ML17264A528

Forwards Update to Correction of Typographical Errors in Application for Amend to License DPR-18

ML17264A528
Person / Time
Site:	Ginna
Issue date:	06/03/1996
From:	Mercredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17264A529	List: ML17264A528 ML17264A530
References
NUDOCS 9606060147
Download: ML17264A528 (7)

Text

CATEGORY 1 REGULATO INFORMATION DISTRIBUTION STEM (RIDS)

ACCESSION NBR:9606060147 DOC.DATE: 96/06/03 NOTARIZED: YES DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MERCREDY,R.C. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION VISSINGIG.S.

SUBJECT:

Forwards update to correction of typographical errors request for application for amend to DPR-18.

DISTRIBUTION CODE: ZOOID COPIES RECEIVED:LTR ( ENCL I SIZE:

TITLE: OR Submittal: General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-1 LA 1 1 PD1-1 PD 1 1 VISSINGPG. 1 ~ 1 INTERN F.lL'E CENT P Ol 1 1 NRR/DE/EMCB 1 1 NRR/DRQH/4 CB 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 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 ROCHES1ER GAS AND EtEClRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N. Y 1rt649-0001 AREA CODE716 546-2700 ROBERT C. MECREDY Vice President Nuclear Operotions June 3, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555

Subject:

Application for Amendment to Facility Operating License Update to Correction of Typographical Errors Request Rochester Gas & Electric Corporation R.E. Ginna Nuclear Power Plant Docket No. 50-244

References:

(a) Letter from R.C. Mecredy, RG&E, to G.S. Vissing, NRC,

Subject:

Application for Amendment to Iracility Operating License, Correction of Typographical Errors, dated May 8, 1996.

(b) Letter from R.C. Mecredy, RG&E, to G.S. Vissing, NRC,

Subject:

Application for Amendment to Facility Operating License, Correction of Typographical Errors, Request for Exigent Consideration, dated May 10, 1996.

(c) Letter from R.C. Mecredy, RG&E, to G.S. Vissing, NRC,

Subject:

Application for Amendment to Facility Operating License, Update to Correction of Typographical Errors, dated May 29, 1996.

Dear Mr. Vissing,

By Reference (a), RG&E submitted a license amendment request (LAR) to correct several typographical errors within the Ginna Station Improved Technical Specifications (ITS).

Subsequently, RG&E requested that this LARbe considered on an exigent basis due to the potential to delay a planned startup (Reference (b)). However, the NRC Staff has requested additional information as to why the LAR should be considered on an exigent basis. This information is provided below.

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The majority of changes documented in Attachment A to Reference (a) (and as updated in Reference (c)), are minor editorial corrections which are readily apparent to operators if they were in the applicable LCO. That is, these errors would not be expected to cause significant operator confusion but are errors which must be corrected. However, changes 3.ii.b and 3.ii.c as documented in Attachment A, Section B are more serious. These two changes relate to the equations for Overtemperature zT and Overpower ~T and are discussed in detail below.

Change 3.ii.b corrects an inequality sign with respect to defining f(d) for both the Overtemperature

~T and Overpower ~T equations. This is significant since the value used for f(~1) in both equations is treated as a penalty (i.e., depending on the degree of power tiltwithin the core, f(d) may be either "0" or some value by which the Overtemperature aT and Overpower aT setpoints must be reduced to ensure that the plant remains bounded by the accident analysis). Without this correction, the equations have no specified value which should be used for f(U) when the difference in power between the top and bottom halves of the reactor core is < 13% RTP. Meanwhile, there are two different values which are to be used when the power difference between the top and bottom halves of the reactor core is > 13% RTP. This conflict would be confusing to operators and creates two equations in which a specific input is not defined for one instance and is defined twice in another instance.

Change 3.ii.c adds units to the equations for Overtemperature ~T and Overpower aT and corrects an error in the Overpower n T equation with respect to constant K>. The correction of constant K5 is significant since the current Overpower ~T equation essentially has no defined value to.be used for this constant. This is due to the fact that K, is supposed to have two values, one for when measured RCS average temperature is less than nominal T,, and one for when measured RCS average temperature is z nominal.T,,. In the current technical specifications, values for when K>

is less than "T"'nd when K, is ~ than "T're specified. However, "T"'s not defined anywhere in the current specifications since it is a typographical error which should be "T'." Again, this would be confusing to operators and creates an equation in which a specific input is not defined.

Both the Overtemperature ~T and Overpower ~T equations are required to be used during MODES 1 and 2 per LCO 3.3.1. The proposed corrections makes both the Overtemperature zT and Overpower ~T equations consistent with those equations used prior to implementation of the ITS.

Failure to approve this LAR prior to entry into MODE 2 following the current refueling outage prevent a planned startup due to editorial and typographical errors only since it would not be 'ould possible to operate with the technical specifications for these equations. Therefore, RG&E contends that the LAR meets the criteria for exigent consideration per 10 CFR 50.91.

4 ~ J In addition, RGB has noticed an error in the revised Attachment II and IIIsubmitted by Reference (c). This error is the removal of "RTP" from the end of the two lines which define f(~I) in the Overtemperature zT and Overpower aT equations. The current equations have this "RTP" and it was RG8cE's intent to retain this text. The "RTP" was inadvertently removed following a conference call with the NRC on May 28, 1996 and not added back in following a conference call on May 29, 1996. As such, please find attached copies of the properly revised Attachments II and III. No other pages of Reference (c) are affected.

Very ruly yours, Robert C. Mecredy Subscribed and sworn to before me on this 3rd day of June 1996.

JOANNE S, GORMAN Beery hhlio in the Stttte o! g@g yotlt Orlettns Cottony ColllttHssion Expires Nov. 5 Notary ublic MDF$857 Attachments xc: U.S. Nuclear Regulatory Commission Mr. Guy Vissing (Mail Stop 14C7)

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 Valentine, President New York State Energy, Research, and Development Authority 2 Rockefeller Plaza Albany, NY,12223-1253

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