Text

LER 98-004-00:on 971030,determined That Improperly Performed Surveillance Resulted in Condition Prohibited by Ts.Caused by Procedure non-adherence.Appropriate Calibr Procedures Were Properly Performed with 24 H of Condition Discovery
	ML17265A493
Person / Time
Site:	Ginna
Issue date:	12/17/1998
From:	St Martin J; ROCHESTER GAS & ELECTRIC CORP.
To:	;
Shared Package
ML17265A491	List: ML17265A490; ML17265A493;
References
	LER-98-004, LER-98-4, NUDOCS 9812240093
	Download: ML17265A493 (13)
	v • d • e

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3160-010$ XPIRES 06/30/2001 (6-1 99 BI Estimated burden per response to comply with this mandato informalion collection request: 50 hrs. Reporled lessons learned ar Incorporated Into the licensing process and fed back to industry LICENSEE EVENT REPORT (LER) Forward comments regarding burden estimate lo Ihe Record Management Branch lTW F33), U.S. Nuclear Regulatory Commission W ton. DC 20555400(, and to the Paperwork Reduction projec (See reverse for required number of 315 104) Office of Management and Budget, Washington,

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digits/characters for each block) 0503. If an information collection does not display a currently vali OMB ccmtrol number, the NRC may not conduct or sponsor, and person is not required to respond lo, the Information collection.

FACILITY NAME (11 DOCKET NUMBER (21 PAGE (3)

R. E. Ginna Power Plant 05000244 1 OF 6 TITLE(4)

Improperly Performed Surveillance, Due to Procedure Non-Adherence, Resulted in Condition Prohibited by Technical Specifications I.FR Uh BF F PORT A OTHF.R FAC I ITIFS INVO D II FACILITYNAME DOCKEI'NUMBER SEQUEÃIIAL REVISION MONIN DAY YEAR MONIH DAY YEAR NUMBER NUMBER 05000 FACILITYNAME 10 30 1997 1998 004 " 00 12 17 '998 DOCKET NUMBER 05000 OPERATING S,U n U. I OTIF, F UI F F SO 0 Chec one or ore 1 MODE (9) 20.2201(b) 20.2203(aX2Xv) 50.73(aX2Xi) 50.73(aX2Xviii)

POWER 20.2203 a I 20.2203 a . i 50.73 a 2 ii 50.73 5 2 x LEVEL(10) 20.2203(aX2Xi) 20.2203(aX3Xii) 50.73(aX2 Xiii) 73.71 20,2203 a 2 ii 20.2203 a 4 50.73 a 2 iv OTHER 20.2203(aX2 iii) 50.36(cXI) 50 73(aX2Xv) S or in

'n Abeusct below C Form 366A 20.2203(aX2Xiv) 50.36(cX2) 50.73(aX2Xvii)

S F.CO . FO H. I NAME TELEPHONE NUMBER(hciude Area Ccxt )

John SLMartin - Technical (716)771-3641 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 CAUSE MANUFACIURER REPORTABI.E;j4'<. SYSIEM COMPONENT MANUFACIURER REPORTABLE TO EPIX ;aj'AUSE 10 EPIX SUPPLEMENTALREPORTEXPECI'ED I4 MONTH DAY EXPECTED YES SUBMISSION gf yes, complete EXPECTED SUBMISSION DATE). X NO DATE (15)

(Limitto 1400 spaces, i.e., approximately 15 singl~ typewritten (ines) (16) 'BSTRACT On November 17, 1998, for the it was identified that calibration procedures for flow transmitters Hydrogen Recombiners had been improperly performed on October 30 and October 31, 1997. Th3.s action had not fully complied w3.th the Surveillance Requirements of the Ginna Station Improved Technical Spec3.fications.

calibration procedures CPI-CNMT-INSTR-398'nd CPI-CNMT-INSTR-398B did not meet the It was determined that performance of requirements of Technical Specification Surveillance Requirement 3.6.7.2, in that a calibration standard was improperly substituted for the specified calibration standard.

Immediate corrective action was to enter Surveillance Requirement 3.0.3, and to perform the required calibration of the flow transmitters against the appropriate calibration standard.

The underlying cause of the improperly performed surveillance was non-adherence to plant procedures.

Corrective action to prevent recurrence is outlined in Section V.B.

9812240093 981217 PDR ADQCK 05000244 S PDR NRC Fotut 366 (6 1998)

NR F RM A U.S. N - AR REGULATORY OMMZ ION (6-1998)

LICENSEE EVENT REPORT, (LER)

TEXT CONTINUATION FA ILETY NAME 1 DO KET LER NUM8ER PA E SEOUENTIAL REVISION NUMBER NUMBER R. E. Ginna Nuclear Power Plant 05000244 1998 "- 004 -- 00 2 OF 6 TEXT (If more space is required, use addi rionai copies of NRC Form 366A) (17)

PRE-EVENT PLANT CONDITIONS:

On November 17, 1998,'t approximately 1315 EST, the plant was in Mode 1 at approximately 100% steady state reactor power. In activities unrelated to plant conditions, a review of previous calibration data for the Hydrogen Recombiners was in progress. It was discovered that the previous calibration of Flow Transmitter FT-3-1A for the "A" Hydrogen Recombiner (and FT-3-1B for the "B" Hydrogen Recombiner) was improperly performed. During performance of CPI-CNMT-INSTR-398A on October 30, 1997, Instrument and Control (Z&C) technicians substituted a Heise digital pressure gauge for the pressure standard (pneumatic deadweight. tester) specified in the procedure when calibrating FT-3-1A. During performance of CPI-CNMT-INSTR-398B on October 31, 1997, I&C technicians again substituted the Heise pressure gauge, for the pneumatic deadweight tester specified in the procedure when calibrating FT-3-1B.

II. DESCRIPTION OF EVENT:

A. DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES:

October 30, 1997: Event date for FT-3-1A.

October 31, 1997: Event date for FT-3-1B.

November 17, 1998, 1315 EST: Discovery date and time.

November 18, 1998, 0900 EST: Flow transmitters FT-3-1A and FT-3-1B are calibrated against the specified calibration standard.

B. EVENT:

On November 17, 1998, at approximately 1315 EST, the plant was in Mode 1 at approximately 100'h steady state reactor power. In activities unrelated to plant conditions, Nuclear Engineering Services (NES) personnel were reviewing previous calibration data for the Hydrogen Recombinezs.

that the previous calibrations of flow transmitters FT-3-1A and FT-3-1B for It was discovered the recombiners were improperly performed. During performance of CPI-CNMT-INSTR-398A on October 30, 1997, Instrument and Control (I&C) technicians substituted a Heise digital pressure gauge for the pressure standard (pneumatic deadweight tester) specified in the procedure. The Heise gauge was less accurate at the pressure range of FT-3-1A than the deadweight tester, and calibration of flow transmitter FT-3-1A, as performed on October 30, 1997, could not be verified with the required accuracy using the Heise gauge. On October 31, 1998, similar activities were conducted during performance of CPI-CNMT-INSTR-398B with respect to FT-3-1B.'ES personnel notified Operations supervision, of this condition on November 17, 1998, at approximately 1315 EST. Based on input from I&C and NES, Operations supervision determined that the two flow transmitters had not been adjusted during the October 30/31, 1997, calibrations. That is, the "as-found" value was the same as the "as-left" value for FT-3-lA and FT-3-1B.

Previous surveillances using the specified deadweight tester indicated that there were no historical drift concerns related to these flow transmitters's such, the Hydrogen Recombiners were believed to remain capable of performing their specified function, but the improperly performed calibrations did not fulfillthe requirements of Ginna Station Improved Technical Specifications (ITS) Surveillance Requirement (SR) 3.6.7.2.

NR FORM 3 U. ~ N L.EAR REGULATORY OMMISSION (6 1998)

LICENSEE EVENT.REPORT (LER)

TEXT CONTINUATION FACILITYNAME 1 DO KET LER NUMBER PA E

. YEAR SEQUENTIAL REVISION NUMBER NUMBER R. E. Ginna Nuclear Power Plant 05000244 -- "" 3 OF 6 1998 004 00 TEXT (if more space is required, use addi tionai copies of NRC Form 366AJ (17)

ITS SR 3.6.7.2 requires performance of a channel calibration of each Hydrogen Recombiner actuation and control channel every 24 months,'o ensure that the Hydrogen Recombiner will function as designed. Flow transmitters FT-3-1A/B sense flow when the recombiner blower motor is running (verifies there is combustion air flow) and provides a current to a current-to-pressure (I/P) converter, which ultimately satisfies an interlock to permit energizing the remainder of the recombiner control circuit. Failure to perform this calibration to the specified accuracy was judged to be a missed surveillance, since the intent of the surveillance could not be determined to have been satisfied.

Based on the discovery date of November 17, 1998, the plant entered ITS SR 3.0.3, effective 1315 EST on November 17, 1998. Utilizing the guidance of SR 3.0.3, the missed surveillance was properly performed at approximately 0900 EST on November 18, 1998, within the required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discovery of this condition. The plant then exited SR 3.0.3.

C. INOPERABLE STRUCTURES ~ COMPONENTS'R SYSTEMS THAT CONTRIBUTED TO THE EVENT

'one D~ OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED:

None E. METHOD OF DISCOVERY:

The review of the Hydrogen Recombiner data was completed on November 17, 1998.

Operations supervision determined that the improperly performed calibration procedure constituted a missed surveillance, in that use of a substitute calibration standard did not fulfill the requirements of ITS SR 3.6.7.2.

F. OPERATOR ACTION:

After discussions between NES personnel and Operations supervision, the Shift Supervisor was advised by Operations supervision that this condition constituted a missed surveillance, and that ITS SR 3.0.3 should be entered.

Review of the calibration history of these flow transmitters was performed, and no it drift was determined that these flow transmitters have exhibited essentially over recent calibrations. No adjustment of setpoint was required during the two most recent calibrations of these flow transmitters, and the flow transmitters were not adjusted against the Heise pressure gauge in 1997.

Thus, there was no reason to suspect that the flow transmitters would be found out of tolerance upon subsequent recalibration within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Pending completion of actions required by ITS SR 3.0.3, NES engineers advised that the Hydrogen Recombiners should be considered operable. No other actions were required of the operators.

R M AR RE R MMI I (6-1998)

LICENSEE EVENT, REPORT (LER)

TEXT CONTINUATION FACILITYNAME 1 DOCKET 2 LER NUMBER PAGE 3 SEQUENTIAL REVISION NIJI4BER NUMBER R. E. Ginna Nuclear Power Plant 05000244 1998 - 004 -- 00 4 OF 6, TEXT (If more space is required, use addicionai copies of iNC Form 366A) (17) satisfactory completion of CPI-CNMT-INSTR-398A and CPI-CNMT-INSTR-398B on the plant exited ITS SR 3,0.3, 'he flow transmitters were Upon November 18, 1998, found to be within the required tolerance, and no adjustments were required to maintain the transmitters within this tolerance. (Slight adjustments were made to optimize the "as-left" setpoints.)

G. SAFETY SYSTEM RESPONSES:

None IIZ. CAUSE OF EVENT:

A. IMMEDIATE CAUSE:

The immediate cause of the missed surveillance was the calibration of flow transmitters FT-3-1A/B performed on October 30/31, 1997, in that the calibration could not be verified with required accuracy using the Heise gauge.

B. INTERMEDIATE CAUSE:

The intermediate cause of the improper calibration was substitution of a Heise pressure gauge for the pressure standard (deadweight tester) specified in procedures CPI-CNMT-INSTR-398A and CPZ-CNMT-INSTR-398B.

C. ROOT CAUSE:

The underlying cause of the substitution of pressure standards was non-adherence to the requirements of procedures CPI-CNMT-ZNSTR-398A and CPI-CNMT-ZNSTR-398B. This was a cognitive personnel error on the part of RG&E I&C technicians, who were not aware that substitution of the Heise digital pressure gauge for the deadweight tester would not fulfillthe accuracy requirements implicit in the calibration procedures, to comply with ITS SR 3.6.7.2. There were no unusual characteristics of the work area.

In discussions with the Z&C technicians who performed this calibration, identified that the deadweight tester was unavailable at the work location on it was October 30/31, 1997. A decision was made in the field to utilize another pressure standard (Heise gauge), under the presumption that the Heise gauge was an acceptable substitute. This substitution was contrary to the requirements of calibration procedures CPI-CNMT-INSTR-398A and CPI-CNMT-INSTR-398B, which specified an accuracy of +/- 0.05 inches of water. The Heise digital pressure gauge (Model 901B) has an accuracy of +/- 0.4 +/- inches of water, and the pneumatic deadweight tester has an accuracy is 0.005 inches of water. Consequently, calibration of flow transmitters FT-3-1A/B'gainst the Heise gauge did not obtain the accuracy of setpoint comparison necessary to comply with the requirements of ITS SR 3.6.7.2.

NR FORM 3 A -1998

R RM A AR RE LA R MM I (6-1998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATlON FACILITYNAME I OOCKET 2 LER NUMBER PAGE 3 SEOUENTIAL REVISION NllMBER NUMBER R. E. Ginna Nuclear Power Plant 05000244'998 -- 004 -- 00 5 oF 6 TEXT (If more space Is requ1red, use add1t1onaI copIes of NRC Eorm 366A) (17)

IV. ANALYSIS OF EVENT:

This event is reportable in accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2) (i) (B), which requires a report of, "Any operation or condition prohibited by the plant's Technical Specifications". (It should be noted that RGEE does not believe this event should be reportable, as discussed in our letter of May 14, 1996.) The improperly performed surveillance constituted a missed surveillance, which required entry into ITS SR 3.0.3.

An assessment was performed considering both the safety consequences and implications of this event with the following results and conclusions:

There were no operational or safety consequences or implications attributed to the missed surveillance because:

o No component failuxes,were identified during this testing.

The function of the Hydrogen Recombiners is to eliminate the potential breach of containment, due to hydrogen oxygen reaction. Recombiners are designed to reduce the hydrogen concentration following a Loss of Coolant Accident (LOCA). No need for the recombiners to function occurred between the event date and November 18, 1998.

The identified surveillance inadequacy would not result in the unavailability of the safety system after an accident.

if it had been called on to function If flow transmitter FT-3-1A or FT-3-1B had been left significantly out of tolerance after calibration against the Heise gauge, the capability to mitigate the consequences an accident would still exist, for the following reasons:

Consequences of flow transmitter FT-3-1A/B setpoint too high would be the failure to energize the control circuit and inability to start up the affected Hydrogen Recombiner. Alternative methods are available to perform the function of this flow transmitter after a LOCA, The function could be accomplished by installation of a jumper in the Hydrogen Recombiner panel in the Intermediate Building. Since the use of the Hydrogen Recombiner following a LOCA is not required for several days after a LOCA has occurred, there is ample time to perform these activities if the flow

.transmitter did not satisfy the interlock for a recombiner.

b. Consequences of flow transmitter setpoint too low would be continued recombinex operation with either low blower motor flow ox complete loss of flow. This undesired operation would be terminated by either high temperature cutout on increasing temperature during continued combustion, or low temperature cutout due to loss of combustion; The installation of a jumper (as noted in subparagraph "a" above) in the Hydrogen Recombiner panel would then allow the function to be performed when acceptable flow is restored; Based on the above, it can be concluded that the public's health and safety was assured at all times'

NR FORM A .N ARRE U TORY MMI I N (6-1998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYNAME 1 DOCKET 2 LER NUMBER PAGE 3 SEOUENTIAL REVISION NUMBER NUMBER R. E. Ginna Nuclear Power Plant 05000244 1998 -- 004 -- 00 6 oF 6 TEXT (If more space is required, use addicionai copies of MC Form 366A) (17)

V. CORRECTIVE ACTION:

A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:

Calibration procedures CPI-CNMT.INSTR-398A and CPI-CNMT.INSTR-398B were properly performed within'4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of discovery of this condition, to ensure operability of flow transmitters FT-3-1A and FT-3-1B for both Hydrogen Recombiners.

B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE:

A Training Work Request (TWR) has been submitted, requesting a "Training Toolbox" for the Electrical Maintenance Department, to cover the root cause of this LER. It is intended that this training should include determine the requirements for equivalent measuring and test equipment, the method to equivalence, and practical examples to reinforce concepts covered. It is also intended that this training should include a review of events that were attributed to procedure non-adherence.

VI. ADDITIONAL INFORMATION:

A. FAILED 'COMPONENTS:

None B. PREVIOUS LERs ON SIMILAR EVENTS:

A similar LER event historical search was conducted with the following results: No documentation of similar LER events with the same root cause at Ginna Station could be identified.

C. SPECIAL COMMENTS:

None NRC 0RM

A HO ROCHESTER GAS AND ELECTRK ICORPORAVON ~ 89 EAST AVENUE, ROCHESTER, N. Y Iddd9 0%1 AREA CODE+id Sdd ~~D0 ROBERT C. MECREDY Vice President Nucleor Operotions May 14, 1996 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

Subject:

Reportability of Missed Technical Specification and Inservice Testing Surveillances Rochester Gas & Electric Corporation R.E. Ginna Nuclear Power Plant .

Docket No. 50-244 Gentlemen, On February 24 t 1996 RG&E implemented the Improved Standard Technical Specifications (ISTS) at Ginna Station per Amendment No. 61. As a result of this conversion, an issue has been raise d with respect to the reportability of missed technical specification and inservice testing (IST) surveillances per 10 CFR 50.73. This issue is due to the fact that previous NRC guidance in this area (NUREG-1022) does not specifically apply to the ISTS in several areas. The purpose of this letter is to discuss these differences and document RG&E's position concerning reportability of these missed surveillances.

In 1994, the NRC published a second draft, revision 1 to NU~llEG-1022. The purpose of NUEEG-1022 was to consolidate NRC reporting guidelines with respect to 10 CFR 50.72 and 50.73 into one document to help achieve consistency within the nuclear power industry. NUREG-1022 was developed using standard technical specifications (STS) which preceded the ISTS. There are several differences between these two versions of technical specifications which create discrepancies'hen atteinpting to use the guidance of NUIT-1022, especially for the reportability of missed technical specifications and IST surveillances. These differences are discussed in detail below.

In STS, the relevant specifications in question are 4.0.1 and 4.0.3. These are restated below for discussion purposes:

4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

0~V 4.0.3 Failure to perform a Surveillance'equirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements ar'e applicable at the time it is identified that a Surveillance Requirement has not been performed. 'he ACTION requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Surveillance Requirements do not have to be performed on inoperable equipment.

In summary, per Specifications 4.0.1 and 4.0.3, ifthe surveillance frequency for a component is exceeded, the subject component must be declared inoperable and the limiting condition for operation (LCO). entered; however, a delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is provided before the associated ACTIONS must be performed.

With respect to reportability, the bases for Specification 4.0.3 state that "the failure to perform a surveillance within the provisions of Specification 4.0.2 is a violation of a Technical Specification requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant's Technical Specifications." NUTMEG-1022 further expands on this by stating that a missed technical specification or IST surveillance must be reported when "enough time has elapsed that, as a result of the missed surveillance, a TS controlled system must be declared inoperable and the LCO action statement has been exceeded." That is, an LER is required if the time period between the last test and the test being performed is greater than the specified testing interval (multiplied by 1.25 per Specification 4.0.2) plus the completion time for restoring the affected component to operable status. In this instance, the afFected component may be inoperable for a longer period of time than the STS would allow (i.e., the plant is in a condition prohibited by technical specifications).

In ISTS, there are significant differences from Specifications 4.0.1 and 4.0.3. The new versions of these Specifications are restated below from the Ginna Station technical specifications:

SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR Failure to meet a SR, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure'to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillance do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.3 Ifit is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is less. This delay is permitted to allow performance of the Surveillance. Ifthe Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Therefore, per SR 3.0.1 and 3.0.3, ifa surveillance frequency is exceeded, a delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is provided in order to perform the surveillance prior to declaring any component inoperable and the LCO not met. This is a significant difference from STS in which the component is first declared in'operable and then a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay is provided prior to performing the required actions. In addition, with respect to reportability of a missed surveillance, there is no longer any discussion in the bases for SR 3.0.3.

Based on these differences, it is RG&E's position that a missed surveillance test is not a reportable event (i.e., LER) per the ISTS. At no time is the plant outside the technical specifications in this

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instance since no equipment is declared inoperable until the allowed delay period from time of discovery has been exceeded (e.g., 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) or the surveillance is failed upon its performance.

These actions are specifically provided by SR 3.0.3 which is part of the technical specifications per 10 CFR 50.36. In addition, a missed surveillance is <pically an administrative issue that does not directly affect plant operation unless the affected component is failed. Therefore, if upon performance of the missed surveillance a required component is discovered inoperable, an LER will be generated in accordance with the guidance provided in NUREG-1022 since the component may have been inoperable for a longer period of time than allowed by the ISTS.

It is noted that ifa missed surveillance test indicates a substantial breakdown in the surveillance testing program (e.g., surveillance test has never been performed), it would be reported per 10 CFR 50.73(a)(2)(i)(B). This is consistent with NUREG-1022 guidance for reportability of administrative control related errors. Since the IST program requirements are in the administrative controls section in ISTS (versus Specification 4.0.5 per STS), this guidance would also apply to missed or deficient IST program requirements.

Therefore, effective February 24, 1996, RG&E will only generate an LER per 10 CFR 50.73 upon a missed technical specification or IST surveillance if:

(1) A component must be declared inoperable and the time period between two successful surveillance tests is greater than 1.25 times the specified frequency plus the completion time for restoring the component to operable status; or (2) The missed surveillance(s) indicate a substantial breakdown in the surveillance testing program.

Please contact George Wrobel, Manager of Nuclear Safety and Licensing at (716) 724-8070 ifyou require any further information. RG&E would like to suggest that the NRC consider these issues in any future revisions of NUREG-1022.

Ve ly yours, g

Robert C. Mecredy MDB845 xc: U.S. Nuclear Regulatory Commission Mr. Guy Vissing (Mail Stop 14C7)

PWR Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Mr. Chris Grimes (Mail Stop 11E22)

Chief, Technical Specifications Branch Washington, D.C. 20555 Ginna Senior Resident Inspector

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