JAFP-20-0008, Response to Request for Additional Information Associated with the License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences

Response to Request for Additional Information Associated with the License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences

ML20017A052
Person / Time
Site:	FitzPatrick
Issue date:	01/16/2020
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-20-0008
Download: ML20017A052 (6)

Text

200 Exelon Way Exelon Generation , Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 JAFP-20-0008 January 16, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Response to Request for Additional Information Associated with the License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences

Reference:

1. Letter from D. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences," dated August 8, 2019

2. Letter from D. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Supplemental Information Associated with the License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences," dated August 27, 2019

3. Email from S. Lee (U.S. Nuclear Regulatory Commission) to T. Loomis (Exelon Generation Company, LLC), "FitzPatrick request for additional information: License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences (EPID: L-2019-LLA-0171 and L-2019-LLE-0020)," dated December 19, 2019 In the Reference 1 letter, Exelon Generation Company, LLC (EGC) requested approval for adopting the Alternative Source Term (AST), in accordance with 10 CFR 50.67, for use in calculating the Loss-of-Coolant Accident (LOCA) dose consequences at the James A.

FitzPatrick Nuclear Power Plant (JAFNPP). In the Reference 2 letter, EGC provided supplemental information concerning this request.

In the Reference 3 letter, the U.S. Nuclear Regulatory Commission requested additional information. Attached is the EGC response.

Response to Request for Additional Information Associated with the License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences January 16, 2020 Page 2 EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in the Reference 1 letter. The supplemental information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92. In addition, EGC has concluded that the information provided in this supplemental response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Tom Loomis at (610) 765-5510.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 16th day of January 2020.

Respectfully, J~ -J-r David T. Gudger 1- J.,._,_

Senior Manager - Licensing Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, JAFNPP USNRC Senior Project Manager, JAFNPP A. L. Peterson, NYSERDA

ATTACHMENT Response to Request for Additional Information

Response to Requst for Additional Information Page 1 Issue:

Exelon provided an evaluation of the radiological impact on the environmental qualification of electrical equipment due to the proposed increased leakage rate of Main Steam Isolation Valve (MSIVs). Previously, the MSIV leakage pathway was not considered because the Main Steam Leakage Collection (MSLC) system would direct any MSIV leakage to the Standby Gas Treatment System (SGTS). The new release pathway for the MSIV leakage is the Turbine Building. However, the licensee did not provide an evaluation of the impact of the MSIV increased leakage rate on temperature, pressure, or humidity of electrical equipment in the Turbine Building. Additionally, it is unclear as to whether the licensee considered the impact of the proposed change on non-safety related equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishments of safety functions by the safety-related equipment.

Request:

RAl-EENB-1 Provide an evaluation that shows that the temperatures, pressures, and humidity remain bounded by the existing environmental qualification for equipment and components in the Turbine Building that are impacted by the proposed change.

RAl-EENB-2 Explain how the licensee has assessed the impact of the proposed change on non-safety related equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishments of safety functions by the safety-related equipment.

RAl-EENB-3 Confirm whether any components are being added to the Environmental Qualification (EQ) equipment list to comply with 10 CFR 50.49 due to the proposed change. If components are being added, describe the equipment qualification for the environmental conditions the components are expected to be exposed to.

Response

RAl-EENB-1 The existing design environmental qualification temperatures, pressures, and humidity accident conditions correspond to postulated High Energy Line Breaks (HELBs) including double ended breaks in main steam lines ranging from 2 to 24 inches. An evaluation was performed to demonstrate that the current environmental qualification design conditions bound the increased mass and energy that would enter the Turbine Building due to not crediting the Main Steam Line Collection (MSLC) system to process MSIV leakage. This evaluation shows that the smallest HELB over the design period of 10 minutes results in mass and energy releases more than 2 orders of magnitude greater than that of the MSIV leakage during the 8-hour release before the Turbine Building ventilation system is restarted.

Response to Requst for Additional Information Page 2 Therefore, the temperatures, pressures, and humidity remain bounded by the existing environmental qualification for equipment and components in the Turbine Building that are impacted by the proposed change.

RAl-EENB-2 The proposed change does not affect the potential for non-safety-related electrical equipment to prevent satisfactory accomplishment of safety functions. With the exception of the Electric Bays and cable tunnels, the Turbine Building is currently considered a Harsh Environment for temperature, pressure, and humidity during a HELB. Thus, any non-safety-related electrical components whose failure could prevent satisfactory accomplishment of a safety function must be scoped into the Equipment Qualification (EQ) program for the postulated HELB. There are currently no EQ components located in the Turbine Building due to either safety-related function during a HELB or a failure with potential to prevent accomplishment of a safety-related function .

The proposed change adds a postulated accident condition for a LOCA which is effectively "radiation only". As described in the LA~. Attachment 1, page 9, location specific dose analyses in the Turbine Building demonstrates that areas that contain electrical equipment that is required to support a safety-related function in the post-LOCA environment are located in a mild radiation environment or complete their mission during the first minute of the accident.

Therefore, there is no new equipment, including non-safety-related equipment, that needs to be considered for inclusion in the EQ Program.

RAl-EENB-3 There are no components that are being added to the Environmental Qualification equipment list to comply with 10 CFR 50.49 due to the proposed change.

Environmental Review Request:

RAl-MENB-1 Part of Exelon's application requests exemptions from the requirements of 10 CFR 50, Appendix J, Option B, Paragraphs Ill.A and 111.B. These exemptions would allow exclusion of the Main Steam Isolation Valve (MSIV) leakage from the overall integrated leakage rate measured when performing Type A, B, and C Tests. As an alternative to the proposed action, the NRC considered what would be required to comply with the existing provisions in 10 CFR 50, Appendix J, Option B, Paragraphs Ill.A and 111.B. To comply with those provisions, the alternative would involve work within a radiation area to refurbish the MSIVs to meet the current MSIV leakage rate limits. While the application does state that personnel radiation exposure would occur with refurbishment of the MSIVs, the application does not give an estimate of those resultant radiological doses. Please provide the personnel radiological dose estimates, and a discussion of the operational experience of incurred personnel doses, for refurbishing the MSIVs to comply with the requirements of 10 CFR 50, Appendix J, Option B, Paragraphs Ill.A and 111.B.

Response to Requst for Additional Information Page 3

Response

A review of work on an MSIV during the 2014 outage estimated a dose of approximately 1.1 REM for activities to correct seat leakage on the repaired MSIV. Doses would vary depending on the cause of the MSIV work and repair. No internal MSIV repairs have been performed since 2014.