ML041140323

R. E. Ginna, Report of Facility Changes, Tests, and Experiments Conducted Without Prior Commission Approval

ML041140323
Person / Time
Site:	Ginna
Issue date:	04/15/2004
From:	Widay J Rochester Gas & Electric Corp
To:	Clark R Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML041140323 (11)

Text

Joseph A. Widay R O Always at Your Service April 15, 2004 Vice President and Plant Manager Mr. Robert L. Clark Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

Report of Facility Changes, Tests, and Experiments Conducted Without Prior Commission Approval R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Clark:

The subject report is hereby submitted as required by 10 CFR 50.59(d)(2). The enclosed report contains descriptions and summaries of the 10 CFR 50.59 evaluations conducted in support of proposed changes to the facility and procedures described in the UFSAR and special tests, from July 2002 through December 2003, performed under the provisions of 10 CFR 50.59. Also included in this report is a summary of commitment changes performed in accordance with NEI 99-04, Guidelines for Managing NRC Commitment Changes, as endorsed by NRC Regulatory Issue Summary 2000-17.

Very truly yours, seph A. Widay Attachment xc: Mr. Robert Clark (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 An equal opportunity employer 89 East Avenue I Rochester, NY 14649 tel (585) 546-2700 www.rge.coqm /°° sA a n An Energy East Company

Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector

REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS CONDUCTED WITHOUT PRIOR NRC APPROVAL FOR JULY 2002 THROUGH DECEMBER 2003 UNDER THE PROVISIONS OF 10 CFR 50.59

50.59 EVALUATION

SUMMARY

REPORT 50.59 Evaluation No: 2003-0001 Title of Change: Reload for Cycle 31 Implementation Document: None UFSAR Affected Sections: 4.2.4.2.5, 4.4.2.2.3, 4.4.2.2.4, Table 6.4-1, Table 6.4-2 System: Reactor Coolant System Descriptionof Change:

This 50.59 Evaluation addressed the change in the source terms for Cycle 31 and the resultant minor change in calculated dose following a design basis accident, and the revision of the Westinghouse fuel performance code to PAD 4.0. All other changes associated with the Cycle 31 Reload Report are addressed under 50.59 Screen 2003-0339.

EvaluationSummary:

Based on a dose analysis evaluation of the new source terms it was determined that all the calculated doses are less than the guidelines set forth in the Standard Review Plan. Furthermore, all increases in doses (calculated vs. current) are less than 10% of the difference between the current value and the regulatory limits set forth in 10 CFR 100 or GDC 19.

The revision of the Westinghouse fuel performance code to PAD 4.0 has been previously approved by the NRC and it is appropriate for the intended application. It has been used in accordance with the terms, conditions, and applications set forth in the NRC Safety Evaluation.

Based on the evaluation performed, it has been concluded that this change may be implemented without NRC approval, per the requirements of 10 CFR 50.59.

REPORT OF COMMITMENT CHANGES FOR JULY 2002 THROUGH DECEMBER 2003 PERFORMED IN ACCORDANCE WITH NEI 99-04

COMMITMENT CHANGE EVALUATION

SUMMARY

REPORT Commitment Change Evaluation No: 2003-001 Source Document: RG&E 120-Day Response to Inspection Report 50-244/

89-81 Safety System Functional Inspection on the RHR System, dated September 11, 1990 OriginalCommitment: A copy of the "information letter" associated with completed plant modifications will be placed in all Training System Descriptions that are effected by the modification.

Revised Commitment: The commitment will be eliminated.

JustificationSummary: The Training System Descriptions are provided as a training tool only and are not to be used to conduct plant operations. A new electronic modification database has been developed which includes notification letters of plant modifications along with copies of the plant change document.

COMMITMENT CHANGE EVALUATION

SUMMARY

REPORT Commitment Change EvaluationNo: 2003-003 Source Document: RG&E Reply to Notice of Violation (NRC Inspection Report No. 50-244/94-28), dated February 13, 1995 RG&E Fitness for Duty Program Additional Corrective Actions, dated August 14, 1995 OriginalCommitment: If a backshift worker is selected for a random drug and alcohol test, the test will be conducted before the worker's shift ends. Conducting the test before the shift ends will avoid predictability in the time of testing. However, if the worker is not available, the worker will be tested during the next scheduled work shift.

Revised Commitment: If the unavailable employee is not normally assigned to work the day-shift, an attempt will be made to conduct the test at the earliest reasonable and practical opportunity when both the donor and collectors are available to collect specimens for testing. Conducting the test within this time frame will avoid predictability in the time of testing.

Administrative tracking will ensure that a person who is not on site and is selected for a random drug and alcohol test is properly tested within a reasonable time frame.

One Saturday, Sunday, or holiday each month will be selected to conduct random drug and alcohol testing.

However, during outage periods, Saturday and Sunday testing may occur through the normal random selection process.

Justification Summary: The original commitment was made as a corrective action for a FFD program violation in that drug and alcohol testing was not being performed in an unpredictable manner for individuals who worked back shifts, weekends, and holidays. The Federal Regulations (10 CFR 26 Fitness for Duty Programs) does not provide any specific direction with regards to followup testing of individuals who are not available at the time they are randomly selected for FFD testing.

The current specific requirements are: "Unannounceddrug and alcohol tests imposed in a statistically random and unpredictablemannerso that allpersons in thepopulation subject to testing have an equalprobabilityof being selected and tested. The tests must be administeredso that a person completing a test is immediately eligiblefor anotherunannounced test. As a minimum, tests must be administeredon a nominal weekly frequency andat various times duringthe day. Random testing must be conducted at an annualrate equal to at least 50percent of the workforce."

The FFD rule (10 CFR 26) is in the process of being amended, and in particular, this area of concern is being clarified. The following statement is from SECY-00-0159 from William D. Travers, NRC Executive Director for Operations, to the NRC Commissioners: "The NRC is clarifying the random testing requirements to morefully describe the random testingselection processfor licensees that may be administeringthe process incorrectly. These practicescompromise the randomnessof the testing process. The NRC has clarifiedthe random testing requirements in response to cases ofrandom testing practicesthat involve simply returningthe names of the individuals who areselectedfor testing but not on site to the 'pool" and testing those who are available. This practicesubjects those individuals who are routinely on site to random testingat a higherfrequency than those who are not routinely on site. This issue was addressedclearly in responses to comments on the originalproposed rule (see NUREG-1354) and in NUREG-1385 which responds to implementation questions. The practiceof returning employees' names to the testingpool without testing is not consistentwith the requirementthat all persons in the testingpool have an equalprobabilityof being selected and actually being tested. The NRC declines to distinguish between licensee employees and contractorswith regardto this aspect of random testing. The NRC intends that all personnelshall have an equallikelihood of being randomly selectedfor testing and of being tested when selected. To assure this, testing periods must include all shifts. Also, it is not the NRC's intent that licensees' specimen collection facilities be attended 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day or that collection personnel be routinely called in to administerrandom tests duringoff shifts. In many cases, there will be an "overlap" at the beginningor end of a shift when the selected employee and the collector are both availableforthe test.

If a worker is not on site at the time ofselection, the worker is to be tested, without priornotification, when he or she returnsto the site, or at the earliestconvenient opportunity.

To make thisflexibility clear, the phrase "at the earliest reasonableandpracticalopportunity"has been added to § 26.24(a)(2). "Reasonable andpractical"meanthat a licensee's notificationand collectionproceduresshould use common sense and achieve the desiredpurpose in an efficient manner. Developing more specific regulatory language to cover allpossible situations would be difficult. "

The changes that are being made to the FFD testing program are in compliance with the current regulatory requirements and with the proposed changes to the requirements.

COMMITMENT CHANGE EVALUATION

SUMMARY

REPORT Commitment Change Evaluation No: 2003-004 Source Document: NRC Review of Plant-Specific Applicability of Westinghouse Topical Report WCAP-14535 for the R. E.

Ginna Nuclear Power Plant, dated August 7, 1997 OriginalCommitment: The reactor coolant pump flywheel inspection has been revised to every 10 years.

Revised Commitment: The reactor coolant pump flywheel inspection has been revised to every 20 years.

JustificationSummary: On August 24, 2001, the Westinghouse Owners Group (WOG) submitted Topical Report (TR) WCAP-15666, "Extension of Reactor Coolant Pump Motor Flywheel Examination", dated July 2001 for NRC staff review.

Further clarifying information was submitted on April 23, 2002, and November 15, 2002. The TR states that the currently approved 10-year inspection interval for flywheels does not coincide with the reactor coolant pump (RCP) refurbishment schedules which typically occur at 10 to 15-year intervals at all domestic Westinghouse plants, but could extend to a maximum of 20 years. The TR provides the technical justification to extend the RCP motor flywheel examination frequency for all domestic Westinghouse plants from the currently approved 10-year inspection interval, to an interval not to exceed 20 years to enable domestic Westinghouse plants to conduct their flywheel examination during a planned RCP refurbishment.

The technical justification in the TR assumes a leak-before-break (LBB) in the reactor coolant system piping to limit RCP overspeed to 1500 revolutions per minute (rpm) in the deterministic evaluation, and a risk assessment that includes all credible flywheel speeds.

The NRC concluded, in a SER transmitted on May 5, 2003, that the conservative assumptions in the TR provide a bounding estimate of the change in risk associated with the increase of the examination interval from 10 to 20 years.

The bounding estimate is below the very small change in LERF guidelines in RG 1.174 and that the increase in risk is small and is consistent with the Commission's Safety Goal Policy Statement. The TR was also determined to addresses the other key principles of risk-informed licensing actions. No changes to the evaluation of design basis accidents and safety analysis margins are being made.

Nondestructive examinations will still be conducted, but on a less frequent basis not to exceed 20 years. The NRC staff stated that the requested change was well-defined, consistent with defense-in-depth philosophy, contained adequate margin of safety, and incorporated a performance measurement strategy to monitor the change. The staff also found that the risk evaluation was consistent with the risk-informed methodology and guidelines described in RG 1.174 and that the potential change in risk caused by the extension of the inspection interval from 10 to 20 years is small and acceptable. The staff found that the regulatory positions in RG 1.14 concerning the three critical speeds are satisfied, and that the evaluation indicating that critical crack sizes are not expected to be attained during a 20-year inspection interval is reasonable and acceptable. The potential for failure of the RCP flywheel is, and will continue to be, negligible during normal and accident conditions.