ML17262A274
| ML17262A274 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/12/1990 |
| From: | Andrea Johnson Office of Nuclear Reactor Regulation |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| TAC-77849, NUDOCS 9012260253 | |
| Download: ML17262A274 (7) | |
Text
December 12, 1
Docket No. 50-244 Dr. Robert C. Hecredy Vice President, nuclear Production Rochester Gas 5 Electric Corporation 89 East Avenue Rochester, New York 14649
Dear Dr. Hecredy:
SUBJECT:
GINNA PROPOSED LICENSE AMENDMENT DATED OCTOBER 15, 1990 -
REMOVAL OF TABLE 3.6'1 FROM TECHltICAL SPECIFICATIONS -
REQUEST FOR ADDITIONAL INFORt1ATION (TAC NO. 77849)
The NRC has performed a preliminary review of the above proposed license amendment to change the Ginna Technical Specifications (TS) and remove the Cx containment penetration and isolation table (3.6-1).
The NRC finds that the language of the proposed amendment could be better revised for reasons noted in the enclosure to this letter.
The reasons and comments in the enclosure are a
result of the NRC's process of issuing a Generic Letter on removing component lists from the TS's.
The enclosed comments are consistent with this guidance.
The NRC is requesting your consideration in revising the language accordingly and would appreciate any additional information you may submit to aid in the amended proposal.
S incere ly, k
Original signed by Allen R. Johnson, Project ttanager Project, Directorate I-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/enclosure:
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Dr. Robert C. Mecredy Ginna CC:
Thomas A. Noslak, Senior Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road
- Ontario, New York '4519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Hs.
Donna Ross Division of Policy Analysis 8 Planning New York State Energy Office Agency Building 2 Empire State Plaza
- Albany, New York 12223 Charlie Donaldson, Esq.
Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Nicholas S. Reynolds Minston 5 Strawn 1400 L St. N.lf.
Vashington, DC 20005-3502
OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION GINNA PROPOSED LICENSE AMENDMENT DATED OCTOBER 15 1990 ENCLOSURE 1
Technical Specification (TS) 3.6.3.1 would be better reworded to state:
With one or more containment isolation valves inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and either:
REASON:
2.
The proposed Action Statements for the Limited Condition of Operation (LCO) would reference Table 6.2-13 of the Updated Final Safety Analysis Report (UFSAR) and specify the valves for which these requirements apply.
These requirements are not dependent upon the UFSAR being correct or up-to-date in establishing those valves for which the requirement applies.
This approach is used in the proposed Generic Letter on removing component lists from the TS. If the licensee elects to use the referenced table a
statement noting this fact may be added to the Bases section of TS 3.6.3.1.
TS 4.4.5.1 would be better reworded to state:
Each containment isolation valve shall be demonstrated to be OPERABLE in accordance with the Ginna Station Pump and Valve Test program submitted in accordance with 10 CFR 50.55a.
REASON:
As noted in the REASON under 1. above, the TS would be better reworded in terms of which containment isolation valves without reference to the table in the UFSAR.
The term OPERABLE should be capitalized since it is a defined term.
3.
TS 4.4.6.2 would be better reworded to state:
The response time of each containment isolation valve shall be demonstrated to be within its limit at least once per 18 months.
The response time includes only the valve travel time for those valves which the safety analysis assumptions take credit for a change in valve position in response to a containment isolation signal.
REASON:
As noted in the REASON under 1. above, the TS would be better reworded in terms of which containment isolation valves without reference to the table in the UFSAR.
The term "response time" should not be capitalized since it is not a defined term in the Ginna TS.
Furthermore, this term is defined in Standard Technical Specifications and its scope is broader than as qualified by the Ginna TS, i.e., only valve stroke time.
The valves that are exempted from the response time test requirements should be more explicitly defined to be consistent with the UFSAR table.
The UFSAR table does not specify a valve closure time for some valves that are closed by a containment isolation signal (CIS), and other valves that may be automatically closed (e.g.,
or manually closed, would qualify as "valves that change position" as clarified in the current specification requirements.
Clarified by the existing TS table also includes the "maximum isolation time" for those valves that would be subjected to response time tests.
4.
Some parts of the existing TS table and the UFSAR table on containment isolation valves could be better worded.
For example, it is noted that the main steam and feedwater isolation valves are not considered containment isolation valves.
The meaning of such statements are not clear.
With regard to the General Design Criteria, these valves are defined containment isolation valves.
The implication that they are not considered containment isolation valves would imply that they are not subiect to the TS requirements for these valves.
If this were the intent they should not have been included in the TS table.
If the implication is that they are not subject to the requirements of Appendix J of 10 CFR Part 50, then this should be addressed by NRC approved exemptions to regulatory requirements (10 CFR 50.12).
The proper understanding and application of regulatory requirements would be enhanced by the removal of such statements from the UFSAR and provide more specific statements for any unique consider ation of any particular containment isolation valve.
Similarly a statement in Footnote 20 of the existing TS table related to valves that are exempt from leak testing is also vague in its meaning.
If exemptions from TS or regulatory requirements exist, they are not granted by the existence of a letter from the licensee to NRC.
There are also a number of notes to the UFSAR table of containment isolation valves that require clarification similar to the examples above.
Distribution:,
&Docket File 50-244 HRC PDR Local PDR PDI-3 Reading S.
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Greenman N. Rushbrook A. Johnson R.
Wessman G. Lainas A. Chu C. NcCracken - 8 D1 J.
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11, F22 OGC - 15 B18 E. Jordan - MNBB 3701 ACRS (10) - P-315 J. Johnson, Region I
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