ML17261A660
| ML17261A660 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/27/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17261A659 | List: |
| References | |
| NUDOCS 8711030009 | |
| Download: ML17261A660 (7) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 24 TO FACILITY OPERATING LICENSE NO. DPR-18 ROCHESTER GAS AND ELECTRIC CORPORATION R.
E.
GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244
- 1. 0 INTRODUCTION By letter dated November 10, 1983, Rochester Gas and Electric (RGLE or the licensee) submitted an application to amend Facility Operating License No.
DPR-18 for R.
E. Ginna Nuclear Power Plant (GNPP).
The proposed amendment
" would provide additional clarification of the term "operable" and provide consistency between limiting conditions for operation (LCO) and the associated action statements.
These proposed Technical Specification (TS) changes were in direct response to an NRC generic letter, dated April 10, 1980.
RG8E requested a delay in the incorporation of this request in their letter of August 25, 1980; this request and delay was acceptable as documented in an NRC letter of April 9, 1981.
By letter dated January 21, 1986, the TS changes proposed by the earlier application were revised in their entirety.
This revision was necessary due to an interim issuance of TS pages related to the Systematic Evaluation Program (SEP) and reissuance of the existing TSs in conjunction with conversion of-the operating license from provisional-to full-term status, thus making the November 1983 application out of date.
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Justification for the initially proposed TS changes were supplemented by the January 1986 submittal.
Following the staff review of the January 1986 amendment request and in response to staff comments, minor changes and clarifications to the proposed TS were forwarded by licensee letters of February 13 and March 9, 1987.
Also, by letter, dated April 14, 1987 and October 2, 1987, the licensee clarified its request in both the November N, 1983 and January 21, 1986 submittals regarding the deletion of the reference to part-length control rods on page 3. 10.2 of the Technical Specification.
Part-length control rods were removed from the plant pursuant to a.10 CFR 50.59 analysis.
The January 1986, et al.,
changes provided clarification of the amendment request and did not alter the proposed action or affect the staff's initial determination published in the Federal Reqister on 1anuary 26, 1984.
2,0 DISCUSSION AND EVALUATION The proposed TS revisions include changing the definition of "operable" to a definition similar to that in'the Standard TS (STS).
This change requires additional changes to some Limiting Conditions for Operation (LCO) and Action Statements.
RG8E states that most of the changes are one of three types as follows:
1.
The LCO was changed to require the system or component to be operable at a lower temperature or condition, i.e. operable at:an RCS temperature greater than 350 F versus requiring the equipment to be operable in order to be critical or at hot shutdown.
2.
The 'action statement was changed to reflect the change in the LCO, i.e.
if the LCO required the component to be operable at an RCS temperature greater than 350 F, then to clear the
- LCO, RCS conditions must be brought to below 350 F.
3.
Time limits to hot shutdown and cold shutdown or to an RCS temperature less than 350 F were added to action statements where required.
The licensee concluded that changes such as Case I, requiring a component to be operable at a lower condition, is inherently more co'nservative.
In changes such as Case 2, if a component is not required in the LCO to be operable until a certain mode of operation, there is no ~eason for the Action Statement to require that RCS condition be reduced to modes below that referenced in the LCO.
Therefore, Action Statements were changed to be consistent with the LCO.
The staff evaluated each of the licensee three reasons (Casesl for making changes as follows:
1.
This case is where the licensee proposes to require the system or component to be operable at a lower temperature or condition than that in the current TS.
(In most cases the changes are from the critical condition or from hot shutdown (T-avg Q to 540 F) to a temperature of 4 350 F.
All such changes were found conservative compa~ed to the current TS, will reduce the consequences of analyzed accidents and are, therefore, acceptable.
2.
This case is where the proposed change is for TS consistency, making the action statements consistent with LCO.
( In most cases, these changes insert the 350 F temperature value into the action statement).
Since the purpose is to make the TS consistent, not to change requirements, such changes are editorial and are, therefore, acceptable.
3.
In many of the current TS requirements, no time limits are specified for a component to be inoperable nr for the plant to reach hot shutdown, 350 F, or cold shutdown conditions.
The licensee's proposed TS changes would impose 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to shutdown (be in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />),
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to reduce RCS temperature below 350 F hours, and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to cooldown the reactor using shutdown cooling (be in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />),
Some proposed TSs combine these basic time intervals for clarity.
Since the proposed TS changes specify time requirements to reach specified plant conditions, they improve specificity and inspectability.
They are also consistent with the time limits usually provided for other facilities.
Therefore, the staff finds Case 3 changes acceptable.
In addition to the licensee types of changes, the staff adds the following two cases.
4.
Some proposed TS changes utilize the wording of the STS, issued by the staff on July 27, 1981.
Since this TS wording has received prior staff review and approval, and the wording clarifies the TS requirements, such changes are acceptable.
5.
During the review of TS pages containing proposed
- changes, the licensee or staff noted that a specification needed a minor improvement or wording correction.
These issues were discussed with the licensee, agreement was
- reached, and the licensee submitted revised TS pages on February 13 and March 9, 1987 documenting the minor correction.
These changes are editorial, improve the TSs, and are, therefore, acceptable.
The following table lists the proposed changes to the indicated TS sections and notes the applicable Case Number for acceptability.
TABLE OF TS SECTIONS BEING CHANGED TS Section Subject of TS Section Case No.
1.2 1.4 3.0 3.1.1.1 3.1.1.3 3.1.1.4 3.1.1.5 3.1.5 3.1.6 3.2 3.2.3.a 3.2.3.d 3.2.4 3.3 3.3.1 3.3.1.2 3.3.1.3 3.3.1.4 3.3.1.5 3.3.2 3.3.3 3.3.4 Definition of Modes 5
Definition of Operable-operability Limiting Conditions for Operation 4
Reactor Coolant Loops
?/3 Pressurizer Safety Valves 1
Pressurizer Power Operated Relief Valves 1
Pressurizer Operability 1
Primary Coolant Leak Detection 1/2/3 Primary Coolant Chemistry 2/5 CVCS Operability 1/2 Charging Pump 3/5 Boric Acid Tank 3/5 One Charging Pump Inoperability 2
Emergency Core Cooling SyStem Safety Injection and RHR Operability 1/2 Refueling Water Storage Tank 3
Accumul a tor 2
Safety Injection Pumps 2
Inoperable Components 3
Containment Cooling and Iodine Removal 1/3 Component Cooling 1/3 Service Water 1/3
TS Section 3.3.5 3.4.1 3.5.1 3.5.2 3.10.1 3.16 Subject of TS Section Control Room Air Treatment Auxiliary Feedwater Protection System Instrumentation ESFA Instrumentation Control Rod Insertion Limit Radiological Environmental Monitoring Case No.
1/3 1/2/3 1-5 1-5 5
5 Rased on the above, we find the proposed revision of Technical Specifications regarding 'operability and related
- changes, as revised, acceptable.
In its November 10, 1983 submittal, the licensee proposed deleting the statement in the Technical Specifications on part-length control rods because these rods were removed pursuant to 10 CFR 50,59 analysis in February 1979.
The effect of these part-length control rods on power distribution and reactivity has not been evaluated as part of the reload safety evaluations since that date.
The deletion of the reference to part-length control rods is reflected by this amendment.
- 3. 0 ENVIRONMENTAL CONS IOERATION This amendment involves only changes in administrative procedures and requirements.
The Coomission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public coranent on such finding.
Accordingly, this amendment meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR Section 51;22(c)(10).
Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
- 4. 0 CONCLUSION We have concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense or security or to the health and safety of the public.
5.0
'ACKNOWLEDGEHENT Principal Contributors:
E. Conner and D. Haverkamp Dated: 0g g 7 5981