ML041140323
| 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 Vice President Always at Your Service April 15, 2004 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 w ww.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:
Implementation Document:
UFSAR Affected Sections:
Reload for Cycle 31 None 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 Description of 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.
Evaluation Summary:
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:
Original Commitment:
Revised Commitment:
Justification Summary:
RG&E 120-Day Response to Inspection Report 50-244/
89-81 Safety System Functional Inspection on the RHR System, dated September 11, 1990 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.
The commitment will be eliminated.
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 Evaluation No: 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 Original Commitment:
Revised Commitment:
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.
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: "Unannounced drug and alcohol tests imposed in a statistically random and unpredictable manner so that all persons in the population subject to testing have an equal probability of being selected and tested. The tests must be administered so that a person completing a test is immediately eligible for another unannounced test. As a minimum, tests must be administered on a nominal weekly frequency and at various times during the day. Random testing must be conducted at an annual rate equal to at least 50 percent 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 more fully describe the random testing selection process for licensees that may be administering the process incorrectly. These practices compromise the randomness of the testing process. The NRC has clarified the random testing requirements in response to cases of random testing practices that involve simply returning the names of the individuals who are selectedfor testing but not on site to the 'pool" and testing those who are available. This practice subjects those individuals who are routinely on site to random testing at a higherfrequency than those who are not routinely on site. This issue was addressed clearly in responses to comments on the original proposed rule (see NUREG-1354) and in NUREG-1385 which responds to implementation questions. The practice of returning employees' names to the testing pool without testing is not consistent with the requirement that all persons in the testing pool have an equalprobability of being selected and actually being tested. The NRC declines to distinguish between licensee employees and contractors with regard to this aspect of random testing. The NRC intends that all personnel shall have an equal likelihood of being randomly selected for 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 administer random tests during off shifts. In many cases, there will be an "overlap" at the beginning or end of a shift when the selected employee and the collector are both availablefor the test.
If a worker is not on site at the time of selection, the worker is to be tested, without prior notifi cation, when he or she returns to the site, or at the earliest convenient opportunity.
To make thisflexibility clear, the phrase "at the earliest reasonable and practical opportunity" has been added to § 26.24(a)(2). "Reasonable andpractical"mean that a licensee's notification and collection procedures should use common sense and achieve the desired purpose in an efficient manner. Developing more specific regulatory language to cover all possible 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:
Original Commitment:
Revised Commitment:
Justification Summary:
NRC Review of Plant-Specific Applicability of Westinghouse Topical Report WCAP-14535 for the R. E.
Ginna Nuclear Power Plant, dated August 7, 1997 The reactor coolant pump flywheel inspection has been revised to every 10 years.
The reactor coolant pump flywheel inspection has been revised to every 20 years.
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.