ML17264A331

Forwards Application for Amend to License DPR-18,revising Containment Requirements During Mode 6 Cost Beneficial Licensing Action

ML17264A331
Person / Time
Site:	Ginna
Issue date:	02/09/1996
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17264A332	List: ML17264A331 ML17264A333 ML17264A334
References
NUDOCS 9602130325
Download: ML17264A331 (5)

Text

CATEGORY 1 REGULA" 1'NFORMATION 'DISTRIBUTION I'STEM (RIDS)

ACCk'SAI(3N NBR: 9602130325 DOC. DATE: 96/02/09 NOTARIZED: YES DOCKET FAC'.L:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AU'".H.NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas & Eleotric Corp, RECIP.NAME RECIPIENT AFFILIATION JOHNSONIA.R.

SUBJECT:

Forwards application for amend to License DPR~18,revising containment requirements during Mode 6 cost 'beneficial licensing action.

DISTRIBUTION CODE: ROOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution:

l ENCL ( SIZE: 0+

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-1 LA 1 1 PD1-1 PD 1 1 JOHNSON,A 1 1 INTERNAL. 01 1 1 . NRR/DE/EMCB 1 1 Y NRR/DRCH/HICB 1 1 "

NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 12 ENCL - 11

AND

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ROCHESTER GAS AND ElECTRIC CORRORATION ~ 89 EASTAYENUE, ROCHESTER, N. Y 1dhf9-0001 AREA CODE716 5'-2700 ROBERT C. MECREDY Vice President NvcteorOperotions February 9, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson Project Directorate I-3 Washington, D.C. 20555

Subject:

Application for Amendment to Facility Operating License Revised Containment Requirements During MODE 6 Cost Beneficial Licensing Action Rochester Gas 2 Electric Corporation R.E. Ginna Nuclear Power Plant Docket No. 50-244

References:

(a) Letter from R.P. Zimmerman, NRC, to R.C. Mecredy, RGB,

Subject:

RE'.

Ginna Nuclear Power Plant Conversion to Improved Standard Technical Specifications - Resolution of the Ginna Design Basis for Refueling Accidents (TAC No. M89516), dated December 7, 1995.

Dear Mr. Johnson,

During the conversion to improved sta'ndard technical specifications (ISTS), RGAE attempted to relocate the requirements for containment during MODE 6 outside the technical specifications.

These requirements would then be under RGAE control. Following a meeting with NRC management and staff on November 16, 1995 and receipt of the NRC position on this request (Ref.

(a)), RGB decided to retain the current technical specification requirements in order to not impact NRC approval of the ISTS for Ginna Station.

Upon further review of this matter, RG8'cE has determined that the existing containment requirements will impact the upcoming steam generator replacement (SGR) outage by at least 1 day.

This is mainly due to the need to have the equipment hatch in place or isolated by a closure plate during movement of irradiated fuel and core alterations. The SGR project requires extensive transfer of equipment into containment at the beginning of the outage and the subsequent removal of this equipment at the end of the outage. These time frames coincide with that for movement of fuel within containment such that most activities associated with equipment movement would have to cease resulting in an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of critical path activities.

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As such, the purpose of this License Amendment Request (LAR) is to allow an installed overhead door assembly to be used to isolate the equipment hatch opening during fuel movement and core alterations. This overhead door assembly can provide substantial protection from the potential radiological consequences of a design basis fuel handling accident and is similar to the device used in the Auxiliary Building during refueling operations associated with the spent fuel pool and for BWRs. The overhead door can also be opened and closed rapidly during interruptions of refueling operations (e.g., shift changes, lunch breaks) enabling recovery of an estimated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of critical path activities. Consistent with Reference (a), technical specification r'equirements would still remain for the containment function during fuel movement following this change, such that the control room and offsite doses would be limited. The recovery of the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of critical path activities, based on a conservative replacement power cost of $ 200,000 per day, meets the necessary minimum for a cost beneficial licensing action (CBLA) of $ 100,000 over the lifetime of the plant.

The estimated cost savings of $ 200,000 does not include cost savings which would be realized in future outages.

RG8 E requests that the NRC review this LAR in order to support the SGR Outage which is scheduled to begin on April 1, 1996. To provide necessary time for implementation of this LAR (e.g., procedure changes, etc.), RGB requires a minimum of 5 days prior to the scheduled outage initiation date (i.e., NRC approval by March 27, 1996). However, RGB requests that the NRC inform RG&E at the earliest opportunity of the likelihood of NRC acceptance of the proposed changes for outage planning purposes.

Very truly yours, Robert C. Mecredy

GJW379'Attachments U.S. Nuclear Regulatory Commission Mr. Allen R. Johnson (Mail Stop 14B2)

PWR Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector Mr. F. William Valentino, President New York State Energy, Research, and Development Authority 2 Rockefeller Plaza Albany, NY 12223-1253