ML17264B047

Forwards Responses to RAI Re 970819 LAR for LCO 3.6.6

ML17264B047
Person / Time
Site:	Ginna
Issue date:	09/29/1997
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9710030211
Download: ML17264B047 (7)

Text

CATEGORY,1 r

REGULAT INFORMATION DISTRIBUTIONOCSTEM (RIDE)

ACCESSIQN -NBR:9710030211 DOC.DATE: 97/09/29 NOTARIZED: YES DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G

05000244 AUTH.NAME.

AUTHOR AFFILIATION MECREDY,R.C."

Rochester Gas 6 Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION VISSING G.S.,

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SUBJECT:

Forwards response to request for addi info re 970819 LAR for LCO 3.6.6.

DISTRIBUTION CODE:

A001D COPIES RECEIVED:LTR ENCL SIZE:

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

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AND ROIAESTER GASANDELECTRIC CORPORATION ~ 89 EASTAYENUE, ROCHESTER, N Y Idbf9-0001 AREA CODE 716 5'-270O ROBERT C. MECREDY Vice President Nuclear Operations September 29, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn:

Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555

Subject:

Response to Request for Additional Information Related to August 19, 1997 License Amendment Request for LCO 3.6.6 Rochester Gas &Electric Corporation R.E. Ginna Nuclear Power Plant Docket No. 50-244

Reference:

Letter from G.S. Vissing, NRC, to R.C. Mecredy, RG&E,

Subject:

Reqrrest for AdditiorralInformation - Testing ofEmergency Core Cooling System (ECCS)

Valves (TAC¹. M99460), dated September 16, 1997.

Dear Mr. Vissing,

Attached please find responses to the questions documented in the referenced letter. Please let us know ifwe may be offurther assistance.

Very truly yours, Robert C. Mecred 97i00302ii 970929 PDR ADQCK 05000244 P

PDR Subscribed and sworn to before me on this 29th day ofSeptember 1997.

tQggq Notary Public DEBORAH A.PIPERNI Notary Public tn the State of New Yorit ONTARIO COUNTY Commission Expires Nov. 23, 19,.rKr7

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MD&957

~ Attachment xc:

U.S. Nuclear Regulatory Commission Mr. Guy Vissing (Mail Stop 14B2)

PWR Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King ofPrussia, PA 19406 Ginna Senior Resident Inspector Mr. F. WilliamValentino, President New York State Energy, Research, and Development Authority 2 Empire State Plaza Albany, NY 12223-1253

Yourproposed change to the Ginna TS wouldprovide a 2-hour allo~ed outage timefor both containment spray pumps, for the purpose oftesting, whileinMODE 4, certain ECCS valve interlocks andfor differentialpressure testing ofcertain residual heat removal system valves. Although operability is requiredin Mode 4, itis not clear to the staffwhyitis necessary or desirable to perform the tests inMode 4. (Shouldn't these tests be performed prior to entry inMode 4?). Please explain the reason for testing in Mode 4.

In order to perform the interlock testing, the residual heat removal (RHR) system must be completely isolated from the reactor coolant system (RCS). This isolation is necessary to prevent draining the RCS and refueling cavity back to the containment sump due to valve lineups (i.e., from TS bases Figure 3.5.2-1, with MOVs 700 and 701 open, the RCS can be gravity feed to containment sump B when MOVs 850A and 850B (RHR pump suction valves) are opened).

There are interlocks on MOV700 and 721 with respect to MOVs 850A and 850B to prevent this from occurring (i.e., MOV850A and 850B can only be opened when these two MOVs are closed).

Also, as shown on the bases drawing, Ginna Station only has a single line both from and to the RCS during shutdown.

Closure of MOVs 700 and 721 prevents both trains ofRHR from providing any decay heat removal.

The subsequent failure of~ line to re-open followingthe test (i.e., one valve) would continue to fail both trains ofRHR.

The TS currently allow isolation ofall RHR during MODE 6 for limited periods oftime (see LCO 3.9.4). For Ginna Station, this LCO is typically only applicable when moving fuel since at other times, less than 23 ft ofwater is above the flange due to other refueling activities. Based on risk considerations, RG&E proposes to isolate all RHR in MODE 4 when the steam generators are available for core cooling and there is~ design basis accident with requires RHR or containment spray (CS) in this mode (see question 3 below). This is, based on shutdown risk considerations, RG&E does not wish to isolate all RHR in MODE 6 when no other means ofcore cooling would be available ifother testing periods are available. It is noted that LCO 3.4.7 has a note allowing termination of RHR during MODE 5 with the RCS loops filled. However, the bases for this note are specific on its uses and would require a TS amendment to allows use ofthis note for the interlock and dp testing (i.e., this would be an unreviewed safety question).

Nonetheless, use ofthis LCO would again require termination ofall core cooling during the test.

To perform dp testing, RG&E can, and has, performed the necessary testing in MODE 6 when CS is not required (i.e., during drain down ofthe cavity in preparation for startup).

However, to gain greater flexibilityin outage scheduling, and to prevent a failed dp test to cause a delayed startup, RG&E wishes to perform this testing in MODE 4 during initial shutdown.

Therefore, any performance issues can be addressed during the subsequent outage instead ofpreventing startup.

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Please identify the specific surveillance requirements that apply to these tests.

I The specific interlock testing is to verify that MOVs 857A/B/C cannot be opened unless:

(1) MOV896A or 896B is closed; (2) MOV 897 or 898 is closed; and (3) MOV850A and 850B are open.

There is no specific TS surveillance requirement for this interlock testing. However, the bases for LCO 3.5.2 discusses these interlocks in detail in the Background Section and how their inoperability would prevent the transfer to the recirculation phase ofan accident.

Consequently, RG&E tests these interlocks on a refueling outage basis since they cannot be performed at power.

RG&E originally considered adding a specific surveillance to LCO 3.5.2 as part ofthe proposed amendment request but due to the desire to allow dp testing in MODE 4, elected not to add this surveillance requirement.

That is, the dp testing would not be a surveillance requirement which created difhculty in the wording for LCO 3.6.6. However, RG&E would consider adding a new surveillance requirement to LCO 3.5.2 consistent with the current testing practices ifrequired for this amendment request.

Itis standard TSpolicy that eqiiipment be declared inoperable whenever rendered inoperable for testing. Ifthe stafffinds that itis indeed desirable or necessary to disable both containment spray pumps during Mode 4, we willerplore the possibility of providing temporary (2-hour) relieffrom any unnecessary administrative actions and Emergency Plan notifications associated with the degraded condition.

We would condition this reliefto include a limitation that allfan coolers be operable.

As part ofthe internal approval process, the Ginna Station PORC and NSARB required that Operations personnel administratively restrict the use ofthe proposed note to conditions when all four containment recirculation fan cooler units were operable.

Therefore, RG&E finds it acceptable to add this restriction to the proposed note to LCO 3.6.6.

With respect to rendering equipment inoperable during testing, the procedures for the interlock testing specify that the CS pumps must be in "pull-stop." This precaution renders the pumps incapable ofautomatic starting and therefore inoperable; however, they can be manually started from the control room. There is no design basis accident at Ginna Station requiring the CS or RHR systems in MODE 4 (see bases for LCO 3.5.3). The bases for LCO 3.5.3 specifically allow 10 minutes for RHR system configuration to the injection mode in order to be considered operable due to this fact. The dp and interlock testing can easily be terminated and the RHR system reconfigured within this 10 minutes such that no other changes to TS are required.

4.

During the interlock and differentialpressure testing, are any additional systems (besides

'he containment spray systems) renderedinoperable, i.e., are 3.5.3 and 3.5.4 operability requirements met during the entire 2-hour test period?

The operability requirements for LCO 3.5.3 continue to be met as described in the response for question 3 above.

The operability for LCO 3.5.4 also continues to be met since this LCO only addresses the volume and boron concentration within the RWST.

The isolation valves between the RWST and other systems (i.e., RHR, CS, and SI) are addressed in LCOs 3.5.2, 3.5.3, and 3.6.6 (see Note 1 to bases Figure 3.5.2-1).

Therefore, only LCO 3.6.6 needs to be modified to support the proposed testing in MODE 4.