ML17264B023

Provides Info Which Supersedes Re Cold Shutdown Justification CS-10 & CS-36 Inservice Testing Program for Pumps & Valves.Justifications Do Not Require NRC Approval

ML17264B023
Person / Time
Site:	Ginna
Issue date:	09/15/1997
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9709230029
Download: ML17264B023 (7)

Text

CATEGORY 1 REGULAT(

INFORMATION DISTRIBUTIONISTEM (RIDE)

ACCESSION NBR:9709230029 DOC.DATE: 97/09/15 NOTARIZED: NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G

AUTH.HARE'UTHOR AFFILIATION MECREDY,R.C.

Rochester Gas

& Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION VISSINGFG.

SUBJECT:

Discusses cold shutdown justification CS-10 a CS-36 to Rev of IST program for pumps a valves 1990-99 third 10-YR interval. Cold shutdown justifications do not require NRC approval because of no deviations from code.

DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code GL-8 NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).

DOCKET ¹ 05000244

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RECIPIENT ID CODE/NAME PD1-1 LA VISSING,G.

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U NOTE TO ALL "RIDS" RECIPIENTS:

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ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:

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AND ROCHESTER GASANDElECTRIC CORPORATION ~ 89 EASTAVENUE, ROCHESTER, N. Y Id&f9-0001 AREA CODE716 5'-2700 ROBERT C. MECREDY Vice President Nvcleor operations September 15, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn:

Guy Vissing Project Directorate I-1 Washington, D.C.

20555

Subject:

Cold Shutdown Justification CS-10 and CS-36 Inservice Testing (IST)

Program for Pumps and Valves 1990-1999 Third 10-Year Interval, Revision 2

R.E.

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

Letter from R.C. Mecredy, RG&E/ to Guy S. Vissing,

NRC, "Cold Shutdown Justification CS-10 and CS-36 Inservice Testing (IST) Program for Pumps and Valves", dated July 31) 1997

Dear Mr. Vissing:

In the referenced

letter, RG&E requested NRC approval of Cold Shutdown Justifications CS-10 and CS-36.

In accordance with NUREG-

1482, cold shutdown justifications do not require NRC approval, since they are not deviations from the Code.

This letter, which is being provided for information only, supersedes the referenced letter in its entirety.

The revision to CS-10 is not intended as a

change but to more clearly define the testing intervals and to more closely tie testing to plant cooldown low temperature overpressure protection (LTOP) enabling requirements.

Since LTOP enabling requirements change due to reactor pressure vessel

aging, the CS-10 testing point during cooldown will also change.

This would necessitate revisions throughout plant life since a temperature and pressure point are specifically identified in the current CS-10.

The basis for the LTOP enabling is controlled through the Pressure-Temperature Limits Report (PTLR) which uses a methodology that has received prior NRC approval.

Cold justification CS-36 has been, generated to address exercising of two newly-incorporated manual valves 3506 and 3507.

The valves serve as block valves from the main steam line to the atmospheric relief valves (ARVs).

They have been added to the inservice testing program (IST) as a result of implementation of the Improved Technical Specifications (ITS).

Testing these valves at power renders the ARVs unable to perform their relief function and allow 4'or emergency heat removal.

The testing also requires the ARVs to 9709'230029

970915, PDR ADOCK 05000244 P

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be manually stroked during power operation which introduces the possibility of power excursions.

RG&E will employ radiographic examinations to verify disk position.

Further discussion is provided in the attached cold shutdown justification.

These justifications will be included in the Inservice Testing Program document.

Since this transmittal is provided as information only, no action on your part is required.

Very truly yours, Robert C. Mecredy REZ/475 xc:

Mr. Guy Vissing (Mail Stop 14B2)

Project Directorate I-1 Washington, D.C.

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

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V Valves:

~Sstem:

Cold Shutdown Justification CS-10 (Revised)

430, 431C Reactor Coolant/Pressurizer P&ID:

33013-1258 CatecaCor

.r:

B, Active Class:

1 Function:

These valves serve as the pressurizer power-operated relief valves (PORVs).

Normally closed, these valves open to protect against excessive pressure surges.

Justification: Exercising these valves during power operation could cause unplanned pressure transients in the RCS resulting in a reactor trip.

When the plant is in a

cold shutdown condition, testing will be performed on a quarterly (92 day) basis.

Testing will also be performed prior to reaching LTOP conditions when cooling down from power operations and it has been ~

92 days

+

25~m since the last test.

P I

Cold Shutdown Justification CS-36 (New)

Valves:

~sstem:

CatecaCor Function:

3506, 3507 Main Steam B, Active P&ID:

Class:

33013-1231 These are manual valves that serve as main steam inlet block valves to the atmospheric relief valves (ARVs 3410 and 3411) for both steam generators.

These valves must, close to isolate its respective ARV, if failed.

These valves must open to permit emergency heat removal from the RCS through its respective ARV.

D Justification:

During power operation, these normally-open valves are exposed to steam generator steam pressure.

These valves also have bypass valves installed around them.

Although test connections are currently installed downstream of each set of inlet block valves and bypass

valves, quarterly testing at power is impractical since this testing would require costly modifications to install test manifolds to minimize the potential for test personnel injury.

This testing would require the manual operation of the associated ARV at power which creates the unnecessary potential for a

reactor power excursion due to excessive heat removal.

A safety hazard would always exist if periodic exercising of these valves under high pressure steam were performed due to the unknown potential for leakage past either the inlet or bypass valve.

Radiographic testing has been performed for valves 3506 and 3507 and proven to successfully demonstrate positive indication of disk position.

Exercising of these valves will be performed during cold shutdown employing radiographic testing of the valves in both the open and closed positions which provides positive indication of the required change of disk position per IWV-3412.

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