ML17263A489
| ML17263A489 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/06/1993 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9312150256 | |
| Download: ML17263A489 (4) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9312150256 DOC.DATE: 93/12/06 NOTARIZED:
NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION MARTIN,T.T.
Region 1 (Post 820201)
SUBJECT:
Provides documentation of info exchanged between util
& NRC during 931115 SALP mgt meeting on SALP Rept 50-244/92-99,w/
respect to operations
& plant support.
DISTRIBUTION CODE:
IE40D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: Systematic Assessment of Licensee Performance (SALP) Report NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
D 05000244 /
RECIPIENT ID CODE/NAME PD1-3 LA JOHNSON,A INTERNAL: AEOD/DOA COMMISSION NRR/DORS/OEAB NRR/DRCH/HOLB NRR/DRIL/RSIB NRR/DRSS/PRPB NRR/PMAS/ILRB QE+gR REG FILE 02 EXTERNAL: EG&G/BRYCE,J. H.
NRC PDR COPIES LTTR ENCL RHCIPIENT ID CODE/NAME PD1-3 PD AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFBPT NRR/DRIL/RPEB NRR/DRSS/PEPB NRR/DRSS/RSGB NUDOCS-ABSTRACT OGC/HDS 1 RGN1 FILE 01 L ST LOBBY WARD NSIC COPIES LTTR ENCL D
D D
NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOiiI P l-37 (EXT. 20079) TO ELliv!INATE YOUR NA!v!EFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 29 ENCL ~9g A
D D
An e t
, ~ i.,'.n,
'OCHESTER GAS AND ELECTRIC CORPORATION 7
enemy
$1@M
~
89 EAST AVENUE, ROCHESTER N.K 14649.0001 ROBERT C. MECREDY Vice Pie>ideni Cinne Nuclear P(odueiion December 6,
1993 TELEPtiONE AREACODE 716 546 2700 U.S. Nuclear Regulatory Commission Region I Attn:
Mr. Thomas T. Martin Regional Administrator 475 Allendale Road King of Prussia, PA 19406
Subject:
SALP Report 50-244/92-99 R.E.
Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Martin:
The purpose of this letter is to provide the documentation of informa-tion exchanged between RGGE and the NRC during our SALP management meeting of November 15, 1993.
In general, we found the NRC SALP Report 50-244/92-99 to be a represen-tative summary of Ginna Station personnel and equipment performance during the period of January 19, 1992 to September 11, 1993.
We were particularly pleased that our Maintenance and Engineering/Technical Support areas were cited Superior.
We did find, however, that the brevity of the new SALP report format did not provide the same broad NRC perspective of our performance.
As noted in our November 15 discussions, we believe some RG&E comments are warranted in order to represent our efforts in Operations and Plant Support.
Operations:
The many strengths of the Operations personnel were accurately described in the SALP report, including excellent response to plant challenges to avert reactor trips, expeditious completion of root-cause analyses and corrective actions, and performance of several complex and infrequent evolutions.
Weaknesses
- noted, such as the mispositioning of several valves, have been the subject of strong and comprehensive action programs to ameliorate the situation.
Regarding falsification of log records, plant management did take steps as soon as industry information became available.
A sample of pre-industry-notification log records were reviewed with no instances of falsification identified. It is acknowledged that, following discus-sions with the
- NRC, more indepth reviews were deemed appropriate.
Additional clarification of management expectations were also issued, where necessary.
Our initial conclusions were substantiated in that there were no instances of falsification identified.
9312i50256 93i206 P
PDR ADOCK 05000244 8
~upgo
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Plant Support:
We acknowledge that two previous components of this new SALP area, Security and Emergency Preparedness, were previously rated
- Superior, and that the strengths exhibited in these areas continued throughout this SALP period.
Also, c'oncerns noted in the previous SALP regarding additional training to control room operators and implementa-tion of the emergency plan were effectively addressed during this SALP period.-
In the area of Radiological Controls, it was noted that implementation of the new requirements of 10CFR Part 20 was a weakness.
Inasmuch as the implementation date for the revised 10CFR Part 20 is January 1,
1994 and we are on schedule for meeting that requirement, we believe your characterization is inappropriate.
We have. been and are committed to full implementation of 10CFR Part'0.
Members of our staff have been directly involved in the NUMARC working committee which worked with the NRC to review draft regulatory guides and to clarify industry implementation requirements.
We have completed our Part 20 training, including revisions to General Employee Training.
We are using a
carefully structured approach to best integrate our training, proce-
- dures, and work methods to ensure full implementation by Jan.
1, 1994.
Our ALARA program has resulted in substantial reduction in personnel exposure over the past two years, decreasing our exposure from 320 person-rem in 1991 to approximately 190 in 1993, even with the same level of.,challenge to our radiation control personnel (extensive SG repair and testing, contaminated material reduction).
Our cobolt reduction program has also already been initiated, and is expected to yield 'excellent results in terms of dose rate reduction.
Source term reduction efforts have been pursued.
The ALARA program for our 1996 steam generator replacement is in progress.
It was initiated at an early phase in the project to allow the maximum planning time to reduce exposures.
An experienced RG&E Health Physicist is directly involved in replacement planning on a full time basis.
We have retained a
radiation protection contractor organization to provide support to us in planning and management of the replacement.
Both this radiation protection contractor and our replacement contractor have been responsible for highly successful steam generator replacements in the past.
In addition, both contractors have contract incentive provisions which are dependent on achieving high levels of ALARA performance in the replacement.
- Thus, the radiation protection aspects of the replacement project have already and will continue to receive signifi-cant management attention.
As in the past, we are committed to continually find ways to improve, with a strong focus on personnel and public safety.
We will continue to develop, document and communicate our expectations as management.
We will pursue higher levels of formality. in our operations.
We will continue to align our organization and its structure to our mission of safe, reliable, and economic operation.
We will make use of our highly skilled and experienced personnel to continue to make progress in our
Page 3
'I areas of strength, as well as in those areas where we see opportunities for improvement.
Very truly yours, Azg Robert C. Mecredy GJW4314 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 NRC Senior Resident Inspector