ML17264A245
| ML17264A245 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/24/1995 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML17264A244 | List: |
| References | |
| GL-91-04, GL-91-4, NUDOCS 9511290008 | |
| Download: ML17264A245 (6) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Attachment 1
S F
V YALUATION BV THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO TECHNICAL SPECIFICATIONS CHANG ROCHESTER GAS AND ELECTRIC CORPORATION R.
E.
GINNA NUC EAR POWER PLANT UN T 1
DOCKET NO. 50-244
1.0 INTRODUCTION
By letter dated Hay 26,
- 1995, Rochester Gas and Electric Corporation (the licensee) submitted an amendment request proposing to revise the Ginna Station Technical Specifications in its entirety by converting to the Improved Technical Specifications (ITS).
The proposed ITS incl,udes a change in the surveillance intervals which are based on fuel cycle lengths which are expected to increase from the current 18-month cycle to a 24 month frequency.
Specifically, this change to Technica'I Specification (TS) surveillance requirements 4.6.3.b, 4.6. l.e.2, 4.6. l.e.3(a),
4.6. l.e.3(b) and 4.6. l.e.3(c) increases the frequency of testing for offsite power and emergency diesel generator systems from 18 months to 24 months.
The subject changes are intended to follow the guidance of Generic Letter (GL) 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate 24-Honth Fuel Cycle."
P After a preliminary review of the above TS change the staff requested additional information in order to clarify the scope of maintenance history and surveillance records review which was conducted by the licensee.
The licensee submitted the additional information by a fax letter dated November 20,
- 1995, which clarifies the technical basis for the extension of the subject surveillance interval.
2.0 2.1 EYALUATION The staff's evaluation of the licensee's proposed changes to the TS follows.
o o h
e to TS Section 4.6.3.b The licensee proposed to replace the existing TS Surveillance Requirement (SR) 4.6.3.b with the Improved Technical Specification (ITS)
SR 3.8. 1.6.
This SR involves the transfer of the 480 volt safeguards bus power supply from the preferred offsite power circuit configuration (50/50 mode) to the alternate offsite power configurations (100/0 mode 951$ 290008 95i i2R.
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and 0/100 mode) which demonstrates the operability of the alternate circuit distribution network to power the required loads.
2.2 P
o o d Chan e to TS Sections 4.6. l.e.2 4.6. l.e.3 a
4.6. l.e.3 b
and 4.6.1.e.3 c
The licensee proposed to replace the existing TS Surveillance Requirements 4.6. I.e.2, 4.6.1.e.3(c),
4.6. l.e.3(a),
and 4.6. I.e.3(b) with the Improved Technical Specification (ITS)
SR 3.8. 1.7, SR 3.8. 1.8 and 3.8. 1.9 respectively.
SR 3.8. 1.7 which replaces existing TS SR 4.6. I.e.2 verifies that each emergency diesel generator (EDG) does not trip during and following a load rejection of 295 kW or greater.
This SR demonstrates that the EDG load response characteristics and capability to reject the largest single load on the buses which will be supplied by the EDG.
SR 3.8. 1.8 which replaces existing TS SR 4.6. l.e.3(c) demonstrates that the EDG noncritical protective functions (e.g.,
overcurrent, reverse power, local stop pushbutton) are bypassed on an actual or stimulated safety injection (SI) actuation signal, and critical protective functions (e.g.,
engine overspeed, low lube oil pressure, and start failure (overcrank) relay) trip the EDG in order to avert substantial damage.
SR 3.8. 1.9 which replaces existing TS SR 4.6. I.e.3(a) and SR 4.6. I.e.3(b) demonstrates the EDG operation during an actual or simulated loss of offsite power (LOP) signal in conjunction with an actual or simulated SI actuation signal.
In the event of a design basis accident coincident with a LOP, the EDG is required to supply the necessary power to the engineered safety features systems so that the fuel, reactor coolant system, and containment design limits are not exceeded.
Overall, the subject SR verifies proper load shedding of 480 volt safeguards buses and the start of each EDG on an actual or simulated LOP signal in conjunction with an SI signal.
In addition to the surveillance interval extension for the above surveillance requirements Note (1) was added to the above surveillance requirements and Note (2) was added to SR 3.8. 1.9 as shown below:
(1)
This Surveillance shall not be performed in NODE 1, 2, 3, 4.
(2)
All DG starts may be preceded by an engine prelube period.
Note 1 is to advise operators that the performance of the specific surveillance could cause perturbations to the electrical distri'bution systems that could challenge continued steady state plant operation.
Note 2 is intended to minimize the wear and tear on the Diesel Generators during testing consistent with manufacturer recommendations.
The other change associated with the replacement of TS SR 4.6. l.e.3(c)
with SR 3.8. 1.9 includes the omission of maximum breaker closure times for all breakers and the breakers for a Train A and B equipment configuration (i.e., Diesel Generator plus SI pump plus Residual Heat Removal pump).
2.3 Staff Evaluation According to the proposed Bases for SR 3.8.1.6, SR 3.8.1.7, SR 3.8. 1.8 and SR 3.8. 1.9 the frequency of 24 months"is based on engineering judgement, taking into consideration the plant conditions required to perform the surveillance and is intended to be consistent with the expected fuel cycle lengths.
The licensee stated in its submittal dated November 20, 1995 that the components addressed by the subject surveillance requirements are included in the Ginna Station Reliability Centered Haintenance (RCH) program.
The Ginna Station diesel generators (DG) are ALCO Hodel 351 generators which are manufactured by the Fairbanks Horse Corporation.
The licensee participates in a Fairbanks Horse DG Working Group which formulates recommended PH activities for these generators.
The licensee stated that neither the manufacturer nor the working group have endors'ed any testing requirements or testing frequencies for the subject DG equipment.
In addition, none of the subject PH activities are recommended on a frequency less than the proposed 24 month interval.
Overall, the licensee asserts that all of the recommended PH activities are either incorporated or otherwise addressed in the DG RCH program.
The Ginna Station RCH program is a "living" program which uses the review of plant maintenance
- records, manufacturer recommendations, plant life extension reports and the importance of the component to implement preventative maintenance (PH) activities.
The licensee program also includes effectiveness monitoring mechanisms to ensure that the recommended PH activities continue to provide the necessary component reliability.
After a review of the RCH program records of the subject surveillance requirement the licensee determined that no component except the service water (SW) pump breaker required testing or PM related activities on a frequency less than 24 months.
The SW pump breaker which is tested as a part of SR 3.8. 1.9 are inspected every 12 months due to past reliability concerns.
- However, the above PH activities are performed at power since there are four SW pumps, of which only two pumps are required to meet TS requirements.
Therefore, the licensee believes that an extension to 24 month for the subject surveillance requirements will not result in any increased failure rates especially since most components are also tested on a more frequent basis as a result of other testing requirements (e.g.,
monthly DG tests).
On the basis of its review of the above information, the staff finds that the proposed
'TS change is consistent with the guidance provided in
- Further, the other changes represent administrative changes consistent with the Standard Technical Specifications format.
The licensee has committed to implement the Maintenance Rule (10 CFR 50.65) beginning in 1996 which will require the monitoring and asses'sment of the component performance in order to ensure that the adequate performance.
Therefore, based upon the above information, the staff finds that the subject TS change is acceptable.
3.0
SUMMARY
AND CONCLUSION By letter dated May 26,
- 1995, Rochester Gas and Electric Corporation (the licensee) submitted an amendment request proposing to revise the Ginna Station Technical Specifications in its entirety by converting to the Improved Technical Specifications (ITS).
The proposed ITS includes a change in the surveillance intervals which are based on fuel cycle lengths which are expected to increase from the current 18-month cycle to a 24 month frequency.
Specifically, this change to Technical Specification (TS) surveillance requirements 4.6.3.b, 4.6. l.e.2, 4.6. 1.e.3(a),
4.6. l.e.3(b) and 4.6. 1.e.3(c) increases the frequency of testing for offsite power and emergency diesel generator systems from 18 months to 24 months.
The subject changes are intended to follow the guidance of Generic Letter (GL) 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate 24-Month Fuel Cycle."
After a preliminary review of the above TS change the staff requested additional information in order to clarify the scope of maintenance history and surveillance records review which was conducted by the licensee.
The licensee submitted the additional information by a fax
'etter dated November 20, 1995, which clarified the technical basis for the extension of the subject surveillance interval.
On the basis of its review, the staff finds the subject TS change is consistent with the guidance provided in GL 91-04.
The licensee has committed to implement the Maintenance Rule (10 CFR 50.65) beginning in 1996.
Since this Rule will require monitoring and assessment activities in order. to ensure the subject components remain capable of performing its safety function, there is sufficient assurance that this change will have no significant safety impact.
Based upon the above information, the staff finds that the amended TS change is acceptable and, therefore, approves the requested change for the Ginna Nuclear Power Plant.
Attachment 2
SALP INPUT PAILITTAAA: Ai.tl I
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SUMMARY
OF REVIEW:
By letter dated May 26,
- 1995, Rochester Gas and Electric Corporation (the licensee) submitted an amendment request proposing to revise the Ginna Station Technical Specifications in its entirety by converting to the Improved Technical Specifications (ITS).
The proposed ITS includes a change in the surveillance intervals which are based on fuel cycle lengths which are expected to increase from the current 18-month cycle to a 24 month frequency.
Specifically, this change to Technical Specification (TS) surveillance requirements 4.6.3.b, 4.6. l.e.2, 4.6. l.e.3(a),
4.6. l.e.3(b) and 4.6. l.e.3(c) increases the frequency of testing for offsite power and emergency diesel generator systems from 18 months to 24 months.
The subject changes are intended to follow the guidance of Generic Letter (GL) 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate 24-Month Fuel Cycle."
After a preliminary review of the above TS change the staff requested additional information in order to clarify the scope of maintenance history and surveillance records review which was conducted by the licensee.
The licensee submitted the additional information by a fax letter dated November 20,
- 1995, which clarified the technical basis for the extension of the subject surveillance interval.
On the basis of its review, the staff finds that the subject TS change is acceptable.
NARRATIVE DISCUSSION OF LICENSEE PERFORMANCE FUNCTIONA R:
ENGINEERING TECHNICAL SUPPORT:
The licensee failed to adequately address the principal issues (technical basis for surveillance extension) for the TS change which caused a delay in the timely disposition of this review.
The licensee showed a less than thorough understanding of the documentation necessary to provide the basis for staff approval.
Author:
R. Jenkins Date:
November 21, 1995