ML17309A176
| ML17309A176 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/22/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| Shared Package | |
| ML17257A494 | List: |
| References | |
| TASK-05-11.A, TASK-5-11.A, TASK-RR LSO5-81-07-069, LSO5-81-7-69, NUDOCS 8107270072 | |
| Download: ML17309A176 (9) | |
Text
RESULATORY QORMATION DISTRIBUTION'SYH
('RIDS) l ACCESSION NBRi 8107270072'.
DOC ~ DATE,; 81/07/22.
NOTARIZED:'O DOCKE>>T! ¹ FACIL>>:50"244 Robert>> Emmet Ginna Nuclear Plant<. Unit 1E, Rocheste'r G
05000244 AUTH(,NAMEI AUTHOR AFFILIATION CRUTCHF IELDp D',
Opeiating, Reactor s Bi anch 5
RECIP ~ NAMEI RECJPIKNT>> AFFILIAT'lON MAIER'rJ", E ~.
Rochester Gas-L Electr.ic Corp'
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SUBJECT:
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/f UNITED STATES NUCLEAR REGULATORY COMMISSION WA'PHINGTON, D. C. 20555 July 22, 1981 Docket No. 50-244 LSOS07-069 Mr. John E. Maier Vice President Electric and Steam Production Rochester Gas 8 Electric Corporation 89 East Avenue Rochester, New York 14649
Dear Mr. Maier:
IMsleaae aeaanea SQNQQN v-
SUBJECT:
SEP TOPIC V-ll.A, ISOLATION OF HIGH AND LOW PRESSURE
- SYSTEMS, REVISED SAFETY EVALUATION REPORT - R.E.
GINNA NUCLEAR POWER PLANT The enclosed revised staff safety evaluation has been revised to reflect corments provided in your June 23, 1981 letter.
We still require modifi-cations to the discharge check valves in the charging subsystem.
The need to actually implement these changes will be determined during the integrated plant safety assessment.
This topic assessment may be revised in the future if your facility design is changed or if NRC criteria relating to this topic are modified before the integrated assessment is completed.
Sincerely,
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Denni s M. Crutchfiel d, Chief Operating Reactors Branch k'5 Division of Licensing
Enclosure:
Safety Evaluation Report (Revised) cc w/enclosure:
See next page
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Hr. John E. t1aier CC Harry H. Voigt, Esquire
- LeBoeuf, Lamb, Leiby and NacRae 1333 New Hampshire Avenue, N.
W.
Suite 1100 Washington, D. C.
20036 Hr. Michael Slade 12 Trailwood Circle Rochester, New York 14618 Ezra Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Jeffrey Cohen New York State Energy Office Swan Street Building Core 1, Second Floor Empire State Plaza
- Albany, New York 12223 Director, Techni ca 1 Devel opment Programs State of New York Energy Office Agency Building 2 Empire State Plaza
- Albany, New York 12223 Rochester Public Library 115 South Avenue Rochester, New York 14604 Supervisor of the Town of Ontario 107 Ridge Road West
- Ontario, New York 14519 Resident Inspector R. E. Ginna Plant c/o U. S.
NRC 1503 Lake Road
- Ontario, New York 14519 Nr. Thomas B. Cochran Natural Resources Defense Council, Inc.
1725 I Street, N.
W.
-Suite 600 Washington, D. C.
20006 U. S. Environmental Protection Agency Region II Office ATTN:
E IS COORDINATOR 26 Federal Plaza New York, New York 10007 Herbert Grossman, Esq.,
Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Richard F. Cole Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr.
Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555
ENCLOSURE TOPIC:
V-ll.A-RE UIREMENTS FOR ISOLATION OF HIGH AND LOW PRESSURE SYSTB1S INTRODUCTION Several systems that have a relatively low design pressure are connected to the reactor coolant pressure boundary.
The valves that form the interface between the high and low pressure systems must have sufficient redundancy and interlocks to assure that the low pressure systems are not subjected to coolant pressures that exceed design limits.
The problem is complicated since under certain operating modes (e.g.,
shutdown cooling and ECCS injection) these valves must open to assure adequate reactor safety.
II.
REVIEW CR'ITERIA The review criteria are presented in Section 2 of EG&G Report 1285.
III. RELATED SAFETY TOPICS AND INTERFACES The scope of review for this topic was limited to avoid duplication of effort since some aspects of the review were performed under related topics.
The related topics and the subject matter are identified below.
Each of the related topic reports contain the criteria and review guidance for its subject matter.
V-3 V-10. B VI-4 XV-16 Overpressurization Protection RHR Reliability Containment Isolation Radiological Consequences of Small LOCA Outside of Containment IV.
Topic V-ll.B is dependent on the present topic information for completion.
REVIEW GUIDELINES The review guidelines are presented in Section 7.3 of the Standard Review Plan.
V.
EVALUATION As noted in EGSG Report 1285, Ginna has three systems with a lower design pressure rating than the RCS, that are directly connected to the RCS.
The RHR, SIS, and CVCS system do not meet current licensing requirements for isolation of high and low pressure systems as specified below.
(2)
The RHR system is not in compliance with the current licensing requirements of BTP RSB 5-1 since none of the isolation valves will automatically close if RCS pressure exceeds RHR design pressure.
Also, the outboard isolation valves have no inter-locks to prevent RHR overpressurization, and the inboard valve interlocks are neither diverse nor independent.
The SIS is not in compliance with the current licensing require-ments of SRP 6.3 since the MOVs in the low pressure injection lines have no interlocks to prevent opening and the single check valve in each line is not tested.
(3)
The CVCS is not in compliance with current licensing require-ments for isolation of high and low pressure systems contained in BTP EICSB-3 since the suction and discharge line solenoid-operated valves have no interlocks to prevent system overpres-surization, and the discharge line check valves have na position indication available in the control room.
Because of the severe consequences of a LOCA outside of containment and the lack of assurance that these isolation valves could be closed against significant flow under the resulting environmental conditions, the staff proposed that the RHR isolation valves and the CVCS'uction valves should be modified to satisfy the functional requirements of BTP RSB 5-1 and BTP EICSB-3.
We also proposed installation of position indication on the charging pump discharge valves.
The licensee responded to our proposals in a letter dated June 23, 1981 (attached).
In summary, the licensee has argued that:
Additional interlocks in the RHR system are not required because the valves can not open against the differential pressure across the valves.
Loss of the differential pressure is a leakage constituting a single failure.
(2)
(3)
Isolation of the let down system and the failure of the relief valve (which is not tested) has been shown to be acceptable based on SEP Topic XV-16.
The probability of failure of a charging pump and the two check valves in the discharge path presents an acceptable small risk without further design changes.
However, the staff notes that there is no way, at this time, to provide adequate assurance that these valves are seating.
The basis for not requiring interlocks in the low pressure injection system is that, since the contractor's report was published, a check valve test program has been established, and thus, the system now satisfies the single failure criterion.
The basis for not requiring interlocks on the CVCS discharge valves is that the check valves in series with the positive displacement pumps satisfy the single failure criterion as long as check position is known (or functionability demonstrated) and the pump capacity is verified periodically.
As previously noted, in our system safety evaluation of SEP Topic V-10.8, it is not necessary to close the RHR valves automatically on increasing reactor coolant system pressure during startup because of the overpressurization protection system.
(See also Topic V-3.)
SEP Topic XV-16 results of a letdown line break outside containment are the basis for not requiring modifications in the letdown sub-system because the radiological consequences satisfy regulatory limits of 10 CFR Part 100.
VI.
CONCLUSIONS Because of the consequences o'f a LOCA outside of containment the staff proposes that the charging pump discharge check valves be modified to include position indication or a suitable check valve testing program should be initiated to assure that these valves will seat.
Our basis is that there is no way, at this time, to provide adequate assurance that these valves are seating.