ML17264A774

Requests Approval to Use Alternative Rule ASME Section IX Code Case N-514 in Lieu of 10CFR50.60 for Calculating LTOP Setpoints,Per 961202 & 10 Ltrs

ML17264A774
Person / Time
Site:	Ginna
Issue date:	12/18/1996
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9701020274
Download: ML17264A774 (6)

Text

CATEGORY 1 REGUIATt M INFORMATION DISTRIBUTIONOISTEM (RIDE)

ACCESSION NBR:9701020274 DOC.DATE: 96/12/18 NOTARIZED: NO DOCKET ¹ FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas  !'lectric Corp.

RECIP.NAME RECIPIENT AFFILIATION VISSING F G.

SUBJECT:

Requests approval to use alternative rule ASME Section IX Code Case N-514 in lieu of 10CFR50.60 for calculating LTOP setpoints,per 961202 6 10 ltrs.

DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code GL-8 -04 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 PD1-1 LA 1 1 PD1-1 PD 1 1 VISSINGFG. 1 1 INTERNAL: AEOD/SPD/RAB 1 1 Sa=eENma 1 1 NRR/DE/EMEB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 RES/DET/EIB 1 1 RES/DET/EMMEB 1 1 EXTERNAL: LITCO ANDERSON 1 1 'OAC 1 1 NRC PDR 1 1 D

0 U

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TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL .12

AND ROCHESTER GAS AND ElECTRIC CORPORATION ~ 89 EASTAYENUE, ROCHESTER, N.Y. 146d9-0001 AREA CODE716 546-2700 ROBERT C. MECREDY Vice President December 18, 1996 Nudeor operations U.S. Nuclear Regulatory Commission Document Control Desk Attn: Guy Vissing Project Directorate I-1 Washington, D.C. 20555

Subject:

Request to Use ASME Code Case N-514 in the Determination of Low Temperature Overpressure Protection (LTOP)

Enable Setpoint R.E. Ginna Nuclear Power Plant Docket No. 50-244 Ref. (a): Letter from R. C. Mecredy, RG&E, to G. S. Vissing, NRC,

Subject:

"Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)," dated December 2, 1996.

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

Subject:

"R.E. Ginna Acceptance of Request to Extend Time for Approval of Revision of Pressure and Temperature Limits Report (PTLR) (TAC No. M97313)," dated December

10) 1996.

Dear Mr. Vissing:

By Reference (a), RG&E requested an extension to the NRC's acceptance of the current Ginna Station Reactor Coolant System (RCS) Pressure and Temperature Report (PTLR) from December 31, 1996 to July 1, 1997, for reasons as stated in the letter. The NRC approved this request in Reference (b) provided that RG&E submit the following by December 31, 1996:

a. Request to allow use of ASME Code Case N-514; and

b. Revised PTLR incorporating all NRC comments received to date.

Therefore, the purpose of this letter is to request approval in accordance with 10CFR50.55a(a)(3) to use the alternative rule of ASME Section XI Code Case N-514 in lieu of 10CFR50.60 for calculating LTOP setpoints. Specifically, the application of the 10CFR50.60, "Acceptance Criteria for Fracture Prevention for Lightwater Nuclear Power Reactors for Normal Operation," would result in an LTOP enable temperature (and the requirement for the Safety Injection system to be isolated from the RCS) to be applied at a point where the Safety Injection System would still be required operable by the Ginna Station Improved Technical Specifications. Use of ASME Code Case N-514 provides a Code 970 f/020274 96 1 2 T 8 PDR" 'ADOCK 05000244I PDR P

acceptable alternative which would resolve this concern.

It is requested that this request be approved by 3/30/97 in order to allow incorporation of revised heatup and cooldown curves into the Ginna Station PTLR, as required by our Improved Technical Specifications. These changes are required in addition to the revised PTLR to be submitted under'separate cover by December 31, 1996 per Reference (b).

If you have any questions Wrobel at (716) 724-8070.

in this regard, please contact George Very truly yours, Robert C. Mec edy Attachment REZ5446 xc: Mr. Guy Vissing (Mail Stop 14C7)

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

Attachment 1 Rochester Gas and Electric (RG&E) requests approval in accordance with 50.55a(a)(3)(i) to apply the American Society of Mechanical Engineers (ASME)Section XI, Code Case N-514, "Low Temperature Overpressure Protection Section XI, Division 1," in the determination of Low Temperature Overpressure Protection (LTOP) setpoints for the Ginna Nuclear Power Plant (Ginna).

Code Case N-514 was approved by ASME on February 12,. 1992 and the guidance in Code Case N-514 has been incorporated into the 1993 Addenda to the ASME Boiler and Pressure Vessel Code,Section XI, Appendix G. Code Case N-514 provides guidance on when LTOP shall be in operation, and the maximum pressure to which LTOP shall limit Reactor Vessel pressure. In particular, Code Case N-514 states:

"LTOP systems shall be effective at coolant temperatures...

corresponding to a reactor vessel metal temperature of RT>> +

50'F... to satisfy Appendix G paragraph G-2215 of Section XI, Division 1." A copy of Code Case N-514 has been included with this request as Attachment. 2.

Ginna established LTOP setpoints based upon the methodology Improved Technical Specifications (ITS) 5.6.6.C.3 which is essentially equivalent to NRC approved WCAP-14040-NP-2, Revision 2.

It was determined that inclusion of RCS temperature measurement uncertainties would result in an operating window, between the LTOP enable temperature and the requirement for having an operable safety injection system (i.e., > 350'F), that is too small to accommodate an orderly plant cooldown.

There are many conservatisms incorporated into the pressure-temperature (P/T) limits calculated using the current methodology of ASME Code Section XI, Appendix G. ASME explicitly recognized the amount of margin inherent in the Appendix G pressure-temperature limits by incorporating Code Case N-514 into the 1993 Addenda to ASME Code Section XI, Appendix G. LTOP will still function to meet the fracture toughness requirements of the pressure-retaining components of the reactor coolant pressure

'oundary to provide adequate margin of safety during any condition of normal operation, including anticipated operational occurrences, to which the pressure boundary will be subjected over its service lifetime. As such, use of Code Case N-514 will meet the underlying purpose of 10CFR50.60 for fracture toughness requirements. Thus, this request is made in accordance with 10CFR50.55a(a)(3)(i) in that use of Code Case N-514 provides an acceptable level of quality and safety. In addition, application of the ASME Code without the Code Case results in undue hardship per 10CFR50.55a(a)(3)(ii) in that plant operational requirement conflicts would result.

P r ~

Attachnent 2 CASE N-5<4 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: February 12, 1992 See Numerical Index for expiration and any reaffirmation dates.

Case N-514 protection against failure during reactor start-up and Low Temperature Overpressure Protection shutdown operation due to low temperature over-Section XI, Division 1 pressure events that have been classified as Service Level A or B events. LTOP systems shall be effective Inquiry: Section XI, Division 1, IWB-3730, re- at coolant temperatures less than 200'F or at coolant quires that during reactor operation, load and tem- temperatures'orresponding to a reactor vessel perature conditions be maintained to provide pro- metal temperature'ess than RT>>+ 50'F, which-tection against failure due to the presence of ever is greater. LTOP systems shall limit.the maxi-postulated flaws in the ferritic portions of the reactor mum pressure in the vessel to 110% of the pressure coolant pressure boundary. For those plants having determined to satisfy Appendix G, para. G-2215 of low temperature overpressure protection (LTOP) Section XI, Division 1.

systems, what load and temperature conditions under IWB-3730 m'ay be used to provide protection against failure during reactor start-up and shutdown opera- 'hc coolant tcmpcraturc is the reactor coolant inlet tempera-tion due to low temperature overpressure events that ture.

have been classified as Service Level A or B events? 'he vessel metal temperature is the tcmpcraturc at a distance onc-fourth of thc vcsscl section thickness from thc inside surface in thc vessel bcltline region. RT~, is thc highest adjusted rcfe-Reply: It is the opinion of the Committee that for rcncc tcmpcraturc for weld or base metal in thc beltlinc region those plants having LTOP systems the following load at a distance onc-fourth of the vessel section thickness from thc vcsscl inside surface, as determined by Regulatory Guide 1.99, and temperature conditions may be used to provide Rcv. 2.

I'93 SUPP. 4 NC

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