ML17264A709
| ML17264A709 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/29/1996 |
| From: | Vissing G NRC (Affiliation Not Assigned) |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| NUDOCS 9610300204 | |
| Download: ML17264A709 (5) | |
Text
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t UNITED STATES NUCLEAR REGULATORY COMIVIISSION WASHINGTON, D.C. 205554001 October 29, 1996 Dr. Robert C. Hecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649
SUBJECT:
COLD SHUTDOWN JUSTIFICATION, CS-37, FOR THE R.
E.
GINNA NUCLEAR POWER STATION INSERVICE TESTING PROGRAH (TAC NO. H96751)
Dear Dr. Hecredy:
By letter dated October 10,
- 1996, Rochester Gas and Electric Corporation requested NRC approval of a cold shutdown justification for the R.
E. Ginna Nuclear Power Plant Inservice Testing Program.
The cold shutdown justification applies to power-operated valves HOV-897 and HOV-898 which are installed in series in the common recirculation path for all three high head safety injection pumps back to the refueling water storage, tank.
These valves are normally open and are required to be open during the safety injection phase of accident mitigation.
These valves also have a safety function to close (i.e., isolate the refueling water storage tank) following the safety injection phase when the emergency core cooling system is placed in the recirculation phase taking cooling water suction from the containment sump.
Section 50.55a of Title 10 of the Code of Federal Regulations requires licensees to implement inservice testing programs to the requirements of Section XI of the American Society of Hechanical Engineers (ASHE) Boiler and Pressure Vessel Code (the Code).
The current R.
E. Ginna Nuclear Power Plant Inservice Testing Program was developed based on the 1989 Edition of the Code which references Part 10 of the ASHE Operations and Haintenance Standards (OH-
- 10) for valve testing.
OH-10 specifies that power-operated valves be exercised quarterly during power operations, but if such exercising is impractical, testing may be conducted (1) during cold shutdowns or (2) during refueling outages if testing during cold shutdowns is also impractical.
The NRC issued guidelines for developing inservice testing program in NUREG-1482.
Section 3. l. 1 of NUREG-1482 address deferring valves testing to cold shutdowns or refueling outages.
In Section 3. 1.1, guidance that was initially issued by the NRC in 1976 was restated which specifically excluded certain valves from quarterly testing during power operations based on the design of the plant (i.e., impracticalities).
The first example in Section 3. 1. 1 is applicable to valves HOV-897 and HOV-898 because "valve failure in a nonconservative position during the cycling test would cause a loss of system function."
Therefore, the proposed cold shutdown justification in your letter of October 10,
- 1996, includes sufficient basis for deferring testing.
Because the Code allows licensees to make the determination regarding test
- deferral, NRC approval is not required prior to implementing cold shutdown or refueling outage justifications (see Section 3. 1. 1 of NUREG-1482).
- However, the NRC does include a review of these justifications during inspections of the inservice testing program.
As such, you may elect to revise the 9hf0300204 9hi029 PDR AOOCK OS0002ee PDR CelISL
r
R. Hecredy cold shutdown justification for valves HOV-897 and HOV-898 to specifically refer to the guidance in Section 3. 1. 1 of NUREG-1482 which indicates that these valves may be excluded from quarterly testing during power operation.
Section 3. 1.2 of NUREG-1482 discusses guidance given in Generic Letter 87-09 regarding entry into a Technical Specification Limiting Condition for Operation (LCO) to perform testing.
While entry into an LCO is not, by itself, sufficient justification to defer testing, the additional support discussed above for the subject cold shutdown justification is adequate to justify deferring testing for valves MOV-897 and MOV-898 at the R.
E. Ginna Nuclear Power Plant.
No further NRC action is required.
Sincerely, Docket No. 50-244 cc:
See next page Guy S. Vissing, Seni r Project Manager Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
C, R. Hecredy October 29, 1996 cold shutdown justification for valves HOV-897 and HOV-898 to specifically refer to the guidance in Section 3. 1.1 of NUREG-1482 which indicates that these valves may be excluded from quarterly testing during power operation.
Section 3. 1.2 of NUREG-1482 discusses guidance given in Generic Letter 87-09 regarding entry into a Technical Specification Limiting Condition for Operation (LCO) to perform testing.
While entry into an LCO is not, by itself, sufficient justification to defer testing, the additional support discussed above for the subject cold shutdown justification is adequate to justify deferring testing for valves HOV-897 and HOV-898 at the R.
E. Ginna Nuclear Power Plant.
No further NRC action is required.
Sincerely,
/s/
Docket No. 50-244 cc:
See next page D ISTR I BUT ION:
Docket File PUBLIC PDI-1 R/F S.
Varga J. Zwolinski S.
Bajwa S. Little G. Vissing OGC ACRS L. Doerflein, Region I I
Guy S. Vissing, Senior Project Hanager Project Directorate I-1 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation DOCUHENT NAME:
G:(GINNA)H96751.CSJ
- See previous concurrence To receive a copy of this document, indicate in the box:
"C" = Copy without attachment enclosure "E" = Co with attachment enclosure "N" = No co y OFFICE HAHE DATE PH:PDI-1 GVIssing/rs 10/QI /96 E
LA:PDI SLittl 10/
96 0
1
/96 0
Ic> a ecor Copy ENEB*
Rllessman 10/28/96 10/
/96
Dr. Robert C. Mecredy R.E.
Ginna Nuclear Power Plant CC:
Peter D. Drysdale, 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 Mr. F. William 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
& Strawn 1400 L St.
N.W.
Washington, DC 20005-3502 Ms. Thelma Wideman
- Director, Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31
- Lyons, NY 14489 Ms. Mary Louise Meisenzahl Administrator, Monroe County Office of Emergency Preparedness 111 West Fall Road, Room 11 Rochester, NY 14620