ML063180228
| ML063180228 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/03/2006 |
| From: | Korsnick M Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML063180228 (5) | |
Text
Maria Korsnick Site Vice President R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.3494 585.771.3943 Fax maria.korsnick@ costellation.com Constellation Energy-Generation Group November 3, 2006 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
SUBJECT:
Document Control Desk R.E. Ginna Nuclear Power Plant Docket No. 50-244 Revised Information Associated with the License Amendment Request:
Technical Specification Improvement Regarding Steam Generator Tube Integrity Using the Consolidated Line Item Improvement Process
Reference:
Letter from D. Holm (Ginna LLC) to NRC Document Control Desk,
Subject:
License Amendment Request: Technical Specification Improvement Regarding Steam Generator Tube Integrity Using the Consolidated Line Item Improvement Process, dated May 1, 2006.
On May 1, 2006, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted a proposed license amendment request associated with the Consolidated Line Item Improvement Process (CLIIP) for steam generator tube integrity. Subsequent to the submittal, as the result of recent discussions with the NRC staff, Ginna LLC would like to provide the attached replacement pages associated with Attachment (2),
Proposed Technical Specification and Bases Changes, of the original submittal.
Should you have questions regarding this matter, please contact Mr. Robert Randall at (585) 771-3734, or robert.randall @constellation.com.
Very truly youi 7
h Mary G.
9 orsnick
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STATE OF NEW YORK
- TO WIT:
COUNTY OF WAYNE I, Mary G. Korsnick, begin duly sworn, state that I am Vice President, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this request on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
Subscribed and sworn before me, a Notary Public in and for the State of New York and County of fl/ofe9.L.
, this -Z day of Jq6LOAW., 2006.
WITNESS my Hand and Notarial Seal:
My Commission Expires:
Notary Pubfic Date SHARON L. MILLER Notay Public, State of New York Regstration No. 01M16017755 Monroe Co*un Cormewo~ Expires Dece=e 21,246RL N
Attachments:
Replacement Pages (2 pages) cc:
S. J. Collins, NRC P.D. Milano, NRC Resident Inspector, NRC (Ginna)
J. P. Spath, NYSERDA P.D. Eddy, NYSDPS
Replacement Pages (2 pages)
INSERT 3.4.13 A NOTE----------------------------------
- 1.
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.
- 2.
Not applicable to primary to secondary LEAKAGE.
Verify RCS operational LEAKAGE is within limits by performance of RCS water inventory balance.
INSERT 3.4.13 B NOTE----------------------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.
-Verify primary to secondary LEAKAGE is < 150 gallons per day through any one SG.
INSERT B 3.4.13 A Primary to secondary LEAKAGE is a factor in the dose releases outside containment resulting from a steam line break (SLB) accident and other accidents or transients which involve secondary steam release to the atmosphere, such as a steam generator tube rupture (SGTR),
reactor coolant pump locked rotor (LR), and a rod ejection (RE) accident. The leakage contaminates the secondary fluid.
The UFSAR (Ref. 3) analysis for SGTR assumes that the intact SG primary to secondary LEAKAGE is 150 gallons per day, which is relatively inconsequential. The safety analysis for the SLB accident assumes 1 gpm primary to secondary LEAKAGE in each SG as a result of the accident. The LR and RE accidents are assumed to result in a 500 gallon per day primary to secondary LEAKAGE in each SG as a result of the accident. The dose consequences resulting from the accidents outside of containment are well within the limits defined in 10 CFR 100 or the staff approved licensing basis (i.e., a small fraction of these limits).
INSERT B 3.4.13 B
- d.
Primary to Secondary LEAKAGE Through Any One SG The limit of 150 gallons per day per SG is based on the operational LEAKAGE performance criterion in NEI 97-06, Steam Generator Program Guidelines (Ref. 4). The Steam Generator Program operational LEAKAGE performance criterion in NEI 97-06 states, "The RCS operational primary to secondary leakage through any one SG shall be
INSERT 5.5.8 A Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the Steam Generator Program shall include the following provisions:
- a.
Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected, or plugged, to confirm that the performance criteria are being met.
- b.
Performance criteria for SG tube integrity. Steam generator tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.
- 1.
Structural integrity performance criterion: All in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down and all anticipated transients included in the design specification) and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady-state full power operation primary to secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.
- 2.
Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for each SG. Leakage is not to exceed 1 gpm per SG.
- 3.
The operational LEAKAGE performance criterion is specified in LCO 3.4.13, "RCS Operational LEAKAGE."
- c.
Provisions for SG tube repair criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.
- d.
Provisions for SG tube inspections. Periodic SG tube inspections shall be performed.
The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial,