ML18143A030
| ML18143A030 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/26/1978 |
| From: | Larson L LeBoeuf, Lamb, Leiby & MacRae, Rochester Gas & Electric Corp |
| To: | Case E Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18143A030 (18) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS>
DISTRIBUTION FOR INCOMING MATERIAL 50-244 REC:
CASE E
G ORG:
LARSON L K DOCDATE: 04/26/78 NRC LAWRENCE LIVERMORE LAB DATE RCVD: 04/27/781 DOCTYPE:
LETTER NOTARIZED:
YES COPIES RECEIVED
SUBJECT:
LTR 1
ENCL FORWARDING REQUEST TO OBTAIN AN EXEMPTION FROM COMMISSION"S ECCS REQUIREMENTS TO ISSUE AN AMEND AUTHORIZING OPERATION OF SUBJECT FACILITY WITH CYCLE 8'ELOAD 2
PURSUANT TO REQUIREMENTS OF 10CFR50. 46 8c 10CFR50 APPENDIX K... NOTARIZED 04/25f78.... W/ATT AFF PLANT NAME: RE GINNA UNIT 1
REVIEWER INITIAL:
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DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS 4+4%<<<<<+<+++++<+
REQUESTS FOR EXEMPTIONS (ALL TYPES)
(DISTRIBUTION CODE 8006)
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LEBOEUF, LAMB,LEI.BY 8 MACRAE l757 N STREET, N.W.
WAsHINGTQN, D. C. 20036 LEON A. ALLEN.JR.
JOSEPH E. BACHELDER,III ERNEST S. BALLARDiJR.
G. S. PETER BERGCN 4 GEOFFRY D.C. BEST DAVID P. BICKS TAYLOR R. BRIGGS CHARI.CS N. BURGER THOMAS C.BURKE ROGER O. FELDMANi c EUGENE R. FIOELL ~a JACOB FRIEDLANDCR GERARD GIORDANO DONALD J. GREENE JA M E S A. G R C E R, IZ c JOHN L. GROSE C
DOUGLAS W. HAWKS CARL D. HOBELMAN MICHAEL IOVCNKO JAMES F. JOHNSON, 4' RONALD D.JONES LCX K.LARSON C
GRANT S.LEWIS KIMBA W. LOVEJOY CAMERON F.MAcRAE 4 CAMERON F. MAcRAC>IIC c GCRARD A.MAHER 9 H CI LA H. MARSHALL JAMES G. MCELROY JAMES P. McGRANERY,JR.~ c PHILIP PALMCR McGUIGAN HARVEY A.NAPICR JAMES O'ALLEY.JR.C J. MICHAEl. PARISH WILLIAMW. ROSCN SLATY JOHN A. RUDY PAUL G. RUSSELL PATRICK J. SCOGNAMIGLIO HAROLD M. SEIDCL HALCYON G. SKINNER JOSEPH S.STRAUSS SAMUEL M.SUGDEN EUGCNC B. THOMAS, JR.
4 LEONARD M. TROSTEN i 0 HARR Y H. VOID T ~ 4 H ~ RICHARD WACHTCL GCRARD P. WATSON THOMAS A. 2 IERK TELEPHONE 202 457 7509 CASLC ADDRESS LESWIN, WASHINGTON> D.C.
TELEX: 449274 TELECDPICIL 202 457 7543 April 26,- 1978
+ RESIDENT PARTNERS WASHINGTON OFFICE 4 AOMITTCD TO THC DISTRICT OF COLUMBIA BAR Mr. Edson G.
Case Acting Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commissio RANDALLJ. LcSDCVF,JR. I929 I979 HDRACC R. LAMB 1934 I977 ADRIAN C. LCIBY I952 I978 I4D BROADWAY NCW YORK,N.Y. IDDDS TCLCPHDHE 2I2 299 IIDO CABLE ADDRCSS
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Rochester Gas and Electric Corporation R. E. Ginna Nuclear Plant Docket No. 50-244
Dear Mr. Case:
As counsel for Rochester Gas and Electric Corporation, I enclose a Request for Exemption from the requirements of 10 C.F.R. Section 50.46 and 10 C.F.R. 50 Appendix K, along with attached Affidavit, of Dr.
Robert C. Mecredy, and the attached Affidavit of Harry G. Saddock.
For your convenience two (2) additional copies of the Request for Exemption and attachments are enclosed.
A copy of this Request for Exemption was telecopied to your Staff on April 25, 1978.
Very truly yours,
- LeBOEUF, LAMB, LEIBY 6 MacRAE Le K. Larson Enclosures hei, gc7007~
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
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ROCHESTER GAS AND ELECTRIC
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CORPORATION
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(R.
E. Ginna Nuclear Power
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Plant)
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Docket No. 50-244 REQUEST FOR EXEMPTION In the recent discussions with the NRC Staff there has been the suggestion by members of the Staff that, because of the logic inconsistency identified by Westinghouse Electric Corporation in their LOCA ECCS Evaluation Model, it will be 1
necessary for RGGE to obtain an exemption from the Commission's ECCS requirements in order for the Director of Licensing to issue an amendment 'authorizing operation of the Ginna Plant with cycle 8 reload. 2 RGSE requests the Director of Licensing to issue an exemption from the requirements of 10 C.F.R. Section 50.46 and 10 C'.F.R.
50 Appendix K, as he deems necessary, to permit timely issuance of the requested reload amendment.
1 See Letter of April 17, 1978 from L.D. White, Jr.,
Rochester Gas and Electric Corp. to Dennis L. Ziemann, Chief, Operating Reactors Branch 42, USNRC 2RGSE does not concede that the requested exemption is required;
- however, in view of the shortness of time it appears necessary to file this request in order to avoid undue delay.
4 F,
The requested exemption is fully justified from the standpoint of the public health and safety, as shown by the attached affidavit of Dr. Robert C. Mecredy (Attachment Nl).
This affidavit demonstrates that continued operation of the facility will be in accordance with the limits of 10 C.F.R.
Section 50.46.
The granting of the requested exemption has no implications whatever for the common defense and security.
Finally, the granting of Applicant's request for exemption is in the public interest.
The denial of a reload license amendment as a result of the Commission's failure to grant an exemption would work undue hardship on Rochester Gas and Electric Corporation, its ratepayers, and other members of the public, as detailed in the attached Affidavit of Harry G.
Saddock (Attachment N2).
ROCHESTER GAS AND ELECTRIC CORPORATION L.D. Wh3.te, Jr.
Vice President Electric and Steam Production Subscribed and sworn to before me this 25th day of April, 1978.
S EPHEI'!
KC >JQA NOTARY PUBLIC, State of N.Y, Mo..roe Oo'hty gy Commissiorr Expires March 30, 19.+Q
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Ottachment Nl BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of ROCHESTER GAS AND ELECTRIC CORPORATION (R.
E. Ginna Nuclear Power Plant)
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Docket No.
50-244
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AFFIDAVIT OF ROBERT C.
MECREDY 1.
My name is Robert C. Mecredy and I am Manager of Nuclear Engineering for Rochester Gas and Electric Corpora-tion.
I received a Bachelor of Science degree in engineering sciences from Purdue University and a master of science and a
Ph.D. in nuclear engineering from the University of Michigan.
My responsibilities with relationship to Ginna include fuel performance evaluation, fuel cycle analysis, reactor transient analysis review and evaluation, and licensing.
This includes responsibility for review of LOCA ECCS analysis for Ginna and for licensing of the cycle 8 reload.
2.
On March 24,
- 1978, RG&E was notified by Westing-house Electric Corporation that it had determined that its LOCA ECCS Evaluation Model did not fully account for the heating effect of the Zirconium-water reaction due to a logic inconsis-tency.
On March 29, 1978 representatives of Westinghouse
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described to the NRC the error and provided an analysis justi-fying continued operation of all Westinghouse PWRs.
On April 24,
- 1978, members of the NRC Staff indicated to RGGE that, in their opinion, a request for exemption from the requirements of 10 C.F.R. Section 50.46 and Appendix K to 10 C.F.R. Part 50 was required for the Ginna facility.
3.
The logic inconsistency in the Evaluation Model involves the interface between the zirconium-water reaction heat generation calculation and the heat conduction equation.
Both the zirconium-water reaction equation (Baker-Just) and the heat conduction equation are solved correctly.
- However, the heat conduction equation uses a volumetric heat flux from the zirconium-water reaction calculat'ion.
The output of the zirconium-water reaction calculation is a surface heat flux.
This surface heat flux is modified by dividing by the thickness of the radial mesh size between the surface temperature node and the first node inside the clad to obtain a volumetric heat flux.
It is this calculation which was performed incorrectly.
The inconsistency underestimates the volumetric heat flux due to zirconium-water reaction by a factor of two.
4.
Since that time, Westinghouse has assessed for R.
E. Ginna the impact on licensed operating limits of fully accounting for, the zirconium-water reaction.
The penalty of fully accounting for the zirconium-water reaction has been generically identified by the NRC as equivalent to 0.20 in F
Westinghouse has reviewed the most recent ECCS analysis for Ginna and has identified the margins available between the results of that analysis and the limits in 10 C.F.R. Section 50.46.
Because the previously calculated peak clad temperature was well below the 2200'F limit, a margin of 0.21 in F
is available.
Because the actual steam generator tube plugging at Ginna is well below the level assumed in the most recent'analysis, an additional margin of 0.05 in F
is also available.
- Thus, since the total Q
margin in FQ, 0.26, exceeds the penalty, 0.20, the continued operation without operating restrictions of Ginna at an FQ of 2.32 and at 100% power results in meeting the limits of 10 C.F.R.
Section 50.46.
Robert C. Mecr y
ROCHESTER GAS AND CTIRC CORPORATION Subscribed and sworn to before me this 25th day of April, 1978.
s EP HEN KOiVBA 1tOTARY PUBLIC, State oi N.Y., Monroe County JAy Commission Expires hfarctt 30, 1980
O Attachment N2 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION
=In the Matter of ROCHESTER GAS AND ELECTRIC CORPORATION (R. E. Ginna Nuclear Power Plant,)
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Docket No. 50-244
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AFFIDAVIT OF HARRY G.
SADDOCK 1.
My name is Harry G. Saddock.
I am Vice President, Electric System Planning and Operation for Rochester Gas and Electric Corporation.
I am responsible for formulating trans-mission and generation plans.
In general, the RG&E system genera-tion economics and scheduling of generating unit additions fall within my area of responsibility.
2.
If the requested exemption from ECCS requirements is determined to be necessary for the issuance of authorization to commence operation beginning with the cycle 8 reload, the granting of the exemption would be in the public interest.
It is our understanding that further analysis would be necessary to satisfy the Staff that, ECCS requirements are fully met.
In order to satisfy the Staff, approval of a revised ECCS Evaluation Model must be obtained by Westinghouse, the analyses for Ginna must be performed by Westinghouse, and the analyses must be reviewed and approved by the Staff.
We understand that Staff approval of the revised Westinghouse ECCS Evaluation Model is not, expected until July 1978.
We estimate that the analysis for Ginna will require approximately three months.
Thus, the total time required until the Staff approves the revised analyses is expected to be at
least six months.
If the reload authorization were not issued, the plant would not be able to operate during this period, re-suiting in large replacement capacity and fuel costs to RGB'nd its customers during that period.
That increased cost, is esti-mated to be approximately
$4,500,000 pei month.
3.
Furthermore, the removal of RGB'E's largest generat-ing unit from its system for such an extended period could jeop-ardize system reliability, particularly in the summer season, with serious consequences to RGB customers and the public generally.
Har G.
Saddock ROCHESTER GAS & ELECTRIC CORPORATION Subscribed and sworn to before me this 25th day of April 1978.
S EPHEN KoiVBA JIOTARY PUBLIC, State ot tt. Y, Monroe Cgotnty gtt Commission Expires March 30, 19M
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of ROCHESTER GAS AND ELECTRIC CORPORATION (R.E. Ginna Nuclear Power Station, Unit No.
1)
Docket No. 50-244 f,
t1 fl CERTIFICATE OF SERVICE I hereb'y certify thatl,'I have served a document entitled "Request for Exemption," along with Affidavits II of Robert C. Mecredy and Harry G.Saddock, attached there-to, by mailing copies thereof first class, postage prepaid to each of the following persons this 26th day of April, 1978:
Mr. Michael L. Slade 1250 Crown Point Drive
- Webster, New York 14580 Warren B. Rosenbaum, Esq.
One Main Street 707 Wilder Building Rochester, New York 14614 Edward G. Ketchen, Esp.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. Robert N. Pinkney Supervisor Town of Ontario 107 Ridge Road West
- Ontario, New York 14519
F VI 1'
la i
>I tl ii'4 Ih,
Jeffrey L. Cohen, Esq.
New York State Energy Office Swan Street Building Core 1, Second Floor Empire State Plaza
- Albany, New York l2223 Edward Luton, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
Dr. Dixon Callihan Union Carbide Corporation P.O.
Box Y Oak Ridge, Tennessee 37830 Lex K. Larson
- LeBoeuf, Lamb, Leiby 6 MacRae Attorneys for Rochester Gas and Electric Corporation