ML17264A832

Responds to 970124 RAI Re Revised Submittal of QA Program for Station Operation.Clarification of Change on Page 19, Provided

ML17264A832
Person / Time
Site:	Ginna
Issue date:	03/14/1997
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9703200079
Download: ML17264A832 (4)

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ACCESSION NBR 9703200079 DOC. DATE: 97/03/14 NOTARIZED: NO DOCKET ¹ FAC IL~50-244 Rob crt Emmet Ginna Nuc l ear P 1 anti Unit ii Roc h ester G 0@000 4O AUTH. NAME AUTHOR AFFILIATION MECREDYi R. 4. Rochester Gas ~~c Electric Corp.

REC IP. !'JAME RECIPIENT AFFILIATION VISSING> G. S.

SUBJECT:

Responds to 970124 RAI re revised submittal oW GA Program

%or Station Operation. Clarilication o+ change on page 19i C provided.

A DISTRIBUTION CODE: GOOCD COPIES RECEIVED: LTR ENCL SIZE:

TITLE: Gh Topical Reporti Changei Amendmenti or Correspondence (Docket/Utili T NOTES: Licens'e Exp date in accordance uiith 10CFR2i 2: 109(9/19/72). "05000244 E RECIPIENT CQP IES REC IP IENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL VISS INGi G.

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NRR/DISP/P IMB NRR NUDQCS-ABSTRACT OC/LFDCB RGNi FILE EXTERNAL: DMi3/QSS IHS NRC PDR D

E NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK/

ROOM OWFN SD-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL phd>

AND ROCHESTER GASANDELECRICCORPORATION ~ 89FASTAYENUE ROCHESTER N.Y 14649-KOI AREA CODE7165d6-2700 ROBERT C. MECREDY Vice President Nvdeor operations March 14, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555

Subject:

Reply to a Request For Additional Information Revised Submittal Of Quality Assurance Program R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Vissing:

This letter is in response to your Request For Additional Information, dated January 24, 1997. The NRC had determined the need for additional information regarding our Revised Submittal of Quality Assurance Program For Station Operation(QAPSO), dated December 13, 1996. Revision 22 of the QAPSO specifically listed Regulatory Guide 1.33, Rev. 2, Position 5a as a commitment.

Revision 23 of the QAPSO did not list Position 5a of the Regulatory Guide and this appeared to be a reduction in commitment.

The change on Page 19 of our submittal is not a reduction in commitment. However, the following explanation should have been included with the changes when submitted.

Regulatory Guide 1.33 This section was rewritten to clarify commitments to various standards and portions of standards. In particular, this section contained a conflict in which a standard was invoked and then taken exception to later.

The second sentence of the remarks in Rev. 22 states "Ginna Station conforms to Regulatory Positions 1, 3 and Sa in RG 1.33 Rev. 2..."

NOTE: Position Sa invokes Section 4.4 of ANSI N18.7 ANS 3.2-1976.

The last sentence of the remarks in Rev. 22 states "Requirements for the onsite review function meet the 9703200079 970314 PDR ADOCK'05000244 ,

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guidelines of ANSI/ANS 3.2-1988, section 4.3 in lieu of ANSI N18.7-1976 section 4.4..."

This conflict in commitment to ANSI N18.7/ANS 3.2-1976, section 4.4 was removed by rewriting this section. Ginna is, and has been, conforming to ANSI/ANS 3.2-1988, Section 4.3 for review activities of the on-site review committee (PORC), as approved by NRC correspondence of February 2,1995. This is consistent with the intent of Position 5a .

of RG 1.33,, Rev. 2. This is also consistent with Page 8 of our Rev. 22 submittal which states "The PORC. scope of review, organization, quorum, and records meet the requirements of ANSI/ANS 3.2-1988, Section 4.3."

Also, the use of ANSI/ANS 3.2-1988, section 4.3 in lieu of ANSI N18.7/ANS 3.2-1976, section 4.4 allows for the use of independent reviewers as described on Page 37 of our Rev. 22 submittal.

Therefore, the change in wording was intended to clarify the commitment and no reduction in commitment was intended or implemented.

Please note also, that there is a typo in our Rev. 23 submittal, in the last sentence of the remarks, in that we incorrectly referred to "ANSI N18.7-1988" which is actually "ANSI/ANS 3.2-1988". We will correct this error in our Rev. 24 submittal.

Very truly yours, Robert C. Mecre xc: U. S. Nuclear Regulatory Commission Mr. Guy S. Vissing (Mail Stop 14D11)

Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Rd.

King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector

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