ML17264A246

Forwards Response to NRC Questions Re Conversion to Improved Tech Specs for 24 Month Refueling Cycle DG Testing

ML17264A246
Person / Time
Site:	Ginna
Issue date:	11/21/1995
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-M92969, NUDOCS 9511290093
Download: ML17264A246 (9)

Text

PR.LC3 R.I EY' (ACCELERATED RIDS PROCESSING REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION 2IBR: 9511290093 DOC. DATE: 95/11/21 NOTARIZED: NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G

AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.

Rochester Gas 6 Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.

DOCKET N

05000244

SUBJECT:

Forwards response to NRC questions re conversion to improved Tech Specs for 24 month refueling cycle DG testing.

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TITLE: OR Submittal: General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).

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O AND ROCHESTER GASANDEIECTRIC CORPORATION ~ 89 EASTAVENUE, ROCHESTER, N. Y Id&f9-0001 AREA CODE716 5'-2j00 ROBERT C. MECREDY Vice President Nuclear Operations November 21, 1995 U.S. Nuclear Regulatory Commission Document Control Desk Attn:

Allen R. Johnson Project Directorate I-1 Washington, D.C.

20555

Subject:

Conversion to Improved Technical Specifications 24 Month Refueling Cycle Diesel Generator Testing (TAC No. M92969)

R.E.

Ginna Nuclear Power Plant Docket No. 50-244 Ref. (a):

Letter from R.C.

Mecredy, RG&E, to A.R.

Johnson, NRC,

Subject:

Application for Amendment to Facility Operating License Conversion to Improved Technical Specifications, dated May 26, 1995.

Dear Mr. Johnson:

By Reference (a),

RG&E submitted a proposed change to 24 month refueling cycles as part of a conversion to Improved Technical Specifications (see Attachment H).

Attached please find a response to several NRC questions related to diesel generator testing and the new refueling cycle.

Please contact Mark Flaherty at 716-724-8512 if you have any further questions.

Very truly yours, Robert C.

Mec edy Attachment MDF5404

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U.S. Nuclear Regulatory Commission Mr. Allen R. Johnson (Mail Stop 14B2)

Project Directorate I-1 Washington, D.C.

20555 U.S. Nuclear Regulatory Commission (v/o attachment)

Mr. Carl Schulten (Mail Stop 011E22)

Office of Technical Specifications Branch Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

e The foll@wing questions apply to both the AC power (Offsite Power) and

. the Emergency Diesel Generator systems

(

Reference:

Surveillance Requirements 3.8.1.6; 3.8.1.7; 3.8.1.8; and 3.8.1.9).

1 ~

Is the change (i.e.,

proposed extension in the surveillance interval) consistent with manufacturer' recommendati ons?

Given that the licensee has consul ted the equipment manufacturer were there any additional measures (e.g., interim inspections, added preventative maintenance acti vities) recommended and if so, what was the disposition of those recommendati ons?

2 ~

The Ginna Station diesel generators (DG) are ALCO Model 351 generators.

Fairbanks Morse currently owns the rights to ALCO designed generators.

RG&E participates in a Fairbanks Morse DG Working Group which is formulating recommended preventative maintenance (PM) activities for these generators.

Neither the manufacturer (i.e.,

Fairbanks Morse) nor the working group have endorsed any ~testin requirements or testing frequencies for these DGs.

Instead, these organizations recommend PM activities.

None of these recommended PM activities are less frequent than the 24 month intervals as being proposed by RG&E.

All recommended PM activities are either incorporated or otherwise addressed in the DG reliability centered maintenance (RCM) program.

Did the licensee evaluation include a review of the corrective and preventative maintenance activities now in place in order to assess whether the proposed extension of the surveillance interval will lead to any deteri orati on in the system or components?

The components addressed by SR 3.8.1.6, SR 3.8.1.7, SR 3.8.1.8, and 3.8.1.9 are all included in the Ginna Station RCM program.

This is a living program which is based on a review of plant maintenance

records, manufacturer recommendations, plant life extension reports (i.e.,

aging issues),

and component importance to implement a

PM activities.

Included within the program are effectiveness monitoring mechanisms to ensure that the recommended PM activities continue to provide the necessary component reliability.

A review of-the RCM program for the subject surveillance requirements has shown that no components require testing or PM related activities on a frequency of less than 24 months.

The only exception is with respect to service water pump breakers which are tested as part of SR 3.8.1.9.

These breakers are inspected every 12 months due to past reliability concerns.

However, these activities are performed at power since there are 4 service water

pumps, of which, only two are required for technical specifications.

Therefore, RG&E believes that an extension to 24 months for these SRs will not result in any increased failure rates especially since most components are also tested on a monthly or quarterly basis as a result of other testing requirements (e.g., monthly DG tests, quarterly valve and pump tests).

3.

Did the licensee evaluation include a

review of the maintenance history to determine whether there were any performance-related indications which would suggest that the proposed extension of the surveillance interval could cause deterioration in the system/component condition or performance?

What additional measures have been taken to address the subject indications?

See Response to question g2.

4 ~

Did the licensee evaluation include a review of the operating surveillance results and history for the subject systems and components to ensure that the proposed extension will not negatively affect any corrective acti on acti vities or the investigation of any long term operating problems?

Discuss any failures involving the subject component/system as well as whether there would be any increase in failure rate as a

result of the proposed extension of the surveillance interval.

See response to question g2.

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