ML17250B040
| ML17250B040 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/27/1989 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| GL-89-04, GL-89-4, NUDOCS 8911080386 | |
| Download: ML17250B040 (4) | |
Text
gc CELE~TED KSTRIBUTION DEMONSTRATlON
'SYSTEM REGULATOR INFORMATION DISTRIBUTION STEM (RIDS)
ACCESSION NBR:8911080386 DOC.DATE: 89/10/27 NOTARIZED: NO DOCKET FACIL:50-2/4 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas 6 Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.
Project Directorate I-3
SUBJECT:
Submits util position on Generic Ltr 89-04, "Inservice Pump S Valve Testing Program."
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR t
ENCL I SIZE:
.5" TITLE: OR Submittal: Inservice Inspection/Testing/Relief from ASME Code NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
05000244 S
RECIPIENT ID CODE/NAME PDl-3 LA JOHNSON,A INTERNAL: AEOD/DSP/TPAB NRR/DEST/MTB 9H O~CLFMB F
Ol EXTERNAL: EG&G BROWN,B LPDR NSIC COPIES LTTR ENCL 1
0 1
1 RECIPIENT ID CODE/NAME PD1-3 PD NRR/DEST/MEB 9H NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB EG6(G ROCKHOLDPH NRC PDR COPIES LTTR ENCL 5
5 1
1 1
1 1
0 1
1 1
1 1
1 h
h TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL 17
~ 1
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LACED OWNS
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r ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649.0001 October 27, 1989 TELEPHONE ARE* CODE T16 546-2700 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Allen R. Johnson Project Directorate I-3 Washington, D.C.
20555
Subject:
Inservice Pump and Valve Testing (IST) Program Generic Letter 89-04 R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr-. Johnson:
In RG&E's May 23, 1989 submittal of the Ginna Station 1990-1999 Inservice Pump and Valve Testing (IST) Program, we stated that a clarification of our position on Generic Letter 89-04, Attachment
', Position 4, would be provided.
This relates to the individual testing of series check valves.
At Ginna Station, the two safety injection lines to the RCS.hot legs include two check valves in
- series, and a locked closed MOV.
Safety injection to the RCS hot, legs is no longer used in the Ginna Station UFSAR Chapter 15 accident analyses.
The high to low pressure system (Event V) isolation function is satisfied by the locked closed MOV, plus either of the two check valves.
- Thus, RG&E uses the two check valves in series as one
- boundary, and.
there is no need to individually test each of these series check valves.
In an October 16, 1989 telecon among RG&E,
- NRC, and EG&G personnel, it was requested that RG&E commit to specific actions, if the series hot leg check valves failed their periodic leak test.
In accordance with Technical Specification 4.3.3.3, it would be required that both of the check valves be inspected to establish the cause of the leakage.
Although it is anticipated that in such cases both of the series check valves would be refurbished, RG&E reserves the right to remove the internals of one of the check
- valves, and rely on one check valve and the locked closed MOV as the high to low pressure system boundary.
This could only be done pending NRC approval of a license amendment to paragraph 4.3.3.3 of the Ginna Technical Specifications.
Another issue discussed during the October 16, 1989 telecon concerned Relief Request VR-21.
The NRC requested that more detail be provided relative to the basis for not performing check, valve (3992 and 3993) testing at cold shutdowns resulting.from reactor trips.
RG&E explained that in order to test these valves, field instrumentation and personnel observation is required.
Under plant trip conditions, RG&E personnel could not be dispatched to perform proper measurements in an appropriate time frame.
This relief request is thus considered valid as written.
S911080386 89i027 PDR ADOCK 05000244 P
PNU
"~
l
, Finally, RG&E will be proposing a revised relief request (VR-
- 8) for check valves 842A,B and 867A,B (accumulator discharge).
The detailed relief request is being prepared, and willbe mailed under separate cover.
A synopsis of the relief request is provided, here for information.
Based on the results of implementation of the disassembly requirements for these check valves during the 1989 Refueling
- Outage, RG&E will propose to extend the sample disassembly and inspection interval.
The inspection revealed no observable evidence of excessive wear or deterioration, following 15 years of operation for the 842A/B check valves and 20 years of operation for the 867A/B check valves since the previous refurbishment of these valves.
The records of these inspections are available at Ginna Station.
The actual disassembly process is extremely burdensome, however.
Because of the location of these valves relative to the reactor coolant system, it would be required to defuel the reactor, or use freeze seals, in order to perform this inspection.
The 1989.
actual inspection and refurbishment resulted in a
personnel radiation exposure in excess of 3 person-rem.
A defueling would require an additional 2.2 person-rem.
Therefore, RG&E intends to keep the family of valves as 2
groups of
. 2 and extend the disassembly interval to every 10 years (i.e., all 4 valves during each ten year reactor vessel examination, which requires defueling).
Partial flow testing would continue on an annual basis.
This testing/disassembly methodology and interval is consistent with the techniques which have maintained.
the valves functionally acceptable, with no observable degradation, for the past 20 years.
Very truly yours, Robert C. Mecredy General Manager Nuclear Production GJWN064 Attachments xc:
U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector