ML061450381
| ML061450381 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/19/2006 |
| From: | Holm D Constellation Energy Group, Constellation Generation Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 1001568 | |
| Download: ML061450381 (30) | |
Text
Dave Holm R.E. Ginna Nuclear Power Plant, LLC Plant General Manager 1503 Lake Road Ontario, New York 14519-9364 585.771.3635
- Dave.A.Holm @constellation.com Constellation EnergyT Generation Group May 19, 2006 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTION: Document Control Desk
SUBJECT:
R.E. Ginna Nuclear Power Plant Docket No. 50-244 Final Response to Requests for Additional Information Re-gardinq Topics Discussed on Conference Calls for Extended Power Uprate (EPU)
By letter dated July 7, 2005, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted an application associated with a request for authorization to increase the maximum steady-state thermal power level at the R.E. Ginna Nuclear Power Plant from 1520 megawatts thermal (MWt) to 1775 MWt. On February 23, 2006, the NRC staff engaged the Ginna Extended Power Uprate Project Team in discussions involving the Extended Power Uprate (EPU) Licensing Submittal.
By letter dated May 9, 2006, Ginna LLC provided the non-proprietary responses to the NRC staff questions. The purpose of this letter is to provide formal documentation of the completion of the responses to the verbal requests for additional information (RAI).
Please note that some information contained within this submittal is considered Proprietary to our design vendor Westinghouse. Accordingly, two versions of our response to the RAI have been prepared.
Attachment I contains the "Application for Withholding Proprietary Information from Public Disclosure". As Attachment 2 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4)of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information Which is proprietary to Westinghouse be withheld from public disclosure in accordance withi 0 CFR Section 2.390 of the Commission's regulations. Correspondence with respect tA the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-05-2077 and should be addressed to B.F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
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Attachment 2 contains a proprietary version of the NRC's questions and Ginna LLC's response.
Attachment 3 contains a non-proprietary version of the NRC's questions and Ginna LLC's response.
In addition to the information requested, Attachment 4 contains errata pages. This page describes typographical errors in our original submittal identified during the preparation of these responses.
The responses do not include any new regulatory commitments.
If you have any questions, please contact Robert Randall at (585) 771-3734 or robert.randall @constellation.com.
Very t rulyyrs, DvA.Holm STATE OF NEW YORK TO WIT:
COUNTY OF WAYNE I, Dave A. Holm, being duly sworn, state that I am Plant General Manager - R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this response on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
Subscribed and sworn before me, a Notary Public and for the State of New York and County of .0-On kO-JI* ,Jthis.J! day of -vmdJ I ,2006.
WITNESS my Hand and Notarial Seal: /&hO -
- k _.,*{
Notary Public My Commission Expires: WHARONLMILLER NIqvw-8tab,ofNewYotk Wm96imf Expk OesMbRW212.6 (40
Attachments:
(1) Application for Withholding Proprietary Information from Public Disclosure (2) Proprietary Response to NRC Request for Additional Information on the R.E.Ginna Extended Power Uprating (3) Non-Proprietary Response to NRC Request for Additional Information on the R.E.Ginna Extended Power Uprating (4) Errata cc: S. J. Collins, NRC J. P. Spath, NYSERDA P.D. Milano, NRC P.D. Eddy, NYSDPS Resident Inspector, NRC (Ginna)
Attachment 1 Application for Withholding Proprietary Information from Public Disclosure
Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4419 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: maurerbf@westinghouse.com Our ref. CAW-06-2138 May 10, 2006 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
RGE-06-17 P-Attachment, "Response to NRC Request for Additional Information on the R. E. Ginna Extended Power Uprating," dated May 10, 2006 (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is
-further identified in Affidavit CAW-06-2138 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Constellation Energy.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-06-2138 and should be addressed to B. F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O.
Box 355, Pittsburgh, Pennsylvania 15230-0355.
Very truly yours, B rer, Acting Manager Regulatory Compliance and Plant Licensing Enclosures A BNFL Group company
CAW-06-2138 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared B. F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this .. *.... day of 1 ,2006 Notary Public Notai!Seal Shamn L Rod, Notary Public Monroevdlle Boro, Allegheny County My Commission EBores January 29,2007 emnber, Pennsylvania Association Of Notaries
2 CAW-06-2138 (1) I am Acting Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse "Application for Withholding" accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.
The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's
3 CAW-06-2138 competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f) It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
4 CAW-06-2138 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in the attachment to letter RGE-06-17 (P-Attachment) "Response to NRC Request for Additional Information on the R. E. Ginna Extended Power Uprating," dated May 10, 2006 (Proprietary) for submittal to the Commission, being transmitted by Constellation Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with Constellation Energy's request for NRC approval of the R. E. Ginna Extended Power Uprating.
This information is part of that which will enable Constellation Energy to:
(a) Obtain NRC approval of the Extended Power Uprating (EPU).
(b) Respond to an NRC Request for Additional Information in support of the EPU.
5 CAW-06-2138 Further this information has substantial commercial value as follows:
(a) Westinghouse plans to sell the use of this information to its customers for purposes of licensing upratings.
(b) Westinghouse can sell support and defense of the use of this model for licensing purposes.
(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar calculations and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
Attachment 3 Non-Proprietary Response NRC Request for Additional Information on the R.E.Ginna Extended Power Uprating
Westinghouse Non-Proprietary Class 3 RGE-06-17 NP-Attachment R.E. GINNA NUCLEAR POWER PLANT EXTENDED POWER UPRATE PROGRAM RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ON THE R. E. GINNA EXTENDED POWER UPRATING May 10, 2006 Westinghouse Electric Company LLC P.O. Box 355 Pittsburgh, PA 15230-0355
© 2005 Westinghouse Electric Company LLC All Rights Reserved
- 3) Following an SBLOCA, the switch to recirculationneeds to be performed. For those breaks where RCS pressure remains above the shutoff head of the LPI pump, a switch to recirculationresults in a termination of HPSI for 10 -15 minutes, when the alignment is performed. At the request of the staff, analyses submitted by the licensee showed that for a range of small breaks, this interruptionin ECC injection demonstratedthat no core uncovery occurredfor a range of small breaks where RCS pressure remainedabove 140 psia. The staff notes that the analysis consideredonly breaks on the bottom of the dischargeleg. Because of the unique ECC design for Ginna, the staff requests that licensee considerbreaks on the side and top of the discharge leg. With the break on the side or top of the dischargeleg, the loop seal region (suction leg piping) will contain large amounts of liquid, which will increase the loop pressure drop following an SBLOGA. This condition is expected to occur late following an SBLOCA when the recirculationalignment would be expected to be performed. With the break on the bottom of the dischargeleg, recovery of the core duringthe long term shows that large amounts of liquid are containedin the upperplenum and hot leg regions late following an SBLOCA. As such, an interruptionin the injection would not boil-off the largeamounts of liquid present in the system for this break location to cause the core to uncover again. ff the break is on the side or top of the discharge leg, water trappedin the loop seals create a largersteam pressure in the upperplenum (to drive the core decay steaming rate through the loop) depressing the two-phase level to nearthe top of the core. The core is expected to remain covered in this condition;however, less liquid is presentabove the core. The concern is that an interruptionin ECC flow could cause the core to re-uncover and heat-up, since the lesser liquidinventory above the break may not be sufficient during the ECC interruptionto preclude heat-up and excessive clad temperatures during the re-alignment. The licensee needs to perform an analysis of breaks on the top and side of the discharge leg to show that core uncovery and excessive temperaturesdo not occur for these particularbreak locations. This issue surfaces during the EPU review because the Ginna NSSS has loop seas (suction leg piping) with a bottom elevation that is well below the top elevation of the core.
Response; Ginna LLC is confident that the time to align high head recirculation in a small break LOCA scenario is less than 10 minutes. The alignment evolution would likely occur more than one hour into the event.
This would provide operators time to prepare for and brief the evolution. Training has and will continue to emphasize the need to minimize the time when injection is secured. The alignment evolution involves three sets of valves (RWST outlet valves, SI pump recirculation valves and RHR to SI pump suction valves), all operated remotely from the control room. Each set of valves takes less than one minute to operate. After the valves are repositioned, an SI pump is started. A realistic estimate for the time to accomplish the alignment evolution is less than five minutes. The ten minute time frame assumed in the analysis is bounding for the expected duration, with margin.
In general, all Westinghouse plant designs are of the same loop seal configuration. As such, the only significant differences in the designs which would affect loop seal plugging are Safety injection (SI) configurations and whether or not the Reactor Coolant Pumps (RCPs) have either a weir on the discharge side or contain a diffuser cone (inherent weir design). The Low Head Safety Injection (LHSI) configuration for R. E. Ginna, as well as all 2-loop Westinghouse designs, is such that it injects into the Upper Plenum (otherwise known as UPI). As such, once the Reactor Coolant System (RCS) pressure drops below the LHSI cut-in pressure for this class of plant, concerns with loop seal re-plugging are essentially eliminated. The Reactor Coolant Pump (RCP) in the R. E. Ginna plant contains a diffuser cone which acts as an inherent cold leg weir. The effective weir height modeled in Page 2 of 11
NOTRUMP is [ ]ac when compared to the cold leg piping diameter of 2.29167 ft (27.5 inch I.D.). Note that the actual top of the diffuser is above the top of the cold leg elevation. This feature can not be modeled in this fashion in the NOTRUMP code without re-nodalization. Therefore, in order to have backflow into the RCP Pump Suction Piping (PSP), the break must be oriented at or above the effective weir height. Thus, the Reactor Coolant System (RCS) has to have significantly refilled following the Loss of Coolant Accident (LOCA) event in order for this to occur. Because of this, downcomer level and the associated driving head, is increased which reduces the core uncovery potential.
In order to illustrate the effects of break orientation with the NOTRUMP Evaluation Model (EM),
several demonstration cases were performed. The limiting PCT transient for R. E. Ginna EPU analysis, 2-Inch Cold Leg Break, was re-performed with [ ]ac of the RCS cold leg. [ ]a'C were performed to encompass the SI interruption effect. These being assuming Containment Spray (CS) actuation at T=0.0 seconds and CS actuation at T=650.0 seconds. The CS on at T=650.0 second case represents the same time at which the limiting I Iax break [ ]ac CS system was actuated. The CS on at T=0.0 second case represents the earliest time at which the SI interruption can occur for this break configuration/size due to RWST drainage. Comparison plots between the results obtained with the traditional [
].C and that of the [ ]ax with CS on at T=650 seconds can be observed in Figure 3-1 through Figure 3-3. Subsequent comparison plots between the results obtained with the traditional [ ]~c with CS on at T=650 seconds and that of the [
Iac with CS on at T=0.0 seconds can be observed in Figure 3-4 through Figure 3-6. As can be seen, the response observed is as previously described in the NOTRUMP documentation, most notably Reference 3-1 which states that the
]a,c The general phenomena associated with the initial loop seal clearing is unaffected by the break location in the NOTRUMP EM. Since the NOTRUMP EM is comprised of a series of stratified fluid nodes with inter-connecting flow links, the initial loop seal clearing process is controlled by the formation of a stratified level in the broken RCS cold leg. The NOTRUMP code does not allow the formation of a stratified level until the region reaches saturation conditions. As such, even if vapor is flowing through the RCP suction cross-over loop seal piping, it can not readily vent out the break and allow for pressure equalization between the vessel downcomer and core/upper plenum region until stratification occurs in the broken loop cold leg. In other words, the liquid trapped in the RCP suction cross-over leg uphill side must saturate and void before vapor flow can be established through this piping. Physical mechanisms such as entrainment and evaporation can also play a role in this.
Obviously the larger the break size, the more significant these mechanisms become. Another possible method of core/upper plenum pressure equalization with the downcomer is via the stratification of the RCS downcomer region through the upper head spray nozzle flow path. The upper head cooling spray nozzles are a design bypass flow path between the vessel downcomer and upper head fluid region. Vapor venting through this flow path typically occurs following the drainage of the upper head region. While this flow path may not be sufficient by itself to relieve core steam generation, it does provide a means of relieving some of the core steam back-pressure once the head has drained. Depending on the break location, orientation and transient time, this may result in a fraction of the core steam being bypassed to the break.
Small breaks may indeed undergo brief periods of uncovery as a result of loop seal re-plugging due to RCS system refill; however, this is highly dependent on the break orientation assumed as well as Page 3 of 11
ECCS performance characteristics utilized in the analysis. For a typical NOTRUMP EM Appendix-K analysis with the [ ],ac of the RCS cold leg, ECCS backflow into the loop seal piping can not occur until a significant refill of the RCS occurs due to the nature of the critical flow models utilized to simulate the break and the SI flow capacities modeled. Therefore, essentially all ECCS flow introduced to the broken loop RCS piping is discharged out the break. As such, backflow due to broken loop ECCS injection can only be expected to occur for breaks oriented at locations other than the [ ]a,¢. As stated previously, the ability to backflow liquid into the PSP is also affected by the existence of an RCP weir or diffuser cone. Depending on the effective height of the weir, the conditions under which SI water backflow into the PSP can occur are limited further. As seen in the figures associated with the [ ]a,c, loop seal re-plugging was indeed observed (Figure 3-3 and Figure 3-6) although the predicted uncovery associated with this type of phenomena was tenuous (Figure 3-2 and Figure 3-5) and the core exit vapor temperatures observed were much less severe than predicted with a [ ],C (Figure 3-1 and Figure 3-4). In fact, the predicted core exit vapor temperatures remained at saturation conditions for the duration of the transient simulated for both [ Iax regardless of the assumed SI interruption. The time at which this loop seal plugging/clearing behavior occurs is after 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, although not modeled, operator action to cooldown and depressurize the plant will be occurring in this time frame. This action will minimize this observed behavior.
As a result of a teleconference between Ginna LLC, Westinghouse and the NRC, additional [
]',c studies were performed for the 4-inch Cold Leg Break. Recall that for the base I
],a, no significant cladding heat-up was observed (non-limiting break size); however, this break size was that at which the NRC was indicating potential concern.
Note that the break modeling technique utilized has an effect on the potential for loop seal re-plugging. The application of liquid pull-through models and break contact diameter affect the ability of the RCS cold leg mixture level to increase to a point which can allow ECCS backflow into the RCP PSP region. Modeling the break at the [ Ic, without the application of liquid pull-through models, results in the most severe prediction of ECCS backflow into the RCP PSP region with the NOTRUMP nodalization utilized. Recall that the RGE RCP has a diffuser cone which acts as a large inherent cold leg weir making ECCS backflow into the RCP PSP region difficult to achieve.
As seen in the comparison figures provided between the [ ]',c for the 4-inch Cold Leg Break, periods of loop seal re-plugging were observed (Figure 3-11) for the [
]a,cx No sustained core uncovery or cladding heat-up was observed for the simulation period modeled (2.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) (Figure 3-7 and Figure 3-8). This is consistent with tests performed at the ROSA facility under similar conditions. It should be noted that the NOTRUMP model predicts that the RCS would depressurize to below the LHSI cut-in pressure prior to RWST switchover for the [
]a,c (Figure 3-10). As such, no interruption of safety injection would be predicted for this case; however, for matter of proof, the LHSI system was not modeled in these transient simulations. As a result, the injection gap can be clearly seen in the downcomer mixture level response (Figure 3-9).
The conclusion which can be reached, as a result of the simulations performed with the NOTRUMP EM, is that the [ ]axc is not limiting in terms of predicted Peak Cladding Temperature (PCT). In addition, loop seal re-plugging as a result of ECCS backflow into the RCP PSP region does not result in sustained core uncovery periods, as a result of loop seal re-plugging, and does not constitute a significant safety concern.
Page 4 of 11
References 3-1 WCAP-1 0054-P-A Addendum 2 Revision 1, "Addendum to the Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code: Safety Injection into the Broken Loop and COSI Condensation Model," July 1997.
Page 5 of 11
a,c Figure 3-1 R.E. Ginna 2-Inch Break, Core Exit Vapor Temperature Comparison a,c Figure 3-22-Inch Break, Core Mixture Level Comparison Page 6 of 11
ac Figure 3-3 R.E. Ginna 2-Inch Break, Broken Loop Seal Vapor Flow Comparison a,c Figure 3-4R.E. Ginna 2-Inch Break, Core Exit Vapor Temperature Comparison Page 7 of 11
a,c Figure 3-5R.E. Ginna 2-Inch Break, Core Mixture Level Comparison a,c Figure 3-6R.E. Ginna 2-Inch Break, Broken Loop Seal Vapor Flow Comparison Page 8 of 11
a,c Figure 3-7 R.E. Ginna 4-Inch Break, Core Exit Vapor Temperature Comparison a,c Figure 3-8R.E. Ginna 4-Inch Break, Core Mixture Level Comparison Page 9 of 11
ac Figure 3-9 R.E. Ginna 4-Inch Break, Downcomer Mixture Level Comparison a,c Figure 3-10 R.E. Ginna 4-Inch Break, RCS Pressure Comparison Page 10 of 11
a,c Figure 3-11 R.E. Ginna 4-Inch Break, RCP Liquid Discharge Flow Comparison Page 11 of 11 Errata
Attachment 4 Response to Letter Dated May 11, 2006 R.E.Ginna EPU Request for Additional Information Response on SBLOCA NON-PROPRIETARY Errata The following typographical errors were discovered in Table 2.8.5.4.2-1: Time Sequence of Events-Uncontrolled RCCA Bank Withdrawal at Power, of the EPU Licensing Report.
- The Case column stating '100% Power, Maximum Feedback, Rapid RCCA Withdrawal (100 pcm/sec)' should instead state '100% Power, Minimum Feedback, Rapid RCCA Withdrawal (100 pcm/sec)'.
- The Case column stating '100% Power, Minimum Feedback, Slow RCCA Withdrawal (5 pcm/sec)' should instead state '100% Power, Maximum Feedback, Slow RCCA Withdrawal (5 pcnmsec)'.
- The Event column stating 'Power Range High Neutron Flux - High Setpoint Reached' should state 'OT AT Setpoint Reached'
- The Time (sec) column value of 3.6 should be 1.2
- The Time (sec) column value of 4.1 should be 1.7
- The Time (sec) column value of 4.3 should be 2.3
- The Time (sec) column value of 26.6 should be 213.9
- The Time (sec) column value of 27.1 should be 215.9
- The Time (sec) column value of 27.5 should be >215.9 In addition, please note typo corrections to the Licensing Report for Section 2.8.5.4.2 Uncontrolled Control Rod Assembly Withdrawal at Power.
- Section 2.8.5.4.2.3 Results. In the second paragraph, the word 'minimum' should be
'maximum' (...from 100% power with, maxi-nnumfeedback is shown in Figures -t Deleted:
e... minimum 2.8.5.4.2-4...)
- Label for Figure 2.8.5.4.2-4 the word Minimum should be changed to Maximum.
- Label for Figure 2.8.5.4.2-5 the word Minimum should be changed to Maximum.
- Label for Figure 2.8.5.4.2-6 the word Minimum should be changed to Maximum.
pressurizer, pressurizer relief and safety valves, pressurizer spray, steam generators, and main steam safety valves (MSSVs). The program computed pertinent plant variables including temperatures, pressures, power level, and DNBR.
Evaluation of Impact on Renewed Plant Operating License Evaluations and License Renewal Programs Components of the reactivity control and protection systems that are within the scope of License Renewal are electrical and instrumentation and control components that are treated as commodity groups in NUREG-1786. Aging effects, and the programs used to manage the aging effects of these components are discussed in NUREG-1 786, section 3.6. There are no modifications or additions to system components as the result of EPU that would introduce any new functions or change the functions of existing components that would affect the license renewal system evaluation boundaries. Operation of the reactivity control and protection systems at EPU conditions does not add any new types of materials or previously unevaluated materials to the system. System component internal and external environments remain within the parameters previously evaluated.
Thus, no new aging effects requiring management are identified.
2.8.5.4.2.3 Results DNB Case Figures 2.8.5.4.2-1 through 2.8.5.4.2-3 show the transient response for a rapid uncontrolled RCCA bank withdrawal incident (100 pcm/sec) starting from 100%
power with minimum feedback. Reactor trip on high neutron flux occurred shortly after the start of the accident. Because of the rapid reactor trip, small changes in Tvg and pressure resulted in the margin to the DNBR limit being maintained.
The transient response for a slow uncontrolled RCCA bank withdrawal (5 pcm/sec) from 100% power withjaxijmum feedback is shown in Figures 2.8.5.4.2-4 through Deleted: minimum 2.8.5.4.2-6. Reactor trip on overtemperature AT occurred after a longer period of time, and the rise in temperature was consequently larger than for a rapid RCCA bank withdrawal. Again, the minimum DNBR was greater than the safety analysis limit value.
Figure 2.8.5.4.2-7 shows the minimum DNBR as a function of reactivity insertion rate from 100% power for both minimum and maximum reactivity feedback conditions. It can be seen that the high neutron flux and overtemperature AT reactor trip functions provided DNB protection over the range of reactivity insertion rates. The minimum DNBR was never less than the safety analysis limit value.
Ginna Station EPU Licensing Report 2.8.5.4.2-7 May 2006 Uncontrolled Control Rod Assembly Withdrawal at Power
Table 2.8.5.4.2-1 Time Sequence of Events - Uncontrolled RCCA Bank Withdrawal at Power Case Event Time (sec) 100% Power, Minimum Initiation of Uncontrolled RCCA Withdrawal 0.0 IDeleted: Maximum Feedback, Rapid RCCA Power Range High Neutron Flux - High -Deleted: 3.6 Withdrawal (100 pcm/sec) Setpoint Reached .12.
'Deleted:4.1 Rods Begin to Fall .17 .
Deleted: 4 Minimum DNBR Occurs 2.3 100% Power, Maximum.... Initiation of Uncontrolled RCCA Withdrawal 0,0 (Deleted: Minimum Deleted: Power Range High Neutron Feedback, Slow RCCA Flux - High Setpoint Reached Withdrawal (5 pcm/sec) OT AT Setooint Reached 213.9
- Deleted: 26.6 Rods Begin to Fall 215.9 Deleted: 27.1 Minimum DNBR Occurs 21.Q 27.5 .
Initiation of Uncontrolled RCCA Withdrawal 0.0 8% Power, RCS Pressure Case, Minimum High Pressurizer Pressure Setpoint Reached 13.3 Feedback, Limiting RCCA Withdrawal (55 pcm/sec) Rods Begin to Fall 15.3 Maximum RCS Pressure Occurs 16.7 Ginna Station EPU Licensing Report 2.8.5.4.2-10 May 2006 Uncontrolled Control Rod Assembly Withdrawal at Power
1.2 r-0 I-C 0-
.o 0G P
.6 0=
0 .4 0)
.2 0 0 I I I 50, I I 160 I. I. 15' ' '
260 . .
Time (sec) 1.2 I
E 0
C-0
.8 0
.6-
.4-Q.)
0 50 100 150 200 250 Time (sec)
Figure 2.8.5.4.2-4 Rod Withdrawal at Power - DNB Case Maximum Reactivity Feedback - 100% Power" 5.pcmlsec . - -( Deleted: Minimum Nuclear Power and Heat Flux vs. Time Ginna Station EPU Licensing Report 2.8.5.4.2-15 May 2006 Uncontrolled Control Rod Assembly Withdrawal at Power
.40 .
2240 -
- _ 2220 -
- 2200-C,,
L 2180-2160-
- 2140-2120 -
'6o'6o 1' ' 0 Time (sec) 700.
~650 -
~600-
~550-450-kb 260 250 Time (sec)
Figure 2.8.5.4.245 Rod Withdrawal at Power - DNB Case Maximum Reactivity Feedback - 100% Power - 5 pcmlsec , -..-"Deleted: Minimum Pressurizer Pressure and Water Volume vs. Time Ginna Station EPU Licensing Report 2.8.5.4.2-16 May 2006 Uncontrolled Control Rod Assembly Withdrawal at Power
590-1585-03
>580-575 -
570 50 100 10 260 0 lime (sec)
Figure 2.8.5.4.2-6 Rod Withdrawal at Power - DNB Case Deleted: Minimum Maximum Reactivity Feedback - 100% Power -5 pcm/sec I Core Average Temperature and DNBR vs. Time Ginna Station EPU Licensing Report 2.8.5.4.2-17 May 2006 Uncontrolled Control Rod Assembly Withdrawal at Power