ML17264A599

Application for Amend to License DPR-18,revising RCS Pressure & Temp Limits Rept

ML17264A599
Person / Time
Site:	Ginna
Issue date:	09/13/1996
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17264A598	List: ML17264A597 ML17264A599 ML17264A600 ML17309A605 ML17309A606
References
NUDOCS 9609180193
Download: ML17264A599 (8)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMSSION In the Matter of )

)

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

APPI ICATIONFOR AMENDMENT T PERATIN II EN E Pursuant to Section 50.90 of the regulations of the U.S. Nuclear Regulatory Commission (NRC), Rochester Gas and Electric Corporation (RGB'), holder of Facility Operating License No.

DPR-18, hereby requests that the Technical Specifications set forth in Appendix A to that license, e be amended. This request for change is to revise the Reactor Coolant System (RCS) Pressure and Temperature (P/7) limits and Low Temperature Overpressure Protection (LTOP) limits as contained in the RCS Pressure and Temperature Limits Report (PTLR) referenced by the Administrative Controls to reflect updated information.

A description of the amendment request, necessary background information, justification of the requested changes, and no significant hazards and environmental considerations are provided in Attachment I. This evaluation demonstrates that the proposed changes do not involve a significant change in the types or a significant increase in the amounts of effluents or any change in the authorized power level of the facility. The proposed changes also do not involve a significant hazards consideration.

PDR AOQCK 050002 P

e A marked up copy of the Ginna Station Technical Specifications which show the changes is set forth in Attachment II. The proposed revised technical specifications requested are provided in Attachment III. The revised PTLR is provided in Attachment IV while WCAP-14684 (which provides necessary supporting documentation) is provided in Attachment V.

WHEREFORE, Applicant respectfully requests that Facility Operating License No. DPR-18, and Attachment A to that license, be amended in the form attached hereto as Attachment III.

Rochester Gas and Electric Corporation By Robert C. Mecredy Vice President Nuclear Operations Subscribed and sworn to before me on this 13th day of September 1996.

Notary Public DEBORAH A.PIPERNl Notary Public in the State ol New York ONTARIO COUNTY Commission Expires Nov. 23, 19.$ .

7

Attachment I R.E. Ginna Nuclear Power Plant License Amendment Request

. Revision of Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)

This attachment provides a description of the license amendment request (LAR) and the necessary justifications to support a revision to the RCS pressure and temperature (P/T) limits and low temperature overpressure protection (LTOP) limits contained in the PTLR as referenced by the Administrative Controls. This attachment is divided into six sections as follows. Section A summarizes all changes to the Ginna Station Technical Specifications while Section B provides the background and history associated with the changes being requested. Section C provides the justifications associated with these proposed changes. A no significant hazards consideration evaluation and environmental consideration of the requested changes to the Ginna Station Technical Specifications are provided in Sections D and E, respectively. Section F lists all references used in this attachment.

A. DESCRIPTION OF TECHNICAL SPECIFICATION CHANGES This LAR proposes to revise the Ginna Station Technical Specifications to reflect a new PILR in the Administrative Controls section. The change is summarized below and shown in Attachment II.

1. Administrative Controls 5.6.6 Item c willbe revised to replace the'reference to the May 23, 1996 NRC letter with a new reference that approves the PTLR included as Attachment IV to this LAR. In addition, reference document item 1 is revised to reference this LAR as the source for the PTLR limits and methodology while item 2 is revised to reference the final approved WCAP-14040 which is the basis for the new P/T curves. Finally, a typographical error in item d will be corrected.

BACKGROUND During the conversion to improved standard technical specifications (ITS) for Ginna Station, RGB proposed to relocate the LTOP and RCS P/T limits to the PTLR (Ref. 1). Associated with this change was the addition of a reference to the Administrative Controls section of technical specifications related to the PTLR documenting the methodology used for all changes to these limits. However, the proposed methodology would be "new" with respect to determination of both the LTOP and RCS'P/T limits. Due to time constraints, RG&E informed the NRC that use of this new methodology would be burdensome and instead, .

RGB wished to retain the existing values. The NRC agreed with this concern and allowed the existing limits to be relocated to the PTLR but required changes to these limits to be reviewed and approved by the NRC as documented in Reference 2.

Subsequent to the conversion to ITS, the NRC completed its review of the latest reactor vessel capsule data and the associated impact on the pressurized thermal shock evaluation for Ginna Station (Ref. 3). Incorporation of this information into the PTLR required a reassessment of the P/T curves and LTOP setpoints that are included in the PTLR.

However, the fluence factor methodology used for the Ginna Station PTS evaluation was an earlier version than that required by WCAP-14040 (Ref. 4) which was to be the basis for the P/T methodology. Since an update of the associated documents could not be completed in the time frame required to support start-up from the 1996 refueling outage, the NRC approved a PTLR for use at Ginna Station until December 31, 1996 using an estimated fluence factor value (Ref. 5).

The purpose of this LAR is to complete implementation of Generic Letter 96-03 for Ginna Station and to respond to the December 31, 1996 time limit on the existing PTLR. Generic Letter 96-03 requires that licensees reference the P/T and LTOP methodologies in the technical specifications and provide a proposed PTLR using the methodology for NRC review. WCAP-14040 (Ref. 4) has been generically approved for use by the NRC for P/T limits. The LTOP methodology for Ginna Station (Ref. 1) has been "previously reviewed by the NRC and found to be acceptable (Ref. 5). Therefore, this LAR provides a proposed PTLR (and supporting documentation as provided in WCAP-14684) and includes a reference to WCAP-14040 and Reference 1 in the Administrative Controls as the basis for the methodology. It should be noted that even though the technical specifications do not require reactor vessel material information to be located within the PTLR, this information is provided consistent with Generic Letter 96-03. This includes a revised RTFis value based on the attached WCAP-14684. The revised RT~ value also includes changes made as a result of additional surveillance capsule chemistry analyses.

This section provides the justification for all changes described in Section A above and shown in Attachment II. The justifications are organized based on whether the change is:

more restrictive (M), less restrictive (L), administrative (A), or the requirement is relocated (R). The justifications listed below are also referenced in. the technical specification(s) which are affected (see Attachment Il). It is noted that there are only administrative changes associated with this LAR.

C.1 mini r i Administrative Controls Section 5.6.6.c is revised to replace reference to the May 23, 1996 submittal with a new reference that approves the PTLR included as Attachment IVto this submittal. In addition, the references for PTLR methodology are updated. These changes are administrative in nature since the RCS P/T limits and LTOP limits were previously relocated from technical specifications to the PTLR.

The only change being requested is to update the PTLR consistent with generically approved WCAP-14040 and to reflec the new methodology being used in the Administrative Controls section.

2. A typographical error in Administrative Controls Section 5.6.6.d is corrected to provide consistency with NUREG-1431.

There are not any more restrictive (M), less restrictive (L), or relocated (R) changes associated with this LAR.

D. SIGNIFICANT HAZARDS CONSIDERATION EVALUATION The proposed changes to the Ginna Station Technical Specifications as identified in Section A and justified in Section C have been evaluated with respect to 10 CFR 50.92(c) and shown to not involve a significant hazards consideration as described below. This section is organized based on Section C above.

Dl Evl i n fA mini r ive hn e The administrative changes discussed in Section C.l do not involve a significant hazards consideration as discussed below:

Operation of Ginna Station in accordance with the proposed changes does not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed changes only revise the reference to the PTLR in the Administrative Controls section of technical specifications and correct a typographical error. The changes complete implementation of Generic Letter 96-03 by referencing NRC approved methodology within the Administrative Controls. As such, these changes are administrative in nature and do not impact initiators or analyzed events or assumed mitigation of accident or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously analyzed.

Operation of Ginna Station in accordance with the proposed changes does not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or changes in the methods governing normal plant operation. The proposed changes will not impose any new or different requirements. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Operation of Ginna Station in accordance with the proposed changes does not involve a significant reduction in a margin of safety. The proposed changes will not reduce a margin of plant safety because the changes have been shown to ensure that the P/T and LTOP limits in the revised PTLR continue to meet all necessary requirements for reactor vessel integrity. These changes are administrative in nature.

As such, no question of safety is involved, and the change does not involve a significant reduction in a margin of safety.

Based upon the above information, it has been determined that the proposed administrative changes to the Ginna Station Technical Specifications do not involve a significant increase in the probability or consequences of an accident previously evaluated, does not create the possibility of a new or different kind of accident previously evaluated, and does not involve a significant reduction in a margin of. safety. Therefore, it is concluded that the proposed changes meet the requirements of 10 CFR 50.92(c) and do not involve a significant hazards consideration.

E. ENVIRONMENTALCONSIDERATION RG&;E has evaluated the proposed changes and determined that:

The changes do not involve a significant hazards consideration as documented in Section D above;

2. The changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite since no specifications related to offsite releases are affected; and

3. The changes do not involve a significant increase in individual or cumulative occupational radiation exposure since no new or different type of, equipment are required to be installed as a result of this LAR.

Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed changes is not required.

F. REFERENCES Letter from R.C. Mecredy, RG&E, to A.R. Johnson, NRC,

Subject:

Technical Specifica(ionsImprovement Program, Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR), dated December 8, 1995.

2. Letter from L. B. Marsh, NRC, to R.C. Mecredy, RG&:E,

Subject:

RL. Ginna-Acceptance for Referencing of Pressure Temperature Limits Report (TAC No.

M92320), dated December 26, 1995.

3. Letter from A.R. Johnson, NRC, to R.C. Mecredy, RG&;E,

Subject:

RL. Ginna Nuclear Power Plant - Pressurized Thermal Shock evaluation (TAC No. M93827),

dated March 22, 1996.

4. WCAP-14040-NP-A, Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves, January 1996.

5. Letter from G.S. Vissing NRC, to R.C. Mecredy, RG&E,

Subject:

Issuance of Amendment No. 64 to Facility Operating License No. DPR-18, RL~. Ginna Nuclear Power Plant (TAC No. M94770), dated May 23, 1996.