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)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (BIDS) i 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 COPIES RECIPIENT COP IES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDi-3 PD STAHLEi C INTERNAL: AEOD DEDRO NRR MOR ISSEAU) D NRR/DOEA DIR NRR/DREP/EPB NRR/DREP/RPB NRR/DRIS DIR NRR/P MAS/ ILRB OE~EBERMANi J OQC/HDS2 REG FILEE) RES DEPY QI RQNC FTl E Oi ERNAL: LPDR NRC PDR NSIC TOTAL 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, TOLD @+Oh(

YKC PflCSl CRT f<L'C ~ RK'. PROD@, T,c ARE< conc ale 546 2700 Ginna Station October 01, 1987 Mr. Vi lliam T. Russell, Regional Administrator U.S. Nuclear Regulatory Commission Region 631 Park Avenue I

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 iinspection mpl ementi ng procedures for each survei llance test, 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 fically, procedures di d not provide for channel calibration of monitors R-29 and R-30 with a source at one point below 10R/hr.

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 tl nad ver ten y deleted when a Procedure Change Notice (PCN) was submitted to change the Procedure from Revision 3 to Revision 4.

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:

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.

20 Corrective steps which wi 1 l be taken to avoid further violati ons:

The change to incorporate the performance radiation source check was a permanent changeof toa a~

CP-224 and, therefore, will continue to ensure that these steps are performed and documented.

b. 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.

~a W~

Very Roper truly yours, PT. Kober Vice President Electric Production xc: Document Control Clerk RVK: ss

49 CS