ML20012D283

Responds to Issues Discussed During 900307 Telcon W/Util & Eg&G Re Inservice Testing Program Status & Relief Request. Valves 5960A & 5960B Will Be Disassembled to Verify Forward Flow.Relief Requests PR-8 & VR-25 Encl

ML20012D283
Person / Time
Site:	Ginna
Issue date:	03/14/1990
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson Office of Nuclear Reactor Regulation
References
NUDOCS 9003270143
Download: ML20012D283 (4)

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ROCHESTER GAS AND ELECTRIC CORPORATION e 89 EAST AVENUE, ROCHESTER, N.Y.146 h'0001l March 14, 1990 ,, m -

aara cous ne 546-2700 I

U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson Project Directorate I-3 Washington, D.C. 20555

Subject:

Inservice Testing Program Status-and Relief Request R.E. Ginna-Nuclear Power Plant Docket No. 50-244

Dear Mr. Johnson:

This correspondence is in response to the issues discussed during the conference call between RG&E, the NRC and EG&G on March 7, 1990. The comments concerning the. Third Interval Inservice Test Program submittal are addressed as follows:

1. -Examples of adverse effects due to securing- nitrogen,

' instrument air, and service air for an extended period as stated in GR-3 would-be loss of primary pressure-control-due to loss, of pressurizer spray and reactor coolant pump seal water. Also, safety would be jeopardized due to the loss of low; pressure ~ overpressure protection and nitrogen to SI accumulators and pressurizer, relief tank. Refueling operation would-be-hindered by. loss of refueling crane control.

2. The safety function performed by ' valves 5960A and 5960B referred to in VR-2 is to provide overpressure protection for the fuel oil day tank. Disassembly will be performed to verify forward flow.-

3. It is extremely impractical ~ to exercise Valves 9627A and 9627B-e ,

referred to in VR-5 because it would contaminate the Standby

. "* Auxiliary Feedwater System with service water. Flushing-and verification activities that would be necessary to restore the lo Standby Auxiliary Feedwater System to its required cleanliness time-consuming and may not be completely effective.

$g 'is mo Furthermore, the secondary chemistry consequences are very

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+o severe should the Standby Auxiliary Feedwater System actuate

.with service water in the lines.

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$8 4.' There has been no demonstration that any currently available Q

c4 diagnostic testing for rapid acting Valves 5907, 5907A, 5908 and 5908A referred to in VR-18 would provide useful trending

&! information. VR-18 is requested to be approved as submitted.

Q Note that the Ginna valves are tested on a frequent (monthly) periodic basis.

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5 ~. 'It is not desirable to disable the Low Temperature overpressure Protection System for an extended period as would be required to test Check Valves 8606A and 8606B referred to in VR-19, particularly at cold- shutdown when this system performs its safety function. Testing will'be performed during refueling as submitted.

6. VR-22 submitted for SI Accumulator Isolation Valves 841 and 865 will be deleted and a cold shutdown justification initiated in its place.

7. The close safety function for Valve 4023 referred to in VR-23' will be deleted.

g! RG&E: continues to be an active participant in nuclear test code Q, committees ( ASME, ANS) and related generic concerns such as service M water system and check valve testing (NIC). Should viable alternative diagnostic test methods emerge, application of these methods at Ginna would be evaluated for possible IST Program inclusion.

-Attached are copies of PR-8 and VR-25 that were inadvertently omitted from_the submittal. Copies of the revised relief requests and cold shutdown justification discussed in this correspondence will be forwarded upon completion.

Very truly yours, Robert C. Mccredy Division Manager Nuclear Production GJW\090 Attachment 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 1

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( , RELIEF REQUEST NO. PR-8 J SYSTEM: Residual Heat Removal (RHR)

PUMPS: Residual Heat Removal Pumps (ACAPRH 1,2) .l

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SAFETY CLASS: 2 FUNCTION: Supply safety injection flow to the reactor vessel.

TEST REQUIREMENT: The resistance of the system shall be varied until either the measured '

differential pressure or the measured flow rate equals the corresponding reference value (IWP-3100).

BASIS-FOR RELIEF: During power operation RHR pumps'can only be tested utilizing minimum-flow return N '

lines. These lines have flow orifices installed and do not allow throttling to an established reference value for either flow or pressure ,

ALTERNATE TESTING: These pumps shall be tested quarterly measuring observed flow, differential pressure and vibration. The pumps shall be tested using the normal flow path during cold shutdowns and refueling outages. Data from-both test frequencies shall be trended as required by IWP-6000.

(re, Generic Letter 89-04, Attachment 1 Position 9) t

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/ - RELIEF-REQUEST NO. VR-25 SYSTEM

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. Emergency Diesel Generator Starting Air VALVES 5941A, 5942A

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CATEG'ORY: ' C SAFETY; CLASS: 3 FUNCTION: These check valves open to allow air flow into the starting air accumulators.

These valves close to prevent depressurization of the accumulators.

TEST REQUIREMENT: Check valves shall be exercised at least once every three months, except as

, provided by IWV-3522. (IWV-3521) r BASIS FOR RELIEF: During operation there is-no practical means to exercise these valves. Valve closure cannot be verified due-to system

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design. To perform a closure verification would require disassembly,of mechanical-joints in the piping, whichlwould' place the diesel in'an-inoperable condition.

ALTERNATE TESTING: One valve will be disassembled, full stroke exercised and inspected each.

refueling outage on a rotating basis. If that valve fails, the remaining valve will be disassembled, full' stroke exercised and inspected during that same outage. (re, Generic Letter 89-04,

Attachment:

1 - Position 2) s I