ML17264A749
| ML17264A749 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/02/1996 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9612110429 | |
| Download: ML17264A749 (4) | |
Text
CATEGORY 1 REGULAT(.
INFORMATION DISTRIBUTION ZSTEM (RIDS)
ACCESSION NBR:9612110429 DOC.DATE: 96/12/02 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas a Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S.
Document Control Branch (Document Control Desk)
SUBJECT:
Requests that util 961231 limit for Rev 1 to plant RCS pressure S temperature limits
& low temperature overpressure protection limits be extended until 970701.
DZSTRIBOTZON CODE:
AOOID COPIES RECEIVED:LTR I
ENCL 0 SIZE:
TITLE: OR Submittal:
General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
05000244 Q
RECIPIENT ID CODE/NAME PDl-1 LA VISSINGPG.
INTERNAL E CENT 01 NRR DRCH/HICB NRR/DSSA/SRXB OGC/HDS3 EXTERNAL: NOAC COPIES LTTR ENCL RECIPIENT ID CODE/NAME PDl-1 PD NRR/DE/EMCB NRR/DSSA/SPLB NUDOCS-ABSTRACT NRC PDR COPIES LTTR ENCL D
N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-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
I ANn ROCHESTER GASANDELECTRIC CORPORATION ~ 89 FASTAVENIJE, ROCHESTER N.Y M6rI9-0001 ARFA CODE716 Sf6-2700 ROBERT C. MECREDY Vice President 8vcteor operations December 2, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy S. Vissing Project Directorate I-l Washington, D.C. 20555
Subject:
Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)
Rochester Gas Ec Electric Corporation R.E. Ginna Nuclear Power Plant Docket No. 50-244
References:
(a)
Letter from G.S. Vissing, NRC, to R.C. Mecredy, RG&E, Issuance of Amendment No. 64 to Facility Operating License No. DPR-18, RL. Ginna Nuclear Power Plant, dated May 23, 1996.
(b)
WCAP-14040-NP-A, Methodology Used to Develop Cold Overpressure MitigatingSystem Setpoints and RCS Heatup and Cooldown LimitCurves, January 1996.
(c)
Letter from R.C. Mecredy, RG&E, to G.S.
Vissing, NRC,
Subject:
Application for Amendment to Facility Operating License, Revision to Reactor Coolant System (RCS) Pressiue and Temperai'ure Limits Report (PTLR), dated September 13, 1996.
Dear Mr. Vissing,
By Reference (a), the NRC approved changes to Administrative Controls Section 5.6.6 ofthe Ginna Station Technical Specifications which allowed referencing of Revision 1 of the Ginna Station PTLR for the RCS pressure and temperature (P/T) limits and low temperature overpressure protection limits (LTOP). However, the cover letter which forwarded Amendment No. 64 stated that "this amendment is only for operation up to the end ofthe year 1996 after which the operation willbe subject to staff approval ofRevision 1 ofthe Pressure Temperature Limits Report (PTLR)"
even though the P/T curves were valid until 22 effective full power years (EFPYs) which is not expected until the end of 1998.
This stipulation was provided since the fluence factors used to generate the values provided in PTLR Revision 1 were estimated and not based on the methodology required by Reference (b). As such, the NRC requested that RG&E submit a revised PTLR using the required fluence factor methodology at least 90 days prior to December 31, 1996 to provide the NRC sufficient time for review.
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".PDR. ADQCK 05000244, P
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RG&E submitted the requested new PTLR on September 13, 1996 which provided the NRC with the requested 90 day review period (Ref. (c)).
Several conference calls have been conducted between RG&E and the NRC concerning this submittal.
The PTLR is essentially organized into three separate categories:
(1) P/T curves, (2) LTOP setpoints, and (3) reactor vessel material surveillance program. It is RG&E's understanding that the NRC's review of the P/T curves and reactor vessel material surveillance program categories is essentially complete.
This includes the new fluence factor values being proposed by RG&E that was the original basis for the December 31, 1996 limitwith respect to Revision 1 ofthe PTLR.
However, during a conference call on November 26, 1996, questions were raised with respect to the proposed LTOP enable temperature and the boltup temperature.
These questions are unrelated to the fluence factor values and are concerned with whether RG&E has taken into account instrument uncertainties for the values specified in the PTLR. The need for instrument uncertainties is based on, the methodology statement that these values shall be based on the "water temperature corresponding to a metal temperature of..." As discussed in that conference call, ifRG&E were to account for these uncertainties, it would create significant operational burdens due to the close proximity of the LTOP enable temperature to the definition of Mode 3 (i.e., 350'F).
The only method ofresolving this concern is for RG&E to request use of an alternative means of determining the LTOP enable temperature (i.e., using ASME Code Case N-514) as allowed by Reference (b) and 10 CFR 50.55(a)(3).
This is expected to take several weeks for RG&E to prepare and must still be approved by the NRC.
As such, RG&E requests that the December 31, 1996 limitfor Revision 1 ofthe PTLR be extended until July 1, 1997. This request is based on the following:
a.
RG&E has met all schedule related commitments for submitting a revised PTLR.
The December 31, 1996 limitwas an arbitrary date that was mutually acceptable both to the NRC,and RG&Ewhen Amendment No. 64 was issued.
There was no technical reason for selecting this date since the fluence factor values used by RG&E were an engineering based conservative estimate based on previous Westinghouse experience in this area.
As a result of further analysis, it was determined that these fluence factors were within 3% of each other. Instead, the date was chosen to ensure that a rapid closure on this issue would be obtained so that RG&E could place the PTLR under licensee control as originally intended.
The existing P/T curves are valid until 22 effective fullpower years (EFPY) which is not expected to be reached at Ginna Station until late 1998. Therefore, an additional six month extension would not affect operation or the P/T curves.
RG&Ewillsubmit a request to allow use ofASME Code Case N-514 prior to December 31, 1996 in order to resolve the instrument uncertainty issue. RG&E willalso submit a revised PTLR by that date incorporating all NRC comments received to date. Therefore, RG&Ewill still meet the intent ofthe December 31, 1996 limitby providing the NRC with all necessary information such that the extension is mainly being requested to provide the NRC with sufficient time for review of all material.
We request that the NRC provide acceptance ofthis request by December 15, 1996 to allow RG8'cE time to revise necessary plant documentation prior to the December 31, 1996 limitfor Revision 1 of the PTLR. Please contact George Wrobel, Manager ofNuclear Safety and Licensing at (716) 724-8070 ifyou have further questions.
Very truly yours, Robert C. Mecredy MDF>894 xc:
U.S. Nuclear Regulatory Commission Mr. Guy S. Vissing (Mail Stop 14C7)
PWR Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King ofPrussia, PA 19406 Ginna Senior Resident Inspector