ML032541025
| ML032541025 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/11/2003 |
| From: | Martin R NRC/NRR/DLPM/LPD2 |
| To: | Jamil D Duke Energy Corp |
| Martin R, NRR/DLPM, 415-1493 | |
| References | |
| TAC MB7014, TAC MB7015 | |
| Download: ML032541025 (10) | |
Text
September 11, 2003 Mr. D. M. Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, SC 29745
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2 RE: REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MB7014 AND MB7015)
Dear Mr. Jamil:
By letter dated November 25, 2002, you submitted an application for amendment of the Technical Specifications for the Catawba Nuclear Station (Catawba), Units 1 and 2, to revise the TS for five ventilation systems, and the reactor building and containment penetrations. The U. S. Nuclear Regulatory Commission technical staff has reviewed the application and has determined that additional information is required, as identified in the Enclosure.
We discussed these issues with your staff on August 27, 2003. Your staff indicated that you would attempt to provide your response by October 15, 2003.
Please contact me at (301) 415-1493, if you have any other questions on these issues.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414
Enclosure:
As stated cc w/encl: See next page
September 11, 2003 Mr. D. M. Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, SC 29745
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2 RE: REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MB7014 AND MB7015)
Dear Mr. Jamil:
By letter dated November 25, 2002, you submitted an application for amendment of the Technical Specifications for the Catawba Nuclear Station (Catawba), Units 1 and 2, to revise the TS for five ventilation systems, and the reactor building and containment penetrations. The U. S. Nuclear Regulatory Commission technical staff has reviewed the application and has determined that additional information is required, as identified in the Enclosure.
We discussed these issues with your staff on August 27, 2003. Your staff indicated that you would attempt to provide your response by October 15, 2003.
Please contact me at (301) 415-1493, if you have any other questions on these issues.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC OGC CHawes KKavanagh PDII-1 R/F ACRS RMartin JNakoski LPlisco, RII RHaag, RII ADAMS Accession: ML032541025 OFFICE PDII-1/PM PDII-1/LA PDII-1/SC NAME RMartin CHawes JNakoski DATE 9/9/03 8/29/03 9/10/03 OFFICIAL RECORD COPY
REQUEST FOR ADDITIONAL INFORMATION DUKE POWER COMPANY CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 The Nuclear Regulatory Commission (NRC) staff has reviewed the licensees submittal dated November 25, 2002, regarding proposed changes Technical Specifications for five ventilation systems, and the reactor building and containment penetrations. The NRC staff has identified the following information that is needed to enable the continuation of its review.
Dose Analysis 1.
The application dated November 25, 2002, includes an analysis of the radiological consequences of a design basis loss of coolant accident (LOCA) using alternative source term (AST) methodology. The application also states the NRC has previously approved the AST methodology for the fuel handling and wier gate drop accidents and that the additional use of AST methodology for the LOCA analysis would represent full implementation of the AST methodology for Catawba. There is at least one other application for Catawba that is currently under review that may be affected by the proposed use of AST methodology in the November 25, 2002, application and that is the application dated February 27, 2003, related to the use of mixed oxide (MOX) lead test assemblies. This issue was addressed in requests for additional information on the MOX application that were issued on July 25, 2003, that addressed how the AST related issues in the two applications would be coordinated. Accordingly, this request for information on the November 25, 2002, application now includes the following request on how the proposed changes included in this application will be coordinated with other pending Catawba applications, including the MOX application.
The licensees February 27, 2003, application to allow the use of four MOX fuel assemblies at either McGuire or Catawba, currently under NRC staff review, does not address the proposed implementation of a full scope alternative source term at Catawba with total effective dose equivalent (TEDE) criteria for the design basis accident dose analyses. The November 25, 2002, application does not address the effect of the proposed MOX lead test assemblies on the dose consequences of design basis accidents. Please explain how the differences between these two applications will be resolved, including comparable differences for any other proposed license amendments for Catawba that are currently pending.
2.
The November 25, 2002, application proposes to use organ dose weighting factors given in International Commission on Radiological Protection Publication 60, 1990 Recommendations of the International Commission on Radiological Protection (ICRP-60). SECY 01-0148, Processes for Revision of 10 CFR Part 20 Regarding Adoption of ICRP Recommendations on Occupational Dose Limits and Dosimetric Models and Parameters, addresses the staff position on ICRP-60. The Commission directed the staff not to adopt ICRP-60 at that time (Staff Requirements -
SECY-01-0148, Processes for Revision of 10 CFR Part 20 Regarding Adoption of ICRP Recommendations on Occupational Dose Limits and Dosimetric Models and Parameters), but to monitor the work of other federal agencies and the revision to ICRP-60, which is ongoing. The NRC staff believes that it is premature to consider adoption of ICRP-60 at this time. On October 17, 1994, in the Federal Register (59 FR 52255), the NRC proposed revisions to 10 CFR Parts 50, 52 and 100 (References 1, 2, and 3) that included definitions of TEDE, deep-dose equivalent, and committed effective dose equivalent. The statements of consideration for this rulemaking noted that the definition of TEDE is meant to be consistent with 10 CFR Part 20 (Reference 4). These definitions are currently codified in 10 CFR 50.2. Therefore, the NRC staff believes that the organ dose weighting factors given in 10 CFR 20.1003 are the accepted values to be used in the calculation of TEDE as defined in 10 CFR 50.2. Please provide further justification for use of the ICRP-60 organ dose weighting factors considering the regulatory definition of TEDE.
3.
The November 25, 2002, application proposes to eliminate the annulus ventilation system (AVS) one minute drawdown time surveillance requirement (SR) in SR 3.6.16.2.
In justification of this change, it is stated on page 5 of Attachment 3 of the November 25, 2002, application that the one minute annulus drawdown time is not a dose analysis input. In the LOCA dose consequences analysis, provided in Appendix A of the submittal, the leakage from the containment is assumed to be an unfiltered ground level release prior to AVS drawdown. After 23 seconds, the release is assumed to be filtered by the AVS and released from the plant vent. This seems to contradict the claim that the drawdown time is not a dose analysis input. Please provide further information on the treatment of containment leakage by the AVS, including the time it takes for the AVS to drawdown the annulus to the required negative pressure.
Additionally, please provide further justification on why a surveillance is not needed to verify that the AVS can provide filtration of the containment leakage as assumed in your dose analyses.
Control Room Relative Concentration (X/Q) Estimates 4.
What are the release heights and distances between the postulated release location and receptor? Are distances straight line or do they factor in flow over or around structures?
For example, does 90 arc mean that the release is assumed to occur due east of the receptor, but is assumed to initially move in an arc around a structure to get to the receptor?
5.
Provide a figure or figures showing structures, assumed paths of air flow, dimensions, heights and distances used as input in estimating the postulated transport of effluent from each of the release locations to the receptors. Are all directional inputs defined in terms of true north? If the figures are drawn to plant or magnetic north, what is the relationship to true north, assuming that the meteorological measurements are based upon true north?
6.
If more than one release to the environment and transport scenario could occur (e.g.,
loss of offsite power, availability of offsite power, single failure), were comparative X/Q calculations made to ensure consideration of the limiting dose?
7.
Confirm that each of the control room intakes meets the applicable qualifications to support a credit for reduction in the X/Q values. These qualifications include, but are not limited to, the single failure criterion for active components and the seismic and missile protection criteria. If both control room air intakes were previously approved by the NRC staff as meeting all of the applicable qualifications and that status has not changed, the licensees response may reference the document approving the intakes.
Also, provide the assumed flow rates for each intake used in the composite X/Q calculations?
8.
Page A-36 of Appendix A to Attachment 3 of the November 25, 2002, submittal lists postulated design basis events. Page A-68 provides some of the input information as a function of release and receptor location. Page A-70 provides X/Q values for two of the four locations listed in a table on Page A-68. What are the pairings of postulated design basis events, release and intake locations, and X/Q values?
Bypass Leakage 9.
In the submittal, the licensee requested a change for penetration and bypass leakage from < 0.05 percent to < 1.0 percent for annulus ventilation, fuel handling ventilation, and auxiliary building ventilation systems. The staff position on this issue is as outlined in Regulatory Position C.5.c and C.5.d of Regulatory Guide (RG) 1.52, Rev. 2, dated March 1978 (Reference 5). Although, a different position was outlined in Generic Letter 83-13 (Reference 6), that position is not the current NRC staffs position. The current staffs position is as indicated above and as outlined in Regulatory Position C.6 of RG 1.52 Rev. 3, dated June 2001. Therefore, the penetration and bypass leakage should be < 0.05 percent for the systems discussed above.
REFERENCES:
1.
Title 10 of Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities.
2.
10 CFR Part 52, Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power Plants.
3.
10 CFR Part 100, Reactor Site Criteria.
4.
10 CFR Part 20, Standards for Protection Against Radiation.
5.
Regulatory Guide 1.52, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered Safety Feature Atmosphere Cleanup Systems in Light Water Cooled Nuclear Power Plants.
6.
Generic Letter 83-13, Clarification of Surveillance Requirements for HEPA Filters and Charcoal Absorbers Units in Standard Technical Specifications on ESF Cleanup Systems.
Catawba Nuclear Station cc:
Mr. Gary Gilbert Regulatory Compliance Manager Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Ms. Lisa F. Vaughn Duke Energy Corporation Mail Code - PB05E 422 South Church Street P.O. Box 1244 Charlotte, North Carolina 28201-1244 Anne Cottingham, Esquire Winston and Strawn 1400 L Street, NW Washington, DC 20005 North Carolina Municipal Power Agency Number 1 1427 Meadowwood Boulevard P. O. Box 29513 Raleigh, North Carolina 27626 County Manager of York County York County Courthouse York, South Carolina 29745 Piedmont Municipal Power Agency 121 Village Drive Greer, South Carolina 29651 Ms. Karen E. Long Assistant Attorney General North Carolina Department of Justice P. O. Box 629 Raleigh, North Carolina 27602 NCEM REP Program Manager 4713 Mail Service Center Raleigh, NC 27699-4713 North Carolina Electric Membership Corporation P. O. Box 27306 Raleigh, North Carolina 27611 Senior Resident Inspector U.S. Nuclear Regulatory Commission 4830 Concord Road York, South Carolina 29745 Henry Porter, Assistant Director Division of Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201-1708 Mr. C. Jeffrey Thomas Manager - Nuclear Regulatory Licensing Duke Energy Corporation 526 South Church Street Charlotte, North Carolina 28201-1006 Saluda River Electric P. O. Box 929 Laurens, South Carolina 29360 Mr. Peter R. Harden, IV VP-Customer Relations and Sales Westinghouse Electric Company 6000 Fairview Road 12th Floor Charlotte, North Carolina 28210
Catawba Nuclear Station cc:
Mr. T. Richard Puryear Owners Group (NCEMC)
Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Richard M. Fry, Director Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721