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ACCESSION #: 9507200264 RGE ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER N.Y. 14649-0001 AREA CODE 716 546-2700 ROBERT C. MECREDY Vice President Nuclear Operations July 14, 1995 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson PWR Project Directorate 1-1 Washington, D.C. 20555 Subject: 10 CFR Part 21 30 Day Report R.E. Ginna Nuclear Power Plant Docket No. 50-244 In accordance with 10 CFR Part 21, Reporting of Defects and Noncompliance, Section 21 (c) (3) (ii), which requires "Written notification to the NRC ... on the identification of a defect or a failure to comply", the attached 10 CFR 21 report is hereby submitted. 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 Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna USNRC Senior Resident Inspector PAGE 2 10CFR21 30 DAY WRITTEN REPORT I. NAME AND ADDRESS OF THE INDIVIDUAL INFORMING THE COMMISSION: NAME: Robert C. Mecredy Vice President Nuclear Operations ADDRESS: Rochester Gas & Electric Corporation 89 East Avenue Rochester, New York 14649 II. IDENTIFICATION OF THE FACILITY, THE ACTIVITY, OR THE BASIC COMPONENT SUPPLIED FOR SUCH FACILITY WHICH FAILS TO COMPLY OR CONTAINS A DEFECT: The facility is the R.E. Ginna Nuclear Power Plant. The basic component is a 14 inch air-operated butterfly valve, used as the Service Water outlet valve AOV-4561 (Fisher Series 7600 valve) for the Containment Recirculation Fan Coolers (CRFC). The valve assembly (less actuator) was replaced during the 1995 refueling outage as preventive maintenance for AOV-4561. III. IDENTIFICATION OF THE FIRM CONSTRUCTING THE FACILITY OR SUPPLYING THE BASIC COMPONENT WHICH FAILS TO COMPLY OR CONTAINS A DEFECT: The butterfly valve installed during the 1995 outage was procured as a replacement for a specific serial numbered original plant valve (AOV-4561). Since the valve is standard and commercially available, it was procured as commercial grade and dedicated as safety-related by Rochester Gas and Electric (RG&E) under Commercial Grade Item Engineering Evaluation (CGIEE) 94-051. The valve was supplied by: Fisher Controls Co. c/o Northeast Controls, Inc. 60 John Glenn DR Amherst, NY 14228 PAGE 3 IV. NATURE OF THE DEFECT OR FAILURE TO COMPLY AND THE SAFETY HAZARD WHICH IS CREATED OR COULD BE CREATED BY SUCH DEFECT OR FAILURE TO COMPLY: The replacement valve was installed as AOV-4561 in mid-April, 1995, with the plant in cold shutdown and this portion of the Service Water system isolated for maintenance and not required to be operable. As part of the installation process and prior to turnover for post-maintenance testing (PMT) and return to operable status, Instrument and Control (I&C) technicians were performing initial alignment of the valve to the valve actuator and valve positioner, using a valve-specific calibration data sheet. On April 18, 1995, during this initial alignment, the I&C technicians found that AOV-4561 actuated opposite from the required configuration. The difference in actuation was caused by improper keyway placement, resulting in "air-to-open" operation. The original engineering requirements stipulated "air-to-close" operation. The safety hazard which could be created by such a defect is the loss of Service Water flow through the Containment Recirculation Fan Coolers (CRFC), when combined with single failure considerations. This condition could result in the Containment pressure slightly exceeding design limitations in the event of the limiting "Steam line break in Containment" accident. V. THE DATE ON WHICH THE INFORMATION OF SUCH DEFECT OR FAILURE TO COMPLY WAS OBTAINED: The information was obtained on April 18, 1995. VI. IN THE CASE OF A BASIC COMPONENT WHICH CONTAINS A DEFECT OR FAILS TO COMPLY, THE NUMBER AND LOCATION OF ALL SUCH COMPONENTS IN USE AT, SUPPLIED FOR, OR BEING SUPPLIED FOR GINNA STATION: One valve was procured for AOV-4561, and installed in mid- April, 1995, in the Service Water system at Ginna Station. PAGE 4 VII. THE CORRECTIVE ACTION WHICH HAS BEEN, IS BEING, OR WILL BE TAKEN; THE NAME OF THE INDIVIDUAL OR ORGANIZATION RESPONSIBLE FOR THE ACTION; AND THE LENGTH OF TIME THAT HAS BEEN OR WILL BE TAKEN TO COMPLETE THE ACTION: Corrective action was taken by the Ginna Station Maintenance group. A nonconformance report (NCR) was initiated, and the valve was repaired in accordance with the Engineering disposition for this NCR, by cutting a new keyway in the valve actuator lever. The actuator lever was reinstalled, and the valve actuator was calibrated per the requirements of the calibration data sheet to verify proper valve operation. These corrective actions were completed within seven days of identification of the problem, with the plant in cold shutdown and this portion of the Service Water system isolated land not required to be operable. The CGIEE for this valve was revised by Procurement Engineering, to include verification of appropriate component operation, with successful completion of PMT as the acceptance criteria. This provides assurance that the valve interfaces correctly with the valve actuator and functions correctly as part of the Service Water system. The purchasing description in the Materials Management computer system was revised by Procurement Engineering to ensure that future purchase orders will stipulate the original design requirement that the valve be supplied as "air-to-close". The importance of verifying equipment interfaces and component interactions during consideration of critical characteristics for dedication was reemphasized to procurement engineers by Procurement Engineering supervision in June, 1995. VIII. ANY ADVICE RELATED TO THE DEFECT OR FAILURE TO COMPLY ABOUT THE FACILITY, ACTIVITY, OR BASIC COMPONENT THAT HAS BEEN, IS BEING, OR WILL BE GIVEN TO PURCHASERS OR LICENSEES: The critical characteristics selected for commercial grade dedication should have required verification that the valve would fail as designed on loss of air. Associated activities that are normally performed to assure that the valve interfaces correctly with the valve actuator (such as I&C calibration and PMT) should be included as part of the commercial grade dedication process. Verification that dedicated components interface correctly assures the configuration necessary for proper component operation and system function. *** END OF DOCUMENT ***