ML20044B048

Discusses Review of Station Blackout Documentation,Per 10CFR50.63.Licensee Will Complete Enhancements to Station Blackout Documentation Identified in Attachment 1 as Indicated & Other Items Will Be Completed within 2 Yrs

ML20044B048
Person / Time
Site:	Ginna
Issue date:	07/10/1990
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Murley T Office of Nuclear Reactor Regulation
References
NUDOCS 9007170249
Download: ML20044B048 (5)

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<m y dqs!G M.mvw j{f mir ROCHESTER GAS AND ELECTRIC CORPORATION e 89 EAST AVENUE, ROCHESTER, N Y. 14649 0001 -  ;

i July 10,1990 ,u,.... ,

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Thomas E. Murley, Director i Office Of Nuclear Reactor Regulation l

~ United States Nuclear Regulatory Commission 1 1' White Filnt North 11555 Rockville Pike - ,

Rockville, Maryland 20852 j i

Subject:

10 CFR e50.63 Station Blackout R. E. Ginna Nuclear Power Plant

~ Docket Number 50-244 q.

Dear Dr. Murley:

- On April 17,1989, Rochester Gas and Electric Corporation supplied the_ NRC with information on {

compilance to 10 CFR 650.63 at the R. E. Ginna Nuclear Power Plant. Since that time, RG&E personnel have been participating in industry groups on station blackout, and have been closely ,

monitoring the recent interactions between NUMARC and the NRC Staff on this subject. We have {

noted generic' concerns from NUMARC and the Staff that the industry's documentation of compliance to 10 CFR 950.63 did not meet the Staff's original intent (see "NUMARC 87-00 Supplemental Questions and Answers," and "NUMARC 87-00 Major Assumptions," December 27,  ;

1989;Thadant to Marion, January 3,1990; and. Lee to NUMARC Board of Directors, " Request for Supplemental SBO Submittal to NRC," January 4,1990). In light of these concems, we would I like to take this opportur ity to inform you of recent activities that RG&E has undertaken to verify j

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station blackout documentation for Ginna.

RCGE iiaa, eu,iducied a cump.eisensivo italew uiits siaiivn blackuut dvuu,nentation. 'This review made a point by point comparison of our April 17, 1989 response and station blackout documentation to the methodology and baseline assumptions of NUMARC 87-00. It also took into 4 account the concerns generated by the NRC Staff in staw . blackout documentation Informational  ;

audits conducted in the industry in 1989, and the NRC Staff's recent interactions with NUMARC.  !

Our review did not indicate any problems with the proposed coping duration of four hours, the target emergency diesel generator reliability of 0.975, or the schedule for completing.the modifications and proceduro changes, Identified in_our submittal of April 17,1989. We did,

!' however, determine that some enhancements to our station blackout documentation were required. We are currently in the process of completing this documentation augmentation.

Details are provided in Attachment 1.

9007170249 90071o m Ok U$

f,DR ADOCK 05000244 PDC V

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7.L RG&E Station Blackout Documentation Review

? July 10; 1990 x Page 2 of 2 e s

" RG&E will complete enhancements to its station blackout documentation identified in Attachment 1 as indicated.in the attachment. Other actions identified in Attachment 1 that are required for

, compilance to the station blackout rule will be completed within two years of the notification to be provided by the Director, Office of Nuclear Reactor Regulation, in accordance with 10 CFR 950.63(c)(3).

Very truly yours,

& /

Robert C. Meeredy, Division Manager Nuclear Production TAD /094 Attachment (1) xc: - United States' Nuclear Regulatory Commission [ Original).

Document Control Desk

. Washington, DC 20555 Mr.' Allen R. Johnson (Mall Stop 14D1)

United States Nuclear Regulatory Commission Project Directorate 13 Washington, DC 20555 Un'ted Ct!J.n. " ;oisar Rugt :ato#> Owinilsusi Region I 475 Allendale Road King Of Prussia, Pennsylvania 19406 USNRC Senior Resident inspector R. E. Ginna Nuclear Power Plant 1503 Lake Road

, - Ontario, New York 14519 Mr. Alex Marlon Nuclear Management And Resources Council 1776 Eye Street North West, Suite 300 Washington, DC 20006-2496

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Attachment 1 Enhancements To RG&E's Station Blackout Documentation Page 1 of 1 NUMARC 87 00, Baseline Assumption 2.5.1 )

NUMARC 87-00 base 4ne assumption 2.5.1 contends that, in consideration of the c.pected Reactor Coolant Systsm (RCS) leakage rate, the reactor core will remain covered and' 4dequate level will exist to maintain adequate core cooling via natural circulation. To evaluate wl ether the core would remain covered during a station blackout, RG&E has reviewed Westinghou .e Topical -i Report 10541 (specifically, Figure 8.5), and determined that the analysis shown is ap )licable to Ginna.

With regard to verifying the ability to sustain adequate core cooling via natural circule lon, Ginna

. procedure ECA 0.0, step 7 directs the operato(a to power a charging pump using th i Technical Support Center (TSC) diesel generator to energize Bus 16. RG&E is evaluating the TSC diesel ,

generefor to enmore that it meets or exceeds criteria estabilched in NUMARC 87M Appendix ,

.B; this eva!uation will be completed and documented by September 1,1990. ,

t NUMARC 87-00, Station Blackout Response Guldellnes 2 And 3 These guidelines pertain to the verification of the operability and reliability of the turbine driven auxillary feedwater pump (TDAFWP) under station blackout conditions. The TDAFWP is designed - t to use service water for bearing and lubricating oil cooling; service water is not available under station blackout conditions. RG&E has demonstrated during tests that the TDAFWP will operate for at least two hours without service water. To meet the four hour coping requirements of the

. station blackout rule, RG&E plans to provide an attemative source of cooling water to the TDAFWP by backfeeding through the service water piping from the fire protection system via the diesel driven fire water pump located in the Screen House. A preliminary drawing review and site walkdown have been performed to confirm the viability of this strategy. RG&E will evaluate the diesel driven fire water pump to ensure that it meets or exceeds the criteria of NUMARC 87 00, Appendix B.NThis evaluation will be completed and documented by September 1,1990. RG&E will further confirm the viability of using the diesel driven fire water pump by conducting a timed l test, simulating this system lineup, where operators will establish the required valve and hose alignments; this test will be completed and documented by June 1,1991.

NUMARC 87-00,' Station Blackout Response Guldeline 5 1 rits guiaeline penalas to line ioentitution of enemaw condensate sources and their associated order of use. Although Ginna procedures are in place to identify alternate water. sources, the sources which are not dependent on AC power are not specifically identified. RG&E will revise the applicable procedures to preclude any confusion and delays; these revisions will be ,

implemented within two years of the notification to be provided by the Director, Office of Nuclear  !

Reactor Regulation in accordance with 10 CFR 650.63(c)(3).

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,. Attachment 1 L> '

Resolutions To Discrepancies Found During RG&E's

. Station Blackout Documentation Review Page 2 of 3 1- 1 NUMARC 8740, Station Blackout Response Guldeline 7 This guideline pertains to actions that will permit appropriate containment isolation and safe shutdown valve operations while AC power is unavailable. RG&E is currently in the process of revising the Ginna Station Technical Spealfications; this revision involves removing Table 3.6.1, and referencing Updated Final Safety Analysl Report Table 6.213. Containment isolation valves in revised UFSAR '

Table 6.213 will be reviewec using f,s i4UMARC 87-00 methodology as part of this submittal effort.

L - RG&E expects this submittal to be completed in October of 1990. Any revisions to procedures o required by the results of this evaluation will be impiemented within two years of the notification to be '

L provided' by the Director, Office of Nuclear Reactor Regulation in accordance with 10 CFR 950.63(c)(3).

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. NUMARC 8740, Station Blackout Response Guldeline 8 c i

This guideline pertains to the identification of portable lighting required for local manual actions. A 1987 RG&E station blackout procedure review identified several areas that did not contain sufficient l

lighting where local manual actions were required. RG&E is in the process of rechecking these areas to determine if these conditions still exist. We will update appilcable procedures to instruct ooerators to obtain appropriate portable lighting before proceeding to those areas that still do not contain sufficient battery-backed lighting. These revisions will be implemented within two years of the notification to be provided by the Director, Office of Nuclear Reactor Regulation in accordance with 10 CFR 950.63(c)(3).

NUMARC 8740, Station Blackout Response Guldeline 10  ;

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This guideline pertains to consideration of the effects of a loss of ventilation on specific energized equipment necessary for shutdown. RG&E has undertaken an extensive analysis of the Ginna control building to assess post loss of HVAC ambient temperature rises. Results of these analyses will be t available on or before September 1,1990. Any revisions to procedures to open cabinet doors, etc.,

L Indicated by these results will be implemented within two years of the notification to be provided by the Director, Office of Nuclear Reactor Regulation in accordance with 10 CFR 50.63(c)(3).~

NUMARC 87-00, Station Blackout Response Guideline 11 Ginna procedure ECA 0.0 currently requires local operator actions to possibly open and close the .

atmospheric relief valves. RG&E is In the process of evaluating the ambient temperature rise and  ;

assessing personnel and equlpment operations in the area of the Atmospheric Relief Valves (ARVs) in the Intermediate Building, using the criteria and methodologies of NUMARC 87 00 Appendices E ,

and F. _ This evaluation will be completed and docurr< 'ed by September 1,1990.

NUMARC 87-00, Station Blackout Response Guideline 12 L

This guideline pertains to the need to include non-1E coping equipment in a maintenance program.

A 1987 RG&E station blackout review identified back-up devices for all non 1E coping equipment in lieu of including them in a maintenance program. Ginna procedure ECA 0.0 has not been updated y to reflect this information as of this date. A follow-up review is being conducted to address this open p item. Procedure changes will be made, as appropriate, to inform operators that alternate equipment l- Is available during a station blackout. These changes will be completed within two years of the l

notification to be provided by the Director, Office of Nuclear Reactor Regulation in accordance with 10 CFR 950.63(c)(3). -

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Attachment 1 L . - i. ' - R0 solutions To Discr;pancies Found During _RG&E's

. Station Blackout Documentation Review  !

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NUMARC 87-00, Section 4.2.3, Severe Weather Guidelines l I

Glnna procedure SC 2, Adverse Weather, will be revised to include a reference to ECA 0.0. This revision will be implemented within two years of the notification to be provided by the Director, Office

~ of Nuclear Reactor Regulation in accordance with 10 CFR 950.63(c)(3).

NUMARC 87-00, Section 7.2.2, Class 1E Battery Capacity An analysis of Class 1E battery capacity utilizing IEEE 485 methodology has been completed. This analysis shows that, under normal ambinnt conditions, vital Mtt9ry capacity is sufficient to meet the -

four hour coping requirement. RG&E is reviewing the impact of extreme ambient conditions on this calculation; review of the Class 1E battery load profile wlIl be completed and documented by  ;

September 1,1990.

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