (11)

MODE (9) N 20.2201(b) 20.2203 (a) (2) (v) X 50.73(a)(2)(i) 50.73(a)(2)(viii) 20.2203(a) (1) 20.2203(a) (3) (i) 50.73(a)(2)(ii) 50.73(a) (2) (x)

POWER LEVEL (10) 97 20.2203(a) (2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2) (ii) 20.2203(a)(4) 50.73(a) (2)(iv) OTHER 20.2203(a) l2)(iii) 50.36(c) (1) 50.73(e) (2) (v) Specify In Abetrect bebw or In NRC Form 366A 20.2203(e) l2)(iv) 50.36(c)(2) 50.73(a)(2)(vii)

UCENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NVMSEIt Orrdude Aree Codel John T. St. Martin - Technical Assistant (716) 771-3641 COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT l13)

REPORTABLE REPORTASIE SYSTEM COh4%NENT MANUFACTURER TO NPRDS SYSTEM CO&ANENT MANUFACTURER TO NPADS SUPPLEMENTAL REPORT EXPECTED l14) EXPECTED MONTH DAY YEAR YEB SUBMISSION (If yas, complete EXPECTED SUBMISSION DATE).

X No DATE (16)

ABSTRACT (Umit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On February 15, 1996, at approximately 0830 EST, the plant was at approximately 97% steady state reactor power. During activities not related to plant operations, it was identified that an inservice test on a valve, requiring the valve to be disassembled, full-stroke exercised and inspected each refueling outage, had not been performed in the time frame identified in a Relief Request to ASME Section XI Code requirements. Not performing this inservice test during a refueling outage is a condition prohibited by the plant's Technical Specifications.

Corrective action was taken to perform the required test of the valve. The valve was disassembled, full-stroke exercised and inspected on February 22, 1996.

The underlying cause of not performing this inservice test during a refueling outage was inadequate tracking of the surveillance frequency. This event is NUREG-1022 Cause Code (E).

Corrective action to prevent recurrence is outlined in Section V.B.

NRC FORM 366 (4.85)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION I4-6SI LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAME I1I DOCKET LER NUMBER I6I PAGE I3I YEAR SEQUENTIAL REVISION NUMBER NUMBER 2 OF 6 R.E. Ginna Nuclear Power Plant 05000244 96 001 00 TEXT (Ifmore spece is required, use edditionel copies of fVRC Form 366AI {17)

PRE-EVENT PLANT CONDITIONS:

There are two Standby Auxiliary Feedwater (SAFW) System service water (SW) suction check valves that are required to be tested in accordance with the Ginna Station Inservice Pump and Valve Testing Program (IST Program) These check valves are V-9627A and V-9627B. In lieu of full-stroke exercising each

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check valve quarterly, Relief Request No. VR-5 (RR VR-5) defines the testing requirements for these two valves to verify operability and satisfy the requirements of the Ginna Technical Specifications (TS) and the IST Program. RR VR-5 requires that "One valve will be disassembled, full-stroke exercised and inspected

'each refueling outage on a rotating basis." These actions had been satisfactorily completed during previous refueling outages.

During a self-assessment of testing requirements for all valves in the IST Program, the IST Engineer and the Results and Test (R&T) Supervisor conducted a complete review of testing requirements. While reconciling this data and matching American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code)Section XI requirements with performance schedules and completion dates for valves, it was identified that V-9627A had been disassembled and full-stroke exercised on July 19, 1994, prior to, but not during, the 1995 refueling outage. Planned corrective maintenance was performed on the "A" train of the SAFW system on July 19, 1994. An inspection of V-9627A was also performed at this time, rather than defer the work to the 1995 outage. This satisfied the maintenance frequency established for the year 1995. Therefore, this work was not repeated during the 1995 refueling outage.

The requirements of RR VR-5 were not met, in that V-9627A had not been disassembled during the 1995 outage. The 1995 outage started on March 26, 1995, and ended on May 4, 1995. Therefore, the event date is May 4, 1995.

DESCRIPTION OF EVENT:

DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES:

April 28, 1993: V-9627A is disassembled and full-stroke exercised during the 1993 refueling outage.

March 28, 1994: V-9627B is disassembled and full-stroke exercised during the 1994 refueling outage.

July 19, 1994: V-9627A is disassembled and full-stroke exercised.

May 4, 1995: Event date.

February 15, 1996, 0830 EST: Discovery date and time.

February 20, 1996, 1622 EST: The "A" train of the SAFW system is declared inoperable.

February 22, 1996, 1714 EST: V-9627A is disassembled and full-stroke exercised, and the "A" train of the SAFW system is declared operable.

NRC FOAM 366A (4-95I

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION I4.99)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME I1) DOCKET LER NUMBER I6) PAGE I3)

YEAR SEQUENTIAL REVISION NUMBER NUMBER 3 OF 6 R.E. Ginna Nuclear Power Plant 05000244 96 001 00 TEXT llfmore space is rettrdred, use additional copies of IVRC Form 366A/ (17)

B. EVENT:

On February 15, 1996, the plant was at approximately 97% steady state reactor power. During activities not related to plant operations, the IST Engineer and RLT Supervisor had completed a self-assessment of the recent test dates for V-9627A and V-9627B. Since V-9627A was not disassembled and full-stroke exercised during the 1995 refueling outage, Operations management was notified. At approximately 0830 EST on February 15, management concluded that V-9627A had not been tested in accordance with the IST Program.

On February 20, 1996, an operability assessment was completed. This assessment concluded that not testing during the 1995 outage resulted in an inoperable SAFW train. It was determined that not performing this test during the 1995 refueling outage is not consistent with TS 4.2.1, which states, in part, "This inservice pump and valve testing program shall be in accordance with Appendix C of the Ginna Station Quality Assurance Manual." Management directed that V-9627A be tested.

The "A" train of the SAFW system was declared inoperable at approximately 1622 EST on February 20, 1996, as per TS 3.4.2.3a. V-9627A was disassembled and full-stroke exercised by 1714 EST on February 22, 1996.

C. INOPERABLE STRUCTURES, COMPONENTS, OR SYSTEMS THAT CONTRIBUTED TO THE EVENT:

None D. OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED:

None E. METHOD OF DISCOVERY:

This event became apparent during the self-assessment of the IST Program, when it had been determined that V-9627A had not been tested during the 1995 refueling outage. The operability assessment determined that disassembly and full-stroke exercise for V-9627A had not been performed in accordance with the requirements of RR VR-S, as required by the Code, TS 4.2.1, and Appendix C of the Ginna Station Quality Assurance Manual.

NAC FCRM 366A I4-95)

NRC FORM 368A U.S. NUCLEAR REGULATORY COMMISSION (4-95)

LZCENBEE EVENT REPORT {LER)

TEXT CONTINUATION FACILITY KAME (1) DOCKET LER NUMBER (6) PAGE (3 YEAR SEQUENTIAL REVISION NUMBER NUMBER 4 OF 6 R.E, Ginna Nuclear Power Plant 05000244 96 001 00 TEXT iifmore spece is required, use additionsi copies of NRC Form 366A/ (17)

F. OPERATOR ACTION:

After an operability assessment was completed, supervision notified the Control Room operators that this inservice test was required, and directed the Maintenance group to perform the surveillance. The Control Room operators declared the "A" train of the SAFW system inoperable, at approximately 1622 EST on February 20, 1996. The A train of the SAFW system was declared operable at approximately 1714 EST on February 22, 1996, after completion of valve disassembly and full-stroke exercising.

G. SAFETY SYSTEM RESPONSES:

None III ~ CAUSE OF EVENT:

A. IMMEDIATECAUSE:

The immediate cause of not performing this inservice test during the 1995 refueling outage was inadequate tracking of the required frequency for performing this surveillance. As stated above, this valve was disassembled during the 1993 outage. The Valve Preventive Maintenance Analyst established the schedule for valves for the year 1995 in mid-1994. An opportunity to disassemble this valve occurred in July, 1994, when the "A" train of the SAFW system was removed from service for planned corrective maintenance. Additional preventive maintenance activities were also performed at this time. One of the activities performed for the "A" train of SAFW was to disassemble V-9627A, on July 19, 1994.

When scheduling valve activities for the 1995 refueling outage, work on V-9627A had been performed in July, 1994, so V-9627A was not included in the scope of activities for the 1995 refueling outage.

B. INTERMEDIATE CAUSE:

The intermediate cause of not performing this inservice test during the 1995 outage was that the performance time limitations were not recognized, and the surveillance was inappropriately implemented prior to the 1995 refueling outage.

)IRC FORM 386A (4.96)

C" NRc FQRM 366A U.S. NUCLEAR REGULATORY COMMISSION 4-9S).

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAME I1) DOCKET LER NUMBER (6) PAGE I3)

YEAR SEQUENTIAL REVISION NUMBER NUMBER 5 OF 6 R,E. Ginna Nuclear Power Plant 05000244 96 001 00 TEXT /ffmore speceis required, use eddilionel copies of NRC Form 366AJ I17)

C, ROOT CAUSE:

The underlying cause of not performing this inservice test during the 1995 refueling outage was that there was no process for ensuring that scheduling frequencies of the IST Program are tracked by one group who is knowledgable of these IST Program requirements. This tracking only occurred for those activities associated with Periodic Test (PT) procedures.

This event is NUREG-1022 Cause Code (E), "Management/Quality Assurance Deficiency". Not performing this surveillance during the 1995 outage does not meet the NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants", definition of a "Maintenance Preventable Functional Failure".

IV. ANALYSIS OF EVENT:

This event is reportable in accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2) (i)

(B), which requires a report of, "Any operation or condition prohibited by the plant's Technical Specifications". Not performing this surveillance constitutes a condition prohibited by the Ginna TS.

An assessment was performed considering both the safety consequences and implications of this event with the following results and conclusions:

There were no operational or safety consequences or implications attributed to not performing this surveillance because:

o Not performing the inservice test during a refueling outage, as required by RR VR-5, did not affect the public's health and safety in that the testing of the valves per the IST Program (as specified in TS 4.2.1) is intended to measure degradation of valve performance.

o The basis for the sample disassembly and inspection schedule requested by RR VR-5 originates from NRC Generic Letter (GL) 89-04, Position 2.c. The disassembly and full-stroke exercising of each valve on an alternate refueling basis was a conservative application of the guidance provided by GL 89-04, based on a two valve group size and twelve (12) month reactor cycle.

o The check valve surveillance frequency was conservative in that the originally scheduled service period between inspections was not exceeded.

o Maintenance history records documenting the previous disassembly and inspection results for V-9627A and V-9627B indicate that no degradation or mechanical interferences were found and that the check valves required only minor cleaning.

Based on the above, it can be concluded that the public's health and safety was assured at ail times.

NAC FORM 366A I4 9s)

C ~

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION I4-95),

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAME I1) DOCKET LER NUMBER )6) PAGE I3)

YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 6 OF 6 05000244 96 001 00 TEXT iifmere spece is required, use edditionel copies of NRC Form 366Ai l17]

V. CORRECTIVE ACTION:

A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:

Disassembly and full-stroke exercising of V-9627A was performed on February 22, 1996.

B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE:

The 1996 outage scope includes a disassembly, full-stroke exercise, and inspection for V-96278.

The 1997 outage scope will include a disassembly, full-stroke exercise, and inspection for V-9627A.

One group will be assigned responsibility for tracking all surveillance activities associated with compliance with scheduled frequencies for IST or ASME Code requirements.

VI. ADDITIONALINFORMATION:

A. FAILED COMPONENTS:

None B. PREVIOUS LERs ON SIMILAR EVENTS:

A similar LER event historical search was conducted with the following results: No documentation of similar LER events with the same root cause at Ginna Nuclear Power Plant could be identified.

C, SPECIAL COMMENTS:

None NRC FORM 366A I4-95)