ML20070W161

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Responds to NRC Re Violations Noted in IE Insp Rept 50-244/82-19.Corrective Actions:Handholes Cut in Wire Gates Barricading Locked Areas Normally Used in Auxiliary Bldg
ML20070W161
Person / Time
Site: Ginna Constellation icon.png
Issue date: 12/29/1982
From: Maier J
ROCHESTER GAS & ELECTRIC CORP.
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
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NUDOCS 8302180312
Download: ML20070W161 (2)


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ROCHESTER GAS AND ELECTRIC CORPORATION

  • 89 EAST AVENUE, ROCHESTER, N.Y.14649 re t t eso%r

..r a toca n. 546 2700 December 20, 1982 U.S.

Nuclear Regulatory Commission Office of Insoection & Enforcement Reqion 1 631 Park Avenue King of Prussia, PA 19046 ATTENTION:

Mr. Thomas J.

Martin, Director Division of Engineering and Technical Programs

Dear Mr. Martin:

This letter is in response to Appendix A of Inspection No. 50-244/82-19 received on December 7, 1982.

As a result of the inspection conducted on September 27

- October 1, 1982, and in accordance with the NRC Enforcement Policy (10 C PR 2, Anoendix C), oublished in the Federal Register on March 9, 19R2 (49 PR 9987), the following violation was iden-tified:

10 CPR 20. 20 3 (c) (3) requires that controls established for high radiation areas be such that no individual will be orevented from leaving a hioh radiation area.

Contrary to the above, on September 29, 1992, high radiation area locked gates in the Auxiliary Building were constructed with bolts and padlocks such that an individual would be prevented from leaving a high radiation area.

This is a Severity Level TV violation (Supplement TV.D.5).

As acknowledged in the report, the initial modifications.

were made to meet the above requirements on October 1, 1982.

The modifications made were cutting handholes in the wire gates, barricading the locked areas normally used in the Auxiliary building.

This allowed an individual to unlock the gate from the inside, oroviding he had the key in his possession.

Although an individual would not necessarily have a key in his oossession in the area, this would be the case in almost all entries.

Also, the existing locked area procedure A-1.1, " Locked Radiation Areas" cautions in steo 3.5.1

... Precautions should be taken 8302180312 820202 PDR ADOCK 05000244 0

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so that the gate cannot be accidently locked shut".

The long term changes which will be made to meet these requirements are as follows:

1.

In locked areas which are normally accessed by operations and other workers, the gate locks will be changed to allow egress from inside without a key.

A Technical Staf f Request has been initiated to have these changes made.

2.

In areas which are not normally accessed, such as the containment vessel reactor coolant filter, A sump and temocrary locked radiation areas, procedural controls, or other methods, will be utilized to ensure personnel cannot be locked into high radiation areas.

Since, in previous NRC Inspections, the previously existing procedural controls of locked areas was acceptable and changes were made as outlined above, I believe we are now in compliance with the intent of 10 CPR 20.203 (c) (3).

We will ma) e the remaining changes as outlined above in g

a timely fashion to furthe ensure that_ egress from a locked high radiation area is always possible.

Sincerely,

3. A,%6-J hn E.

Maier Vice President Electric & Steam Production JEM/1vh l

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