ML17254A509

Responds to Generic Ltr 85-07, Implementation of Integrated Schedules for Plant Mods. Informal Integrated Living Schedule Already in Effect & Proven Functional.No Incentive Exists to Formalize Program

ML17254A509
Person / Time
Site:	Ginna
Issue date:	08/06/1985
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Thompson H Office of Nuclear Reactor Regulation
References
GL-85-07, GL-85-7, NUDOCS 8508140069
Download: ML17254A509 (8)

Text

REGULATORY Ib, RMATION DISTRIBUTION SYST (BIDS)

ACCESSION NBR;8508140069 OOC ~ DATE: 85/08/06 NOTARIZED:

NO DOCKET FACIL:50"244 Robert Emmet Ginna Nuclear Planti Unit li Rochester G

05000244 AUTH'AI1E AUTHOR AFFILIATION KOBERiR ~ 8 ~

Rochester Gas 8 Electric Corp, RECIP ~ I'IAt1E-RECIPIENT AFF II.IATION THOMPSONiHi Division of Licensing

SUBJECT:

Responds to Generic Ltr 85"07i "Implementation of Integrated Schedules for Plant Mods." Informal integrated living schedule already in effect S, proven functional.No incentive'xists to formalize program, DISTRIBUTION CODEe A001D COPIES RECEIVED:LTR ENCL SIZE' TITI E:

OR Submittal:

General Distribution NOTES:NRR/DL/SEP icy, OL:09/19/69 05000244 RECIPIENT IO CODE/NAME NRR ORB5 BC 01 INTERNAL: ACRS 09 ELO/HOSu NRR/DL DIR NRR/DL/TSRG NRR/DS I/RAB RGiV1 COPIES LTTR ENCI.

7 7

'6 6

1 0

1 1

1 1

1 1

1 1

RECIPIENT ID CODE/NAME ADM/LFMB NRR/DE/MTEB NRR/DL/ORAB TB E

FILE 00 COPIES LTTR ENCL 1

0 1

1 1

0 1

1 1

1 EXTERNALS 2AX LPDR NSIC NOTES:

03 05 1

1 1

1 1

1 EGLG BRUSKE'iS NRC POR 02 1

1 1

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 29 ENCL 26

(g.

l

)

iir w

r

~

v j arw

~

q

~ t,'FFW

'Ww>W, F

w, III I

f w

))'>r f>

tw wr, tl

,, ~

FA r u

I '> iti >I Iwa I

F') r I

F,a rjf Fw

<<F r, r <<r

~e F,

~

~

'r>jh aa r" I fa'lF FW f A ry r 'f F'1F "r) I

'f i, IF

~i F'w IF'l or <<I l

'<r I>>

',r O

IF,,~F>r f'yn,.>

>yaws r, fg w>f

~

'1 r 1 9Oapa" flwjwl e

'l w) w'FI>ww ril p'r) g ~w'I g illa rr l gpss t

wr

'i~r I>>'> Nr ) "f

I 'r~'~

." 1<7 ~

I 'I I,) I w

Il wwwa gyor9g~.lrggawr Ig r yww'p ",'a f 9r a

wx II jf

.y <<I F <<>>" Il ~F>>

,w> I I F

I

<l'

) I 1

I',w i Ff F I

'<f F

t

>W'

+agW($

N,,'rtw r

WP ra

<lXJ w i

IIIIIII lla< Oalsl IIII"'II~ irZZiZuu 8Z..::-'OCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649.0001 ROGER W. KO8ER VICE PRESIDENT ELECTRIC 6a STEAM PROOVCTION TELEPHONE 985 AREA CODE TIS 546.2700 August Director of Nuclear Reactor Regulation Attention:

Mr. Hugh Thompson> Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington>

D.C.

20555

Subject:

Generic Letter 85-07 "Living Schedules" R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Thompson:

This letter provides our response to NRC Generic Letter 85-07 "Implementation of Integrated Schedules for Plant Modifications".

In the letteri it was requested that each utility provide the NRC with its intentions regarding implementation of an Integrated Living Schedule (ILS)I similar to what has been set up in cooperation with Iowa Electric< using the format suggested in Enclosure 2 of 85-07.

The response form is attached.

RGSE believes that we are>

as a result of years of licensing experience and participation in the Systematic Evaluation Program>

effectively implementing an ILS at this time.

We maintain an integrated schedule through our normal budget review process.

All known projects are included and additions or changes are reviewed by the appropriate individuals. If changes are required in NRC commitmentsi the reasons for the required changes are provided to the NRC and a mutually agreed upon schedule adjustment is established.

We do not feel compelled to formalize an ILS program, with its resultant additional NRC negotiations>

and additional documentationi because we believe it will simply result in the same program plan we are now followingi plus add the burden of an expanded commitment tracking system as well as a formal prioritization system.

We stress that our experience has been satisfactory in large part due to the agreements reached during recent major licensing reviewsT such as the Systematic Evaluation Program>

where the NRC asked RG6E to set up modification schedules consistent with our abilities> including scheduling of RGGE initiated modifications (maintenancei plant bettermenti upgradesi etc).

This philosophy must be maintained>

both within NRR and Region II in order for us to continue our positive experience.

Especially important is the continuation of strong and effective project managementi which we have had the benefit of during the past many yearsi and the timely promulgation of backfitting reform (revision of 10CFR50.l09).

'8508140069 850806 PDII ADOCII 05000244 J

P PDR

4

~ k 1

ROCHESTER GAS AND ELECTRIC CO August 6g l985 Nr. Hugh Thompson SHEET NO.

In summary>

RG6E has had in effect an informal ILS> have been pleased with its implementation<

and thus do not have any incentive to add to RGSE and NRC documentation burden by formal-izing -the program.

We trust this satisfactorily responds to your concerns>

and provides the incentive to maintain dialogue and negotiations regarding modification schedules at the highly satisfactory level that they have been.

V truly yours R

er W. Kober

'i,)

C 1

4 4

ENCLOSURE 2

RESPONSE

FORMAT - GENERIC LETTER 85-PLANT NANE:

UTILITY:

R.

E.

Ginrra Nuclear Power Plant Rochester Gas and Electric Corporation INTENTIONS A.

Intend to work with the staff to develop an ILS B.

Have reservations that must be resolved before developing ILS C.

Oo not presently intend to negotiate an ILS with the staff 0.

Plan to implement an informal ILS only II.

STATUS A. If you answered I.A above:

1.

Have you settled on a method for prioritizing the work at your plant(s)?

Circle One:

Yes No If yes, select'best description:

Engineering judgement Analytic Hiearchy process Risk based analysis.

Cost-benefit analysis Other (p'lease describe)

If no, provide estimated date for selecting a'ethodology:

ate or If not presently available, provide estimated date for scheduling the selection of a methodology:

2.

Mhat is your estimated date for making a

submittal to the NRC-If not presently available, planned date for scheduling a submittal to the NRC

0 B. If you answered I.B above:

1.

Please explain vour reservations on separate sheet(s) or provide your schedule for supplying an explanation See separate sheet(s)

Separate submittal scheduled for ate

2. If available to meet with the staff to discuss your

concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact/Time Frame Phone Number C.

I< you answered I.C 1.

Would you he willing to meet with the staff to discuss the

. development of an ILS for vour faci litv(s)?

Circle One:

Yes No If yes, propose a time frame for such a meeting and provide a contact that can make arrangements.

Contact Time Frame Phone Number If no, any constructive comments you have would be appreciated.

III.

ADDITIONAL ITEMS Please make any sugges'tions you may have as to how a utility sponsored availabilitv/reliability pro,iect might be credited f'r plant safety enhancement.

Provide additional constructive comments as appropriate.