ML17261B136

Responds to Commitment Tracking Concerns Noted in Insp Rept 50-244/90-09 & Planned Corrective Actions.Util Confirms Commitments Dates for Implementation of Effective Shelf Life Program & Comprehensive Preventive Maint Program for Parts

ML17261B136
Person / Time
Site:	Ginna
Issue date:	08/14/1990
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9008230157
Download: ML17261B136 (12)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9008230157 DOC.DATE: 90/08/14 NOTARIZED: NO DOCKET PT FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas 6 Electric iCorp.

RECIP.NAME RECIPIENT AFFILIATION MARTIN,T.T. Region 1 (Post 820201)

SUBJECT:

Responds to commitment tracking concerns noted in Insp Rept 50-244/90-09.

DISTRIBUTION CODE: IEOID COPIES RECEIVED LTR i ENCL J SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 PD 1 1 JOHNSON,A 1 1 1'NTERNAL:

AEOD 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 DEDRO 1 1 NRR MORISSEAUi D 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 NRR/DOEA DIR 11 1 1 NRR/DREP/PEPB9D 1 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 OE@3X 1 1 OGC/HDS2 1 ECj FI 02 1 1 RGN1 FILE 01 1 EXTERNAL: LPDR 1 1 NRC PDR NSIC 1 1 po R

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D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTA'CT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR'NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

c lee ROCHESTER GAS AND ELECTRIC CORPORATION 4 89 EAST AVENUE, ROCHESTER N.Y. 14649 0001 ROBE'RT C.,r tFCREOY 'tEt.Etrrro NE Vice t'rertdent aREa COoE ate 546.2700

(,irma Nuctear Vrnerrrttrrn August 14, 1990 Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406

SUBJECT:

Inspection Report 50-244/90-09 R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Martin:

This letter provides our response to the commitment tracking concerns identified in the subject inspection report, and of our planned corrective actions. (See Enclosure 1) We are also confirming our commitments, including dates when our actions will be completed, for the implementation of an effective shelf life program and a comprehensive preventive maintenance program for spare parts. (See Enclosures 2 and 3)

RG&E will be pleased to provide additional information to assist the NRC in your review of RG&E's compliance and performance in these matters.

Very truly yours,

~Cg~+

Robert C. Mecredy Encs.

xc: U. S. Nuclear Regulatory Commission (Original)

Document Control Desk Washington, D.C. 20555 Ginna NRC Senior Resident Inspector t9."6~;.i r) O(57 90O814 PDR ADQC K O;OOO244 9 pDC

e ENCLOSURE 1 PAGE 1 OF 4 COMMITMENT TRACKING INTRODUCTION Detail 6.9 of Inspection Report 50-244/90-09 concluded that the commitment tracking system at Ginna may not be fully effective because there are no apparent plans for addressing certain items.

Report Detail 7.1 identified an apparent prolonged failure to meet a commitment (to maintain the excess letdown heat exchanger component cooling water return line containment isolation valve as normally closed). The Inspection Report cover letter requested that we evaluate the above matters, that we inform you of the assessment of our ability to meet and adhere to similar safety commitments, and of any planned corrective actions.

Both Inspection Report Details 6.9 and 7.1 address the implementation and maintenance of commitments. However, the concerns identified in Report Detail 6.9 apply to commitments which typically require a one-time action to complete (e.g., NRC Violations, Unresolved Items, Deviations). Report Detail 7.1 applies to design commitments which require continual cognizance and implementation (e.g., operating AOV-745 as normally closed).

Each of the above commitment categories require unique implementation and maintenance processes. Accordingly, our corrective actions will include separate methods for tracking each of the above categories of commitments.

We believe that both of our methods will provide us with a higher

. level of assurance that commitments are being maintained as well as providing a more efficient means of tracking commitment-related information. Both of our methods are discussed below.

The section titled Commitment and Action Trackin S stem outlines our approach to track the one-time action commitments that are discussed in Report Detail 6.9. The second section titled Desicen Basis Documents outlines our approach to tracking design commitments discussed in Report Detail 7.1.

RG&E's Commitment and Action Tracking System (CATS) which has been under development since 1989, is not the tracking system which was reviewed and identified in Report. Detail 6.9. RG&E has developed the plans, is developing the mainframe software, and will provide the necessary organization which will allow for the integration of a number of current tracking systems, one of which was reviewed in Report Detail 6.9, into a single system for regulatory and other types of commitments.

ENCLOSURE 1 (Continued) PAGE 2 OF 4 COMMITMENT AND ACTION TRACKING SYSTEM CATS RG&E has previously recognized the stated shortcomings with our current commitment tracking methods. To address this issue and concerns noted in Inspection Reports 88-15 and 89-05, a Commitment Tracking Assessment was completed in January, 1989. Subsequent to the assessment, the RG&E Commitment and Action Tracking System (CATS) Project Plan was developed and approved by RG&E's Senior Management in October, 1989. Development of our upgraded tracking system is progressing. As noted at. the March 6, 1990 NRC Region I RG&E Management Meeting, the anticipated implementation schedule for the tracking system is May 29, 1991 (Reference RG&E Configuration Management Level I Schedule included in the meeting handouts which are attached to Inspection Report 50-244/90-03, dated April 18, 1990).

The following provides a brief description of some of the features of the Commitment and Action Tracking System (CATS):

COMPUTER HARDWARE/SOFTWARE CATS will reside on our Data General mainframe computer.

The use of the mainframe will allow access to up-to-date commitment data by both plant and corporate Nuclear Division personnel.

The upgraded tracking system will significantly expand the types of data elements being tracked. Data elements include, but are not limited to: responsible department and individual; document information such as source of the commitment, related documents, and implementing/closure documents; due date and priority; RG&E and agency closure dates; status; agency; cause; plant systems/structures; keywords; related commitments; summary and detailed text of the commitment; and comments. Each commitment will also include an activities section which will allow for development of action plans where necessary. The activities section includes: activity number; department and individual; description of activity; target completion date and actual completion date; and activity status.

The software design includes menus to allow for various types of reports to be easily requested by Nuclear Division personnel. User Manuals will be developed to aid personnel in the use of the system. The Detailed Software Design for the CATS is currently under development.

ENCLOSURE 1 (Continued) PAGE, 3 OF 4 DATABASE Our established goal is to provide an integrated database of potentially safety significant issues which originate from various sources. At the time the system goes operational, the database wi'll, at a minimum, consist of those open commitments which originated in correspondence to or from the NRC. In our current plans, we expect to expand the database to include other commitments/action items from documents such as Corrective Action Reports, Identified Deficiency Reports, Nonconformance Reports, Management Action Items, other federal, state, and local regulatory agency correspondence, INPO Evaluations, and INPO generic industry correspondence (e.g., SOERs, SERs, etc.) The extent of the items to be addressed by CATS has not yet been finalized.

To allow for the building of a commitment database concurrent with the development of the mainframe software, a PC based tracking system was developed in the Nuclear Safety and Licensing Group as an interim measure until the mainframe system implementation. Reports generated from this interim system have the essential data elements and appearance that reports generated from the mainframe will have, with the exception that the activities section discussed in Section 1 above was excluded. Currently, the PC database includes commitments/action items which originated in correspondence to and from the NRC dated subsequent to January 1, 1990.

The database also includes a number of commitments which originated prior to 1990 yet remained open. We are conducting additional reviews of our current tracking systems to identify pre-1990 commitments which remain open. These reviews should assure that open NRC issues are identified and included in the database at the time the mainframe system becomes operational. It is our intent to retain closed commitments in the database to facilitate future historical research of issues. The database that exists on the PC will be incorporated into the mainframe computer system at the time of its implementation.

k ENCLOSURE 1 (Continued) PAGE 4 OF 4 3 ~ MANAGEMENT CONTROLS The Commitment and Action Tracking System will provide assurance to management that safety significant issues are being addressed. In addition to tracking the commitment/action items, the system will allow action plans with appropriate target completion dates to be established.

Periodic reports to management and line personnel showing issues overdue and coming due are planned. Administrative controls and implementing procedures are scheduled to be developed prior to full system implementation. These administrative controls will establish responsibilities for the maintenance and implementation of commitments.

Sufficient progress has been made on our development to allow us to start the distribution of the significant commitment reports from the interim PC system. At this time, these reports are being used to supplement information from other systems and provide a higher level of confidence that commitments are being met.

DESIGN BASIS DOCUMENTS As noted at the March 6, 1990 NRC Region I RG&E Management Meeting, the RG&E Configuration Management Level I Schedule shows a June 16, 1990 start date for the Design Basis Documents (DBDs) and a completion date of November 21, 1994. The Design Basis Documents (DBDs) currently being developed for use by Engineering and Ginna Station personnel will contain or reference the Design Basis and Licensing commitments applicable to the structures, systems and components contained within them. The DBDs will be controlled so that they will accurately reflect the up-to-date Design Basis and commitments. They will provide the required reference documents for Engineering and Ginna Station personnel to ensure that proposed modifications are properly reviewed and that the Design Basis and ongoing commitments are properly maintained at Ginna Station. This will reduce the probability of future occurrences such as the improperly positioned valve described in Section 7.1 of the inspection report. As previously noted in NRC correspondence and conversations, the DBD effort a recently initiated documentation program. It will be performed in a systematic fashion, with the most important systems and topics receiving higher priority.

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ENCLOSURE 2 PAGE 1 OF 1 VIOLATION 50-244/87-10-04 DEVELOPMENT AND IMPLEMENTATION OF AN EFFECTIVE SHELF-LIFE PROGRAM As identified in Detail 6.6 of NRC Inspection Report 50-22/90-09, the Procurement Engineering Group has been assigned the task of development/implementation of a comprehensive shelf-life program for items maintained in the Ginna Station Warehou'se. Development of the computer software which will be used to identify, track and control items with limited shelf-life was begun June 15, 1990. Based on the progress thus far, completion date for this phase is October 1, 1990.

Development of the implementing procedures for the shelf-life program was begun July 23, 1990, with an estimated completion date of October 1, 1990. The decision was made to develop the software first and the procedures would then be developed.

Based on the implementation dates identified above, the overall shelf-life program will be available for implementation by Procurement Engineering on October 1, 1990. At that. time, all procured items will start to be processed through the shelf-life program to assure that items with limited shelf-life are contained in the controlling program. Previously procured items will continue to be handled in accordance with our interim policy of "Last-In, First-Out" (LIFO).

The Procurement Engineering Group will also perform a review of previously procured items maintained in the warehouse. This program will be initiated after the in-storage preventive maintenance program is complete, and is scheduled to begin around November 1, 1990. We expect this phase of the program to take a minimum of one year, at which time we will discontinue the interim LIFO policy.

ENCLOSURE 3 PAGE 1 OF 1 UNRESOLVED ITEM 50-244/88-23-01 DEVELOPMENT AND IMPLEMENTATION OF A COMPREHENSIVE PREVENTATIVE MAINTENANCE PROGRAM As identified in Detail 6.7 of NRC Inspection Report 50-244/90-09, the Procurement Engineering Group has been assigned the task of development/implementation of a comprehensive preventive maintenance program for items maintained in the Ginna Station Warehouse.

Development of the computer software which will be used to identify, track and control items with preventive maintenance requirements was begun June 15, 1990 with a previously estimated completion date of September 1, 1990. However, the shelf-life program is being developed in parallel with the preventative maintenance program. Therefore, the estimated date for software completion is now October 1, 1990.

Development of the implementing procedures for the preventative maintenance program was begun July 23, 1990 with an estimated completion date of September 1, 1990. However, since development of the implementing procedures is dependent on completion of the software, identified above, the estimated completion date has changed to October 1, 1990. This represents a one month deviation from the estimated completion date of September 1, 1990 which was identified during the inspection.

Based on the implementation dates, identified above, the overall preventive maintenance program will be available for implementation by Procurement Engineering on October 1, 1990. At that time, all procured items will start to be processed through the preventative maintenance program to assure that items with preventative maintenance requirements are contained in the controlling program.

The Procurement Engineering Group will be performing a review of previously procured items maintained in the warehouse. This program will be initiated after implementation of the preventative maintenance program, and is scheduled to begin November 1, 1990.

This phase is estimated to have a completion time of approximately one year.