ML17262A610
| ML17262A610 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/26/1991 |
| From: | Andrea Johnson Office of Nuclear Reactor Regulation |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| GL-91-08, TAC-77849, NUDOCS 9110030287 | |
| Download: ML17262A610 (7) | |
Text
September 26, 1991 Docket No. 50-244 Dr. Robert C. Mecredy, Vice President Ginna Nuclear Production Rochester Gas 5 Electric Corporation 89 East Avenue Rochester, New York 14649
Dear Dr. Mecredy:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) - APPLICATION FOR AMENDMENT TO OPERATING LICENSE DPR REMOVAL OF CONTAINMENT ISOLATION VALVE LIST (TABLE 3.6-1)
FROM THE GINNA TECHNICAL SPECIFICATIONS (TAC NO. 77849)
REFERENCE:
GENERIC LETTER 91-08, REMOVAL OF COMPONENT LISTS FROM TECHNICAL SPECIFICATIONS, DATED MAY 1, 1991.
Rochester Gas 8 Electric Corporation's (RGIIEs) Application for Amendment to Operating License DPR-18, dated October 15,
- 1990, and subsequent response to the NRC Request for Additional Information, dated March 8, 1991, has been reviewed by the NRC staff.
The requested license amendment to remove the containment isolation valve list (Table 3.6-1) from the Ginna Technical Specificatons (TS), within the guidance of the above Reference, has raised an issue of accuracy and completeness in transferral of data to Table 6.2-13 (associated Figures 6.2-14 through 6.2-75) of RG&Es Updated Final Safety Analysis Report (UFSAR).
This RAI (Enclosure) identifies futher NRC staff comments on the proposed amendment request which will require resolution prior to issuance.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P. L.96-511.
Sincerely, 0
~siOOSOam iaama PDR ADOCl( 05000244 )I P
PDR Ordinal sianed by AVlen R. Johnson, Project Manager Project Directorate I-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation cc w/enclosure:
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Dr. Robert C. Necredy Ginna CC:
Thomas A. Moslak, Senior'esident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road
- Ontario, New Yor k 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Ms.
Donna Ross Division of Policy Analysis 5 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 Winston 5 Strawn 1400 L St.
N.W.
Washington, DC 20005-3502
ENCLOSURE COMMENTS ON REMOVAL OF CONTAINMENT ISOLATION VALVE.LIST (TABLE 3.6-1)
FROM THE GINNA TECHNICAL SPECIFICATIONS (REFERENCING UFSAR TABLE 6.2-13 IN THE TECHNICAL SPECIFICATION BASIS)
Comments with regard to the Ginna Updated Final Safety Analysis Report (UFSAR)
Table 6.2-13 and Figures 6.2-14 through 6.2-75 are as follows:
The proposal to remove the list of containment isolation valves from the Ginna Technical Specifications (TS) included a modification of the Bases of TS 3.6.3 that noted that containment isolation valves and boundaries are listed in UFSAR Table 6.2-13.
It is also noted that isolation boundaries can include isolation valves, closed
The NRC staff has the following comments on the accuracy and completeness of the data included in Table 6.2-13 and the associated Figures 6.2-14 through 6.2-75.
1.
Table 6.2-13 identifies many valves, but does not distinguish between which valves are containment isolation valves and those that are not, other than by use of notes.
For example some notes indicate that some valves are not considered containment isolation valves.
The use of the term "considered" does not clarify what the classification of the valve is and should be used to describe valves.
If there is any clarification to be noted because valves are listed which are not classified as containment isolation valves, it should be provided for accuracy.
Additional comments on specific notes are provided in paragraphs below.
With respect to boundaries, the table, in general, is not clear on what constitutes a boundary particularly in cases where only one valve is classified as a containment isolation valve for a given penetration.
A containment isolation boundary may be a blind flange or a
closed system.
- However, the table does not make clear the boundaries of the second containment isolation barrier.
The figures note that some instruments constitute a containment isolation boundary.
Therefore, where a system or component is considered a second barrier, in addition to a
single containment isolation valve, it should be so identified.
Also, the location of that component would be identified under Table 6.2-13 column heading "Position Relative to Containment."
Footnote 4
to the table would be app1 icable where thi s boundary i s a
closed system outside containment, however, this note presently does not identify that closed system.
Footnote 4 is poor ly worded since it is appended to the line entry that identifies the containment isolation valve.
This information is important since the TS requires an operable
- boundary, or second isolation valve in the case that one containment isolation valve is inoperable, and the TS Bases references this table for such information.
2.
In a number of cases, more than one penetration is listed under a single penetration number in Table 6.2-13.
This is contrary to the general practice of identifying each penetration with its associated valves or boundary as a
separate entry.
Each penetration should be listed and identified individually.
This includes the following:
124a (Separate penetrations for supply and return.)
124b (Separate penetrations for air sample to "C" fan and common return.)
201 Top and 201 Bottom 202 (Separate penetrations for H2 "main" and "pilot" burners.)
203b (Separate penetrations for air sample to "B" fan and common return.)
209 Top and 209 Bottom 306c (Appears to be three penetrations, but containment boundary is not shown on Figure 6.2-61.)
332c (Three penetrations shown for the same penetration number.)
Where footnote 9 is used in Table 6.2-13, the purpose for the automatic closure of the associated valve should be clarified.
For valve 427 on the letdown line, its closure on a
containment isolation signal (CIS) is important if one of the orifice valves fails to close since it pr ecludes the loss of reactor coolant to the pressurizer relief tank when reactor pressure is greater than the relief setting of relief valve 203 that is isolated by the closure of valve 371 on a CIS.
For penetrations
- 123, 205,
- 206a, 207a, and
- 210, the closure of a
second valve on a
CIS provides a degree of redundancy for containment isolation.
For penetration 143 in the Table 6.2-13, valve 1722 should be added since it has been marked as a "CIV" (containment isolation valve) on Figure 6.2-43.
Note 17 in the table should be updated to reference correspondence which granted relief from Appendix J
leak testing, not just correspondence requesting such.
Figure 6.2-14 includes a note that "CIV" is used to designate containment isolation valves on this and subsequent figures.
This notation was also used on some other figures to designate an isolation boundary, but has been subsequently modified by deleting the letter "V." It is recommended that you identify "CI," or preferably "CIB," as notation for a
containment isolation boundary or barrier by the use of a note on this figure.
Also on Figure 6.2-14, Figure 6.2-16, and Figure 6.2-18, an arrow is shown for the check valves to designate flow direction.
On other figures it appears that marked changes for check valves (Figures 6.2-37 and 6.2-38) were for the purpose to clarify flow direction (it is presumed that the intent is that the flow direction is from the upper side marking) yet no convention for such is provided.
It would appear to be clearer to use the arrow symbol for consistency, since the presumed intent of marking does not work for a check valve shown in a vertical line such as in Figure 6.2-15.
I On Figure 6.2-19, valve 304B was added and on Figure 6.2-23, Valve 304A was added.
One of these figures could now be deleted since they are redundant.
Also both figures identify the penetration as P-110 rather than by its full designation "P-110a (top)" as identified in Table 6.2-13.
On Figure 6.2-33, the containment penetrations should be labeled as
9.
10.
12.
"P-124a (Supply)" and "P-124a (Return)" to identify each.
On Figure 6.2-34, the containment penetrations should be labeled as "P-124b (Top) "and" P-'124b (Bottom)" or other appropriate means to distinguish between the two penetrations that are currently designated as "P-124b."
On Figures 6.2-40 and 6.2-44, the location of containment relative to P-131 and P-209 (Top) is the reverse of what is shown (Figures 6.2-33 and 6.2-44 have the proper configuration shown).
The "CIV" designation is improperly used for the reactor compartment cooler 1B on Figure 6.2-44.
On Figure 6.2-46, the two penetrations should be identified to distinguish them as separate penetrations and with the same P-202 designation used in the title block and the table.
13.
14.
On Figure 6.2-72, the pressure transmitters should not be designated as "CIVs" but rather as an isolation boundary.
All check valves on Figure 6.2-75 (P-403 5 P-404) should be designated and shown as "CIVs."
Likewise, Footnote 11 should be deleted for these valves as shown in Table 6.2-13.
15.
16.
Where instruments are connected to a line upstream of the containment isolation valve, the instrument and its root valve should be listed in Table 6.2-13, simi lar to the other listing of instruments and root valves.
This includes valves
- 885A, 885B and the associated PTs (which should be numbered) as shown on Figure 6.2-15.
This is true also of valve 2856 and PI-933A and an unidentified instrument on Figure 6.2-18, valve 2859 and PI-933B on Figure 6.2-22, valve 4588 and PI-2141 on Figure 6.2-44, valve 4590 and PI 2232 on Figure 6.2-45, PI-(unidentified number) on Figure 6.2-49, valve 8052 and PI-(unidentified number) on Figure 6.2-56, valves and PIs and FIs shown on Figure 6.2-63.
Test, vent, and drain valves that are used for Appendix J local leak rate testing need not be listed Table 6.2-13.
- However, valves provided for other purposes including testing should be listed as locked closed valves and identified as containment isol ation valves.
Therefore, it i s suggested to identify those valves which are test, vent, or drain valves used for local leak rate testing with some notation on the figures, or by listing them in Table 6.2-13 with an appropriate footnote.
By providing this identification it will be clear as to which of the remaining valves are "CIVs" and subject to the Appendix J requirements.
Clarification of the function of the following valves on the following figures should be noted:
18.
F iciure 6.2-18 6.2-22 6.2-30 6.2-56 6.2-322c On Figure 6.2-24, valve 959 should Valve 864A, 2825, 2829
- 8648, 2826, 2830 497, 498, 567, 576 8049
- 7448, 7452 0
- 7456, 8437,
- 8438, 8439 be noted as a CIV since it ensures that
19.
20 21.
22.
23.
the Residual Heat Removal (RHR) system is a
closed system on a
CIS and should be listed in Table 6.2-13.
Also, the valves to the safety injection system inside containment should be shown and listed in the table as CIVs as well as the check valve and parallel valve shown connecting to the l'etdown line.
If an exception is taken to this position, it should be justified.
Valves 9704A and 9704B on Figure 6.2-26 should be shown as CIVs and listed in Table 6.2-13.
Footnote 14 states that valve 745 for penetration 124a (return) is to be manually closed until it is modified to receive an automatic closure signal.
What is the status of this change and why has it not been implemented?
Please provide your 50.59 evaluation and the basis for the change in the classification for valves 851A and 851B to delete the CIV notation from these valves.
Also on Figure 6.2-42, valves 1813A and 1813B should be shown as CIVs. If an exception is taken to this position, it should be justified.
Valve 1722 should be listed in Table 6.2-13 and is presumed to be a locked closed valve.
If not, a justification should be provided.
Valve 8074 on Figure 6.2-49 should be shown as a
CIV and listed in the Table 6.2-13 as a locked closed valve.
- 24. Valve 5749 on Figure 6.2-52 should be shown as a
CIV and listed in the Table 6.2-13 as a locked closed valve.
- 25. Valve 5754 on Figure 6.2-54 should be shown as a
CIV and listed in the Table 6.2-13 as a locked closed valve.
- 26. Valve 8050 on Figure 6.2-56 should be shown as a
CIV and listed in the Table 6.2-13 as a locked closed valve.
27.
28.
The containment penetration should be shown on Figure 6.2-61.
If three penetrations, Top, Hiddle, and Bottom,.exist, they should be identified and listed separately Table 6.2-13.
The drain valves shown on Figure 6.2-63 should be shown as CIVs and listed in Table 6.2-13 as locked closed valves.
29.
30.
Valve 5752 on Figure 6.2-69 should be shown as a
CIV and listed in the Table 6.2-13 as a locked closed valve.
Valves
- 3504A, 3505A,
- 3516, 3517,
- 3520, 3521, and
- 3506, 3507 or their associated atmospheric relief valves should be shown as CIVs on Figure 6.2-74, for penetrations 403 and 404, and listed in Table 6.2-13 as such.