ML17263A873
| ML17263A873 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/07/1994 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9412150098 | |
| Download: ML17263A873 (18) | |
Text
4hlD ROCHESTER GASANDELECTRIC CORPORATION ~ 89 EASTAYENUE, ROCHESTER, N. Y Id6d9.000!
AREA CODE 716 5'-2700 ROBER7 C. MECREDY Vice President Nuclear Operations December 7 1994 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Allen Johnson PWR Project Directorate I-3 Washington, DC 20555
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-244/94-21, dated November 7, 1994 R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Johnson:
During an NRC Inspection conducted on October 3, 1994, through October 6, 1994, two 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, the violations are listed below:
A.
10 CFR Part 50, Appendix E, IV, D. 3 states, in part, "By February 1, 1982, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ (Emergency Planning Zone)."
Section 6.3.13 of the R.E. Ginna Station Nuclear Emergency Response Plan states that, "Siren reliability will be tested periodically at 3 levels of operation:
- 1. Bi-weekly silent tests to verify system electronic components are functioning. 2. Quarterly manually activated growl tests. 3. Annual full duration audible tests of the entire system."
Contrary to the above, from March 2, 1994, to October 5, 1994, the licensee did not conduct growl tests in the second quarter (April through June) and the third quarter (July through September) of 1994 to test siren operation.
B.
10 CFR Part 50.54(q) states, in part, "The nuclear power reactor licensee may make changes to these (emergency) plans without Commission approval only if the. changes do not decrease the effectiveness of the plans and the plans, as changed, continue to meet the standards of paragraph 50.47 (b) and the requirements of Appendix E to this part... If a change is made without approval, the licensee shall submit each change within 30 days after the change is made."
10 CFR Part 50.4(b)(5) states, in part, "Written communications as defined in paragraphs (b)'(5)(i) through (iii) in this section, must be submitted as follows: the signed original to the Nuclear Regulatory Commission, Document Control
- Desk, Washington, DC 20555, two copies to the appropriate Regional Office, and one copy to the appropriate NRC Resident Inspector if one has been assigned to the site of the facility." 10 CFR Part 50.4(b)(5)(ii) references "Change to an emergency plan pursuant to paragraph 50.54(q)."
Contrary to the above, as of the date of the inspection (October 3-6, 1994), the licensee had not submitted copies of Revision 12 (dated July 1, 1993), Revision 13 (dated May 4, 1994), or Revision 14 (dated (August 31, 1994) to the Region 1
Office (the appropriate Regional Office) and, therefore, exceeded the 30-day time limit for submitting the three plan changes.
Rochester Gas and Electric Corporation (RG8E) agrees the violations. occurred.
The following is RG8E's reply to the statement of violations; and also comments relative to additional areas covered in the'inspection report which we believe to require additional clarification.
Violation A - Failing to perform quarterly emergency siren growl tests, during two consecutive quarters, as specified in the Nuclear Emergency
Response
Plan (NERP).
Reason for the violation:
RG8 E investigations have determined the following cause for the violation:
A schedule for siren growl testing was assembled for 1994. However, the schedule was assembled incorrectly. Secondly, the nuclear emergency planning group did not verify that the tests were being performed.
Corrective steps that have been taken and the results achieved:
When the missed growl tests were identified, the line operating group was immediately instructed to perform growl tests on all 96 sirens. These growl tests were completed on October 7, 1994. Allthe sirens functioned properly.
Corrective steps that willbe taken to avoid further violations:
RGSE has identified and implemented the corrective actions required to address both the specific violation and the broader issues associated with emergency planning activities carried on outside of the emergency preparedness group.= We determined the need to establish clearer accountability and more effective control mechanisms to verify that time-related program requirements are met.
Since the inspection, we have reviewed this issue and have established a single point of accountability. The Corporate Nuclear Emergency Planner (CNEP) is responsible and accountable for assuring that all corporate actions relative to the emergency plan are met. The CNEP has been tasked to implement a simple method that verifies the completion of all scheduled tests and inspections. The CNEP has accomplished this through an enhanced emergency planning schedule and tracking list. This list is distributed to members of the corporate "Emergency Planning-Milestone Committee", a group of RG8 E department representatives which meets monthly to provide oversight and track the progress of emergency planning actions throughout the year. Any issues that cannot be resolved can then be referred to the Vice President Nuclear Operations for action.
In the specific case of the Ginna sirens, a section for siren testing was incorporated in the Milestone Committee oversight and tracking list. The
~ CNEP willverify that all key scheduled tests and inspections have been completed as required. The Milestone Committee willreview the progress of all required actions, and willassist the CNEP in addressing any performance concerns.
Membership of the Milestone Committee-has also been changed to improve the awareness of RG8 E support departments with siren testing, and other emergency planning requirements.
4.
The date when full compliance willbe achieved:
Full compliance, relative to the violation, was achieved on October 7, 1994, when a successful growl test was completed on all 96 prompt notification system sirens. Additional program scheduling and performance verification improvements were implemented by November 17, 1994.
Violation B - Failing to submit changes to the NERP to NRC Region 1 as required in 10 CFR 50.54(q).
1.
Reason for the violation:
RGRE investigations have determined the following cause for the violation:
The NERP revisions were not clearly marked for transmission to NRC Region 1 offices. Therefore, clerical staff did not mail changes.
2.
Corrective steps that have been taken and the results achieved:
The required copies of the current NERP (Revision 14) was transmitted to the NRC Region 1 office on October 6, 1994.
Corrective steps that willbe taken to avoid further violations:
The NERP is on a controlled user distribution. In addition to the NRC Document Control Desk, the NRC Region 1 office has now been assigned controlled user numbers by RGRE Document Control. We have also added instructions to our controlled document distribution procedures to describe how revisions to the NERP are controlled.
4.
The date when full compliance will be achieved:
Full compliance was achieved on October 18, 1994, when NERP Revision 14 transmittal acknowledgments fro'm NRC Region 1 offices were received by RGB E Document Control.
We have also carefully reviewed the inspection report and have noted additional areas where further management attention is warranted. For example, we have tasked the Corporate Nuclear Emergency Planner to ensure that all emergency communications equipment, including telephone numbers and phone labels, are more effectively checked for operability and currency. We have also requested that the Emergency Planning Milestone Committee periodically ensure that new policy and program requirements, such as the recent change in emergency respirator qualification criteria, be more formally integrated in implementing procedures and training.
With regard to the inclusion of the nuclear emergency preparedness function within our Nuclear Assessment organization, we are confident that sufficient management controls are in place to assume that independence is maintained between the quality and line functions.
In fact, we have already observed several ways in which the emergency preparedness function is enhanced through the Nuclear Assessment Department's mission in the areas of self-assessment, corrective action, software quality assurance and formalized training qualifications. Progress in these and other areas will continue to be monitored through management oversight.
Thank you for bringing these issues to our attention and please be assured we will continue to enhance what we believe is a dynamic and effective emergency preparedness program.
Very y yours, Robert C. Mecredy xc:
Mr. Allen R. Johnson (Mail Stop 14D1)
PWR Project Directorate I-3 Washington, DC 20555 U.S. Nuclear Regulatory Commission Region 1
Attn: Regional Administrator 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector
HH.IMH.I' 'Y (ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
I-CESSION NBR:9412150098 DOC.DATE: 94/12/07 NOTARIZED:
NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.
Document Control Branch (Document Control Desk)
DOCKET 05000244
SUBJECT:
Responds to NRC ltr re violaitons noted in insp rept 50-244/94-21 on 941003-06.Corrective actions:from 940302-1005,licensee did not conduct growl tests in second
& third quarter of 1994 to test siren operation.
DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTRj ENCL 0 SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
f 05000244 RECIPIENT ID CODE/NAME PD1-3 PD COPIES LTTR ENCL RECIPIENT ID CODE/NAME JOHNSON,A COPIES LTTR ENCL INTERNAL: AEOD/DEIB AEOD/SPD/RRAB DEDRO NRR/DORS/OEAB NRR/PMAS/IRCB-E OE DIR RGN1 FILE 01 EXTERNAL: LITCO BRYCE,J H
NRC PDR AEOD/SPD/RAB ALOD~.
~ FILE CENTER 02 NRR/DKCEf&HFB NUDOCS-ABSTRACT OGC/HDS3 NOAC YOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE!CONTACTI'HE DOC!:iIEYTCONTROL DESk, ROOM Pl.37 (EXT. 504.~0S3
) TO ELIXfli,KTE5'Oj'R i'ANIL'ROil DISTRIBUTION. LIS'I'S I'OR DOCI,'PIED'I'S 3'Ol.'O/"I'L'II)!
c7 TAL NUMBER OF COPIES REQUIRED:
LTTR 18 ENCL
AND I
ROCHFSTER GAS ANDEIECTRICCORPORATION ~ 89EASTAVFNUE ROCHESTER N Y Id6d9.0DOl AREA CODES I6 5d6. o7M ROBERT C. MECREDY Vice Presitient t4vctear Operations December 7, 1994 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Allen Johnson PWR Project Directorate I-3 Washington, DC 20555
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-244/94-21, dated November 7, 1994 R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Johnson:
During an NRC Inspection conducted on October 3, 1994, through October 6, 1994, two 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, the violations are listed below:
A.
10 CFR Part 50, Appendix E, IV, D. 3 states, in part, "By February 1, 1982, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ (Emergency Planning Zone)."
Section 6.3.13 of the R.E. Ginna Station Nuclear Emergency Response Plan states that, "Siren reliability will be tested periodically at 3 levels of operation:
- 1. Bi-weekly silent tests to verify system electronic components are functioning. 2. Quarterly manually activated growl tests. 3. Annual full duration audible tests of the entire system."
Contrary to the above, from March 2, 1994, to October 5,
1994, the licensee did not conduct growl tests in the second quarter (April through June) and the third quarter (July through September) of 1994 to test siren operation.
",Ilgwu q
94121500'sts sst422g7 PDR ADOCti 05000244 9
PDR Z pipg<ld 4'7l
10 CFR Part 50.54{q) states, in part, "The nuclear power reactor licensee may make changes to these (emergency) plans without Commission approval only if the changes do not decrease the effectiveness of the plans and the plans, as changed, continue to meet the standards of paragraph 50.47 (b) and the requirements of Appendix E to this part... If a change is made without approval, the licensee shall submit each change within 30 days after the change is made."
10 CFR Part 50.4(b)(5) states, in part, "Written communications as defined in paragraphs (b) (5)(i) through (iii) in this section, must be submitted as follows: the signed original to the Nuclear Regulatory Commission, Document Control
- Desk, Washington, DC 20555, two copies to the appropriate Regional Office, and one copy to the appropriate NRC Resident Inspector if one has been assigned to the site of the facility." 10 CFR Part 50.4(b)(5)(ii) references "Change to an emergency plan pursuant to paragraph 50.54{q)."
Contrary to the above, as of the date of the inspection (October 3, 1994), the licensee had-not submitted copies of Revision 12 (dated July 1, 1993), Revision 13 {dated May 4, 1994), or Revision 14 (dated {August 31, 1994) to the Region 1
Office (the appropriate Regional Office) and, therefore, exceeded the 30-day time limit for submitting the three plan changes.
Rochester Gas and Electric Corporation (RG8E) agrees the violations occurred.
The following is RG8E's reply to the statement of violations; and also comments relative to additional areas covered in the inspection report which we believe to require additional clarification.
VioIation A - Failing to perform quarterly emergency siren growl tests, during two consecutive quarters, as specified in the Nuclear Emergency
Response
Plan (NERP).
Reason for the violation:
RGB E investigations have determined the following cause for the violation:
A schedule for siren growl testing was assembled for 1994. However, the schedule was assembled incorrectly. Secondly, the nuclear emergency planning group did not verify that the tests were being performed.
Corrective steps that have been taken and the results achieved:
When the missed growl tests were identified, the line operating group was immediately instructed to perform growl tests on all 96 sirens. These growl tests were completed on October 7, 1994. All the sirens functioned properly.
Corrective steps that will be taken to avoid further violations:
RGB E has identified and implemented the corrective actions required to address both the specific violation and the broader issues associated with emergency planning activities carried on outside of the emergency preparedness group. We determined the need to establish clearer accountability and more effective control mechanisms to verify that time-related program requirements are met.
Since the inspection, we have reviewed this issue and have established a
single point of accountability. The Corporate Nuclear Emergency Planner (CNEP) is responsible and accountable for assuring that all corporate actions relative to the emergency plan are met. The CNEP has been tasked to implement a simple method that verifies the completion of all scheduled tests and inspections. The CNEP has accomplished this through an enhanced emergency planning schedule and tracking list. This list is distributed to members of the corporate "Emergency Planning Milestone Committee", a group of RG8 E department representatives which meets monthly to provide oversight and track the progress of emergency planning actions throughout the year. Any issues that cannot be resolved can then be referred to the Vice President Nuclear Operations for action.
In the specific case of the Ginna sirens, a section for siren testing was incorporated in the Milestone Committee oversight and tracking list. The CNEP willverify that all key scheduled tests and inspections have been completed as required. The Milestone Committee will review the progress of all required actions, and willassist the CNEP in addressing any performance concerns.
Membership of the Milestone Committee has also been changed to improve the awareness of RG8 E support departments with siren testing, and other emergency planning requirements.
~
4.
The date when full compliance willbe achieved:
Full compliance, relative to the violation, was achieved on October 7, 1994, when a successful growl test was completed on all 96 prompt notification system sirens. Additional program scheduling and performance verification improvements were implemented by November 17, 1994.
Violation B - Failing to submit changes to the NERP to NRC Region 1 as required in 10 CFR 50.54(q).
Reason for the violation:
RG8 E investigations have determined the following cause for the violation:
The NERP revisions were not clearly marked for transmission to NRC Region 1 offices. Therefore, clerical staff did not mail changes.
Corrective steps that have been taken and the results achieved:
The required copies of the current NERP (Revision 14) was transmitted to the NRC Region 1 office on October 6, 1994.
3.
Corrective steps that willbe taken to avoid further violations:
The NERP is on a controlled user distribution. In addition to the NRC Document Control Desk, the NRC Region 1 office has now been assigned controlled user numbers by RG8E Document Control. We have also added instructions to our controlled document distribution procedures to describe how revisions to the NERP are controlled.
4.
The date when full compliance willbe achieved:
Full compliance was achieved on October 18, 1994, when NERP Revision 14 transmittal acknowledgments from NRC Region 1 offices were received by RGRE Document Control.
We have also carefully reviewed the inspection report and have noted additional areas where further management attention is warranted. For example, we have tasked the Corporate Nuclear Emergency Planner to ensure that all emergency communications equipment, including telephone numbers and phone labels, are more effectively checked for operability and currency. We have also requested that the Emergency Planning Milestone Committee periodically ensure that new policy and program requirements, such as the recent change in emergency respirator qualification criteria, be more formally integrated in implementing procedures and training.
With regard to the inclusion of the nuclear emergency preparedness function within our Nuclear Assessment organization, we are confident that sufficient management controls are in place to assume that independence is maintained between the quality and line functions.
In fact, we have already observed several ways in which the emergency preparedness function is enhanced through the Nuclear Assessment Department's mission in the areas of self-assessment, corrective action, software quality assurance and formalized training qualifications. Progress in these and other areas will continue to be monitored through management oversight.
Thank you for bringing these issues to our attention and please be assured we will continue to enhance what we believe is a dynamic and effective emergency preparedness program.
Very y yours, Robert C. Mecredy xc:
Mr. Allen R. Johnson (Mail Stop 14D1)
PWR Project Directorate I-3 Washington, DC 20555 U.S. Nuclear Regulatory Commission Region 1
Attn: Regional Administrator 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector