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| issue date = 06/12/1980
| issue date = 06/12/1980
| title = Comments on 800506 Presentation to NRC Commissioners Re Status of SEP & Description of Difficulty as Lack of Aggression by Licensees.Nrc Has Not Provided Guidelines. Issues W/Higher Priorities Have Arisen
| title = Comments on 800506 Presentation to NRC Commissioners Re Status of SEP & Description of Difficulty as Lack of Aggression by Licensees.Nrc Has Not Provided Guidelines. Issues W/Higher Priorities Have Arisen
| author name = WHITE L D
| author name = White L
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| addressee name = EISENHUT D G
| addressee name = Eisenhut D
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000244, 05000485
| docket = 05000244, 05000485
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:REGULATORY IIRMATIONDISTRIBUTION SYS(RIDS)ACCESSION NBR:8006180537 DOC,DATE:
{{#Wiki_filter:REGULATORY     II    RMATION DISTRIBUTION SYS                   (RIDS)
80/06/12NOTARI2EDi NODOCKETFACIL:502r4r4RobettEmmetGinnaNuclea'rPlantrUnit,irRochester G050002r4r4 STN-50-r485 SterlingPowerProjectNuclearrUnitiiRochester 050004485 AUTH'AMEAUTHORAFFILIATION WHITErL~D,Rochester Gas8ElectricCorp~RECIPNAMERECIPIENT AFFILIATION EISENHUTiD.G.
ACCESSION NBR:8006180537             DOC,DATE: 80/06/12                NOTARI2EDi    NO                      DOCKET FACIL:50 2r4r4 Robett Emmet Ginna Nuclea'r Plantr                    Unit,ir    Rochester G                050002r4r4 STN-50-r485   Sterling    Power    Project Nuclearr Unit              ii Rochester                050004485 AUTH'AME              AUTHOR    AFFILIATION WHITE r L ~ D,       Rochester     Gas  8  Electric        Corp ~
DivisionofLicensing
RECIP NAME            RECIPIENT AFFILIATION EISENHUTiD.G.         Division of Licensing


==SUBJECT:==
==SUBJECT:==
Commentson800506presentation toNRCCommissioners restatusofSEPLdescription ofdifficulty aslackofaggression bylicensees,NRC hasnotprovidedguidelines issuesw/higherpriorities havearisen,DISTRIBUTION CODE:A055SCOPIESRECEIVEDILTR iENCL~SIZEITITLE:SEPTopicsE:lPA>''f'~AACd--tl.L---++'Lh,~~C-~A/37rg7z,RECIPIENT COPIESRECIPIENT COPIESIDCODE/NAME LTTRENCLIDCODE/NAME LTTRENCL'CTION:
Comments on 800506 presentation to NRC Commissioners re status of SEP L description of difficulty as lack of aggression by licensees,NRC has not provided guidelines issues w/higher priorities have arisen, DISTRIBUTION CODE: A055S          COPIES RECEIVEDILTR                i  ENCL  ~  SIZEI
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                                                                              ~ ~C-~A TITLE: SEP    Topics E:lP A>''f'~ AA                      C d--tl.L --+           +'Lh,
A/DMATLEQUAL16 HYD/GKOBR1702EGFILE0110111'11CONTSYSA13I8E08ORASSESSBR15SEPBR0QEXTERNAL:
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INTERNAL: A/D MATLEQUAL16                1                CONT SYS      A    13 HYD/GKO BR      17        1                  I8E                08 02        1                OR    ASSESS    BR 15 EG  FILE      01        '1                  SEP  BR          0Q 10        1 EXTERNAL: ACRS                23      16      1            LPDR                03 NSIC            07        1 Ju,') g          0 lg8O NUMBER OF COPIES        REQUIRED: LTTR        k4 03'OTAL ENCL
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ROCHESTER GASANDELECTRICCORPORATION o89EASTAVENUE,ROCHESTER, N.Y.14649LEOND,WHITE,JR.VICCPRESIDENT TCLSPHONC ARCACOOKTld546.2700June12,1980Mr.DarrellG.Eisenhut, DirectorDivisionofProject.Management OfficeofNuclearReactorRegulation U.S.NuclearRegulatory Commission Washington, D.C.20555


==DearMr.Eisenhut:==
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Werecentlyreviewedthetranscript ofthepresentation youandothersfromtheNRCStaffmadetotheCommissioners onMay6,1980regarding thestatusoftheSystematic Evaluation Program(SEP).Weweredisappointed tonotethatyoudescribed amajorprogramdifficulty asbeing"licensees notaggressively pursuingprogram."
                    ////I///I/
Further,wedrewtheinference fromthepresentation thatlicensees werebeinguncooperative inproviding
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/theproperinformation totheStaff.Wearedisappointed fortworeasons.First,thattheNRCStaffhasnotcommunicated tousanyspecifics regarding whatweshouldnowbedoingthatwearenotnowdoing.Andsecond,wedonotbelieve,theStaffcharacterization ofprogramdifficulties tobefair.ThepurposeofthisletteristoprovideRochester GasandElectricCorporation's viewsonouraggressiveness intheSystematic Evaluation Programandtobrieflyoutlineourviewsonprogramdifficulties.
ROCHESTER GAS AND ELECTRIC CORPORATION                    o 89 EAST AVENUE, ROCHESTER, N.Y. 14649 LEON D, WHITE, JR.                                                                    TCLSPHONC VICC PRESIDENT                                                            ARCA COOK Tld 546.2700 June 12, 1980 Mr.          Darrell G. Eisenhut, Director Division of Project. Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
IthasbeencleartousthattheSEPistheNRCStaff'sprogram.This.preceptwasstatedinitially andhasbeenrestatedanumberofptxmes.
 
Itwasmostrecentlyevidenced inaletterdatedDecember12,1979whichcategorized topicsintothosethattheNRCwouldaddressandthoseforwhichthelicenseewouldbeaskedtobearmajorresponsibility.
==Dear Mr. Eisenhut:==
Theareasthatwehavebeenaskedtoperformmajorreviewshavebeenfewinnumber.IntheDecember12letter,theStaffstatedthat.wewouldbeprovidedguidelines forourefforts.Iackofguidelines forsometopicsshouldnothowever,betakentomeanthatwehaveignoredtheseandothertopics.Substantial workhasbeenperformed insupportofStaffsitevisitsandevaluations.
 
Anexampleispreparation andreviewofsafeshutdowntechniques, including discussion inlicensedoperatortrainingclasses,whichwascompleted priortotheStaff'ssafeshutdownsitevisitofJune14-16,1978andhasbeencontinued sincethattime.Thatworkhasbeenusefulinaddressing otherlicensing andoperating concernsandhas,webelieve,provideda5strongeroperating complement.
We        recently reviewed the transcript of the presentation you and others from the NRC Staff made to the Commissioners on May 6, 1980 regarding the status of the Systematic Evaluation Program (SEP). We were disappointed to note that you described a major program                    difficulty as being "licensees not aggressively pursuing program." Further, we drew the inference from the presentation that licensees were being uncooperative in providing /the proper information to the Staff. We are disappointed for two reasons.
8008180631 011I8T
First, that the NRC Staff has not communicated to us any specifics regarding what we should now be doing that we are not now doing.
~E~~VROCHESTER GASANDELECTRICCORP.DATEJune12,1980ToMr.DarrellG.Eisenhut, DirectorSHEETNO.Anotherexamplewasourstudyonelectrical penetrations, sub-mittedonApril12,1979.Althoughinitiated forreasonsotherthenSEP,ourSeismicUpgradeProgramisamajorinitiative.
And second, we do not believe, the Staff characterization of program difficulties to be fair. The purpose of this letter is to provide Rochester Gas and Electric Corporation's views on our aggressiveness in the Systematic Evaluation Program and to briefly outline our views on program difficulties.
Asdescribed toyourStaffonJuly24,1979,thisprogramwillresultinreanalysis ofallmajorseismiccategoryIpipingatGinna.Theresultsofourprogramwillbeincorporated intotheStaff'sSEPevaluation asdescribed inanNRCletterdatedApril29,1980.Programdifficulties andtheattendant, slippageincompletion datesisnotunexpected tous.First,theProgrambeganwithout,clearlydefinedreviewcriteria.
It hasThis.      been  clear to  us that the    SEP  is the  NRC    Staff's program.                             precept  was stated  initially  and has been          restated a number dated December 12, ofptxmes. It 1979 was most recently evidenced in a which categorized topics into those that letter the NRC would address and those for which the licensee would be asked to bear major responsibility. The areas that we have been asked to perform major reviews have been few in number.                                       In the December 12 letter, the Staff stated that. we would be provided guidelines for our efforts.
Whilerealistic assessments, givingcreditforalternate'methods ofsatisfying
I ack of guidelines for some topics should not however, be taken to mean that                        we have ignored these and other topics.
: criteria, weretobeperformed, littleguidanceonhowtoperformtheserealistic assessments orwhatconstituted anacceptable levelof"realism" wasprovidedfortheStaffreviewers.
Substantial work has been performed in support of Staff site visits and evaluations. An example is preparation and review of safe shutdown techniques, including discussion in licensed operator training classes, which was completed prior to the Staff's safe shutdown site visit of June 14-16, 1978 and has been continued since that time. That work has been useful in addressing other licensing and operating concerns and has, we believe, provided a                                      5 stronger operating complement.
Thisiscertainly under-standable sincenosuchprogramhadbeenperformed previously.
8008180 631
Further,it.wasprobablydesirable nottobeoverlyprescriptive priortobeginning theProgrambuttoletexperience gainedduringearlyreviewsshapethereviewtechniques
 
'tobeusedlater.Progresshasthusbeendeliberate.
0 1      I 1    8 T
: Secondly, issueswithhigherpriorities havearisenduringtheSEPwhichcouldnotbeforeseen.
 
ThesehaveaffectedtheStaffreviewsinsomecasesandthelicensees resources inothers.Althoughtheyarewellknown,itisusefultomentionseveralofthese:environmental qualification ofelectrical equipment, IEBulletins 79-02,79-04,79-14,andresponses tothelessonslearnedfromTMIarebutseveral.AthirdreasonthatweperceiveforslippageisthechangingofStaffreviewers onindividual topics.Thesechangeshavebeenduetoreviewertransfers orpromotions or,mostrecently, tothereorganization withinNRR.Afewexamplesinthisareamaybeillustrative.
V
Controlroomhabitability wasapartofanSEPsitevisitonSeptember 6,1978.Sincethattimetherehasbeenanadditional sitevisitandtherehavebeentwosubsequent reviewers.
  ~E ~ ~
Further,arelatedaspect,offsitehazards,wasassignedtoanotherreviewer.
ROCHESTER GAS AND ELECTRIC CORP.                                     SHEET NO.
Heobtainedsubstantial information fromusandweunderstand thathemadeanumberofthecontactsgathering information.
DATE  June 12, 1980 To    Mr. Darrell G. Eisenhut,       Director Another example was our study on electrical penetrations, sub-mitted  on April 12, 1979. Although initiated for reasons other then SEP, our Seismic Upgrade Program is a major initiative. As described to your Staff on July 24, 1979, this program will result in reanalysis of all major seismic category I piping at Ginna. The results of our program will be incorporated into the Staff's SEP evaluation as described in an NRC letter dated April 29,   1980.
Unfortunately, priortopreparing hisassessment hewastransferred toanotherNRCBranch.Itmay,therefore, benecessary foranewreviewertoreperform thistask.AnotherexampleisTopicII-2.D,Meteorological Measure-mentsProgram.Information onthetopicwasprovidedinformally onAugust,24,1978.Inresponsetoadraftsafetyassessment whichwereviewedwiththeStaffonMay29,1979,weprovidedcommentsbothinformally (July5,1979)andformally(April11,1980).FurtherwehavemadenumerousattemptstodiscussthistopicwiththeStaffeitherviatelephone orinameetingbuthavebeenunsuccessful inourattemptstoarrangeatechnical ROCHESTER GASANDELECTRICCORP.DATEJune12,1980ToMr.DarrellG.Eisenhut, Director8SHEETNO.dialogue.
Program  difficulties and the attendant, slippage in completion dates  is not unexpected to us. First, the Program began without
InTopicIII-5.A,HighEnergyLineBreaksInsideContainment, weprovidedtheStaffwithinformation duringasitevisitinMarch1979andbysubmittals datedFebruary9,1979andSeptember 11,1979.Sincethattime,wehavebeeninformedthattheStaffisradically revisingtheanalysisguidelines, jeopardiz-ingmuchoftheprogressmadetodatebyusandotherSEPutilities.
        ,clearly defined review criteria. While realistic assessments, giving credit for alternate'methods of satisfying criteria, were to be performed, little guidance on how to perform these realistic assessments or what constituted an acceptable level of "realism" was provided for the Staff reviewers.         This is certainly under-standable since no such program had been performed previously.
Atthistime,weareawaitingStaffresponsetooursubmittals orStaffissuanceoftherevisedguidelines.
Further, it. was probably desirable not to be overly prescriptive prior to beginning the Program but to let experience gained during early reviews shape the review techniques 'to be used later. Progress has thus been deliberate.
BasedonourreviewofSEP,wedonotbelievethatthereasonsforslippageinSEPshouldbeattributed tolackoflicenseeaggressiveness.
Secondly, issues with higher priorities have arisen during the  SEP  which could not be foreseen.       These have affected the Staff reviews in some cases and the licensees resources in others.
Itisapparent, however,thatthereneedstobeincreased communications betweentheStaffandRG&Eregarding thestatusandprogressofSEP.Wewouldbepleased.to discusstheSEPwithyouoryourStaffatyourconvenience.
Although they are well known,         it is useful to mention several of these: environmental qualification of electrical equipment, IE Bulletins 79-02, 79-04, 79-14, and responses to the lessons learned from TMI are but several.
Verytrulyyours,p}}
A third reason that we perceive for slippage is the changing of Staff reviewers on individual topics. These changes have been due to reviewer transfers or promotions or, most recently, to the reorganization within NRR. A few examples in this area may be illustrative. Control room habitability was a part of an SEP site visit on September 6, 1978. Since that time there has been an additional site visit and there have been two subsequent reviewers. Further, a related aspect, offsite hazards, was assigned to another reviewer. He obtained substantial information from us and we understand that he made a number of the contacts gathering information. Unfortunately, prior to preparing his assessment he was transferred to another NRC Branch. It may, therefore, be necessary for a new reviewer to reperform this task. Another example is Topic II-2.D, Meteorological Measure-ments Program.       Information on the topic was provided informally on August, 24, 1978.       In response to a draft safety assessment which we reviewed with the Staff on May 29, 1979, we provided comments both informally (July 5, 1979) and formally (April 11, 1980). Further we have made numerous attempts to discuss this topic with the Staff either via telephone or in a meeting but have been unsuccessful in our attempts to arrange a technical
 
ROCHESTER GAS AND ELECTRIC CORP.                         8            SHEET NO.
DATE  June 12, 1980 To    Mr. Darrell G. Eisenhut,         Director dialogue.     In Topic III-5.A, High Energy Line Breaks Inside Containment, we provided the Staff with information during a site visit in March 1979 and by submittals dated February 9, 1979 and September 11, 1979. Since that time, we have been informed that the Staff is radically revising the analysis guidelines, jeopardiz-ing much of the progress made to date by us and other SEP utilities.
At this time, we are awaiting Staff response to our submittals or Staff issuance of the revised guidelines.
Based on our review        of SEP, we do not believe that the reasons    for slippage in      SEP should be attributed to lack of licensee aggressiveness.           It is apparent, however, that there needs to be increased communications between the Staff and RG&E regarding the status and progress of SEP. We would be pleased.to discuss the SEP with you or your Staff at your convenience.
Very truly yours, p}}

Latest revision as of 20:55, 29 October 2019

Comments on 800506 Presentation to NRC Commissioners Re Status of SEP & Description of Difficulty as Lack of Aggression by Licensees.Nrc Has Not Provided Guidelines. Issues W/Higher Priorities Have Arisen
ML17250A332
Person / Time
Site: Ginna, Sterling  Constellation icon.png
Issue date: 06/12/1980
From: White L
ROCHESTER GAS & ELECTRIC CORP.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
TASK-***, TASK-RR NUDOCS 8006180537
Download: ML17250A332 (6)


Text

REGULATORY II RMATION DISTRIBUTION SYS (RIDS)

ACCESSION NBR:8006180537 DOC,DATE: 80/06/12 NOTARI2EDi NO DOCKET FACIL:50 2r4r4 Robett Emmet Ginna Nuclea'r Plantr Unit,ir Rochester G 050002r4r4 STN-50-r485 Sterling Power Project Nuclearr Unit ii Rochester 050004485 AUTH'AME AUTHOR AFFILIATION WHITE r L ~ D, Rochester Gas 8 Electric Corp ~

RECIP NAME RECIPIENT AFFILIATION EISENHUTiD.G. Division of Licensing

SUBJECT:

Comments on 800506 presentation to NRC Commissioners re status of SEP L description of difficulty as lack of aggression by licensees,NRC has not provided guidelines issues w/higher priorities have arisen, DISTRIBUTION CODE: A055S COPIES RECEIVEDILTR i ENCL ~ SIZEI

~ ~C-~A TITLE: SEP Topics E:lP A>f'~ AA C d--tl.L --+ +'Lh,

/37rg 7z, RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR BC C.RNMHFJE'r-91 9 ENCL'CTION:

pd~88t.oao, 8.

INTERNAL: A/D MATLEQUAL16 1 CONT SYS A 13 HYD/GKO BR 17 1 I8E 08 02 1 OR ASSESS BR 15 EG FILE 01 '1 SEP BR 0Q 10 1 EXTERNAL: ACRS 23 16 1 LPDR 03 NSIC 07 1 Ju,') g 0 lg8O NUMBER OF COPIES REQUIRED: LTTR k4 03'OTAL ENCL

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ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649 LEON D, WHITE, JR. TCLSPHONC VICC PRESIDENT ARCA COOK Tld 546.2700 June 12, 1980 Mr. Darrell G. Eisenhut, Director Division of Project. Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Eisenhut:

We recently reviewed the transcript of the presentation you and others from the NRC Staff made to the Commissioners on May 6, 1980 regarding the status of the Systematic Evaluation Program (SEP). We were disappointed to note that you described a major program difficulty as being "licensees not aggressively pursuing program." Further, we drew the inference from the presentation that licensees were being uncooperative in providing /the proper information to the Staff. We are disappointed for two reasons.

First, that the NRC Staff has not communicated to us any specifics regarding what we should now be doing that we are not now doing.

And second, we do not believe, the Staff characterization of program difficulties to be fair. The purpose of this letter is to provide Rochester Gas and Electric Corporation's views on our aggressiveness in the Systematic Evaluation Program and to briefly outline our views on program difficulties.

It hasThis. been clear to us that the SEP is the NRC Staff's program. precept was stated initially and has been restated a number dated December 12, ofptxmes. It 1979 was most recently evidenced in a which categorized topics into those that letter the NRC would address and those for which the licensee would be asked to bear major responsibility. The areas that we have been asked to perform major reviews have been few in number. In the December 12 letter, the Staff stated that. we would be provided guidelines for our efforts.

I ack of guidelines for some topics should not however, be taken to mean that we have ignored these and other topics.

Substantial work has been performed in support of Staff site visits and evaluations. An example is preparation and review of safe shutdown techniques, including discussion in licensed operator training classes, which was completed prior to the Staff's safe shutdown site visit of June 14-16, 1978 and has been continued since that time. That work has been useful in addressing other licensing and operating concerns and has, we believe, provided a 5 stronger operating complement.

8008180 631

0 1 I 1 8 T

V

~E ~ ~

ROCHESTER GAS AND ELECTRIC CORP. SHEET NO.

DATE June 12, 1980 To Mr. Darrell G. Eisenhut, Director Another example was our study on electrical penetrations, sub-mitted on April 12, 1979. Although initiated for reasons other then SEP, our Seismic Upgrade Program is a major initiative. As described to your Staff on July 24, 1979, this program will result in reanalysis of all major seismic category I piping at Ginna. The results of our program will be incorporated into the Staff's SEP evaluation as described in an NRC letter dated April 29, 1980.

Program difficulties and the attendant, slippage in completion dates is not unexpected to us. First, the Program began without

,clearly defined review criteria. While realistic assessments, giving credit for alternate'methods of satisfying criteria, were to be performed, little guidance on how to perform these realistic assessments or what constituted an acceptable level of "realism" was provided for the Staff reviewers. This is certainly under-standable since no such program had been performed previously.

Further, it. was probably desirable not to be overly prescriptive prior to beginning the Program but to let experience gained during early reviews shape the review techniques 'to be used later. Progress has thus been deliberate.

Secondly, issues with higher priorities have arisen during the SEP which could not be foreseen. These have affected the Staff reviews in some cases and the licensees resources in others.

Although they are well known, it is useful to mention several of these: environmental qualification of electrical equipment, IE Bulletins 79-02, 79-04, 79-14, and responses to the lessons learned from TMI are but several.

A third reason that we perceive for slippage is the changing of Staff reviewers on individual topics. These changes have been due to reviewer transfers or promotions or, most recently, to the reorganization within NRR. A few examples in this area may be illustrative. Control room habitability was a part of an SEP site visit on September 6, 1978. Since that time there has been an additional site visit and there have been two subsequent reviewers. Further, a related aspect, offsite hazards, was assigned to another reviewer. He obtained substantial information from us and we understand that he made a number of the contacts gathering information. Unfortunately, prior to preparing his assessment he was transferred to another NRC Branch. It may, therefore, be necessary for a new reviewer to reperform this task. Another example is Topic II-2.D, Meteorological Measure-ments Program. Information on the topic was provided informally on August, 24, 1978. In response to a draft safety assessment which we reviewed with the Staff on May 29, 1979, we provided comments both informally (July 5, 1979) and formally (April 11, 1980). Further we have made numerous attempts to discuss this topic with the Staff either via telephone or in a meeting but have been unsuccessful in our attempts to arrange a technical

ROCHESTER GAS AND ELECTRIC CORP. 8 SHEET NO.

DATE June 12, 1980 To Mr. Darrell G. Eisenhut, Director dialogue. In Topic III-5.A, High Energy Line Breaks Inside Containment, we provided the Staff with information during a site visit in March 1979 and by submittals dated February 9, 1979 and September 11, 1979. Since that time, we have been informed that the Staff is radically revising the analysis guidelines, jeopardiz-ing much of the progress made to date by us and other SEP utilities.

At this time, we are awaiting Staff response to our submittals or Staff issuance of the revised guidelines.

Based on our review of SEP, we do not believe that the reasons for slippage in SEP should be attributed to lack of licensee aggressiveness. It is apparent, however, that there needs to be increased communications between the Staff and RG&E regarding the status and progress of SEP. We would be pleased.to discuss the SEP with you or your Staff at your convenience.

Very truly yours, p