ML17309A628
| 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