ML040680721

Application for Technical Specification (TS) Improvement to Extend the Completion Time for Condition B of TS 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process

ML040680721
Person / Time
Site:	Ginna
Issue date:	03/01/2004
From:	Mecredy R Rochester Gas & Electric Corp
To:	Clark R Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML040680721 (18)

Text

Robert C. Mecredy Vice President Always at Your Service Nuclear Operations March 1, 2004 Mr. Robert L. Clark Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Application For Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, "Accumulators," Using the Consolidated Line Item Improvement Process R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Clark:

In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Rochester Gas & Electric (RG&E) is submitting a request for an amendment to the technical specifications (TS) for the R. E. Ginna Nuclear Power Plant.

The proposed amendment would extend the completion time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Condition B of Technical Specification (TS) 3.5.1, "Accumulators." The change is consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-370, "Risk Informed Evaluation of an Extension to Accumulator Completion Times for Westinghouse Plants." The availability of this technical specification improvement was announced in the Federal Register on March 12, 2003 as part of the consolidated line item improvement process (CLIIP).

Enclosure 1 provides a description of the proposed change and confirmation of applicability.

Enclosure 2 provides the existing TS pages marked-up to show the proposed change. Enclosure 3 provides the new TS pages. Enclosure 4 provides the existing TS Bases pages marked-up to reflect the proposed change (for information only). Changes to the TS Bases will be provided in a future update in accordance with the Bases Control Program. There are no new regulatory commitments associated with this proposed change.

RG&E requests approval of the proposed license amendment by December 3, 2004 with the amendment being implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated New York State Official.

An equal opportunity employer A 89 East Avenue I Rochester, NY 14649 tel (585) 546-2700 www.rge.com I) OEO-5+

An Energy East Company

I declare under penalty of perjury under the laws of the United States of America that I am authorized by RG&E to make this submittal and that the foregoing is true and correct.

Any questions concerning this submittal should be directed to Tom Harding, Nuclear Safety and Licensing at (585) 771-3384.

Very truly yours, Executed on March 1, 2004 Robert C. ey

Enclosures:

1. Description and Assessment

2. Proposed Technical Specification Changes (markup)

3. Revised Technical Specification Pages

4. Planned Technical Specification Bases Changes (for information only) xc: Mr. Robert L. Clark (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector Mr. Peter R. Smith New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy NYS Department of Public Service 3 Empire Plaza, I 0th Floor Albany, NY 12223

Enclosure I R.E. Ginna Nuclear Power Plant Description and Assessment

1.0 DESCRIPTION

The proposed License amendment extends the completion time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Condition B of Technical Specification (TS) 3.5.1, "Accumulators."

The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-370, "Risk Informed Evaluation of an Extension to Accumulator Completion Times for Westinghouse Plants." The availability of this technical specification improvement was announced in the Federal Register on March 12, 2003 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Rochester Gas & Electric (RG&E) has reviewed the safety evaluation published on July 15, 2002 (67 FR 46542) as part of the CLIIP. This verification included a review of the NRC staff's evaluation as well as the supporting information provided to support TSTF-370 (i.e., WCAP-15049-A, "Risk-Informed Evaluation of an Extension to Accumulator Completion Times," dated May 18, 1999). RG&E has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to the R. E. Ginna Nuclear Power Plant and justify this amendment for the incorporation of the changes to the Technical Specifications.

2.2 Optional Changes and Variations RG&E is not proposing any variations or deviations from the technical specification changes described in TSTF-370 or the NRC staff's model safety evaluation published on July 15, 2002.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Determination RG&E has reviewed the proposed no significant hazards consideration determination published on July 15, 2002 (67 FR 46542) as part of the CLIIP. RG&E has concluded that the proposed determination presented in the notice is applicable to the R. E. Ginna Nuclear Power Plant and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments There are no new regulatory commitments associated with this proposed change.

4.0 ENVIRONMENTAL EVALUATION RG&E has reviewed the environmental evaluation included in the model safety evaluation published on July 15, 2002 (67 FR 46542) as part of the CLIIP. RG&E has concluded that the NRC staff's findings presented in that evaluation are applicable to the R. E. Ginna Nuclear Power Plant and the evaluation is hereby incorporated by reference for this application.

Enclosure 2 R.E. Ginna Nuclear Power Plant Proposed Technical Specification Changes (markup)

Accumulators 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Accumulators LCO 3.5.1 Two ECCS accumulators shall be OPERABLE.

APPLICABILITY: MODES I and 2, MODE 3 with pressurizer pressure > 1600 psig.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One accumulator A.1 Restore boron 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable due to boron concentration to within concentration not within limits.

limits.

B. One accumulator B.1 Restore accumulator to hour<J inoperable for reasons OPERABLE status. to wR other than Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met.

C.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to S 1600 psig.

D. Two accumulators D.1 Enter LCO 3.0.3. Immediately inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify each accumulator motor operated isolation 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> valve is fully open.

SR 3.5.1.2 Verify borated water volume in each accumulator Is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 1111 cubic feet (50%) and

• 1139 cubic feet (82%).

R.E. Ginna Nuclear Power Plant 3.5.1-1 Amendmento

Accumulators 3.5.1 SURVEILLANCE FREQUENCY SR 3.5.1.3 Verify nitrogen cover pressure in each accumulator is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 700 psig and < 790 psig.

SR 3.5.1.4 Verify boron concentration in each accumulator is 31 days on a 2 2100 ppm and S 2600 ppm. STAGGEREDTEST BASIS SR 3.5.1.5 Verify power is removed from each accumulator 31 days motor operated isolation valve operator when pressurizer pressure is > 1600 psig.

R.E. Ginna Nuclear Power Plant 3.5.1-2 Amendment -

Enclosure 3 R.E. Ginna Nuclear Power Plant Revised Technical Specification Pages

Accumulators 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Accumulators LCO 3.5.11 Two ECCS accumulators shall be OPERABLE.

APPLICABILITY: MODES 1 and 2, MODE 3 with pressurizer pressure > 1600 psig.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One accumulator A.1 Restore boron 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable due to boron concentration to within concentration not within limits.

limits.

I B. One accumulator B.1 Restore accumulator to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inoperable for reasons OPERABLE status.

other than Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met.

C.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to

• 1600 psig.

D. Two accumulators D.1 Enter LCO 3.0.3. Immediately inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify each accumulator motor operated isolation 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> valve is fully open.

SR 3.5.1.2 Verify borated water volume in each accumulator is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 1111 cubic feet (50%) and

• 1139 cubic feet (82%).

R.E. Ginna Nuclear Power Plant 3.5.1 -1 Amendment

Accumulators 3.5.1 SURVEILLANCE FREQUENCY SR 3.5.1.3 Verify nitrogen cover pressure in each accumulator is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 700 psig and

• 790 psig.

SR 3.5.1.4 Verify boron concentration in each accumulator is 31 days on a

> 2100 ppm and

• 2600 ppm. STAGGEREDTEST BASIS SR 3.5.1.5 Verify power is removed from each accumulator 31 days motor operated isolation valve operator when pressurizer pressure is > 1600 psig.

R.E. Ginna Nuclear Power Plant 3.5.1 -2 Amendment

Enclosure 4 R.E. Ginna Nuclear Power Plant Planned Technical Specification Bases Changes (for information only)

Accumulators B 3.5.1 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.1 Accumulators BASES BACKGROUND The functions of the ECCS accumulators are to supply water to the reactor vessel during the blowdown phase of a large break loss of coolant accident (LOCA), to provide inventory to help accomplish the refill phase that follows thereafter, and to provide Reactor Coolant System (RCS) makeup for a small break LOCA.

The blowdown phase of a large break LOCA is the initial period of the transient during which the RCS departs from equilibrium conditions, and

____ heat-from fission product decay, hot internals, and the vessel continues to be transferred to the reactor coolant. The reactor coolant inventory is vacating the core during this phase through steam flashing and ejection out through the break. The blowdown phase of the transient ends when the RCS pressure falls to a value approaching that of the containment atmosphere.

In the refill phase of a LOCA, which immediately follows the blowdown phase, the core is essentially in adiabatic heatup. The balance of accumulator inventory is available to reflood the core and help fill voids in the lower plenum and reactor vessel downcomer so as to establish a recovery level at the bottom of the core.

The accumulators are pressure vessels partially filled with borated water and pressurized with nitrogen gas. The level transmitters for the accumulators measure the level over a 14" span for the corresponding 0-100% level indicated on the main control board. The accumulators are passive components, since no operator or control actions are required in order for them to perform their function. Internal accumulator tank pressure is sufficient to discharge the accumulator contents to the RCS, if RCS pressure decreases below the accumulator pressure.

Each accumulator is piped into an RCS cold leg via an accumulator line and is isolated from the RCS by a motor operated isolation valve and two check valves in series (see Figure B 3.5.2-1a). The motor operated isolation valves (841 and 865) are maintained open with AC power removed under administrative control when pressurizer pressure is

> 1600 psig. This feature ensures that the valves meet the single failure

-criterion-of manually-controlled electrically operated valves per Branch Technical Position (BTP) ICSB-18 (Ref. 1). This is also discussed in References 2 and 3.

R.E. Ginna Nuclear Power Plant B 3.5.1-1 Revisiono

Accumulators B 3.5.1 The accumulator size, water volume, and nitrogen cover pressure are selected so that one of the two accumulators is sufficient to partially cover the core before significant clad melting or zirconium water reaction can occur following a LOCA. The need to ensure that one accumulator is adequate for this function is consistent with the LOCA assumption that the entire contents of one accumulator will be lost via the RCS pipe break

- - during the blowdown phase of the LOCA.

APPLICABLE The accumulators are assumed OPERABLE in both the large and small SAFETY break LOCA analyses at full power (Ref. 4). These are the Design Basis ANALYSES Accidents (DBAs) that establish the acceptance limits for the accumulators. Reference to the analyses for these DBAs is used to assess changes In the accumulators as they relate to the acceptance limits.

In performing the LOCA calculations, conservative assumptions are made concerning the availability of ECCS flow. In the early stages of a large break LOCA, with or without a loss of offsite power, the accumulators provide the sole source of makeup water to the RCS. The assumption of loss of offsite power is required by regulations and conservatively imposes a delay wherein the ECCS pumps cannot deliver flow until the emergency diesel generators start, come to rated speed, and go through their timed loading sequence. In cold leg break scenarios, the entire contents of one accumulator are assumed to be lost through the break.

The limiting large break LOCA is a double ended guillotine break at the discharge of the reactor coolant pump. During this event, the accumulators discharge to the RCS as soon as RCS pressure decreases to below accumulator pressure. As a conservative estimate, no credit is taken for ECCS pump flow until an effective delay has elapsed. This delay accounts for SI signal generation, the diesels starting, and the pumps being loaded and delivering full flow. During this time, the accumulators are analyzed as providing the sole source of emergency core cooling. No operator action is assumed during the blowdown stage of a large break LOCA.

The worst case small break LOCA analyses also assume a time delay before pumped flow reaches the core. For the larger range of small breaks, the rate of blowdown is such that the increase in fuel clad temperature is terminated solely by the accumulators, with pumped flow then providing continued cooling. As break size decreases, the accumulators and safety injection pumps both play a part in terminating the rise in clad temperature. As break size continues to decrease, the role of the accumulators continues to decrease until they are not required and the safety injection pumps become solely responsible for terminating the temperature Increase.

R.E. Ginna Nuclear Power Plant B 3.5.1 -2 Revisiono3

Accumulators B 3.5.1 This LCO helps to ensure that the following acceptance criteria established for the ECCS by 10 CFR 50.46 (Ref. 5)will be met following a LOCA:

a. Maximum fuel element cladding temperature is

• 22000F;

b. Maximum cladding oxidation is < 0.17 times the total cladding thickness before oxidation;

c. __Maximum hydrogen generation from a zirconium water reaction is

• 0.01 times the hypothetical amount that would be generated if all of the metal in the cladding cylinders surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react; and

d. Core is maintained in a coolable geometry.

Since the accumulators discharge during the blowdown phase of a LOCA, they do not contribute to the long term cooling requirements of 10 CFR 50.46.

For both the large and small break LOCA analyses, a nominal contained accumulator water volume is used. The contained water volume is the same as the deliverable volume for the accumulators, since the accumulators are emptied, once discharged. For small breaks, an increase in water volume is a peak clad temperature penalty due to the reduced gas volume. A peak clad temperature penalty is an assumed increase in the calculated peak clad temperature due to a change in an input parameter. For large breaks, an increase in water volume can be either a peak clad temperature penalty or benefit, depending on downcomer filling and subsequent spill through the break during the core reflooding portion of the transient. The analysis uses a nominal accumulator volume and includes the line water volume from the accumulator-to the-check-valve due to these competing effects.

The minimum boron concentration setpoint is used in the post LOCA boron concentration calculation. The calculation is performed to assure reactor subcriticality in a post LOCA environment. Of particular interest is the large break LOCA, since no credit is taken for control rod assembly insertion. A reduction in the accumulator minimum boron concentration would produce a subsequent reduction in the available containment sump-concentration-for post LOCA shutdown and an increase in the maximum sump pH. The maximum boron concentration is used in determining the-time-frame-in-which-boron precipitation is addressed post LOCA. The maximum boron concentration limit is based on the coldest expected temperature of the accumulator water volume and on chemical effects resulting from operation of the ECCS and the Containment Spray (CS) System. The maximum value of 2600 ppm would not create the potential for boron precipitation in the accumulator assuming a containment temperature of 600F (Ref. 6). Analyses performed in R.E. Ginna Nuclear Power Plant B 3.5.1-3 Revisiono

Accumulators B 3.5.1 response to 10 CFR 50.49 (Ref. 7) assumed a chemical spray solution of 2000 to 3000 ppm boron concentration (Ref. 6). The chemical spray solution impacts sump pH and the resulting effect of chloride and caustic stress corrosion on mechanical systems and components. The sump pH also affects the rate of hydrogen generation within containment due to the interaction of CS and sump fluid with aluminum components.

The large and small break LOCA analyses are performed at the minimum nitrogen cover pressure, since sensitivity analyses have demonstrated that higher nitrogen cover pressure results in a computed peak clad temperature benefit. The maximum nitrogen cover pressure limit prevents accumulator relief valve actuation at 800 psig, and ultimately preserves accumulator integrity.

The effects on containment mass and energy releases from the accumulators are accounted for in the appropriate analyses (Refs. 8 and 9).

The accumulators satisfy Criterion 3 of the NRC Policy Statement.

LCO The LCO establishes the minimum conditions required to ensure that the accumulators are available to accomplish their core cooling safety function following a LOCA. Two accumulators are required to ensure that 100% of the contents of one accumulator will reach the core during a LOCA. This is consistent with the assumption that the contents of one accumulator spill through the break. If less than one accumulator is injected during the blowdown phase of a LOCA, the ECCS acceptance criteria of 10 CFR 50.46 (Ref. 5) could be violated.

For an accumulator to be considered OPERABLE, the motor-operated isolation valve must be fully open (see Figure B 3.5.2-1a), power

-- removed above-1600-psig,-and-the-limits-established in the SRs for contained volume, boron concentration, and nitrogen cover pressure must be met.

APPLICABILITY In MODES 1 and 2, and in MODE 3 with RCS pressure > 1600 psig, the

-_accumulator OPERABILITY requirements are based on full power operation. Although cooling requirements decrease as power decreases, the accumulators are still required to provide core cooling as long as elevated RCS pressures and temperatures exist.

This LCO is only applicable at pressures > 1600 psig. At pressures

< 1600 psig, the rate of RCS blowdown is such that the ECCS pumps can provide adequate injection to ensure that peak clad temperature remains below the 10 CFR 50.46 (Ref. 5) limit of 2200 0F.

R.E. Ginna Nuclear Power Plant B 3.5.1-4 Revisiono

Accumulators B 3.5.1 In MODE 3, with RCS pressure

• 1600 psig, and in MODES 4, 5, and 6, the accumulator motor operated isolation valves are closed to isolate the accumulators from the RCS. This allows RCS cooldown and depressurization without discharging the accumulators into the RCS or requiring depressurization of the accumulators.

ACTIONS A.1 If the boron concentration of one accumulator is not within limits, it must be returned to within the limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the ability to maintain subcriticality or minimum boron precipitation time may be reduced. The boron in the accumulators contributes to the assumption that the combined ECCS water in the partially recovered core during the early reflooding phase of a large break LOCA is sufficient to keep that portion of the core subcritical. One accumulator below the minimum boron concentration limit, however, will have no effect on available ECCS water and an insignificant effect on core subcriticality during reflood since the accumulator water volume is very small when compared to RCS and RWST inventory. Boiling of ECCS water in the core during reflood concentrates boron in the saturated liquid that remains in the core. In addition, current analysis techniques demonstrate that the accumulators are not expected to discharge following a large steam line break. Even if they do discharge, their impact is minor and not a design limiting event. Thus, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to return the boron

' -'cncentration toWithin'lirmit-s- -- '

B.1 If one accumulator is inoperable for a reason other than boron concentration, the accumulator must be returned to OPERABLE status tn1 7 In this Condition, the required contents of one accumulator cannot-be -assumed-to-reachthe-core during-a-LOCA.-Due to the severity of the consequences should a LOCA occur in these conditions, thee o hour Completion Time to open the valve, remove power to the valve, or restore the proper water volume or nitrogen cover pressure ensures that prompt action will be taken to return the inoperable accumulator to OPERABLE status. The Completion Time minimizes the potential for exposure of the plant to--a LOCA-under these conditions '

RE. ~

fr/a3Revi ~

iauaP S q--t7S f0e-'- lo-c- te-rV. Aa--a/ e0 m IC)le R.E. Ginna Nuclear Power Plant B 3.5.1-5 Revision(X5

Accumulators B 3.5.1 C.1 and C.2 If the accumulator cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to

< 1600 psig within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

D.1 If both accumulators are inoperable, the plant is in a condition outside the accident analyses; therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Each accumulator motor-operated isolation valve shall be verified to be fully open every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Use of control board indication for valve position is an acceptable verification. This verification ensures that the accumulators are available for injection and ensures timely discovery if a valve should be less than fully open. If an isolation valve is not fully open, the rate of injection to the RCS would be reduced. Although a motor operated valve position should not change with power removed, a closed valve could result In not meeting accident analyses assumptions. This Frequency is considered reasonable in view of other administrative controls that ensure a mispositioned isolation valve is unlikely.

SR 3.5.1.2

-The-borated -water-volume and-nitrogen cover-pressure shall be verified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for each accumulator. This Frequency is sufficient to ensure adequate injection during a LOCA. Because of the static design of the accumulator, a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency usually allows the operator to identify changes before limits are reached. Main control board alarms are also available for these accumulator parameters. The level

--transmitters for the accumulators measure the level over a 14" span for the corresponding 0-100% level indicated on the main control board.

Operating experience has shown this Frequency to be appropriate for early detection and correction of off normal trends.

SR 3.5.1:3-See SR 3.5.1.2 R.E. Ginna Nuclear Power Plant B 3.5.1-6 Revisions

Accumulators B 3.5.1 SR 3.5.1.4 The boron concentration shall be verified to be within required limits for each accumulator every 31 days on a STAGGERED TEST Frequency since the static design of the accumulators limits the ways in which the concentration can be changed. The 31 day STAGGERED TEST Frequency is adequate to identify changes that could occur from mechanisms such as stratification or inleakage.

SR 3.5.1.5 Verification every 31 days that power is removed from each accumulator isolation valve operator when the pressurizer pressure is > 1600 psig ensures that an active failure could not result in the undetected closure of an accumulator motor operated isolation valve. If this were to occur, no accumulators would be available for injection if the LOCA were to occur in the cold leg containing the only OPERABLE accumulator. Since power is removed under administrative control and valve position is verified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the 31 day Frequency will provide adequate assurance that power is removed.

REFERENCES 1. Branch Technical Position (BTP) ICSB-1 8 "Application of the Single Failure Criterion to Manually-Controlled Electrically Operated Valves."

2. Letter from D. M. Crutchfield, NRC, to J. E. Maier, RG&E,

Subject:

"SEP Topics VI-7.F, VII-3, VII-6, and VlIl-2," dated June 24,1981.

3. Letter from R.A. Purple, NRC, to L. D. White, RG&E,

Subject:

"Issuance of Amendment 7 to Provisional Operating License No.

DPR-18," dated May 14, 1975.

4. UFSAR, Section 6.3.

5. 10 CFR 50.46.

6. UFSAR, Section 3.11.

7. 10 CFR 50.49.

8. UFSAR, Section 6.2.

9. UFSAR, Section 15.6.

(0.~~~~~ Rc,-soq8 ev. IJ A4lorw1 /595 R.E. Ginna Nuclear Power Plant B 3.5.1-7 Revisiono