ML17309A552

Submits Response to Violations Noted in Insp Rept 50-244/94-17.Corrective Actions:Items Identified by Inspector Appropriately Capped,Plugged or Sealed

ML17309A552
Person / Time
Site:	Ginna
Issue date:	08/26/1994
From:	MECREDY R C ROCHESTER GAS & ELECTRIC CORP.
To:	JOHNSON A R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9409020133
Download: ML17309A552 (6)

See also: IR 05000244/1994017

Text

P R.IC)R.IWY'ACCELERATED

RIDS PROCESSING)

REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9409020133

DOC.DATE: 94/08/26 NOTARIZED:

YES FACIL:50-244

Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G AUTH.NAME AUTHOR AFFILIATION

MECREDY,R.C.

Rochester Gas&Electric Corp.RECIP.NAME

RECIPIENT AFFILIATION

JOHNSON,A.R.

, Project Directorate

I-3 SUBJECT: Submits response to violations

noted in Insp Rept 50-244/94-17.Corrective

actions: items identified

by inspector appropriately

capped, plugged or sealed.DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL I SIZE-TITLE: General (50 Dkt)-Insp Rept/Notice

of Vio ation Response NOTES:License

Exp date in accordance

with 10CFR2,2.109(9/19/72).

DOCKET 05000244 05000244 RECIPIENT ID CODE/NAME PD1-3 PD INTERNAL: AEOD/DEIB AEOD/SPD/RRAB

DEDRO NRR/DRCH/HHFB

NUDOCS-ABSTRACT

~~OGC/HDS3 RES/HFB EXTERNAL: EG&G/BRYCE, J.H.NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME JOHNSON,A AEOD/SPD/RAB

AEOD/TTC NRR/DORS/OEAB

NRR/PMAS/IRCB-E

OE DIR~DR~TL~E 02 RGN1 FILE 01 NOAC COPIES LTTR ENCL 1 1 1, 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37<E>lT.504-2083)TO ELI!iIINATE

YOUR NAME FROM DISTRIBUTION

LISTS f OR DOCUMENTS YOU DON'T NEED!OTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

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ROCHESTER GAS AND ELECTRIC CORPORATION

ROBERT C MECREDY Vice President Clnne Nucleer Production

II c W t/o'roe@~89 EAST AVENUE, ROCHESTER N.K 14649-0001

TELEPHONE AREA CODE 7t8 546'2700 August 26, 1994 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 of Violation Ginna Procurement

Inspection

94-17, dated July 15, 1994 R.E.Ginna Nuclear Power Plant Docket No.50-244 Dear Mr.Johnson: During an NRC inspection

conducted from June 27 through July 1, 1994, a 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: "10 CFR 50, Appendix B, Criterion VIII, states, in part,"Measures shall be established

for the identification

and control of materials, parts, and components," and Criterion XVI, states, in part,"Measures shall be established

to assure that conditions

adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances

are promptly identified

and corrected." Ginna Station,"Quality Assurance Manual," Section No.13,"Handling, Storage, and Shipping" requirement

that states, in part,"...procedures

shall require adherence to supplier's

requirements

or alternate requirements

so that the quality of items is maintained

while they are handled or stored prior to installation

or use," and"Deficiencies

noted during periodic inspections

of storage areas shall be documented

and corrected." Ginna Procedures

A-407,"Evaluation

of Items for In-Storage

Maintenance

Requirements," A-701,"Receipt and Acceptance

of Materials/Parts," and A-1501,"Control of Non-Conforming

Materials," implement the above requirements.

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Letter: 'age 2 Subject: Violation Response 94-17-01 Date;August 26, 1994 Contrary to the above, as of July 1, 1994, handling, preservation, storage, cleaning, packaging, and inspection

activities

associated

with safety-related

items were not properly performed by the Inventory Control personnel in the Ginna Station Level B storeroom in that: (1)items were not stored with protective

caps and plugs;(2)items were not cleaned before being stored in the storage area;and (3)none'onforming

items were not reported on a nonconformance

form by Material, Procurement, and Budget personnel, nor by Quality Assurance personnel as required by Ginna Station Procedure A-1502,"Nonconformance

Reports." This is a Severity Level IV violation (Supplement

1)" The response to the violation is provided separately

for each of the three conditions

stated.A.Response for Items Stored Without Caps and Plugs (1)The reason for the violation, or, if contested, the basis for disputing the violation:

Rochester Gas and Electric Corporation (RG&E)accepts the violation, and acknowledges

that some items were not stored with protective

caps, plugs, or seals.At the time of the NRC inspection, an existing and ongoing packaging upgrade program was in place, and the initial upgrading of packaging had not yet been completed for all items.Therefore, there were still some items, as identi-fied by the.inspector, that had not been adequately

capped, plugged, or sealed.(2)The corrective

steps that have been taken and the results achieved: The items identified

by the inspector were appropriately

capped, plugged, or sealed.Management

completed a comprehensive

inspection

of materials in various storage areas to assess the extent of the missing caps, plugs, and seals.The results indicated that there were only a few isolated cases of missing caps, plugs, or seals.All of these deficiencies

were immediately

corrected.

Management

expectations

and standards regarding the importance

of caps, plugs, or seals have been reaffirmed

to the Inventory Control organization.

(3)The corrective

steps that will be taken to avoid further violations:

The packaging upgrade program will continue.Inventory Control management

will periodically

perform inspections

of materials in selected storage areas to assess the effectiveness

of packaging.

Inventory Control training modules will be reviewed to ensure the issue of adequate packaging is addressed.

Quality Assurance will perform an assessment

of these corrective

steps.

Letter: 'ubject: Date: Page 3 Violation Response 94-17-01 August 26, 1994 (4)The date when full compliance

will be achieved: Full compliance

was achieved for those items with identified

cap, plug, or seal deficiencies

on July 18, 1994, when these deficiencies

were corrected.

B.Response for Items not Cleaned Before Being Stored (1)The reason for the violation, or, if contested, the basis for disputing the violation:

RG&E accepts the violation, and acknowledges

that some Foxboro modules were physically

located in the Level B storeroom and had not been cleaned.The items were in the storage area awaiting formal processing

and integration

into existing stock and thus had not been cleaned.These modules still had an existing film of dust on the terminal ends.(2)The corrective

steps that have been taken and the results achieved: The modules were cleaned to conform to the requirements

for a Level B Storage Area.Management

performed a representative

sampling of items in various storage areas, to assess the extent of cleanliness

concerns.No other items were identified

as not being cleaned.Management

expectations

and standards regarding the importance

of cleanliness

of items in Level B storage areas have been reaffirmed

to the responsible

organization.

(3)The corrective

steps that will be taken to avoid further violations:

Quality Assurance will perform an assessment

of the cleanliness

of items located in storage areas.Inventory Control training modules will be reviewed to ensure the issue of cleaning of items, prior to items being physically

located in storage areas, is addressed.

(4)The date when full compliance

will be achieved: Full compliance

was achieved on July 7, 1994, when these Foxboro modules were cleaned.

Letter: Subject: Date: Page 4 Violation Response 94-17-01 August 26, 1994 C.Response for Nonconforming

Items not Reported The reason for the violation, or, if contested, the basis for disputing the violation:

RG&E acknowledges

that a nonconformance

report (NCR)was not initiated for grease seepage from some Limitorque

limit switches that were in storage.This seepage was previously

identified

by RG&E personnel, who immediately

contacted appropriate

RG&E and site technical personnel to determine the possible need for the initiation

of an NCR.In accordance

with administrative

procedure A-1502,"Nonconformance

Reports", a determination

was made that the grease seepage was not a condition deleterious

to the limit switches, was not a nonconforming

condition, and, therefore, did not constitute

a violation of requirements.

(2)The corrective

steps that have been taken and the results achieved: As a result of this NRC inspection, NCR 94-114 was initiated by Inventory Control to report this condition.

This NCR has been processed.

The results confirm that no nonconforming

condition existed, and that an NCR was not appropriate

for the identified

condition.

RG&E received documentation

from the manufacturer's

engineering

organization

substantiating

the conclusion

that seeping grease is not an issue of concern.The manufacturer

stated that it is a characteristic

of this grease that some oil may separate from the grease base when the grease is dormant for extended periods.Separation

of oil and grease should be expected when a geared limit switch is in storage for long periods.This separation

is not detrimental

to the function of the switch.When a switch is to be removed from storage to be placed in service, the switch should be wiped to remove any accumulation

of oil which may have occurred during storage..Management

investigated

Inventory Control's understanding

of the nonconformance

report program and reviewed NCRs that had been initiated by Inventory Control in the past.The results indicated to management

that Inventory Control personnel have an acceptable

level of understanding

of the nonconformance

report program.The corrective

steps that will be taken to avoid further violations:

Based on the results of the actions taken, no further corrective

steps are needed.

Letter: Subject: Date: Page 5 Violation Response 94-17-01 August 26, 1994 (4)The date when full compliance

will be achieved: RG&E has been, and continues to be, in full compliance.

Very T y Yours, Robert C.Mecredy Subscribed

and sworn to before me on this 26th day of August, 1994 KAP-.4 Q, j()})g~~c+~)Pl:uric: Ill l~~~wAYlvc couypy Cocntni~~~~~(.Q xc: Mr.Allen R.Johnson (Mail Stop 14D1)PWR Project Directorate

1-3 Washington, D.C.20555 U.S.Nuclear Regulatory

Commission

Region I 475 Allendale Road King of Prussia, PA 19406 Ginna USNRC Senior Resident Inspector