ML17258A312
| ML17258A312 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/07/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| TASK-05-11.A, TASK-5-11.A, TASK-RR LSO5-81-11-007, LSO5-81-11-7, NUDOCS 8111130649 | |
| Download: ML17258A312 (7) | |
Text
November 7, 1981 Docket No. 50-244 LSO5 81 11-007 Mr. John E. Maier, Vice President Electric and Steam Production Rochester Gas 8 Electric Corporation 89 East Avenue Rochester, New York 14649
Dear Mr. Maier:
SUBJECT:
SEP TOPIC V-ll.A, ISOLATION OF HIGH AND LOll PRESSURE
- SYSTEMS, REVISED SAFETY EVALUATIOI'l REPORT - R. E.
GINNA NUCLEAR POllER PLANT The enclosed staff safety evaluation has been revised to reflect a change in NRC procedures for dealing with open issues in the SEP.
Our safety evaluation still identifies the charging pump discharge valves as an area of concern.
However, these concerns are being pursued under Topic VI-4.
Accordingly,'he enclosed report is the basis for the staff's conclusion that Topic V-ll.A has been completed satisfactorily.
Sincerely,
/
Dewis M. Crutchfield, Chief Operating. Reactors Branch No.
5 I
Division of Licensing Cch~
Enclosure:
Safety Evaluation Report (Revised) cc w/enclosure:
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Mr. John E. Maier CC Harry H. Voigt, Esquire
- LeBoeuf, Lamb, Leiby and MacRae 1333 New Hampshire Avenue, N.
W.
Suite 1100 Washington, D. C.
20036 Mr. Michael Slade 12 Trailwood Circle Rochester, New York 14618 Ezra Bialik Assistant Attorney General Environmental Pr otection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Jeffrey Cohen New York State Energy Office Swan Street Building Core 1, Second Floor Empire State Plaza
- Albany, New York 12223 Director, Bureau of Nuclear Operations State of New York Energy Office Agency Building 2 Empire State Plaza
- Albany, New York 12223 Rochester Public Library 115 South Avenue Rochester, New York 14604 Supervisor of the Town of Ontario 107 Ridge Road West
- Ontario, New York 14519 Resident Inspector R. E. Ginna Plant c/o U. S.
NRC 1503 Lake Road Ontario, New'ork 14519 Mr. Thomas B. Cochran Natural Resources Defense Council, Inc.
1725 I Street, N.
W.
Suite 600 Washington, D. C.
20006
~ L U-S. Environmental Protection Agency Region II Office ATTN:
Regional Radiation Representative 26 Federal Plaza New York, New York 10007 Herbert Grossman, Esq.,
Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Coranission Washington, D. C.
20555 Dr. Richard F. Cole Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr.
Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Comnission Washington, D. C.
20555
SYSTEMATIC EVALUATION PROGRAM TOPIC V-'ll.
TOPIC:
V-ll.A -
RE UIREMENTS FOR ISOLATION OF HIGH AND LOll PRESSURE SYSTEMS INTRODUCTION Several systems that have a relatively low design pressure are connected to the reactor coolant pressure boundary.
The valves that form the interface between the high and low pressure systems must have sufficient redundancy and interlocks to assure that the low pressure systems are not subjected to coolant pressures that exceed design limits.
The problem is complicated since under certain operating modes (e.g.,
shutdown cooling and ECCS injection) these valves must open to assure adequate reactor safety.
II.
REVIEW CRITERIA The review criteria are presented in Section 2 of EGKG Report 1285.
III. RELATED SAFETY TOPICS AND INTERFACES The scope of review for this topic was limited to avoid duplication of effort since some aspects of the review were performed under related topics.
The related topics and the subject matter are identified below.
Each of the related topic reports contain the criteria and review guidance for its subject matter.
V-3 V-10.8 VI-4 XV-16 Overpressurization Protection RHR Reliability Containment Isolation Radiological Consequences of Small LOCA Outside of Containment Topic V-11.8 is dependent on the present topic information for completion.
IV.
REVIEW GUIDELINES The review guidelines are presented in Section 7.3 of the Standard Review Plan.
V.
EVALUATION As noted in EG&G Report
- 1285, Ginna has three systems with a lower design pressure rating than the RCS, that are directly connected to the RCS.
The RHR, SIS, and CVCS system do not meet current licensing requirements for isolation of high and low pressure systems as specified below.
(2)
(3)
The RHR system is not in compliance with the current licensing requirements of BTP RSB 5-1 since none of the isolation valves will automatically close if RCS pressure exceeds RHR design pressure.
Also, the outboard isolation valves have no inter-locks to prevent RHR overpressurization, and the inboard valve interlocks are neither diverse nor independent.
The SIS is not in compliance with the current licensing require-ments of SRP 6.3 since the t10Vs in the low pressure injection lines have no interlocks to prevent opening and the single check valve in each line is not tested.
The CVCS is not in compliance with current licensing require-ments for isolation of high and low pressure systems contained in BTP EICSB-3 since the suction and discharge line solenoid-operated valves have no interlocks to prevent system overpres-surization, and the discharge line check valves have no position indication available in the control room.
Because of the severe consequences of a LOCA outside of containment and the lack of assurance that these isolation valves could be closed against significant flow under the resulting environmental conditions, the staff proposed that the RHR isolation valves and the CYCS ~uction valves should be modified to satisfy the functional requirements of BTP RSB 5-1 and BTP EICSB-3.
lie also proposed installation of position indication on the charging pump discharge valves.
The licensee responded to our proposals in a letter dated June 23, 1981 (attached).
In summary, the.licensee has argued that:
Additional interlocks in the RHR system are not reouired because the valves can not open against the differential pressure across the valves.
Loss of the differential pressure is a leakage constituting a single failure.
, (2)
(3)
Isolation of the let down system and the failure of the relief valve (which is not tested) has been shown to be acceptable based on SEP Topic XY-16.
The probability of failure of a charging pump and the two check valves in the discharge path presents an acceptable small risk without further design'changes.
However, the staff notes that there is no way, at this time, to provide adequate assurance that these valves are seating.
The basis for not requiring interlocks in the low pressure injection system is that, since the contractor's report was published, a
check valve test program has been established, and thus, the system now satisfies the single failure criterion.
The basis for not requiring interlocks on the CVCS discharge valves is that the check valves in series with the positive dis-placement pumps satisfy the single failure criterion as long as check position is known (or functionability demonstrated) and the pump capacity is verified periodically.
Consideration of gross failure of a positive displacement pump at the high pressure-low pressure interface is not within the scope of this topic since it is an extremely improbable event.
As previously noted, in our system safety evaluation of SEP Topic V-10. B, it is not necessary to close the RHR valves automatically on increasing reactor coolant system pressure during startup because of the overpressurization protection system.
(See also Topic V-3).
SEP Topic XV-16 results of a letdown line break outside containment are the basis for not requiring modifications in the letdown sub-system because the radiological consequences satisfy regulatory limits of 10 CFR Part 100.
VI.
CONCLUSIONS The charging pump dischagge valves will be evaluated further under SEP Topic VI-4.
The staff finds that Ginna satisfies the review criteria for Topic V-ll.A. Therefore, we conclude that, for Ginna, Topic V-ll.A has been completed satisfactorily.
1