ML17264A158
| ML17264A158 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/21/1995 |
| From: | Andrea Johnson NRC (Affiliation Not Assigned) |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| TAC-M92963, NUDOCS 9509250383 | |
| Download: ML17264A158 (7) | |
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/y qO i +4**4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-$ $ 1 September 21, 1995 Dr. Robert C. Hecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS ATTACHMENT H, EXTENSION OF INSTRUMENT SURVEILLANCE INTERVALS, R.
E.
GINNA NUCLEAR POWER PLANT (TAC NO. H92963)
Dear Dr. Hecredy:
Enclosed is a list of questions related to the proposed technical specification changes to extend the instrument surveillance interval to accommodate a 24-month fuel cycle.
A response to this request is needed by September 30, 1995.
This request affects one respondent and, therefore, is not subject to the Office of Management and Budget review under P.L.96-511.
Sincerely, Docket No. 50-244
Enclosure:
List of Questions cc w/encl:
See next page len R. Johns n, Project Manager oject Dire orate I-1 Di 'eactor Projects I/II Office of Nuclear Reactor Regulation 950'725038395092'DR'ADCICK 05000244 P
Dr. Robert C. Mecredy R.E. Ginna Nuclear Power Plant CC:
Thomas A. Moslak, Senior Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road
- Ontario, NY 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Hr. F. Williams Valentino, President New York State
- Energy, Research, and Development Authority 2 Rockefeller Plaza
- Albany, NY 12223-1253 Charlie Donaldson, Esq.
Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Nicholas S. Reynolds Winston 3 Strawn 1400 L St.
N.W.
Washington, DC 20005-3502 Hs. Thelma Wideman
- Director, Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31
- Lyons, NY 14489 Hs.
Mary Louise Heisenzahl Administrator, Monroe County Office of Emergency Preparedness ill West Fall Road, Room 11 Rochester, NY 14620
CNCA S
CF IOS-ST UM SU Provide a copy of Engineering Work Request
- 5126, "Guidelines for Instrument Loop Performance Evaluation and Setpoint Verification," August 1992.
Provide justification to show that how and what were the sample sizes chosen form the instrument population and based on what section of HIL-STD-105Dm "Sampling Procedures and Tables for Inspection By Attributes,"
to support a claim of 95/95 confidence level.
Instrument Drift Study is based on only a sample of the installed instrumentation at Ginna.
Is this appropriate considering:
instrument types, installation, characteristics, manufacturer and service requirements?
Explain the bases for stating that the confidence level is 95/95.
Are the instrument uncertainties listed referenced to the sensor/transmitter only or to all components in the loop?
Drift is the difference between as-left and'as-found.
In the submittal, the year data sheet uses "desired/calculated" and as-found" values.
Explain the difference.
The submittal states that the worst case consecutive 3-year variance is selected.
What is the basis for selecting three consecutive calibration results?
Also, our review of the data indicates that the selected intervals widely vary (1.5 to >3 years),
not always 3 years.
The submittal states that the three consecutive calibration interval demonstrates acceptable instrument performance for calibration intervals greater than 30 months.
Explain the methodology and assumptions to support this conclusion.
How is instrument calibration handled when included in the three consecutive interval criteria (no longer representative of a 36-month interval)?
The term "variance" as used in the discussion and the summary sheets appear to be misleading.
Does this represent the fluctuation of the data (10 point calibration results)
The total instrument uncertainty (TIU) term referenced in the submittal appears to represent an "allowable value."
Provide a description of the Ginna setpoint methodology and the development of the allowable value.
Sheet 5 of the drift study (LT-2039) process an increase of TIU to 3.14X and total channel uncertainty to 4.57X.
How does the change in acceptance criteria affect instrument operability determination?
It Enclosure
appears that the instrument may in fact be failing and is not indicative of performance for this type of transmitter.
ll.
The drift analysis presented does not reference current industry guidance as expressed by EPRI, ISA, Westinghouse or GE.
Justify authenticity of the method chosen.
12.
Is RGKE's conclusion that instrument drift generally occurs shortly after the calibration is based solely on observed data'hen such data should be provided for our review.
Surveillance interval can be increased if it is established by extensive data that the instrument drift is independent of time after the calibration.
September 21, 1995 Dr. Robert C. Mecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649
SUBJECT:
RE(VEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS - ATTACHMENT H, EXTENSION OF INSTRUMENT SURVEILLANCE INTERVALS, R.
E.
GINNA NUCLEAR POWER PLANT (TAC NO. H92963)
Dear Dr. Hecredy:
Enclosed is a list of questions related to the proposed technical specification changes to extend the instrument surveillance interval to accommodate a 24-month fuel cycle.
A response to this request is needed by September 30, 1995.
This request affects one respondent and, therefore, is not subject to the Office of Management and Budget review under P.L.96-511.
Sincerely, Original signed by:
Allen R. Johnson, Project Hanager Project Directorate I-1 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
List of questions cc w/encl:
See next page Distribution:
~ Docket File PUBLIC PDI-1 Reading SVarga JZwolinski LMarsh SLittle AJohnson OGC ACRS (4)
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LMarsh 09/ g/95 09/
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