ML17261A489
| ML17261A489 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/21/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261A488 | List: |
| References | |
| 50-244-87-10, NUDOCS 8706040295 | |
| Download: ML17261A489 (6) | |
Text
APPENDIX A NOTICE OF VIOLATION Rochester Gas and Electric Company Rochester, New York 14649 Docket No. 50-244 License No.
DPR-18 As a result of the inspection conducted on April 13-16,
- 1987, and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (Enforcement Policy) ( 1986),
the following violations were identified:
A.
Technical Specification 6.8. 1 states in part, "Written procedures shall be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, November 1972...".
Appendix "A" of the Regulatory Guide lists "Procedure Review and Approval" and "Modification" among safety related activities to be covered by procedures.
1.
Administrative Procedure A"601.4, Procedure Control Periodic
- Review, Revision 3, January 29,
- 1987, paragraph
3.2 states
Any procedure may be reviewed when deemed necessary, but must be
- reviewed, approved and distributed within the next 2, 2', or 3 year time frame."
This procedure requires that Administrative Procedures A-100 through A-1800 be reviewed and issued within a
two year time frame.
Contrary to the
- above, as of April 16,
- 1987, Administrative procedures A-102. 4, A-102. 9, A-102. 15, A-202, A-205. 1, A-701, A-1011, and A-1604 were not reviewed, approved and distributed within the required time frame.
2.
Engineering Procedure
- gE316, Preparation, Review and Approval of Field Change Requests (FCRs),
Revision 5,
Paragraph 3.4 states in part:...."
The Responsible
- Engineer, assigned by the Engineering Manager or Lead
- Engineer, shall review the FCR....
FCRs involving changes shall be submitted to the Lead Engineer or the Engineering Manager for review and approval in the "Approved By" block...".
Contrary to the
- above, as of April 16,
- 1987, FCRs 3258A-12, 3258-13 and 3258-16 that involved changes were not submitted to the Lead Engineer or the Engineering Manager for review and approval in that the Responsible Engineer signed the "prepared by" block signifying review of the FCR and also signed the "Approved by" block approving the change.
This is a Severity Level IV violation.
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OFFICIAL RECORD COPY IR GINNA 87"10 " 0003.0.0 05/15/87
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Criterion III states in part:
"Measures shall also be established for the selection and review for suitability of application of materials,
- parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components."
The Ginna Station guality Assurance Manual states in part:
"Use-as-is/
waiver dispositions shall require an evaluation....
The evaluation and technical basis for acceptance shall be documented....
The technical basis for use-as-is/waiver dispositions shall demonstrate that the nonconforming item will meet or exceed applicable design requirements for its use or is otherwise acceptable."
Contrary to the above as of April 16,
- 1987, the following items, purchased as non-safety-related (non gA),
were upgraded for safety-related appli-cation (QA) by issuing an Nonconformance Report (NCR) for each item and then dispositioning the NCR use-as-is without objective evidence of the required evaluation being accomplished.
C.
1.
NCR G87-066, Emergency Power Supply Filter Elements and Gaskets.
2.
NCR G87-155, Auxiliary Building Overhead Crane Switch and Contact Block.
3.
NCR G86-301, Radiation Monitoring Control Relay.
This is a Sever ity Level IV Violation (Supp 1 ement I).
10 CFR 50, Appendix B, Criterion XIII, requires that stored material and parts be protected from damage or deterioration.
- Further, the licensee's equality Assurance Program description commits to ANSI N45.2.2-1972, Packaging,
- Shipping, Receiving, Storage and Handling of
- Items, that requires items to be protected from detrimental contamination.
Contrary to the above as of April 16,
- 1987, safety related 3/4" Schedule 80 Stainless Steel Piping was not protected from detrimental contamination in that it was almost enti rely layered by mounds of bird excrement.
This is a Severity Level IV violation (Supplement I).
10 CFR 50, Appendix B, Criterion VIII, requires controls to prevent the use of defective material.
Contrary to the
- above, as of April 16, 1987, all elastomeric 0-Rings were not controlled to prevent the use of defective material in that they were excluded from established shelf-life controls and no engineering evaluation was performed to determine the effects of aging on these O-rings.
This is a Severity Level IV violation (Supplement I)
OFFICIAL RECORD COPY IR GINNA 87-10 " 0004.0.0 05/15/87
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Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for the violation: (1) corrective action taken and the results achieved; (2) corrective action taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
OFFICIAL RECORD COPY IR GINNA 87"10 " 0005.0.0 05/15/87