ML17258A813
| ML17258A813 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/20/1981 |
| From: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8102250239 | |
| Download: ML17258A813 (6) | |
Text
REGULATORY.
FORMATION DISTRIBUTION SY EM (RIDS)
ACCESSION NBR: 8102250239 DOC ~ DATE: 81/02/20 NOTARIZED:
YES DOCKET FACIL'50-204 Robert Emmet Ginna Nuclear PlantP Unit ii Rochester G
05000244 AUTH BYNAME AUTHOR AFFILIATION MAIERFJ,E
~
Rochester Gas 8 Electric Corp'ECIP
~ NAME,.
RECIPIENT AFFILIATION CRUTCHFIELD,DE Operating Reactors Branch 5
SUBJECT:
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ROCHESTER GAS
.;~':,,, TOa~
AND ELECTRIC CORPORATION o
89 EAST AVENUE, ROCHESTER, N.Y. 14649 JOHN E.
MAIER VICE PRESIDENT TCI.CPHONC ARCACOOC>IO 546-2700 February 20, 1981 Director of Nuclear Reactor Regulation ATTN:
Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch 45 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Environmental Qualification of Safety-related Electrical Equipment R. E. Ginna Nuclear Power Plant Docket. No. 50-244
Dear Mr. Crutchfield:
This letter is in response to a letter of February ll, 1981 (received on February 13) from Mr. Gus C. Lainas, Assistant Director for Safety Assessment in the Office of Nuclear Reactor Regulation, concerning the environmental qualification of electrical equipment at the R. E. Ginna Nuclear Power Plant.
In that letter, Mr. Lainas requested
- that, RG&E review the deficiencies identified in the "Partial Review, Equipment Evaluation Report by the Office of Nuclear Reactor Regulation"
("Partial Review" ) for the Ginna plant, together with the ramifications of those deficiencies, and provide an overall finding regarding the continued safe operation of the facility.
After reviewing this matter with responsible Company personnel, I can state that there is no aspect of the environmental qualifica-tion of safety-related electrical equipment at the Ginna plant which would interfere with the safe, continued operation of the Ginna plant.
The bases for acceptability of the Ginna equipment were provided in the October 31, 1980 RG&E report concerning "Environmental Qualification of Electrical Equipment,"
and my subsequent. letter of December 15, 1980 addressed to you.
In concluding that our above-referenced submittals provide an adequate basis.for determining that Ginna can continue to operate safely, we took into account. the preliminary list of deficiencies in the Partial Review.
Our evaluation of the latter document would have been aided,
- however, by a statement of the factual basis underlying each identified deficiency.
Many of these deficiencies were specifically addressed in our October 31, 1980 submittal, but Mr. Lainas'ebruary 11, 1981 letter and the Partial Review make no reference to them.
We also note with some
ROCHESTER GAS AND ELECTRIC CORP.
DATE February 20, 1981 To Mr. Dennis M. Crutchfield, Chief SHEET NO.
concern the fact that there are a number of discrepancies between Franklin Research Center's Draft Interim Technical Evaluation
- Report, FRC Project C5257, dated August 20,
- 1980, and the Partial Review.
We have not, as yet, received the final Technical Evaluation Report from the Franklin Research Center and thus are unable to evaluate fully the significance and validity of these discrepancies.
In addition, RG&E is concerned about the novel approach being employed by the staff to ensure margin requirements for containment. temperature, as stated in paragraph 3.3 of the Partial Review.
Comments concerning this approach are provided in the attachment..
RG&E has made every effort to ensure compliance with the June 30, 1982 deadline for achieving environmental qualification for our electrical equipment at the Ginna plant.
However, it must be recognized that delays in our receiving the full Technical Evaluation Report may seriously jeopardize our ability to meet the June 30, 1982 deadline.
RG&E requests a meeting with representatives of the Nuclear Regulatory Commission to discuss these matters.
I would suggest, however, that such a meeting would be productive only after we have received,and reviewed Franklin Research Center's final Technical Evaluation Report together with a detailed description of the bases for the con-clusion reached in Appendices B and C of the Partial Review.
Very truly yours, J
n E. Maier Attachment STATE OF NEW YORK SS.
COUNTY OF MONROE Subscribed and sworn to before me on this 20th day of February, 1981.
GARY L. REISS NOTARY PUBLIC, State of N. Y. Monroe Co.
My Commission Expires March 30, 19.
t'
Attachment In Section 3.3 of the "Partial Review", it is stated that the minimum temperature profile for equipment qualifica-tion purposes should include a margin to account for higher than average temperatures in the upper regions of the containment that, can exist due to stratification especially following a
,postulated MSLB.
Use of the steam saturation temperature corresponding to the total building pressure (partial pressure of steam plus partial pressure of air) versus time until the sprays become effective will provide an acceptable margin for either a
postulated LOCA or MSLB, whichever is controlling as to potential adverse environmental effects on equipment. "
RGSE has serious reservations concerning both the method of imposition of this new requirement, and its technical validity.
a)
The purpose of the October 31, 1980 RG6E submittal was to respond to the September 19, 1980 Commission Order, re-quiring submittal of information to show compliance with the "DOR Guidelines".
The "DOR Guidelines" explicitly state that in Section.4.2.1 that ".
. equipment qualified for a LOCA environment is considered qualified for a MSLB accident environment in plant with automatic spray systems not subject to disabling single component failures."
In Appendix A of FRC Project C5257, it is stated that ".
. the design of the Ginna plant s'atisfies these criteria.
We consider it inappropriate that the staff would modify explicit previous guidance via this "Partial Review".
The requirement to meet a 307'F temperature envelope is obviously beyond the requirements of the "DOR Guidelines".
b)
The apparent reason for this new requirement is to provide margin to account for higher than average temperatures in the upper regions of containment due to potential stratifi-cation.
RG&E does not have any safety-related electrical equipment in this area of containment.
Therefore, the basis for the staff concern does not apply to the Ginna plant.
c)
Since it is not conceivable that all the air in containment would be expelled after a LOCA or MSLB, it does not appear reasonable to determine margin in this manner.
The criteria of IEEE-323-1974, together with the margin inherent in the analyses arriving at containment conditions, serve as ample assurance of the determination of conservative environmental conditions.
It is requested that. the above concerns be addressed by the staff in making a determination of the required environ-mental conditions for the Ginna plant.