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| | issue date = 11/03/1997 | | | issue date = 11/03/1997 |
| | title = Clarifies Testing Commitment Made Re Insp Rept 50-244/97-201 & Notifies That Appropriate Alternative to Clarified Testing Commitment Has Been Performed During Current Refueling Outage | | | title = Clarifies Testing Commitment Made Re Insp Rept 50-244/97-201 & Notifies That Appropriate Alternative to Clarified Testing Commitment Has Been Performed During Current Refueling Outage |
| | author name = MECREDY R C | | | author name = Mecredy R |
| | author affiliation = ROCHESTER GAS & ELECTRIC CORP. | | | author affiliation = ROCHESTER GAS & ELECTRIC CORP. |
| | addressee name = VISSING G S | | | addressee name = Vissing G |
| | addressee affiliation = NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) | | | addressee affiliation = NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| | docket = 05000244 | | | docket = 05000244 |
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| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE |
| | page count = 5 | | | page count = 5 |
| | | project = |
| | | stage = Other |
| }} | | }} |
| See also: [[followed by::IR 05000244/1997201]]
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| =Text= | | =Text= |
| {{#Wiki_filter:CATEGORY1REGULATORYINFORMATIONDISTRIBUTIONSYSTEM(RIDS)ACCESSIONNBR:9711120009DOC.DATE:97/11/03NOTARIZED:NODOCKETFACZL:50-244RobertEmmetGinnaNuclearPlant,Unit1,RochesterG05000244AUTH.NAMEAUTHORAFFILIATION'MECREpY,R.C.RochesterGasaElectricCorp.RECIP.NAMERECIPIENTAFFILIATIONVISSING,.G.S.SUBJECT:Clarifiestestingcommitmentmadereinsprept50-244/97-201¬ifiesthatappropriatealternativetoclarifiedtestingcommitmenthasbeenperformedduringcurrentrefuelingoutae.gDISTRIBUTION,CODE:IE01DCOPIESRECEIVED:LTRENCLSIZE:TITLE:General(50Dkt)-ZnspRept/NoticeofViolationResponseCNOTES:LicenseExpdateinaccordancewith10CFR2,2.109(9/19/72).05000244EG,RECIPIENTIDCODE/NAMEPD1-1PDINTERNAL:AEOD/SPD/RAB.DEDRONRR/DISP/PIPBNRR/DRPM/PECBNUDOCS-ABSTRACTOGC/HDS3XTERNAL:LZTCOBRYCE,JHNRCPDRCOPIESLTTRENCL1'11111RECIPIENTIDCODE/NAMEVISSING,G.AEODLECENTECH/HHFBNRR/DRPM/PERBOEDIRRGN1FILE01NOACNUDOCSFULLTEXTCOPIESLTTRENCLD0NNOTETOALL"RIDS"RECIPIENTS:PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATIONREMOVEDFROMDISTRIBUTIONLISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION,CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION415-2083TOTALNUMBEROFCOPIESREQUIRED:LTTR18ENCL | | {{#Wiki_filter:CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) |
| 0
| | ACCESSION NBR:9711120009 DOC.DATE: 97/11/03 NOTARIZED: NO DOCKET FACZL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION |
| November3,1997U.S.NuclearRegulatoryCommissionDocumentControlDeskAttn:GuyS.Vissing'rojectDirectorateI-1Washington,D.C.20555Subject:ClarificationofA/EInspectionCommitmentNRCInspectionReportNo.50-244/97-201R.E.GinnaNuclearPowerPlantDocketNo.50-244DearMr.Vissing:DuringtheperiodfromJune9throughAugust15)1997theUS.NuclearRegulatoryCommission(NRC),OfficeofNuclearReactorRegulation(NRR)performedanA/EInspectionoftheR.E.GinnaNuclearPowerPlant.Duringthisinspection,theNRCinferredthatRochesterGas&Electric(RG&E)hadcommittedtoperformingseatleakagetestingfortwoComponentCoolingWater(CCW)Systemcheckvalves.TheintentofthiscorrespondenceistoclarifythetestingcommitmentmadebyRG&E.Also,RG&EwishestonotifytheNRCthatanappropriatealternativetotheclarifiedtestingcommitmenthasbeenperformedduringthecurrentrefuelingoutage.DuetotheshortperiodoftimefromthereceiptofNRCInspectionReport50-244/97-201totheprojectedcompletionofthisrefuelingoutage,RG&EbelievesitisprudenttonotifytheNRCofthecheckvalvetestclarificationandproposedalternativenow,ratherthan60daysafterissuanceoftheinspectionreport.Asrequestedintheinspectionreport,RG&Ewillprovideascheduleforcompletionofcorrectiveactions,whereapplicable,within60daysofissuanceoftheinspectionreport.NRCInspectionReportNo.50-244/97-201,underSectionEl(ConductofEngineering),ItemE1.2.2.2(d)(CCWSystemTesting)lgg]states:"thelicenseestatedthatvalves753AandBwouldbeaddedtothein-serviceinspectionprogramandrequireleaktesting."Itiscorrectthatcheckvalves753Aand753BwillbeaddedtotheGinnaStationInserviceTestingProgram,butwithatestrequirementofcheckvalveclosureverificationtestingandnotseatleakagetesting.II!Ill!(llllll/llllllllllllillfIlla'll
| | 'MECREpY,R.C. Rochester Gas a Electric Corp. |
| Checkvalves753Aand753BareintheCCWSystemsupplypipingtothereactorcoolantpumpthermalbarriers.Althoughthesevalves'aredesignedaspressureclassboundariesbetweentheReactorCoolantSystemandthelowerpressureCCWSystem,theyarenot,consideredpressureisolationvalves(PIVs)since,shouldathermalbarrierleakoccur,theassociatedCCWpipingisprotectedfromoverpressurebypressurereliefvalvesandtheGinnaStationlicensingbasisconsidersathermalbarrierleakasasmallbreaklossofcoolantaccident.SincethecapacityoftheassociatedpressurereliefvalvesissufficienttoprovideoverpressureprotectionfortheaffectedCCWSystempipingshouldathermalbarrierleakoccur,thesafetyfunctionofcheckvalves753Aand753Bistoclosetomitigatetheconsequencesoftheaccident.Thus,seat,leakageintheclosedpositionisinconsequential.Therefore,RG&Eagreesthatitisprudenttosubjectcheckvalves753Aand753Btoperiodicinservicetestingtoverifyclosurecapability.Inordertoperformclosureverificationtesting,amodificationisrequiredtoinstallsuitabletestconnections.Duetotheshortamountoftimefromwhenthecommitmentforinservicetestingwasmadepriortothecommencementofthecurrentrefuelingoutage,theproperpreparationswerenotabletobemadetoperformthisrequiredmodification.However,RG&Ehasdisassembledcheckvalves753Aand753BduringthisrefuelingoutagetoverifyvalveobturatormovementtotheclosedpositioninaccordancewithOMa-1988,Part10,Section4.3.2.4.ThisactivityisanacceptablealternativepursuanttoPosition2ofNRCGenericLetter89-04and,assuch,doesnotrequirearequestforrelieffromCoderequirements.RG&EintendstomodifytheaffectedpipingsystemtoinstallsuitabletestconnectionsduringtheSpring,1999refuelingoutageandtocommencetheperiodicclosureverificationtestingscheduleinaccordancewiththeGinnaStationInserviceTestingProgramatthattime.Verytrulyyours,/~grq'RobertC.MecredyGJW5482
| | RECIP.NAME RECIPIENT AFFILIATION VISSING,.G.S. |
| xc:Mr.GuyS.Vissing(MailStop14B2).ProjectDirectorateI-1Washington,D.C.20555U.S.NuclearRegulatoryCommissionRegionI475AllendaleRoadKingofPrussia,PA19406USNRCGinnaSeniorResidentInspector
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| }} | | ==SUBJECT:== |
| | Clarifies testing commitment made re insp rept 50-244/97-201 |
| | & notifies that appropriate alternative to clarified testing commitment has been performed during current refueling C outa g e. |
| | DISTRIBUTION,CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE: |
| | TITLE: General (50 Dkt)-Znsp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 E G, |
| | RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-1 PD VISSING,G. |
| | INTERNAL: AEOD/SPD/RAB 1 AEOD |
| | .DEDRO '1 LE CENTE NRR/DISP/PIPB 1 CH/HHFB NRR/DRPM/PECB 1 NRR/DRPM/PERB NUDOCS-ABSTRACT 1 OE DIR OGC/HDS3 1 RGN1 FILE 01 XTERNAL: LZTCO BRYCE,J H NOAC NRC PDR NUDOCS FULLTEXT D 0 |
| | N NOTE TO ALL "RIDS" RECIPIENTS: |
| | PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL |
| | |
| | 0 November 3, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Guy S. Vissing Directorate I-1 |
| | 'roject Washington, D.C. 20555 |
| | |
| | ==Subject:== |
| | Clarification of A/E Inspection Commitment NRC Inspection Report No. 50-244/97-201 R. E. Ginna Nuclear Power Plant Docket No. 50-244 |
| | |
| | ==Dear Mr. Vissing:== |
| | |
| | During the period from June 9 through August 15) 1997 the U S. |
| | Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor Regulation (NRR) performed an A/E Inspection of the R.E. Ginna Nuclear Power Plant. During this inspection, the NRC inferred that Rochester Gas & Electric (RG&E) had committed to performing seat leakage testing for two Component Cooling Water (CCW) System check valves. The intent of this correspondence is to clarify the testing commitment made by RG&E. Also, RG&E wishes to notify the NRC that an appropriate alternative to the clarified testing commitment has been performed during the current refueling outage. |
| | Due to the short period of time from the receipt of NRC Inspection Report 50-244/97-201 to the projected completion of this refueling outage, RG&E believes it is prudent to notify the NRC of the check valve test clarification and proposed alternative now, rather than 60 days after issuance of the inspection report. As requested in the inspection report, RG&E will provide a schedule for completion of corrective actions, where applicable, within 60 days of issuance of the inspection report. |
| | NRC Inspection Report No. 50-244/97-201, under Section El (Conduct of Engineering), Item E1. 2. 2. 2 (d) (CCW System Testing) l gg] |
| | states: |
| | "the licensee stated that valves 753A and B would be added to the in-service inspection program and require leak testing." |
| | It is correct that check valves 753A and 753B will be added to the Ginna Station Inservice Testing Program, but with a test requirement of check valve closure verification testing and not seat leakage testing. |
| | II!Ill!(llllll/llllllllllllillf Illa'll |
| | |
| | Check valves 753A and 753B are in the CCW System supply piping to the reactor coolant pump thermal barriers. Although these valves |
| | 'are designed as pressure class boundaries between the Reactor Coolant System and the lower pressure CCW System, they are not, considered pressure isolation valves (PIVs) since, should a thermal barrier leak occur, the associated CCW piping is protected from overpressure by pressure relief valves and the Ginna Station licensing basis considers a thermal barrier leak as a small break loss of coolant accident. |
| | Since the capacity of the associated pressure relief valves is sufficient to provide overpressure protection for the affected CCW System piping should a thermal barrier leak occur, the safety function of check valves 753A and 753B is to close to mitigate the consequences of the accident. Thus, seat, leakage in the closed position is inconsequential. |
| | Therefore, RG&E agrees that 753A and 753B to periodic it is prudent to subject check valves inservice testing to verify closure capability. In order to perform closure verification testing, a modification is required to install suitable test connections. |
| | Due to the short amount of time from when the commitment for inservice testing was made prior to the commencement of the current refueling outage, the proper preparations were not able to be made to perform this required modification. However, RG&E has disassembled check valves 753A and 753B during this refueling outage to verify valve obturator movement to the closed position in accordance with OMa-1988, Part 10, Section 4.3.2.4. This 2 of activity is an acceptable alternative pursuant to Position request NRC Generic Letter 89-04 and, as such, does not require a for relief from Code requirements. |
| | RG&E intends to modify the affected piping system to install suitable test connections during the Spring, 1999 refueling outage and to commence the periodic closure verification testing schedule in accordance with the Ginna Station Inservice Testing Program at that time. |
| | Very truly yours, |
| | /~grq ' |
| | Robert C. Mecredy GJW5482 |
| | |
| | xc: Mr. Guy S. Vissing (Mail Stop 14B2) |
| | .Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 US NRC Ginna Senior Resident Inspector}} |
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Informs That Util Wishes to Amend Extend of Alternate Exams Provided for Relief Request Re ISI Program ASME Section XI Require Exams for First 10-Yr Interval for Containment
ML17265A6741999-06-15015 June 1999
Submits Annual ECCS Rept IAW 10CFR50.46(a)(3)(ii) Requirements.No Changes Have Been Made to Large Break LOCA PCT & Small Break LOCA PCT
ML17265A6751999-06-11011 June 1999
Responds to NRC RAI Re Licensee GL 96-05 Program.Encl Info Verifies That Util Is Implementing Provisions of JOG Program on MOV Periodic Verification
ML17309A6551999-06-0707 June 1999
Responds to NRC 990310 RAI Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment
ML17265A6671999-06-0101 June 1999
Requests Approval of Ginna QA Program for Radioactive Matl Packages,Form 311,approval Number 0019.Ginna QA Program for Station Operation, Was Most Recently Submitted to NRC by Ltr Dtd 981221 & Supplemented on 990301
ML17265A6641999-05-25025 May 1999
Forwards Addl Info on Use of GIP Method a for Re Ginna Nuclear Power Plant.Copy of Re Ginna Station USI A-46 Outlier Resolution Table as Requested
ML17265A6611999-05-24024 May 1999
Forwards LER 99-007-00 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Rt.Util Is Planning to Submit Suppl to LER by 990730
ML20206U0921999-05-13013 May 1999
Forwards Four Copies of Rev R to Gnpp Security Plan,Per Provisions of 10CFR50.54(p).Rev Clarifies Armed Response Team Assignments & Does Not Degrade Physical Security Effectiveness.Rev Withheld,Per 10CFR73.21
ML17265A6461999-05-12012 May 1999
Forwards 1998 Annual Radioactive Effluent Release Rept & 1998 Annual Radiological Environ Operating Rept, for Re Ginna NPP
ML17265A6411999-05-12012 May 1999
Forwards LER 99-004-00 IAW 10CFR50.73 & 10CFR21.Further Assessment Will Be Provided in Suppl to LER by 990630
ML20206E7221999-04-29029 April 1999
Forwards Four Copies of Rev Q to Re Ginna Nuclear Power Plant Security Plan,Per 10CFR50.54(p).Changes Do Not Degrade Physical Security Effectiveness.Encl Withheld,Per 10CFR73.21
ML20206H6911999-04-22022 April 1999
Forwards Info Requested During Informal Telcon on 980408 Concerning Upcoming Osre at Ginna Station.Info Requested Listed.Without Encls
ML17265A6271999-04-19019 April 1999
Forwards Rev 0 & Rev 1 to Colr,Cycle 28 for Re Ginna NPP, Per TS 5.6.5
ML17309A6501999-04-14014 April 1999
Forwards Revised Ginna Station EOPs & Procedures Index
ML17265A6121999-03-29029 March 1999
Forwards Rept on Status of Decommissioning Funding for Re Ginna Npp,For Which Rg&E Is Sole Owner,Per 10CFR50.75. Data Presented Herein,Current as of 981231
ML17265A6041999-03-24024 March 1999
Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii)(B) & 10CFR21.Addl Analyses Are Being Performed to Support Future Cycle Operation & Supplemental LER Is Scheduled to Be Submitted by 990618
ML17265A5641999-03-0101 March 1999
Forwards Response to NRC 990217 RAI Concerning Changes to QA Program for Re Ginna Station Operation.Rg&E Is Modifying Changes Requested in 981221 Submittal.Modified QA Program,Encl
ML17265A5671999-03-0101 March 1999
Forwards Application for Amend to License DPR-18,to Revise TSs Battery Cell Parameters Limit for Specific Gravity (SR 3.8.6.3 & SR 3.8.6.6).Supporting Tss,Encl
ML17265A5551999-02-25025 February 1999
Informs That Util Is in Process of Revising fitness-for-duty Program,Developed in Accordance with 10CFR26.Util Will Continue to Use Dept of Health & Human Svcs Certified Test Facility for Majority of Tests During Yr
ML17265A5561999-02-22022 February 1999
Forwards FFD Performance Data Rept for Six Months Ending 981231,per 10CFR26.71(d)
ML17265A5451999-02-12012 February 1999
Forwards Simulator Four Year Certification Rept,Per 10CFR55.45(b)(5)(ii)
ML17309A6491999-02-12012 February 1999
Forwards Ginna Station EOPs
ML17265A5431999-02-0909 February 1999
Supplements 980806 Relief Request with Attached Table.Util Third 10-Yr ISI of Reactor Vessel Being Performed During 1999 Refueling Outage,Beginning on 990301
ML17265A5361999-02-0202 February 1999
Forwards Response to NRC 981203 RAI Re Resolution of Unresolved Safety Issue USI A-46.Util Does Not Agree with NRCs Interpretation.Detailed Bases,Encl
ML17311A0691999-01-25025 January 1999
Forwards Revs to Ginna Station Emergency Plan Implementing Procedures (Epips).Previous Rev Had Incorrect Effective Date
ML17311A0671999-01-14014 January 1999
Forwards Revised Emergency Operating Procedures for Re Ginna NPP
ML17265A5131999-01-12012 January 1999
Forwards Revised Cover Page for Ginna Station Technical Requirements Manual (Trm), Rev 7,correcting Error in Effective Date
ML17265A5111999-01-11011 January 1999
Requests Relief Per 10CFR50.55a(a)(3)(ii) from Certain Requirements of Section XI of ASME Bp&V Code for ISI Program.Relief Requests 37,38 & 39 Encl
ML17265A5101999-01-11011 January 1999
Requests Relief Per to 10CFR50.55a(a)(3)(ii) from Certain Requirements of Section XI of ASME B&PV Code for ISI Program.Relief Request 40 Encl
1999-09-30
[Table view] |
Text
CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9711120009 DOC.DATE: 97/11/03 NOTARIZED: NO DOCKET FACZL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION
'MECREpY,R.C. Rochester Gas a Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION VISSING,.G.S.
SUBJECT:
Clarifies testing commitment made re insp rept 50-244/97-201
& notifies that appropriate alternative to clarified testing commitment has been performed during current refueling C outa g e.
DISTRIBUTION,CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Znsp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 E G,
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-1 PD VISSING,G.
INTERNAL: AEOD/SPD/RAB 1 AEOD
.DEDRO '1 LE CENTE NRR/DISP/PIPB 1 CH/HHFB NRR/DRPM/PECB 1 NRR/DRPM/PERB NUDOCS-ABSTRACT 1 OE DIR OGC/HDS3 1 RGN1 FILE 01 XTERNAL: LZTCO BRYCE,J H NOAC NRC PDR NUDOCS FULLTEXT D 0
N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL
0 November 3, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Guy S. Vissing Directorate I-1
'roject Washington, D.C. 20555
Subject:
Clarification of A/E Inspection Commitment NRC Inspection Report No. 50-244/97-201 R. E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Vissing:
During the period from June 9 through August 15) 1997 the U S.
Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor Regulation (NRR) performed an A/E Inspection of the R.E. Ginna Nuclear Power Plant. During this inspection, the NRC inferred that Rochester Gas & Electric (RG&E) had committed to performing seat leakage testing for two Component Cooling Water (CCW) System check valves. The intent of this correspondence is to clarify the testing commitment made by RG&E. Also, RG&E wishes to notify the NRC that an appropriate alternative to the clarified testing commitment has been performed during the current refueling outage.
Due to the short period of time from the receipt of NRC Inspection Report 50-244/97-201 to the projected completion of this refueling outage, RG&E believes it is prudent to notify the NRC of the check valve test clarification and proposed alternative now, rather than 60 days after issuance of the inspection report. As requested in the inspection report, RG&E will provide a schedule for completion of corrective actions, where applicable, within 60 days of issuance of the inspection report.
NRC Inspection Report No. 50-244/97-201, under Section El (Conduct of Engineering), Item E1. 2. 2. 2 (d) (CCW System Testing) l gg]
states:
"the licensee stated that valves 753A and B would be added to the in-service inspection program and require leak testing."
It is correct that check valves 753A and 753B will be added to the Ginna Station Inservice Testing Program, but with a test requirement of check valve closure verification testing and not seat leakage testing.
II!Ill!(llllll/llllllllllllillf Illa'll
Check valves 753A and 753B are in the CCW System supply piping to the reactor coolant pump thermal barriers. Although these valves
'are designed as pressure class boundaries between the Reactor Coolant System and the lower pressure CCW System, they are not, considered pressure isolation valves (PIVs) since, should a thermal barrier leak occur, the associated CCW piping is protected from overpressure by pressure relief valves and the Ginna Station licensing basis considers a thermal barrier leak as a small break loss of coolant accident.
Since the capacity of the associated pressure relief valves is sufficient to provide overpressure protection for the affected CCW System piping should a thermal barrier leak occur, the safety function of check valves 753A and 753B is to close to mitigate the consequences of the accident. Thus, seat, leakage in the closed position is inconsequential.
Therefore, RG&E agrees that 753A and 753B to periodic it is prudent to subject check valves inservice testing to verify closure capability. In order to perform closure verification testing, a modification is required to install suitable test connections.
Due to the short amount of time from when the commitment for inservice testing was made prior to the commencement of the current refueling outage, the proper preparations were not able to be made to perform this required modification. However, RG&E has disassembled check valves 753A and 753B during this refueling outage to verify valve obturator movement to the closed position in accordance with OMa-1988, Part 10, Section 4.3.2.4. This 2 of activity is an acceptable alternative pursuant to Position request NRC Generic Letter 89-04 and, as such, does not require a for relief from Code requirements.
RG&E intends to modify the affected piping system to install suitable test connections during the Spring, 1999 refueling outage and to commence the periodic closure verification testing schedule in accordance with the Ginna Station Inservice Testing Program at that time.
Very truly yours,
/~grq '
Robert C. Mecredy GJW5482
xc: Mr. Guy S. Vissing (Mail Stop 14B2)
.Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 US NRC Ginna Senior Resident Inspector
