ML17262A251

Provides Response to NRC 901026 Transmittal of SALP Board Comments & Results of Discussions During 901120 Meeting

ML17262A251
Person / Time
Site:	Ginna
Issue date:	11/27/1990
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9012040061
Download: ML17262A251 (10)

Text

ACCELERATED DIStaRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9012040061 DOC.DATE: 90/11/27 NOTARIZED:

NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1,.Rochester G

AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.

Rochester Gas

& Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION MARTIN,T.T.

Region 1 (Post 820201)

SUBJECT:

Provides response to NRC 901026 transmittal of SALP board comments

& results of discussions during 901120 meeting.

DISTRIBUTION CODE:

IE40D COPIES RECEIVED:LTR I'ENCL J SIZE:

7 TITLE: Systematic Assessment of Licensee Performance (SALP) Report NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).

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05000244 05000244 RECIPIENT ID CODE/NAME PD1-3 LA JOHNSON,A INTERNAL: AEOD/DOA COMMISSION NRR SHANKMAN,S NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DRIS/RSGB9D NRR/PMAS/ILRB12 O

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1 NOTE TO ALL"RIDS" RECIPIENTS:

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

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c ROCHESTER GAS AND ELECTRIC CORPORATION 0

89 EAST AVENUE, ROCHESTER N. K 14649-0001 ROBERT C. MECREDY Vice President Cinna Nucieat PcoducBon November 27, 1990 TELEPHCNE AREA CODE 7>6 546 2700 Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

Subject:

Systematic Evaluation of Licensee Performance (SALP)

R.E.

Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Martin:

This document provides our response to the NRC's October 26, 1990 transmittal of SALP Board

comments, and includes the results of discussions held during our November 20, 1990 meeting on this subject.

RG&E has dedicated significant personnel and capital resources to attaining our goal of improving our operation-and striving for excellence, operating a safe and economic nuclear unit throughout its present operating license period and beyond.

We are pleased that the NRC has recognized the many strides we have made toward.

this

end, as reflected in the "improving" trends in Maintenance/Surveillance and Security.

The SALP Board.

comments further suggest that major improvements have been made in several other categories, particularly Operations.

RG&E further recognizes that aggressive maintenance of high performance in our areas of strength, as well as improvements in all areas, must occur in order for us to realize our goal.

Many program

areas, such as Configuration Management and Procedural

Upgrades, have been initiated. but must be maintained at a high level of effort in order to demonstrate their effectiveness.

Specific comments relative to the individual SALP categories are provided in the attached report.

We look forward to working with the NRC in the future to ensure that our mutual goals of maintaining a consistently high safety level in all areas at Ginna Station are attained.

90l,2A40061 90li.27 PDF; ADOCK O"-OOO2nn 9

PDC Very truly yours, Robert C. Mecred GJWN127 Attachment

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

Document Control Desk Washington, D.C.

20555 Allen R. Johnson (Mail Stop 14D1)

Project Directorate I-3 Washington, D.C.

20555 Ginna Senior Resident Inspector

Attachment RG&E comments relative to individual 10/26/90 SALP Categories A.

Plant 0 erations:

We would like to acknowledge your assessment of our performance in plant operations.

The identified strengths and opportunities for improvement parallel our self-assessment.

You have recognized our operators knowledge, competence, and professionalism in the operation of our facility.

Although we will continue to pursue excellence in the stated strengths, detailed plans for improvements have already been instituted to address independent verification, procedure adherence, and housekeeping.

As correctly stated in your

report, a

task force was established to address independent verification and procedure adherence.

This task force, comprised of the plant manager and a large cross-section of staff personnel, has been meeting regularly since March 1990.

Final approved procedure changes and Phase 1 of our Training Program have been completed.

While developing our longer term improvement program, it should be noted that immediate corrective actions involving interim procedure 'hanges were implemented.

Procedure A-1408, "independent Verification" was revised and.

made effective in May 1990.

Procedure A-503 "Procedure Adherence" has also been revised and implemented.'he improvements as noted. in your report resulted from these interim corrective actions.

Our shop area housekeeping is being

improved, striking a

balance between the need for tool storage and controlled work spaces.

We will continue to utilize our knowledgeable, competent and professional operating staff to meet the challenge of the future.

We believe that we demonstrated substantial improvement during this SALP period, that we are on the threshold of being a

superior performer, and will not be satisfied until this performance is fully realized.

B.

Radiolo ical Controls:

RG&E is pleased

that, for the most part, we were able to maintain adequate staffing of the radiological controls program, provide adequate training programs, and provide a good program for monitoring and minimizing internal and external exposures.

We do take pride in the success of our efforts to reduce cumulative annual personnel exposures, particularly through the effective use of mock-ups, and our successful corrective action to decrease the number of personnel contamination events.

We also recognize the need for further self-improvement and have instituted plans to achieve this.

Our staffing has been augmented with eight additional technicians.

The selection process for two'of the three Health Physicists has been completed with offers pending.

Our training program has been expanded to offer individual radiation monitoring to selected personnel.

Monitoring requirements for steam generator entries have been reevaluated to conservatively assess accumulated dose.

Tracking of internal exposures has been changed to reflect implementation of new methodology to conservatively assess Maximum Permissible Concentration (MPC) hours.

We had previously taken the initiative to develop and, formalize a

quality control position 'or our

primary, secondary, environmental chemistry and countroom activities. It should be noted that QC procedures were in effect in the Radiochemistry Laboratory throughout the SALP

period, contrary to the statement in the report.

In addition, as noted in NRC Inspection Report 90-16, we have in place many of the elements of an overall laboratory QA/QC program.

We acknowledge that implementation of these procedures in the Environmental Lab is still in need of improvement.

We acknowledge that a violation resulted due to non-compliance of a radwaste shipment, and we have enhanced our radwaste resin shipment program to include procedure changes and equipment upgrades.

We believe we have made strides, particularly toward the end of the SALP period, to improve our overall controls of the Radiological Protection

program, and anticipate both qualitative and quantitative benefits to result.

C.

Maintenance/Surveillance RG&E concurs with the NRC Assessment of the Maintenance/

Surveillance functional area.

RG&E appreciates NRC recognition of our strengths and improving trend.

Our improved Maintenance/Surveillance Effectiveness has been achieved through knowledgeable, conscientious individuals who strive for excellence in their overall performance.

This improved level of performance has been achieved by applying knowledge, skill and initiative toward accomplishing performance and organizational objectives.

Our proactive efforts to perform self assessments and upgrade our work control

system, procedures, and optimize our Preventive Maintenance Program via the Reliability Centered Maintenance Project are achieving their expected results.

A 2

h

Your insight is valuable in our assessment and oversight for continuous improvement.

Comprehensive actions are being planned or have already been implemented to address weaknesses addressed, by this SALP Report.

Our corrective actions for identified weaknesses in the Sling Inspection

Program, Training, Records Retrievability, Surveillance, and Procedure Adherence areas will address the root cause of the problem(s) and prevent recurrence.

Management attention and involvement will continue to be

~

readily evident and willcontinue to place emphasis on superior performance of Maintenance/Surveillance activities.

In the next period, we willmaintain our aggressive posture and commitment to maintain the highest, standards and achieve the highest category rating.

D.

Emer enc Pre aredness:

RG&E concurs with the Emergency Preparedness strengths identified in the SALP Report, and attributes these strengths to our continued emphasis on management support and involvement in maintaining program effectiveness.

We also believe our performance reflects widespread cooperation being fostered among participating RG&E departments, and among external supporting agencies at the local, state, and federal level.

We are striving to improve the Emergency Preparedness program wherever possible through continuous upgrades, when considered necessary, in our equipment, procedures, and training as well as through the exchange of ideas with our industry

'ounterparts.

In the next SALP review

period, we are challenging ourselves to improve our overall emergency readiness by bettering the effectiveness of our training and drills.

RG&E's management is committed to maintaining superior performance in this area, and will ensure that we maintain the excellent working relationships necessary to achieve that performance.

E.

~Eecurit While the SALP Report concluded that our security program is "Improving", it did identify certain limited weaknesses which we address here. It was pointed out that there has been a slow response to the correction of a few hardware problems, and it must be explained that stringent engineering analysis has been required to ensure that the ongoing systems upgrade project is not adversely impacted.

Compensatory measures are implemented as required.

A method for documenting changes in training for Crucial Tasks is being developed to address the Board's concern relative'o the introduction of lessons learned into the Training and Qualification Plan.

Finally, the Quality Assurance group has also recognized the need for performance A 3

based assessment and has utilized a consultant specialist to assist addressing this concern in the most recent security audit. It is anticipated that management's ongoing commitment to the security systems upgrade project and their support of security force development will be reflected in continued improvement and a return to superior performance.

F.

En ineerin Technical Su ort RG&E agrees with the many examples cited of strong technical support for Ginna Station, and is pleased that the NRC has recognized the high level of engineering and licensing expertise of RG&E personnel.

RG&E also acknowledges improvements that are needed in engineering assurance to achieve high standards which we set for ourselves and are expected in the nuclear industry.

Assessments conducted by both internal and external groups are being used to recommend improvements in our engineering processes and procedures which will address shortcomings identified, during the SALP period,.

Communications between our offsite engineering department and the onsite technical support group have been formalized to assure that potential safety issues are documented and.

evaluated through the used of procedure QE-1603, "Documenting and Reporting Potential Conditions Adverse to Quality".

We also expect to make other significant improvements in our processes during the current SALP period to better control, closeout and track design changes for the station.

It should be noted

that, although RG&E is planning, to participate in the Westinghouse two-loop Design Basis Documentation (DBD) coordinated effort, present plans do not include the completion of an RHR System DBD in 1990.

Our Design Basis efforts will, however, be increased in conformance with our integrated Configuration Management Program.

As acknowledged by the SALP Board, RG&E has initiated several significant program upgrades, and we are anxious to demonstrate their effectiveness in our future design efforts.

G.

Safet Assessment/ ualit Verification We agree with the NRC's assessment that improved performance occurred in this

area, as indicated by the high quality submittals to the

NRC, safety-conscious responses to NRC generic

issues, and rapid and comprehensive evaluations of potential safety issues.

We further concur with your comments that self-assessment concerns identified by Quality Performance need to be tracked to completion.

We acknowledge the length of time required to complete the license amendment cycle for the Auxiliary Feedwater

System, but must point out that administrative controls were in place to ensure conservative operability of the system in this time period.

We have also A-4

implemented comprehensive changes in our procedure adherence and. independent verification requirement.

The procedures have been upgraded and

approved, and training of appropriate personnel in these areas has been conducted.

A complete review and enhancement is still going on to update all plant procedures to the new independent verification requirements.

A-5