ML17262A367
| ML17262A367 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/08/1991 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17262A366 | List: |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 50-244-90-31, EA-91-002, EA-91-2, NUDOCS 9102140187 | |
| Download: ML17262A367 (3) | |
Text
NOTICE OF VIOLATION Rochester Gas 4 Electric Corp.
Ginna Docket No. 50-244 License No.
DPR-18 EA 91-002 During an NRC inspection conducted between December 13, 1990 and January 3,
- 1991, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for'NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1990), the particular violations 'are set forth below:
A.
10 CFR Part 50, Appendix B, Criterion VI, "Document Control," states in part, that measures shall be established to control the issuance of documents, such as procedures, including changes
- thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy.
Contrary to the above, in March 1989, a procedure affecting quality,
- namely, Procedure M-48. 14, "Isolation of Bus 14 Undervoltage System for Maintenance, Troubleshooting, Rework and Testing,"
was changed without an adequate review being performed.
The specific change in'volved inclusion of a step in the procedure which allowed the disabling of Engineered Safety Feature Actuation System (ESFAS) instrumentation while the reactor was in any mode of operation, including power.
The licensee's organizational measures for review, approval, and issuance of this procedure
- change, including the review by the Plant Operations Review Committee, did not assure that the change was adequately reviewed in that it did not identify that implementation of the procedure change in a mode other than cold shutdown condition would place the plant in a condition that was prohibited by Technical Specification 3'.2
~
B.
Technical Specification 6.8. 1 requires establishment of the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972 (Safety Guide 33).
Regulatory Guide 1.33, November 1972, Appendix A,Section I, specifies that maintenance which can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Contrary to the above, on December 12, 1990, the licensee failed to adequately preplan and perform corrective maintenance on the A emergency diesel generator undervoltage circuit card.
Specifically, maintenance procedure M-48. 14, "Isolation of Bus 14 Undervoltage System for Maintenance, Troubleshooting, Rework and Testing,"
was used to perform the corrective maintenance while the reactor was at 3 percent power during startup.
Step 5.5.1 directed personnel to open OC circuit breakers for the A and B safeguards logic trains which disabled the automatic and manual (push button) sequencing of safeguards equipment.
This step was OFFICIAL RECORD COPY CP PKG GINNA 2/7 - 0009.0.0 91021401EV 910208 02/07/91 PDR ADOCK 05000244 8
Notice of Violati on both unnecessary to perform the required work and inappropriate for the circumstances as it disabled the safeguards sequencing function at a time prohibited by plant technical specifications.
Additionally, use of M-48.14 proceeded despite indications that the procedure was inappropriate.
Those indication's included labels on the DC breaker panels warning of possible safety injection consequences and the initiation of alarm annunciator L-31, "Safeguards DC Bus Failure."
Violations A and B are classified in the aggregate at Severity Level III.
(Supplement 1)
Pursuant to the provisions of 10 CFR 2.201, Rochester Gas 8 Electric Corporation is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region I and a copy to the NRC Resident Inspector within 30 days of the date after the letter transmitting this Notice of Violations This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation:
(1) the reasons for the violation, or if contested the basis for disputing the violation, (2) the corrective steps that have been taken and the results
- achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved, If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Atomic Energy Act, 42 U.S.C.
2232, this response shall be submitted under oath or affirmation.
FOR THE NUCLEAR REGULATORY COMMISSION Thomas T. Martin Regional Administrator Dated at King of Prussia, Pennsylvania this day of February 1991 OFFICIAL RECORD COPY CP PKG GINNA 2/7 0010.0.0 02/07/91