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 DOCKET g FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATIONi MECREDY,R.C. Rochester Gas & Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R. Project Directorate I-3
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 ( ENCL ( SIZE: /~7 ~ S TITLE: OR Submittal: Inservice Inspection/Testa.ng/Relief from ASME Code
/
NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 A
RECIPIENT COPIES RECIPIENT COP1ES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-3 LA 1 0 PD1-3 PD 1 1 D JOHNSON,A 2 2 INTERNAL: NRR/DET/ECMB 9H 1 1 NRR/DET/EMEB 7E 1 1 NUDOCS-ABSTRACT 1 1 OC LFMB 1 0 OGC/HDS1 1 0 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: EG&G BROWN, B 1 1 EG&G RANSOME,C 1 '1'
, NRC PDR 1 1 NSIC 1 yO pg'pg7$ l! ~ f R
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D NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 12
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( ffIfffIIII Ill/Ill/1Ã rfrl////II ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER N.Y. 14649-0001 ROBERT C MECREDY TELEPHONE Vice President AREA CODE Tt tt 546 2700 Olnne Nudeer Production October 29, 1991 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 ~6ertzt'~ t PDR P
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valves: 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 Valves Chanches 4620B Added to Remarks that this valve is '
Manually Operated MOV.
4758 Added to Remarks that leak test is per-formed "In Lieu of LT-J" since this note was inadvertently omitted.
8418 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.
9627A Added to Remarks that this is a Sample Disassembly.
9627B Added to Remarks that this is a Sample Disassembly.
- 2) o ra hical Errors Text Section Chanches 2.2 Changed Parts 1, 10 for OMa-1988 to Parts 6 and 10.
6.3.12 Changed. OMa-1988 to OM-1987.
Valve 1713 Changed P&ID from 1272-3 to 1272-2 3508 Changed test frequency from 10Y to 5Y.
3509 Changed test frequency from 10Y to 5Y.
3510 Changed test frequency from 10Y to 5Y.
3511 Changed test frequency from 10Y to 5Y.
3512 Changed test frequency from 10Y to 5Y.
3513 Changed test frequency from 10Y to 5Y.
3514 Changed test frequency from 10Y to 5Y.
3515 Changed test frequency from 10Y to 5Y.
5907 Changed fail position from FS-0 to FS-C.
5907A Changed fail position from FS-C to FS-O.
5908 Changed fail position from FS-0 to FS-C.
5908A Changed. fail position from FS-C to FS-O.
9701A Changed valve type from GTV to GLV Page 1 of 6
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- 3) S ecific NRC Generic Letter 89-04 Text Section ~Chan es 2.10 Added reference to Minutes of Public Meet-ing on GL 89-04.
4.1 Added ASME/ANSI OM Code, NRC GL 89-04 and the Minutes of Public Meetings on GL 89-04 as sources of this program.
- 4) Modifications Valves Chanches 515 Valve type changed from globe to gate per modification by EWR 3755.
516 Valve type changed from globe to gate per modification by EWR 3755.
697A/B 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-flow recirculation piping by EWR 4675, VR-20 no longer ap-plies.
4023 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.
5941A/B Changed CV-C-R to CV-C-Q and deleted VR-25 due installation of test connections by EWR 3596.
8655 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 Chanches 842A/B Changed frequency for CV-O, C from 10Y to 6Y per NRC review.
853A/B Changed CS-16 to VR-3 and deleted CS-16 since CS-16 duplicated VR-3.
867A/B Changed frequency for CV-O, C from 10Y to 6Y per NRC review.
3992 3993 Deleted CS-5 since Deleted CS-5 since it duplicated VR-21.
itit duplicated VR-21.
4023 Deleted CV-C-R since 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 Changed measured parameters for positive-displacement pumps and added PR-9.
Valve 697A/B Changed CV-C-CS to CV-C-Q since new test methodology permits this testing.
- 7) Clarifications/U rades Text Section Chanches 2.3 Added OM-1987, Part 1 as a reference.
4.1.1 Clarified the duties of the ANII with regards to IST program.
5.4.e Added SSC for safety significant classifi-cation.
6.4.g Added SSC for safety significant classifi-cation.
8.0 Revised P&ID for Construction Fire Service Water per P&ID upgrade.
Table of Acronyms Added SSC for safety significant classifi-cation.
PAF03 Changed, ID from PFW04 per P&ID Upgrade PAF01A Changed ID from PFW02A per P&ID Upgrade PAF01B Changed ID from PFW02B per P&ID Upgrade PSF01A Changed ID from PFW03A per P&ID Upgrade PSF01B Changed. ID from PFW03B per P&ID Upgrade PAC07A Changed Safety Class from 3 to SSC Page 3 of 6
Valve Changed valve size, safety class and ID from 014 per P&ID Upgrade and. changed PIT-Q to PIT-R to reflect proper frequency.
17 Changed ID from 0017 per P&ID Upgrade and added. PIT-R since this test is performed as part of the program.
270A/B Changed safety class from 1 to 2 per P&ID Upgrade.
310 Changed safety class from 2 to 1 per P&ID Upgrade.
370B Changed safety class from 2 to 1 per P&ID Upgrade.
386 Changes safety class from 1 to 2 per P&ID Upgrade.
392A Changed safety class from 2 to 1 per P&ID Upgrade.
528 Changed valve size per P&ID Upgrade.
590 Changed valve size per P&ID Upgrade.
591 Changed valve size per P&ID Upgrade.
592 Changed valve size per P&ID Upgrade.
593 Changed. valve size per P&ID Upgrade.
651 Changed, ID from BAC01 per P&ID Upgrade.
700 Changed valve size per P&ID Upgrade.
701 Changed valve size per P&ID Upgrade,.
704A/B Changed valve size per P&ID Upgrade.
720 Changed valve size per P&ID Upgrade.
721 Changed valve size per P&ID Upgrade.
723A/B Changed P&ID coordinates per P&ID Upgrade.
814 Changed P&ID coordinate per P&ID Upgrade.
844A/B Changed valve size per P&ID Upgrade.
845C Changed ID from BSI03, valve size and, safety class per P&ID Upgrade.
845D Changed ID from BSI04, valve size and, safety class per P&ID Upgrade.
852B Changed P&ID coordinate per P&ID Upgrade.
856 Changed P&ID coordinate per P&ID Upgrade.
857A/B/C Changed valve size per P&ID Upgrade.
955 Changed valve size per P&ID Upgrade.
1802 Changed safety class from 2 to 3 per P&ID Upgrade.
2850 Changed ID from BSI01 per P&ID Upgrade.
2851 Changed ID from BSI02 per P&ID Upgrade.
3518 Changed, safety class from NC to SSC per Q-List.
3519 Changed safety class from NC to SSC per Q-List.
4269 Changed safety class from NC to SSC per Q-List.
4270 Changed safety class from NC to SSC per Q-List.
Page 4 of 6
14 Valve 4271 Changed. safety class from NC to SSC per Q-List.
4272 Changed safety class from NC to SSC per Q-List.
4609 Changed, valve type and size per P&ID Up-grade.
4636 Changed valve type per P&ID Upgrade.
5129 Changed P&ID and coordinate per P&ID Up-grade.
5133 Changed safety class from NC to SSC per Q-List.
5134 Changed safety class from NC to SSC per Q-List.
5136 Changed safety class from NC to SSC per Q-List.
5171 Changed safety class from NC to SSC per Q-List.
5393 Changed P&ID coordinate per P&ID Upgrade.
5733 Changed valve type per P&ID Upgrade.
5734 Changed valve type per P&ID Upgrade.
8655 Changed safety class from 3 to SSC per Q-List.
9634B Changed valve size per P&ID Upgrade.
10205S1 Changed safety class from NC to 2 per P&ID Upgrade.
10209S1 Changed safety class from NC to 2 per P&ID Upgrade.
10211S1 Changed safety class from NC to 2 per P&ID Upgrade.
10213S1 Changed safety class from NC to 2 per P&ID Upgrade.
10214S1 Changed safety class from NC to 2 per P&ID Upgrade.
10215S1 Changed safety class from NC to 2 per P&ID Upgrade.
- 8) Deletions Valve 4627 Deleted LT-X-R and remark since this test was incorrectly included.
4628 Deleted LT-X-R and remark since this test was incorrectly included.
4635 Deleted LT-X-R and remark since this test was incorrectly included'.
4641 Deleted LT;X-R and remark since this test was incorrectly. included,.
4642 Deleted LT-X-R and remark since this test was incorrectly included.
Page 5 of 6
Valve 4757 Deleted LT-X-R and remark since this test was incorrectly included.
8685 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.
8689 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 Resolution Date/Rev.
- 1. Relief requested The accuracy of the (PR-6) from instrument vibration instruments full-scale range re- employing multiple quirements and to use overlapping scales used vibration detectors for IST of safety-with multiple overlap- related pumps is equiv-ping scales for IST of alent to that provided safety-related pumps. by a single scale in-strument that complies with the requirements of IWP-4110 and 4120. 9-27-91/0
- 2. Relief requested The IST of the diesel (PR-2) from the flow generator fuel oil rate measurement re- transfer pumps (PDG02A quirements for the and B) involving the diesel generator fuel determination of pump oil transfer pumps flow rate by measuring (PDG02A and B) and to the change in day tank determine pump flow level versus time com-rate by measuring plies with the Allow-change in day tank able Ranges and Correc-level versus time. tive Action require-ments specified in IWP-3200. 9-27-91/0
- 3. Relief requested The measurement of the (PR-7) from the flow IST flow rate for the rate measurement re- service water pumps quirements for the (PSW01A, 1B, 1C and 1D) service water pumps employing flow instru-(PSW01A, 1B, 1C and mentation for the con-1D) and to measure the tainment fan cooler flow rate in the con- outlet lines has been tainment fan cooler established as a re-outlet lines. peatable test condition providing valid data for detecting pump deg-radation. Test results 9-27-91/0 are trended and evalu-ated for indication of degradation.
Page 1 of 8
Anomaly Resolution Date/Rev.
- 4. Relief requested Resolution options are (GR-6) from the stroke being evaluated.
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 The stroke time evalua-GR-7) from stroke time tion and corrective
-evaluation and correc- action plan based on tive action require- deviation from a refer-ments and to follow a ence stroke time agrees plan based on devia- with the criteria of GL tion from a reference 89-04, Attachment 1, stzoke time instead of Position 6.
previous stroke time. 9-27-91/0
- 6. Relief requested Withdrawn-
<VR-25) from the exer- Reverse flow closure cising frequency and testing of emergency test method require- diesel generator air ments for the emergen- start accumulator check cy diesel generator valve 5941A and 5942A air start accumulator will be performed in check valves 5941A and accordance with PT12.7 5942A. as a result of the com-pletion of a piping modification under EWR 3596. 9-27-91/0 Page 2 of 8
Anomaly Resolution Date/Rev.
- 7. Relief requested Resolution options are
{VR-13) from the being evaluated.
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 After disassembly and,
{VRs 5 & 17) from the inspection of 9627A, exercising requireme- 9627B, 4601, 4602, nts for 9627A, 9627B, 4603, and 4604, on a 4601, 4602, 4603 and sampling basis a par-4604 and to partially tial flow test of the "xercise quarterly and. affected, valve is per-to disassemble and formed per PTs-36Q or manually full-stroke 2.7 before returning exercise on a sampling the valve to service.
basis during refueling As part of the Relia-outages. bility Centered Main-tenance Program, actively pursuing RG&E's non-intrusive diagnos-tic technology which will be employed. for 9-27-91/0 the 1ST Program.
- 9. Relief requested Withdrawn
{VR-23) from the exer- Full-stroke open exer-cising requirements cising of 4023 will be for 4023, TDAFW recir- performed per PT-16Q-T culation check valve as a result of the in-and. to verify full- stallation of flow in-stroke capability by strumentation under EWR disassembly and inspe- 4755.
ction each refueling 9-27-91/0 outage.
Page 3 of 8
B Anomaly Resolution
- 10. Relief requested Resolution options are (VR-6) from the stroke being evaluated.
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 Resolution options are (VR-7) from the remote being evaluated.
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.
Page 4 of 8
Anomaly Resolution Date/Rev.
- 12. Relief requested Disassembly of 842A, (VRs 8 & 9) from the 842B, 867A and 867B exercising requirem- shall occur so that the ents for 842A, 842B, interval between exam-867A and 867B, the ining each valve is not accumulator discharge longer than once every check valves and com- 6 years. Once a non-bined accumulator/ intrusive diagnostic safety injection pump methodology is incorpo-check valves and to partially stroke exer-rated by RGGE, it be employed while per-will cise quarterly and forming a reduced flow disassemble and in- test each refueling spect to verify full- outage.
stroke capability once 9-27-91/0 every 10 years.
- 13. Relief requested Resolution options are (VR-24) from the exer- being evaluated.
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.
Page 5 of 8
Anomaly Resolution Date/Rev.
- 14. Relief requested Resolution options are (VR-18) from the being evaluated.
stroke time measure-ment requirements for 5907, 5907A, 5908 and 5908A and to verify proper valve operabil-ity by observing quar-their operation during terly diesel testing without measuring stroke time. Licensee should develop a meth-nd to monitor for valve degradation.
- 15. Relief requested Resolution options are iVR-2) from the exer- being evaluated.
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 Cold shutdown justifi-justifications CS-5, cations CS-5 and CS-16 CS-16 and CS-30 iden- have been deleted. from tify test frequencies other than cold Revision 1 to Appendix C to the Quality Assur-during shutdowns. Since the ance Manual. CS-30 has affected valves are not been deleted since included in relief relief requests VR-20 requests VR-21, VR-3, no longer applies to VR-14 and VR-20, de- 697A and 697B due to lete CS-5, CS-16 and the installation of the CS-30. RHR mini-flow recircu-lation piping under EWR 4675. 9-27-91/0 Page 6 of 8
Anomaly Resolution Date/Rev.
- 17. The licensee has Resolution options are not provided adequate being evaluated.
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 Resolution options are justification CS-20 being evaluated.
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 Page 7 of 8
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Anomaly Resolution Date/Rev.
l9. Cold shutdown Resolution options are justification CS-29 being evaluated.
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.
Page 8 of 8