ML17265A564

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

ML17265A564
Person / Time
Site:	Ginna
Issue date:	03/01/1999
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17265A565	List: ML17265A564 ML17265A566
References
NUDOCS 9903100116
Download: ML17265A564 (7)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

A'ACCESSION NBR:9903100116 DOC.DATE: 99/03/Ol NOTARIZED: NO DOCKET ¹ FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G; 05000244 AUTri'a3'J+. AUTHOR AFFILIATION MECREDY R.d. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S.

SUBJECT:

Forwards response to NRC 990217 RAI concerning changes to QA program for RE Ginna Station operation.RGScE is modifying changes requested in 981221 submittal. Modified QA Program, encl.

DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: QA Topical Report, Change, Amendment, or Correspondence ocket/Utile NOTES:License Exp date in. accordance with 10CFR2,2.109 (9/19/72) . 0500020$

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL VISSING,G. 1 1 INTERNAL: DRS/RGN.. 1 1 NTZ~h 1 1 Y NRR/DISP/PIMB 1 1 NRR DRCH/HQMB 1 1 NUDOCS-ABSTRACT 1 1 OC/LFDCB 1 1 RGN1 PILE 1 1 1

EXTERNAL: DMB/OSS 1 1 IHS NRC PDR 1 1 0

C Ina~eeklIIIB NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 11

ANn ROCHESTER GAS AND ElECTRIC CORPORATION ~ 89 EASTAVENUE, ROCHESTER, N. Y Id649-0001 AREA CODE716 5'-2700 ROBERT C. MECREDY Vice President Nudeor Operotions March 1, 1999 U. S. Nuclear Regulatory Commission Document Control Desk ATTN: Mr. Guy S. Vissing.

Project Directorate I-1 Washington, DC 20555

SUBJECT:

Revised Submittal of Quality Assurance Program for Station Operation R. E. Ginna Nuclear Power Plant Docket Number 50-244

REFERENCES:

a. Letter from R.C. Mecredy, RG&E, to G.S. Vissing, NRC,

Subject:

"Revised Submittal of Quality Assurance Program for Station Operation," dated December 21, 1998.

b. Letter from G.S. Vissing, NRC, to R.C. Mecredy, RG&E,

Subject:

"Revised Submittal of Quality Assurance Program for Station Operation, Request for Additional Information - R.E. Ginna Nuclear Power Plant (TAC No. MA4455)," dated February 17, 1999.

Dear Mr. Vissing:

In Revision 26 of QA Program for Station Operations (Reference a), RG&E requested the following changes:

~ Change commitment to Regulatory Guide 1.58, Rev. l. An alternative to the use of SNT-TC-1A-1975 for the qualification and certification of nondestructive testing personnel is requested.

Change commitment to Regulatory Guide 1.144, Rev. 1. In lieu of the 30 day requirement of Section 4.5.1 of ANSI N45.2.12-1977, an alternative is proposed.

On February 17, 1999, the NRC requested additional information concerning these changes in Reference b. RG&E is modifying the changes requested in Reference a and is providing the additional information requested.

9903i001ih 99030i PDR ADQCK 05000244,,]

( P PDR

The modified changes are described in Attachment 1. Changes made to Revision 25 of the Quality Assurance Program for Station Operation are denoted by a single revision bar in the left margin in the Enclosure. Attachment 2 is a copy of the enclosure with changes highlighted or struck out.

Very truly yours, Robert C. Mecred RCM~cjkgqapsorai.R26 Attachments 1 and 2

Enclosure:

QA Program for Station Operation Revision 26 xc: U.S. Nuclear Regulatory Commission Mr. Guy S. Vissing (Mail Stop 14B2)

Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

ATTACHMENT 1 17.1 MANAGEMENT Table 17.1.7-1 Conformance of Ginna Station Pro ram to ualit Assurance Standards Re uirements and Guides Regulatory Guide 1.58 RGRE Current Commitments RG&E commits to Reg. Guide 1.58, Rev. 1, which references SNT-TC-1A-1975 for the qualification and certification of nondestructive testing personnel

~ RGEE's ISI Plan currently endorses ASME Code Section XI-1986 Edition. This edition of'the ASME code references SNT-TC-1A-1980.

RG&E Re uested Chan e In Reference a, RGSE requested the following exception to the Reg. Guide 1. 58, Rev. 1 commitment to eliminate the current conflicts in our commitments:

~ RGGE's ISI Plan endorses ASME Code Section XI. The version of the ASME code endorsed is updated periodically. ASME Code Section XI references standards for the qualification and certification of nondestructive testing personnel. The standard referenced in the ASME code is used in lieu of SNT-TC-1A-1975, which is referenced by Reg. Guide 1.58, Rev.

1.

NRC= Res onse In Reference b, the NRC staff recommended a modification to RGIt'E's proposed text, as follows:

"RG8E's ISI Plan endorses ASME Code Section XI. The version of the ASME code endorsed is updated periodically. ASME Code Section XI references standards for the qualification and certification of nondestructive testing personnel. Section XI of the ASME Code contains specific requirements for nondestructive examination and also references the use of other supplementary standards for the qualification and certification of personnel performing nondestructive examinations. The applicable versions of the standards referenced in Section XI of the ASME code, as permitted for use by 10 CFR Part SO.S5a, may

I ATTACHMENT 1 I

be used for the qualification and certification of personnel performing nondestructive examinations required by Section III and Section XI of the ASME Code in lieu of the standard identified in Reg. Guide 1.58, Rev. 1, (SNT-TC-1A-1975) provided that other applicable rules contained in Section XI of the ASME Code are met RG&E Res onse RG&E agrees with the NRC's modified text of our proposal.

RG&E is incorporating this wording into Revision 26 of the QA Program for Station Operations.

Regulatory Guide 1.144 RG&E Current Commitment RG&E is currently committed to Reg. Guide 1.144, Rev. 1, which endorses ANSI N45.2.12-1977. Section 4.5.1 of ANSI N45.2.12-1977 requires "In the event that corrective action cannot, be completed within thirty days, the audited organization's response shall include a scheduled date for corrective action."

RG&E Re uested Chan e In Reference a, RG&E requested that in lieu of the 30 day requirement of Section 4.5.1 of ANSl N45.2.12-1977 that the following be applied:

"The audited organization shall respond to audit findings prior to the requested date. In the event that corrective action can not be completed prior to the response due date, the audited organization's response shall include a scheduled date for completion of the corrective action."

NRC Res onse In reference b, the NRC staff expressed concerns relative to the processing and prioritization of significant audit findings.

ATTACHMENT 1 RGGE Res onse RG&E is modifying the requested change to address the concerns of the NRC staff. Audit findings that are determined to be significant conditions adverse to quality will be required to be responded to by the audited organization within 30 days. The modified change is as follows:

"Corrective action response due dates and priority shall be based on safety significance. For audit findings that are determined to be significant conditions adverse to quality, the audited organization's response shall be provided within 30 days. ln the event that the corrective action for an audit finding cannot be completed by the response due date, the audited organization's response shall include a scheduled date for corrective action."