ML20080G415

Responds to Notices of Violation & Deviation from IE Insp Rept 50-244/83-05.Conscious Effort Continuously Being Maintained by Results & Test Section to Maintain Full Compliance W/Surveillance Schedule

ML20080G415
Person / Time
Site:	Ginna
Issue date:	06/10/1983
From:	Maier J ROCHESTER GAS & ELECTRIC CORP.
To:	Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8309200266
Download: ML20080G415 (3)

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ROCHESTER GAS AND ELECTRIC CORPORATION

• 89 EAST AVENUE, ROCHESTER, N.Y.14649

-c.uwa June 10, 1983 , ,_

w . wwce * = t . c on s 7i e 546-2700 Mr. James Allan, Regional Administrator U.S. Nuclear Regulatory Commission d Office of Inspection and Enforcement Region I 631 Park Avenue

[MT King of Prussia, Pennsylvania 19406

Subject:

I&E Inspection Report 83-05 Notice of Violation - Incomplete Preliminary Safety Evaluation Notice of Deviation - Failure to Fully Implement a Licensee Commitment

Dear Mr. Allan:

The Notice of Violation contained in Inspection Report 83-05 states the following:

" Contrary to the above, (10CFR50, Ginna Quality Assurance Manual Section 3, Quality Engineering Procedure 311) the Preliminary Safety Evaluation, approved on February 3, 1983, for the installation of the non-seismic closure device in place of the containment equipment hatch during refueling activities, did not evaluate and document the consequences of a seismic event in determining whether the proposed major modification involved an unreviewed safety question."

The corrective steps which have been taken as a result of this violation are that a revised Safety Analysis (EWR 3107B, Rev. 1) has been prepared, reviewed and approved in accordance with Engineering Department Procedures. The Design Criteria and revised Safety Analysis were subsequently reviewed and approved by the PORC (meeting 83-45, April 11, 1983) and NSARB (meeting 136, April 12, 1983). To preclude recurrence, personnel have been reminded to review all events for applicability and to include all applicable events in the Safety Analysis. Full compliance has already been accomplished.

The Notice of Deviation contained in Inspection Report 83-05 states the following:

" Contrary to the licensee's commitment the following corrective actions had not been fully implemented:

Although records are maintained of all tests to be performed (monthly Surveillance Schedule) no Master Log containing a remarks column is being maintained by the Results and Test Department.

0309200266 830610 PDR ADOCK 05000244 G PDR hol to

t b ROCf1 ESTER CAS AND ELECTRIC CORP. Syggy y l2 DstrE June 10, 1983 a ,,

to .M'r. James Allan

-- 'No verification of the schedule by three Results und Test Technicians is administratively required nor is any verification of its performance documented or otherwise indicated.

-- The Results and Test Supervisor's Master Log was the same monthly surveillance schedule as maintained by the Results and Test Department. This same monthly s' surveillance schedule is also distributed to various departments and other personnel onsite. No verification of the Results and Test Department Master Log is admin-istratively required or otherwi'se indicated as being performed."

This Notice of Deviation stems fro::1 a January 27, 1983 letter from John Maier to Ronald Haynes responding to a Notice of Violation contained in I&E Inspectior. Report 82-24. This '

Notice of Violation states the following:

'" Technical Speci fication 4.1.1 requires a surveillance test of the loss of voltage / degraded voltage protection for the four^480 volt safeguard buses at least every thirty-one days +-25%.  ;

Contrary to the above, [as of October 28, 1982, the surveillance test frequency of the losa of voltage / degraded voltage protection for three of the . four 490 volt' safeguard buses exceeded thirty-one days ,+ 25% by .: days."

.Our records show an,d your inspection report states that PT-9.1 "Undervoltage Protection -480 Volt Safeguard Buses" was performed on September 20, 1982 (September 29, 1982 Bus 17 only) and-October 28, 1982. The period of time from September 20 to October 28 is within the'31 days + 251 as allowed by-yechnical Specification 4.1.1. Thus, it is our opinion' that we acted in full compliance with our Technical Specifications,,and*ask .

that you withdraw section B of the Notice of Violation contained Lin Appendix A of Inspect).on Report 82-24. ,

The January-27, 1983 letter made specific comnitments to you that were.not f ully7 implemented . Our failure to implement.

these commitments resulted from'.the Results and Test personnel not being f amiliar with ' tJtect. This was stated by your inspector in Inspection Report 83-05. Inspection Report 83-05 also addresses

, other instances where,RG&E reported incorrect-or l'naccurate information-to'you. Our corrective action to this problem was addressed at a recent Enforcement Conference held at your office en June 1,;1983.

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ROCHESTER GAS AND ELECTRIC CORP. 9 SHEET NO. 3 D*47E, J,une 10, 1983 To *Mr. James Allan A conscious effort is continuously being maintained by the Results and Test Section as well as the Results and Test Supervisor to maintain full compliance with the Surveillance Schedule. This is accomplished by a constant review of upcoming and. completed tests by use of a scheduling board as well as maintaining a current surveillance schedule. In addition, a comment 'section has been added to the surveillance schedule to be used to log unscheduled test completions and other pertinent testing information.

In: addition, a review of the Ginna Technical Specification testing requirements as compared to the current surveillance program is currently in progress. This review should be completed by November 1, 1983 and will ensure that the surveillance program includes all the Technical Specification requirements. This review,' coupled with the increased effort to maintain the surveil-lance schedule should ensure that surveillance test frequencies are not exceeded.

Very truly yours, M

John E. Maier JEM/Ims Subscribed and worn to me on this /s - day of J ne, 1983

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WILLIS C S E NOTARY PUCUC, Sta's of it.Y., Monroe County My Comm ss:en Expires March 30,196

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