IR 05000244/1985099

Comments on 860918 Ltr Transmitting SALP Rept 50-244/85-99 & Results of 861007 Meeting Re Control of Activities.Agrees W/Salp Board Recommendations on Housekeeping.Formal Housekeeping Program Will Be Instituted

ML17251A840
Person / Time
Site:	Ginna
Issue date:	10/28/1986
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8611030482
Download: ML17251A840 (12)

Text

~~~i 43'k~ROCHESTER GAS AND ENCLOSURE'4.l*2 j~~llktf'LECTRIC CORPORATION

~89 EAST AVENUE, ROCHESTER, N.Y.1484&0001 ROGER W.KOBER WCC PRC%OKNT CIXCTlOC O 5TEAM PROOUCTlON TCLKPHONC ABACA COOC%le 546.2700 Dr.Thomas E.Murley, Regional Administrator U.S.Nuclear Regulatory Commission Region I 631 Park Avenue I October.28, 1986 King of Prussia, Pennsylvania 19406 Subject: RG&E Response to Systematic Assessment of.Licensee Performance (SALP)Report No.50-244/85-99

Dear Dr.Murley:

In response to your September 18, 1986 letter.transmitting the SALP,Report 85-99 and as a result of our October 7, 1986 meeting in Rochester, we are providing written comments.In general, we agree with the report and appreciate the opportunity to discuss our performance over the SALP period with you.We note your assessment that our performance demonstrates a strong commitment to safe and efficient plant operations.

Regarding strengthening.of our Quality Assurance Program, we have been accelerating completion of our initiatives.

These have been discussed with you and members of your staff and we will continue to keep you informed of,our progress.We believe the issue of"informality with regard to station activities" is more properly addressed as an issue of"control of activities."'!Two types of comments are provided.First, comments on the SALP-Board Observations regarding"an apparent attitude of informality at Ginna Station" are provided in Attachment A"RG&E Comments on Control of Activities." Second, specific comments on specific pages in'he report are included in Attachment B-"RG&E Comments on SALP Report 50-244/85-99." This discussion should provide you with assurance that the staff at RG&E is continuously striving for excellence in perform-ance.Ro r W.Kober Attachment

/Copies: Document Control Desk c'W fR pf I ll'

'RQfE Response to SAXP Report No.50-2li/85-99 Page ATTACHMENT A ATTACHMENT A t&o e so o o c 8 We believe the issue of"informal versus formal"" attitude to be one of<<control of activities." It is necessary to review some of the formal programs already in place or in progress which are designed to improve ouZ"control of activities." There are two modes that naturally apply when controlling activities.

A reactive mode, logically entered for events such as plant trips or emergency maintenance, and a pro-active mode for pre-planning of activities.

Addressing the reactive mode, there are several formal processes.already in place," in which the plant staff is quite proficient, which demonstrate control of activities.

These processes include: o Post Trip Review (A-25.4)o Emergency Maintenance Procedures o Corrective Action System o Morning Priority Action Required (MOPAR)o Emergency Operating Procedures (EOPs)Recovery from plant trips is accomplished by the plant staff safely and effectively in a formal fashion.Emergency Maintenance is planned in a well thought out manner and is formally approved by the Plant Operations Review Committee (PORC).Our control of operationa events has improved.The upgraded EOP's coupled with the newly installed simulator has strengthened our response to off-normal ev'ents.However, we have identified additional areas to be evaluated which could improve our"control of activities." These are: o Root Cause Identification o Troubleshooting 1~The plant staff will review these areas and will implement those aspects which can improve our control of activities.

In the pro-active mode, the following programs/processes are in place to control activities.

o PORC o QA/QC Sub-Committee o ALARA Committee o.MOPAR'

t f'I 4 RGfE Response to 8ALP Report No.50-2ii/85-99 Page 2 ATTACHMENT A You are aware of these committees and have commented on them as strengths so no further elaboration is recpxired here.The following programs are being.developed and implemented:

o Accreditation o Maintenance Procedure Upgrade (stressing acceptance criteria)o Maintenance Information System (MIS)o Objective Based Management Program (OBM)These programs will improve our control of activities at all levels within the plant.Several other areas will be evaluated by the plant staff to determine aspects.which can improve our control of activities.

0 0 0 0 Concurrent Activity Identification and Control Non QA Work Activity Control OBM Planning Conduct of Meetings In reviewing performance"at the plant, review of concurrent activities, can be improved with the objective of identifying and eliminating potential conflicts.

This concept has already been included in the MOPAR meetings and will continue to be stressed.This discussion should provide you with assurance that the staff at Ginna is continuously striving for excellence in perfonnance.

Pa RG&E Response to SALP Report No.50-2ii/85-99 Page 1 ATTACHMENT B Attachment B Specific Comments RO&E Response to Systematic Assessment of License Performance (SALP)Report No.50-2ii/85-99 The following provides comments to specific pages for the purposes of clarification, updating information, and/or points of disagree-ment.Page 9, 2nd paragraph regarding 1985 Reactor'rips on Steam-.Generator Levels (S/G).This is provided, for clarification and updating of the situation.

After close operations supervision of the startup following the 1986 outage, we have concluded that the subject trips had a root cause of equipment failure.This is based on the following:

1.Z&C calibration of the Steam Dump Control System resulted in being able to operate in manual-auto during the startup with proper response obtained.2.The feedwater flow transmitters were checked and recalibrated with the lower output set exactly at 10 millianps.

While still somewhat inaccurate at very.low power levels, their response was better than in previous'ears.

'Page 12, regarding SALP Board Recommendation on housekeeping.

We agree with recommendation and will'institute a formal housekeeping program.The program will consist of three phases: defining the standards, performing an education program, and implementating.

k RGSE Response to SALP Report No.50-244/85-99 Page 2 ATTACHMENT B Page 13,.bottom paragraph regarding SWP clarification The following is provided for as an update: A procedure is currently being developed which will describe the purpose of each section of a work permit.This procedure will also outline the generally accepted interpretation for common work permit entries.This should reduce the chance of misinterpretatXori'f the meaning of work permit require-ments.-Page 14, 1st paragraph regarding ALARA policy: A number of formal mechanisms have been and continue to be in place.to ensure that radiation exposure is maintained ALARA and additional formal mechanisms are being developed.

A Corporate ALARA Policy was issued by Francis E.Drake, Jr., the Corporate Chairman of the Board in 1978 and was updated by Paul W.Briggs, Chairman of the Board, in 1984.A.much more detailed policy was issued in 1986.Plant ALARA procedures have been in place for a number of years and govern all activities at the plant, including modifications.

After requirements for ALARA review of modification designs were added to Engineering Department procedures on November 1, 1985.A detailed checklist to assist in compliance with this review requirement is being prepared.Page 14, 1st paragraph regarding'Corporate Health Physicists gob description:

The Corporate Health Physicist position description and list of duties was prepared and issued in November 1980.The position description and list of duties was revised in July 1985.Page 15, 3rd paragraph regarding TLD correction factor: The following is provided for update: Our environmental TLD badges were submitted to the DOE for irradiation and subsequent readout at our facility.We have received verbal verification that our system is within normally acceptable range, but the official report has not yet been received.

A r~4 ROSE Response to 8ALP Report No.50-2ii/85-99 Page 3 ATTACHMENT B Page 18, 2nd paxagraph regarding all Balance of Plant (BOP)instrumentation:

This is to clarify that it is our intent to provide controls and procedures for selective BOP instrumentation and not all.Page 20, 2nd paragraph regarding{}C backshift covexage: RGRE will implement QC backshift'overage of selected preplanned safety related operations activities.

Page 22,-bottom of page: We assume the word"none" was omitted regarding the Board" Recommendation for the Licensee and NRC.Page 28, 2nd paragraph regarding fuel consolidation:

I , The discussion of fuel consolidation activities does not completely reflect all the circumstances surrounding that licensing issue.The NRC licensing issues involved vere stxaight forward and did not involve the actual consolidation technicpxes..

The initial recgxest for license amendment and responses to'RC cpxestions were submitted in a timely fashion.However, largely due to doubts within governmental organizations as to the likelihood that consolidation would actually take place, certain key NRC licensing milestones wexe delayed.All safety issues were resolved as required by the schedule and fuel consolidation was actually performed.

RG&E kept the NRC apprised of all activities during the licensing process.Page 34, bottom of page regarding the Board recommendation:

Since the end of the SALP review period, we have met with you and provided you with an update of our plans and progress.We will continue to keep you informed.

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