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| The following address each criterion in the context of the Ginna design: 5'003270i20 9003i9 PDR ADOCK 05000244 PDC 001 MjA)py4o$5~P Overfill protection is provided through trip bistables in the reactor protection racks, which are powered from A, B, C and D 120 VAC instrument buses.Upon bistable actuation, the 120 VAC protection relays (normally powered.by the bistable)are de-energized, and the relay contacts (configured in a 2-out-of-3 matrix)open, de-energizing the vent solenoids from Train A and Train B 125 VDC power, resulting in closure of the main feedwater control and bypass valves.The Feedwater Control System receives power from the A and C 120 VAC instrument buses.Separate-breakers are used to provide power to the protection racks and the feedwater control system except Feedwater Loop A and Level Loop 461 share a common instrument Bus A breaker and a common regulator (TWINCO-MQ400A).Failure of the common breaker or regulator would cause a loss of Loop A feedwater control and.makeup of the LT-461 portion of overfill protection logic.Loss of any other breaker or regulator would only affect its associated level channel or Feedwater Control Loop B.Since overfill protection is fail safe, actuation of overfill protection will vent the feedwater control valve thus overriding any actions of the Control System.The design of overfill protection is considered to be adequate because of the fail safe design and actuation will override any actions of the feedwater control system.2.Location Overfill protection and feedwater control are physically located in separate cabinets.3.Routin-Overfill Protection The SG level transmitters, are located inside,.containment. | | The following address each criterion in the context of the Ginna design: 5'003270i20 9003i9 PDR ADOCK 05000244 PDC 001 MjA)py4o$5~P Overfill protection is provided through trip bistables in the reactor protection racks, which are powered from A, B, C and D 120 VAC instrument buses.Upon bistable actuation, the 120 VAC protection relays (normally powered.by the bistable)are de-energized, and the relay contacts (configured in a 2-out-of-3 matrix)open, de-energizing the vent solenoids from Train A and Train B 125 VDC power, resulting in closure of the main feedwater control and bypass valves.The Feedwater Control System receives power from the A and C 120 VAC instrument buses.Separate-breakers are used to provide power to the protection racks and the feedwater control system except Feedwater Loop A and Level Loop 461 share a common instrument Bus A breaker and a common regulator (TWINCO-MQ400A).Failure of the common breaker or regulator would cause a loss of Loop A feedwater control and.makeup of the LT-461 portion of overfill protection logic.Loss of any other breaker or regulator would only affect its associated level channel or Feedwater Control Loop B.Since overfill protection is fail safe, actuation of overfill protection will vent the feedwater control valve thus overriding any actions of the Control System.The design of overfill protection is considered to be adequate because of the fail safe design and actuation will override any actions of the feedwater control system.2.Location Overfill protection and feedwater control are physically located in separate cabinets.3.Routin-Overfill Protection The SG level transmitters, are located inside,.containment. |
| Level signals from four of the transmitters exit containment in the Auxiliary Building Intermediate Floor (ABI).Two of the level signals exit containment in the Intermediate Building Basement (IBB).The trip bistables are lo'cated in protection racks in the Control Room.The basic relay contacts for solenoid actuation are located in the SIA&SIB racks in the Relay Room.Routing from the penetration to the valve is illustrated on Table 1.Routin-Feedwater Control The Feedwater Control System is located in the feedwater rack in the Relay Room.The SG level signal is taken from LT-461 and, LT-471 channels via isolators located in the protection racks in the Control Room and supplied to the feedwater rack.The valve control signal is routed from the feedwater rack to the control valves as illustrated on Table 1.Overfill protection and feedwater control share common fire areas but are not routed in the same cable.A review of Ginna's safe shutdown capability in the event of any credible postulated fire (which include the common areas)was documented in our fire protection and Appendix R conformance reviews, and approved by the NRC in Safety Evaluation Reports dated 02/14/79 (Fire Protection) and 02/27/85 (Appendix R).Also, RG&E has~documented contingency actions in the event of fires in specific areas (e.g., SC-3.30 series procedures and other plans covering fire-fighting strategies for safety-related fire areas).Thus, it is considered that all required situations involving safe shutdown in the event of a fire have been addressed, and no additional changes are warranted. | | Level signals from four of the transmitters exit containment in the Auxiliary Building Intermediate Floor (ABI).Two of the level signals exit containment in the Intermediate Building Basement (IBB).The trip bistables are lo'cated in protection racks in the Control Room.The basic relay contacts for solenoid actuation are located in the SIA&SIB racks in the Relay Room.Routing from the penetration to the valve is illustrated on Table 1.Routin-Feedwater Control The Feedwater Control System is located in the feedwater rack in the Relay Room.The SG level signal is taken from LT-461 and, LT-471 channels via isolators located in the protection racks in the Control Room and supplied to the feedwater rack.The valve control signal is routed from the feedwater rack to the control valves as illustrated on Table 1.Overfill protection and feedwater control share common fire areas but are not routed in the same cable.A review of Ginna's safe shutdown capability in the event of any credible postulated fire (which include the common areas)was documented in our fire protection and Appendix R conformance reviews, and approved by the NRC in Safety Evaluation Reports dated 02/14/79 (Fire Protection) and 02/27/85 (Appendix R).Also, RG&E has~documented contingency actions in the event of fires in specific areas (e.g., SC-3.30 series procedures and other plans covering fire-fighting strategies for safety-related fire areas).Thus, it is considered that all required situations involving safe shutdown in the event of a fire have been addressed, and no additional changes are warranted. |
| 4.Technical S ecifications/Surveillance Technical Specification 3.5.2 requires SG overfill protection to be operable and specifies limiting conditions for operation should the system or portions of the system become inoperable. | | 4.Technical S ecifications/Surveillance Technical Specification |
| | |
| | ====3.5.2 requires==== |
| | SG overfill protection to be operable and specifies limiting conditions for operation should the system or portions of the system become inoperable. |
| Technical Specification Table 4.1-1 requires SG level be tested monthly..There'fore, Technical Specifications require periodic verification of system operability. | | Technical Specification Table 4.1-1 requires SG level be tested monthly..There'fore, Technical Specifications require periodic verification of system operability. |
| Procedures are in place that implement the Technical Specification requirements. | | Procedures are in place that implement the Technical Specification requirements. |
| Also, functional logic tests are performed that verify valve response.Based upon Technical Specification surveillance requirements, power supply configuration, fail-safe design of overfill protection, separate cabinets and adequate cable routing (fires have been addressed.-in Appendix R reviews), the Ginna design provides sufficient separation to ensure automatic SG overfill protection to mitigate a main feedwater overfeed event.No system modifications are planned as a result of this Generic Letter.Ver truly yours, Robert C.c d Division Manager Nuclear Production Subscribed and sworn to before me on this 19th da of March, 1990.g~l, HAUCK~~~&&aedNc York RWE/091 MONROEcoU~ | | Also, functional logic tests are performed that verify valve response.Based upon Technical Specification surveillance requirements, power supply configuration, fail-safe design of overfill protection, separate cabinets and adequate cable routing (fires have been addressed.-in Appendix R reviews), the Ginna design provides sufficient separation to ensure automatic SG overfill protection to mitigate a main feedwater overfeed event.No system modifications are planned as a result of this Generic Letter.Ver truly yours, Robert C.c d Division Manager Nuclear Production Subscribed and sworn to before me on this 19th da of March, 1990.g~l, HAUCK~~~&&aedNc York RWE/091 MONROEcoU~ |
| 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 TABLE 1 CABLE ROUTING OVERFILL PROTECTION Level Sicpal LT-461 6 LT-472 LT-463 G LT-471 Containment Penetration (AE10)ABI (AEll)ABI R~outin ABI, CT, CR ABI, CT, CR Protection Rack Location CR SIA SIB Location RR.Routine[RR, AHR, TB, Valve RR, AHR, TB, Valve LT-462<"473 (CE4)IBB IBB, CR CR RR, AHR, TB, Valve FEEDWATER CONTROL SYSTEH Level Sicgial Signal Pickup Location Feedwater Rack Location~Routin LT-461 LT-471 CR CR RR RR, AHR, TB, Valve RR, AHR;'TB, Valve~Le enu: ABI-Auxiliary Building Intermediate Floor IBB-Intermediate Building Basement CT-Cable Tunnel CR-Control Room RR-Relay Room TB-Turbine Building V>g~/C.r}} | | 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 TABLE 1 CABLE ROUTING OVERFILL PROTECTION Level Sicpal LT-461 6 LT-472 LT-463 G LT-471 Containment Penetration (AE10)ABI (AEll)ABI R~outin ABI, CT, CR ABI, CT, CR Protection Rack Location CR SIA SIB Location RR.Routine[RR, AHR, TB, Valve RR, AHR, TB, Valve LT-462<"473 (CE4)IBB IBB, CR CR RR, AHR, TB, Valve FEEDWATER CONTROL SYSTEH Level Sicgial Signal Pickup Location Feedwater Rack Location~Routin LT-461 LT-471 CR CR RR RR, AHR, TB, Valve RR, AHR;'TB, Valve~Le enu: ABI-Auxiliary Building Intermediate Floor IBB-Intermediate Building Basement CT-Cable Tunnel CR-Control Room RR-Relay Room TB-Turbine Building V>g~/C.r}} |
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Category:CORRESPONDENCE-LETTERS
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[Table view] Category:INCOMING CORRESPONDENCE
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Calculation Encl. 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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] Category:UTILITY TO NRC
MONTHYEARML20059L4481990-09-18018 September 1990 Forwards Responses to Rer 900709-13 Team Visit Findings, Per .Responses Withheld (Ref 10CFR73.21) ML17309A4491990-09-13013 September 1990 Forwards Slides Presented by Facility & Westinghouse to NRC in 900724 Meeting.Encl Withheld ML17262A1331990-09-11011 September 1990 Responds to Violations & Several Unresolved Items Noted in SSFI Rept 50-244/89-81.Update of Appropriate Unresolved Items Encl.Specific Actions Re All NRC Unresolved Items Being Tracked to Completion ML17261B1511990-08-29029 August 1990 Forwards Semiannual Radioactive Effluent Release Rept Jan- June 1990 & Rev 3 to Process Control Program for Ginna Station, Per Tech Specs 6.9.1.4 & 6.16,respectively ML17261B1481990-08-28028 August 1990 Lists Understanding of Issues Util Planning to Address Re Containment Integrity,Per 900718 Telcon.Any Concerns or Action Items Different from Listed Submittal Should Be Provided to Util Prior to NRC 900905 & 06 Visit to Plant IR 05000244/19880261990-08-20020 August 1990 Submits Update on Util Plans to Provide Appropriate Ventilation to Intermediate Bldg Clean Side,Per Violation Noted in Insp Rept 50-244/88-26.Extensive Program to Manually Close All External Openings Implemented ML17261B1501990-08-20020 August 1990 Submits Update on Util Plans to Provide Appropriate Ventilation to Intermediate Bldg Clean Side,Per Violation Noted in Insp Rept 50-244/88-26.Extensive Program to Manually Close All External Openings Implemented ML17261B1371990-08-17017 August 1990 Forwards Rev 0 to, Inservice Insp Rept for Third Interval (1990-1999),First Period,First Outage (1990) at Re Ginna Nuclear Power Plant. ML17309A4481990-08-16016 August 1990 Responds to NRC 900717 Ltr Re Violations Noted in Insp Rept 50-244/90-80.Corrective Actions:Westinghouse Drawing E-2508 Approved & Issued to Central Records ML17261B1351990-08-15015 August 1990 Provides Info & Assessment on Integrity of Connection of Containment Bldg to Foundation,Per 900808 Telcon.Util Believes That Existing Condition Not Safety Concern & No Reason Exists to Suspect Joint Will Not Perform Function ML17261B1361990-08-14014 August 1990 Responds to Commitment Tracking Concerns Noted in Insp Rept 50-244/90-09 & Planned Corrective Actions.Util Confirms Commitments Dates for Implementation of Effective Shelf Life Program & Comprehensive Preventive Maint Program for Parts ML17261B1331990-08-13013 August 1990 Recommits to Performing Enhanced primary-to-secondary Leak Rate Monitoring,Per NRC Bulletin 88-002 ML17261B1261990-07-30030 July 1990 Clarifies Commitment Made in 900316 RO Re Restoring Inoperable Fire Damper I-411-21-P.Util Plans to Design Removable Track Which Will Allow Charcoal Drawer to Be Manipulated.Definitive Schedule Will Be Provided in 60 Days ML20055H9291990-07-23023 July 1990 Forwards Revised Page 6:4 of Plant Security Plan.Page Withheld Per 10CFR73.21 ML17261B1091990-07-20020 July 1990 Advises That Structural Evaluations of Containment Sys Being Performed in Response to Containment Integrity Insp ML17309A4471990-07-17017 July 1990 Forwards Decommissioning Rept, for Plant,Per 10CFR50.33(k) & 50.75(b) ML17261B0881990-07-13013 July 1990 Provides Update to Util 860616 Ltr Re Implementation of NUREG-0737,Item 6.2,Suppl 1, Emergency Response Capability. ML17261B0921990-07-11011 July 1990 Responds to 900709 Request for Addl Info Re Containment Integrity Insp.Util Will Provide Preliminary Results by 900716 Re Where Groundwater Entering Annular Access Area. Meeting Proposed for Wk of 900723 ML20044B0481990-07-10010 July 1990 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 ML17309A4461990-07-0909 July 1990 Responds to Generic Ltr 90-04 Re Status of Licensee Implementation of Generic Safety Issues Resolved W/ Imposition of Requirements or Corrective Actions ML17261B0931990-07-0909 July 1990 Responds to Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Util Completed All Actions Requested in Generic Ltr & Will Retain Documentation Verification for Min of 2 Yrs ML17261B0901990-07-0909 July 1990 Advises That Licensee Will Install Containment Isolation Signal Going to Valve AOV 745 by End of 1992 Refueling Outage,Per Util 900608 Ltr Notifying of Condition Outside Design Basis of Plant Under 10CFR50.72 Criterion ML17250B2151990-06-29029 June 1990 Forwards Application for Amend to License DPR-18, Reformatting Auxiliary Electrical Sys Tech Specs & Action Statements for Offsite & Onsite Power Sources Available for Plant Auxiliaries ML17261B0851990-06-28028 June 1990 Forwards LER 89-016-02 Re 891117 Failure of Safety Injection Block/Unblock Switch Which Could Render Both Trains of Safety Injection Sys Inoperable.Also Reported Per Part 21 ML17250B1991990-06-0808 June 1990 Responds to NRC 900509 Ltr Re Violations Noted in Insp Rept 50-244/89-81.Corrective Actions:Improved Battery Load Profile Developed Incorporating Calculational Improvements Contained in Current Industry Std IEEE 485-1983 ML17250B1951990-06-0505 June 1990 Responds to Generic Ltr 89-08, Erosion/Corrosion Induced Pipe Wall Thinning. Util Developed Erosion/Corrosion Program for Single & Two Phase Sys Consistent W/Requirements of NUREG-1344 & NUMARC 870611 Rept ML17250B1851990-06-0101 June 1990 Forwards Application for Amend to License DPR-18,providing Guidance for Action Statements Associated W/Power Distribution Limit Specs ML17261B0691990-06-0101 June 1990 Discusses Testing Frequency for Insp of Incore Neutron Monitoring Sys Thimble Tubes,Per NRC Bulletin 88-009.Thimble Tube Indicating Greatest Wear Recently Repositioned in Effort to Minimize Future Wear ML17250B1811990-05-31031 May 1990 Forwards Addl Info Re Response to Notice of Violation from Insp Rept 50-244/90-04.Info Withheld (Ref 10CFR73.21) ML17250B1801990-05-29029 May 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Util Does Not Need to Develop Enhanced Surveillance Program to Monitor Currently Installed Transmitter Based Upon Limited Installed Quantity ML17250B1841990-05-29029 May 1990 Responds to NRC Bulletin 89-002, Stress Corrosion Cracking of High Hardness Type 410 Stainless Steel (SS) Internal Pre-Load Bolting.... Valves Disassembled & 410 SS Studs Removed & Visually & Liquid Penetrant Examined ML17261B0961990-05-29029 May 1990 Responds to NRC 900427 Ltr Re Violations Noted in Insp Rept 50-244/90-07.Corrective Actions:Worker Records Immediately Corrected Indicating That Worker Received No Significant Exposure for Time While Error Occurred ML17250B1721990-05-18018 May 1990 Forwards Rev 1 to Summary Exam Rept for 1990 Steam Generator Eddy Current Insp. Rept Summarizes Observations & Corrective Actions Resulting from Insps Performed During 1990 Outage ML20042G8931990-05-0808 May 1990 Forwards Revised Emergency Operating Procedures,Including Rev 3 to AP-RHR.2,Rev 1 to ES-0.3 & Rev 11 to ES-1.3 ML17261B0611990-04-26026 April 1990 Advises of Changes to 890201 Commitments Made Under Programmed Enhancement Response to Generic Ltr 88-17.Changes Will Not Reduce Capability to Operate Safely in Reduced Inventory Condition or Scope of Programmed Enhancements ML17261B0591990-04-17017 April 1990 Advises That No Interlocks Required for RHR motor-operated Valves 701 & 720 Based on Present Arrangement.Listed Failures Would Have to Occur in Order for Potential Overpressurization of RHR Sys to Occur ML17261B0461990-04-12012 April 1990 Responds to Issues Discussed During 900323 Telcon Re Inservice Testing Program Status & Relief Request.Current Test Methodology for Seat Leakage Acceptable Based on Application of Direct Measurement Sys ML17262A1431990-04-12012 April 1990 Responds to NRC 900202 Ltr Re Weaknesses Noted in Insp Rept 50-244/89-80.Corrective Actions:Procedure ES-0.3 Modified to Provide Guidance for Rapid Cooldown & Depressurization W/ & W/O Reactor & Vessel Instrumentation Sys ML17250B1451990-04-0606 April 1990 Discusses Impact of SER Issuance for Inservice Insp & Inservice Testing Programs & Advises That Timing Will Not Affect Util Implementation Plans for Programs,Except as Listed ML17250B1441990-04-0505 April 1990 Responds to NRC 900309 Ltr Re Violations Noted in Insp Rept 50-244/90-02.Corrective Actions:Positive Indicator Will Be Installed for All Check Valves to Enhance Visible Positive Position Verification Ability & to Avoid Confusion ML17261B0401990-03-30030 March 1990 Advises That Final Results of Station Blackout Documentation Review Will Be Submitted to NRC on or About 900501 ML17261B0321990-03-28028 March 1990 Forwards Annual Rept of ECCS Model Revs as Applicable to Facility,Per 10CFR50.46.Mods to Model for Small Break LOCA Do Not Affect Calculated Peak Clad Temp ML17261B0331990-03-28028 March 1990 Forwards Info Re Reactor Vessel Issues,Per 900305 Telcon Concerning Change of License Expiration Date ML17261B0231990-03-26026 March 1990 Responds to NRC 890222 Ltr Re Violations Noted in Insp Rept 50-244/89-17.Corrective Actions:Personnel Verified Safety Injection Block/Unblock Switch in Proper Position & Operator Procedure 0-1.1 Changed as Indicated ML17261B0281990-03-23023 March 1990 Forwards Addl Info Re Proposed Tech Spec Amend Concerning Use of Reconstituted Fuel,Per 900315 Telcon.During Fuel Assembly Reconstitution,Failed Fuel Rods Will Be Placed W/ Filler Rods ML17261B0221990-03-22022 March 1990 Provides Revised Test Schedule for motor-operated Valve Diagnostic Test Program,Per IE Bulletin 85-003.NRC Notification of Changes to Valve Operability Program Required by Generic Ltr 89-10,dtd 890828 ML17261B0411990-03-20020 March 1990 Forwards Summary of Onsite Property Damage Coverage Currently in Force at Plant,Per 10CFR50.54(w)(4) ML17261B0151990-03-19019 March 1990 Responds to Generic Ltr 89-19, Safety Implication of Control Sys in LWR Nuclear Plants (USI A-47). Overfill Protection Provided Through Trip Bistables in Reactor Protection Racks Powered from 120-volt Instrument Buses ML17261B0101990-03-15015 March 1990 Forwards Application for Amend to License DPR-18,allowing Use of Reconstituted Fuel Assemblies ML20012D2831990-03-14014 March 1990 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 1990-09-18
[Table view] |
Text
ACCELERATED DISTBJBUTION DEMONSTPA,TION SYSHM I I REGULATORY-.
INFORMATION DISTRIBUTION SYSTEM (RI DS)ACCESSION,,NBR:9003270120 DOC.DATE: 90/03/19 NOTARIZED:
YES FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas 6 Electric Corp.RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.
Project Directorate I-3 DOCKET G 05000244 R
SUBJECT:
Responds to Generic Ltr 89-19,"Safety Implication of Control Sys in LWR Nuclear Plants." DISTRIBUTION CODE A001D COPIES RECEIVED:LTR ENCL SIZE: TITLE: OR Submittal:
General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
D S 05000244 RECIPIENT ID CODE/NAME PD1-3 LA JOHNSON,A INTERNAL: NRR/DET/ECMB 9H NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 5 5 1 1 1 1 1 1 1 1~.1 0 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD1-3 PD NRR/DOEA/OTSB11 NRR/DST/SELB 8D NRR/DST/SRXB 8E 0 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 0 1 1 1 1 D D'D NOTE TO ALL"RIDS" RECIPIENTS:
A D D PLEASE HELP US TO REDUCE WASTEI CONTACT THE.DOCUMENT CONTROL DESK, ROOM PI-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISIRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 19 I'lÃlllll/f/EIFIE EIaI (h la ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N Y.14649.0001 March 19, 1990 TELEPHONE AREA COOE 715 546.2700 U.S.Nuclear Regulatory Commission Document Control Desk Attn: Allen" R.Johnson Project Directorate I-3 Washington, D.C.20555
Subject:
Generic Letter 89-19,"Safety Implication of Control System in LWR Nuclear Power Plants" (USI A-47)R.E.Ginna Nuclear Power Plant Docket No.50-244
Dear Mr.Johnson:
Generic Letter 89-19 required licensees to respond within 180 days of the Generic Letter detailing whether the recommendations of the letter will be implemented and an implementation schedule if applicable.
The Generic Letter addresses concerns about.Steam Generator (SG)overfill protection.
At Ginna, overfill protection is initiated on a SG high-water-level signal based on a 2-out-of-3 initiating logi'c.This instrumentation is safety grade but one of the three channels is used for both control and protection.
The system isolates Main Feedwater (MFW)by closing the main feedwater.
control and bypass valves.In terms of USI A-47, this design is concluded to be acceptable if: A)The Feedwater Control System is not powered from the same source as overfill protection.
B)Overfill protection and feedwater control are not located within the same cabinets.C)Overfill protection and feedwater control signals are routed such that a fire is not likely to affect both systems.D)Plant procedures and.Technical Specifications include requirements to periodically verify operability of overfill protection.
The following address each criterion in the context of the Ginna design: 5'003270i20 9003i9 PDR ADOCK 05000244 PDC 001 MjA)py4o$5~P Overfill protection is provided through trip bistables in the reactor protection racks, which are powered from A, B, C and D 120 VAC instrument buses.Upon bistable actuation, the 120 VAC protection relays (normally powered.by the bistable)are de-energized, and the relay contacts (configured in a 2-out-of-3 matrix)open, de-energizing the vent solenoids from Train A and Train B 125 VDC power, resulting in closure of the main feedwater control and bypass valves.The Feedwater Control System receives power from the A and C 120 VAC instrument buses.Separate-breakers are used to provide power to the protection racks and the feedwater control system except Feedwater Loop A and Level Loop 461 share a common instrument Bus A breaker and a common regulator (TWINCO-MQ400A).Failure of the common breaker or regulator would cause a loss of Loop A feedwater control and.makeup of the LT-461 portion of overfill protection logic.Loss of any other breaker or regulator would only affect its associated level channel or Feedwater Control Loop B.Since overfill protection is fail safe, actuation of overfill protection will vent the feedwater control valve thus overriding any actions of the Control System.The design of overfill protection is considered to be adequate because of the fail safe design and actuation will override any actions of the feedwater control system.2.Location Overfill protection and feedwater control are physically located in separate cabinets.3.Routin-Overfill Protection The SG level transmitters, are located inside,.containment.
Level signals from four of the transmitters exit containment in the Auxiliary Building Intermediate Floor (ABI).Two of the level signals exit containment in the Intermediate Building Basement (IBB).The trip bistables are lo'cated in protection racks in the Control Room.The basic relay contacts for solenoid actuation are located in the SIA&SIB racks in the Relay Room.Routing from the penetration to the valve is illustrated on Table 1.Routin-Feedwater Control The Feedwater Control System is located in the feedwater rack in the Relay Room.The SG level signal is taken from LT-461 and, LT-471 channels via isolators located in the protection racks in the Control Room and supplied to the feedwater rack.The valve control signal is routed from the feedwater rack to the control valves as illustrated on Table 1.Overfill protection and feedwater control share common fire areas but are not routed in the same cable.A review of Ginna's safe shutdown capability in the event of any credible postulated fire (which include the common areas)was documented in our fire protection and Appendix R conformance reviews, and approved by the NRC in Safety Evaluation Reports dated 02/14/79 (Fire Protection) and 02/27/85 (Appendix R).Also, RG&E has~documented contingency actions in the event of fires in specific areas (e.g., SC-3.30 series procedures and other plans covering fire-fighting strategies for safety-related fire areas).Thus, it is considered that all required situations involving safe shutdown in the event of a fire have been addressed, and no additional changes are warranted.
4.Technical S ecifications/Surveillance Technical Specification
3.5.2 requires
SG overfill protection to be operable and specifies limiting conditions for operation should the system or portions of the system become inoperable.
Technical Specification Table 4.1-1 requires SG level be tested monthly..There'fore, Technical Specifications require periodic verification of system operability.
Procedures are in place that implement the Technical Specification requirements.
Also, functional logic tests are performed that verify valve response.Based upon Technical Specification surveillance requirements, power supply configuration, fail-safe design of overfill protection, separate cabinets and adequate cable routing (fires have been addressed.-in Appendix R reviews), the Ginna design provides sufficient separation to ensure automatic SG overfill protection to mitigate a main feedwater overfeed event.No system modifications are planned as a result of this Generic Letter.Ver truly yours, Robert C.c d Division Manager Nuclear Production Subscribed and sworn to before me on this 19th da of March, 1990.g~l, HAUCK~~~&&aedNc York RWE/091 MONROEcoU~
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 TABLE 1 CABLE ROUTING OVERFILL PROTECTION Level Sicpal LT-461 6 LT-472 LT-463 G LT-471 Containment Penetration (AE10)ABI (AEll)ABI R~outin ABI, CT, CR ABI, CT, CR Protection Rack Location CR SIA SIB Location RR.Routine[RR, AHR, TB, Valve RR, AHR, TB, Valve LT-462<"473 (CE4)IBB IBB, CR CR RR, AHR, TB, Valve FEEDWATER CONTROL SYSTEH Level Sicgial Signal Pickup Location Feedwater Rack Location~Routin LT-461 LT-471 CR CR RR RR, AHR, TB, Valve RR, AHR;'TB, Valve~Le enu: ABI-Auxiliary Building Intermediate Floor IBB-Intermediate Building Basement CT-Cable Tunnel CR-Control Room RR-Relay Room TB-Turbine Building V>g~/C.r