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| issue date = 03/28/1990
| issue date = 03/28/1990
| title = Forwards Annual Rept of ECCS Model Revs as Applicable to Facility,Per 10CFR50.46.Mods to Model for Small Break LOCA Do Not Affect Calculated Peak Clad Temp
| title = Forwards Annual Rept of ECCS Model Revs as Applicable to Facility,Per 10CFR50.46.Mods to Model for Small Break LOCA Do Not Affect Calculated Peak Clad Temp
| author name = MECREDY R C
| author name = Mecredy R
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| author affiliation = ROCHESTER GAS & ELECTRIC CORP.
| addressee name = JOHNSON A R
| addressee name = Johnson A
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000244
| docket = 05000244
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=Text=
=Text=
{{#Wiki_filter:ACCELERATED DISTjUBUTION DEMONSHRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9004130169 DOC.DATE: 90/03/28 NOTARIZED:
{{#Wiki_filter:ACCELERATED DISTjUBUTION DEMONSHRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
ACCESSION NBR:9004130169             DOC.DATE: 90/03/28       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 6 Electric Corp.
Rochester Gas 6 Electric Corp.RECIP.NAME RECIPIENT AFFILIATXON JOHNSON,A.R.
RECIP.NAME           RECIPIENT AFFILIATXON JOHNSON,A.R.           . Project Directorate I-3
.Project Directorate I-3  


==SUBJECT:==
==SUBJECT:==
Forwards annual rept of ECCS model revs as applicable to facility,per 10CFR50.46.
Forwards annual rept of ECCS model revs             as applicable to facility,per   10CFR50.46.
DISTRXBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: TITLE: OR Submittal:
DISTRXBUTION CODE: A001D         COPIES RECEIVED:LTR         ENCL     SIZE:
General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
TITLE: OR Submittal: General Distribution                                                 .S NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).                   05000244 RECIPIENT             COPIES            RECIPIENT          COPIES              A ID CODE/NAME            LTTR ENCL      ID   CODE/NAME       LTTR ENCL N
DOCKET 05000244 05000244.S RECIPIENT ID CODE/NAME PDl-3 LA JOHNSON,A INTERNAL: NRR/DET/ECMB 9H NRR/DST 8E2 NRR/DST/SXCB 7E NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 5 5 1 1 1 1 1 1 1 1 1 0 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD1-3 PD NRR/DOEA/OTS B11 NRR/DST/SELB 8 D NRR/DST/SRXB 8E EMB REG LE 01 NRC PDR COPIES LTTR ENCL 1"1 1 1 1 1 1 1 1 0 1 1 1 1 A N D D Ps9~<rmo7 R A NOTE TO ALL"RIDS" RECIPIENTS:
PDl-3 LA                     1    1    PD1-3 PD                1    "1              D JOHNSON,A                   5    5 D
PLEASE HELP US TO REDUCE WASTElCONTACT THE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM'DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 21, ENCL 19 S A~fg 4 ,h g'l>>~)VI Al e~I PJ k C c f 1~)~<, iJ i/(*-P'(I Jl fl 0 i)l/IIIIIIIIIIIIII lillllllE/I i/ANO/j jIIIII/jjjjjIIII SZZZuI l(liltiiZikll IIIIIII/ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N Y.14649.0001 March 28, 1990 TELEP NON E AREA COOK 7ld 546-2700 U.S.Nuclear Regulatory Commission Document Control Desk Attn: Mr.Allen R.Johnson PWR Project Directorate I-3 Washington, D.C.20555  
INTERNAL: NRR/DET/ECMB 9H               1     1     NRR/DOEA/OTS B11       1    1 NRR/DST        8E2          1    1    NRR/DST/SELB 8 D       1    1 NRR/DST/SXCB 7E              1    1    NRR/DST/SRXB 8E         1    1 NUDOCS-ABSTRACT              1    1          EMB               1    0 OGC/HDS2                    1    0    REG     LE       01     1     1 RES/DSIR/EIB                1     1 EXTERNAL: LPDR                          1     1     NRC PDR                1     1 NSIC                        1     1 Ps9~<rmo7                                                                             R A
NOTE TO ALL "RIDS" RECIPIENTS:
S PLEASE HELP US TO REDUCE WASTEl CONTACT THE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM'DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR             21,   ENCL     19
 
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ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N Y. 14649.0001 TELEP NON E March 28, 1990           AREA COOK 7ld 546-2700 U.S. Nuclear Regulatory Commission Document                       Control Desk Attn: Mr. Allen R. Johnson PWR Project Directorate I-3 Washington, D.C.                             20555


==Subject:==
==Subject:==
10CFR50.46 Annual Report ECCS Evaluation Model Revisions R.E.Ginna Nuclear Power Plant Docket No.50-244  
10CFR50.46 Annual Report ECCS Evaluation Model Revisions R.E. Ginna Nuclear Power Plant Docket No. 50-244


==Reference:==
==Reference:==
: 1) NS-NRC-89-3463, "10CFR50.46 Annual Notification for 1989 of Modifications in the Westinghouse ECCS  Evaluation Models", Letter from W.J. Johnson (Westinghouse)  to T.E. Murley (NRC), Dated.
October 5, 1989.
: 2) NS-NRC-89-3464,      "Correction of Errors and Modifications    to the NOTRUMP Code in the Westinghouse Small Break LOCA ECCS Evaluation Model Which Are Potentially Significant", Letter from W.J. Johnson (Westinghouse) to T.E. Murley (NRC), Dated October 5, 1989.


1)NS-NRC-89-3463,"10CFR50.46 Annual Notification for 1989 of Modifications in the Westinghouse ECCS Evaluation Models", Letter from W.J.Johnson (Westinghouse) to T.E.Murley (NRC), Dated.October 5, 1989.2)NS-NRC-89-3464,"Correction of Errors and Modifications to the NOTRUMP Code in the Westinghouse Small Break LOCA ECCS Evaluation Model Which Are Potentially Significant", Letter from W.J.Johnson (Westinghouse) to T.E.Murley (NRC), Dated October 5, 1989.
==Dear Mr. Johnson:==
 
This letter provides the annual report of Emergency Core Cooling System (ECCS) model revisions as they apply to R.E.
Ginna.                          Zn References      1) and 2), Westinghouse        Electric Corporation provided information regarding modifications to their ECCS evaluation models to NRC Staff. References 1) and
: 2) describe the generic effects of the model revisions for both large and small break Loss Of Coolant Accidents (LOCA).
The attachment                to this letter provides information regarding                          the    effects of the ECCS evaluation model modifications on the Ginna UFSAR Chapter 15.6.4 LOCA analysis.
Modifications to the model cause the large break LOCA Peak Clad Temperature (PCT) to increase by 2 F to 1889 F.
9004i30i69 90032S PDR              ADOCK            05000244 R                                        PDC i p'gget5/44'/
 
Modifications to the model for small break      LOCA do not affect calculated. peak clad temperature.
Very truly yours, Robert  C. Mecredy Division  Manager Nuclear Pr'oduction RWEi088 Enclosures xc:  Mr. Allen R. Johnson (Mail Stop  14D1)
Project Directorate I-3 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475  Allendale Road King of Prussia, PA  19406 Ginna Senior Resident Inspector
 
ATT          'O  10CFR50. 46 ANNUAL        PORT Effect of Westinghouse ECCS Evaluation Model Modifications on the LOCA Analysis Results Found in Chapter 15.6.4 of the R.E. Ginna (RG&E) Nuclear Power Plant Updated, Final Safety Analysis Report and. WCAP-11609 Containing the Steam Generator Tube Plu in Re ort for Ginna Nuclear Power Station The October 17, 1988    revision to   10CFR50.46    required applicants and holders of operating licenses or construction permits to notify the Nuclear Regulatory'ommission (NRC) of errors and changes in the ECCS Evaluation Models on an annual basis,               when the errors and changes are not. significant.         Reference 1      defines  a significant error or change as one which results in              a  calculated    peak fuel cladding temperature different by              more    than    50'F    from the temperature calculated for the limiting            transient    using the last acceptable model, or is a cumulation of changes                and  errors such that the sum of the absolute magnitudes                    of  the  respective temperature changes is greater than          50'F.
In References    2 and 3,  information regarding modifications to the Westinghouse large break and small break LOCA ECCS Evaluation Models was submitted to the NRC.              The following presents an assessment of the effect of the modifications to the Westinghouse ECCS Evaluation Models on the Loss-Of-Coolant Accident (LOCA) analyses results found in WCAP-11609, "Steam Generator Tube Plugging (SGTP) Report for Ginna Nuclear Power Station", October 1987 and Chapter 15.6.4 of the R.E. Ginna (RG&E) Nuclear Power Plant Updated Final Safety Analysis Report.
LARGE BREAK LOCA    -  EVALUATION MODEL CHANGES The  large break LOCA analysis for R.E. Ginna (RG&E) was examined to assess the effect of the applicable modifications to the Westinghouse large break LOCA ECCS Evaluation Model on Peak Cladding Temperature (PCT) results reported. in WCAP-11609.                   The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP) level of 12'-o.
The large break analysis was subsequently reanalyzed and licensed for 15% tube plugging and. the results were documented in WCAP-11609, "Steam Generator Tube Plugging (SGTP) Report for Ginna Nuclear Power Station", October 1987.                  The large break LOCA analysis results were calculated. using the 1981 version of the Westinghouse large break LOCA ECCS Evaluation Model which is documented in WCAP-9220-P-A (Reference 4). The current licensing basis analysis assumed .the following information important to the large break LOCA analysis NSSS power    level  102-o  of  1520 MWt Fuel Type    ,14  X14 OFA Pellet  Edge  Configuration      Chamfer Uniform Steam Generator Tube Plugging Level              15%
i Nuclear Peaking Factors of 2.32 for the Total Peaking Factor and 1.66 for the Enthalpy Rise Peaking Factor.


==Dear Mr.Johnson:==
This letter provides the annual report of Emergency Core Cooling System (ECCS)model revisions as they apply to R.E.Ginna.Zn References 1)and 2), Westinghouse Electric Corporation provided information regarding modifications to their ECCS evaluation models to NRC Staff.References 1)and 2)describe the generic effects of the model revisions for both large and small break Loss Of Coolant Accidents (LOCA).The attachment to this letter provides information regarding the effects of the ECCS evaluation model modifications on the Ginna UFSAR Chapter 15.6.4 LOCA analysis.Modifications to the model cause the large break LOCA Peak Clad Temperature (PCT)to increase by 2 F to 1889 F.9004i30i69 90032S PDR ADOCK 05000244 R PDC i p'gget5/44'/
Modifications to the model for small break LOCA do not affect calculated.
peak clad temperature.
Very truly yours, Robert C.Mecredy Division Manager Nuclear Pr'oduction RWEi088 Enclosures xc: Mr.Allen R.Johnson (Mail Stop 14D1)Project Directorate I-3 Washington, D.C.20555 U.S.Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector ATT'O 10CFR50.46 ANNUAL PORT Effect of Westinghouse ECCS Evaluation Model Modifications on the LOCA Analysis Results Found in Chapter 15.6.4 of the R.E.Ginna (RG&E)Nuclear Power Plant Updated, Final Safety Analysis Report and.WCAP-11609 Containing the Steam Generator Tube Plu in Re ort for Ginna Nuclear Power Station The October 17, 1988 revision to 10CFR50.46 required applicants and holders of operating licenses or construction permits to notify the Nuclear Regulatory'ommission (NRC)of errors and changes in the ECCS Evaluation Models on an annual basis, when the errors and changes are not.significant.
Reference 1 defines a significant error or change as one which results in a calculated peak fuel cladding temperature dif f erent by more than 50'F from the temperature calculated for the limiting transient using the last acceptable model, or is a cumulation of changes and errors such that the sum of the absolute magnitudes of the respective temperature changes is greater than 50'F.In References 2 and 3, information regarding modifications to the Westinghouse large break and small break LOCA ECCS Evaluation Models was submitted to the NRC.The following presents an assessment of the effect of the modifications to the Westinghouse ECCS Evaluation Models on the Loss-Of-Coolant Accident (LOCA)analyses results found in WCAP-11609,"Steam Generator Tube Plugging (SGTP)Report for Ginna Nuclear Power Station", October 1987 and Chapter 15.6.4 of the R.E.Ginna (RG&E)Nuclear Power Plant Updated Final Safety Analysis Report.LARGE BREAK LOCA-EVALUATION MODEL CHANGES The large break LOCA analysis for R.E.Ginna (RG&E)was examined to assess the effect of the applicable modifications to the Westinghouse large break LOCA ECCS Evaluation Model on Peak Cladding Temperature (PCT)results reported.in WCAP-11609.
The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP)level of 12'-o.The large break analysis was subsequently reanalyzed and licensed for 15%tube plugging and.the results were documented in WCAP-11609,"Steam Generator Tube Plugging (SGTP)Report for Ginna Nuclear Power Station", October 1987.The large break LOCA analysis results were calculated.
using the 1981 version of the Westinghouse large break LOCA ECCS Evaluation Model which is documented in WCAP-9220-P-A (Reference 4).The current licensing basis analysis assumed.the following information important to the large break LOCA analysis NSSS power level-102-o of 1520 MWt Fuel Type-,14 X14 OFA Pellet Edge Configuration
-Chamfer Uniform Steam Generator Tube Plugging Level-15%i Nuclear Peaking Factors of 2.32 for the Total Peaking Factor and 1.66 for the Enthalpy Rise Peaking Factor.
~~
~~
r~~or R.E.Ginna (R), the limiting break reslked from the double ended.guillotine rupture of the cold leg piping with a discharge coefficient of CD=0.4.The calculated peak cladding temperature was 1887'F including the applicable penalties.
r
The PCT value of 1887'F includes a 6'enalty to account for an upper plenum injection and.a core crossflow penalty'of 10'F.The following modifications to the Westinghouse ECCS Evaluation Model were evaluated to determine if they would affect the current licensing basis-large break LOCA analysis results for R.E.Ginna for 15%SGTP found.'n WCAP-11609.
~~or R.E. Ginna (R), the limiting break reslked from the double ended. guillotine rupture of the cold leg piping with a discharge coefficient of CD = 0.4. The calculated peak cladding temperature was 1887'F including the applicable penalties. The PCT value of 1887'F includes a 6'enalty to account for an upper plenum injection and. a core crossflow penalty'of 10'F.
1981 ECCS Evaluation Model: (Not Max-SI Limited,)In the 1981 version of the Westinghouse ECCS Evaluation Model, a modification was made to delay downcomer overfilling.
The   following modifications to the Westinghouse ECCS Evaluation Model were evaluated   to determine if they would affect the current licensing basis -large break LOCA analysis results for R.E. Ginna for 15% SGTP found.'n WCAP-11609.
The delay corresponds to backfilling of the intact cold legs.Data from tests simulating cold leg injection during the post-large break LOCA reflood phase which have adequate safety injection flow to condense all of the-available steam flow show a significant amount of subcooled.
1981 ECCS   Evaluation Model: (Not Max-SI Limited,)
liquid to be present in the cold leg pipe test section.This situation corresponds to the so-called maximum safety injection scenario of ECCS Evaluation Model analyses.The R.E.Ginna (RGGE)LOCA analysis performed with the Westinghouse 1981 large break LOCA ECCS Evaluation Model is not affected.by the WREFLOOD code modifications since the maximum safeguards safety injection flow assumption is not limiting.1981 ECCS Evaluation Model.: (Two-Loop Plants)In the 1981'version of the Westinghouse ECCS Evaluation Model, the pressurizer is modeled as being attached to the broken (faulted)loop in the SATAN-VI code for calculating large break blowdown behavior.Sensitivity studies were performed to determine if this pressurizer location in the noding scheme was the most limiting position.The results indicated that two-loop Westinghouse PWRs are sensitive'to the pressurizer nodal location and that in some cases modeling the pressurizer in the intact (non-faulted) loop resulted.in a slight increase in the calculated Peak Cladding Temperature (PCT).For a two loop plant, core cooling is provided by negative core flow and.the negative core flow period.lasts through most of the remaining blowdown period;The concern regarding pressurizer location relates to the negative core flow period which is crucial for core cooling in a two-loop plant.With the pressurizer on the broken loop, pressurizer flow is a large contributor to break flow (pump side), lessening the contribution from the upper plenum and leaving a large upper plenum inventory for negative core flow later in blowdown.For Ginna, a penalty of 2'F due to modeling the pressurizer in the intact (non-faulted) loop was assessed to be used in tracking margin to the 10CFR50.46 limit on the current licensing basis analysis for 15-o SGTP contained.
In the 1981 version of the Westinghouse ECCS Evaluation Model, a modification was made to delay downcomer overfilling. The delay corresponds to backfilling of the intact cold legs.       Data from tests simulating cold leg injection during the post-large break LOCA reflood phase which have adequate safety injection flow to condense all of the- available steam flow show a significant amount of subcooled. liquid to be present in the cold leg pipe test section. This situation corresponds to the so-called maximum safety injection scenario of ECCS Evaluation Model analyses.
in WCAP-11609.
The R.E. Ginna (RGGE) LOCA analysis performed with the Westinghouse 1981 large break LOCA ECCS Evaluation Model is not affected. by the WREFLOOD code modifications since the maximum safeguards       safety injection flow assumption is not limiting.
The PCT for the limiting C=0.4 break is 1887'F with applicable penalties, and thus adding the 2'F increase brings the PCT, to 1889'F which is well below the 10CFR50.46 limit.
1981 ECCS Evaluation Model.: (Two-Loop Plants)
ks discussed abov modifications to the Nestgghouse large break LOCA ECCS Evaluation Model could affect the result by altering the~PCT.A.Analysis Calculated Result B.Modifications to Westinghouse ECCS Evaluation Model C.ECCS Evaluation Model Modifications Resultant PCT 1887'F 2oF 1889 F SMALL BREAK LOCA-EVALUATION MODEL CHANGES The small break.LOCA analysis for R.E.Ginna (RG&E)was also examined to assess the effect of the applicable modifications to the Westinghouse ECCS Evaluation Models on Peak Cladding Temperature (PCT)results reported in Chapter 15.6.4.1 of the UFSAR.The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP)level of 12%.The small break LOCA analysis was subsequently evaluated and licensed for a SGTP level increase from 12: to 15%.The small break LOCA event was not reanalyzed because the results are not sensitive to a SGTP level increase from 12%to 15:.The evaluation was documented, and transmitted in WCAP-11609,"Steam Generator Tube Plugging (SGTP)Report for Ginna Nuclear Power Station", October 1987.The small break LOCA analysis results were calculated using the Westinghouse small break LOCA ECCS Evaluation Model documented in WCAP-8970 (Reference 12)which utilized the WFLASH computer code.For R.E.Ginna (RG&E), the limiting size small break resulted from a 6 inch equivalent diameter break in the cold leg.The calculated peak cladding temperature was 1092 F.The analysis assumed the following information important to the small break analyses: NSSS power level-102%of 1520 MWt Fuel Type-14 Z14 OFA Pellet Edge Configuration
In the 1981'version of the Westinghouse ECCS Evaluation Model, the pressurizer is modeled as being attached to the broken (faulted) loop in the SATAN-VI code for calculating large break blowdown behavior. Sensitivity studies were performed to determine   if pressurizer location in the noding scheme was the most limiting this position. The results indicated that two-loop Westinghouse PWRs are sensitive'to the pressurizer nodal location and that in some cases modeling the pressurizer in the intact (non-faulted) loop resulted. in a slight increase in the calculated Peak Cladding Temperature (PCT). For a two loop plant, core cooling is provided by negative core flow and. the negative core flow period. lasts through most of the remaining blowdown period;         The concern regarding pressurizer location relates to the negative core flow period which is crucial for core cooling in a two-loop plant. With the pressurizer on the broken loop, pressurizer flow is a large contributor to break flow (pump side), lessening the contribution from the upper plenum and leaving a large upper plenum inventory for negative core flow later in blowdown.
-Chamfer Uniform Steam Generator Tube Plugging Level-12-o Nuclear Peaking Factors of 2e32 for the Total Peaking Factor and 1.66 for the Enthalpy Rise Peaking Factor.600 GPM Total Auziliary Feedwater Flow.The following modification to the Westinghouse ECCS Evaluation Model were evaluated to determine if they would affect the current licensing basis small break LOCA analysis results for R.E.Ginna.WFLASH ECCS Evaluation Model Following the accident at Three Mile Island Unit 2, additional attention was focused on the small break LOCA and.Westinghouse submitted a report, WCAP-9600 (Reference 5), to the Nuclear Regulatory Commission (NRC)detailing the performance of the Westinghouse small break LOCA Evaluation Model which utilized the WFLASH computer code.In NUREG-0611 (Reference 6), the NRC staff questioned the validity of certain models in the WFLASH, computer  
For Ginna, a penalty of 2'F due to modeling the pressurizer in the intact (non-faulted) loop was assessed to be used in tracking margin to the 10CFR50.46 limit on the current licensing basis analysis for 15-o SGTP contained. in WCAP-11609. The PCT for the limiting C =0.4 break is 1887'F with applicable penalties, and thus adding the 2'F increase brings the PCT, to 1889'F which is well below the 10CFR50.46   limit.
~t1'V code and required censees to justify contin acceptance of the model.Section II.K.3.30 of NUREG-0737 (Reference 7), which clarified the NRC Post-TMI requirements regarding small break LOCA modeling, required that the licensees revise the small break LOCA ECCS models along the guidelines specified in NUREG-0611.
 
Following the issuance of NUREG-0737, Westinghouse and the Westinghouse Owners Group decided to develop the NOTRUMP (Reference 9)computer code for use in a new small break LOCA ECCS Evaluation Model (Reference 10).The NRC approved the use of NOTRUMP for small break LOCA ECCS analyses in May 1985.Since approval of the NOTRUMP small break LOCA ECCS Evaluation Model in 1985, the WFLASH computer code has not been maintained as.part of the Westinghouse ECCS Evaluation Model computer codes.In section II.K.3.31 of NUREG-0737, the NRC required that each licensee submit a new small break LOCA analysis using an NRC approved small break LOCA Evaluation Model.which satisfied the requirements of NUREG-0737 section II.K.3.30.
ks discussed   abov modifications to the Nestgghouse large break LOCA ECCS   Evaluation Model could affect the result by altering the
NRC Generic Letter 83-35 (Reference 8)relaxed the requirements of Item II.K.3.31 by allowing a more generic response and providing a basis for retention of the existing small, break LOCA analyses.Provided that the previously existing model results were demonstrated to be conservative with respect to the new small break LOCA model approved under the requirements of NUREG-0737 II.K.3.30 (NOTRUMP), plant specific analyses using the new small break LOCA Evaluation Model would not be required.In WCAP-11145 (Reference 11), Westinghouse and the Westinghouse Owners Group demonstrated that the result's obtained from calculations with WFLASH were conservative relative to those obtained.with NOTRUMP.Compliance with Item II.K.3.31 of NUREG-0737 could be completed by referencing WCAP-11145 and supplying some plant specific information.
~ PCT.
Westinghouse, therefore, has not been modifying, investigating, or evaluating proposed changes to the WFLASH.small break LOCA ECCS Evaluation Model.As discussed above, none of the modifications to the Westinghouse small break LOCA ECCS Evaluation Model would affect the small break LOCA analysis results by altering the PCT.A.Analysis Calculated Result B.Modifications to Westinghouse ECCS Evaluation Model C.ECCS Evaluation Model Modifications Resultant PCT 1092'F+0oF 1092'F CONCLUSION An evaluation of the effect of modifications to the Westinghouse ECCS Evaluation Model as reported in References 2 and 3 was performed for both the large break LOCA and small break LOCA analyses results found in WCAP-11609 and Chapter 15.6.4 of the R.E.Ginna Nuclear Power Plant Updated Final Safety Analysis Report.The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP)level of 12-o.The large break LOCA analysis was subsequently reanalyzed and licensed for an increase to 15: tube plugging.The small break LOCA analysis was evaluated and was not impacted by the increase in SGTP level to.The results of the ana es and evaluations for the increase in.SGTP level to 15-o were documented in WCAP-11609,"Steam Generator Tube Plugging (SGTP)Report for Ginna.Nuclear Power Station".When the effects of the ECCS model changes were combined with the current plant analysis results, it was determined that compliance with the requirements of 10CFR50.46 would be maintained.
A. Analysis Calculated Result                             1887'F B. Modifications to Westinghouse ECCS Evaluation Model                                         2oF C. ECCS Evaluation Model Modifications Resultant PCT                                         1889 F SMALL BREAK LOCA   - EVALUATION MODEL CHANGES The small break. LOCA analysis for R.E. Ginna (RG&E) was also examined to assess the effect of the applicable modifications to the Westinghouse ECCS Evaluation Models on Peak Cladding Temperature (PCT) results reported in Chapter 15.6.4.1 of the UFSAR. The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP)   level of 12%.       The small break LOCA analysis was subsequently evaluated   and licensed for a SGTP level increase from 12: to 15%. The small break LOCA     event was not reanalyzed because the results are not sensitive to a SGTP level increase from 12% to 15:. The evaluation was documented, and transmitted in WCAP-11609, "Steam Generator Tube Plugging (SGTP) Report for Ginna Nuclear Power Station", October 1987.         The small break LOCA analysis results were calculated using the Westinghouse small break LOCA ECCS Evaluation Model documented in WCAP-8970 (Reference 12) which utilized the WFLASH computer code. For R.E. Ginna (RG&E), the limiting size small break resulted from a 6 inch equivalent diameter break in the cold leg.         The calculated peak cladding temperature was 1092 F.         The analysis assumed the following information important to the small break analyses:
REFERENCES 2.3.4.5.6.7.8.9.10.12."Emergency Core Cooling Systems;Revisions to Acceptance Criteria", Federal Register, Vol.53, No.180, pp.35996-36005, dated September, 16, 1988.NS-NRC-89-3463,"10CFR50.46 Annual Notification for 1989 of Modifications in the Westinghouse ECCS Evaluation Models," Letter from W.J.Johnson (Westinghouse) to T.E.Murley (NRC), dated.October 5, 1989.NS-NRC-89-3464,"Correction of Errors.and Modifications to the NOTRUMP Code in the Westinghouse Small Break LOCA ECCS Evaluation Model Which Are Potentially Significant", Letter from W.J.Johnson (Westinghouse) to T.E.Murley (NRC), dated October 5, 1989.WCAP-9220-P-A, Revision 1 (Proprietary), WCAP-9221-A, Revision 1 (Non-Proprietary),"Westinghouse ECCS Evaluation Model 1981 Version", 1981, Eicheldinger, C.WCAP-10924-P-A (Proprietary), WCAP-12130-A (Non-Proprietary),"Westinghouse Large Break LOCA Best Estimate Methodology", Hochreiter, L.E., et.al., January 1987.Report on Small Break Accidents for Westinghouse Nuclear Steam Supply System", WCAP-9601 (Non-Proprietary), June 1979, WCAP-9600 (Proprietary), June 1979."Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in Westinghouse Designed Operating Plants", NUREG-0611, January 1980."Clarification of TMI Action Plan Requirements", NUREG-0737, November 1980."Clarification of TMI Plan Item II.K.3.31,"NRC Generic Letter 83-85 from D.G.Eisenhut, November 2, 1983."NOTRUMP-A Nodal Transient Small Break and General Network Code", WCAP-10079-P-A (Proprietary), WCAP-10081-A (Non-'Proprietary), Lee, N., et.al., August 1985."Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code", WCAP-10054-P-A (Proprietary), WCAP-10081-A (Non-Proprietary), Lee, N., et.al., August 1985.WCAP-8970 (Proprietary) and WCAP-8971 (Non-Proprietary),"Westinghouse Emergency Core Cooling System Small Break October 1975 Model", April 1977.}}
NSSS power level 102% of 1520 MWt Fuel Type   14 Z14 OFA Pellet   Edge Configuration   Chamfer Uniform Steam Generator Tube Plugging Level       12-o Nuclear Peaking Factors of 2e32 for the Total Peaking Factor and 1.66 for the Enthalpy Rise Peaking Factor.
600 GPM Total Auziliary Feedwater Flow.
The following modification to the Westinghouse ECCS Evaluation Model were evaluated to determine if they would affect the current licensing basis small break LOCA analysis results for R.E. Ginna.
WFLASH ECCS Evaluation Model Following the accident at Three Mile Island Unit 2, additional attention was focused on the small break LOCA and. Westinghouse submitted a report, WCAP-9600 (Reference 5), to the Nuclear Regulatory Commission (NRC) detailing the performance of the Westinghouse small break LOCA Evaluation Model which utilized the WFLASH computer code.     In NUREG-0611 (Reference 6), the NRC staff questioned the validity of certain models in the WFLASH, computer
 
~ t1 censees to justify contin V
code and required                                   acceptance of the model. Section II.K.3.30 of NUREG-0737 (Reference 7), which clarified the NRC Post-TMI requirements regarding small break LOCA modeling, required that the licensees revise the small break LOCA ECCS models along the guidelines specified in NUREG-0611.
Following the issuance of NUREG-0737, Westinghouse and the Westinghouse Owners Group decided to develop the NOTRUMP (Reference
: 9) computer code for use in a new small break LOCA ECCS Evaluation Model (Reference 10).       The NRC approved the use of NOTRUMP for small break LOCA   ECCS analyses in May 1985. Since approval of the NOTRUMP small break LOCA ECCS Evaluation Model in 1985, the WFLASH computer code has not been maintained as. part of the Westinghouse ECCS Evaluation Model computer codes.
In section II.K.3.31 of NUREG-0737, the NRC required that each licensee submit a new small break LOCA analysis using an NRC approved small break LOCA Evaluation Model. which satisfied the requirements of NUREG-0737 section II.K.3.30. NRC Generic Letter 83-35 (Reference 8) relaxed the requirements of Item II.K.3.31 by allowing a more generic response and providing a basis for retention of the existing small, break LOCA analyses. Provided that the previously existing model results were demonstrated to be conservative with respect to the new small break LOCA model approved under the requirements of NUREG-0737 II.K.3.30 (NOTRUMP),
plant specific analyses using the new small break LOCA Evaluation Model would not be required.         In WCAP-11145 (Reference 11),
Westinghouse and   the Westinghouse Owners Group demonstrated that the   result's obtained     from calculations   with WFLASH were conservative relative to those obtained. with NOTRUMP. Compliance with Item II.K.3.31 of NUREG-0737 could be completed by referencing WCAP-11145 and supplying some plant specific information.
Westinghouse, therefore, has not been modifying, investigating, or evaluating proposed changes to the WFLASH .small break LOCA ECCS Evaluation Model.
As discussed above, none of the modifications to the Westinghouse small break LOCA ECCS Evaluation Model would affect the small break LOCA analysis results by altering the PCT.
A. Analysis Calculated Result                           1092'F B. Modifications to Westinghouse ECCS Evaluation Model                                   +    0oF C. ECCS Evaluation Model Modifications Resultant PCT                                       1092'F CONCLUSION An evaluation of the effect of modifications to the Westinghouse ECCS   Evaluation Model as reported in References 2 and 3 was performed for both the large break LOCA and small break LOCA analyses results found in WCAP-11609 and Chapter 15.6.4 of the R.E.
Ginna Nuclear Power Plant Updated Final Safety Analysis Report.
The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP) level of 12-o. The large break LOCA analysis was subsequently reanalyzed and licensed for an increase to 15: tube plugging. The small break LOCA analysis was evaluated and was not impacted by the increase
 
in SGTP level to     . The results of the ana   es and evaluations for the increase in. SGTP   level to 15-o were documented   in WCAP-11609, "Steam Generator   Tube Plugging   (SGTP) Report for Ginna.
Nuclear Power Station".
When the effects of the ECCS model changes were combined with the current plant analysis results,     it was determined that compliance with the requirements of 10CFR50.46 would be maintained.
 
REFERENCES "Emergency     Core   Cooling Systems;     Revisions   to Acceptance Criteria", Federal Register, Vol.         53, No. 180, pp. 35996-36005, dated September, 16, 1988.
: 2. NS-NRC-89-3463,     "10CFR50.46 Annual Notification for 1989 of Modifications in the Westinghouse ECCS Evaluation Models,"
Letter from W.J. Johnson (Westinghouse) to T.E. Murley (NRC),
dated. October 5, 1989.
: 3. NS-NRC-89-3464,     "Correction of Errors.and Modifications to the NOTRUMP   Code   in the   Westinghouse Small Break LOCA ECCS Evaluation Model Which Are Potentially Significant", Letter from W.J. Johnson (Westinghouse) to T.E. Murley (NRC), dated October 5, 1989.
: 4. WCAP-9220-P-A, Revision 1     (Proprietary), WCAP-9221-A, Revision 1 (Non-Proprietary), "Westinghouse       ECCS Evaluation Model 1981 Version", 1981, Eicheldinger,       C.
: 5. WCAP-10924-P-A     (Proprietary), WCAP-12130-A (Non-Proprietary),
    "Westinghouse     Large Break   LOCA Best Estimate Methodology",
Hochreiter, L.E., et.al., January 1987.
: 6. Report on Small Break Accidents for Westinghouse Nuclear Steam Supply System", WCAP-9601 (Non-Proprietary), June 1979, WCAP-9600   (Proprietary),   June 1979.
: 7.  "Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in Westinghouse Designed Operating Plants",   NUREG-0611, January     1980.
: 8.  "Clarification of     TMI Action Plan Requirements",     NUREG-0737, November 1980.
: 9.  "Clarification of TMI Plan Item II.K.3.31,       "NRC Generic Letter 83-85 from D.G. Eisenhut, November 2, 1983.
: 10.  "NOTRUMP   - A Nodal Transient Small Break and General Network Code",   WCAP-10079-P-A     (Proprietary), WCAP-10081-A (Non-
    'Proprietary),   Lee, N., et. al., August 1985.
    "Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code",       WCAP-10054-P-A (Proprietary), WCAP-10081-A (Non-Proprietary), Lee, N., et. al., August 1985.
: 12. WCAP-8970     (Proprietary)     and   WCAP-8971   (Non-Proprietary),
    "Westinghouse Emergency Core Cooling System             Small Break October 1975 Model", April 1977.}}

Latest revision as of 10:54, 4 February 2020

Forwards Annual Rept of ECCS Model Revs as Applicable to Facility,Per 10CFR50.46.Mods to Model for Small Break LOCA Do Not Affect Calculated Peak Clad Temp
ML17261B032
Person / Time
Site: Ginna Constellation icon.png
Issue date: 03/28/1990
From: Mecredy R
ROCHESTER GAS & ELECTRIC CORP.
To: Andrea Johnson
Office of Nuclear Reactor Regulation
References
NUDOCS 9004130169
Download: ML17261B032 (11)


Text

ACCELERATED DISTjUBUTION DEMONSHRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9004130169 DOC.DATE: 90/03/28 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 6 Electric Corp.

RECIP.NAME RECIPIENT AFFILIATXON JOHNSON,A.R. . Project Directorate I-3

SUBJECT:

Forwards annual rept of ECCS model revs as applicable to facility,per 10CFR50.46.

DISTRXBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution .S NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES A ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL N

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NOTE TO ALL "RIDS" RECIPIENTS:

S PLEASE HELP US TO REDUCE WASTEl CONTACT THE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM'DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 21, ENCL 19

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ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N Y. 14649.0001 TELEP NON E March 28, 1990 AREA COOK 7ld 546-2700 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Mr. Allen R. Johnson PWR Project Directorate I-3 Washington, D.C. 20555

Subject:

10CFR50.46 Annual Report ECCS Evaluation Model Revisions R.E. Ginna Nuclear Power Plant Docket No. 50-244

Reference:

1) NS-NRC-89-3463, "10CFR50.46 Annual Notification for 1989 of Modifications in the Westinghouse ECCS Evaluation Models", Letter from W.J. Johnson (Westinghouse) to T.E. Murley (NRC), Dated.

October 5, 1989.

2) NS-NRC-89-3464, "Correction of Errors and Modifications to the NOTRUMP Code in the Westinghouse Small Break LOCA ECCS Evaluation Model Which Are Potentially Significant", Letter from W.J. Johnson (Westinghouse) to T.E. Murley (NRC), Dated October 5, 1989.

Dear Mr. Johnson:

This letter provides the annual report of Emergency Core Cooling System (ECCS) model revisions as they apply to R.E.

Ginna. Zn References 1) and 2), Westinghouse Electric Corporation provided information regarding modifications to their ECCS evaluation models to NRC Staff. References 1) and

2) describe the generic effects of the model revisions for both large and small break Loss Of Coolant Accidents (LOCA).

The attachment to this letter provides information regarding the effects of the ECCS evaluation model modifications on the Ginna UFSAR Chapter 15.6.4 LOCA analysis.

Modifications to the model cause the large break LOCA Peak Clad Temperature (PCT) to increase by 2 F to 1889 F.

9004i30i69 90032S PDR ADOCK 05000244 R PDC i p'gget5/44'/

Modifications to the model for small break LOCA do not affect calculated. peak clad temperature.

Very truly yours, Robert C. Mecredy Division Manager Nuclear Pr'oduction RWEi088 Enclosures xc: Mr. Allen R. Johnson (Mail Stop 14D1)

Project Directorate I-3 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

ATT 'O 10CFR50. 46 ANNUAL PORT Effect of Westinghouse ECCS Evaluation Model Modifications on the LOCA Analysis Results Found in Chapter 15.6.4 of the R.E. Ginna (RG&E) Nuclear Power Plant Updated, Final Safety Analysis Report and. WCAP-11609 Containing the Steam Generator Tube Plu in Re ort for Ginna Nuclear Power Station The October 17, 1988 revision to 10CFR50.46 required applicants and holders of operating licenses or construction permits to notify the Nuclear Regulatory'ommission (NRC) of errors and changes in the ECCS Evaluation Models on an annual basis, when the errors and changes are not. significant. Reference 1 defines a significant error or change as one which results in a calculated peak fuel cladding temperature different by more than 50'F from the temperature calculated for the limiting transient using the last acceptable model, or is a cumulation of changes and errors such that the sum of the absolute magnitudes of the respective temperature changes is greater than 50'F.

In References 2 and 3, information regarding modifications to the Westinghouse large break and small break LOCA ECCS Evaluation Models was submitted to the NRC. The following presents an assessment of the effect of the modifications to the Westinghouse ECCS Evaluation Models on the Loss-Of-Coolant Accident (LOCA) analyses results found in WCAP-11609, "Steam Generator Tube Plugging (SGTP) Report for Ginna Nuclear Power Station", October 1987 and Chapter 15.6.4 of the R.E. Ginna (RG&E) Nuclear Power Plant Updated Final Safety Analysis Report.

LARGE BREAK LOCA - EVALUATION MODEL CHANGES The large break LOCA analysis for R.E. Ginna (RG&E) was examined to assess the effect of the applicable modifications to the Westinghouse large break LOCA ECCS Evaluation Model on Peak Cladding Temperature (PCT) results reported. in WCAP-11609. The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP) level of 12'-o.

The large break analysis was subsequently reanalyzed and licensed for 15% tube plugging and. the results were documented in WCAP-11609, "Steam Generator Tube Plugging (SGTP) Report for Ginna Nuclear Power Station", October 1987. The large break LOCA analysis results were calculated. using the 1981 version of the Westinghouse large break LOCA ECCS Evaluation Model which is documented in WCAP-9220-P-A (Reference 4). The current licensing basis analysis assumed .the following information important to the large break LOCA analysis NSSS power level 102-o of 1520 MWt Fuel Type ,14 X14 OFA Pellet Edge Configuration Chamfer Uniform Steam Generator Tube Plugging Level 15%

i Nuclear Peaking Factors of 2.32 for the Total Peaking Factor and 1.66 for the Enthalpy Rise Peaking Factor.

~~

r

~~or R.E. Ginna (R), the limiting break reslked from the double ended. guillotine rupture of the cold leg piping with a discharge coefficient of CD = 0.4. The calculated peak cladding temperature was 1887'F including the applicable penalties. The PCT value of 1887'F includes a 6'enalty to account for an upper plenum injection and. a core crossflow penalty'of 10'F.

The following modifications to the Westinghouse ECCS Evaluation Model were evaluated to determine if they would affect the current licensing basis -large break LOCA analysis results for R.E. Ginna for 15% SGTP found.'n WCAP-11609.

1981 ECCS Evaluation Model: (Not Max-SI Limited,)

In the 1981 version of the Westinghouse ECCS Evaluation Model, a modification was made to delay downcomer overfilling. The delay corresponds to backfilling of the intact cold legs. Data from tests simulating cold leg injection during the post-large break LOCA reflood phase which have adequate safety injection flow to condense all of the- available steam flow show a significant amount of subcooled. liquid to be present in the cold leg pipe test section. This situation corresponds to the so-called maximum safety injection scenario of ECCS Evaluation Model analyses.

The R.E. Ginna (RGGE) LOCA analysis performed with the Westinghouse 1981 large break LOCA ECCS Evaluation Model is not affected. by the WREFLOOD code modifications since the maximum safeguards safety injection flow assumption is not limiting.

1981 ECCS Evaluation Model.: (Two-Loop Plants)

In the 1981'version of the Westinghouse ECCS Evaluation Model, the pressurizer is modeled as being attached to the broken (faulted) loop in the SATAN-VI code for calculating large break blowdown behavior. Sensitivity studies were performed to determine if pressurizer location in the noding scheme was the most limiting this position. The results indicated that two-loop Westinghouse PWRs are sensitive'to the pressurizer nodal location and that in some cases modeling the pressurizer in the intact (non-faulted) loop resulted. in a slight increase in the calculated Peak Cladding Temperature (PCT). For a two loop plant, core cooling is provided by negative core flow and. the negative core flow period. lasts through most of the remaining blowdown period; The concern regarding pressurizer location relates to the negative core flow period which is crucial for core cooling in a two-loop plant. With the pressurizer on the broken loop, pressurizer flow is a large contributor to break flow (pump side), lessening the contribution from the upper plenum and leaving a large upper plenum inventory for negative core flow later in blowdown.

For Ginna, a penalty of 2'F due to modeling the pressurizer in the intact (non-faulted) loop was assessed to be used in tracking margin to the 10CFR50.46 limit on the current licensing basis analysis for 15-o SGTP contained. in WCAP-11609. The PCT for the limiting C =0.4 break is 1887'F with applicable penalties, and thus adding the 2'F increase brings the PCT, to 1889'F which is well below the 10CFR50.46 limit.

ks discussed abov modifications to the Nestgghouse large break LOCA ECCS Evaluation Model could affect the result by altering the

~ PCT.

A. Analysis Calculated Result 1887'F B. Modifications to Westinghouse ECCS Evaluation Model 2oF C. ECCS Evaluation Model Modifications Resultant PCT 1889 F SMALL BREAK LOCA - EVALUATION MODEL CHANGES The small break. LOCA analysis for R.E. Ginna (RG&E) was also examined to assess the effect of the applicable modifications to the Westinghouse ECCS Evaluation Models on Peak Cladding Temperature (PCT) results reported in Chapter 15.6.4.1 of the UFSAR. The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP) level of 12%. The small break LOCA analysis was subsequently evaluated and licensed for a SGTP level increase from 12: to 15%. The small break LOCA event was not reanalyzed because the results are not sensitive to a SGTP level increase from 12% to 15:. The evaluation was documented, and transmitted in WCAP-11609, "Steam Generator Tube Plugging (SGTP) Report for Ginna Nuclear Power Station", October 1987. The small break LOCA analysis results were calculated using the Westinghouse small break LOCA ECCS Evaluation Model documented in WCAP-8970 (Reference 12) which utilized the WFLASH computer code. For R.E. Ginna (RG&E), the limiting size small break resulted from a 6 inch equivalent diameter break in the cold leg. The calculated peak cladding temperature was 1092 F. The analysis assumed the following information important to the small break analyses:

NSSS power level 102% of 1520 MWt Fuel Type 14 Z14 OFA Pellet Edge Configuration Chamfer Uniform Steam Generator Tube Plugging Level 12-o Nuclear Peaking Factors of 2e32 for the Total Peaking Factor and 1.66 for the Enthalpy Rise Peaking Factor.

600 GPM Total Auziliary Feedwater Flow.

The following modification to the Westinghouse ECCS Evaluation Model were evaluated to determine if they would affect the current licensing basis small break LOCA analysis results for R.E. Ginna.

WFLASH ECCS Evaluation Model Following the accident at Three Mile Island Unit 2, additional attention was focused on the small break LOCA and. Westinghouse submitted a report, WCAP-9600 (Reference 5), to the Nuclear Regulatory Commission (NRC) detailing the performance of the Westinghouse small break LOCA Evaluation Model which utilized the WFLASH computer code. In NUREG-0611 (Reference 6), the NRC staff questioned the validity of certain models in the WFLASH, computer

~ t1 censees to justify contin V

code and required acceptance of the model.Section II.K.3.30 of NUREG-0737 (Reference 7), which clarified the NRC Post-TMI requirements regarding small break LOCA modeling, required that the licensees revise the small break LOCA ECCS models along the guidelines specified in NUREG-0611.

Following the issuance of NUREG-0737, Westinghouse and the Westinghouse Owners Group decided to develop the NOTRUMP (Reference

9) computer code for use in a new small break LOCA ECCS Evaluation Model (Reference 10). The NRC approved the use of NOTRUMP for small break LOCA ECCS analyses in May 1985. Since approval of the NOTRUMP small break LOCA ECCS Evaluation Model in 1985, the WFLASH computer code has not been maintained as. part of the Westinghouse ECCS Evaluation Model computer codes.

In section II.K.3.31 of NUREG-0737, the NRC required that each licensee submit a new small break LOCA analysis using an NRC approved small break LOCA Evaluation Model. which satisfied the requirements of NUREG-0737 section II.K.3.30. NRC Generic Letter 83-35 (Reference 8) relaxed the requirements of Item II.K.3.31 by allowing a more generic response and providing a basis for retention of the existing small, break LOCA analyses. Provided that the previously existing model results were demonstrated to be conservative with respect to the new small break LOCA model approved under the requirements of NUREG-0737 II.K.3.30 (NOTRUMP),

plant specific analyses using the new small break LOCA Evaluation Model would not be required. In WCAP-11145 (Reference 11),

Westinghouse and the Westinghouse Owners Group demonstrated that the result's obtained from calculations with WFLASH were conservative relative to those obtained. with NOTRUMP. Compliance with Item II.K.3.31 of NUREG-0737 could be completed by referencing WCAP-11145 and supplying some plant specific information.

Westinghouse, therefore, has not been modifying, investigating, or evaluating proposed changes to the WFLASH .small break LOCA ECCS Evaluation Model.

As discussed above, none of the modifications to the Westinghouse small break LOCA ECCS Evaluation Model would affect the small break LOCA analysis results by altering the PCT.

A. Analysis Calculated Result 1092'F B. Modifications to Westinghouse ECCS Evaluation Model + 0oF C. ECCS Evaluation Model Modifications Resultant PCT 1092'F CONCLUSION An evaluation of the effect of modifications to the Westinghouse ECCS Evaluation Model as reported in References 2 and 3 was performed for both the large break LOCA and small break LOCA analyses results found in WCAP-11609 and Chapter 15.6.4 of the R.E.

Ginna Nuclear Power Plant Updated Final Safety Analysis Report.

The LOCA safety analyses reported in the UFSAR were performed for Ginna with a uniform Steam Generator Tube Plugging (SGTP) level of 12-o. The large break LOCA analysis was subsequently reanalyzed and licensed for an increase to 15: tube plugging. The small break LOCA analysis was evaluated and was not impacted by the increase

in SGTP level to . The results of the ana es and evaluations for the increase in. SGTP level to 15-o were documented in WCAP-11609, "Steam Generator Tube Plugging (SGTP) Report for Ginna.

Nuclear Power Station".

When the effects of the ECCS model changes were combined with the current plant analysis results, it was determined that compliance with the requirements of 10CFR50.46 would be maintained.

REFERENCES "Emergency Core Cooling Systems; Revisions to Acceptance Criteria", Federal Register, Vol. 53, No. 180, pp. 35996-36005, dated September, 16, 1988.

2. NS-NRC-89-3463, "10CFR50.46 Annual Notification for 1989 of Modifications in the Westinghouse ECCS Evaluation Models,"

Letter from W.J. Johnson (Westinghouse) to T.E. Murley (NRC),

dated. October 5, 1989.

3. NS-NRC-89-3464, "Correction of Errors.and Modifications to the NOTRUMP Code in the Westinghouse Small Break LOCA ECCS Evaluation Model Which Are Potentially Significant", Letter from W.J. Johnson (Westinghouse) to T.E. Murley (NRC), dated October 5, 1989.
4. WCAP-9220-P-A, Revision 1 (Proprietary), WCAP-9221-A, Revision 1 (Non-Proprietary), "Westinghouse ECCS Evaluation Model 1981 Version", 1981, Eicheldinger, C.
5. WCAP-10924-P-A (Proprietary), WCAP-12130-A (Non-Proprietary),

"Westinghouse Large Break LOCA Best Estimate Methodology",

Hochreiter, L.E., et.al., January 1987.

6. Report on Small Break Accidents for Westinghouse Nuclear Steam Supply System", WCAP-9601 (Non-Proprietary), June 1979, WCAP-9600 (Proprietary), June 1979.
7. "Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in Westinghouse Designed Operating Plants", NUREG-0611, January 1980.
8. "Clarification of TMI Action Plan Requirements", NUREG-0737, November 1980.
9. "Clarification of TMI Plan Item II.K.3.31, "NRC Generic Letter 83-85 from D.G. Eisenhut, November 2, 1983.
10. "NOTRUMP - A Nodal Transient Small Break and General Network Code", WCAP-10079-P-A (Proprietary), WCAP-10081-A (Non-

'Proprietary), Lee, N., et. al., August 1985.

"Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code", WCAP-10054-P-A (Proprietary), WCAP-10081-A (Non-Proprietary), Lee, N., et. al., August 1985.

12. WCAP-8970 (Proprietary) and WCAP-8971 (Non-Proprietary),

"Westinghouse Emergency Core Cooling System Small Break October 1975 Model", April 1977.