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{{#Wiki_filter:<<ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEMREGULATORY INFORMATION DISTRIBUTION SYSTEM(RIDS)ACCESSION NBR:9007170340 DOC.DATE:
{{#Wiki_filter:<<ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9007170340 DOC.DATE: 90/07/09 NOTARIZED:
90/07/09NOTARIZED:
NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G AUTH.NAME AUTHOR AFFILIATION MECREDY,R.
NOFACIL:50-244 RobertEmmetGinnaNuclearPlant,Unit1,Rochester GAUTH.NAMEAUTHORAFFILIATION MECREDY,R.
Rochester Gas 6 Electric Corp.RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.
Rochester Gas6ElectricCorp.RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.
Project Directorate I-3 DOCKET 05000244
ProjectDirectorate I-3DOCKET05000244


==SUBJECT:==
==SUBJECT:==
Discusses designbasisofplantreAOV745,CCWIreturnvalvefromexcessletdownHX.DISTRIBUTION CODE:AOOIDCOPIESRECEIVED:LTR gENCL~SIZE:~TITLE:ORSubmittal:
Discusses design basis of plant re AOV 745,CCWI return valve from excess letdown HX.DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR g ENCL~SIZE:~TITLE: OR Submittal:
GeneralDistribution NOTES:License Expdateinaccordance with10CFR2,2.109(9/19/72).
General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
05000244RECIPIENT IDCODE/NAME PD1-3LAJOHNSON,A COPIESLTTRENCLRECIPIENT IDCODE/NAME PD1-3PDCOPIESLTTRENCLINTERNAL:
05000244 RECIPIENT ID CODE/NAME PD1-3 LA JOHNSON,A COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD1-3 PD COPIES LTTR ENCL INTERNAL: NRR/DET/ECMB 9H NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB EXTERNAL: LPDR NSIC NRR/DOEA/OTSB11 1 NRR/DST/SELB 8D 1 NRR/DST/SRXB 8E 1 ,OC/-LFMB E 1 REG FKE~>>=01~~
NRR/DET/ECMB 9HNRR/DST8E2NRR/DST/SICB 7ENUDOCS-ABSTRACT OGC/HDS2RES/DSIR/EIB EXTERNAL:
NRC PDR NOTE TO ALL"RIDS" RECIPIENTS:
LPDRNSICNRR/DOEA/OTSB11 1NRR/DST/SELB 8D1NRR/DST/SRXB 8E1,OC/-LFMB E1REGFKE~>>=01~~
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL y  
NRCPDRNOTETOALL"RIDS"RECIPIENTS:
>~f f//51/II I//I'I/t/AND ESgPII///////SS////SF'/F//F 5TAYE ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y.14649-0001 July 9, 1990 TELEPHONE AREA COOE Tld 546.2700 U.S.Nuclear Regulatory Commission Document Control Desk Attn: Allen R.Johnson Project Directorate I-3 Washington, D.C.20555  
PLEASEHELPUSTOREDUCEWASTE!CONTACTTHEDOCUMENTCONTROLDESK,ROOMPl-37(EXT.20079)TOELIMINATE YOURNAMEFROMDISTRIBUTION LISTSFORDOCUMENTS YOUDON'TNEED!TOTALNUMBEROFCOPIESREQUIRED:
LTTR21ENCL y  
>~ff//51/III//I'I/t/
ANDESgPII///////SS////SF'/F//F5TAYEROCHESTER GASANDELECTRICCORPORATION o89EASTAVENUE,ROCHESTER, N.Y.14649-0001 July9,1990TELEPHONE AREACOOETld546.2700U.S.NuclearRegulatory Commission DocumentControlDeskAttn:AllenR.JohnsonProjectDirectorate I-3Washington, D.C.20555


==Subject:==
==Subject:==
Rochester GasandElectricCorporation R.E.GinnaNuclearPowerPlantDocketNo.50-244
Rochester Gas and Electric Corporation R.E.Ginna Nuclear Power Plant Docket No.50-244  


==DearMr.Johnson,==
==Dear Mr.Johnson,==
OnJune8,1990,RG&EnotifiedtheNRCunderthecriterion of10CFR550.72, ofacondition outsidethedesignbasisoftheplantassociated withAOV745,thecomponent coolingwaterisolation returnvalvefromtheexcessletdownheatexchanger.
On June 8, 1990, RG&E notified the NRC under the criterion of 10CFR550.72, of a condition outside the design basis of the plant associated with AOV 745, the component cooling water isolation return valve from the excess letdown heat exchanger.
Thisnotification wasmadeasaresultofinformation contained inTable3.6-1oftheGinnaTechnical Specifications andUFSARTable6.2-13,whichindicated thatAOV745shouldreceiveaContainment Isolation Signal(CIS).However,elementary wiringdrawingsdidnotshowthisvalveasreceiving suchasignal.Subsequent tothisnotification, RG&Edetermined thatinformation contained onTechnical Specification Table3.6-1forMOV749AandMOV749B(component coolingwaterisolation valvestothereactorcoolantpumps)wasalsopotentially misleading basedonthefactthatthesevalvesdonotreceiveaCISbutareshownwithamaximumisolation timeof60seconds.Consequently, RG&Ehasreviewedthebackground information available withrespecttoAOV745,MOV749A,andMOV749B.AllthreevalveswerereviewedbytheNRCduringimplementation oftheTMILessonsLearnedrecommendations andtheSystematic Evaluation Program.Penetration 124awasevaluated inthesetwoprogramsassumingthatitwasnonessential, andthatAOV745wasanormallyopenvalvewhichdidnotreceiveaCISbutwasclosedpost-LOCA.
This notification was made as a result of information contained in Table 3.6-1 of the Ginna Technical Specifications and UFSAR Table 6.2-13, which indicated that AOV 745 should receive a Containment Isolation Signal (CIS).However, elementary wiring drawings did not show this valve as receiving such a signal.Subsequent to this notification, RG&E determined that information contained on Technical Specification Table 3.6-1 for MOV 749A and MOV 749B (component cooling water isolation valves to the reactor coolant pumps)was also potentially misleading based on the fact that these valves do not receive a CIS but are shown with a maximum isolation time of 60 seconds.Consequently, RG&E has reviewed the background information available with respect to AOV 745, MOV 749A, and MOV 749B.All three valves were reviewed by the NRC during implementation of the TMI Lessons Learned recommendations and the Systematic Evaluation Program.Penetration 124a was evaluated in these two programs assuming that it was nonessential, and that AOV 745 was a normally open valve which did not receive a CIS but was closed post-LOCA.
Meanwhile, Penetrations 127(MOV749A)and128(MOV749B)wereconsidered essential penetrations withnormallyopenedvalvesthatalsodidnotreceiveaCISbutremainopenpost-LOCA.
Meanwhile, Penetrations 127 (MOV 749A)and 128 (MOV 749B)were considered essential penetrations with normally opened valves that also did not receive a CIS but remain open post-LOCA.
InaNovember19,1979lettertotheNRCdiscussing TMILessonsLearneptopics,RG&EstatedthatPenetration 124awas"nonesbential" whilePenetrations 127and128were"essential".
In a November 19, 1979 letter to the NRC discussing TMI Lessons Learnep topics, RG&E stated that Penetration 124a was"nonesbential" while Penetrations 127 and 128 were"essential".
Inpreviouscorrespondence fromRG&Eonthissubject(datedJune22,1979),atablewasprovidedwhichlistedallvalvesreceiving aCIS;neitherAOV745,MOV749A,norMOV749Bwerelistedonthistable.9007l70340 900709PDRAGOCK05000244pplleap
In previous correspondence from RG&E on this subject (dated June 22, 1979), a table was provided which listed all valves receiving a CIS;neither AOV 745, MOV 749A, nor MOV 749B were listed on this table.9007l70340 900709 PDR AGOCK 05000244 ppl leap
/ep44I InTable1oftheFinalEvaluation ReportforSEPTopicVI-4,datedApril12,1982,itisindicated thattheNRCassumedthatAOV745wasnormallyopen,butclosedpost-LOCA.
/e p 4 4I In Table 1 of the Final Evaluation Report for SEP Topic VI-4, dated April 12, 1982, it is indicated that the NRC assumed that AOV 745 was normally open, but closed post-LOCA.
However,thereisnoinformation listedbeneaththe"Actuation" columnforthisvalvewhichwouldindicatehowthevalvewasexpectedtoclose.ThistablealsoshowsMOV749AandMOV749Basnormallyopenvalveswhichremainopenpost-LOCA.
However, there is no information listed beneath the"Actuation" column for this valve which would indicate how the valve was expected to close.This table also shows MOV 749A and MOV 749B as normally open valves which remain open post-LOCA.
Thesevalvesareshownas"remotemanual"under"Actuation".
These valves are shown as"remote manual" under"Actuation".
Inaddition, drawingsandtheoriginalGinnaFSARasusedbytheNRCduringtheSEPdidnotshowthattherewasaCIStothesethreevalves.Therefore, theNRChadevaluated AOV745,MOV749AandMOV749Bintheircurrentconfigurations duringboththeTMILessonsLearnedandSystematic Evaluation
In addition, drawings and the original Ginna FSAR as used by the NRC during the SEP did not show that there was a CIS to these three valves.Therefore, the NRC had evaluated AOV 745, MOV 749A and MOV 749B in their current configurations during both the TMI Lessons Learned and Systematic Evaluation Programs, and found them to be acceptable.
: Programs, andfoundthemtobeacceptable.
Since there was no conflicting supporting design basis information (e.g., UFSAR, elementary drawings)showing that MOV 749A and MOV 749B receive a CIS, these valves were not declared inoperable when it was determined that they did not receive a CIS, as had been done with AOV 745.Based on our review of this situation, RG&E interprets the 60 second maximum isolation time as listed in Technical Specification Table 3.6-1 to be valve closure time following a demand to close.This interpretation is consistent with Standard Review Plan 6.2.4, section II (n)and has been transmitted to the Ginna Station operation staff.'Therefore, no changes are required with respect to MOV 749A and MOV 749B.Penetration 124a is a closed system inside containment which is seismic and missile-protected.
Sincetherewasnoconflicting supporting designbasisinformation (e.g.,UFSAR,elementary drawings) showingthatMOV749AandMOV749BreceiveaCIS,thesevalveswerenotdeclaredinoperable whenitwasdetermined thattheydidnotreceiveaCIS,ashadbeendonewithAOV745.Basedonourreviewofthissituation, RG&Einterprets the60secondmaximumisolation timeaslistedinTechnical Specification Table3.6-1tobevalveclosuretimefollowing ademandtoclose.Thisinterpretation isconsistent withStandardReviewPlan6.2.4,sectionII(n)andhasbeentransmitted totheGinnaStationoperation staff.'Therefore, nochangesarerequiredwithrespecttoMOV749AandMOV749B.Penetration 124aisaclosedsysteminsidecontainment whichisseismicandmissile-protected.
The current GDC 57 only requires a manual or remote-manual valve outside containment for this configuration.
ThecurrentGDC57onlyrequiresamanualorremote-manual valveoutsidecontainment forthisconfiguration.
The safety function (i.e., containment isolation) of this penetration is met in the current configuration, even with AOV 745 normally open.RG&E has thus concluded that AOV 745 does not require a CIS to be considered operable since the containment isolation function associated with Penetration 124a is accomplished by the closed system inside containment and AOV 745 (without a CIS)outside containment.
Thesafetyfunction(i.e.,containment isolation) ofthispenetration ismetinthecurrentconfiguration, evenwithAOV745normallyopen.RG&Ehasthusconcluded thatAOV745doesnotrequireaCIStobeconsidered operablesincethecontainment isolation functionassociated withPenetration 124aisaccomplished bytheclosedsysteminsidecontainment andAOV745(withoutaCIS)outsidecontainment.
Therefore, the criteria of 10CFR550.73 are not applicable to the discovery that AOV 745 does not receive a CIS.However, because our response to item 2.1.4.3 in the above cited November 19, 1979 letter indicated that we would provide a CIS to valves in non-essential penetrations, even though such a signal goes beyond the requirements of GDC 57, RG&E commits to install such a signal to AOV 745 by the end of the 1992 refueling outage.In the meantime, in order to provide another level of assurance of containment isolation, RG&E is planning to modify the Emergency Procedures to direct the operators to remote-manually close this valve from the Control Room at an appropriate time following receipt of a CIS (e.g., following immediate actions of E-0).The addition of this procedure step will be accomplished by August 15, 1990.
Therefore, thecriteriaof10CFR550.73 arenotapplicable tothediscovery thatAOV745doesnotreceiveaCIS.However,becauseourresponsetoitem2.1.4.3intheabovecitedNovember19,1979letterindicated thatwewouldprovideaCIStovalvesinnon-essential penetrations, eventhoughsuchasignalgoesbeyondtherequirements ofGDC57,RG&EcommitstoinstallsuchasignaltoAOV745bytheendofthe1992refueling outage.Inthemeantime, inordertoprovideanotherlevelofassurance ofcontainment isolation, RG&EisplanningtomodifytheEmergency Procedures todirecttheoperators toremote-manually closethisvalvefromtheControlRoomatanappropriate timefollowing receiptofaCIS(e.g.,following immediate actionsofE-0).Theadditionofthisprocedure stepwillbeaccomplished byAugust15,1990.
RGaE has also discovered several additional typographical errors and needed clarifications associated with Technical Specification Table 3.6-1.However, these anomalies do not affect the safe operation of Ginna and will be corrected in the upcoming Amendment request to remove this table from the Technical Specifications and reference the UFSAR (anticipated submittal date October 1990).Very truly yours, Robert Mecredy Division Manager Nuclear Production MDFN147 xc: Mr.Allen R.Johnson (Mail Stop 14D1)Project Directorate'-3 Washington, D.C.20555 Ms.Donna Ross New York State Energy Office U.S.Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident inspector}}
RGaEhasalsodiscovered severaladditional typographical errorsandneededclarifications associated withTechnical Specification Table3.6-1.However,theseanomalies donotaffectthesafeoperation ofGinnaandwillbecorrected intheupcomingAmendment requesttoremovethistablefromtheTechnical Specifications andreference theUFSAR(anticipated submittal dateOctober1990).Verytrulyyours,RobertMecredyDivisionManagerNuclearProduction MDFN147xc:Mr.AllenR.Johnson(MailStop14D1)ProjectDirectorate'-3 Washington, D.C.20555Ms.DonnaRossNewYorkStateEnergyOfficeU.S.NuclearRegulatory Commission Region1475Allendale RoadKingofPrussia,PA19406GinnaSeniorResidentinspector}}

Revision as of 14:25, 7 July 2018

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
ML17261B090
Person / Time
Site: Ginna Constellation icon.png
Issue date: 07/09/1990
From: MECREDY R
ROCHESTER GAS & ELECTRIC CORP.
To: JOHNSON A R
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9007170340
Download: ML17261B090 (6)


Text

<<ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9007170340 DOC.DATE: 90/07/09 NOTARIZED:

NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G AUTH.NAME AUTHOR AFFILIATION MECREDY,R.

Rochester Gas 6 Electric Corp.RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.

Project Directorate I-3 DOCKET 05000244

SUBJECT:

Discusses design basis of plant re AOV 745,CCWI return valve from excess letdown HX.DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR g ENCL~SIZE:~TITLE: OR Submittal:

General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).

05000244 RECIPIENT ID CODE/NAME PD1-3 LA JOHNSON,A COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD1-3 PD COPIES LTTR ENCL INTERNAL: NRR/DET/ECMB 9H NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB EXTERNAL: LPDR NSIC NRR/DOEA/OTSB11 1 NRR/DST/SELB 8D 1 NRR/DST/SRXB 8E 1 ,OC/-LFMB E 1 REG FKE~>>=01~~

NRC PDR NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL y

>~f f//51/II I//I'I/t/AND ESgPII///////SS////SF'/F//F 5TAYE ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y.14649-0001 July 9, 1990 TELEPHONE AREA COOE Tld 546.2700 U.S.Nuclear Regulatory Commission Document Control Desk Attn: Allen R.Johnson Project Directorate I-3 Washington, D.C.20555

Subject:

Rochester Gas and Electric Corporation R.E.Ginna Nuclear Power Plant Docket No.50-244

Dear Mr.Johnson,

On June 8, 1990, RG&E notified the NRC under the criterion of 10CFR550.72, of a condition outside the design basis of the plant associated with AOV 745, the component cooling water isolation return valve from the excess letdown heat exchanger.

This notification was made as a result of information contained in Table 3.6-1 of the Ginna Technical Specifications and UFSAR Table 6.2-13, which indicated that AOV 745 should receive a Containment Isolation Signal (CIS).However, elementary wiring drawings did not show this valve as receiving such a signal.Subsequent to this notification, RG&E determined that information contained on Technical Specification Table 3.6-1 for MOV 749A and MOV 749B (component cooling water isolation valves to the reactor coolant pumps)was also potentially misleading based on the fact that these valves do not receive a CIS but are shown with a maximum isolation time of 60 seconds.Consequently, RG&E has reviewed the background information available with respect to AOV 745, MOV 749A, and MOV 749B.All three valves were reviewed by the NRC during implementation of the TMI Lessons Learned recommendations and the Systematic Evaluation Program.Penetration 124a was evaluated in these two programs assuming that it was nonessential, and that AOV 745 was a normally open valve which did not receive a CIS but was closed post-LOCA.

Meanwhile, Penetrations 127 (MOV 749A)and 128 (MOV 749B)were considered essential penetrations with normally opened valves that also did not receive a CIS but remain open post-LOCA.

In a November 19, 1979 letter to the NRC discussing TMI Lessons Learnep topics, RG&E stated that Penetration 124a was"nonesbential" while Penetrations 127 and 128 were"essential".

In previous correspondence from RG&E on this subject (dated June 22, 1979), a table was provided which listed all valves receiving a CIS;neither AOV 745, MOV 749A, nor MOV 749B were listed on this table.9007l70340 900709 PDR AGOCK 05000244 ppl leap

/e p 4 4I In Table 1 of the Final Evaluation Report for SEP Topic VI-4, dated April 12, 1982, it is indicated that the NRC assumed that AOV 745 was normally open, but closed post-LOCA.

However, there is no information listed beneath the"Actuation" column for this valve which would indicate how the valve was expected to close.This table also shows MOV 749A and MOV 749B as normally open valves which remain open post-LOCA.

These valves are shown as"remote manual" under"Actuation".

In addition, drawings and the original Ginna FSAR as used by the NRC during the SEP did not show that there was a CIS to these three valves.Therefore, the NRC had evaluated AOV 745, MOV 749A and MOV 749B in their current configurations during both the TMI Lessons Learned and Systematic Evaluation Programs, and found them to be acceptable.

Since there was no conflicting supporting design basis information (e.g., UFSAR, elementary drawings)showing that MOV 749A and MOV 749B receive a CIS, these valves were not declared inoperable when it was determined that they did not receive a CIS, as had been done with AOV 745.Based on our review of this situation, RG&E interprets the 60 second maximum isolation time as listed in Technical Specification Table 3.6-1 to be valve closure time following a demand to close.This interpretation is consistent with Standard Review Plan 6.2.4, section II (n)and has been transmitted to the Ginna Station operation staff.'Therefore, no changes are required with respect to MOV 749A and MOV 749B.Penetration 124a is a closed system inside containment which is seismic and missile-protected.

The current GDC 57 only requires a manual or remote-manual valve outside containment for this configuration.

The safety function (i.e., containment isolation) of this penetration is met in the current configuration, even with AOV 745 normally open.RG&E has thus concluded that AOV 745 does not require a CIS to be considered operable since the containment isolation function associated with Penetration 124a is accomplished by the closed system inside containment and AOV 745 (without a CIS)outside containment.

Therefore, the criteria of 10CFR550.73 are not applicable to the discovery that AOV 745 does not receive a CIS.However, because our response to item 2.1.4.3 in the above cited November 19, 1979 letter indicated that we would provide a CIS to valves in non-essential penetrations, even though such a signal goes beyond the requirements of GDC 57, RG&E commits to install such a signal to AOV 745 by the end of the 1992 refueling outage.In the meantime, in order to provide another level of assurance of containment isolation, RG&E is planning to modify the Emergency Procedures to direct the operators to remote-manually close this valve from the Control Room at an appropriate time following receipt of a CIS (e.g., following immediate actions of E-0).The addition of this procedure step will be accomplished by August 15, 1990.

RGaE has also discovered several additional typographical errors and needed clarifications associated with Technical Specification Table 3.6-1.However, these anomalies do not affect the safe operation of Ginna and will be corrected in the upcoming Amendment request to remove this table from the Technical Specifications and reference the UFSAR (anticipated submittal date October 1990).Very truly yours, Robert Mecredy Division Manager Nuclear Production MDFN147 xc: Mr.Allen R.Johnson (Mail Stop 14D1)Project Directorate'-3 Washington, D.C.20555 Ms.Donna Ross New York State Energy Office U.S.Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident inspector