ML17261A626

Responds to Violations Noted in Insp Rept 50-244/87-19. Corrective Actions:Procedure CP-224 Changed on 870731 to Incorporate Steps Required to Document Radiation Source Check Steps

ML17261A626
Person / Time
Site:	Ginna
Issue date:	10/01/1987
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8710130224
Download: ML17261A626 (8)

See also: IR 05000244/1987019

Text

i REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (BIDS)ACCESSION NBR: 8710130224

DOC.DATE: 87/10/01 NOTARIZED:

NO DOCKET FACIL: 50-244 Robert Emmet Ginna Nuclear Planti Unit i.Rochester Q 05000244 AUTH.NAME~~~AUTHOR AFFILIATION

OBER R.N.Rochester Qas 5 Electric Corp.REC IP.NAME RECIPIENT AFFILIATION

RUSSELL W.T.Region 1 Office of Director SUBJECT: Responds to violations

noted in Insp Rept 50-244/87-19.

Corrective

actions: Procedure CP-224 changed on 870731 to incorporate

steps required to document radiation source chec k steps.DISTRIBUTION

CODE: IE01D COPIES RECEIVED: LTR~ENCL~SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: License Exp date in accordance

eith 10CFR2i 2.109(9/19/72).

05000244 RECIPIENT ID CODE/NAME PDi-3 PD RQNC ERNAL: LPDR NSIC INTERNAL: AEOD NRR MOR ISSEAU)D NRR/DREP/EPB

NRR/DRIS DIR OE~EBERMANi

J REG FILEE)FTl E Oi COPIES LTTR ENCL RECIPIENT ID CODE/NAME STAHLEi C DEDRO NRR/DOEA DIR NRR/DREP/RPB

NRR/P MAS/ILRB OQC/HDS2 RES DEPY QI NRC PDR COP IES LTTR ENCLTOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL

N[1~~v~~C'y', so~~>51AIC ROCHESTER>As.'.e',t.,I~hi<'.iRi-ORATION

89 EAST AVENUE, ROCHESTER, N.Y.74649-OP07

ROGER Vd't(OQEf, YKC PflCSl CRT f<L'C~RK'.PROD@, T,c TOLD@+Oh(ARE<conc ale 546 2700 Ginna Station October 01, 1987 Mr.Vi lliam T.Russell, Regional Administrator

U.S.Nuclear Regulatory

Commission

-Region I 631 Park Avenue King of Prussia, PA 19406 Subj ect: Inspection

Report 50-244/87-19

Notice of'iolation

R.E.Ginna Nuclear Power Plant Docket No.50-244 Dear Mr.Russell: Rou tine unannounced

occupati onal radiation protection

Inspection

Report 50-244/87-19

states in part: As a result of the inspection

conducted on July 27-31, 1987, and in accordance

with the"General Statement of Poli cy and Procedure for NRC Enforcement

Actions", 10 CFR Part 2, Appendix C (Enforcement

Policy)(1986), the following violation was identified:

Techni cal Speci f'i cati on 6.8.1 (a)requires, in part, that written procedures

be established, implemented

and maintained

covering the activities

referenced

in Appendix A of Regul atory Guide 1.33, November 1972.One of those activities, procedures

for control of measuring and test equipment, in Section H of Appendix Regulatory

Guide 1.33, requires that specific i mpl ementi ng procedures

for each survei llance test, inspection

or calibration

listed in Technical Specifica-

ti ons be provided to assure that...instruments...

are properly controlled, calibrated

and adjusted at specified periods to maintain accuracy.Table 4.1-3, Accident Moni tori ng Instrumentation

Survei l lance Requi rements, of the li censee~s Technical Specifications

requires that a channel calibration

of the Containment

Area High Range Radiation Monitors (R-29 and R-30)be performed at each refueling in accordance

with criteria for calibration

provided in Table II.F.1-3 of NUREG-0737.

87~0>30m<BVX0OS PDR ADOCK 05000244 8 PDR g~ml

'

Page 2 Inspection

Report 87-19 October 01, 1987 Contrary to the above, as of July 30, 1987, a procedure was not established

and implemented

which incorporated

all criteria for calibration

specified in Table II.F.1,-3 of NUREG-0737.

Speci fi cally, procedures

di d not provide for channel calibration

of monitors R-29 and R-30 with a source at one point below 10R/hr.The following is=-RG&E's explanation

and reply to this statement of'iolation:

1~Corrective

steps which have been taken and the results achieved: Rochester Gas and Electric Corporation (RG&E)agrees wi th the violation identified

in that Maintenance

Calibration

Procedure CP-224"Calibration

and/or Maintenance

of Containment

High Range Area Monitors" was not properly maintained

to cover the complete calibration

of these instruments

in accordance

with Table II.F.2.-3 of NUREG-0737.

Specifi cally, the steps which require channel calibration

using an approved radiation source below 10 R/hr were i nad ver ten tl y deleted when a Procedure Change Notice (PCN)was submitted to change the Procedure from Revision 3 to Revision 4.a~Procedure CP-224 was changed on July 31, 1987 to incorporate

the steps required to document the radiation source check steps.Revised copy of CP-224 was used and completed for both containment

high range radiation monitors on August 12, 1987, with satisfactory

results.2 0 Corrective

steps which wi 1 l be taken to avoid further viol ati ons: a~b.The change to incorporate

the performance

of a radiation source check was a permanent change to CP-224 and, therefore, will continue to ensure that these steps are performed and documented.

A letter has been issued to all plant personnel to stress the importance

of a step by step review of all procedure changes to insure that all changes are incorporated

properly, and to all Procedure Specialists

to stress the importance

of routing all permanent procedure changes (other than typographical

error corrections)

for a step by step review for complete-ness.

Cl

Page 3 Inspection

Report 87-19 October 01, 1987 3~Date when full compliance

will be achieved: Documentation

of the source check of the high range containment

radiation monitors was achieved upon completion

of the revised CP-224 procedure on August 12, 1987.Very truly yours,~a W~Roper PT.Kober Vice President Electric Production

xc: Document Control Clerk RVK: ss

49 CS