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| | number = ML092950485 | | | number = ML092950485 |
| | issue date = 10/16/2009 | | | issue date = 10/16/2009 |
| | title = R.E. Ginna Nuclear Power Plant Response to Request for Additional Information Associated with Inservice Test Program Relief Request Number PR-01 | | | title = Response to Request for Additional Information Associated with Inservice Test Program Relief Request Number PR-01 |
| | author name = Swift P | | | author name = Swift P |
| | author affiliation = Constellation Energy Nuclear Group, LLC, R. E. Ginna Nuclear Power Plant, LLC | | | author affiliation = Constellation Energy Nuclear Group, LLC, R. E. Ginna Nuclear Power Plant, LLC |
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| =Text= | | =Text= |
| {{#Wiki_filter:Paul Swift Manager, Nuclear Engineering Services R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5208 585.771.3392 Fax Paul.swift@constellation.com Constellation Energy*Nuclear Generation Group October 16, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: | | {{#Wiki_filter:Paul Swift Swift R.E. |
| | R.E. Ginna Ginna Nuclear Nuclear Power Power Plant, Plant, LLC LLC Manager, Manager, Nuclear Nuclear Engineering Engineering Services Services 1503 1503 Lake Road Road Ontario, New York Ontario, New York 14519-9364 14519-9364 585.771.5208 585.771.5208 585.771.3392 585.771.3392 Fax Fax Paul.swift@constellation.com Paul.swift@constellation.com 0 <"'\* |
| | Constellation Energy" Nuclear Generation Nuclear Constellation Generation Group Group Energy* |
| | October October 16, 2009 2009 U. S. Nuclear Nuclear Regulatory Regulatory Commission Washington, Washington, DC 20555 20555 ATTENTION: |
| | ATTENTION: Document Control Document Control Desk |
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| ==SUBJECT:== | | ==SUBJECT:== |
| Document Control Desk R.E. Ginna Nuclear Power Plant Docket No. 50-244 Response to Request for Additional Information Associated With Inservice Test Program Relief Request Number PR-01
| | R.E. Ginna Nuclear N ucIear Power Plant Plant Docket No. 50-244 50-244 |
| | |
| | ===Response=== |
| | Response to Request Request for Additional Information Associated Information Associated With With Inservice Inservice Test Program Program Relief Request Number ReJiefRequest Number PR-01PR-Ol |
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| ==References:== | | ==References:== |
| | (1) Letter Letter from P. Swift, Ginna Ginna LLC, to NRC Document Document Control Desk, |
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| (1) Letter from P. Swift, Ginna LLC, to NRC Document Control Desk,
| | ==Subject:== |
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| ==Subject:== | | ==Subject:== |
| Fifth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves, dated September 11, 2009.(2) Letter from D. Pickett, NRC, to J. Carlin, Ginna LLC, | | Fifth Ten-Year Ten-Year Inservice Inservice Test Test Program Program for Safety-Related Safety-Related Pumps and Valves, Valves, dated dated September 11,2009. |
| | 11, 2009. |
| | (2) |
| | (2) Letter from D. Pickett, NRC, to J. Carlin, Ginna LLC, |
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| ==Subject:== | | ==Subject:== |
| Request for Additional Information (RAI) Re: Relief Request No. PR-01, Revision 0, for the Fifth 10-Year Inservice Testing Interval -R.E. Ginna Nuclear Power Plant (TACNO. ME2239), dated October 6, 2009.On September 11, 2009 R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted relief request PR-01 associated with the Fifth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves (Reference 1). On October 6, 2009 the NRC responded to that submittal with a request for additional information (Reference 2). Enclosed please find the response to the staff's question.There are no regulatory commitments contained in this letter. Should you have questions regarding this matter, please contact Thomas Harding (585) 771-5219, or thomnas.hardingjrgconstellation.com. | | Request for Additional Information (RAI) Re: Relief Request No. PR-Ol, Additional PR-01, Revision 0, for the Fifth 10-Year Inservice Inservice Testing Interval - R.E. Ginna Nuclear Power Plant (TAC Testing Interval-NO. ME2239), dated October October 6, 2009. |
| Very truly yours, Paul M. Swift | | On September 11,200911, 2009 R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted relief request PR-01 associated with the Fifth Ten-Year Inservice Test Program for Safety-Related Safety-Related Pumps and Valves (Reference 1). On OctoberOctober 6, 2009 the NRC responded to that submittal with a request for additional information (Reference (Reference 2). Enclosed please find the response to the staffs staff's question. |
| | commitments contained in this letter. Should you have questions regarding this There are no regulatory commitments matter, please contact Thomas Harding (585) (585) 771-5219, or thomas.hardingjr@constellation.com. |
| | thomnas.hardingjrgconstellation.com. |
| | Very truly yours, Swift Paul M. Swift |
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| ==Attachment:== | | ==Attachment:== |
| | Response to Request for' for Additional Information Associated With Relief Relief Request Number PR-Ol PR-01 AJ4L7 (74 1.J'0 L'Ni q 6 - /00ý?0'03 |
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| Response to Request for Additional Information Associated With Relief Request Number PR-01 AJ4L7(7 4 1.J'0 L'Ni q 6 -/00ý?0'03 0<"'\* ....... Paul Swift Manager, Nuclear Engineering Services Constellation Energy" Nuclear Generation Group R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5208 585.771.3392 Fax Paul.swift@constellation.com October 16, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
| | Document Control Desk October 16, 2009 October Page 2 cc: S. J. Collins, NRC D. V. Pickett, NRC Resident Inspector, NRC |
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| ==SUBJECT:==
| | ATTACHMENT ATTACHMENT Response to Request for Additional Information Response Associated With Information Associated Request Number PR-Ol Relief Request PR-01 RE. Ginna Nuclear Power Plant, LLC R.E. |
| | 16, 2009 October 16, |
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| ==References:==
| | ATTACHMENT ATTACHMENT |
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| Document Control Desk R.E. Ginna N ucIear Power Plant Docket No. 50-244 Response to Request for Additional Information Associated With Inservice Test Program ReJiefRequest Number PR-Ol (1) Letter from P. Swift, Ginna LLC, to NRC Document Control Desk,
| | ===Response=== |
| | Response to RequestRequest for Additional Information Associated Associated With Relief Request Number PR-Ol PR-01 Question Question It is the NRC staff's understanding understandingthat the diesel transferpumps PDG02A diesel fuel oil transfer PDGO2A and and PDGO2B PDG028 are positive displacement are displacement pumps. Please Please explain explain how the proposedproposedalternative alternative testing methodology utilizingutilizing the accuracy accuracy in design design analysis 4526-ME-20 meets the analysis EWR 4526-ME-20 recommendations recommendations as described described in NUREG-1482, NUREG-1482, Revision 1, Section 5.5.2. |
| | 1, Section 5.5.2. |
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| ==Subject:== | | ===Response=== |
| Fifth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves, dated September 11,2009. (2) Letter from D. Pickett, NRC, to J. Carlin, Ginna LLC,
| | Ginna's Ginna's diesel fuel oil transfer pumps, PDG02A & & PDG02B, are positive displacement displacement pumps. |
| | | The flow rate for these pumps is determined determined by measuring measuring the indicated level change change in in the the diesel generator generator fuel oil day tank during a timed pump run and converting this data into fuel oil transfer pump flow rate for both the Group 8B and comprehensive comprehensive pump tests. |
| ==Subject:==
| | Level Gauges LG-2044 ("A" E DIG) and LG-2045 LG-2045 ("8" ("B" EE DIG) are utilized to measure the the change change in in indicated level while the fuel oil transfer pump is running and restoring fuel oil day tank level. 80th Both LG-2044 LG-2044 and LG-2045 (sight glasses equipped equipped with a reference scale in in inches of level) inches level) have a range of indicatedindicated level of 99 inches (2.5 inches to 11.5 11.5 inches). |
| Request for Additional Information (RAI) Re: Relief Request No. PR-Ol, Revision 0, for the Fifth 10-Year Inservice Testing Interval-R.E. Ginna Nuclear Power Plant (TAC NO. ME2239), dated October 6, 2009. On September 11,2009 R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted relief request PR-01 associated with the Fifth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves (Reference 1). On October 6, 2009 the NRC responded to that submittal with a request for additional information (Reference 2). Enclosed please find the response to the staffs question.
| | The respective day tank is drained drained to an initial indicated indicated level of 5.0 to 5.5 inches before before initiating the fuel oil pump start. This level level is logged as the initial level. The pump is then started coincident coincident with with starting starting the stopwatch and the system allowed allowed to stabilize. A minimum 2 minute minute stabilization stabilization period is observed for the comprehensive comprehensive test. |
| There are no regulatory commitments contained in this letter. Should you have questions regarding this matter, please contact Thomas Harding (585) 771-5219, or thomas.hardingjr@constellation.com.
| | Following a total minimum run time of 5 minutes (or exceeding Following exceeding an indicated tank level of 11 11 inches), |
| Very truly yours, Paul M. Swift
| | inches), the pump is stopped coincident coincident with stopping the stopwatch the. stopwatth and the day tank level is read in in inches to the nearestnearest 0.25 inch. This level is logged as the final level. |
| | | The change in in day tank level is determined determined in in inches and then converted converted to total gallons gallons pumped using the constant conversion conversion factor of 24.76 gallons per inch. The constant of 24.76 gallons per gallons per inch inch ofof indicated indicated level level on on the day day tank tank sight sight glass was established by EWR 4526-ME-20 based on the tank's geometrical ME-20 based on the tank's geometrical dimensions. dimensions. |
| ==Attachment:==
| | i The total The total gallons gallons pumped pumped is is then then divided by the total total pump pump runrun time time to to arrive at the arrive at the pump pump test flow rate rate inin gallons gallons per minuteminute (gpm). This calculation calculation is documented documented in in the pump test procedures. |
| | procedures. |
| | The test circuit The test circuit for for each each pump is a fixed flow path from the storage tank (pump suction) to the the day tank (pump discharge). |
| | day tank (pump discharge). Pump Pump suction suction pressure pressure is nearly constant because of the very small change in in storage tank level. This change change in in suction pressure during pump operation is is considered negligible. |
| | considered negligible. The The normal normal rise rise in day tank level in day level is is approximately approximately 5.5 inches, which which corresponds to corresponds to aa quantity quantity of of approximately approximately 136 gallons pumped 136 gallons pumped during the the 55 minutes of pump pump operation, resulting in operation, in a typical typical flow rate rate of approximately approximately 27 gpm. The current flow rate rate reference values of each reference each pump pump are as follows: PDG02A - 27.2 gpm, PDG028 PDG02B - 27.1 gpm. |
| | 1I |
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| Response to Request for' Additional Information Associated With Relief Request Number PR-Ol Document Control Desk October 16, 2009 Page 2 cc: S. J. Collins, NRC D. V. Pickett, NRC Resident Inspector, NRC Document Control Desk October 16, 2009 Page 2 cc: S. J. Collins, NRC D. V. Pickett, NRC Resident Inspector, NRC ATTACHMENT Response to Request for Additional Information Associated With Relief Request Number PR-01 R.E. Ginna Nuclear Power Plant, LLC October 16, 2009 ATTACHMENT Response to Request for Additional Information Associated With Relief Request Number PR-Ol RE. Ginna Nuclear Power Plant, LLC October 16, 2009 ATTACHMENT Response to Request for Additional Information Associated With Relief Request Number PR-01 Question It is the NRC staff's understanding that the diesel fuel oil transfer pumps PDGO2A and PDGO2B are positive displacement pumps. Please explain how the proposed alternative testing methodology utilizing the accuracy in design analysis EWR 4526-ME-20 meets the recommendations as described in NUREG-1482, Revision 1, Section 5.5.2.Response: Ginna's diesel fuel oil transfer pumps, PDG02A & PDG02B, are positive displacement pumps.The flow rate for these pumps is determined by measuring the indicated level change in the diesel generator fuel oil day tank during a timed pump run and converting this data into fuel oil transfer pump flow rate for both the Group B and comprehensive pump tests.Level Gauges LG-2044 ("A" E DIG) and LG-2045 ("B" E DIG) are utilized to measure the change in indicated level while the fuel oil transfer pump is running and restoring fuel oil day tank level. Both LG-2044 and LG-2045 (sight glasses equipped with a reference scale in inches of level) have a range of indicated level of 9 inches (2.5 inches to 11.5 inches).The respective day tank is drained to an initial indicated level of 5.0 to 5.5 inches before initiating the fuel oil pump start. This level is logged as the initial level. The pump is then started coincident with starting the stopwatch and the system allowed to stabilize.
| | ATTACHMENT ATTACHMENT Response to Request for Additional Information Associated Additional Information Associated With Relief Request Number PR-Ol PR-01 The small rise inin day tank level during pump operation does not affect pump discharge discharge pressure pressure or flow rate. This conclusion is supported supported by the discussion discussion inin NUREG 1482 Rev.1, section Rev.1, section 5.5.2, where the NRC states: "Pump discharge discharge pressure will match match system pressure up to the the shutoff head head of the positive displacement Because of the characteristics displacement pump. Because characteristics of a positive positive displacement pump, there should be virtually no change in displacement in pump discharge discharge flow rate as a result of the rising tank level. |
| A minimum 2 minutestabilization period is observed for the comprehensive test.Following a total minimum run time of 5 minutes (or exceeding an indicated tank level of 11 inches), the pump is stopped coincident with stopping the stopwatch and the day tank level is read in inches to the nearest 0.25 inch. This level is logged as the final level.The change in day tank level is determined in inches and then converted to total gallons pumped using the constant conversion factor of 24.76 gallons per inch. The constant of 24.76 gallons per inch of indicated level on the day tank sight glass was established by EWR 4526-ME-20 based on the tank's geometrical dimensions.
| | of level. Therefore, Therefore, rising tank level will not have an impact on test results. By By having approximately approximately the same level in in the tank at the beginning beginning of each test, licensees licensees can achieve repeatable results." |
| The total gallons pumped is then divided by the total pump run time to arrive at the pump test flow rate in gallons per minute (gpm). This calculation is documented in the pump test procedures.
| | The accuracy of level gauges, LG-2044 and LG-2045, is determined The accuracy determined using the nine (9) inch indicated range of level and the constant of 24.76 gallons per inch. This yields a total volume indicated volume change of 222.84 gallons. Based change Based on a readability uncertainty of +/- 0.125 inch (0.25 inch readability uncertainty scaling), |
| The test circuit for each pump is a fixed flow path from the storage tank (pump suction) to the day tank (pump discharge).
| | scaling), which isis equivalent equivalent to 3.10 gallons, divided by the total indicated volume of 222.84222.84 gallons, the overall accuracy accuracy of the sight glass is +/- 1.39%. |
| Pump suction pressure is nearly constant because of the very small change in storage tank level. This change in suction pressure during pump operation is considered negligible.
| | In addition, the stopwatch In stopwatch used to measure measure the time the pump is operating and pumping pumpirig fuel oil accurate to within +/-+/- 0.6 seconds per minute for a calibrated accuracy is accurate accuracy of +/- 1.0%. Combining |
| The normal rise in day tank level is approximately 5.5 inches, which corresponds to a quantity of approximately 136 gallons pumped during the 5 minutes of pump operation, resulting in a typical flow rate of approximately 27 gpm. The current flow rate reference values of each pump are as follows: PDG02A -27.2 gpm, PDG02B
| | +/- 1.0%. Combining the accuracies accuracies ofof the the level level gauge sight glass and stopwatch, using the square square root of the sum of the squares method, results in in an overall indicated indicated accuracy accuracy of +/- 1.711.71%. overall accuracy |
| -27.1 gpm.I Question ATTACHMENT Response to Request for Additional Information Associated With Relief Request Number PR-Ol It is the NRC staff's understanding that the diesel fuel oil transfer pumps PDG02A and PDG028 are positive displacement pumps. Please explain how the proposed alternative testing methodology utilizing the accuracy in design analysis EWR 4526-ME-20 meets the recommendations as described in NUREG-1482, Revision 1, Section 5.5.2. Response:
| | %. This overall unchanged from that which relief was granted is unchanged granted for during th 10-year during the 44th interval 1ST 10-year interval IST program. |
| Ginna's diesel fuel oil transfer pumps, PDG02A & PDG02B, are positive displacement pumps. The flow rate for these pumps is determined by measuring the indicated level change in the diesel generator fuel oil day tank during a timed pump run and converting this data into fuel oil transfer pump flow rate for both the Group 8 and comprehensive pump tests. Level Gauges LG-2044 ("A" E DIG) and LG-2045 ("8" E DIG) are utilized to measure the change in indicated level while the fuel oil transfer pump is running and restoring fuel oil day tank level. 80th LG-2044 and LG-2045 (sight glasses equipped with a reference scale in inches of level) have a range of indicated level of 9 inches (2.5 inches to 11.5 inches). The respective day tank is drained to an initial indicated level of 5.0 to 5.5 inches before initiating the fuel oil pump start. This level is logged as the initial level. The pump is then started coincident with starting the stopwatch and the system allowed to stabilize.
| | 2}} |
| A minimum 2 minute stabilization period is observed for the comprehensive test. Following a total minimum run time of 5 minutes (or exceeding an indicated tank level of 11 inches), the pump is stopped coincident with stopping the. stopwatth and the day tank level is read in inches to the nearest 0.25 inch. This level is logged as the final level. The change in day tank level is determined in inches and then converted to total gallons pumped using the constant conversion factor of 24.76 gallons per inch. The constant of 24.76 gallons per inch of indicated level on the day tank sight glass was established by EWR 4526-ME-20 based on the tank's geometrical dimensions.
| |
| i The total gallons pumped is then divided by the total pump run time to arrive at the pump test flow rate in gallons per minute (gpm). This calculation is documented in the pump test procedures.
| |
| The test circuit for each pump is a fixed flow path from the storage tank (pump suction) to the day tank (pump discharge).
| |
| Pump suction pressure is nearly constant because of the very small change in storage tank level. This change in suction pressure during pump operation is considered negligible.
| |
| The normal rise in day tank level is approximately 5.5 inches, which corresponds to a quantity of approximately 136 gallons pumped during the 5 minutes of pump operation, resulting in a typical flow rate of approximately 27 gpm. The current flow rate reference values of each pump are as follows: PDG02A -27.2 gpm, PDG028 -27.1 gpm. 1 ATTACHMENT Response to Request for Additional Information Associated With Relief Request Number PR-01 The small rise in day tank level during pump operation does not affect pump discharge pressure or flow rate. This conclusion is supported by the discussion in NUREG 1482 Rev.1, section 5.5.2, where the NRC states: "Pump discharge pressure will match system pressure up to the shutoff head of the positive displacement pump. Because of the characteristics of a positive displacement pump, there should be virtually no change in pump discharge flow rate as a result of the rising tank level. Therefore, rising tank level will not have an impact on test results. By having approximately the same level in the tank at the beginning of each test, licensees can achieve repeatable results." The accuracy of level gauges, LG-2044 and LG-2045, is determined using the nine (9) inch indicated range of level and the constant of 24.76 gallons per inch. This yields a total volume change of 222.84 gallons. Based on a readability uncertainty of +/- 0.125 inch (0.25 inch scaling), which is equivalent to 3.10 gallons, divided by the total indicated volume of 222.84 gallons, the overall accuracy of the sight glass is +/- 1.39%.In addition, the stopwatch used to measure the time the pump is operating and pumping fuel oil is accurate to within +/- 0.6 seconds per minute for a calibrated accuracy of +/- 1.0%. Combiningthe accuracies of the level gauge sight glass and stopwatch, using the square root of the sum of the squares method, results in an overall indicated accuracy of +/- 1.71%. This overall accuracy is unchanged from that which relief was granted for during the 4 th 10-year interval IST program.2 ATTACHMENT Response to Request for Additional Information Associated With Relief Request Number PR-Ol The small rise in day tank level during pump operation does not affect pump discharge pressure or flow rate. This conclusion is supported by the discussion in NUREG 1482 Rev.1, section 5.5.2, where the NRC states: "Pump discharge pressure will match system pressure up to the shutoff head of the positive displacement pump. Because of the characteristics of a positive displacement pump, there should be virtually no change in pump discharge flow rate as a result of the rising tank level. Therefore, rising tank level will not have an impact on test results. By having approximately the same level in the tank at the beginning of each test, licensees can achieve repeatable results." The accuracy of level gauges, LG-2044 and LG-2045, is determined using the nine (9) inch indicated range of level and the constant of 24.76 gallons per inch. This yields a total volume change of 222.84 gallons. Based on a readability uncertainty of +/-0.125 inch (0.25 inch scaling), which is equivalent to 3.10 gallons, divided by the total indicated volume of 222.84 gallons, the overall accuracy of the sight glass is +/-1.39%. In addition, the stopwatch used to measure the time the pump is operating and pumpirig fuel oil is accurate to within +/- 0.6 seconds per minute for a calibrated accuracy of +/- 1.0%. Combining the accuracies of the level gauge sight glass and stopwatch, using the square root of the sum of the squares method, results in an overall indicated accuracy of +/- 1.71 %. This overall accuracy is unchanged from that which relief was granted for during the 4th 10-year interval 1ST program. 2}}
| |
Letter Sequence Response to RAI |
|---|
|
|
MONTHYEARML0926104352009-09-11011 September 2009
R. E. Ginna - Fifth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves
Project stage: Request
ML0927505172009-10-0101 October 2009
E-mail Ginna Acceptance Review of IST Relief Requests
Project stage: Acceptance Review
ML0929504852009-10-16016 October 2009
Response to Request for Additional Information Associated with Inservice Test Program Relief Request Number PR-01
Project stage: Response to RAI
ML0931400912009-11-0505 November 2009
R. E. Ginna Nuclear Power Plant, Withdrawal of Relief Request VR-03 from the Fifth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves
Project stage: Withdrawal
ML0935701732009-12-30030 December 2009
Alternative Requests for Fifth 10-Year Pump and Valve Inservice Testing Program-R.E. Ginna Nuclear Power Plant
Project stage: Acceptance Review
ML1000601112010-01-19019 January 2010
Correction Letter to Alternative Requests for Fifth 10-Year Pump and Valve Inservice Testing Program-R. E. Ginna
Project stage: Other
ML1006903082010-03-0202 March 2010
R. E. Ginna Nuclear Power Plant - Commitment Associated with Technical Specification LCO 3.4.14 RCS Pressure Isolation Valve (PIV) Leakeage
Project stage: Request
ML1008902372010-04-14014 April 2010
Alternative Request GR-01 for the Fifth 10-Year Pump and Valve Inservice Testing Program-R.E. Ginna Nuclear Power Plant
Project stage: Other
2009-12-30
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2024-09-25
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Text
Paul Swift Swift R.E.
R.E. Ginna Ginna Nuclear Nuclear Power Power Plant, Plant, LLC LLC Manager, Manager, Nuclear Nuclear Engineering Engineering Services Services 1503 1503 Lake Road Road Ontario, New York Ontario, New York 14519-9364 14519-9364 585.771.5208 585.771.5208 585.771.3392 585.771.3392 Fax Fax Paul.swift@constellation.com Paul.swift@constellation.com 0 <"'\*
Constellation Energy" Nuclear Generation Nuclear Constellation Generation Group Group Energy*
October October 16, 2009 2009 U. S. Nuclear Nuclear Regulatory Regulatory Commission Washington, Washington, DC 20555 20555 ATTENTION:
ATTENTION: Document Control Document Control Desk
SUBJECT:
R.E. Ginna Nuclear N ucIear Power Plant Plant Docket No. 50-244 50-244
Response
Response to Request Request for Additional Information Associated Information Associated With With Inservice Inservice Test Program Program Relief Request Number ReJiefRequest Number PR-01PR-Ol
References:
(1) Letter Letter from P. Swift, Ginna Ginna LLC, to NRC Document Document Control Desk,
Subject:
Subject:
Fifth Ten-Year Ten-Year Inservice Inservice Test Test Program Program for Safety-Related Safety-Related Pumps and Valves, Valves, dated dated September 11,2009.
11, 2009.
(2)
(2) Letter from D. Pickett, NRC, to J. Carlin, Ginna LLC,
Subject:
Request for Additional Information (RAI) Re: Relief Request No. PR-Ol, Additional PR-01, Revision 0, for the Fifth 10-Year Inservice Inservice Testing Interval - R.E. Ginna Nuclear Power Plant (TAC Testing Interval-NO. ME2239), dated October October 6, 2009.
On September 11,200911, 2009 R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted relief request PR-01 associated with the Fifth Ten-Year Inservice Test Program for Safety-Related Safety-Related Pumps and Valves (Reference 1). On OctoberOctober 6, 2009 the NRC responded to that submittal with a request for additional information (Reference (Reference 2). Enclosed please find the response to the staffs staff's question.
commitments contained in this letter. Should you have questions regarding this There are no regulatory commitments matter, please contact Thomas Harding (585) (585) 771-5219, or thomas.hardingjr@constellation.com.
thomnas.hardingjrgconstellation.com.
Very truly yours, Swift Paul M. Swift
Attachment:
Response to Request for' for Additional Information Associated With Relief Relief Request Number PR-Ol PR-01 AJ4L7 (74 1.J'0 L'Ni q 6 - /00ý?0'03
Document Control Desk October 16, 2009 October Page 2 cc: S. J. Collins, NRC D. V. Pickett, NRC Resident Inspector, NRC
ATTACHMENT ATTACHMENT Response to Request for Additional Information Response Associated With Information Associated Request Number PR-Ol Relief Request PR-01 RE. Ginna Nuclear Power Plant, LLC R.E.
16, 2009 October 16,
ATTACHMENT ATTACHMENT
Response
Response to RequestRequest for Additional Information Associated Associated With Relief Request Number PR-Ol PR-01 Question Question It is the NRC staff's understanding understandingthat the diesel transferpumps PDG02A diesel fuel oil transfer PDGO2A and and PDGO2B PDG028 are positive displacement are displacement pumps. Please Please explain explain how the proposedproposedalternative alternative testing methodology utilizingutilizing the accuracy accuracy in design design analysis 4526-ME-20 meets the analysis EWR 4526-ME-20 recommendations recommendations as described described in NUREG-1482, NUREG-1482, Revision 1, Section 5.5.2.
1, Section 5.5.2.
Response
Ginna's Ginna's diesel fuel oil transfer pumps, PDG02A & & PDG02B, are positive displacement displacement pumps.
The flow rate for these pumps is determined determined by measuring measuring the indicated level change change in in the the diesel generator generator fuel oil day tank during a timed pump run and converting this data into fuel oil transfer pump flow rate for both the Group 8B and comprehensive comprehensive pump tests.
Level Gauges LG-2044 ("A" E DIG) and LG-2045 LG-2045 ("8" ("B" EE DIG) are utilized to measure the the change change in in indicated level while the fuel oil transfer pump is running and restoring fuel oil day tank level. 80th Both LG-2044 LG-2044 and LG-2045 (sight glasses equipped equipped with a reference scale in in inches of level) inches level) have a range of indicatedindicated level of 99 inches (2.5 inches to 11.5 11.5 inches).
The respective day tank is drained drained to an initial indicated indicated level of 5.0 to 5.5 inches before before initiating the fuel oil pump start. This level level is logged as the initial level. The pump is then started coincident coincident with with starting starting the stopwatch and the system allowed allowed to stabilize. A minimum 2 minute minute stabilization stabilization period is observed for the comprehensive comprehensive test.
Following a total minimum run time of 5 minutes (or exceeding Following exceeding an indicated tank level of 11 11 inches),
inches), the pump is stopped coincident coincident with stopping the stopwatch the. stopwatth and the day tank level is read in in inches to the nearestnearest 0.25 inch. This level is logged as the final level.
The change in in day tank level is determined determined in in inches and then converted converted to total gallons gallons pumped using the constant conversion conversion factor of 24.76 gallons per inch. The constant of 24.76 gallons per gallons per inch inch ofof indicated indicated level level on on the day day tank tank sight sight glass was established by EWR 4526-ME-20 based on the tank's geometrical ME-20 based on the tank's geometrical dimensions. dimensions.
i The total The total gallons gallons pumped pumped is is then then divided by the total total pump pump runrun time time to to arrive at the arrive at the pump pump test flow rate rate inin gallons gallons per minuteminute (gpm). This calculation calculation is documented documented in in the pump test procedures.
procedures.
The test circuit The test circuit for for each each pump is a fixed flow path from the storage tank (pump suction) to the the day tank (pump discharge).
day tank (pump discharge). Pump Pump suction suction pressure pressure is nearly constant because of the very small change in in storage tank level. This change change in in suction pressure during pump operation is is considered negligible.
considered negligible. The The normal normal rise rise in day tank level in day level is is approximately approximately 5.5 inches, which which corresponds to corresponds to aa quantity quantity of of approximately approximately 136 gallons pumped 136 gallons pumped during the the 55 minutes of pump pump operation, resulting in operation, in a typical typical flow rate rate of approximately approximately 27 gpm. The current flow rate rate reference values of each reference each pump pump are as follows: PDG02A - 27.2 gpm, PDG028 PDG02B - 27.1 gpm.
1I
ATTACHMENT ATTACHMENT Response to Request for Additional Information Associated Additional Information Associated With Relief Request Number PR-Ol PR-01 The small rise inin day tank level during pump operation does not affect pump discharge discharge pressure pressure or flow rate. This conclusion is supported supported by the discussion discussion inin NUREG 1482 Rev.1, section Rev.1, section 5.5.2, where the NRC states: "Pump discharge discharge pressure will match match system pressure up to the the shutoff head head of the positive displacement Because of the characteristics displacement pump. Because characteristics of a positive positive displacement pump, there should be virtually no change in displacement in pump discharge discharge flow rate as a result of the rising tank level.
of level. Therefore, Therefore, rising tank level will not have an impact on test results. By By having approximately approximately the same level in in the tank at the beginning beginning of each test, licensees licensees can achieve repeatable results."
The accuracy of level gauges, LG-2044 and LG-2045, is determined The accuracy determined using the nine (9) inch indicated range of level and the constant of 24.76 gallons per inch. This yields a total volume indicated volume change of 222.84 gallons. Based change Based on a readability uncertainty of +/- 0.125 inch (0.25 inch readability uncertainty scaling),
scaling), which isis equivalent equivalent to 3.10 gallons, divided by the total indicated volume of 222.84222.84 gallons, the overall accuracy accuracy of the sight glass is +/- 1.39%.
In addition, the stopwatch In stopwatch used to measure measure the time the pump is operating and pumping pumpirig fuel oil accurate to within +/-+/- 0.6 seconds per minute for a calibrated accuracy is accurate accuracy of +/- 1.0%. Combining
+/- 1.0%. Combining the accuracies accuracies ofof the the level level gauge sight glass and stopwatch, using the square square root of the sum of the squares method, results in in an overall indicated indicated accuracy accuracy of +/- 1.711.71%. overall accuracy
%. This overall unchanged from that which relief was granted is unchanged granted for during th 10-year during the 44th interval 1ST 10-year interval IST program.
2
