ML17261A577

Responds to Violations Noted in Insp Rept 50-244/87-09. Corrective Actions:New Temporary Mod Authorizations Have Been Accompanied W/Specifically Worded Determinations as Required by Administrative Procedure A-1406.1

ML17261A577
Person / Time
Site:	Ginna
Issue date:	07/29/1987
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8708070166
Download: ML17261A577 (8)

Text

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. ) ~ REGULATORY INFORMATION DISTRIBUTION SYSTEM ( R IDS )

ACCESSION NBR: 8708070166 DOC. DATE: 87/07/29 NOTARIZED: YES DOCKET 0

.ACIL: 50-244 Robert Emmet Ginna Nuclear Planti Unit ii Rochester G 05000244 AUTH. NAME 'UTHOR AFFILIATION OBERON R. N. Rochester Gas 5 Electric Corp.

REC IP. NAME RECIPIENT AFFILIATION RUSSELL'. Region ii Office of Director

SUBJECT:

Responds to NRC notice of violation in Insp Rept 50-244/87-09. Corrective actions: upgraded several previous reviews e/plans to follow up on all active authorizations.

DISTRIBUTION CODE: IE01D COPIES RECEIVED: LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: License Exp date in accordance eith 10CFR2i 2. 109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDi-3 PD STAHLEz C INTERNAL: AEOD 1 DEDRO NRR MORISSEAUi D 1- NRR/DOEA DIR NRR/DREP/EPB 1 NRR/DREP/RPB NRR/DRIS DIR 1 NRR/PMAS/ ILRB OE *Ni J 1 OGC/HDS2 G FI RES DEPY GI RGN1 FILE 01 1 ERNAL: LPDR NRC PDR NSI C TOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL

' ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N.K 14649-0001

'55555 ROGER W. KGBER TCLCPHONC VICC PII CSIDCMT CLCCTRIC PIIOOVCTIOII AIICA CODC TIII 546.2700 July 29, 1987 U.S. Nuclear Regulatory Commission Region I Att: Mr. William Russell Regional Administrator 631 Park Avenue King of Prussia, PA 19406 Sub)ect: Inspection Report 50-244/87-09 Notice of Violations R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

Routine Inspection Report 50-244/87-09 Appendix A, stated in part:

During the inspection conducted on April 19, 1987 through May 30, 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 violation was identified:

Technical Specification 6.8.1 states that written procedures shall be established, implemented, and maintained covering activities referenced in Appendix A of Regulatory Guide 1.33, November 1972.'ppendix A, paragraph I, "Procedures for Performing Maintenance", discusses control of maintenance and modification work.

Administrative Procedure A-1406.1, "Installation and Removal of Temporary Structural Features", Step 3.4.2, of A-1406.1 states that the Technical Manager or alternate shall document. his review providing a determination whether the temporary installation will: 1) result in a change to the facility or its operation as described in the Safety Analysis Report, 2) provide a change to the Plant Technical Specifications, or 3) involve an unreviewed safety question.

Further, step 3.4.,6 states that documentation of the review shall be attached to the authorization form, and the authorization form shall be forwarded to the Temporary Modification Coordinator for distribution.

8708070l66 870729 PDR ADOCK 05000244 8 PDR

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Id ROCHESTER GAS AND ELECTRIC CORP SHEET NO. 2 DATE t'uly 29, 1987 Mr. William Russell Contrary to the above, as of May 21, 1987, Administrative Procedure A-.1406.1 was not followed-; in that, the required documented review was not attached to the following temporary structural features authorization forms:

From April 15,'986 to October 9; 1986, scaffolding was installed in the Auxiliary Building over safeguards Bus 14.

2 ~ From November 17, 1986 to December 19, 1986, scaffolding was installed in the control room above and around the main control board while at power.,

3 ~ From April 7, 1987 to May 8, 1987, scaffolding was installed in the Auxiliary "Building over safeguards Bus 14.

Rochester Gas and Electric Corporation (RG&E) agrees with the violation in that justification for the determinations Plant with respect to 1) changes to the facility or operation, 2)

Technical Specif ications, or 3) an unreviewed safety question were not provided with the temporary modification authorization forms. The procedure cited directs the review to assess the proposed activity for the three criteria. It had been the or alternate intent that the signature by the Technical Manager met the requirement for compliance with the three criteria. RG&E does agree, however, that documentation in the form of a clear statement of the determinations and any conditions imposed as a basis for them should have been supplied to back up each conclusion. We also agree with the discussion in the details section of the Inspection Report of the difficulty in control of concurrent activities the omission caused.

The Temporary Modification Authorization Forms for the instances discussed in the Notice of Violation were accompanied by a review by the Technical Manager or alternate which consisted of a recognition of the other features in close proximity to the activity proposed and a list of conditions or requirements to be imposed. Without actually stating negative determinations in whether the temporary installation would 1) result in a change to the facility or its operation as described in the Safety Analysis Report, 2) provide a change to the Plant Technical Specifications, or 3) involve an unreviewed safety question, observance of the requirements provided would be sufficient to it was =believed that allow such determinations.

action taken and results achieved:

'orrective Since discussion of this matter with the inspector, new temporary modification authorizations have been accompanied with specifically worded determinations as required by procedure A-1406.1 "Installation and Removal of Temporary Structural Features".

Several of the previous reviews have also been upgraded in this way, with plans to follow up on all active authorizations.

ROCHESTER GAS AND ELECTRIC CORP. SHEET NO. 3 DATE July 29, 1987 Nr. William Russell Existing temporary modifications are currently being formally presented to the MoPAR (Morning Priority Action Required) Committee via the plan-of-the-week schedule. In addition, selected proposed for their temporary modifications are verbally presented to MoPAR concurrence prior to implementation. This exchange of information when integrated with the maintenance and operational activities minimizes the potential of safety implications in regards to c'oncurrent activities.

Corrective actions to be taken, in addition to completion of the above upgrade:

The series of procedures under A-1406 "Control of Temporary Modifications" will be reviewed and changes will be proposed to provide clearer direction on proper documentation of reviews.

After a period of'ime for operation with the new for procedural control of guidance, a Quality Assurance audit of the program temporary modifications will be scheduled.

Dates when full compliance will be achieved:

~

Proposals to amend the series of procedures on control of temporary modifications are currently in progress with schedule for approval by September 1987. Upgrading of the review documentation for active authorizations will also be complete by September 1987.

Y s truly, Ro er W. Kober RWK/lms Subscribed and sworn to on this 9 ~ da of me EYWl.HAUCK Nouuy Prrtke er the Stete oI Nerr Ytrrlt MONROE COUNTY Corrrrrirrioa Errpiree Nov. Stt, 19RF xce U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 T. Pollich Ginna Resident Inspector

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