ML17264A200
| ML17264A200 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/18/1995 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Andrea Johnson NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17264A201 | List: |
| References | |
| TAC-M92965, NUDOCS 9510260338 | |
| Download: ML17264A200 (7) | |
Text
PRZORXTY (ACCELERATED RZDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9510260338 DOC.DATE: 95/10/18 NOTARIZED: NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.
DOCKET 05000244
SUBJECT:
Forwards info requested from 950921
& 1016 telcons re testing of ventilation sys
& impact of 24-month fuel cycles.
DISTRIBUTION CODE:
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SIZE:
TITLE: OR Submittal:
General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
05000244 RECIPIENT ID CODE/NAME PD1-1 LA JOHNSON,A "4
"-"2X.
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~
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CONTACT THE DOCUMENT CONTROL
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AND ROCHESTER GASANDElECTRIC CORPORATION ~ 89 FASTAVENUE, ROCHFSTFR, N. Y Id@f9-0001 AREA CODE716 54'6-27M ROBERT C. MECREDY Vice President Nvcteor Operations October 18, 1995 U.S. Nuclear Regulatory Commission Document Control Desk Attention:
Mr. Allen R. Johnson Project Directorate I-1 Washington, D.C. 20555
Subject:
Conversion to Improved Technical Specifications 24 Month Cycle Evaluation, Ventilation Testing Requirements (TACNo. 92965)
Rochester Gas &Electric Corporation R.E. Ginna Nuclear Power Plant Docket No. 50-244
References:
(a)
Letter from R.C. Mecredy, RG&E, to A.R. Johnson, NRC,
Subject:
ApplicationforAmendment to Facility Operating License, Conversion to Improved Technical Specifications, dated May 26, 1995.
(b)
NUREG-1431, Improved Standard Technical Specifications for 8'estinghouse Plants, Revision 1, April 1995.
Dear Mr. Johnson,
On September 21, 1995 and October 16, 1995, separate conference calls were held between RG&E and the NRC with respect to testing ofventilation systems and the impact of24 month fuel cycles. During the first conference call, the NRC requested that RG&:E perform a review of historical ventilation test data and document the results of this review. During the second conference call, the NRC requested that RG&E address certain differences between the Ventilation Filter Testing Program (VFTP) submitted by RG&;E (Ref. (a)) and that contained in NUREG-1431 (Ref. (b)). The purpose ofthis letter is to provide the requested information from these two conference calls.
RG&E has reviewed plant records from 1980 through the present for the four ventilation systems contained in the proposed improved technical specifications (ITS) for Ginna Station (Ref. a):
Cr G~
'st5i0260338 95iOi8 PDR ADOCK 05000244 trjp4~ $833 /<0 Off a.
b.
C.
d.
Containment Post-Accident Charcoal System Control Room Emergency AirTreatment System (CREATS)
Spent Fuel Pool (SFP) Charcoal Adsorber System Containment Recirculation Fan Coolers (CRFC)
The results ofthis review are provided in the attached table. This review shows that between January 1980 and September 1995, there have not been any observed failures in these four systems.
This includes data from filter, damper, fan, and actuation logic testing.
Copies ofthe current procedures which implement this testing are also attached for your information. As such, RGB believes this data supports extending the surveillance testing interval from 18 months to 24 months for r'efueling outage based tests.
'I Please note that RGB'as no plans to adjust these current ventilation testing frequencies followingimplementation of the ITS except to change from annual to 18 month tests in support ofthe upcoming fuel cycle change.
However, RG&E reserves the right to adjust these test frequencies in the future ifcontinued system reliability is-maintained.
The NRC also requested during the October 16, 1995 conference call that RGkE address the following issues:
The RGd'cE proposed VFTP only references Regulatory Guide 1.52, Revision 2. This regulatory gui de limitsrefiielingoutage based surveillance test intervals to 18 months versus the proposed 24 months.
The bases forproposed SR 3.6 6.5, SR 3.6.6.6 SR 3.7.9.2, and SR 3.7.10.2 should specifically address this issue.
RGLE proposes to add the followingsentence to the end of each of the four referenced bases sections:
However, the maximum surveillance interval for refueling outage tests is based on 24 month refueling cycles and not 18 month cycles as defined by Regulatory Guide 1.52.
RGB ITS comment ¹149 has been opened to track incorporation ofthis sentence (attached).
The VFTP specifiedin NUREG-1431 contains references to ASMEN510-1989 for fiowrate testing and ASTMD3803-1989for laboratory testing.
The RGd'cE proposed VFTP only references Regulatory Guide 1.52, Revision 2 which does not contain equivalent level ofdetailfor these tests.
The current Ginna Station procedures for testing ofthe four subject ventilation systems contain references for the following:
a.
Containment Post-Accident Charcoal System ANSIN510-1989, Section 5.5.1.6 (Moisture Separators)
ANSIN510-1980 b.
Control Room Emergency AirTreatment System (CREATS)
ANSIN510-1975 c.
Spent Fuel Pool (SFP) Charcoal Adsorber System ANSIN510-1980 d.
Containment Recirculation Fan Coolers (CRFC)
ANSIN510-1989, Section 5.5.1.6 (Moisture Separators)
ANSIN510-1980 As can be seen, references to ANSIN510 vary between the 1975, 1980, and 1989 editions. RGB would prefer not to specify which edition ofthis standard is used in the VFTP contained in the Administrative Controls section oftechnical specifications since this could not be changed (even to a more recent edition) without prior NRC approval.
In addition, Regulatory Guide 1.52, Revision 2 specifically references ANSIN510-1975 for testing.
Since there is no existing regulatory guide endorsing a later edition to this standard, RG&E proposes to maintain this information in station procedures as is the current practice.
There are other similar programs which reference early standards and regulatory guides both in the ITS and current technical specifications (e.g., ITS 5.3.1).
With respect to ASTMD3803-1989, RGAE does not believe that this reference is necessary in the VFTP since Regulatory Guide 1.52, Revision 2 references ANSIN509-1976.
Since there is no existing regulatory guide endorsing a later edition to this standard, RGEcE proposes to maintain this information in station procedures as is the current practice.
The VFTP in NUlI;G-1431 specifically lists the minimrimflowrate through HEPA and charcoal filters while the RG&Eproposed VFTP does not.
The RGkE proposed VFTP is based on the current Ginna Station technical specifications which do not specify this flowrate information. RG&E does not believe that this level of information is necessary in the Administrative Controls section.
However, RGB proposes to add to the followingto the bases for SR 3.6.6.5, SR 3.6.6.6, SR 3.7.9.2, and SR 3.7.10.2 to address this issue:
[SR 3.6.6.5]
The minimum required flowrate through each ofthe two post-accident charcoal filters is 33,000 cubic feet per minute at accident conditions (or 38,500 cubic 'feet per minute at normal operating conditions).
[SR 3.6.6.6]
The minimum required flowrate through each ofthe four CRFC units is 33,000 cubic feet per minute at accident conditions (or 38,500 cubic feet per minute at normal operating conditions).
[SR 3.7.9.2]
The minimum required flowrate through the CREATS filtrationtrain is 2,000 cubic feet per minute.
[SR 3.7. 10.2]
There is no minimum required flowrate through the SFP charcoal adsorbers since SR 3.7.10.1 requires verification that a negative pressure is maintained during fuel movement in the AuxiliaryBuilding. As long as this minimum pressure is maintained by drawing air from the surface ofthe SFP through the SFP charcoal adsorbers, the assumptions ofthe accident analyses are met.
RGB'TS comment 8150 has been opened to track incorporation ofthis information into the bases (attached).
The VFTP in NURI'G-1431 contains detailed discussion ofthe allowable methyl iodide penetration and associated "safetyfactor" while the RGd'cLproposed VFTP only contains the allowable penetration value.
The VFTP in NUREG-1431contains a Reviewer's Note stating that the "allowable penetration = [100% - methyl iodide efficiency for charcoal credited in staff safety evaluation] / (safety factor)" where the safety factor is "5 for systems with heaters" and "7 for systems without heaters."
The RGRE proposed VFTP requires a penetration of "<
1%" for all four ventilation systems.
In addition, the methyl iodide efficiency of all four ventilation systems must be "a 90%." Placing these values into the NUREG-1431 Reviewer's note yields:
(100% - 90%) / (safety factor) < 1%
safety factor = 10 Therefore, the actual safety factor is greater than that proposed in NUREG-1431 for systems with or without heaters.
Consequently, RGB does not believe that this safety factor limitneeds to be added to the VFTP.
Please direct any additional questions related to these issues to Mark Flaherty at (716) 724-8512.
Very truly yours, Robert C. Mecredy MDF3752
. attachments xc:
U.S. Nuclear Regulatory Commission Mr. Allen R. Johnson (Mail Stop 14B2)
PWR Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission (w/o attachment)
Mr. Carl Schulten (Mail Stop 011E22)
Office ofTechnical Specifications Branch Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King ofPrussia, PA 19406 Ginna Senior Resident Inspector
COMMENTS/CHAPTER 18-Oct-95 CHAPTER/LCO: 5.5.10 ITEM¹:
150 DESCRIPTION OF ISSUE: Add discussion on minimum required flowrates to the bases for SR 3.6.6.5, SR 3.6.6.6, SR 3.7.9.2, and SR 3.7. 10.2. This closes commitment in 10/18/95 letter to NRC.
DATEIDENTIFIED:
10/18/95 DATE CLOSED:
TRAVELLEREXIST?:
No TRAVELLERNAME:
COMMENTS:
CHAPTER/LCO: 5.5.10 ITEM¹:
DESCRIPTION OF ISSUE:
149 Add the followingto the last sentence ofthe bases for SR 3.6.6.5, SR 3.6.6.6, SR 3.7.9.2, and SR 3.7.10.2, "However, the maximum surveillance internal for refueling outage tests is based on 24 month refueling cycles and not 18 month cycles defined by Regulatory Guide 1.52." This closes commitment in 10/18/95 letter to NRC.
DATEIDENTIFIED:
10/18/95 DATE CLOSED:
TRAVELLEREXIST?:
No TRAVELLERNA'ME:
COMMENTS: