ML17263A392
| ML17263A392 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/30/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17263A391 | List: |
| References | |
| NUDOCS 9309140048 | |
| Download: ML17263A392 (11) | |
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+p*y4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&4001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
4 TO FACILITY OPERATING LICENSE NO.
DPR-18 ROCHESTER GAS AND ELECTRIC CORPORATION R.
E.
GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244
- 1. 0 INTRODUCTION By letter dated October 25,
- 1990, as supplemented March 8,
- 1991, November 30,
- 1992, and July 13,
- 1993, the Rochester Gas
& Electric Company (the licensee) submitted an application to amend the facility Technical Specifications (TS) relating to containment isolation and containment integrity.
The July 13, 1993, application was a resubmittal of earlier applications dated October 15,
- 1990, March 8,
- 1991, and November 30, 1992.
The resubmitted application of July 13,
- 1993, was revised to reflect changes resulting from three staff requests for additional information (RAI) dated November 12,
- 1990, September 26,
- 1991, and March 11, 1993.
On June 2,
1993, the licensee provided a draft response to the March ll, 1993, RAI, and incorporated this information into this July 13, 1993, submittal.
The November 30, 1992, letter also requested exemptions from certain provisions of 10 CFR Part 50, Appendix J.
This evaluation addresses the proposed TS changes.
The Appendix J exemption requests will be the subject of separate staff evaluations.
Each proposed TS change is discussed and evaluated below.
- 2. 0 DISCUSSION AND EVALUATION
- 2. 1 TS 3.6. 1 Containment Integrity Pro osed Chan e:
TS 3.6. 1 "Containment Integrity" would be amended to include a statement that "Closed valves may be opened on an intermittent basis under administrative control."
The change would allow for temporary'pening of locked or sealed closed isolation valves."
Staff Evaluation:
Addition of the statement "Closed valves may be opened on an intermittent basis under administrative control" to the limiting conditions for operation (LCO) is part of the guidance of Generic Letter (GL) 91-08.
In the GL, the staff concluded that addition of this statement to the LCO is an acceptable alternative to identifying specific valves that may be opened under administrative control.
This change is acceptable based on consistency with the GL.
2.2 TS 3.6.3 Containment Isolation Valve Operability 9309140048 930830 PDR ADOCK 05000244 P
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2-2.2.1 Deletion of Table 3.6.1 P
o osed Chan e:
Table 3.6-1 "Table of Isolation Valves," would be removed from the TS.
Isolation devices would be identified in a Ginna Station Procedure which is subject to the administrative controls of the TS, including review and approval by the Plant Operations Review Committee and Plant Nanager.
[Note:
the original application proposed to relocate the isolation valve table to the updated safety analysis report.
The licensee revised its application, in response to the staff's larch 11,
- 1993, RAI to relocate the table to a station procedure.]
Staff Evaluation:
GL 91-08 provides the staff's guidance for removal of component lists from TS.
The guidance states that the TS Table of Containment Isolation Valves may be relocated to a plant procedure subject to the administrative controls specified in the TS.
The guidance also discusses the treatment of footnotes to the TS Table of Containment Isolation Valves.
The licensee's proposed change complies with the guidance of the GL and is therefore acceptable.
2.2.2 TS 3.6.3 - Containment Isolation "Boundaries" Pro osed Chan e:
TS 3.6.3 would be changed to apply to containment isolation "boundaries,"
as opposed to "valves."
Staff Evaluation:
The proposed change would clarify the fact that devices other than valves may be used as acceptable containment piping penetration isolation bar riers.
This change is therefore acceptable.
2.2.3 Appendix J Leakage Limits as Isolation Valve Operability Criteria Pro osed Chan e:
The statement "Isolation valves are inoperable from a leakage standpoint if the leakage is greater than that allowed by 10 CFR 50, Appendix J" would be deleted from TS 3.6.3.
Staff Evaluation:
Title 10 of the Code of Federal Regulations Part 50, Appendix J does not specify leak rate limits for individual containment isolation valves or piping penetrations.
Elimination of the statement will have no effect on isolation valve operability requirements and is therefore acceptable.
TS 4.4.2.2 (see below) specifies the Appendix J limit on total leakage as an acceptance criterion for containment integrity.
The proposed change is therefore acceptable.
2.4 TS 3.8 Refueling Requirements 2.4. I Containment Integrity Requirements for Refueling Pro osed Chan e:
The TS 3.8. I would be changed to eliminate requirements
- that, during refueling operations:
(I) all automatic containment isolation valves be operable, or at least one valve in each line be locked closed and
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(2) the 48-inch shutdown purge valves be operable or closed, or the associated flange installed.
The proposed change would replace these requirements with a requirement that each penetration providing direct access from the containment atmosphere to the outside atmosphere be closed by an isolation valve, blind flange or manual valve, or be capable of being closed by an operable automatic shutdown purge or mini-purge valve.
The proposed change would eliminate containment isolation operability requirements during refueling for piping that does not provide an open path between the containment atmosphere and outside environment.
The licensee's application states that this is acceptable based on:
(I) a fuel handling accident would not pressurize containment, and (2) the fuel handling accident analysis (for non-seismic conditions) indicates that Part 100 dose consequences acceptance criteria can be met without credit for containment isolation or filtration of effluent.
The licensee also states that this is more nearly consistent with the Standard Technical Specifications.
Also included in the change are editorial changes relating to air locks, equipment
- hatches, and access doors.
The operability requirements relating to these would not be affected.
Staff Evaluation:
There is no staff position requiring primary containment integrity during refueling mode operation.
During refueling (MODE 6 operation),
the potential for containment pressurization as a result of an accident is greatly reduced; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent.
Such requirements are referred to as "containment closure" rather than "containment OPERABILITY."
Containment closure means that all potential escape paths are closed or capable of being closed.
The requirements for containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted from escaping to the environment.
The proposed piping penetration containment closure requirements would ensure that all potential piping escape paths from the containment atmosphere to the environs are closed or capable of being closed.
The changes to the piping penetration TS are therefore acceptable.
2.4.2 Action Statement for Inoperable Residual Heat Removal (RHR) During Refueling Pro osed Chan e:
TS 3.8.3 would be changed to specify that, during refueling, in the event at least one RHR pump is not operable, the licensee must isolate all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The licensee proposes to revise TS 3.8.3 to make this action apply only to the shutdown purge and mini-purge penetrations.
Staff Evaluation:
The proposed change to TS 3.8.3 is consistent with the proposed revision of TS 3.8. 1.
Under the proposed 3.8.1 all piping paths from the containment atmosphere to the outside environment except for the shutdown
purge and mini-purge penetrations will already be closed for refueling.
In the event of no operable RHR loop, it will thus only be necessary to isolate the shutdown purge and mini-purge penetrations.
The proposed change is therefore acceptable.
2.5 TS 4.4. 1.4
- Integrated Leak Rate Test - Definitions Pro osed Chan e:
Expanded definitions would be provided in TS 4.4. 1.4 for PP,,
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Staff Evaluation:
The licensee's safety evaluation accompanying the application states that the change is for clarification only, and that the definitions are consistent with existing requirements for Ginna and do not constitute a technical change.
The staff 'has reviewed these changes and agrees.
The proposed changes are therefore acceptable.
2.6 TS 4.4. 1.5
Leak Rate Test Frequency For Steam Generator Inspection/Maintenance Penetration Pro osed Chan e:
TS 4.4. 1.5.a.ii would be modified to require a local leak test of the generator inspection/maintenance penetration prior to returning the plant to operation after each inservice inspection.
Staff Evaluation:
The proposed change reflects the conversion of a spare, previously capped, 10-inch containment penetration into a new, blind-flange penetration which is used for steam generator maintenance during outages.
The new penetration facilitates cabling of maintenance equipment in a manner that would enable more rapid establishment of containment integrity in the event of a mid-loop event.
The inclusion of the new containment'enetration to the list of penetrations to be tested prior to return of the plant to operation is similar to the treatment of personnel and equipment hatches and the fuel transfer tube.
This surveillance requirement, plus the proposed change to TS 4.4.2.4 described below ensure integrity of the new penetration during plant operation and is acceptable.
2.7 TS '4.4.2.2 Acceptance Criteria for Local Leak Rate Tests Pro osed Chan e:
TS 4.4.2.2 presently, states that "the total leakage from all penetrations and isolation valves shall not exceed 0.60 L,."
The proposed change would revise the statement to read "Containment isolation boundaries are inoperable from a leakage standpoint when the demonstrated leakage of a single boundary or the cumulative total leakage of all boundaries is greater than 0.60 L,."
Staff Evaluation:
The proposed change clarifies that leak tightness is an operability criterion for all containment boundaries and replaces the term "isolation valve" with "isolation boundary."
The proposed change would provide consistency and clarification and does not affect operability or surveillance requirements.
It is therefore acceptable.
2.8 TS 4.4.2.3 - Corrective Action for Leak Rate Tests Pro osed Chan e:
The action requirement for failure of "penetration and isolation valves" to meet the 0.60 L, acceptance criterion would be clarified as applicable to "penetrations and isolation boundaries."
Staff Evaluation:
The proposed change is a simple clarification that does not affect operability or surveillance requirements and is therefore acceptable.
2.9 TS 4.4.2.4.a Test Frequency for Hini-Purge Valves Pro osed Chan e:
A statement requiring that the four mini-purge isolation valves shall be tested at 6-month intervals for 2 years following installation of the mini-purge system would be deleted from the surveillance requirement regarding local leak rate test frequencies.
Staff Evaluation:
Deletion of these requirements from the TS is acceptable since they have expired.
The intent of the original accelerated leak test rate was to gather increased data regarding the leak tightness of the valves under service conditions to determine if increased testing is needed on a
permanent basis.
This relates to staff concerns about large isolation valves having resilient seats.
The licensee and staff reviewed the test history of the valves and confirmed that a 2-year test interval is supported by valve-specific historical test results.
- 2. 10 TS 4.4.2.4.d - Containment Purge Isolation Valve Testing Pro osed chan e:
Text related to a former temporary requirement for increased test frequency of the purge valves, pending provision of flanges, would be deleted.
Staff Evaluation:
The expired text may be deleted from the TS.
The shutdown flanges have been provided and are currently tested after each refueling shutdown or use under the requirements of TS 4.4.2.4.b.
This change is therefore acceptable.
A reference to the TS Table of Isolation Valves/Table 3.6. 1, would be deleted in-the isolation valve surveillance requirements relating to 10 CFR 50.55a inservice testing program.
Staff Evaluation:
Deletion of the table reference would reflect the removal of the table from the TS as discussed in 2.2 above, and is acceptable based on the guidance of GL 91-08.
- 2. 12 TS 4.4.6.2
Response
Time Testing for Isolation Valves
- 2. 12. 1 Reference to Table 3.6. 1 Pro osed Chan e:
A reference to the TS Table of Isolation Valves/Table 3.6. 1, would be deleted in the isolation valve response time testing requirement.
Staff Evaluation:
Deletion of the table reference would reflect the removal of the table from the TS as discussed in 2.2 above, and is acceptable based on the guidance of GL 91-08.
- 2. 12.2 Limitation on Scope of Valves Requiring
Response
Time Testing Pro osed Chan e:
The containment isolation valve response time testing requirement would be limited to valves for which a change of position in response to a containment isolation signal is assumed in the accident analyses.
Staff Evaluation:
The proposed change is consistent with guidance provided by the staff in a November 12,
- 1990, RAI.
In that correspondence, the staff specifically recommended use of the wording now proposed in order to avoid use of undefined terms and to more explicitly identify which valves require response time testing.
Limiting response time surveillance testing to containment isolation valves that change position in response to a containment isolation signal is consistent with the assumptions used in analyses of the radiological consequences of design basis accidents and is acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment.
The State official had no comments.
- 4. 0 ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released
- offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a
proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (55 FR 51186).
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
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5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed
- above, that:
(I) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
A. Chu W. Long Date:
August 30, 1993
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