ML17309A628

Provides Response to Violations Noted in Insp Rept 50-244/97-12.Corrective Actions:Edg Mechanic Counseled by Mechanical Maint Mgr on Policy for Resolution of Data Outside Acceptance Criteria

ML17309A628
Person / Time
Site:	Ginna
Issue date:	03/13/1998
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-244-97-12, NUDOCS 9803250127
Download: ML17309A628 (7)

See also: IR 05000244/1997012

Text

ROCHESTER GAS AND ELECTRIC CORPORATION

~89 EAST AVENUE, ROCHESTER, N.K 14649-0001

10IC rr Jr(ROBERT C.MECREDY Vice president Nuclear Operations

rr.r.r~o~r Aer.i cour.sir 546.2700 March 13, 1998 U.S.Nuclear Regulatory

Commission

Document Control Desk Attn: Guy S.Vissing Project Directorate

I-1 Washington, D.C.20555 Subject: Reply to a Notice of Violation NRC Integrated

Inspection

Report 50-244/97-12

and Notice of Violation, dated February 9, 1998 R.E.Ginna Nuclear Power Plant Docket No.50-244 Dear Mr.Vissing: Rochester Gas and Electric (RG&E)provides this reply within 30 days of receipt of the letter which transmitted

the Notice of Violation.

During an NRC Inspection

conducted on November 17 January 4, 1998, a violation of NRC requirements

was identified.

1n accordance

with the"General Statement of Policy and Procedure for NRC Enforcement

Actions," NUREG-1600, the violation is listed below: n10 CFR 50, Appendix B, Criterion V requires that activities

affecting quality be prescribed

and accomplished

in accordance

with documented

procedures

and instructions, and that these procedures

include appropriate

quantitative

or qualitative

acceptance

criteria for'etermining

that important activities

have been satisfactorily

accomplished.

Nuclear Directive ND-MAI, RMaintenance," required that unexpected

problems be documented, and that any deficiencies

identified

be reported in accordance

with the Corrective

Action Program.Maintenance

Procedure M-15.1M,"A or B Diesel Generator Mechanical

Inspection

and Maintenance," step 5.20.1.h required that the emergency diesel generator highest and lowest firing pressures be recorded at full engine load, and specified that the difference

between the highest and lowest pressures must not exceed a maximum of 150 pounds per square inch.eDR AoocK osaaoaee 9803i3 8 PDR

Page 2 Contrary to the above, on May 3, 1996, and November 11, 1997, the acceptance

criteria in maintenance

procedure M-15.1M were not met during post-maintenance

testing of the B-emergency

diesel generator (B-EDG).In both instances, the difference

between the highest and lowest firing pressures for the B-EDG engine was recorded above the maximum allowable limit specified by procedure M-15.1M.The unacceptable

data was not resolved in accordance

with the licensee's

Corrective

Action Program, or justified and documented

as acceptable

before the B-EDG was returned to'ervice." (1),, the reason for the violation, or, if contested, the basis for disputing the violation or severity level: Rochester Gas 6 Electric Corporation (RGEE)accepts the violation.

We acknowledge

that EDG performance

data was not properly resolved relative to established

acceptance

criteria and the Corrective

Action Program.The collection

of EDG firing pressure data is based on guidance from the EDG vendor manual.Historically, such data was collected and documented

in Maintenance

Procedure M-15.1.2,"A or B Diesel Generator-Obtain Cylinder Firing Pressure'at Full Load", at t'e same time as periodic testing of the EDG was being performed (using Surveillance

Test Procedure PT-12.1 or PT-12;2,"Emergency

Diesel Generator A" and"Emergency

Diesel Generator B")~The data collection

was scheduled prior to planned EDG maintenance

overhauls.

This data was one of the sole indicators

of EDG condition, and was provided to the original equipment manufacturer (OEM)field services representative

for use in planning any needed maintenance

.during the subsequent

overhaul.The OEM'epresentative

.is contracted

to provide guidance and be-present during the EDG maintenance

overhaul.After completion

of EDG maintenance

overhauls, data (to verify that proper adjustments

and engine performance

are acceptable)

is obtained during the restoration

of the EDG to service.Procedures

PT-12.1 or PT-12.2 are used for post-maintenance

testing (PMT)and, operability

performance

testing (OPT).Documentation

of the firing pressure is recorded in Maintenance

Procedure M-15.1M, ,"A or B Diesel Generator Mechanical

Inspection

and Maintenance", at this time.In the past'wo years, Ginna Station has taken additional

measures to determine EDG engine condition by contracting

with an EDG engine analysis contractor.

This type of engine analysis has gained increasing

acceptance

within the nuclear power industry, and has been endorsed by the ALCO Owner's Group.

Page 3 The engine analysis contractor

assists RGSE personnel in performing

state-of-the-art condition monitoring, both prior to and following EDG maintenance

overhauls.

This monitoring

includes enhanced diagnostic

testing, and provides many of the parameters

to assist in determining

engine performance.

Maintenance

procedures

have not totally reflected the new methodology

for data collection

and its applicability

to engine performance.

The data collected, that was above the maximum allowable limit, was obtained with the concurrence

of the OEM field services representative, the engine analysis contractor, and the System Engineer.~This data was reviewed in conjunction

with determining

the overall engine performance.

The representative

was knowledgeable

of these parameters, and was aware of the basis for the firing pressure limits.Nevertheless, this out-of-specification

data was recorded and not properly resolved in accordance

with the Ginna Station administrative

procedures, in that the RGEE maintenance

personnel inappropriately

accepted the data, based on the apparent acceptance

of the data by the contractor

and engineering

personnel.

(2)the corrective

steps that have been taken and, the results achieved: 0 The EDG mechanic was counselled

by the Manager, Mechanical

Maintenance

on the policy for resolution

of data outside acceptance

criteria.0 ACTION Report, 97-2095 was initiated to resolve the specific data within the work package and to initiate cause invest3.gation

for not using the Corrective

Action Program for resolution

of the data.0 The EDGs were retested in February 1998 in the presence of the engine analysis contractor.

RG&E and contractor

personnel determined

the operational

performance

of the EDG's to be satisfactory.

(3)the corrective

steps that will be taken to avoid further violations:

o ACTXON Report 97-2095 resulted in a Training Work Request (TWR), which was initiated to develop specific training in the proper resolution

of out-of-specification

results from field data collection.

Page 4 0 This training will be provided for all appropriate

.Maintenance

'ersonnel.

The training will review applicable

Nuclear Directives

and Interface Procedures, and the responsibilities

of RGEE personnel when vendor representatives

are involved in oversight of work.This training will be completed by October 1,'998.0 Data collected during recent EDG maintenance

and testing will be reviewed.Any anomalies will be entered into the Corrective

Action Program for resolution.

This review will be completed by March 31, 1998.(4)the date when full compliance

will be achieved: Full compliance

was achieved on December 2, 1997, when ACTION Report 97-2095 was written, initiating

resolution

of the unacceptable

data within the Corrective

Action Program.Very ly yours, Robert C.Mecr y xc: Mr.Guy S.Vissing (Mail Stop 14B2)Project Directorate

I-1 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation

U.S.Nuclear Regulatory

Commission

Washington, D.C.20555 Regional Administrator, Region I U.S.Nuclear Regulatory

Commission

475 Allendale Road King of Prussia, PA 19406 U.S.NRC Ginna Senior Resident Inspector