ML17261A639

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-244/87-18.Corrective Actions:New Form for Planning, Scheduling & Coordination of Maint Activities Generated to Aid Supervision in Addressing Adequacy of Maint Controls

ML17261A639
Person / Time
Site:	Ginna
Issue date:	10/09/1987
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8710270075
Download: ML17261A639 (14)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR: 8710270075 DOC.DATE: 87/10/09 NOTARIZED:

NO DOCKET FACIL: 50-244'Robert Emmet Ginna Nuclear Planti Unit ii Rochester G 05000244 AUTH.NAME AUTHOR AFFILIATION OBERi R.W.Rochester Gas h ElectT ic'Corp.RECIP.NAME RECIPIENT AFFILIATION RUSSELLi W.T.Region ii Ofc of the Director

SUBJECT:

Responds to NRC ltr re violations noted in Insp Rept 50-244/87-18.

Corrective actions: nee form for planning.scheduling 5 coordination of maint activities generated to aid supervision in addressing adequacy of maint controls.DISTRIBUTION CODE: IEOID COPIES RECEIVED: LTR I ENCL D SIZE:&TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: License Exp date in accordance eith 10CFR2i 2.109(9/19/72).

05000244 RECIPIENT ID CODE/NAME PDi-3 PD INTERNAL: AEOD NRR MOR I SBEAUi D NRR/DREP/EPB NRR/DRIS DIR OE MANi J EG FILE 1 FILE 01 TERNAL: LPDR NBIC COP IEB LTTR ENCL RECIPIENT ID CODE/NAME STAHLEi C DEDRO NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ILRB OGC/HDB2 RES DEPY GI NRC PDR COPIES LTTR ENCL 1 1 2 1 1 TOTAL NUMBER OF COPIES REQUIRED:.

LTTR 20 ENCL CIV ROCHESTER (rw.~'...'.f, (~i, c in'&iih47lON c 89 EAST AYENUE, ROCHESTER, N.Y nfl ln 14649.0001 HOGE',R Yr M.LL.)i vKL nncs.<<L"', r.t.rcTA>c, ply(Dt-" i t TCLrnKOHE.

inrun ccor.~ir, 546-2700 Ginna Station Oct'ober 09, 1987 Mr.William T.Russell Regional Administrator U.S.Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussi.a, PA 19406

Subject:

.Inspection Report 50-244/87-18 Notice of'iolation R.E.Ginna Nuclear Power Plant Docket No.50-244 I

Dear Mr.Russell:

Rou tine Inspection Report 50-244/87-18, Appendix A, stated in part': "During an i nspect'i on conducted on March 15, 1987 t'hrough April 1.8, 1,987, and in accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions 10 CFR Part 2, Appendix C (Enforcement Policy 1986), the following violation vas identified:

Techni cal Specification 6.8.1 states that vri t ten procedures shall be established, implemented, and maintained covering activities referenced in Appendix A of Regulatory Guide 1.33, November 1972.Appendix A, Paragraph I"Procedures for Performing Maintenance" discusses control of maintenance and repair.ga-eo L>9 Contrary to the above, on Apri l 9, 1987, the li censee failed to control safety-related maintenance in that,.Gi nna Station Maintenance Work Request Trouble Report 8 7-208 0 written t'o adjust a packing leak of Motor Operated Valve (MOV)860B (contai nment spray pump"A" discharge valve)vas designated as"Non-QA" work by the responsi bl e maintenance reviewer.Furthermore, af ter performing the above maintenance, no post-maintenance test'i ng of MOV 860B vas performed to demonstrate operability".

8710270075 872009 PDR ADOCK 05000244 8 PDR Ill' Page 2 Inspection Report 87-18 October 09, 1987 Rochester Gas and Electric Corporation agrees with the above violation in that Technical Specification 6.8 states that written procedures shall be establi shed, implemented and maintained covering activities referenced in Appendix A of Regulatory Guide, 1.33, November 1972.MOV 860B is a QA item requiring post-maint-enance testing.We had already recognized potential weaknesses in our maintenance controls prior to this violation, and had been preparing corrective actions to address control of maintenance activities and post-maintenance testing of maintenance activities; Cause for violation:

The root cause of this event was inadequate identification, review, planning and control of maintenance activities when conducted using the Ginna Station Maintenance Work Request Trouble Report (MWRTR).Had this work order been written or reviewed or cl assi fi ed or planned properly, existing procedures and controls over maintenance'ctivities would have guided maintenance personnel through the proper steps.a~The valve was incorrectly identified by the initiator as"V-860B Containment Spray Pump A".The fact that the valve was not designated as a Motor Operated Valve (e.g.MOV 860B)made it less likely that maintenance supervision would recognize the automatic function and testing requirements associated with the maint-enance on this valve.b.The MWRTR was reviewed by the proper maintenance supervision, as defined in Step 3.2.1.1 of Admini s-trative Procedure A-1603.However, it is apparent that some items that are delineated in Step 3.2.3 of A-1603 for review were not correctly evaluated when reviewing this work order."Notify the Shi'f t Supervisor prior to start".This item was not checked.A-1603 states!'This should be checked for work that directly effects plant operation or directly effects the function of safety-related or.Tech.Spec.equipment on.systems".This item should have been checked.

T Pa,ge 3 Inspection Report 87-18 October 09, 1987~~L2."Notify QC prior to start".This item was not checked.A-1603 states that'this be checked,"For work performed'by the Maintenance group where QC coverage will be required".

Any motor operated val ve maintenance woul d normally require QC coverage.This item should have been checked.i iv."Notify R&T upon completion".

This item was not checked.A-1603 states"should be checked to identify where Results&Test Group must test the equipment after mai ntenance".Any valve identified in the Ginna Station Quality Assurance Manual Appendix C is required to have this item checked.Because the valve was incorrectly identified as a manual valve, and was not recognized as a Motor Operated Valve, Maint-enance supervision di d not realize that the valve on the referenced work order was an Appendix C val ve.Thi s item should have been checked."Notify the Shift Supervisor upon completion".

Thi s item was not checked.A-1603 states that"This should be'checked if 4.1 (notify Shift Supervisor prior to start)was required".

This item should have been checked.Ce Several opportuni ti'es existed for licensee personnel'o identify that this valve was a MOV covered by Technical Specifications.

As stated in the Inspection Report,"the pipefitter who performed the work di d not question the reviewer~s decision and adj usted the packing".Ve recognize that the pipefitter and Pipefitter Foreman are not the pr'imary individuals

'responsible for the pre-planning and interface activities of a parti cular j ob, but acknowledge that they should have questioned the HVRTR reviewer's decision.

I Page 4 I'nspection Report 87-18 October 09, 1987 2 0 Corrective steps which have been taken and the results achieved: a.A review and root cause analysis of the event was performed.

b.c The Pipefitter Foreman held a documented trainirig cl ass with all pi pefi tters on Apri l 23, 1987 to discuss the importance of proper review and control of maintenance work orders and requirements for post-maintenance testing on AOVs and MOVs.The Maintenance Manager held a consul tati on session with those maintenance supervision who review hSRTRs on the importance of control of maintenance activities'.

MWRTRs 87-2133 and 87-2167 were performed.

to assure that the packing adjustment minimized system leakage with CV spray pump discharge pressure applied at MOV 860B, f ol 1 owed by post-maintenance testing per the appli cable steps of procedure PT-3,"Containment Spray Pumps and NaOH Additive System".These items were completed on April 10 and May 1,4,~1987, respectively.

e.The Maintenance Manager held a briefing session on this subject at the Maintenance Foremen's Meeting of April 23, 1987.3.Corrective steps which have been or wi l 1 be taken to prevent recurrence:

a~A new form for planning, scheduling and coordination of maintenance activities has been generated to ai d supervision in addressing the adequacy of maintenance controls.These forms were first distributed within the"Ginna Station'ctivities Schedule for the Peek of 6/1/87 through 6/7/87".

gill Page 5 Inspection Report 87-18 October 09, 1987 b.c The Ginna Station Maintenance Section has been organized to provide more structure for formally reviewing and controlling maintenance activities performed using the MWRTR.Included in this reorgan-ization is the use of a licensed Senior Reactor Operator to review all MWRTRs for Technical Specifica-tions, impli cations, operating and planning require-ments, and the use of a Quality Control Engineer to review all MWRTRs for applicability of proper Quality Assurance requirements.

A new MWRTR Form will be prepared, to improve the form for documentation of reviews and control of activities.

d.permanent reorganization of the Ginna Station Maintenance Section.'.Date when full compliance was achieved: a.Full compli ance with Technical Specification 6.8.1 was achieved on May 14, 1987, when the valve passed PT-3 satisfactorily.

Full compliance to implement organizational structure and controls for maintenance activities was completed with the temporary restructuring of the Ginna Station Maintenance Section on May 6, 2987..The cover letter also requested Rochester Gas and Electric to provide the results of our review on the practices of entering Technical Specification action statements when out-of-specification chemi cal analysis are obtained.The following is a summary of-our results in this review: We believe that reanalysis of a sample is warranted when prelimi nary resul ts deviate significantly from the results of prior samples or expected values, especially when dependent parameters have not changed.Resampling and reanalysis are a significant part of the confirmation process in the required supervisory review'and acceptance of preliminary data.This is of parti cular importance, as in this case, where a significant procedural change was made in the analytical process and was being implemented for the first time.

Page 6 Inspection Report 87-18 October 09, 1987 We do not consider confirmatory, assurance of quality actions by the supervisory personnel, required to approve initial grab sample results, as an accepted"grace period".The Corporate and Station Management has a strong commitment, backed up by appro-pri a te admi ni s trati ve control s, to assure strict compli ance to Technical Specification requirements in the event of unacceptable results in any surveillance.

The event discussed in this Inspection Report was complicated by the decision to initiate an A-25.1, Ginna Station Event Report.The purpose of initiating the A-25.1, was to ensure that proper plant technical personnel were involved in the assessment of the situation and was not intended to indicate acceptance of the preliminary results.Notification of the Operations personnel of a potential problem wi th an analysis is a normal laboratory practice, since they are aware.of changing plant conditions that can effect the analytical results.This is an important step in determining the validity of the analysis.Normally, the notifica-tion and interface with the Control Room personnel have been performed verbally, but in this case an A-25.1 was initiated to assure that all on duty shifts during the reanalysis would be aware of all the facts during the evaluation.

We believe continuation of our required supervisory approval steps in all surveillance is necessary to ensure safe operation of the plant.With the approval authority, comes the responsi-bility to verify the validity of the results obtained along with the responsibility for prompt assessment of all potential safety concerns using input from all areas of expertise.

V truly yours, Roger W.Kober Vice-President Electri c Production attachment xc: Document Control Clerk Cll'lll