ML17309A466
| ML17309A466 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/29/1991 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17262A639 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9111060399 | |
| Download: ML17309A466 (26) | |
Text
,,. -- ACCELERATED D TRIBUTION DEMONS TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9111060399 DOC.DATE: 91/10/29 NOTARIZED: NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
AUTH.NAME AUTHOR AFFILIATIONi MECREDY,R.C.
Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.
Project Directorate I-3 DOCKET g
05000244
/
05000244 A
NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
SUBJECT:
Forwards Rev 1 to QA Manual,App C, "Inservice Pump
& Valve Testing Program for 1990-1999 Interval," incorporating cold shutdown justifications
& relief requests,per Generic Ltr 89-04.
DISTRIBUTION CODE: A047D COPIES RECEIVED: LTR
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S TITLE: OR Submittal: Inservice Inspection/Testa.ng/Relief from ASME Code RECIPIENT ID CODE/NAME PDl-3 LA JOHNSON,A INTERNAL: NRR/DET/ECMB 9H NUDOCS-ABSTRACT OGC/HDS1 RES/DSIR/EIB EXTERNAL: EG&G BROWN, B
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LTTR 15 ENCL 12
t iZZiiP ( ffIfffIIII rfrl////II Ill/Ill/1Ã ROCHESTER GAS AND ELECTRIC CORPORATION o
89 EAST AVENUE, ROCHESTER N.Y. 14649-0001 ROBERT C MECREDY Vice President Olnne Nudeer Production October 29, 1991 TELEPHONE AREACODE Tttt 546 2700 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Allen R. Johnson Project Directorate I-3 Washington, D.C.
20555
Subject:
Inservice Testing (IST) Program for Pumps and Valves 1990 - 1999 Third 10-Year Interval, Revision 1
R.E.
Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Johnson:
The purpose of this letter is to update the status and. request approval of the Rochester Gas
& Electric (RG&E) Corporation IST Program for pumps and. valves at the R.E. Ginna Nuclear Power Plant.
This submittal is made in accordance with the recommendations delineated in NRC Generic Letter 89-04.
By letter dated April 15, 1991, the Safety Evaluation (SE) for the IST Program, third 10-year interval, at the R.E.
Ginna Nuclear Power Plant was issued by the Nuclear Regulatory Commission.
Rochester Gas
& Electric Corporation has reviewed the SE and its attached Technical Evaluation Report (TER) and is in the process of resolving those nineteen unresolved items identified in Appendix A of the TER as program anomalies.
The, SE requested anomalies 4, 6, 7, 10, 14, and 15 be resolved within the longer of either one (1) year or the next refueling outage and the remaining anomalies resolved within six (6) months of RG&Es receipt of the SE.
Seven of the nineteen program anomalies have been addressed and our resolution is contained in attachment 2.
Two relief requests (anomalies 6 and 9) have been withdrawn.
NRC concurrence of these resolved items is requested.
In addition, RG&E is continuing to upgrade the IST Program based.
on test experience, plant modifications and changes in program administration.
This correspondence details the changes in the current RG&E program.
All of the changes presented herein are in compliance with either ASME Section ZI and OM Codes or the guidance established in Generic Letter 89-04.
As changes are proposed to the IST Program, the NRC will be informed. of such changes as noted.
in the April 15, 1991 letter.
The following attachments are enclosed to document the status of the R.
E.
Ginna Nuclear Power Plant IST Program for pumps and 9iii060399 9ii029 PDR ADOCK 05000244 P
PDR gQ ~6ertzt'~ t
'I 1
f" a
N J
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t
valves:
Attachment 1
Attachment 2
Attachment 3
Summary of Changes to the IST Program Status of IST Program Anomalies Revision 1
to Appendix C of the Ginna Station Quality Assurance Manual.
Ten of the nineteen IST Program anomalies remain unresolved by RGRE (items 4,7,10,11,13,14,15,17,18,19) as documented. in Attachment 2
to this letter.
These will be resolved.
and addressed in a future correspondence.
It is requested that the time period for resolution of items ll, 13, 17, 18, and 19 be extended from 6 to 12 months, due to the necessity to evaluate new test methodology and plant modification feasibility.
Very truly yours, Robert C. Mecredy KAM/182 Attachments xc: Mr. Allen R. Johnson (Mail Stop 14D1)
Project Directorate I-3 Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
ATTACHMENT 1 Summar of Chan es to the IST Pro ram Note:
All changes are reflected in Revision 1 to Appendix C of the Ginna Station Quality Assurance Manual (Attachment 3 to this letter).
1)
Addition of Com onents Notes or Test Re irements 2)
Valves 4620B 4758 8418 9627A 9627B o ra hical Text Section 2.2 6.3.12 Valve Chanches Added to Remarks that this valve is Manually Operated MOV.
Added to Remarks that leak test is per-formed "In Lieu of LT-J" since this note was inadvertently omitted.
Changed from passive to active and added tests EX Q, ST-C Q and FS-C Q due to FSAR change for this containment isolation valve.
Added to Remarks that this is a
Sample Disassembly.
Added to Remarks that this is a
Sample Disassembly.
Errors Chanches Changed Parts 1,
10 for OMa-1988 to Parts 6
and 10.
Changed.
OMa-1988 to OM-1987.
1713 3508 3509 3510 3511 3512 3513 3514 3515 5907 5907A 5908 5908A 9701A Changed Changed Changed Changed Changed Changed Changed Changed Changed Changed Changed Changed Changed.
Changed P&ID from 1272-3 to 1272-2 test frequency from 10Y to test frequency from 10Y to test frequency from 10Y to test frequency from 10Y to test frequency from 10Y to test frequency from 10Y to test frequency from 10Y to test frequency from 10Y to fail position from FS-0 to fail position from FS-C to fail position from FS-0 to fail position from FS-C to valve type from GTV to GLV 5Y.
5Y.
5Y.
5Y.
5Y.
5Y.
5Y.
5Y.
FS-C.
FS-O.
FS-C.
FS-O.
Page 1 of 6
9 )->-)o60>9
$ J
3)
S ecific NRC Generic Letter 89-04 Text Section 2.10 4.1 4)
Modifications Valves 515 516 697A/B 4023 5941A/B 8655
~Chan es Added reference to Minutes of Public Meet-ing on GL 89-04.
Added ASME/ANSI OM Code, NRC GL 89-04 and the Minutes of Public Meetings on GL 89-04 as sources of this program.
Chanches Valve type changed from globe to gate per modification by EWR 3755.
Valve type changed from globe to gate per modification by EWR 3755.
Changed. relief request for CV-P-CS and CV-0-R from VR-20 to VR-29 since after the addition of the RHR mini-flowrecirculation piping by EWR
- 4675, VR-20 no longer ap-plies.
Deleted CV-P-Q, changed CV-0-R to CV-0-Q and deleted VR-23 due to the installation of flow instrumentation by EWR 4755.
Changed CV-C-R to CV-C-Q and deleted VR-25 due installation of test connections by EWR 3596.
Deleted CV-P-Q, changed CV-0-R to CV-0-Q and deleted VR-28 due to installation of flow instrumentation by EWR 4755.
5)
Resolution of Action Items Valve 842A/B 853A/B 867A/B 3992 3993 4023 Chanches Changed frequency for CV-O, C from 10Y to 6Y per NRC review.
Changed CS-16 to VR-3 and deleted CS-16 since CS-16 duplicated VR-3.
Changed frequency for CV-O, C from 10Y to 6Y per NRC review.
Deleted CS-5 since it duplicated VR-21.
Deleted CS-5 since it duplicated VR-21.
Deleted CV-C-R since it does not perform a closed. safety function per NRC review.
Page 2 of 6
I
CSJ CS-10 Clarified testing frequency concern for PORVs per NRC review.
VR-21 Added statement from CS-5 to ensure duplic-ation is maintained with CS-5.
6)
Chan es as a Result of Test Im lementation Chanches PCH01A/B/C Valve 697A/B Changed measured parameters for positive-displacement pumps and added PR-9.
Changed CV-C-CS to CV-C-Q since new test methodology permits this testing.
7)
Clarifications/U Text Section 2.3 4.1.1 5.4.e 6.4.g 8.0 Table of Acronyms rades Chanches Added OM-1987, Part 1 as a reference.
Clarified the duties of the ANII with regards to IST program.
Added SSC for safety significant classifi-cation.
Added SSC for safety significant classifi-cation.
Revised P&ID for Construction Fire Service Water per P&ID upgrade.
Added SSC for safety significant classifi-cation.
PAF03 PAF01A PAF01B PSF01A PSF01B PAC07A
- Changed, ID from PFW04 per P&ID Upgrade Changed ID from PFW02A per P&ID Upgrade Changed ID from PFW02B per P&ID Upgrade Changed ID from PFW03A per P&ID Upgrade Changed.
ID from PFW03B per P&ID Upgrade Changed Safety Class from 3 to SSC Page 3 of 6
Valve 17 270A/B 310 370B 386 392A 528 590 591 592 593 651 700 701 704A/B 720 721 723A/B 814 844A/B 845C 845D 852B 856 857A/B/C 955 1802 2850 2851 3518 3519 4269 4270 Changed valve
- size, safety class and ID from 014 per P&ID Upgrade and. changed PIT-Q to PIT-R to reflect proper frequency.
Changed ID from 0017 per P&ID Upgrade and added. PIT-R since this test is performed as part of the program.
Changed safety class from 1 to 2 per P&ID Upgrade.
Changed safety class from 2 to 1 per P&ID Upgrade.
Changed safety class from 2 to 1 per P&ID Upgrade.
Changes safety class from 1 to 2 per P&ID Upgrade.
Changed safety class from 2 to 1 per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed. valve size per P&ID Upgrade.
- Changed, ID from BAC01 per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed valve size per P&ID Upgrade,.
Changed valve size per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed P&ID coordinates per P&ID Upgrade.
Changed P&ID coordinate per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed ID from
- BSI03, valve size
- and, safety class per P&ID Upgrade.
Changed ID from
- BSI04, valve size
- and, safety class per P&ID Upgrade.
Changed P&ID coordinate per P&ID Upgrade.
Changed P&ID coordinate per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed valve size per P&ID Upgrade.
Changed safety class from 2 to 3 per P&ID Upgrade.
Changed ID from BSI01 per P&ID Upgrade.
Changed ID from BSI02 per P&ID Upgrade.
Changed, safety class from NC to SSC per Q-List.
Changed safety class from NC to SSC per Q-List.
Changed safety class from NC to SSC per Q-List.
Changed safety class from NC to SSC per Q-List.
Page 4 of 6
14
Valve 4271 4272 4609 4636 5129 5133 5134 5136 5171 5393 5733 5734 8655 9634B 10205S1 10209S1 10211S1 10213S1 10214S1 10215S1 8)
Deletions Valve Changed. safety class from NC to SSC per Q-List.
Changed safety class from NC to SSC per Q-List.
- Changed, valve type and size per P&ID Up-grade.
Changed valve type per P&ID Upgrade.
Changed P&ID and coordinate per P&ID Up-grade.
Changed safety class from NC to SSC per Q-List.
Changed safety class from NC to SSC per Q-List.
Changed safety class from NC to SSC per Q-List.
Changed safety class from NC to SSC per Q-List.
Changed P&ID coordinate per P&ID Upgrade.
Changed valve type per P&ID Upgrade.
Changed valve type per P&ID Upgrade.
Changed safety class from 3 to SSC per Q-List.
Changed valve size per P&ID Upgrade.
Changed safety class from NC to 2 per P&ID Upgrade.
Changed safety class from NC to 2 per P&ID Upgrade.
Changed safety class from NC to 2 per P&ID Upgrade.
Changed safety class from NC to 2 per P&ID Upgrade.
Changed safety class from NC to 2 per P&ID Upgrade.
Changed safety class from NC to 2 per P&ID Upgrade.
4627 4628 4635 4641 4642 Deleted LT-X-R and remark was incorrectly included.
Deleted LT-X-R and remark was incorrectly included.
Deleted LT-X-R and remark was incorrectly included'.
Deleted LT;X-R and remark was incorrectly. included,.
Deleted LT-X-R and remark was incorrectly included.
Page 5 of 6
since this test since this test since this test since this test since this test
Valve 4757 8685 8689 Deleted LT-X-R and remark since this test was incorrectly included.
Deleted from program since its basis for inclusion was that all passive valves with remote indication would have a
PIT per-formed; this valve is a manual valve with no remote indication.
Deleted from program since its basis for inclusion was that all passive valves with remote indication would have a
PIT per-formed; this valve is a manual valve with no remote indication.
Page 6 of 6
ATTACHMENT 2 Revision 0
September 27, 1991 Note:
Anomalies are paraphrased from that of Appendix A to the TER.
Status of IST Pro ram Anomalies Anomaly 1.
Relief requested (PR-6) from instrument full-scale range re-quirements and to use vibration detectors with multiple overlap-ping scales for IST of safety-related pumps.
2.
Relief requested (PR-2) from the flow rate measurement re-quirements for the diesel generator fuel oil transfer pumps (PDG02A and B) and to determine pump flow rate by measuring change in day tank level versus time.
3.
Relief requested (PR-7) from the flow rate measurement re-quirements for the service water pumps (PSW01A, 1B, 1C and 1D) and to measure the flow rate in the con-tainment fan cooler outlet lines.
Resolution The accuracy of the vibration instruments employing multiple overlapping scales used for IST of safety-related pumps is equiv-alent to that provided by a single scale in-strument that complies with the requirements of IWP-4110 and 4120.
The IST of the diesel generator fuel oil transfer pumps (PDG02A and B) involving the determination of pump flow rate by measuring the change in day tank level versus time com-plies with the Allow-able Ranges and Correc-tive Action require-ments specified in IWP-3200.
The measurement of the IST flow rate for the service water pumps (PSW01A, 1B, 1C and 1D) employing flow instru-mentation for the con-tainment fan cooler outlet lines has been established as a re-peatable test condition providing valid data for detecting pump deg-radation.
Test results are trended and evalu-ated for indication of degradation.
Date/Rev.
9-27-91/0 9-27-91/0 9-27-91/0 Page 1 of 8
Anomaly 4.
Relief requested (GR-6) from the stroke time measurement re-quirements for hand control valves which operate using a vari-able set air signal and to quarterly exer-cise but not measure
+he stroke time for these valves.
5.
Relief requested GR-7) from stroke time
-evaluation and correc-tive action require-ments and to follow a plan based on devia-tion from a reference stzoke time instead of previous stroke time.
6.
Relief requested
<VR-25) from the exer-cising frequency and test method require-ments for the emergen-cy diesel generator air start accumulator check valves 5941A and 5942A.
Resolution Resolution options are being evaluated.
The stroke time evalua-tion and corrective action plan based on deviation from a refer-ence stroke time agrees with the criteria of GL 89-04, Attachment 1, Position 6.
Withdrawn-Reverse flow closure testing of emergency diesel generator air start accumulator check valve 5941A and 5942A will be performed in accordance with PT12.7 as a result of the com-pletion of a piping modification under EWR 3596.
Date/Rev.
9-27-91/0 9-27-91/0 Page 2 of 8
Anomaly 7.
Relief requested
{VR-13) from the stroke time measure-ment requirements for the isolation valves in the auxiliary feed-water and standby aux-iliary feedwater pump recirculation lines,
- 4291, 4304,
- 4310,
. 9710A and. 9710B and to exercise but not mea-sure stroke time.
Licensee should devel-op an adequate
- means, of monitoring valve degradation.
8.
Relief requested
{VRs 5
& 17) from the exercising requireme-nts for 9627A,
- 9627B, 4601,
- 4602, 4603 and 4604 and to partially "xercise quarterly and.
to disassemble and manually full-stroke exercise on a sampling basis during refueling outages.
9.
Relief requested
{VR-23) from the exer-cising requirements for 4023, TDAFW recir-culation check valve and. to verify full-stroke capability by disassembly and inspe-ction each refueling outage.
Resolution Resolution options are being evaluated.
After disassembly
- and, inspection of 9627A,
- 9627B, 4601,
- 4602, 4603, and 4604, on a sampling basis a par-tial flow test of the affected, valve is per-formed per PTs-36Q or 2.7 before returning the valve to service.
As part of the Relia-bility Centered Main-tenance
- Program, RG&E's actively pursuing non-intrusive diagnos-tic technology which will be employed. for the 1ST Program.
Withdrawn Full-stroke open exer-cising of 4023 will be performed per PT-16Q-T as a result of the in-stallation of flow in-strumentation under EWR 4755.
Date/Rev.
9-27-91/0 9-27-91/0 Page 3 of 8
B
Anomaly 10.
Relief requested (VR-6) from the stroke time measurement re-quirements for 4324, 4325 and 4326, sole-noid operated valves in the service water lines to the AFW pump bearings and. to exer-cise quarterly but not measure stroke time.
Licensee should devel-op an adequate means of monitoring valve degradation.
11.
Relief requested (VR-7) from the remote position indication verification require-ments for 434 and 435, the pressurizer safety relief valves and to verify valve remote position indication during refueling out-ages by simulating valve actuation by moving the valve's coil.
Granted, if valve position indica-tion is verified to accurately reflect obturator position during the valve set-point testing.
Resolution Resolution options are being evaluated.
Resolution options are being evaluated.
Page 4 of 8
Anomaly 12.
Relief requested (VRs 8
& 9) from the exercising requirem-ents for 842A,
- 842B, 867A and 867B, the accumulator discharge check valves and com-bined accumulator/
safety injection pump check valves and to partially stroke exer-cise quarterly and disassemble and in-spect to verify full-stroke capability once every 10 years.
13.
Relief requested (VR-24) from the exer-cising requirements for 862A and 862B and proposed to exercise these valves quarterly using a mechanical exerciser and measur-ing the breakaway force and comparing this force to a refer-ence value when the valve is known to be in good condition.
Licensee must also continue to measure the running force re-quired to exercise these valves to their fully open position.
Resolution Disassembly of 842A,
- 842B, 867A and 867B shall occur so that the interval between exam-ining each valve is not longer than once every 6 years.
Once a non-intrusive diagnostic methodology is incorpo-rated by RGGE, it will be employed while per-forming a reduced flow test each refueling outage.
Resolution options are being evaluated.
Date/Rev.
9-27-91/0 Page 5 of 8
Anomaly 14.
Relief requested (VR-18) from the stroke time measure-ment requirements for
- 5907, 5907A, 5908 and 5908A and to verify proper valve operabil-ity by observing their operation during quar-terly diesel testing without measuring stroke time. Licensee should develop a meth-nd to monitor for valve degradation.
15.
Relief requested iVR-2) from the exer-cising requirements for 5960A and 5960B, check valves in the diesel day tank over-flow lines to the sto-rage tanks and to dis-assemble and inspect during refueling out-ages without partial flow test after reas-sembly.
Licensee should be able to ade-quately test these valves or take other actions.
16.
Cold shutdown justifications CS-5, CS-16 and CS-30 iden-tify test frequencies other than during cold shutdowns.
Since the affected valves are included in relief requests VR-21, VR-3, VR-14 and VR-20, de-lete CS-5, CS-16 and CS-30.
Resolution Resolution options are being evaluated.
Resolution options are being evaluated.
Cold shutdown justifi-cations CS-5 and CS-16 have been deleted.
from Revision 1 to Appendix C to the Quality Assur-ance Manual.
CS-30 has not been deleted since relief requests VR-20 no longer applies to 697A and 697B due to the installation of the RHR mini-flow recircu-lation piping under EWR 4675.
Date/Rev.
9-27-91/0 Page 6 of 8
Anomaly 17.
The licensee has not provided adequate technical basis in cold shutdown justifi-cation CS-12 to demon-strate the impracti-cality of quarterly exercising 813 and 814.
Licensee states exercising these valves could result in thermal stress to the reactor vessel sup-ports.
Licensee must exercise quarterly or revise the cold shut-down justification.
18.
Cold shutdown justification CS-20 states that 8419 is normally closed during power operation and is not required to change position to perform its safety function.
8419 is listed as an Active Category A/C valve in program.
If 8419 were open during power operations it would have to change position.
8419 should be exercised quarter-ly Resolution Resolution options are being evaluated.
Resolution options are being evaluated.
Date/Rev.
Page 7 of 8
'T
~
Anomaly l9.
Cold shutdown justification CS-29 states that 9227 and 9229 are normally closed during power operation and are not required to change position to perform their safety function.
9227 is listed as an Active Category A
valve and 9229 is lis-ted as an Active Cate-gory A/C valve.
Xf 9227 or 9229 were open during power operation they would have to change position.
9227 and 9229 should be exercised quarterly.
Resolution Resolution options are being evaluated.
Date/Rev.
Page 8 of 8