Similar Documents at Ginna |
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML17250B3041999-10-20020 October 1999 Forwards Changes to Tech Specs Bases for Re Ginna Nuclear Power Plant.Change Bars Indicate Those Revs Which Have Been Incorporated IR 05000244/19990081999-10-14014 October 1999 Forwards Insp Rept 50-244/99-08 on 990809-0919.Severity Level IV Violation of NRC Requirements Occurred & Being Treated as non-cited Violation Consistent with App C of Enforcement Policy ML17265A7651999-10-0808 October 1999 Forwards Fifteen Relief Requests That Will Be Utilized for Ginna NPP Fourth Interval ISI Program That Will Start on Jan 1,2000.Attachment 1 Includes Summaries & Detailed Description of Each Relief Request ML17265A7631999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 43 to Address Volumetric Examination Limitations (Less than 90%) Associated with a & B RHR Heat Exchanger Outlet Nozzle to Shell Welds.Approval Is Requested by Dec 31,2000 ML17265A7641999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 42 to Address Volumetric Examinations Limitations (Less than 90%) Associated with Eight Class 1 Identified Welds or Areas of Reactor Pressure Vessel ML20212J3561999-09-30030 September 1999 Forwards Four Copies of Re Ginna NPP Training & Qualification Plan for Security Officers, Rev 7,dtd 990930. Synopsis of Changes,Encl.Encl Withheld Per 10CFR73.21 ML20212J3801999-09-30030 September 1999 Forwards Four Copies of Rev to Re Ginna NPP Security Plan.Rev Changes Contingency Weapons Available to Response Force to Those Most Effective in Current Defensive Strategy.Encl Withheld Per 10CFR73.21 IR 05000244/19990051999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7571999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs IR 05000244/19992011999-09-24024 September 1999 Forwards Insp Rept 50-244/99-201 (Operational Safeguards Response Evaluation) on 990621-24.No Violations Noted. Primary Purpose of Osre to Assess Licensee Ability to Respond to External Threat.Insp Rept Withheld ML17265A7461999-08-31031 August 1999 Submits Response to NRC Administrative Ltr 95-03,rev 2, Availability of Reactor Vessel Integrity Database,Version, Dtd 990726 ML17265A7401999-08-26026 August 1999 Requests Approval for Use of Relief Request Number 35 Re Use of ASME Section XI Code,1995 Edition,1996 Addenda.Code Will Be Used to Develop Plant Fourth 10-year Interval ISI Program on Class 1,2 & 3 Components ML17265A7411999-08-26026 August 1999 Forwards LER 99-004-01 Re Plant Being Outside Design Basis Due to Containment Recirculation Fan Moisture Separator Vanes Being Incorrectly Installed.Part 21 Notification of 990512 Is Being Rescinded ML17265A7451999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Rept for Six Months Ending 990630,per 10CFR26.71(d) ML17250B3021999-08-23023 August 1999 Informs That Util & NRC Had Conference Call on 990816 to Review Approach in Responding to Questions,As Result of Questions Re Main Steam Check Valve Performance Included in Insp Rept 50-244/99-05,dtd 990806 ML17265A7271999-07-30030 July 1999 Forwards 10CFR21 Interim Rept Per Reporting of Defects & Noncompliance,Section 21 (a) (2).Interim Rept Prepared Because Evaluation Cannot Be Completed within 60 Days from Discovery of Deviation or Failure to Comply ML17265A7151999-07-23023 July 1999 Forwards LER 99-007-01 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Reactor Trip.Further Investigation of Event Identified Addl Corrective Actions ML17265A7061999-07-22022 July 1999 Forwards LER 98-003-02,re Actuations of CR Emergency Air Treatment Sys.All Creats Actuations,Including Those Originally Believed to Be Valid Actuations,Were,In Fact Invalid Actuations ML17265A7191999-07-21021 July 1999 Forwards Ginna Station ISI Rept for Refueling Outage Conducted in 1999 ML17265A7141999-07-21021 July 1999 Withdraws Relief Request 35 for Plant Inservice Insp Program Section XI Requirements,Submitted on 980806.Licensee Plans to Resubmit Relief Request,Which Includes Addl Level of Detail,In Near Future ML17265A7041999-07-16016 July 1999 Submits Info Re Specific Licensing Actions Which May Be Expected to Generate Complex Reviews,In Response to Administrative Ltr 99-02,dtd 990603 ML17265A6911999-06-30030 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Readiness Disclosure Attached ML17265A6871999-06-22022 June 1999 Forwards Response to RAI Made During 990225 Telcon Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Calculation Encl. Encl ML17265A6841999-06-21021 June 1999 Informs That Util Wishes to Amend Extend of Alternate Exams Provided for Relief Request Re ISI Program ASME Section XI Require Exams for First 10-Yr Interval for Containment ML17265A6741999-06-15015 June 1999 Submits Annual ECCS Rept IAW 10CFR50.46(a)(3)(ii) Requirements.No Changes Have Been Made to Large Break LOCA PCT & Small Break LOCA PCT ML17265A6751999-06-11011 June 1999 Responds to NRC RAI Re Licensee GL 96-05 Program.Encl Info Verifies That Util Is Implementing Provisions of JOG Program on MOV Periodic Verification ML17309A6551999-06-0707 June 1999 Responds to NRC 990310 RAI Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment ML17265A6671999-06-0101 June 1999 Requests Approval of Ginna QA Program for Radioactive Matl Packages,Form 311,approval Number 0019.Ginna QA Program for Station Operation, Was Most Recently Submitted to NRC by Ltr Dtd 981221 & Supplemented on 990301 ML17265A6641999-05-25025 May 1999 Forwards Addl Info on Use of GIP Method a for Re Ginna Nuclear Power Plant.Copy of Re Ginna Station USI A-46 Outlier Resolution Table as Requested ML17265A6611999-05-24024 May 1999 Forwards LER 99-007-00 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Rt.Util Is Planning to Submit Suppl to LER by 990730 ML20206U0921999-05-13013 May 1999 Forwards Four Copies of Rev R to Gnpp Security Plan,Per Provisions of 10CFR50.54(p).Rev Clarifies Armed Response Team Assignments & Does Not Degrade Physical Security Effectiveness.Rev Withheld,Per 10CFR73.21 ML17265A6461999-05-12012 May 1999 Forwards 1998 Annual Radioactive Effluent Release Rept & 1998 Annual Radiological Environ Operating Rept, for Re Ginna NPP ML17265A6411999-05-12012 May 1999 Forwards LER 99-004-00 IAW 10CFR50.73 & 10CFR21.Further Assessment Will Be Provided in Suppl to LER by 990630 ML20206E7221999-04-29029 April 1999 Forwards Four Copies of Rev Q to Re Ginna Nuclear Power Plant Security Plan,Per 10CFR50.54(p).Changes Do Not Degrade Physical Security Effectiveness.Encl Withheld,Per 10CFR73.21 ML20206H6911999-04-22022 April 1999 Forwards Info Requested During Informal Telcon on 980408 Concerning Upcoming Osre at Ginna Station.Info Requested Listed.Without Encls ML17265A6271999-04-19019 April 1999 Forwards Rev 0 & Rev 1 to Colr,Cycle 28 for Re Ginna NPP, Per TS 5.6.5 ML17309A6501999-04-14014 April 1999 Forwards Revised Ginna Station EOPs & Procedures Index ML17265A6121999-03-29029 March 1999 Forwards Rept on Status of Decommissioning Funding for Re Ginna Npp,For Which Rg&E Is Sole Owner,Per 10CFR50.75. Data Presented Herein,Current as of 981231 ML17265A6041999-03-24024 March 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii)(B) & 10CFR21.Addl Analyses Are Being Performed to Support Future Cycle Operation & Supplemental LER Is Scheduled to Be Submitted by 990618 ML17265A5671999-03-0101 March 1999 Forwards Application for Amend to License DPR-18,to Revise TSs Battery Cell Parameters Limit for Specific Gravity (SR 3.8.6.3 & SR 3.8.6.6).Supporting Tss,Encl ML17265A5641999-03-0101 March 1999 Forwards Response to NRC 990217 RAI Concerning Changes to QA Program for Re Ginna Station Operation.Rg&E Is Modifying Changes Requested in 981221 Submittal.Modified QA Program,Encl ML17265A5551999-02-25025 February 1999 Informs That Util Is in Process of Revising fitness-for-duty Program,Developed in Accordance with 10CFR26.Util Will Continue to Use Dept of Health & Human Svcs Certified Test Facility for Majority of Tests During Yr ML17265A5561999-02-22022 February 1999 Forwards FFD Performance Data Rept for Six Months Ending 981231,per 10CFR26.71(d) ML17265A5451999-02-12012 February 1999 Forwards Simulator Four Year Certification Rept,Per 10CFR55.45(b)(5)(ii) ML17309A6491999-02-12012 February 1999 Forwards Ginna Station EOPs ML17265A5431999-02-0909 February 1999 Supplements 980806 Relief Request with Attached Table.Util Third 10-Yr ISI of Reactor Vessel Being Performed During 1999 Refueling Outage,Beginning on 990301 ML17265A5361999-02-0202 February 1999 Forwards Response to NRC 981203 RAI Re Resolution of Unresolved Safety Issue USI A-46.Util Does Not Agree with NRCs Interpretation.Detailed Bases,Encl ML17311A0691999-01-25025 January 1999 Forwards Revs to Ginna Station Emergency Plan Implementing Procedures (Epips).Previous Rev Had Incorrect Effective Date ML17311A0671999-01-14014 January 1999 Forwards Revised Emergency Operating Procedures for Re Ginna NPP ML17265A5131999-01-12012 January 1999 Forwards Revised Cover Page for Ginna Station Technical Requirements Manual (Trm), Rev 7,correcting Error in Effective Date 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17250B3041999-10-20020 October 1999 Forwards Changes to Tech Specs Bases for Re Ginna Nuclear Power Plant.Change Bars Indicate Those Revs Which Have Been Incorporated ML17265A7651999-10-0808 October 1999 Forwards Fifteen Relief Requests That Will Be Utilized for Ginna NPP Fourth Interval ISI Program That Will Start on Jan 1,2000.Attachment 1 Includes Summaries & Detailed Description of Each Relief Request ML17265A7631999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 43 to Address Volumetric Examination Limitations (Less than 90%) Associated with a & B RHR Heat Exchanger Outlet Nozzle to Shell Welds.Approval Is Requested by Dec 31,2000 ML17265A7641999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 42 to Address Volumetric Examinations Limitations (Less than 90%) Associated with Eight Class 1 Identified Welds or Areas of Reactor Pressure Vessel ML20212J3561999-09-30030 September 1999 Forwards Four Copies of Re Ginna NPP Training & Qualification Plan for Security Officers, Rev 7,dtd 990930. Synopsis of Changes,Encl.Encl Withheld Per 10CFR73.21 ML20212J3801999-09-30030 September 1999 Forwards Four Copies of Rev to Re Ginna NPP Security Plan.Rev Changes Contingency Weapons Available to Response Force to Those Most Effective in Current Defensive Strategy.Encl Withheld Per 10CFR73.21 IR 05000244/19990051999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7571999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7461999-08-31031 August 1999 Submits Response to NRC Administrative Ltr 95-03,rev 2, Availability of Reactor Vessel Integrity Database,Version, Dtd 990726 ML17265A7401999-08-26026 August 1999 Requests Approval for Use of Relief Request Number 35 Re Use of ASME Section XI Code,1995 Edition,1996 Addenda.Code Will Be Used to Develop Plant Fourth 10-year Interval ISI Program on Class 1,2 & 3 Components ML17265A7411999-08-26026 August 1999 Forwards LER 99-004-01 Re Plant Being Outside Design Basis Due to Containment Recirculation Fan Moisture Separator Vanes Being Incorrectly Installed.Part 21 Notification of 990512 Is Being Rescinded ML17250B3021999-08-23023 August 1999 Informs That Util & NRC Had Conference Call on 990816 to Review Approach in Responding to Questions,As Result of Questions Re Main Steam Check Valve Performance Included in Insp Rept 50-244/99-05,dtd 990806 ML17265A7451999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Rept for Six Months Ending 990630,per 10CFR26.71(d) ML17265A7271999-07-30030 July 1999 Forwards 10CFR21 Interim Rept Per Reporting of Defects & Noncompliance,Section 21 (a) (2).Interim Rept Prepared Because Evaluation Cannot Be Completed within 60 Days from Discovery of Deviation or Failure to Comply ML17265A7151999-07-23023 July 1999 Forwards LER 99-007-01 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Reactor Trip.Further Investigation of Event Identified Addl Corrective Actions ML17265A7061999-07-22022 July 1999 Forwards LER 98-003-02,re Actuations of CR Emergency Air Treatment Sys.All Creats Actuations,Including Those Originally Believed to Be Valid Actuations,Were,In Fact Invalid Actuations ML17265A7191999-07-21021 July 1999 Forwards Ginna Station ISI Rept for Refueling Outage Conducted in 1999 ML17265A7141999-07-21021 July 1999 Withdraws Relief Request 35 for Plant Inservice Insp Program Section XI Requirements,Submitted on 980806.Licensee Plans to Resubmit Relief Request,Which Includes Addl Level of Detail,In Near Future ML17265A7041999-07-16016 July 1999 Submits Info Re Specific Licensing Actions Which May Be Expected to Generate Complex Reviews,In Response to Administrative Ltr 99-02,dtd 990603 ML17265A6911999-06-30030 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Readiness Disclosure Attached ML17265A6871999-06-22022 June 1999 Forwards Response to RAI Made During 990225 Telcon Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Calculation Encl. Encl ML17265A6841999-06-21021 June 1999 Informs That Util Wishes to Amend Extend of Alternate Exams Provided for Relief Request Re ISI Program ASME Section XI Require Exams for First 10-Yr Interval for Containment ML17265A6741999-06-15015 June 1999 Submits Annual ECCS Rept IAW 10CFR50.46(a)(3)(ii) Requirements.No Changes Have Been Made to Large Break LOCA PCT & Small Break LOCA PCT ML17265A6751999-06-11011 June 1999 Responds to NRC RAI Re Licensee GL 96-05 Program.Encl Info Verifies That Util Is Implementing Provisions of JOG Program on MOV Periodic Verification ML17309A6551999-06-0707 June 1999 Responds to NRC 990310 RAI Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment ML17265A6671999-06-0101 June 1999 Requests Approval of Ginna QA Program for Radioactive Matl Packages,Form 311,approval Number 0019.Ginna QA Program for Station Operation, Was Most Recently Submitted to NRC by Ltr Dtd 981221 & Supplemented on 990301 ML17265A6641999-05-25025 May 1999 Forwards Addl Info on Use of GIP Method a for Re Ginna Nuclear Power Plant.Copy of Re Ginna Station USI A-46 Outlier Resolution Table as Requested ML17265A6611999-05-24024 May 1999 Forwards LER 99-007-00 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Rt.Util Is Planning to Submit Suppl to LER by 990730 ML20206U0921999-05-13013 May 1999 Forwards Four Copies of Rev R to Gnpp Security Plan,Per Provisions of 10CFR50.54(p).Rev Clarifies Armed Response Team Assignments & Does Not Degrade Physical Security Effectiveness.Rev Withheld,Per 10CFR73.21 ML17265A6461999-05-12012 May 1999 Forwards 1998 Annual Radioactive Effluent Release Rept & 1998 Annual Radiological Environ Operating Rept, for Re Ginna NPP ML17265A6411999-05-12012 May 1999 Forwards LER 99-004-00 IAW 10CFR50.73 & 10CFR21.Further Assessment Will Be Provided in Suppl to LER by 990630 ML20206E7221999-04-29029 April 1999 Forwards Four Copies of Rev Q to Re Ginna Nuclear Power Plant Security Plan,Per 10CFR50.54(p).Changes Do Not Degrade Physical Security Effectiveness.Encl Withheld,Per 10CFR73.21 ML20206H6911999-04-22022 April 1999 Forwards Info Requested During Informal Telcon on 980408 Concerning Upcoming Osre at Ginna Station.Info Requested Listed.Without Encls ML17265A6271999-04-19019 April 1999 Forwards Rev 0 & Rev 1 to Colr,Cycle 28 for Re Ginna NPP, Per TS 5.6.5 ML17309A6501999-04-14014 April 1999 Forwards Revised Ginna Station EOPs & Procedures Index ML17265A6121999-03-29029 March 1999 Forwards Rept on Status of Decommissioning Funding for Re Ginna Npp,For Which Rg&E Is Sole Owner,Per 10CFR50.75. Data Presented Herein,Current as of 981231 ML17265A6041999-03-24024 March 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii)(B) & 10CFR21.Addl Analyses Are Being Performed to Support Future Cycle Operation & Supplemental LER Is Scheduled to Be Submitted by 990618 ML17265A5641999-03-0101 March 1999 Forwards Response to NRC 990217 RAI Concerning Changes to QA Program for Re Ginna Station Operation.Rg&E Is Modifying Changes Requested in 981221 Submittal.Modified QA Program,Encl ML17265A5671999-03-0101 March 1999 Forwards Application for Amend to License DPR-18,to Revise TSs Battery Cell Parameters Limit for Specific Gravity (SR 3.8.6.3 & SR 3.8.6.6).Supporting Tss,Encl ML17265A5551999-02-25025 February 1999 Informs That Util Is in Process of Revising fitness-for-duty Program,Developed in Accordance with 10CFR26.Util Will Continue to Use Dept of Health & Human Svcs Certified Test Facility for Majority of Tests During Yr ML17265A5561999-02-22022 February 1999 Forwards FFD Performance Data Rept for Six Months Ending 981231,per 10CFR26.71(d) ML17265A5451999-02-12012 February 1999 Forwards Simulator Four Year Certification Rept,Per 10CFR55.45(b)(5)(ii) ML17309A6491999-02-12012 February 1999 Forwards Ginna Station EOPs ML17265A5431999-02-0909 February 1999 Supplements 980806 Relief Request with Attached Table.Util Third 10-Yr ISI of Reactor Vessel Being Performed During 1999 Refueling Outage,Beginning on 990301 ML17265A5361999-02-0202 February 1999 Forwards Response to NRC 981203 RAI Re Resolution of Unresolved Safety Issue USI A-46.Util Does Not Agree with NRCs Interpretation.Detailed Bases,Encl ML17311A0691999-01-25025 January 1999 Forwards Revs to Ginna Station Emergency Plan Implementing Procedures (Epips).Previous Rev Had Incorrect Effective Date ML17311A0671999-01-14014 January 1999 Forwards Revised Emergency Operating Procedures for Re Ginna NPP ML17265A5131999-01-12012 January 1999 Forwards Revised Cover Page for Ginna Station Technical Requirements Manual (Trm), Rev 7,correcting Error in Effective Date ML17265A5111999-01-11011 January 1999 Requests Relief Per 10CFR50.55a(a)(3)(ii) from Certain Requirements of Section XI of ASME Bp&V Code for ISI Program.Relief Requests 37,38 & 39 Encl ML17265A5101999-01-11011 January 1999 Requests Relief Per to 10CFR50.55a(a)(3)(ii) from Certain Requirements of Section XI of ASME B&PV Code for ISI Program.Relief Request 40 Encl 1999-09-30
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059L4481990-09-18018 September 1990 Forwards Responses to Rer 900709-13 Team Visit Findings, Per .Responses Withheld (Ref 10CFR73.21) ML17309A4491990-09-13013 September 1990 Forwards Slides Presented by Facility & Westinghouse to NRC in 900724 Meeting.Encl Withheld ML17262A1331990-09-11011 September 1990 Responds to Violations & Several Unresolved Items Noted in SSFI Rept 50-244/89-81.Update of Appropriate Unresolved Items Encl.Specific Actions Re All NRC Unresolved Items Being Tracked to Completion ML17261B1511990-08-29029 August 1990 Forwards Semiannual Radioactive Effluent Release Rept Jan- June 1990 & Rev 3 to Process Control Program for Ginna Station, Per Tech Specs 6.9.1.4 & 6.16,respectively ML17261B1481990-08-28028 August 1990 Lists Understanding of Issues Util Planning to Address Re Containment Integrity,Per 900718 Telcon.Any Concerns or Action Items Different from Listed Submittal Should Be Provided to Util Prior to NRC 900905 & 06 Visit to Plant IR 05000244/19880261990-08-20020 August 1990 Submits Update on Util Plans to Provide Appropriate Ventilation to Intermediate Bldg Clean Side,Per Violation Noted in Insp Rept 50-244/88-26.Extensive Program to Manually Close All External Openings Implemented ML17261B1501990-08-20020 August 1990 Submits Update on Util Plans to Provide Appropriate Ventilation to Intermediate Bldg Clean Side,Per Violation Noted in Insp Rept 50-244/88-26.Extensive Program to Manually Close All External Openings Implemented ML17261B1371990-08-17017 August 1990 Forwards Rev 0 to, Inservice Insp Rept for Third Interval (1990-1999),First Period,First Outage (1990) at Re Ginna Nuclear Power Plant. ML17309A4481990-08-16016 August 1990 Responds to NRC 900717 Ltr Re Violations Noted in Insp Rept 50-244/90-80.Corrective Actions:Westinghouse Drawing E-2508 Approved & Issued to Central Records ML17261B1351990-08-15015 August 1990 Provides Info & Assessment on Integrity of Connection of Containment Bldg to Foundation,Per 900808 Telcon.Util Believes That Existing Condition Not Safety Concern & No Reason Exists to Suspect Joint Will Not Perform Function ML17261B1361990-08-14014 August 1990 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 ML17261B1331990-08-13013 August 1990 Recommits to Performing Enhanced primary-to-secondary Leak Rate Monitoring,Per NRC Bulletin 88-002 ML17261B1261990-07-30030 July 1990 Clarifies Commitment Made in 900316 RO Re Restoring Inoperable Fire Damper I-411-21-P.Util Plans to Design Removable Track Which Will Allow Charcoal Drawer to Be Manipulated.Definitive Schedule Will Be Provided in 60 Days ML20055H9291990-07-23023 July 1990 Forwards Revised Page 6:4 of Plant Security Plan.Page Withheld Per 10CFR73.21 ML17261B1091990-07-20020 July 1990 Advises That Structural Evaluations of Containment Sys Being Performed in Response to Containment Integrity Insp ML17309A4471990-07-17017 July 1990 Forwards Decommissioning Rept, for Plant,Per 10CFR50.33(k) & 50.75(b) ML17261B0881990-07-13013 July 1990 Provides Update to Util 860616 Ltr Re Implementation of NUREG-0737,Item 6.2,Suppl 1, Emergency Response Capability. ML17261B0921990-07-11011 July 1990 Responds to 900709 Request for Addl Info Re Containment Integrity Insp.Util Will Provide Preliminary Results by 900716 Re Where Groundwater Entering Annular Access Area. Meeting Proposed for Wk of 900723 ML20044B0481990-07-10010 July 1990 Discusses Review of Station Blackout Documentation,Per 10CFR50.63.Licensee Will Complete Enhancements to Station Blackout Documentation Identified in Attachment 1 as Indicated & Other Items Will Be Completed within 2 Yrs ML17309A4461990-07-0909 July 1990 Responds to Generic Ltr 90-04 Re Status of Licensee Implementation of Generic Safety Issues Resolved W/ Imposition of Requirements or Corrective Actions ML17261B0931990-07-0909 July 1990 Responds to Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Util Completed All Actions Requested in Generic Ltr & Will Retain Documentation Verification for Min of 2 Yrs ML17261B0901990-07-0909 July 1990 Advises That Licensee Will Install Containment Isolation Signal Going to Valve AOV 745 by End of 1992 Refueling Outage,Per Util 900608 Ltr Notifying of Condition Outside Design Basis of Plant Under 10CFR50.72 Criterion ML17250B2151990-06-29029 June 1990 Forwards Application for Amend to License DPR-18, Reformatting Auxiliary Electrical Sys Tech Specs & Action Statements for Offsite & Onsite Power Sources Available for Plant Auxiliaries ML17261B0851990-06-28028 June 1990 Forwards LER 89-016-02 Re 891117 Failure of Safety Injection Block/Unblock Switch Which Could Render Both Trains of Safety Injection Sys Inoperable.Also Reported Per Part 21 ML17250B1991990-06-0808 June 1990 Responds to NRC 900509 Ltr Re Violations Noted in Insp Rept 50-244/89-81.Corrective Actions:Improved Battery Load Profile Developed Incorporating Calculational Improvements Contained in Current Industry Std IEEE 485-1983 ML17250B1951990-06-0505 June 1990 Responds to Generic Ltr 89-08, Erosion/Corrosion Induced Pipe Wall Thinning. Util Developed Erosion/Corrosion Program for Single & Two Phase Sys Consistent W/Requirements of NUREG-1344 & NUMARC 870611 Rept ML17250B1851990-06-0101 June 1990 Forwards Application for Amend to License DPR-18,providing Guidance for Action Statements Associated W/Power Distribution Limit Specs ML17261B0691990-06-0101 June 1990 Discusses Testing Frequency for Insp of Incore Neutron Monitoring Sys Thimble Tubes,Per NRC Bulletin 88-009.Thimble Tube Indicating Greatest Wear Recently Repositioned in Effort to Minimize Future Wear ML17250B1811990-05-31031 May 1990 Forwards Addl Info Re Response to Notice of Violation from Insp Rept 50-244/90-04.Info Withheld (Ref 10CFR73.21) ML17250B1801990-05-29029 May 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Util Does Not Need to Develop Enhanced Surveillance Program to Monitor Currently Installed Transmitter Based Upon Limited Installed Quantity ML17250B1841990-05-29029 May 1990 Responds to NRC Bulletin 89-002, Stress Corrosion Cracking of High Hardness Type 410 Stainless Steel (SS) Internal Pre-Load Bolting.... Valves Disassembled & 410 SS Studs Removed & Visually & Liquid Penetrant Examined ML17261B0961990-05-29029 May 1990 Responds to NRC 900427 Ltr Re Violations Noted in Insp Rept 50-244/90-07.Corrective Actions:Worker Records Immediately Corrected Indicating That Worker Received No Significant Exposure for Time While Error Occurred ML17250B1721990-05-18018 May 1990 Forwards Rev 1 to Summary Exam Rept for 1990 Steam Generator Eddy Current Insp. Rept Summarizes Observations & Corrective Actions Resulting from Insps Performed During 1990 Outage ML20042G8931990-05-0808 May 1990 Forwards Revised Emergency Operating Procedures,Including Rev 3 to AP-RHR.2,Rev 1 to ES-0.3 & Rev 11 to ES-1.3 ML17261B0611990-04-26026 April 1990 Advises of Changes to 890201 Commitments Made Under Programmed Enhancement Response to Generic Ltr 88-17.Changes Will Not Reduce Capability to Operate Safely in Reduced Inventory Condition or Scope of Programmed Enhancements ML17261B0591990-04-17017 April 1990 Advises That No Interlocks Required for RHR motor-operated Valves 701 & 720 Based on Present Arrangement.Listed Failures Would Have to Occur in Order for Potential Overpressurization of RHR Sys to Occur ML17261B0461990-04-12012 April 1990 Responds to Issues Discussed During 900323 Telcon Re Inservice Testing Program Status & Relief Request.Current Test Methodology for Seat Leakage Acceptable Based on Application of Direct Measurement Sys ML17262A1431990-04-12012 April 1990 Responds to NRC 900202 Ltr Re Weaknesses Noted in Insp Rept 50-244/89-80.Corrective Actions:Procedure ES-0.3 Modified to Provide Guidance for Rapid Cooldown & Depressurization W/ & W/O Reactor & Vessel Instrumentation Sys ML17250B1451990-04-0606 April 1990 Discusses Impact of SER Issuance for Inservice Insp & Inservice Testing Programs & Advises That Timing Will Not Affect Util Implementation Plans for Programs,Except as Listed ML17250B1441990-04-0505 April 1990 Responds to NRC 900309 Ltr Re Violations Noted in Insp Rept 50-244/90-02.Corrective Actions:Positive Indicator Will Be Installed for All Check Valves to Enhance Visible Positive Position Verification Ability & to Avoid Confusion ML17261B0401990-03-30030 March 1990 Advises That Final Results of Station Blackout Documentation Review Will Be Submitted to NRC on or About 900501 ML17261B0321990-03-28028 March 1990 Forwards Annual Rept of ECCS Model Revs as Applicable to Facility,Per 10CFR50.46.Mods to Model for Small Break LOCA Do Not Affect Calculated Peak Clad Temp ML17261B0331990-03-28028 March 1990 Forwards Info Re Reactor Vessel Issues,Per 900305 Telcon Concerning Change of License Expiration Date ML17261B0231990-03-26026 March 1990 Responds to NRC 890222 Ltr Re Violations Noted in Insp Rept 50-244/89-17.Corrective Actions:Personnel Verified Safety Injection Block/Unblock Switch in Proper Position & Operator Procedure 0-1.1 Changed as Indicated ML17261B0281990-03-23023 March 1990 Forwards Addl Info Re Proposed Tech Spec Amend Concerning Use of Reconstituted Fuel,Per 900315 Telcon.During Fuel Assembly Reconstitution,Failed Fuel Rods Will Be Placed W/ Filler Rods ML17261B0221990-03-22022 March 1990 Provides Revised Test Schedule for motor-operated Valve Diagnostic Test Program,Per IE Bulletin 85-003.NRC Notification of Changes to Valve Operability Program Required by Generic Ltr 89-10,dtd 890828 ML17261B0411990-03-20020 March 1990 Forwards Summary of Onsite Property Damage Coverage Currently in Force at Plant,Per 10CFR50.54(w)(4) ML17261B0151990-03-19019 March 1990 Responds to Generic Ltr 89-19, Safety Implication of Control Sys in LWR Nuclear Plants (USI A-47). Overfill Protection Provided Through Trip Bistables in Reactor Protection Racks Powered from 120-volt Instrument Buses ML17261B0101990-03-15015 March 1990 Forwards Application for Amend to License DPR-18,allowing Use of Reconstituted Fuel Assemblies ML20012D2831990-03-14014 March 1990 Responds to Issues Discussed During 900307 Telcon W/Util & Eg&G Re Inservice Testing Program Status & Relief Request. Valves 5960A & 5960B Will Be Disassembled to Verify Forward Flow.Relief Requests PR-8 & VR-25 Encl 1990-09-18
[Table view] |
Text
ACCESSION NBR:8809010097 DOC.DATE: 88/08/26 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH.~ NAME AUTHOR AFFILIATION
%ECREDY,R.C.~
~ Rochester Gas 6 Electric Corp.
RECIP.NAME
~ RECIPIENT AFFILIATION Ofc of Enforcement (Post 870413)
SUBJECT:
Responds to NRC 880727 ltr re violations noted in Insp Rept 50-244/88-10.Corrective actions:check valves exercised.
DISTRIBUTION CODE: IE14D COPIES RECEIVED:LTR / ENCL TITLE: Enforcement Action Non-2.790-Licensee Response L SIZE: /DL NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR.ENCL PD1-3 LA 1 1 PD1-3 PD 1 1 STAHLEiC 1 1 INTERNAL: AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 DEDRO 1 1 NRR/DOEA/EAB 11 1 1 NRR/DREP/EPB 10 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE 01 1 1
'
OE LIEBERMANgJ 1 1 G FIL 02 1 RGN1 FILE 03 1 1 RGN2/DRSS/EPRPB 1 1 ERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1
@ gory/Fd TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 18
f 4
ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649-0001 abaci August 26, 1988 J c c c D te Q H c cocle v ia 5 46 2 700 Director, Office of Enforcement U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Inspection Report 50-244/88-10 Notice of Violation and Proposed Imposition of Civil Penalty Enforcement Action EA 88-154 R.E. Ginna Nuclear Power Plant Docket No. 50-244 Gentlemen:
Enclosed is Rochester Gas and Electric Corporation's (RG&E) response to the Notice of Violation and Proposed Imposition of Civil Penalty dated July 27, 1988. The first enclosure is RG&E's Reply to Notice of Violation filed in accordance with 10CFR2.201. The Reply admits the violations and, documents the corrective actions taken. Also enclosed is a check for $ 50,000, the amount of the civil penalty.
The second enclosure is RG&E's Answer to the Proposed Imposition of Civil Penalty, filed in accordance with 10CFR2.205. Although RG&E has chosen not to contest the proposed civil penalty, we have included information for the record describing reasons why the NRC could have mitigated the proposed penalty. These reasons include our excellent enforcement record at Ginna, prior good performance in the general area of concern, and alternative operation and maintenance practices.
Very truly yours, 8809010097 880826 PDR ADOCK 05000244 G PNU Robert C. Me edy General Manage Nuclear Production Enclosures xc: Mr. William T. Russell Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
ENCLOSURE 1 Re 1 to a Notice of Violation NRC Inspection Report 88-10 stated:
"During an NRC inspection conducted. on May 16-20, 1988, viola-tions of NRC requirements were identified. In accordance with the "General Statement of Policy and. Procedure for NRC Enforce-ment Action," 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:
Technical Specification 4.2 requires that inservice testing (IST) of pumps and valves be performed in accordance with Section ZI of the ASME Boiler and Pressure Vessel Code and.
applicable Addenda, as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the NRC pursuant to 10 CFR Part 50.55a(g)(6)(1).
Article IWV-1100 of the ASME Code, Section ZI, 1977 edition, which is applicable in this situation, requires, in part, periodic testing for those valves which are required to perform a specific function in shutting down a reactor to the cold shutdown condition, or in mitigating the consequences of an accident.
Contrary to the above, as of May 20, 1988, the IST test program for pumps and valves did not include periodic testing of the following safety related check valves that are used to mitigate the consequence of an accident:
- a. Check valves Nos. 3504B and 3505B in the main steam supply lines for the auxiliary feedwater pump turbine; and
- b. -Main feedwater check valves Nos. 3992 and 3993.
,I, lh
- 2. .-'-Puticle IWV-3522 of ASME Code, Section ZI, 1977
-edition, which is applicable in this situation, requires, in part, that the testing required by Article IWV-1100 be performed by exercising the check valves to the position required to plant operation. Further, fulfill if their function during only limited operation. of a check valve is practical during plant operation, the check valve shall be full stroke exercised during. cold shutdowns.
Contrary to the above, as of May 20, 1988, the following check valves which are used to mitigate the consequences of an accident, had not been full-stroke exercised to the position required to functions:
fulfill their
- a. Nos. 9627A and B in the 1C and 1D standby auxiliary feedwater pump service water suction lines;
- b. Nos. 862A and B in the 1A and 1B containment spray pump discharge lines:
- c. Nos. 710A and B in the 1A and 1B residual heat removal (RHR) pump discharge;
- d. Nos. 853A and B in the core deluge check;
- e. No. 854 in the refueling water storage tank (RWST) to RHR pump suction check;
- f. Nos. 842A and B in the loop A and B accumulator dump line check; and
- g. Nos. 867A and B in the loop A and B accumulator dump and safety injection (SI) to cold leg."
I The following responses are provided.
Admission or denial of the alle ed violation 1.
Rochester Gas and Electric admits to Violation 1. The Inservice
'Test Program delineated in Appendix C of the Ginna Station Quality Assurance Manual did not include check valves 3504B, 3505B, 3992 and 3993.
(1) Check Valves 3504B and 3505B (a) lanation and reasons for the violation These valves were installed as part of a 1981 system modification, subsequent to the establishment of the current IST program. RG&E's controls for reviewing the impact of modifications on the IST program scope were less formal in 1981 than our present practice.
"'The 6 point modification improvement established in 1985 has resulted in more through review of modifica-tions relative to the impact on the IST Program.
(b) Corrective ste s that have been taken and. the results achieved.
The check valves have been exercised monthly as part of the PT-16, Auxiliary Feedwater System, test procedure to demonstrate operation of the turbine driven AFW pump. Each valve has been sequentially tested since May 1988 to assure proper opening, backseating and return to the post test normally closed position.
e p
(c) Corrective ste s that will be taken to avoid further violations and when full com liance will be achieved.
Steps to preclude further violations include formaliza-tion of the testing of these valves in accordance with IST commitments by the end of this year. Further, RG&E modification control procedures have been modified to specifically require that the effect of all modifica-tions will be reviewed to identify any required IST Program changes. Additional actions being taken to ensure adequacy of the IST Program are described later in this reply.
(2) Check Valves 3992 and 3993 (a) Ex lanation and reasons for the violation Lack of comprehensive selection criteria at the time -of RG&E's IST Program establishment contributed to feedwater check valves 3992 and 3993 not being included in the program. Original program selections considered safeguards systems actuated to mitigate the conse-quences of an accident or to provide safe shutdown, but did not specifically include valves forming the boundary to interfacing systems. RG&E is completing its review of systems and has found very few potential omissions. These potential omissions are being evaluated for inclusion and for significance at this time. An additional contributing cause was that an independent assessment of the IST program for scope and adequacy was not conducted at the time of its develop-ment.
(b) Corrective ste s that have been taken and the results achieved.
As a result of RG&E's review of SOER 86-03, these valves were disassembled in 1986 and 1987. It was determined that the valves were capable of performing their intended functions.
As further assurance of the capability of these valves to perform this isolation function, during each plant startup when the AFW pumps are in operation a large pressure differential exists across these valves maintaining them closed.
(c) Corrective ste s that will be taken to avoid further violations and when full com liance will be achieved.
Actions taken to preclude further violations include formalization of the testing of these valves during cold shutdown, beginning with the 1989 refueling outage, in accordance with IST commitments, and plans to include these valves in the next IST Program submittal scheduled for 1989. Additional actions being taken to ensure adequacy of the IST program are described later in this response.
~
JP
Admission or denial of the alle ed violation 2.
In response to Violation 2, Rochester Gas and Electric admits, with one exception, that the governing test procedures did not provide for full stroke exercising without a corresponding relief request from Article IWV-3522 of ASME code,Section XI, 1977 edition. Consistent with page 9 paragraph 4 of the inspection report, SI Accumulator Discharge check valves 842 A and B are tested. in accordance with a partial stroking relief request submitted to the NRC with program revision 3A on June 20, 1983.
(a) Ex lanation and. reasons for the violation.
Ten years ago, when. the existing program was established, comprehensive detailed test specifications were not developed, which could have been used as input to the procedures used to perform testing. Additionally the check valve test procedures that were established to comply with IVV-3521 used "observation of substantially free flow" as an indicator that the valve disk moved promptly away from the seat Internal audits of the program did not identify part-stroke testing of the valves as deficient due to our inter-pretation of "substantially free flow" as being "demons-trated partial flow".
(b) Corrective ste s that have been taken and the results achieved.
Engineering dispositions have been provided for each valve, for which full flow testing has not been performed and relief has not been requested. These measures will ensure future valve testing meets our current commitments Valves Di sition 9627A & B Quarterly Partial stroke testing will be augmented, hy disassembly of one valve each refueling shutdown.
is inoperable, the other If that valve valve will he disassembled.
Note: Relief request is being prepared..
862A & B Test Procedure PT-3,'ontainment Spray System, is heing revised to require a mechanical exerciser to move the disc.
The force required to initiate movement will he measured, and subsequent movement will be demonstrated to the position required to fulfillits function.
Note: The reference value will be es-tablished and subsequent testing will demonstrate a breakaway force within 50% from the established reference value.
Valves Dis sition 710A & B PT-2.10.2 will be revised to verify 853A & B the minimum safeguards flow of 1560 854 in each flow path during refueling cavity fill.
Note: A relief request for the deferral of quarterly to the refueling frequency to be prepared.
842A & B For the 1989 outage, either of the following two options for 842A & B 867A & B and 867A & B will be implemented to supplement the existing partial stroke testing.
~tion A Discharge each accumulatcr and measure the pressure and level drop vs. time. Evaluate these parameters against the required system performance to demonstrate check valve operability .
~tice B - Disassemble and inspect either 867A or 867B and either 842A or 842B for operability verification, using a maintenance procedure. Should the inspected. valve require corrective maintenance, the other check valve of similar number will also be inspected.
Note: Relief requests are being prepared.
(c) Corrective ste s that will he taken to avoid further violations and when full com liance will he achieved,.
The short term and long term actions heing taken for both violations will ensure adequacy of the IST Program and avoid similar violations are:
Short Term Actions:
These short,.term actions will ensure that ASME Section XI requirements.. are heing met by the IST Program and. are heing properly. implemented by procedures.
a0 Comprehensive selection criteria have been developed and are heing used to guide an in-depth review of the current program. This review will identify program pump and valve additions or deletions and test category changes for both the current IST program and for the third 10-year interval program, scheduled to be submitted next year. These selection criteria will identify all valves required to be tested, in accordance with the RG&E Section XI IST program, including interfacing system boundary valves.
- b. An indepth review has been completed of the IST implementing procedures to identify any other potential discrepancies from current program commitments.
Corrective actions are being taken to resolve any deficiencies as they are identified in accordance with applicable procedures. These actions include procedure changes, additional testing, generation of relief requests and cold shutdown justifications. Justifica-tions for continued operation are being formulated as appropriate.
c Existing valves are also being evaluated to the recently established test category guidelines to ascertain need for revised testing requirements relative to the 19S6 edition of ASME Section XI. These evaluations are being performed, concurrently with the reviews described in item (a) for identifying valve additions or deletions. The attached milestone schedule identifies the dates for evaluation completion and issuance of interim program changes. Engineering will be involved in this effort and will be defining the safety function parameters relative to each valve (for example full flow rates). This information will be provided to the personnel performing and, reviewing test results.
- d. Plans for an independent assessment of the program revisions have been formulated and will be implemented in early September.'est
- e. procedures are being revised to implement the interim program changes. The December completion is identified on the attached-schedule.
ir Selected personnel involved in our program assessment have visited three other utilities to discuss their programs and have reviewed current IST programs made
.=available from other nuclear plants.
gi Audits of the IST program activities are being enhanced 6o include technical expertise in pump and valve testing and other Section XI requirements.
Lon Term Actions:
These long term actions will ensure that the IST Program will receive the necessary engineering support to be maintained and monitored adequately to prove continued operability of Ginna pumps and valves.
a ~ Responsibility for program control will be shifted from the Quality Assurance group to another group prior to the end of 1988. This change will facilitate the communication of industry pump and valve issues to a group more directly involved with technical issues.
This change will also provide separation between the groups with program respon-sibility and audit responsibility.
- b. Actions are being taken to ensure that notifications of industry experience, vendor bulletins and NRC issuances involving the program are reviewed by cognizant IST test and program personnel.
In summary, the efforts which began after the NRC inspection to
~
.establish definitive IST selection guidelines and test require-ment guidelines are providing a documented. basis for not only identifying the changes and. additions to the current program and implementing test procedures but are also providing a basis upon which responses to regulatory review inquiries can be facilitated and. for which future changes can be adequately considered.
Attached is a milestone schedule of the. actions being taken which, when completed, will provide full compliance to testing commitments.
MILESTONE SCHEDULE Action TCD Review IST implementing procedures to identify Completed potential discrepancies from current program commitments Initiate proposed interim actions and proposed Completed resolution to differences noted in 1 Finalize selection criteria for which valves Completed and pumps will be added to the program Evaluate relevant PGIDs to new criteria for 10/07/88 potential addition to program Finalize test category selection guidance Completed requirements Revise Mod control procedures to ensure modifi- Completed cation impact on IST program is considered Evaluate new and existing program valves to 10/15/88 new selection criteria delineated in 5 above and establish related test recpxirements and corresponding test acceptance criteria for each valve Begin independent assessment. of program 09/01/88 development Augment and revise procedures consistent with 12/15/88 proposed. program revisions
~
f
ENCLOSURE 2 ANSWER TO PROPOSED IMPOSITION OF CIVIL PENALTY Although Rochester Gas and Electric has chosen not to contest the proposed civil penalty, RG&E believes that mitigation could have been granted. The reasons for our position are (1) the superior enforcement history of the Ginna facility and prior good performance in the area of concern, (2) the level of safety significance of the violations, (3) the prompt and extensive corrective actions taken, and (4) our response to prior notice of related events.
The Staff stated in the Notice of Violation (at 2):
"A basis exists for 50% mitigation of the base penalty in view of your prior good enforcement history in the area of surveillance testing, as evidenced by a Category I SALP rating in this area during. the last three rating periods.
Full 100'%itigation based on this factor is inappropriate since the root cause of the violation was inadequate engineering support, which received a Category II SALP rating during the last rating period, which was the first period that engineering support was evaluated as a separate area.
Furthermore, ,a basis exists for 50%
escalation of the civil penalty in light of your prior notice, via NRC Information Notice 86-01 and INPO SOER 86-03, of the need to adequately test operation of check valves. Therefore, on balance, no adjustment to the civil penalty amount is
,"appropriate."
For the following reasons, RG&E believes that the Staff should have considered granting mitigation.
- 1. Past Performance During the 18 years of operating the Ginna facility, RG&E has an excellent record relative to enforcement action.,
As this record shows, RG&E places the highest priority on compliance with NRC requirements and maintaining a cooperative working relationship with the NRC Staff.
RG&E's commitment in the area of concern is reflected in
the Category I SALP rating for surveillance testing during the last three rating periods. From a policy standpoint, such exemplary past performance should be rewarded. The NRC's Enforcement Policy, 10 CFR Part 2, Appendix C, allows for up to 100% mitigation for prior good performance.
The Staff, however, concluded that 100% mitigation was not appropriate given the Category II SALP rating for engineering support during the last rating period. RG&E respectfully submits that a Category II SALP rating (which basically means "satisfactory performance") should not be cited in this manner as essentially an escalation factor. Such a satisfactory rating should not adversely affect other mitigation or escalation conclusions.
Level of Safet Si ificance Although RG&E admits that the valves in question were not tested in accordance with ASME Section XI criteria, we have also determined by analysis that the lack of testing did not result in the violation of any Ginna safety limits. RG&E recognizes that all these valves
,should have been included in the IST program, and that relief requests should have been submitted to permit less than full flow testing of the valves as necessary.
However, RG&E does believe that the partial testing, operation, and maintenance practices on the valves provided reasonable assurance of their capability to perform the required functions. Most of these valves will be addressed in relief requests, currently being prepared for submittal to the Staff, to permit alternatives to full flow testing (the SI accumulator discharge check valves were the subject of a relief request filed in 1983 but not yet acted on by the Staff).
These relief requests have already been discussed with the NRC Staff as the basis for continued operation.
Pr t. and Extensive Corrective Actions RG&E'.s- prompt and extensive corrective actions are detailed in the Reply provided in Enclosure 1 to this lettei. In brief terms, RG&E has not only aggressively pursued resolution of the specific violations, also adopted comprehensive short-term and long-term it has measures which will result in a substantially improved IST program. RG&E has not narrowly focused its actions on the cited deficiencies, but rather has taken broad initiatives to resolve any programmatic weaknesses.
These unusually extensive corrective actions warrant mitigation under the NRC's Enforcement Policy (See 10 CFR Part 2, Appendix C, V.B.2).
~
g
- 4. Res nse to Prior Notice The NOV concluded that a basis exists for 50% escalation as a result of prior notification in Information Notice 86-01 and INPO SOER 86-03. It should be noted that RG&E did perform extensive maintenance in response to these issuances, and performed maintenance of valves 3992 and 3993 as a direct result of our review of SOER 86-03.
Since RG&E did consider these issuances, and performed a number of actions as a result of these documents, we do not believe that we should be cited for escalation of enforcement action.