ML20092M472

Responds to NRC Re Violations Noted in IE Insp Rept 50-244/84-07.Futuristic Effective Date Considered Isolated Case W/Subsequent Distributions Concurrent W/ Effective Date.Nrc Audit Findings Improperly Evaluated

ML20092M472
Person / Time
Site:	Ginna
Issue date:	06/08/1984
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20092M451	List: ML20092M472
References
NUDOCS 8407020257
Download: ML20092M472 (5)

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ROCHESTER GAS AND ELECTRIC CORPORATION e 89 EAST AVENUE, ROCHESTER, N.Y.14649-O' f ROGER W. MOBER

' ytCE pytESIDENT TF L E PMON E.

ELecTasc a STEAM PRODUCUON aat 4 CODE. v e 546-2700 June 8, 1984

-Dr. Thomas E.

Murley, Regional Administrator U.S.

Nuclear Regulatory Commission l Region I 631-Park Avenue King of Prussia, Pennsylvania 19406

Subject:

-I & E Inspection Report 84-07 Notice of-Violations Conduct. of Plant Operations Review Committee, Control

.of-Plant Procedures, and ' Conduct of Quality Assurance Audits R.

E. Ginna Nuclear Power Plant, Unit No. 1 Docket 50-244

Dear Dr. Murley:

In accordance with the above subject which stated "As a : result - of the inspection conducted on February 13, 1984 through March 1,

1984, and in accordance with the NRC Enforcement' Policy (10~CFR 2, Appendix C), published in the Federal Register on March 9, 1982 (47 FR 9987)-the ifollowing Violations were. identified:

A.

Technical Specification 6.5.1.5~ specifies that a PORC quorum consists of at-least the chairman and (four)

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4 members,' no more than two of which may be alternates.

Contrary to' the above, a PORC quorum was not indicated

-present for meetings83-111 and 83-121.

B.

Technical Specification 6.8. 2 and licensee procedure A-501, " Plant Procedures Preparation and Classifi-cation",' Revision 2, require that procedures be approved a

prior to implementation.

Contrary to the _ above~ on December 11, 1981, procedure Pr-13.1.15, Revision 0, was used to perform a surveillance

'. test'on the Halon fire suppression system, although it was not approve _d for use by the Plant Superintendent 8407020257 840625 PDR ADOCK 05000244 E

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2 NRC Inspection Report 84-07 Page 2 runtil December 14, 1981.

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'10--CFRc50,, Appendix B,

Criterion XVI and the licensee

Quality Assurance Manual, Section-16 require conditions adverse.to quality be promptly. identified.and corrected.

Contrary.to the above, the violations in paragraphs A and.B above-were identified _during licensee quality

assurance audits, but were not documented, evaluated or. corrected by the licensee.

the following is submitted.in response.

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A.

With respect to. meeting 83-111, a proper quorum attended

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this meeting.- One alternate member's name was incorrectly

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typed in the wrong - section of our minute's format

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under "Others Attending".

When an. alternate member

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attends a PORC' meeting, and the regular member does not, the alternate is considered a-voting member.

With respect'to meeting 83-121, the quorum consisted of three (3) regular members and two (2) alternate members.

One of the regular members-administered the meeting in'the abse'nce of the chairman.

This delegation of the chair is identified in our administrative procedures.

B..

Technical Specification 6.8.2 states "Each procedure and' administrative' policy of 6.8.~1 above,.and' changes

.thereto, shall~be= reviewed by the PORC'and approved by the Station Superintendent prior to implementation and ' reviewed periodically as set forth in the applicable procedures."

Also, plant procedure A-501, Plant Procedure Preparation.and Classification, states " Procedures

shall be reviewed and approved for use prior -to performing the activity in accordance with A-601.

Plant procedure

~A-601,-' Plant Procedure Do'cument Control, states "After-all.necessary signatures are on the coversheet, the

'PS (procedure specialist) shall indicate the Effective Date on the coversheet and distribute the procedure in'accordance with A-602.'"

Plant procedure A-602, Plant Procedure Distribution, states " Transmittal of-'all controlled copies shall be performed on the

" Effective Date" of.the procedures" and "Raceipt and

' incorporation of the. changes shall be accomplished for Control Copy #2.and #4 on the effective date,

.plus or minus one working day."

It ~is the policy 'of Ginna Station that the PORC Review

~ Date and the Superintendent's signature on the coversheet

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'o f fa procedure documents the requirements for PORC c review and plant superintendent s a'pp'roval respectively.

Therefore, once the appropridte dignatures are on the~coversheet, the procedure is approved for use.

The act of placing an effective date on the coversheet by.the procedure specialist is4 to documen't the formal distribution date, thyt: dc1tte when adequate :: opie s of a procedure are av311able.for distribution and

- u s e.-. This date 'is wherl ?.he various controlled copies of~a procedure are either updated, or have been transmitted to' control"copysholders for; updating of their copy.

Thistpracti'ce; precludes use-of previous' revisions which havo been superceded in most-situations and g

allows for early use of approved new procedures prior

.to formal, distribution ivi emergency. situations.

In the future',,to ensure procedure use and effective i

dates are -- compatible and previous. revisions remain unavailable for use-i'n all situations, distributio'n procedures are - being revis'ed. to ' preclude use of equipment related procedures 1n advance of their effective date.

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7 This change when3 fully-implemented by July 15, 1984 D

will necessitate' distribution concurrent with need l

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for:usein' situations inv.alving need prior to routine-ndistribution.

It should also be notedEthat in all.

instances, the ' temporary change to procedures policy, as' defined.by Technical. Specification 6.8.'3 is still

,available'for use bylall plant personnel.

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The procedure completed on 'Decemb'er 11, 1981 had been-

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previously distributed and satisfied all the requirements of ITechnical Specification 6.8. 2 and Plant Procedure A-502.

Although the Dece'mber 14, 1981 effective date was somewhat in error, beincj 4 days $fter distribution, it had no impact on the relateditest activity as PT-13.1.15 was.a new procedure eliminating.any concernofor a 6

. previous revision.

This " futuristic" effective date

'is c~onsidered an isolated case with subsequent distrib-utions concurrent with the effe'dtive date.

t C.

. Violation-C is based primarily on the events associated.

with our handling 1of = alleged violations of Technical

. Specification administrative -requirements during internal U

audit 83-36.and' reported'in I -& E Inspection' Report 84-03.

.I & E Inspection Reports 84 and '84-07 : describe two Technical. Specification violations-inappropriately

' handled-during the audit. process.

Additionally, I-

,& E Inspection Report 84-07 states that the audit findings on these items should have resulted in appropriate corrective. action, when in fact the audit-findings

..were not properly evaluated or resolved.

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s NRC Inspection Report 84-07 Page 4

.'A : thorough ; review ~ of, the -audit documentation including

. draft reports,~ final-reports, and notes associated with the -resolution of 'the draft audit findings indicate

-that while timely corrective actio'n may.not have been taken withl regard to the PORC quorum-issue, we disagree that;the related, audit finding-wa's inappropriately evaluated:.within the Quality Assurance audit organization.

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Additionally, all' actions associated with the approved i

procedure concern were reviewed and res'olved during

the;same time-frame by the. auditor supervision based

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on. previous and1 current knowledge of the established

-procedure: review and approval process which was confirmed

--with.PORC' members during a subsequent meeting.

It should be noted that the procedure approval concern,

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' identified.as Violation'"B", was.not raised during the' conduct of, an xaudit' including audit 83-36 but

'in theLresponse. review consideration of an unrelated

. finding.~-

.The PORC:' quorum concern presented:at.the October 12 exit meeting-as draft..AFCAR"5 was-determined prior lto report -issuance 'to.be an out of scope problem which

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is; processed by other methods.

The audit ~ file clearly

_ ~ documents the October: 25 supervisory review, bases,

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andirecommendation that the problem-be forwarded to 6

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.Ginna Station'QC in accordance with the established Corrective Action' Procedure.

CAR 1537 is currently tracking. the investigation of the PORC quorum problem, the cause'- investigation. and actions to preclude recur-rence'.

Quality Assurance assessment, to date, indicates

' that' the audito'r attempted ' to notify the QC Engineer on November.10 nearly two (2) weeks after the audit

_ report was; issued.

Discussion with the QC Engineer has indicated that he didRnot remember receiving notif-

'ication and subsequently no. action was taken.

Actions

,to preclude.. recurrence have been taken within the audit organization during a recent auditor meeting which reviewed.'their handling of identified concerns

'and.significant deviations - f ound. during audits or routine plant visits.:

Your.~ report identifies a few other examples of recent audit program deficiencies which has raised a concern over;the e f fectiveness of the audit program.

As a result of deficiencies identified in I & E Inspection R'eport183-23, audit conduct has received closer supervisory review.

Subsequent Modification Project audits are

b' ing better prepared ~and making better use of checklists.

e The audit ~ program is sufficiently comprehensive to

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NRC Inspection Report 84-07 Page 5

---identify deficiencies in safety related construction, stosting-and turnover activities.

The annual audit

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program evaluation presented to management in January have.resulted in Ginna actions which intend to eliminate overdue. responses and facilitate timely corrective action.- Early indications verify that these new Ginna

.c; actions are being e f fectively implemented.

Increased i

communications!during'the audits have also been stressed in attempt to achieve finding' acknowledgement prior to receipt of the report.

This will'.not only facilitate i

timely corrective action but will minimize post audit p

-disagreements'and discussions.

As part of the biennial review of the QA program, an independent audit.is being planned for later this Lyear.

The audit is intended to review the. corrective action progress in response to the December 1982 audit

-including. those actions formulated in '1983 with. regard

'to modification testing and turnover ac'tivities.

Also included will-be the traditional review of the-1 r

' audit program with emphasis on the Quality Assurance

-Audit-Organization as well as'a broader examination

.of the overall ' effectiveness of the1 Quality Assurance program.

truly yours, dA er'W. Kober I ubscribed and sworn to me S

' onEth's 8th-day f Ju e -1984.

N' i _ (ykk (A4A ? -

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m...ai. mucs' NOIARY PUBUC, State of N.Y Mdnroe County

,My Commission Expires March 30,19M -

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