ML17265A490

Forwards LER 98-004-00 Re Improperly Performed Surveillance Due to Procedure non-adherence.Licensee Does Not Agree That, for Equipment Item That Is Otherwise Known to Be Operable, Reporting of Missed Surveillance Should Be Required

ML17265A490
Person / Time
Site:	Ginna
Issue date:	12/17/1998
From:	MECREDY R C ROCHESTER GAS & ELECTRIC CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17265A491	List: ML17265A490 ML17265A493
References
NUDOCS 9812240091
Download: ML17265A490 (5)

Text

CATEGORY 1REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

SUBJECT:

Forwards LER 98-004-00 re improperly performed surveillance due to procedure non-adherence.

Licensee does not agree that, for equipment item that is otherwise known to be operable,-reporting of missed surveillance'hould be required.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR I ENCL I SIZE: Zr$TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.A E 05000244 Q NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72)

.ACCESSION NBR:9812240091 DOC.DATE: 98/12/17.NOTARIZED:

NO-DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH.NAM i AUTHOR AFFILIATION MECREDY,R.C.

Rochester Gas&Electric Corp.RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)RECIPIENT ID CODE/NAME PD1-1 PD INTERNAL: AEOD/SPD CE E NRR/DE/EELB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RGN1 FILE 01 COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME VZSSING,G.

AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HOHB NRR/DRPM/PECB RES/DET/EIB COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR 1 1 1 1 1 1 LITCO BRYCE,J H NOAC QUEENER,DS NUDOCS FULL TXT 1 1 1 1 1 1%epee P A s NTS thy N%'Dt 1I"-I-"c C>"'"'0 S" M'J-'CUR JA~C..ORGA 4 ZA EON RSMOV~"RCM I.STRT U ON L~'hl t g t Is+1 I 0~'rt FULL TEXT CONVERSION REQUIRED warrior AND ROCHESTER GAS AND EIECTRIC CORPORATION

~B9 EASTAVENUE, ROCHESTER, N.Y 14649-000I AREA CODE 716 5'.2700 ROBERT C.MECREDY Vice President Nvcteor Operations December 17, 1998 U.S.Nuclear Regulatory Commission

~Document Control Desk Attn:Guy'S.Vissing Project Directorate I-1 Washington, D.C.20555

Subject:

LER 1998-004, Improperly Performed Surveillance, Due to Procedure Non-Adherence, Resulted in Condition Prohibited by Technical Specifications R.E.Ginna Nuclear Power Plant Docket No.50-244

Dear Mr.Vissing:

In accordance with 10 CFR 50.73, Licensee Event Report System, item (a)(2)(i)(B), which requires a report of,"Any operation or condition prohibited by the plant's Technical Specifications", the attached Licensee Event Report LER 1998-004 is hereby submitted.

Although we are submitting this LER in accordance with the guidance provided in NUREG-1022, Revision 1, we do not agree that, for an equipment item that is otherwise known to be operable, the reporting of a missed surveillance should be required.The Ginna Station Technical Specifications Bases for Surveillance Requirement 3.0.3 allows the plant to defer declaring equipment inoperable for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for a missed surveillance.

No Limiting Condition for Operation (LCO)is entered and no equipment is declared inoperable, if the resultant surveillance test proves that the equipment is operable.Since there is no operation or condition prohibited by the Technical Specifications, 10 CFR 50.72 and 10 CFR 50.73 do'not apply, and no report should be made./f~P 98i224009i 98i21T PDR ADOCK 05000244 PDR.'

The philosophy behind the Ginna Station Technical Specifications and Bases were presented to the NRC in a letter from RG&E (Mecredy)to NRC, dated May 14, 1996, which is attached.RG&E has never received a formal response to this letter, and hereby requests such a response.We note that the advanced notice of ProPosed rulemaking (ANPR)for 10 CFR 50.72 and 10 CFR 50.73, dated July 23, 1998, indicates that singular events such as missed surveillances should not be reported.We believe that a conforming response to our May 14, 1996, letter will supersede NUREG-1022, Revision 1, which is a guidance document, and allow us not to report missed surveillances for operable equipment in the future.This event has in no way affected the public's health and safety.Ver ruly your Robert C.Mecredy Attachments:

1.LER 1998-004 2.Letter dated May 14, 1996 xc: U.S.Nuclear Regulatory Commission Mr.Guy S.Vissing (Mail Stop 14C7)Project Directorate I-1 Washington, D.C.20555 U.S.Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 U.S.NRC Ginna Senior Resident Inspector t,