ML041610356

R. E. Ginna Nuclear Power Plant, RAI, Control Room Emergency Air Treatment System Modification

ML041610356
Person / Time
Site:	Ginna
Issue date:	06/09/2004
From:	Clark R NRC/NRR/DLPM/LPD1
To:	Mecredy R Rochester Gas & Electric Corp
Clark R, NRR/DLPM, 415-2297
References
TAC MB9123
Download: ML041610356 (6)

Text

June 9, 2004 Dr. Robert C. Mecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING R. E. GINNA NUCLEAR POWER PLANT LICENSE AMENDMENT REQUEST RELATING TO THE CONTROL ROOM EMERGENCY AIR TREATMENT SYSTEM MODIFICATION (TAC NO. MB9123)

Dear Dr. Mecredy:

By letter dated May 21, 2003, as supplemented on December 1, 2003, (two letters), February 16, 2004, March 1, 2004, March 8, 2004, Rochester Gas & Electric Corporation submitted a request to revise the Ginna Station Improved Technical Specifications to reflect design modifications to the Control Room Emergency Air Treatment System, and elimination of the requirements for the Containment Post Accident Charcoal Filters. The proposed design modifications are based on the use of the alternate source term.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information and based on our review, we have determined that additional information is required in order for the staff to complete its review. Enclosed is the NRC staffs request for additional information (RAI). This RAI was discussed with your staff on May 20, 2004, and it was agreed that your response would be provided 30 days from the date of this letter.

Sincerely,

/RA/

Robert Clark, Project Manager, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosure:

RAI cc w/encl: See next page

June 9, 2004 Dr. Robert C. Mecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING R. E. GINNA NUCLEAR POWER PLANT LICENSE AMENDMENT REQUEST RELATING TO THE CONTROL ROOM EMERGENCY AIR TREATMENT SYSTEM MODIFICATION (TAC NO. MB9123)

Dear Dr. Mecredy:

By letter dated May 21, 2003, as supplemented on December 1, 2003, (two letters), February 16, 2004, March 1, 2004, March 8, 2004, Rochester Gas & Electric Corporation submitted a request to revise the Ginna Station Improved Technical Specifications to reflect design modifications to the Control Room Emergency Air Treatment System, and elimination of the requirements for the Containment Post Accident Charcoal Filters. The proposed design modifications are based on the use of the alternate source term.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information and based on our review, we have determined that additional information is required in order for the staff to complete its review. Enclosed is the NRC staffs request for additional information (RAI). This RAI was discussed with your staff on May 20, 2004, and it was agreed that your response would be provided 30 days from the date of this letter.

Sincerely,

/RA/

Robert Clark, Project Manager, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosure:

RAI cc w/encl: See next page DISTRIBUTION:

PUBLIC PDI-1 R/F RLaufer SLittle RClark ACRS OGC JLee BHarvey RDennig CBixler, R1 Accession Number: ML041610356 OFFICE PDI-1/PM SPSB-C SC PDI-1/SC NAME RClark RDennig TColburn for RLaufer DATE 6/9/04 6/9/04 6/9/04 OFFICIAL RECORD COPY

R.E. Ginna Nuclear Power Plant cc:

Kenneth Kolaczyk, Sr. Resident Inspector Mr. Paul Eddy R.E. Ginna Plant New York State Department of U.S. Nuclear Regulatory Commission Public Service 1503 Lake Road 3 Empire State Plaza, 10th Floor Ontario, NY 14519 Albany, NY 12223 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Peter R. Smith, Acting President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Daniel F. Stenger Ballard Spahr Andrews & Ingersoll, LLP 601 13th Street, N.W., Suite 1000 South Washington, DC 20005 Ms. Thelma Wideman, Director Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31 Lyons, NY 14489 Ms. Mary Louise Meisenzahl Administrator, Monroe County Office of Emergency Preparedness 1190 Scottsville Road, Suite 200 Rochester, NY 14624

REQUEST FOR ADDITIONAL INFORMATION R. E. GINNA NUCLEAR POWER PLANT CONTROL ROOM EMERGENCY AIR TREATMENT SYSTEM Rochester Gas & Electric Corporations proposed design modifications to the Control Room Emergency Air Treatment System, the Control Room Emergency Cooling System, and the Containment Post Accident Charcoal Filters are based on the full scope implementation of the alternate source term. The Nuclear Regulatory Commission staff has determined that the following additional information is needed to complete its review.

Meteorological Data

1. There are apparently a number of day-of-the-year and hour-of-the-day labeling discrepancies in the ARCON96 1999-2003 hourly meteorological data set. Examples of these day and hour labeling discrepancies for the year 1999 are provided in Table 1.

Similar abnormalities exist for each of the other years in the data set. A precursory review of the data base also indicates that the data capture rate for each year is less than 100% (e.g., there are less than 8,760 hourly values for each year); yet, there are no hours in the data set that have been identified as having invalid data.

The day and hour labeling discrepancies should not have an impact on the ARCON96 results. However, in order to properly implement ARCON96's intended technical approach, the ARCON96 meteorological data input file should have one record for every hour in the year, even for those hours where there are no valid data. As explained in Subsection 3.8 of Revision 1 to NUREG/CR-6331, Atmospheric Relative Concentrations in Building Wakes, ARCON96 uses time series of hourly meteorological data to properly account for the effects on wind direction persistence in reducing average relative concentrations for periods longer than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in duration. Missing data are treated by deleting hours with missing data from the calculation of the average relative concentrations used in determining the cumulative frequency distributions.

Missing data tolerance criteria are used to determine when the number of hours of missing data make a specific average relative concentration unacceptable. The criterion for averaging 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less is zero missing data; for longer duration averages, up to 10% missing data is acceptable. Averages are not calculated for periods in which the number of hours of missing data exceed tolerance criteria.

2. There are nearly 700 consecutive hours in the 2003 data base (from day 197, hour 11 through day 227, hour 08) where nearly all of the lower level wind direction values are reported as 002." Likewise, there are 144 consecutive hours in the 2002 data base (from day 253, hour 08 through day 259, hour 07) where nearly all of the lower level wind direction values are also reported as 002." These are most likely invalid data values which should be reset to 999."

Enclosure

Control Room Atmospheric Dispersion Factors

3. There are apparently three ARCON96 files (CASE1A.log, CASE2A.log, and CASE2TA.log) related to determining control room CHI/Q values for a containment leakage release. Which one of these three runs is being considered for use in the dose assessment analyses and why?

4. There are apparently two ARCON96 files (CASE4A.log and CASE4TA.log) related to determining control room CHI/Q values for atmospheric relief valve releases. Which one of these two runs is being considered for use in the dose assessment analyses and why?

5. There are apparently two ARCON96 files (CASE5A.log and CASE6A.log) related to determining control room CHI/Q values for plant releases. Which one of these two runs is being considered for use in the dose assessment analyses and why?

6. There are apparently five ARCON96 files (Case7.log, Case7a.log, Case7b.log, Case7cc.log, and Case7dd.log) related to determining control room CHI/Q values for auxiliary building leakage releases. Which one of these five runs is being considered for use in the dose assessment analyses and why? Please also justify using the containment building area (1071 m2) as the basis for determining wake diffusion for this release point.

Site Boundary Atmospheric Dispersion Factors

7. Is it still your intent to use the current CHI/Q values presented in the Ginna Updated Final Safety Analysis Report for all the exclusion area boundary and low population zone dose calculations, except for the tornado missile and locked rotor accidents?

TABLE 1 Day-of-the-year and Hour-of-the-day Labeling Discrepancies For 1999 Range of Data Labels Missing Data Labels Repeated Data Labels Date of First Date of Last Date of First Date of Last Date of First Date of Last Data Record Data Record Data Record Data Record Data Record Data Record Day Hour Day Hour Day Hour Day Hour Day Hour Day Hour 001 00 353 23 008 10 008 10 031 00 031 23 056 01 056 04 058 00 058 23 069 22 070 07 087 00 087 23 072 15 072 15 116 00 116 23 075 07 075 08 146 00 146 23 088 07 088 08 175 00 175 23 090 02 090 02 205 00 205 23 090 06 091 06 235 00 235 23 092 19 092 19 264 00 264 23 093 11 093 13 294 07 294 09 153 08 154 15 323 00 323 23 267 04 267 04 295 12 295 12 317 18 317 18 323 10 323 12 327 05 327 06 329 12 329 12 329 16 329 16 343 23 344 06 345 02 345 06 345 08 345 13