ML17261A684

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Responds to Violations Noted in Insp Rept 50-244/87-19. Corrective Actions:Procedure CP-224 Changed on 870731, Incorporating Steps Required to Document Radiation Source Check Steps & for high-range Radiation Monitoring
ML17261A684
Person / Time
Site: Ginna Constellation icon.png
Issue date: 10/01/1987
From: Kober R
ROCHESTER GAS & ELECTRIC CORP.
To: Russell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML17261A683 List:
References
NUDOCS 8712080371
Download: ML17261A684 (6)


Text

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ROCHESTER GAS ~NO ELEC TRiG

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I TIIEE STATE CORFORATIGN

~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649-0001 ROGER W, KOBER VICC PRCSICICNT CI.CCTRIC PITOOVC ~ ICIT

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. Ginna S tati on October 01,,

1987 Mr. William T. Russell, Regional Administrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

Inspection Report 50-244/87-19 Notice of Violation R.E.

Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

Routine unannounced occupati onal radiation protection, Inspection Report 50-244/87-19 states in part:

As a result of the inspection conducted on July 27-31,

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:

Techni cal Specification

6. 8. 1 (a) requires, in part, that written procedures be established, implemented and ma'i ntai ned covering the activities referenced in Appendix A of Regulatory Guide 1.33, November 1972.

One of those activities, procedures for control of measuring and test equipment, in Section

=H of Appendix A, Regul a tory Guide

1. 33, requires that specific implementi ng procedures for each survei llance test, inspection or calibration listed in Technical Specifica-tions be provided to assure that... instruments... are properly controlled, calibrated and adjusted at specified peri ods to maintain accuracy.

Table 4.1-3, Accident Monitoring I'nstrumentati on Surveillance Requirements, of the licensee 's Techni cal Speci fications requires that a channel calibration of the Containment Area High Range Radiation Monitors (R-29 and R-30) be performed at each refueling in accordance with criteria for calibration provided in Table II.F.1-3 of NUREG-0737.

871208037i 87i204 PDR ADQCI( 05000244 8

PDR

CS

Page 2

Inspection Report 87-19 October 01, 1987 Contrary to the

above, as of July 30,
1987, a procedure was not establi shed and implemented whi ch incorporated all criteria for calibration specified in Table II.F.1-3 of NUREG-0737.

Speci fically, procedures di d not provide for channel calibration of monitors R-29 and R-30 with a source at one point below 10R/hr.

Rochester Gas and Electric Corporation (RGEE) agrees with the violation identified in that Maintenance Calibration Procedure CP-224 "Calibration and/or Maintenance of Containment High Range Area Monitors" was not properly maintained to cover the complete calibration of these instruments in accordance with Table II.F.2,-3 of NUREG-0 73 7.

Speci fically, the steps which require channel calibration using an approved radiation source below 10 R/hr were inadvertently deleted when a Procedure Change Notice (PCN) was submitted to change the Procedure from Revision 3 to Revision 4.

The following is RG&E ~s explanation and reply to this statement of violation:

1.

Corrective steps which have been taken and the results achieved:

a ~

Procedure CP-224 was changed on July 31, 1987 to incorporate the steps required to document the radiation source check steps.

b.

Revised copy of CP-224 was used and completed for both containment high range radiation monitors on August 12, 1987, with satisfactory results.

2 ~

Corrective steps whi ch will be taken to avoid further violati ons:

a 0 b.

The change to incorporate the performance of a

radiation source check was a permanent change to CP-224

and, therefore, will continue to ensure that these steps are performed and documented.

letter has been issued to all plant personnel to stress the importance of a step by step review of all procedure changes to insure that all changes are incorporated properly, and to all Procedure Specialists to stress the importance of routing all permanent procedure changes (other than typographi cal error corrections) for a step by step review for complete-ness.

L Page 3

Inspection Report 87-19 October 01, 2987 3 ~

Date when full compliance will be achieved:

Documentation of the source check of the high range containment radiation monitors was achieved upon completion of the revised CP-224 procedure on August 22, 2987.

Very truly yours, Roger W. Kober Vice President Electric Production xc:

Document Control Clerk RWK:ss

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