ML17251A344

Responds to Violations Noted in Insp Rept 50-244/88-16. Corrective Actions:Both Periodic Test Procedures Revised to Assure Clarity of Need to Evaluate Condition Against Inoperability Criteria

ML17251A344
Person / Time
Site:	Ginna
Issue date:	11/04/1988
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8811150213
Download: ML17251A344 (8)

Text

ACCELE RA.TED DlSTMBUTtON DE MON STRA.TION SYSTEM)d REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 8811150213 DOC. DATE: 88/11/04 NOTARIZED: NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.

Rochester Gas

& Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION RUSSELL,W.T.

Region 1, Ofc of the Director

SUBJECT:

Responds to violations noted in Insp Rept 50-244/88-16.

DISTRIBUTION CODE:

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TITLE: General (50 Dkt)-Insp Rept/Notice of VioTation Re ponse NOTES:License Exp date in accordance with '10CFR2,2.109(9/19/72).

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)tall ROCHESTER GAS AND ELECTRIC CORPORATION a 89 EAST AVENUE, ROCHESTER, N.K 14649.0001 I

TEE,C><ONE inca casa ~ie 546.2700 November 4, 1988 Mr. William T. Russell Regional Administrator US Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

Subject:

Inspection Report 50-244/88-16 Notice of Violation R.E.

Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

In accordance with NRC Inspection Report 88-16 which stated:

Technical Specification 6.8.1 requires, in part, written procedures shall be implemented covering surveillance and test activities of safety related equipment and the

. radiological environmental monitoring program.

Periodic Test procedure PT-12.1, Emer enc Diesel Generator lA, Revision 38, effective July 15,

1988, step 2.1 requires the lA Emergency Diesel Generator be demonstrated operable and step 2.1.6 requires, in part, various local panel readings are verified within given acceptable values.

Contrary to the

above, on August 8,

1988, PT-12.1 was performed with actual fuel oil pressure documented outside the range of acceptable values;

and, on August 9,

1988, PT-12.1 was again performed with lube oil pressure documented outside the.range of acceptable values.

In each

case, station personnel failed to declare the diesel inoperable.

Procedure PT-ll.l, Heat Trace Circuit Functional Check, Revision 9,

effective October 16,

1987, step 1.1

requires, in part, Technical Specification required heat trace circuitry be insured operable.

Contrary to the

above, on March 7, 1988, electrical maintenance personnel failed to notify operations personnel and declare Technical Specification required heat trace circuitry inoperable.

SSi>SSO2> 'ec>04 FDa ODOCP.

<~~000244 9

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Health Physics Procedure (HP) 5.1, Area Radiation Surve s, Revision 24, effective May 12,

1988, step 6.4 requires, in part, survey results for the Auxiliary Building and other radiation areas will be entered on area maps and postecl at the access control area.

Contrary to the

above, on September 7g 1988/

the inspectors discovered weekly maps documenting surveys performed on August 30 and September 1,

1988, had not been posted as required.

We believe the Notice of Violation contains one error. It refers to the lube oil pressure instead of to the out of specification condition identified in section 4 a for lube oil temperature.

1)

Reason for the violation In response, RG&E concurs with the stated violation.

In both Periodic Test (PT) procedures, the field test personnel.

followed the steps as written, initiating a trouble report for the identified deficiency.

The procedures did not clearly require an evaluation to determine whether the declaration of equipment inoperability was warranted, or whether the deficiency was only intended to identify necessary maintenance when certain conditions are reached from a

predictive maintenance standpoint.

The Health Physics (HP) weekly survey was taken as required by Health Physics Procedure HP-5.1 Area Radiation Surve s, however, the latest surveys were not posted due to personnel oversight as required by step 6.4 "Areas inside of controlled areas that have posted survey maps should have the most recent results and date."

2)

Corrective steps which have been taken and the results-achieved Both PT procedures have been revised to assure clarity of the need to evaluate the condition against the inoperability criteria and to assure implementation of the necessary tracking mechanisms for out of service equipment.

These revisions were in progress at the time of the violation.

Necessary personnel have been familiarized in this mechanism.

All personnel in the HP section have been reminded of the posting requirements.

The requirements for posting the surveys have been added to the list of duties for the HP technician.

3)

Corrective steps which will be taken to avoid further violations We concur that the review and approval of the completed test data needs better oversight to assure operability decisions along with analysis and trending of data.

We have set and

4) will continue to set higher standards and clear criteria for operational and supervisory reviews on all critical informa-tion.

Responsible personnel have been familiarized with these expectations and significant changes

. have already taken place.

Date when full compliance will be achieved All corrective action concerned with the specific violation have been completed,

however, additional improvement will continue to be made.

Additional information'n the specifics of the ongoing improvement plan can be best conveyed in our discussion on Inspection Report 88-15.

Very truly yours, Robert C.

M cr General Manage Nuclear Production xc:

U.S. Nuclear Regulatory Commission (original)

Document Control Desk Washington, DC 20555 Ginna Senior Resident Inspector