ML17261B100
| ML17261B100 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/17/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261B099 | List: |
| References | |
| 50-244-90-80, NUDOCS 9007230119 | |
| Download: ML17261B100 (4) | |
Text
APPENDIX A
~Notice of Violation Rochester Gas and Electric Corporation R.E.
Ginna Nuclear Power Station Docket No. 50-244 License No.
DPR-18 As a result of the Maintenance Team Inspection conducted from April 2-6,
- 1990, and April 16-20, 1990 and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (Enforce-ment Policy) ( 1990),
the following violations were identified:
Technical Specifications Section
- 6. 10.2 requires that records and drawing changes be retained for the duration of the Facility Operating License.
Station Procedure A-603 states:
- 1) All as-built drawings listed in Table 1 shall be received by the Central Records Specialist for distribution; and 2)
As a minimum, one copy of each document shall be retained by the Central Records Specialist in accordance with the requirements of Refer-ence
- 2. 1.
(Reference
- 2. 1 is Procedure A-1701, Ginna Records).
Contrary to the above, no copy of Westinghouse drawing E-2508, for the N-31 Source and Intepmediate detector before and after the recent modifi-cation that added a drainage hole to detector housing ML-23785, was being retained by the Central Records Specialist during the April 1990 team inspection.
This is a Severity Level V Violation (Supplement I).
10 CFR 50.59(a)(2) specifies, in part, that a proposed change shall be deemed to involve an unreviewed safety question if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created.
10 CFR 50.59(b)( 1) specifies, in part, that the licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report.
These records must include a written safety evaluation which provides the bases for the determination that the change,
- test, or experiment does not involve an unresolved safety question.
Station Procedure 301. 1, Station Modification Classification and Review, Steps 3.2.2 and 3.2.3 describe modifications as:
1) a change which involves a component change (vendor product improvement or user initiated) and 2) changes to... structures... which affect performance requirements...
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A.
Contrary to the above, the use of a building identified in the Up-dated Final Safety Analysis Report, Figure 1.2-1, Ginna Station Plot
- Plan, as a storage building, was changed to include long term storage of radioactively contami'nated equipment without completing a written safety evaluation which provided the bases for the determination that the use of this building for contaminated storage does not involve an unresolved safety question.
Contaminated equipment had been stored in this building from at least 1983 until April 1990.
B.
Contrary to the above, as of April 20,
- 1990, Work Order 90-21224 replaced the original N-31 Source Range Detector, without drain holes, with a new housing, with drain holes, without completing a
written safety evaluation which provided the bases for the determi-nation that the modification does not involve an unreviewed safety question.
The nuclear instrument system source range is described in the Updated Final Safety Analysis Report, Section 7.7.3.2. 1.
This is Severity Level IV Violation.
(Supplement 1)
Pursuant to the provisions of 10 CFR 20.201, Rochester Gas and Electric Corpo-ration is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply including for each vio.]atio'n:
( 1) the reason for the violations if
,admitted; (2) the corrective steps which have been taken and the results achieved; (3) the corrective steps which will be taken to avoid further viola-tions; and, (4) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
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