ML17309A522

Responds to NRC 930624 Ltr Re Violations Noted in Insp Rept 50-244/93-10 on 930423-0609.C/As:Site Fire Protection Engineer Issued Ltr to All Shop Foremen,On 930611 to Share W/Personnel Lessons Learned from Recent Fire Problems

ML17309A522
Person / Time
Site:	Ginna
Issue date:	07/26/1993
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9308040231
Download: ML17309A522 (5)

Text

ACCELERATED DOCUMENT DISTRIBUTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)

ACCESSION NBR:9308040231 DOC.DATE: 93/07/26 NOTARIZED: NO DOCKET ACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 UTH.NAME . AUTHOR AFFILIATION CREDY,R.C. Rochester Gas 6 Electric Corp.

RECZP.NAME RECIPIENT AFFILIATION JOHNSON,A.R. Project Directorate I-3 g 1

SUBJECT:

Responds to NRC 930624 ltr re violations noted in insp rept 50-244/93-10 on 930423-0609.C/As:Site Fire Protection Engineer issued ltr to all shop foremen, on 930611 to share w/personnel lessons learned from recent fire problems. D DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR J ENCL P SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 PD JOHNSONPA D

INTERNAL: AEOD/DEIB AEOD/DSP/ROAB AEOD/DSP/TPAB AEOD/TTC DEDRO NRR/DORS/OEAB NRR/DRCH/HHFB NRR/DRIL/RPEB NRR/DRSS/PEPB NRR/PMAS/ILPBl NRR/PMAS/ILPB2 NUDOCS-ABSTRACT 0 OGC/HDS1 REG FIL 02 RES/HFB RGN1 FILE Ol EXTERNAL: EG!EG/BRYCEPJ.H. NRC PDR NSIC D

NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL

l i%i~i&i 8//Pily'ZN $~ IQ Ik s Ilt~

roeK r

dlufP~/ill'illifkill/SEIZE sr*re ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER N. Y. 14649-0001 ROBERT C MECREDY 7Et.EPHONE Vice President AAEA coDE 7 t ts 546 2700 Cinna Nuclear Production July 26, 1993 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson PWR Project Directorate I-3 Washington, DC 20555

Subject:

Reply to a Notice of Violation NRC Inspection Report No. 50-244/93-10, dated June 24, 1993 R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Johnson:

During an NRC Inspection conducted on April 23, 1993 to June 9, 1993, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

"Technical Specifications, paragraph 6.8.1 states, in part:

"Written procedures shall be established, implemented, and maintained covering...Fire Protection Program implementation..."

A procedure that implements the Fire Protection Program, Ginna Station Procedure No. A-905, "Open Flame, Welding and Grinding Permit (Hot Work Permit), paragraph 3.3 states, in part: "The work area will be inspected by Fire Protection and Safety personnel and the following conditions shall be satisfied before work commences...Any openings into adjoining areas within a thirty-five foot radius shall be closed and/or a second firewatch established..."

930804023i 930726 ~i@i PDR ADQCK 05000244 8 PDR >0

Contrary to the above, on June 7, 1993, grinding work was conducted on the sill of a closed fire door between the turbine building and the intermediate building without the appropriate fire prevention controls being implemented to prevent sparks from entering into the intermediate building where safety related equipment is located, including a second firewatch established in the intermediate building to monitor for the presence of sparks.

Rochester Gas and Electric Corporation (RG&E) agrees the violation occurred.

This event was identified by the NRC Resident Inspector during a routine plant tour. During the NRC Resident's tour, he observed sparks entering the Intermediate Building from underneath fire door S36F, an infrequent access door to the Turbine Building.

The following is RG&E's reply to this statement of violation:

1. Reason for the violation:

RG&E investigations have determined the following cause for the violation:

During Fire Protection personnel's pre-inspection of the job site, the effect of a normal gap under the fire 0

door- was not considered. It had been perceived that the wall and door provided a barrier to prevent the transmission of potential ignition sources, when performing hot work activities. Therefore, no fire prevention measures were instituted on the Intermediate Building side of fire door S36F.

2. , Corrective steps that have been taken and the results achieved:

Upon notification to the Site Fire Protection Engineer of the situation,. immediate action was taken to station a firewatch on the Intermediate Building side of the door, per Administrative requirements.

I

3. Corrective .steps that will be .taken to avoid further viola-..

tions:

An awareness critique with Fire Protection, personnel was conducted on June 10, 1993 to heighten their awareness with regards to fire protection requirements. Recent .fire protection problems were discussed"at.this= meeting, including this violation and the corrective steps necessary to prevent recurrence. Corrective steps. include o All personnel present were informed that all doors may have gaps, such that, they do,not provide a barrier to prevent the transmission of potential ignition sources, when performing hot work activities. In order to mitigate this hazard, a. firewatch will be posted on the opposite side of the door, or a weld blanket shielding

~

the door and all openings will be provided.

o All personnel present were informed that when they are inspecting the hot work activity site, they must take the time to ensure all .fire; hazards are removed or protected within 35 feet of the site, prior to the starting of the hot work activity.

Site Fire Protection Engineer issued a letter to the Training bI The Department, on June 10, 1993,,requesting appropriate changes to the fire protection. section of the General Employee Training Lesson Plan, to heighten all plant personnel's awareness of fire protection requirements; Implementation of these changes is tracked by Corrective Action Report 2076.

j The Site Fire Protection Engineer issued a letter to all Shop

~ ~

Foreman, on June 11, 1993; to share with their, personnel the lessons, learned from the recent fire protection problems and the corrective action that must be taken to prevent recurrence.

4 ~ The date when full compliance will be achieved:

Full compliance was achieved June 7, 1993 when a firewatch was stationed on the Intermediate Building side of the door.

Ver truly yours, Robert C. Me edy xco Mr. Allen R. Johnson (Mail Stop 14D1)

PWR Project Directorate I-3 Washington, DC 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector