BSEP 04-0024, Response to Request for Additional Information Regarding the Updated Final Safety Analysis Report Section 9.4.5, Turbine Building Ventilation System
| ML040430052 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/05/2004 |
| From: | Gannon C Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BSEP 04-0024, TSC-2003-02 | |
| Download: ML040430052 (6) | |
Text
Progress Energy FEB 0 5 2004 Cornelius J. Gannon Vice President Brunswick Nuclear Plant Progress Energy Carolinas, Inc.
SERIAL: BSEP 04-0024 TSC-2003-02 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Response to Request for Additional Information Updated Final Safety Analysis Report Section 9.4.5 Turbine Building Ventilation System
Reference:
Letter from John S. Keenan to the U. S. Nuclear Regulatory Commission (Serial: BSEP 03-0115), "Request for License Amendment - Updated Final Safety Analysis Report Section 9.4.5, Turbine Building Ventilation System,"
dated July 31, 2003 Ladies and Gentlemen:
On July 31, 2003, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC) requested a license amendment to revise the Updated Final Safety Analysis Report, Section 9.4.5, "Turbine Building Ventilation System," and supporting information in Section 6.4.4.1, "Radiological Protection," and Section 15.6.3, "Main Steam Line Break Accident," to allow the system to be operated in a once-through versus recirculation configuration in support of outage activities. On February 2, 2004, the NRC provided an electronic request for additional information (RAI) concerning this request. The response to this RAI is enclosed.
Please refer any questions regarding this submittal to Mr. Edward T. O'Neil, Manager - Support Services, at (910) 457-3512.
J. Gannon P.O.
Box 10429 Southport, NC 28461 r-o D I T> 910.457.3698 F> 910.457.2803
Document Control Desk BSEP 04-0024 / Page 2 MAT/mat
Enclosure:
Response to Request for Additional Information Cornelius J. Gannon, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, and agents of Carolina Power & Light Company.
YrMu 4 S. A Notary (Seal)
My commission expires: G-uc
, 2004 I %v.
Document Control Desk BSEP 04-0024 / Page 3 cc:
U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)
ATTN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission (Electronic Copy Only)
ATTN: Ms. Margaret H. Chernoff (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221
BSEP 04-0024 Enclosure Page 1 of 3 Response to Request for Additional Information
Background
On July 31, 2003, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC) requested a license amendment to revise the Updated Final Safety Analysis Report (UFSAR), Section 9.4.5, "Turbine Building Ventilation System," and supporting information in Section 6.4.4.1, "Radiological Protection," and Section 15.6.3, "Main Steam Line Break Accident," to allow the system to be operated in a once-through versus recirculation configuration in support of outage activities. On February 2, 2004, the NRC provided an electronic request for additional information (RAI) concerning this request. The response to this RAI follows.
NRC Question 1 The submittal states that a temporary radiation monitor will be used to monitor site releases.
10 CFR 50.36a (a) 2 requires, in part, that licensees submit a report annually that specifies the quantity of each of the principal radionuclides released to unrestricted areas in gaseous effluents.
Please explain how the total dose released to the environment through the once through path will be estimated. Describe whether timed grab samples will be taken. Please describe the records that will be kept of the activity in the release and the estimated quantity of the release.
Response to NRC Question 1 The temporary system will be sampled continuously for particulate, iodine, and noble gas, in accordance with Section 7.3.7, "Dose Rate - Gaseous Effleuents," Table 7.3.7-1, "Radioactive Gaseous Waste Sampling and Analysis Program," of the site's Offiste Dose Calculation Manual (ODCM). In accordance with the Section 3.2 of the ODCM, "Compliance with 10CFR20 (Gaseous), Particulates, and Tritium," the sample results and release volume will be summarized with the corresponding turbine building discharge as a ground level release. The subsequent dose will be calculated based on this source term and reported in the annual Radioactive Effluent Release Report, as required by Technical Specification 5.6.3. Weekly gas reports are performed to assist in tracking the effluent releases at the Brunswick Steam Electric Plant (BSEP) and then summarized monthly in accordance with the Section 3.3 of the ODCM, "Compliance with 10CFR50 (Gaseous)." Isotopic reports, sampling attachments, and gas reports are vaulted following appropriate review. Additionally, the particulate filters from this temporary release path are composited for gross alpha and Sr-89 and Sr-90 analysis. No timed grab sample, beside routine weekly filter changes, will be incorporated since the pathway would be secured immediately, in accordance with operating procedures, in the event of an accident. A description of the temporary modification will also be included in the aforementioned annual report under the section for major modifications to the radioactive waste treatment system.
BSEP 04-0024 Enclosure Page 2 of 3 NRC Ouestion 2 Section 11.5.2.6 of the Updated Final Safety Analysis Report describes the Turbine Building Ventilation Radiation Monitoring System. This section describes isokinetic sample probes in the effluent air stream of the ventilation exhaust. Please describe how this monitor will be impacted by a change in flow rate through the turbine building vent. Explain whether the total dose will be the sum of the release from the turbine building vent and the release from the new once through vent.
Response to NRC Question 2 The temporary radiation monitor will be sampling via an isokinetic probe installed in the effluent pathway. The turbine building, with the once-through system in service, will have two distinct release paths. Neither path would be impacted from the flow rate in the other. Additionally, each point is monitored for release volume in accordance with the Section 7.3.2 of the ODCM, "Radioactive Gaseous Monitoring Instrumentation," and the total dose will be summarized as releases from the turbine building.
NRC Question 3 The submittal states that the feasibility of implementing a permanent modification to operate the Turbine Building Ventilation System in a once-through configuration is being evaluated. Please describe how the stated objective of the turbine building ventilation radiation monitoring system (to provide a clear indication to operations personnel whenever abnormal amounts of radioactivity exist in the Turbine Building ventilation exhaust) would be achieved if the modification were made permanent. Please include a discussion of the method of compliance with 10 CFR 50.36a (a)(2). Please include in your discussion the plans with respect to permanence of the effluent radiation monitors, the ability for control room annunciation, and total dose release measuring capability.
Response to NRC Question 3 PEC has not currently decided whether a permanent modification to operate the Turbine Building Ventilation System in a once-through configuration will be pursued. However, if a permanent modification is pursued; it would require modifying the Turbine Building Ventilation System to include a once-through release point. An additional probe would be installed to monitor this release path. This probe would be tied into the existing turbine building monitoring system. If effluent activity levels were to rise to unacceptable levels, the once-through release point would be isolated and the Turbine Building Ventilation System would be aligned in the recirculation mode for a filtered and monitored release via the currently existing release path/monitor configuration. The final design of the permanent modification, if pursued, would comply with the UFSAR description of the existing radiation monitors which include control room annunciation and dose release measuring capability from either release point in each operating unit. A revision to the BSEP ODCM would be implemented to add the release point
BSEP 04-0024 Enclosure Page 3 of 3 for the once-through configuration in each operating unit. This would assure compliance with 10 CFR 50.36a (a)(2).