ML17264A583
| ML17264A583 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/15/1996 |
| From: | Vissing G NRC (Affiliation Not Assigned) |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| IEB-96-001, IEB-96-1, TAC-M95001, NUDOCS 9608230165 | |
| Download: ML17264A583 (24) | |
Text
Dr. Robert C. Hecredy
~Vice President, Nucle~Operations Rochester Gas and Electric Corporation, 89 East Avenue Rochester, NY 14649 Augu 15, 1996
SUBJECT:
STATUS OF NRC REVIEW OF RESPONSES TO NRC BULLETIN 96-01, "CONTROL ROD INSERTION PROBLEMS" (TAC NO. H95001)
Dear Dr. Mecredy:
Thank you for your responses to NRC Bulletin 96-01, "Control Rod Insertion Problems,"
dated March 28,
- 1996, March 29, 1996, April 8,
- 1996, and Hay ll, 1996, for the R.
E. Ginna Nuclear Plant.
The NRC staff is currently evaluating the responses from all Westinghouse plants and is following the fuel testing and inspection activities being conducted by Westinghouse at selected plants.
We look forward to receiving the results of the inspection and testing activities at your site during the 1996 calendar year.
Should we identify any questions or concerns regarding either your planned inspection and testing activities or the results from these activities, we will contact you.
In addition, if over the next several
- months, you obtain information that was not specifically requested in the Bulletin but that may be of use to the NRC staff in assessing the operability of control rods, we would appreciate your sharing this information with us.
If you have any questions, please contact Margaret Chatterton at (301) 415-2889, Larry Kopp at (301) 415-2879, or Kris Thomas at (301) 415-1362.
Sincerely, Docket No. 50-244 cc:
See next page
/s/
Guy S. Vissing, Senior Project Manager Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation DISTRIBUTION:
CDocket:EU~e~
PUBLIC PDI-1 R/F S.
Varga J. Zwolinski J. Mitchell S. Little ACRS '.
Kopp G. Vissing L. Doerflein, RI K. Thomas OGC H. Chatterton
~~Col c DOCUMENT NAME:
G: iGINNAi9601.RSP To receive a copy of this document, indicate in the box:
"C" Copy without attachment enclosure "E" = Co with attachment enclosure "N" = No co OFFICE IIAME DATE LA:PDI-1 SLittle 08/16/96 E
PM:PDI 1
GVissing/rsl 08/
/96 D:PDI-1 JMitchell 08/
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9608230165 960815 PDR ADQCK 05000244 Q
" ffi cial Record Copy
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 15, 1966 Dr. Robert C. Hecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649
SUBJECT:
STATUS OF NRC REVIEW OF RESPONSES TO NRC BULLETIN 96-01, "CONTROL ROD INSERTION PROBLEHS" (TAC NO. H95001)
Dear Dr. Hecredy:
Thank you for your responses to NRC Bulletin 96-01, "Control Rod Insertion Problems,"
dated Harch 28, 1996,- Harch 29, 1996, April 8,
- 1996, and Hay ll, 1996, for the R.
E. Ginna Nuclear Plant.
The NRC staff is currently evaluating the responses from all Westinghouse plants and is following the fuel testing and inspection activities being conducted by Westinghouse at selected plants.
We look forward to receiving the results of the inspection and testing activities at your site during the 1996 calendar year.
Should we identify any questions or concerns regarding either your planned inspection and testing activities or the results from these activities, we will contact you.
In addition, if over the next several
- months, you obtain information that was not specifically requested in the Bulletin but that may be of use to the NRC staff in assessing the oper ability of control rods, we would appreciate your sharing this information with us.
If you have any questions, please contact Hargaret Chatterton at (301) 415-2889, Larry Kopp at (301) 415-2879, or Kris Thomas at (301) 415-1362.
Sincerely, Docket No. 50-244 cc:
See next page Guy
. Vissing, Sen or Project Hanager Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
J
Dr. Robert C. Hecredy R.E.
Ginna Nuclear Power Plant CC:
Peter D. Drysdale, Senior Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road
- Ontario, NY 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Hr.
F. William Valentino, President New York State
- Energy, Research, and Development Authority 2 Rockefeller Plaza
- Albany, NY 12223-1253 Charlie Donaldson, Esq.
Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Nicholas S.
Reynolds Winston
& Strawn 1400 L St.
N.W.
Washington, DC 20005-3502 Ms. Thelma Wideman
- Director, Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31
- Lyons, NY 14489 Hs.
Mary Louise Heisenzahl Administrator, Monroe County Office of Emergency Preparedness 111 West Fall Road, Room 11 Rochester, NY 14620
- . ~/Nfl Distribution Sheet Priority: Normal From: Elaine Walker Distri75.txt (gi/.~(rt Action Recipients:
NRR/DLPM/LPD1-1 G Vissing Copies:
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1 1
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NRC PDR NOAC QUEENER,DS NOAC POORE,W.
L ST LOBBYWARD internet: smittw@inel.gov INEEL Marshall Not Found Not Found Not Found Not Found Not Found Not Found Total Copies:
22 Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 003670528
Subject:
LER 1999-012, Opening, Control Room Ventilation System for Filter Placement Resulted Page 1
Distri75.txt in Plant Being Outside Design Basis Body:
PDR ADOCK05000244 S Docket: 05000244, Notes: License Exp date in accordance with 10CFR2,2.109(9/19/72).
Page 2
AHD A Subsidiary of RGS Energy Group, Inc.
ROCHESTER GAS ANO ELECTRIC CORpORATION
~ 89EASTAVENUE, ROCHESTER, NY. IrI6rI9C60I
~ 7I6 5d62700 wwwrge.corn RO8ERT C. MECREDY Vice President Nuclear Operations December 23, 1999 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy S. Vissing Project Directorate I Washington, D.C.
20555
Subject:
LER 1999-012, Opening Control Room Ventilation System for Filter Replacement Resulted in Plant Being Outside Design Basis R.ED Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Vissing:
The attached Licensee Event Report LER 1999-012 is submitted in accordance with 10 CFR 50.73, Licensee Event Report
- System, item (a)
(2),(ii) (B), which requires a report of, "Any event or condition that resulted in the nuclear power plant being... In a condition that was outside the design basis of the plant".
Very truly yours, Robert C. Mecr dy xc:
Mr. Guy S. Vissing (Mail Stop SC2)
Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale.Road King of Prussia, PA 19406 U.S.
NRC Ginna Senior Resident Inspector
NRL FORM 366 (6-)998)
US. NUCLEARREGULATORYCOMBIISSION LICENSEE EVENT REPORT (LER)
(See reverse for required number of digits/characters for each block)
APPROVED BY 081B iNO. 3150-0104 EXPIRES 06/30/200 Estimated burden per response to comply with this mandatory informat'en collection request: 50 hrs. Reported lessons learned are incorporated int the licensing process and fed back to industry. Forward comments regarding burden estimate to the Records Management Branch (TW F33), U.S.
Nudear Regulatory Commission, Washington, DC 205554001
~ and to th Papenvork Reduction Project (3150-0104), Office of Management a
Budget, Washington, Dc 20503, lfan information collection does not dispta a currently valid OMBcontrol number, the NRC may not conduct or sponsor and a person is not required to respond to, the information collection.
FACILITYNAME(1)
R. E. Ginna Nuclear Power Plant DOCKET NUMBER (2) 05000244 PAGE (3) 1 OF 7
TITLEIe)
Opening Control Room Ventilation System for Filter Replacemeht Resulted in Plant Being Outside Design Basis ri. /
EVENT DATE (5)
LER NUMBER (6)
REPO TDATE(7)
OTHER FACILITIESINVOLVED(8)
MONTH DAY YEAR SEQUENTIAL REVISION NUMBER NUMBER MONTH DAY YEAR FACILITYNAME DOCKET NUMBER 05000 24 1999 1999 012 00 12 23 1999 FACILITYNAME DOCKET NUMBER 05000 OPERATING MODE (9)
POWER LEVEL(10) 100 20.2201(b) 20.2203 a 1
20.2203(a)(2)(i) 20.2203(a)(2)(v) 20.2203 a 3
i 20.2203(a)(3)(ii) 50.73(a)(2)(i) 50.73 a 2
ii 50.73(a)(2)(iii) 50.73(a)(2)(viii) 50,73a 2 x 73.71 THIS REPORT IS SUBMITTEDPURSUANT TO THE REQUIREMENTS OF 10 CFR g: (Check one or more) (11) 20,2203 a 2
ii 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203 a 4
50.36(c)(1) 50.36(c)(2) 50.73 a 2
iv 50.73(a)(2)(v) 50.73(a)(2)(vii)
OTHER Specify in Abstract belov or in NRC Foun 366A John T. St. Martin - Technical Assistant LICENSEE CONTACT FOR THIS LER 12 TELEPHONE NUMBERIinokide Ares Code)
(716) 771-3641 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE To EPIX CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO EPIX SUPPLEMENTAL REPORT EXPECTED (14)
YES (Ifyes, complete EXPECTED SUBMISSION DATE).
NO EXPECTED SUBMISSION DATE (15)
MONTH DAY YEAR ABSTRACT (Umitto 1400 spaces, i.e.. approximately 15 single-spaced typewritten lines) (16)
On November 24, 1999, the plant was in Mode 1 at approximately 100% steady state reactor power.
As part ofthe Work Control System process, Work Order ¹9902102 was reviewed by the Shift Supervisor prior to authorizing the start ofthe work. This work order consisted ofinspecting and replacing, as necessary, the Control Room HVACair filters. In order to inspect these filters, small access covers in the side ofthe HVACunit have to be removed.
During this pre-job review on November 24, it was discovered that performing this work would cause a breach in the integrity ofthe Control Room HVAC system ductwork. The Shift Supervisor denied permission to perform the work on the basis that removing the filterbank access covers would be equivalent to opening the Control Room HVACsystem envelope.
At various times in the past such a breach was permitted to occur when this work was performed. This breach could have allowed in-leakage in excess ofthe assumed leak rate listed in the Ginna Station Updated Final Safety Analysis Report. It was concluded that the system may have been outside the design basis at those times in the past, and that it had not been recognized that the plant was outside its design basis during those times.
The cause ofthe occasional breaches in the integrity ofthe Control Room HVACsystem ductwork was inadequate procedural guidance for conformance with requirements ofTechnical Specifications.
Corrective action to prevent recurrence is outlined in Section V.B.
NRC FORM 366 (6-I998)
NRC FORM 366A (6-1998)
U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITYNAME(1)
R. E. Glnna Nuclear Power Plant DOCKET (2)
NUMBER(2) 05000244 LER NUMBER (6)
SEQUENTIAL REVISION NUMBER NUMBER 1999
012
00 PAGE (3) 2 OF 7
TEXT (Ifmore spaceis required, use additional copies ofNRC Form 366A) (17)
I. PRE-EVENT PLANTCONDITIONS:
The Control Room HVACunit supplies conditioned air to the Control Room during normal and accident conditions. The Control Room HVACunit is designed to isolate and recirculate the air upon receiving a isolation signal indicating the presence ofradioactivity or toxic gas. Preventive Maintenance Work Order ¹9902102 addresses periodic HVACfilterinspections.
One ofthe filterunits listed in the work order (WO) for inspection is the Control Room HVACunit.
As part ofthe Work Control System process, work orders are reviewed on-shift prior to the start ofwork.
During the midnight shift on November 24, 1999, the plant was in Mode 1 at approximately 100% steady state reactor power. WO ¹9902102 was reviewed by the ShiA Supervisor.
This work order consisted of finspecting and replacing, as necessary, the Control Room HVACair filters, and was scheduled to be worked on the day shift on November 24. In order to inspect these filters, small access covers in the side ofthe HVACunit have to be removed.
II.
DESCRIPTION OF EVENT:
A.
DATES ANDAPPROXIMATETIMES OF MAJOR OCCURRENCES:
The Control Room HVACair filters have been inspected and/or replaced numerous times. A review ofdocumented previous occurrences is listed in Section II.B. below. (Prior to 1995, changing the filters was not specifically documented in the Work Control System.)
October 1995 through August 1999: Event dates for the past four years.
November 24, 1999, 0900 EST: Discovery date and time.
B.
EVENT:
On November 24, 1999, the plant was in Mode 1 at approximately 100% steady state reactor power. During the midnight shiA, WO ¹99021g2 was reviewed by the Shift Supervisor.
The Shift Supervisor denied permission to perform t$e work on the basis that removing the filterbank access covers would be equivalent to opening the Control Room HVACsystem envelope.
NRC FORM 366A (6.1998)
NRC FORM 366A (6-1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION U.S. NUCLEAR REGULATORYCOMMISSION FACILITYNAME(1 )
R. E. Ginna Nuclear Power Plant DOCKET (2)
NUMBER(2) 05000 LER NUMBER (6)
SEQUENTIAL REVISION NUMBER NUMBER 1999
012
00 PAGE (3) 3 OF 7
TEXT(ifmore speceis required, use edditionel copies ofNRC Form 366A) (17)
The Ginna Station Technical Specifications (TS) LimitingCondition for Operation (LCO) 3.7.9 requires that the Control Room HVACunit be operable during all plant modes.
In accordance with the basis for TS LCO 3.7.9, the Control Room boundary must be maintained, including the integrity ofthe walls, floors, ceilings, ductwork, and access doors. Removing the filterbank access covers would create an opening in the boundary ofthe ductwork.
Thus, on November 24, 1999, it was discovered that performing this work would cause a breach in the integrity ofthe Control Room HVACsystem ductwork, which may have placed the plant outside its design basis at various times in the past. The event occurred when the Shift Superviso identified that inspection ofthe filters required removal offilterbank access covers on Control Room HVACsystem, which would no longer maintain the integrity ofthe ductwork.
Removal ofthe filterbank access covers could allow outside air flowinto the Control Room HVACsystem in the post accident recirculation mode., Evaluations had been previously completed (on August 23, 1999) to determine maximum allowable duct opening when a flexible expansion joint was found ripped, as reported in LER 1999-011.
(Refer to Ginna Docket No. 50-244, LER 1999-011.) This evaluation showed that the opening could have allowed in-leakage in excess ofthe assumed leak rate listed in the Ginna Station Updated Final Safety Analysis Report (UFSAR) Section 6.4, Table 6.4-1. With this information it was concluded that the system may have been outside the design basis at the followingtimes in the past (the plant was in Mode 1 at each ofthese times):
Event Date Work Order Work Performed October 5, 1995 September 16, 1996 December,6, 1996 April29, 1997 June 23, 1997 October 13, 1997 December 17, 1997 February 2, 1998 May 27, 199S August 3, 1998 September 30, 1998 December 22, 1998 June 7, 1999 August 30, 1999 19504302 19602760 19604974 19700551 19700889 19701444 19702780 19703520 19801385 19802067 19)03198 19803199 19804)59 19900993 Visual inspection-Visual inspection Visual inspection Filters replaced Visual inspection Visual inspection Filters replaced Visual inspection Visual inspection Visual inspection Filters replaced Visual inspection Filters replaced Visual inspection covers removed NRC FORM 366A (6-1998)
f
NRC FORM 366A (6-1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION U.S. NUCLEAR REGULATORYCOMMISSION FACILITYNAME (1)
R. E. Ginna Nuclear Power Plant DOCKET (2)
NUMBER (2) 05000 LER NUMBER (6)
SEQUENTIAL REVISION NUMBER NUMBER 1999
012
00 PAGE (3) 4 OF 7
TEXT (Ifmore space is required, use edditionel copies ofNRC Form 366A) (17)
Prior to 1995, changing the filters was not specifically documented using the work control system.
C.
INOPERABLE STRUCTURES, COMPONENTS, OR SYSTEMS THATCONTRIBUTEDTO THE EVENT:
None D.
OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED:
None E.
METHOD OF DISCOVERY:
During a pre-job review ofthe WO for inspection and replacement ofControl Room HVAC filters, this event was discovered when the Shift Supervisor identified that an opening would be created in the Control Room HVACsystem ductwork when this inspection is performed.
F.
OPERATOR ACTION:
The Control Room HVACsystem was operable at the time ofdiscovery. The Shift Supervisor denied permission to perform Work Order ¹9902102 on the Control Room HVACunit filter bank, and no further actions were required. ACTIONReport ¹99-1541 was initiated to review th event.
G.
SAFETY SYSTEM RESPONSES:
None NRC FORM 366A (6-1998)
NRC FORM 366A (6-1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION U.S. NUCLEAR REGULATORY COMMISSION FACILITYNAME(1)
R. E. Ginna Nuclear Power Plant DOCKET (2)
NUMBER (2) 05000 LER NUMBER (6)
SEQUENTIAL REVISION NUMBER NUMBER 1999
012
00 PAGE (3) 5 OF 7
TEXT (Ifmore space is required, use additional copies ofNRC Form 366A) (17)
III.
CAUSE OF EVENT:
A.
IMMEDIATECAUSE:
The immediate cause ofthe plant being in a condition that was outside its design basis at various times in the past was there would have been a breach in the supply air handling ductwork when the Control Room filterbank access covers were opened, and the calculated in-leakage would have been in excess ofthe assumed leak rate listed in UFSAR Table 6.4-1.
B.
INTERMEDIATECAUSE:
The intermediate cause ofthe occasional breaches in the Control Room HVACductwork was the practice that allowed performance ofthe WO without maintaining the integrity ofthe ductwork.
C.
ROOT CAUSE:
The underlying cause for allowing this practice is the use ofa plant administrative procedure for controlling work on a subcomponent ofsafety-related equipment and inadequate procedural guidance in the administrative procedure to ensure compliance with Technical Specification (TS) requirements.
Administrative Procedure A-1040 (Filter Inspection and Testing Program) lists filters that are subject to TS and those that are not subject to TS, and describes the activities necessary to inspect and/or replace these filters. The subject filters, in terms oftheir function, are low efficiency filter and not designed for safeguarding Control Room habitability. Their function is to maintain the cleanliness ofthe heating and cooling coils and fans. A-1040 lists the subject filters as non-Tech.
Spec. related, when they are, in fact, a subcomponent ofsafety-related equipment.
IV.
ANALYSISOF EVENT:
This event is reportable in accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2)
(ii)(B), which requires a report of, "Any event or condition... that resulted in the nuclear power plant being... In a condition that was outside the design basis ofthe plant". The calculated in-leakage due to an opening that could have been created is greater than the assumed leak rate listed in the UFSAR.
NRC FORM 366A (6.1998)
NRC FORM 366A (6-1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION U.S. NUCLEAR REGULATORY COMMISSION FACILITYNAME (1)
R. E. Ginna Nuclear Power Plant DOCKET (2)
NUMBER(2) 05000 LER NUMBER(6)
SEQUENTIAL REVISION NUMBER NUMBER'999
012
00 PAGE (3) 6 OF 7
TEXT(ifmore space is required, use additional copies ofNRC Form 366A) (1 7)
An assessment was performed considering both the safety consequences and implications ofthis event with the followingresults and conclusions:
There were no actual operational or safety consequences and implications attributed to the occasional breaches in the Control Room HVACductwork because:
While it is presumed that the plant was outside its design basis on the dates listed in Section II.B. above, Operations would be notified ofthe filterchange activity and would be aware ofthe need to reinstall the filterbank access covers upon receipt ofa radiation signal. Therefore, Operations could have directed reinstallation ofthe filtercovers, and a maintenance person could have reinstalled the covers in a short amount oftime.
Any event that results in a significant release would require entry into the Nuclear Emergency Response Plan, resulting in continuous Radiation Protection (RP) shift technician coverage in the Control Room. In this situation the Control Room area radiation and airborne activity are continuously monitored.
Should the activity concentration reach unacceptable levels, the RP shift technician would implement appropriate protective actions.
Some ofthe contingencies available are respirators and potassium iodide tablets to limitthe uptake ofradioactive iodine.
The on-site chemicals which could result in a toxic gas situation (chlorine, ammonia, hydrazine, sulfuric acid, and sodium hydroxide) are in a liquid state.
Therefore, due to the slower evaporation rate, the Control Room atmosphere is less likelyto reach hazardous airborne concentrations during a spill. In addition, the sulfuric acid and sodium hydroxide tanks in the primary demineralizer room have been emptied and are no longer in use.
Similar tanks in the Condensate Demineralizer building are located in separate pits which prevents inadvertent mixing ofthese chemicals.
The most likely off-site toxic gas release source is gaseous chlorine located at the Ontario water plant, approximately one mile to the east ofthe plant. The distance involved would allow significant dilution ofthe gas in the atmosphere.
Also, the water plant is in a location where the prevailing winds in the area tend to blow the gas away from the plant.
Finally, the presence ofthese gasses in the Control Room atmosphere would be readily apparent to the Operators due to the noxious nature ofthe fumes. There are two Self-Contained Breathing Apparatus (SCBA) units located in the Control Room with additional units located in other areas adjacent to the Control Room.
NRC FORM 366A (6-1998)
4
NRC FORM 366A (6-1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION h
U.S. NUCLEAR REGULATORY COMMISSION FACILITYNAME (1)
R. E. Ginna Nuclear Power Plant DOCKET (2)
NUMBER (2) 05000244 LER NUMBER (6)
YEAR SEQUENTIAL REVISION NUMBER NUMBER 1999
012
00 PAGE (3) 7 OF 7
TEXT (Ifmore space is required, use additional copies ofNRC Form 366A) (17)
Based on the above, it can be concluded that there were no unreviewed safety questions, and that the public's health and safety was assured at all times.
II V.
CORRECTIVE ACTION:
A.
ACTIONTAKENTO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:
None required.
B.
ACTIONTAKENOR PLANNEDTO PREVENT RECURRENCE:
Performance ofany WO for inspection ofthe Control Room HVACfilters has been administratively preverited, and willnot be resumed until additional corrective actions are taken, as listed below.
Procedure A-1040 willbe changed to prevent the removal ofthe filterbank access covers without proper isolation or closure capability.
Modification PCR 96-125 willbe performed to provide suitable boundary isolation to prevent breaching the integrity ofthe Control Room ductwork when opening the filter bank access covers.
VI.
ADDITIONALINFORMATION:
A.
FAILEDCOMPONENTS:
None B.
PREVIOUS LERs ON SIMILAREVENTS:
A similar LER event historical search was conducted with the followingresults: LER 1999-011, ripped ductwork flex-joint, was a similar event with a different root cause.
C.
SPECIAL COMMENTS:
None NRC FORM 366A (6-1998)
0
AND A Subsicfiory oI RGS Energy Group, Inc.
ROCHESTER GAS ANDELECTRIC CORPORATION
~ 89 EASTAVENUE, ROCHESTER, N.Y. 14649CXQI
~ 716 546 2700 ROBERT C. MECREDY www.rge.corn Vice President hfvcleor Operotions December 22,1999 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy Vissing Project Directorate I
Washington, D. C. 20555
Subject:
Clarification of work performed for Rochester Gas 5. Electric vendors.
R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Vissing:
Rochester Gas 5 Electric (RG&E) was the subject of an inspection (96-201) in 1996 which reviewed monitoring of vendor quality control.
In the Nuclear Regulatory Commission (NRC) Inspection Report, dated March 1, 1996 statements were made regarding future avoidance of the perception of conflict of interest.
The report included the following text:
"It is our understanding that, in the future, current management will avoid any perception of a conflict of interest with a vendor, will not suggest to their engineers to perform such an audit, and have instructed QA engineers not to perform work for a company that QA was responsible to assess, either as independent consultants or as RG&E employees."
The above content was in response to a situation wherein an auditor had served as an independent (from RG5E) contractor to a vendor and then assessed that vendor's performance for RGSE.
That situation did not result in any actual deficiency, but created a perception as a result of an individual who exercised poor judgement.
We would like to clarify our intentions in this area so as to assure that future erroneous perceptions are avoided, without imposing unnecessary constraints.
Our intentions are that RGRE will not provide any services to a vendor and then have the vendor evaluated by the same person who performed the services.
This addresses the original concern which the NRC
identified in 1996, while not constraining other personnel from assisting vendors in improving the quality of their programs.
The application of this approach is similar to other activities within the plant where Independent Verification is performed by personnel other than the one who performed the original action.
It is in RG5E's best interest to assure that a conflict of interest does not, either in appearance or in fact, exist.
It is also desirable to both RGS.E and the industry, that we assist vendors in resolving deficiencies and strengthening their quality program.
We will continue to assure the quality of assessments is not compromised and hope that this clarification helps to alleviate any potential concerns which could arise.
Very truly yours, Robert C. Mecr dy Xc:
Mr. Guy S. Vissing (Mail Stop 8C2)
Project Directorate I
Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Regional Administrator, Region I
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector
I