ML062680254

NRC Staff Letter from Guy Vissing to Dr. Robert Mecredy, NRC Safety Evaluation to Rg&E, Dated July 22, 1998

ML062680254
Person / Time
Site:	Ginna
Issue date:	07/22/1998
From:	Vissing G NRC/NRR/DLPM/LPD1
To:	Mecredy R Rochester Gas & Electric Corp
Cruz, H. D.
References
TAC MA0391 NUDOCS 9807270329, NUDOCS 9807270331
Download: ML062680254 (6)

Text

JANI-31-2*06 MOB P.02/07 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. 0.C. WN4M4 ally 22# 1In Dr. Robert C. Mecredy Vice President, Nuclear Operations Rochester Gas Wd Electric Corporation 109 East Avenue Ro6hestor, NY 14849

SUBJECT:

APPROVAL OF PROPOSED AWEV. ION 25 TO THE ROCHESTER OAS AND ELECTRIC CORPORATION'S R. E. GINNA NUCLEAR POWER PLANT OUALITY ASSURANCE PROGRAM FOR STATION OPERATION (TA, NO. MA030I)

Dear Dr,

Mecredy.

By letter dated December 17, 1997, you trunmltted proposed Revision 24 to the R. E. Ginna Nuclear Power Plant Ouality Assurance program for Siation operatlon (QAPSO). Revision 24 to the QAPSO was subrnitted In accordance with the rquiruments of 10 CFR 50.54(a)(3) as reflecting changes that reduced commitmeents In tfh QAPSO description pteviously approved by the NRC. 'However. this submittal also included changes for which RG&E was not seeking NRC approval based on the licensee's concluslon that .theyhad no I.pact on commitments in the QAPSO.

As a result of requests for additional Information by the NRC staff and additional reorganbzstion changes, you amended or claifled the oiiginal subnittal vila correspondence dated April 6, 1998.

This submhttsl forwarded Revslon'25 to the QAWOO which provided add lionl justification for changes previously Identified as reductions In commitment In Revision 24 to the QAPSO, end lse6 Identified new organizational changes for which you were not seeking NRC approval.

Therefore, Revision 25 to the QAPSO s.upereded Revilson 24 in its entirety.

The enclosed safety evaluation documents the bases for our conclusion that the reductions In commltments Identified In Revision 25 to th QAP.SO continue to tloisfy the requirements or

• Appendix B to 10 CFR Part 50 and am, therefore, acceptable.

Sincerey Guy 8. Vissing, :Snior"roject Manager Project Directorate 1H Division of Reactor Projects . 111 Office of Nuclear Reactor Regulation Docket No. 5244

Enclosure:

Safety Evaluation cc WOWnc: See next Poo*

" JAN-31-2006 15:08 P.

Dr. Robert C. Mecr*dy Rochester Go* and Electric Company R.E. Ginna Nuclear Power Plant Peter 0. Drydale, Sr. Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road Ontarlo, NY 14519 Regional Administrator.Region I U.S. Nuclear Regulatory Commission 476 AMlendale Road Kng of Prussia, PA 19406 O

Mr. F. Wlhlarn Valentino, President New York Stae Energy, Research, and Development Authority

• Corporato Planz West 2586 Washington Avenue Extension

• Albany, NY 12203-6399 Charles Donsldson, Esquire, Assistant Attorney General New York Department of 1*1v 120 Brosdway New York, NY 10271 NMcholas 8. Reynolds Winston & Strewn 1400 8 Street N.W.

Wash*ngton; b; 200054502 Ms. Thelma Wideman, Director Wayne County Emergency Management Office Wayne County Emergency Operations Center 7338 Route 31 Lyons, NY 14489 Ms. Mary Loulse Malsenzahl Administrator, Monroe County Office of Emergency Preparedness 111 Wast Falls Road, Room 11 Rochester. NY 14820 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plan, loth Floor Albany, NY 12223

• TAN-31'-2006 IS: 98 P.04/0?

UNITED STATES NUCLEAR REGULATORY COMMISSION o ~WASHINGTON,. D.C.

• 9AFETY EVALUATION BY-THE OCFICE OF NUCLEAR REACTORREGULATION PROPOSED1REVISION 25 TO T_62ROCHESTER GAS AND ELECTRIC CORPORATION QUALIrY ASSURANCE PROGRAM FOR STATION OPERATION R. E. GINNA NUCLEAR POWER PLANT DOCKET NO. 5-244

1.0 INTRODUCTION

By letter dated December 17, 1997, Rochester Gas and Elect*ic Corporation (RG&E) transmitted proposed Revision 24 to the R. E. Ginna Nuclear Power Plant Quality Assurance Program for Station Operation (QAPSO). Revision 24 to the QAPSO was submltledin accordance with the requirements of 10 CFR 50.54(a)(3) as reflecting changes that reduced commitments in the QAPSO description previously approved by the NRC, However, tis submittal also Included changes for which RG&E was not seeking NRC approval based on the licensee's conclusion that they had no Impact on commitments in the QAPSO.

As a result of requests for additional Information by the N.RC staif (Reference 2) and additional reorganization changes, RGAE amended or calefied Its original submittal via correspondence dated April 6, 1998 (Reference 3). This submittal forwarded Revision 25 to the QAPSO which provided additional justificston for changes previously Identified as reductions in commitment in Revision 24 to the QAPSO, and also Identified new organizational changes for which RG&E was not seeking NRC approval. Therefore, Revision 25 to the QAPSO superseded Revision 24 In its entirety. This evaluation only addresses changes In-Revision 25 to the QAPSO which RG&E has deemed to be reductions in commitment pursuant to 10 CFR 50.54(a)(3).

2.0 EVALUATLIO In Its December 17, 1997. submittal (Reference 1), ROLE proposed to establish that a *grace period" of twenty five per cenl (25%), not to exceed 90 days, be applied.to frequencies for:

performance of periodic activities described In the QAPSO and the regulatory guides and..,'.

standards listed In the QAPSO, Table 17.1,7-1, "Conformance of Ginna Station Program to Quality Assurance Standards, Requirements, and Guldes?'

In its request for additional Information (RAI) dated April e, 1998, the NRC requested that RG&E supplement its submittal to clarity which specific periodic activides described In Table 17.1.7.1 of the QAPSO would be affected by the (plus) 25% "grace period." NRC also requested that RG&E describe the Impact of the proposed deferral on RG&E's audit activities and corresponding commitments to Regulatory Guide (RG) 1,33, 'Quality Assurance Program Requirements (Operation)", and RG 1.144, "Auditing of Quality Assurance Programs for Nuclear Power Plants.*

RG&E Incorporated its response to the NRC's RAI In Revision 25 to QAPSO which was transmitted via letter dated June 4, 1995. In this revlsion to the QAPSO, RG&E proposed to revise its commitments to RGs and standards as necessary to apply a grace period of 90 days;.

for the performance of the following activities:

9007270331 960722 PDR ADOCK O5Oo244 Enclosure P PDR

. JAN-31-2006 15:08 P.050

, Annual Supplier Evaluation& In accordance with RO 1.144, Revision I (Section 0.3.b.2)

/ *Triennial Vendor Audits In accordance with RO 1.144, Revision I (SecilOn C.3.b.{2))

• RecertificaUon In accordance with ANSI N45,2.23-1978, "Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants' (Sections 3.2 and 5.3)

V/. Annual Evaluations In accordance with ANSI N45.2.6-1978, "Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plant? (Section 2.3)

• InternalAudits in accordance with ANSI Nl8.7-1972, (Section 4.4)

Specifically, RG&E has proposed to modify its RG cornmilmenl as follows:

1. RG 1.33. RevIsIOn 0 Internal Audits . Section C.3,a,(1) of RG 1.144 refers to RG 1.33 for requirements. Since RG&E Is committed to RG 1.33, Revision 0, except for Appendix A, ANSI N18.7-1972 requirements are Invoked. A grace period of 90 days will be applied to the 24-month frequency for:internal audits described In Section 4.4 of ANSI N1B.7-1972, which states that.

audits of safety related activities are completed 'within a period of two years.' RG&E noted that this grace period will not be applied to audits of the Nuclear Emergency Response Plan to satisfy the requirements of 10 CFR 50.54(t), and Slation Security Plan to satisfy the requirements of 10 CFR S0.54(p)( 3 ), 73.56 (g)(1) and (g)(2) and 10 CFR 73.55(g)(4). Audit frequency and further discussion of these audits are described in their respective plans.

2. RO 1.58. "Quallfilcaton of Nucleyr Power Plmn¶ InsPection. Examinstlon. and Tetijng Personnel.' Revision I Annual Evaluations - Section 2.3 of ANSI N45.2.5 -1978 states that "Any person who has not performed Inspection, examination, or testing activities in his. qualified area for a period of one year shall be reevaluated..." The 90-day grace period will be applied to thisactivity.

3. RG 1.144 Revfislon1 (a) Supplier Audits - Section C.3.b.(2) of Reg. Guide 1,144. Revision I states that audits be performed on a .'trennial basis., The 90-day grace period will be applied to this activity.

Section 17.2.5 of the QAPSO is being revised to allow for applicatlon of the grace period.

(b) Supplier Evaluations - Section C,3,b.(2) of Reg. Guide 1.144 Revision I states that documented evaluations be performed "annually'. The 90-day grace pelod will be applied to this actIvity.

(c) Revised commitment to perform vendor audits from lat least every three years' to "on a triennial basis" to be consistent with the wording used In RG 1.144, Revision 1, Section C.3.b.(2).

JAN-31-2006 15:09 P. 06/07*

.3

4. RG 1.148. wousi Ication of Qualltv AssUranco Proor rn Augot Personnel for Nucdear Power Plants.! Revlison 0 Lead Auditor Recertifications - Sections 3.2 and 5.3 of ANSI N45.2.23-1978 require that an annual assessment be performed of each lead auditors qualification and that each lead auditor's records be updated annually. The 90-day g'aceperiod will be applied to this a Oivity.

AddIllonally, RG&E modified QAPSO Section 17.1.7, 'Regulatory Cormitrneni,"to establish a commitment that for actiYitIes deferred In accordance the 90-day 'grace pediod," the next performance due date for such activities "wil be based on their originally scheduled date, i.e., in all cases, the peilod"cty for these activitles will not be allowed to exceed the original RG' commitment plus 90 days.

Appendix 0,"Qumilty Assurance Criteria for Nuclear Power Plants and Fuel R'eprocessing Plants,' to 10 CFR Part 50, "Domes lc Ucensing of Productiol and Utilization Facillties,l requires, Inpart, that the quality assurance program provide for Indoctdnation and training of personnel performing activities affecting quality as necessary to ensure that such personnel achieve and maintain suitable proficiency, and Italso establishes that audits of the quality assurance programs for these faclitles (including their sup'pliers) be conducted at regular Intervals. As described 1.148 to satisfy above, RG&E relies on Its commitments to RGs 1.33, 1.58, 1.144, enf.

these requirements...

While Appendix 9 to 10 SFR Part 50 provides that audits be performed 'periodically,' and that suitable personnel proflicency be malntainad, It does not provide specific Intervals for performing these activities. As a result, the NRCestablished nominal periodicity Intervals for certain activities described in RGs 1.33,*1.58,1.144, and 1.146. However, the NRC stafis regulatory position on the required periodicity for these activities was not ained at preventing flexibility in the scheduled performance of suchactivitles but rather at providing an objective measure for ensuring plant personnel proficiency and suitable periodic Intervals for activities affecting quality as required by the regulations.

Since the 90-day grace period proposed by RG&E only alms to allow some limited additional flexibility In scheduling activities associated with the subject RGs, personhel proficiency :.

standards and periodicity objectives In the QAPSO will remain unchanged. This is consistent with the provisions in Section 17.2 of NUREG-O800, "Stand"rd Review Plan," (SRP) and Is, therefore, acceptable.

3.0 QQrLU2I0 While the proposed 90-day deferral period (grace period) proposed by RG&E for the RG activities desrcribed above constitute a reduction In commitments In the QA program description previously approved by the NRC, such exceptions continue to satisfy the provisions of Section 17.2 of the SRP. Therefore, proposed Revision 25 to RG&E's QAPSO, daled June 4, 1098, conlinues to comply with the quality assurance criteria of Appendix B to 10 CFR Part 50 and is acceptable.

JRN-31-2006 15:09 P.07/07 9

.4 O 4.0 4 1.0 Robert C. Mecreoy (RG&E) letter to USNRC, Revised Submittal of Quality Assurance Program for Station Operation- RE. Ginn& Nuclear Power Plant- Docket No. 50-244,"

dated December 17. 1997.

2.0 USNRC Letter to RG&E, 'Request for Additional Information Concerning Revision 24 of the Quallty Assurance Plan for the R.E. Ginns Nucleir Power Plant (TAC No. MA0391). dated April 6, 1998.

3.0 Robert C. Meer.dy (RG&E) letlr to USNRC, "Revised Submittal of Quality Assurance Program for Station Operatlon - R.E. Ginn* Nuclear Power Plant - Docket No. 50-244,0 datld June 4, 1998, Principal Conbibutor. J. Poralta Date: auy 22, 19M Tf'Tpi P. R"7