ML17261B136

Responds to Commitment Tracking Concerns Noted in Insp Rept 50-244/90-09 & Planned Corrective Actions.Util Confirms Commitments Dates for Implementation of Effective Shelf Life Program & Comprehensive Preventive Maint Program for Parts

ML17261B136
Person / Time
Site:	Ginna
Issue date:	08/14/1990
From:	MECREDY R C ROCHESTER GAS & ELECTRIC CORP.
To:	MARTIN T T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9008230157
Download: ML17261B136 (12)

See also: IR 05000244/1990009

Text

ACCELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9008230157

DOC.DATE: 90/08/14 NOTARIZED:

NO FACIL:50-244

Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G AUTH.NAME AUTHOR AFFILIATION

MECREDY,R.C.

Rochester Gas 6 Electric iCorp.RECIP.NAME

RECIPIENT AFFILIATION

MARTIN,T.T.

Region 1 (Post 820201)SUBJECT: Responds to commitment

tracking concerns noted in Insp Rept 50-244/90-09.

DISTRIBUTION

CODE: IEOID COPIES RECEIVED LTR i ENCL J SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response DOCKET PT 05000244 NOTES:License

Exp date in accordance

with 10CFR2,2.109(9/19/72).

05000244 1'NTERNAL:

RECIPIENT ID CODE/NAME PD1-3 PD AEOD AEOD/TPAD NRR MORISSEAUi

D NRR/DLPQ/LPEB10

NRR/DREP/PEPB9D

NRR/DST/DIR

8E2 NUDOCS-ABSTRACT

OGC/HDS2 RGN1 FILE 01 COPIES RECIPIENT LTTR ENCL ID CODE/NAME 1 1 JOHNSON,A 1 AEOD/DEIIB

1 DEDRO 1 NRR SHANKMAN,S

1 NRR/DOEA DIR 11 1 NRR/DRIS/DIR

1 NRR/PMAS/ILRB12

1 OE@3X 1 ECj FI 02 1 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EXTERNAL: LPDR NSIC 1 1 NRC 1 1 PDR po$5f ggq lf/0/R D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTA'CT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR'NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

c lee ROCHESTER GAS AND ELECTRIC CORPORATION

4 89 EAST AVENUE, ROCHESTER N.Y.14649 0001 ROBE'RT C.,r tFCREOY Vice t'rertdent

(,irma Nuctear Vrnerrrttrrn

'tEt.Etrrro

NE aREa COoE ate 546.2700 August 14, 1990 Mr.Thomas T.Martin Regional Administrator

U.S.Nuclear Regulatory

Commission

Region I 475 Allendale Road King of Prussia, Pennsylvania

19406 SUBJECT: Inspection

Report 50-244/90-09

R.E.Ginna Nuclear Power Plant Docket No.50-244 Dear Mr.Martin: This letter provides our response to the commitment

tracking concerns identified

in the subject inspection

report, and of our planned corrective

actions.(See Enclosure 1)We are also confirming

our commitments, including dates when our actions will be completed, for the implementation

of an effective shelf life program and a comprehensive

preventive

maintenance

program for spare parts.(See Enclosures

2 and 3)RG&E will be pleased to provide additional

information

to assist the NRC in your review of RG&E's compliance

and performance

in these matters.Very truly yours,~Cg~+Robert C.Mecredy Encs.xc: U.S.Nuclear Regulatory

Commission (Original)

Document Control Desk Washington, D.C.20555 Ginna NRC Senior Resident Inspector t9."6~;.i K O;OOO244 r)O(57 90O814 PDR ADQC pDC 9

e

ENCLOSURE 1 COMMITMENT

TRACKING PAGE 1 OF 4 INTRODUCTION

Detail 6.9 of Inspection

Report 50-244/90-09

concluded that the commitment

tracking system at Ginna may not be fully effective because there are no apparent plans for addressing

certain items.Report Detail 7.1 identified

an apparent prolonged failure to meet a commitment (to maintain the excess letdown heat exchanger component cooling water return line containment

isolation valve as normally closed).The Inspection

Report cover letter requested that we evaluate the above matters, that we inform you of the assessment

of our ability to meet and adhere to similar safety commitments, and of any planned corrective

actions.Both Inspection

Report Details 6.9 and 7.1 address the implementation

and maintenance

of commitments.

However, the concerns identified

in Report Detail 6.9 apply to commitments

which typically require a one-time action to complete (e.g., NRC Violations, Unresolved

Items, Deviations).

Report Detail 7.1 applies to design commitments

which require continual cognizance

and implementation (e.g., operating AOV-745 as normally closed).Each of the above commitment

categories

require unique implementation

and maintenance

processes.

Accordingly, our corrective

actions will include separate methods for tracking each of the above categories

of commitments.

We believe that both of our methods will provide us with a higher.level of assurance that commitments

are being maintained

as well as providing a more efficient means of tracking commitment-

related information.

Both of our methods are discussed below.The section titled Commitment

and Action Trackin S stem outlines our approach to track the one-time action commitments

that are discussed in Report Detail 6.9.The second section titled Desicen Basis Documents outlines our approach to tracking design commitments

discussed in Report Detail 7.1.RG&E's Commitment

and Action Tracking System (CATS)which has been under development

since 1989, is not the tracking system which was reviewed and identified

in Report.Detail 6.9.RG&E has developed the plans, is developing

the mainframe software, and will provide the necessary organization

which will allow for the integration

of a number of current tracking systems, one of which was reviewed in Report Detail 6.9, into a single system for regulatory

and other types of commitments.

ENCLOSURE 1 (Continued)

COMMITMENT

AND ACTION TRACKING SYSTEM CATS PAGE 2 OF 4 RG&E has previously

recognized

the stated shortcomings

with our current commitment

tracking methods.To address this issue and concerns noted in Inspection

Reports 88-15 and 89-05, a Commitment

Tracking Assessment

was completed in January, 1989.Subsequent

to the assessment, the RG&E Commitment

and Action Tracking System (CATS)Project Plan was developed and approved by RG&E's Senior Management

in October, 1989.Development

of our upgraded tracking system is progressing.

As noted at.the March 6, 1990 NRC Region I-RG&E Management

Meeting, the anticipated

implementation

schedule for the tracking system is May 29, 1991 (Reference

RG&E Configuration

Management

Level I Schedule included in the meeting handouts which are attached to Inspection

Report 50-244/90-03, dated April 18, 1990).The following provides a brief description

of some of the features of the Commitment

and Action Tracking System (CATS): COMPUTER HARDWARE/SOFTWARE

CATS will reside on our Data General mainframe computer.The use of the mainframe will allow access to up-to-date

commitment

data by both plant and corporate Nuclear Division personnel.

The upgraded tracking system will significantly

expand the types of data elements being tracked.Data elements include, but are not limited to: responsible

department

and individual;

document information

such as source of the commitment, related documents, and implementing/closure

documents;

due date and priority;RG&E and agency closure dates;status;agency;cause;plant systems/structures;

keywords;related commitments;

summary and detailed text of the commitment;

and comments.Each commitment

will also include an activities

section which will allow for development

of action plans where necessary.

The activities

section includes: activity number;department

and individual;

description

of activity;target completion

date and actual completion

date;and activity status.The software design includes menus to allow for various types of reports to be easily requested by Nuclear Division personnel.

User Manuals will be developed to aid personnel in the use of the system.The Detailed Software Design for the CATS is currently under development.

ENCLOSURE 1 (Continued)

PAGE, 3 OF 4 DATABASE Our established

goal is to provide an integrated

database of potentially

safety significant

issues which originate from various sources.At the time the system goes operational, the database wi'll, at a minimum, consist of those open commitments

which originated

in correspondence

to or from the NRC.In our current plans, we expect to expand the database to include other commitments/action

items from documents such as Corrective

Action Reports, Identified

Deficiency

Reports, Nonconformance

Reports, Management

Action Items, other federal, state, and local regulatory

agency correspondence, INPO Evaluations, and INPO generic industry correspondence (e.g., SOERs, SERs, etc.)The extent of the items to be addressed by CATS has not yet been finalized.

To allow for the building of a commitment

database concurrent

with the development

of the mainframe software, a PC based tracking system was developed in the Nuclear Safety and Licensing Group as an interim measure until the mainframe system implementation.

Reports generated from this interim system have the essential data elements and appearance

that reports generated from the mainframe will have, with the exception that the activities

section discussed in Section 1 above was excluded.Currently, the PC database includes commitments/action

items which originated

in correspondence

to and from the NRC dated subsequent

to January 1, 1990.The database also includes a number of commitments

which originated

prior to 1990 yet remained open.We are conducting

additional

reviews of our current tracking systems to identify pre-1990 commitments

which remain open.These reviews should assure that open NRC issues are identified

and included in the database at the time the mainframe system becomes operational.

It is our intent to retain closed commitments

in the database to facilitate

future historical

research of issues.The database that exists on the PC will be incorporated

into the mainframe computer system at the time of its implementation.

k

ENCLOSURE 1 (Continued)

PAGE 4 OF 4 3~MANAGEMENT

CONTROLS The Commitment

and Action Tracking System will provide assurance to management

that safety significant

issues are being addressed.

In addition to tracking the commitment/action

items, the system will allow action plans with appropriate

target completion

dates to be established.

Periodic reports to management

and line personnel showing issues overdue and coming due are planned.Administrative

controls and implementing

procedures

are scheduled to be developed prior to full system implementation.

These administrative

controls will establish responsibilities

for the maintenance

and implementation

of commitments.

Sufficient

progress has been made on our development

to allow us to start the distribution

of the significant

commitment

reports from the interim PC system.At this time, these reports are being used to supplement

information

from other systems and provide a higher level of confidence

that commitments

are being met.DESIGN BASIS DOCUMENTS As noted at the March 6, 1990 NRC Region I-RG&E Management

Meeting, the RG&E Configuration

Management

Level I Schedule shows a June 16, 1990 start date for the Design Basis Documents (DBDs)and a completion

date of November 21, 1994.The Design Basis Documents (DBDs)currently being developed for use by Engineering

and Ginna Station personnel will contain or reference the Design Basis and Licensing commitments

applicable

to the structures, systems and components

contained within them.The DBDs will be controlled

so that they will accurately

reflect the up-to-date

Design Basis and commitments.

They will provide the required reference documents for Engineering

and Ginna Station personnel to ensure that proposed modifications

are properly reviewed and that the Design Basis and ongoing commitments

are properly maintained

at Ginna Station.This will reduce the probability

of future occurrences

such as the improperly

positioned

valve described in Section 7.1 of the inspection

report.As previously

noted in NRC correspondence

and conversations, the DBD effort a recently initiated documentation

program.It will be performed in a systematic

fashion, with the most important systems and topics receiving higher priority.

f 1 0

ENCLOSURE 2 PAGE 1 OF 1 VIOLATION 50-244/87-10-04

DEVELOPMENT

AND IMPLEMENTATION

OF AN EFFECTIVE SHELF-LIFE

PROGRAM As identified

in Detail 6.6 of NRC Inspection

Report 50-22/90-09, the Procurement

Engineering

Group has been assigned the task of development/implementation

of a comprehensive

shelf-life

program for items maintained

in the Ginna Station Warehou'se.

Development

of the computer software which will be used to identify, track and control items with limited shelf-life

was begun June 15, 1990.Based on the progress thus far, completion

date for this phase is October 1, 1990.Development

of the implementing

procedures

for the shelf-life

program was begun July 23, 1990, with an estimated completion

date of October 1, 1990.The decision was made to develop the software first and the procedures

would then be developed.

Based on the implementation

dates identified

above, the overall shelf-life

program will be available for implementation

by Procurement

Engineering

on October 1, 1990.At that.time, all procured items will start to be processed through the shelf-life

program to assure that items with limited shelf-life

are contained in the controlling

program.Previously

procured items will continue to be handled in accordance

with our interim policy of"Last-In, First-Out" (LIFO).The Procurement

Engineering

Group will also perform a review of previously

procured items maintained

in the warehouse.

This program will be initiated after the in-storage

preventive

maintenance

program is complete, and is scheduled to begin around November 1, 1990.We expect this phase of the program to take a minimum of one year, at which time we will discontinue

the interim LIFO policy.

ENCLOSURE 3 UNRESOLVED

ITEM 50-244/88-23-01

PAGE 1 OF 1 DEVELOPMENT

AND IMPLEMENTATION

OF A COMPREHENSIVE

PREVENTATIVE

MAINTENANCE

PROGRAM As identified

in Detail 6.7 of NRC Inspection

Report 50-244/90-

09, the Procurement

Engineering

Group has been assigned the task of development/implementation

of a comprehensive

preventive

maintenance

program for items maintained

in the Ginna Station Warehouse.

Development

of the computer software which will be used to identify, track and control items with preventive

maintenance

requirements

was begun June 15, 1990 with a previously

estimated completion

date of September 1, 1990.However, the shelf-life

program is being developed in parallel with the preventative

maintenance

program.Therefore, the estimated date for software completion

is now October 1, 1990.Development

of the implementing

procedures

for the preventative

maintenance

program was begun July 23, 1990 with an estimated completion

date of September 1, 1990.However, since development

of the implementing

procedures

is dependent on completion

of the software, identified

above, the estimated completion

date has changed to October 1, 1990.This represents

a one month deviation from the estimated completion

date of September 1, 1990 which was identified

during the inspection.

Based on the implementation

dates, identified

above, the overall preventive

maintenance

program will be available for implementation

by Procurement

Engineering

on October 1, 1990.At that time, all procured items will start to be processed through the preventative

maintenance

program to assure that items with preventative

maintenance

requirements

are contained in the controlling

program.The Procurement

Engineering

Group will be performing

a review of previously

procured items maintained

in the warehouse.

This program will be initiated after implementation

of the preventative

maintenance

program, and is scheduled to begin November 1, 1990.This phase is estimated to have a completion

time of approximately

one year.