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Forwards Request,Background Info & Justification Re Request for Enforcement Discretion.Provides All Necessary Info Requested During 940214 Telcon
	ML20078K529
Person / Time
Site:	Ginna
Issue date:	02/15/1994
From:	Mecredy R; ROCHESTER GAS & ELECTRIC CORP.
To:	Martin T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20078K505	List: ML20078K512; ML20078K529;
References
	FOIA-94-167 NUDOCS 9502090284
	Download: ML20078K529 (8)
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ROCHESTER GAS AND ELECTRIC CORPORATION e 89 EAST AVENUE, ROCHESTER N Y. 1464$ $ 01 if Or(tt T t' MfC.RIDY reunos

,,e e .a Pen.4.atkm AMA CODE FIS 640-2700 February 15, 1994 U.S. Nuclear Regulatory Commission Regional Administrator, Region I Mr. Thomas T. Martin 475 Allendale Road King of Prussia, PA 19406

.3 obj ect : Request For Enforcement Discretion '

R.E. Ginna Nuclear Power Plant Docket No. 50-244 t

/ctr Mr. Martin, In accordance with 10 CFR Part 2, Appendix C, and using the guidance contained in NRC Inspection ManuaE Part 9900, RG&E requests Enforcement Discretion with respect to Ginna' Station Technical Specification Table 4.2-1, #9 (Containment Isolation.

Trip). The request, background information, and. justification is attached. This request was initially discussed with the NRC riuring a conference call on February 14th at 1400 EST. RG&E .

received verbal approval of the enclosed Enforcement Discretion tiuring a phone conversation between James Linville , NRC, . Region, T, and Richard Marchionda, Ginna Station Superintendent, at -

approximately 1520 EST on that same date. This letter provides al] necessary information requested during these two phone conversations.

Very ruly yours, Robert C. Mec edy xc: U.S. Nuclear Regulatory Commission .

Office of Nuclear Reactor Regulation Assistant Director for Region I Reactors Mr. Jose A. Calvo Washington, D.C. 20555 -

Ginna Station Senior Resident Inspector 9502090284 940614 PDR FO'A RICCIO94-167 PDR ,

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1. DESCRIPTION OF TECHNICAL SPECIFICATION REQUIREMENT !

Ginna Station Technical Specification (TS) Table 4.1-2, #9 requires that the i

" Containment isolation Trip" be tested for " functioning" each refueling shutdown. TS Table 3.5-2, #4.1 defines the Containment isolation function with respect to both manual and Safety injection (auto actuation). The !

automatic actuation function was successfully tested during the 1993 refueling outage. There are two manual containment isolation pushbuttons; either pushbutton will actuate both trains'of containment isolation.

However, only one manual pushbutton was verified operable during the ILRT l conducted during the 1993 refueling outage. Tif Table 3.5-2, #4.1.a '

requires two channels of manual containment isolation. Generic Letter 87-09 states that failure to meet a required surveillance test is a failure to nwet the LCO. The LCO with one channel inoperable is to restore the channel to -

operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be at Hot Shutdown within an additional i 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and at Cold Shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , i

2. DESCRIPTION DEREQUESI In response to Notice of Violation #93-021-01, RG&E committed to perform j a review of surveillance requirements contained in TS Section 4 to ensure that implementing procedures existed for each requirement and that these procedures, do in fact, implement the TS requirement in the course of l performing this review, it was determined that the two manual containment ;

isolation pushbuttons are not periodically. tested in accordance with TS ;

requirements. RG&E has conservatively determined that the pushbuttons are !

required to be tested in accordance with TS Table 4.1-2, #9. j i

The design of the containment isolation function, including the pushbuttons !

is shown on the attached.two figures. As-can be seen from these figures, !

either pushbutton will actuate both containmentlsolation trains. Relay C1(O) 1 (or C2(0) for the redundant train) as shown on the drawings is normally deonergized. Pressing either pushbutton will energize this relay closes ;

contact C1 (or C2) which energizes relay C15X (or C25X). ,

Surveillance Testing has not been routinely performed of the manual .

containment isolation pushbuttons. However, in preparing for performance ;

of the ILRT during the 1993 refueling outage, one of the two manual pushbuttons was utilized to initiate containment isolation (procedure RSSP- ,

6.0, step 6.8). Therefore, one pushbutton and the entire remaining containment isolation function was verified to be operable at this time. Only ,

the remaining pushbutton and associated wiring to the containment isolation function was not tested within the TS required frequency (shown as a cloud on the drawings). It should be noted that since the ILRT procedure does not specify which pushbutton to use, it can be conservatively postulated that one pushbutton has not been verified.

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. . ._ ms ,,m ....., os Tu 7.ua Ginna Station is currently operating at approximately 98% full power. In cidcr lo perform the test of the remaining pushbutton, RG&E has determined i that slide links would need to be opened for both trains of containment isolation. In addition, slide links for Containment Ventilation isolation (CVI) :

would also have to be opened since manual containment isolation will also l generate a CVI signal. The crSnsequence of error in performing this action negates an) e' vantage in prerforrning this type of testing. Initiating fuil :

manual containment isolation at power would create a significant transient '

as RCS letdown, steam generator blowdown, instrument air to containment '

(supplies the PORVs) and seal return would isolate. Consequently, RG&E has concluded that the necessary pushbutton test has the potential for

challenging engineered safety features and safe power operation.

Enforcement Discretion is therefore requested to grant RG&E relief from compliance with the requirements of TS Table 4.1-2, #9. This Enforcement Discretion is requested to begin on February 18,1994 at 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months when j the current LCO for TS Table 3.5-2, #4.1 will expire. The Enforcement !

Discretion is requested to end on A4 arch 6,1994 at 2400 hours0.0278 days 0.667 hours 0.00397 weeks 9.132e-4 months when Ginna Station expects to achieve Cold Shutdown, The test of both containment isolation manual pushbuttons will be performed during the 1994 refueling outage. ;

3. BASIS FOR REQUEST An automatic Safety injection (SI) signal generates a-Containment isolation l (Cl) signal. Manual Cl is only used if the Si annunciator is not lit and plant conditions require Safety injection and Containment isolation (Procedure E-0, Step 4). These conditions are defined based upon the plant parameters j which automatically initiate C, or if operators determine that Si is required. !

The failure of the automatic Si and Cl initiation requires a failure of two l independent channels. Since a manuel Si signal will not initiate a Cl signal, I there must be a failure of the two independent automatic Si channels and a ,

failure of the tested C1 channel before the untested pushbutton would need to be operated.

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In addition, all automatic containment isolation valves are stroked tested ;

from the main control board on either a quarterly or refueling basis as docurnented in the NRC approved Ginna Station IST Program. Therefore, .

there is sufficient verification that operators could manually close all effected ;

containment isolation valves from the control room if required. Finally, based :

upon the simple mechanical design of the pushbutton, there is a reasonable !

degree of assurance that the pushbutton will operate when required. !

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4. . COMPENSATORY ACTIONS i

Procedure E-0, Step 12 (Immediate Action Step) requires verification of the ,

Cl and CVI annunciators and the valve status lights. The failure to achieve !

annunciation and status lights results in operators rnanually closing the containment isolation valves from the control room or dispatching an auxillary operator to locally close the valve (EOP Attachment Cl/CVI).

Therefore, sufficient guidance currently exists with respect to responding to the postulated scenario, in addition, written guidance has been provided to operators in the Plan of the Day (POD) to ensure that the second containment isolation pushbutton is used if manual Cl is required and the ;

first pushbutton falls.

5. JUSTlFICATION FOR DURATION OF REQUEST Ginna Station is currently scheduled to begin a refueling outage on March 4, 1994. Therefore, the duration of the enforcement discretion is a total of 17 days until RG&E enters Cold Shutdown in preparation for the 1994 refueling ,

outage. The need to initiate shutdown to perform the test of the pushbutton prior to the scheduled outage could potentially result in a plant transient during the shutdown process or the subsequent startup. Since the test would also have to be performed at Cold Shutdown, a significant number of tests would also have to be performed prior to startup. A test during power '

operation could potentially generate a containment isolation signal which would place a significant transient upon the plant. Based-on the safety-review in 3. above, RG&E has concluded that it is acceptable for one ;

pushbutton to remain untested for the period of 17 days. '

t G. SIGNIFICANT HAZARDS EVALUATION RG&E has evaluated the Enforcement Discretion request and concluded that there is no potential detriment to the public health and safety and that a .

significant safety hazard is not involved. This basis for this conclusion is, summarized t.elow:

a. Delaying testing of the affected containment isolation pushbutton does not involve a significant increase in the probability or consequences of an accident previously evaluated. The containment isolation function is used to mitigate an accident only and is not considered with respect to initiating an accident. Also, the manual l containment isolation function is not credited in the Ginna Station UFSAR Chapter 15 accident analysis and, therefore, will not adversely i affect any consequence analyses.

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b. Delaying testing of the affected containment isolation pushbutton does not create the possibility of a new or different kind of accident from any previously evaluated. Since the manual containtnent isolation function is not credited in the Ginna Station UFSAR Chapter 15 accident analysis, the failure to test the identified pushbutton does not 4 create a new or different kind of accident. The pushbuttons are also )

only used in response to an accident and would not be used in any l scenario which creates a new or different kind of accident.

c. Delaying testing of the affected containtnent isolation pushbutton !

does not involve a significant reduction in a margin of safety since the -

function is not credited in the Ginna Station UFSAR Chapter 15 accident analyses. In addition, sufficient operator guidance is provided in the event that manual containtnent isolation is required ,

and does not operate. !

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7. ENVIRONMENTAL IMPACT y There are no environmental releases associated with the current plant condition nor the proposed relief from testing. The probability of requiring ;

use of the untested manual containment isolation pushbutton is very small. ;

in addition, sufficient guidance is currently available to the operators to !

respond to any postulated scenario which would require these pushbuttons. - '

Therefore, there are no environtnental consequences associated.with this

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request. .

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8. REVIEW BY PORC '

l The Ginna Station PORC has reviewed and approved this request for .

Enforcement Discretion.

t ex e -

Richard Idarchionda l Ginna Station PORC Chairman i i

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