ML040570073

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Supplement to License Amendment Request for Full-Scope Implementation of the Alternate Source Term Technical Specification Change (TSC) No. 2001-07
ML040570073
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 02/18/2004
From: Rosalyn Jones
Duke Energy Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TSC 2001-07
Download: ML040570073 (19)
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Text

_ Duke R. A. JONES

  • wPower, Vice President A Duke Energy Company Duke Power 29672 1 Oconee Nuclear Site 7800 Rochester Highway Seneca, SC 29672 864 885 3158 864 885 3564 fax February 18, 2004 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk

Subject:

Oconee Nuclear Station Docket Numbers 50-269, 270, and 287 Supplement to License Amendment Request for Full-Scope Implementation of the Alternate Source Term Technical Specification Change (TSC) Number 2001-07 On October 16, 2001, Duke Energy (Duke) submitted the license amendment request (LAR) for full-scope implementation of the Alternate Source Term (AST).

This LAR requested approval of the AST analysis methodology for Oconee Nuclear Station (ONS) that will support simplification of Ventilation System testing requirements during core alterations or movement of irradiated fuel.

Duke received additional questions from the Nuclear Regulatory Commission (NRC) related to the AST LAR.

Supplements to the LAR were submitted on May 20, 2002, September 12, 2002, November 21, 2002, September 22, 2003, and November 20, 2003.

In the submittal dated November 20, 2003, Duke removed Penetration Room Ventilation System (PRVS) from the technical specifications (TS) and adopted TSTF-51 for Spent Fuel Pool Ventilation System (SFPVS) with the exception of the surveillance requirement to run the SFPVS trains.

In a conference call with the NRC on February 3, 2004, additional justification to support the SFPVS changes was requested.

Ado(

www. duke-energy. corn

U. S. Nuclear Regulatory Commission February 18, 2004 Page 2 contains a re-typed copy of the TS. contains the marked-up copies of the TS. contains justification for the changes requested.

Duke has committed to the following three modifications as a part of the AST LAR:

a dual air intake system to the Control Room; a modification to limit Emergency Core Cooling System leakage during post Loss-of-Coolant-Accident Recirculation; and a passive caustic addition system.

These modifications will be completed on all three units by the end of 2005.

TS 3.7.9 will be implemented upon approval of the LAR to facilitate completion of the control room dual air intake modification.

TS 3.3.16, TS 3.7.16, TS 3.7.17, TS 3.8.2, TS 3.8.4, TS 3.8.7, TS 3.8.9, TS 3.9.3, TS 3.9.6 and the sections in TS 5.5.12 pertaining to Control Room Ventilation System (CRVS) and SFPVS, will be implemented after the dual air intake system to the control room modification is completed.

TS 3.3.5, TS 3.3.6, TS 3.3.7, TS 3.7.10, TS 5.5.2 and the sections in TS 5.5.12 pertaining to Penetration Room Ventilation System (PRVS) will be implemented after completion of all three modifications described above.

Pursuant to 10 CFR 50.91, a copy of this proposed license amendment is being sent to the State of South Carolina.

If there are any questions regarding this submittal, please contact Reene' Gambrell at (864) 885-3364.

Very u

yours, R.
nes, Vice President Oconee Nuclear Site

U. S. Nuclear Regulatory Commission February 18, 2004 Page 3 cc:

Mr. L. N. Qishan, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, D. C. 20555 Mr. L. A. Reyes, Regional Administrator U. S. Nuclear Regulatory Commission -

Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. C. Shannon Senior Resident Inspector Oconee Nuclear Station Mr. Henry Porter, Director Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health & Environmental Control 2600 Bull Street Colturibia, SC 29201

U. S. Nuclear Regulatory Commission February 18, 2004 Page 4 R. A. Jones, being duly sworn, states that he is Vice President, Oconee Nuclear Site, Duke Energy Corporation, that he is authorized on the part of said Company to sign and file with the U. S. Nuclear Regulatory Commission this revision to the Renewed Facility Operating License Nos.

DPR-38, DPR-47, DPR-55; and that all the statements and matters set orth herein are true and correct to the best of his kn 1 dge.

R. A. on Vice President Oconee Nuc ear Site

ibscribed and sworn to before me this IS day of 2004 Notaryipublic My Commission Expires:

/ 

ATTACHMENT 1 Duke Energy Corporation Retype of Technical Specifications REMOVE PAGE INSERT PAGE 3.7. 17-1 3.7.17-2 5.0-20 5.0-21 B 3.7.17-3 3.7.17-1 3.7.17-2 5.0-20 5

. 0-21 B 3.7.17-3

SFPVS 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Spent Fuel Pool Ventilation System (SEP VS)

LCO 3.7.17 APPLICABILITY:

Two SFPVS trains shall be OPERABLE.

During movement of recently irradiated fuel assemblies in the spent fuel pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SEP VS train A.1 Place OPERABLE Immediately inoperable.

SFPVS train in operation.

OR A.2 Suspend movement of Immediately recently irradiated fuel assemblies in the spent fuel pool.

B. Two SEP VS trains B.1 Suspend movement of Immediately inoperable, recently irradiated fuel assemblies in the spent fuel pool.

OCONEE UNITS 1,2,

&3 3.7.17-1 Amendment Nos. XXX, XXX, & XXX I

SEP VS 3.7.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.17.1 Operate each SEP VS train for Ž 15 minutes.

Within 31 days prior to movement of recently irradiated fuel assemblies SR 3.7.1 7.2 Perform required SFPVS filter testing in In accordance with the accordance with the Ventilation Filter VFTP Testing Program (VFTP).

OCONEE UNITS 1,2,

& 3 3.7.17-2 Amendment Nos. XXX, XXX, & XXX I

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.11 Secondary Water Chemistry This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control points for these variables;

b.

Identification of the procedures used to measure the values of the critical variables;

c.

Identification of process sampling points;

d.

Procedures for the recording and management of data;

e.

Procedures defining corrective actions for all off control point chemistry conditions; and

f.

A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.12 Ventilation Filter Testing Program (VFTP)

A program shall be established to implement the following required testing of filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2.

The VFTP is applicable to the Control Room Ventilation System (CRVS) Booster Fan Trains and the Spent Fuel Pool Ventilation System (SFPVS).

a.

Demonstrate, for the CRVS Booster Fan Trains, that a DOP test of the HEPA filters shows Ž 99.5% removal when tested in accordance with ANSI N51 0-1 975 at the system design flow rate +/- 10%.

b.

Demonstrate, for the CRVS Booster Fan Trains, that a halogenated hydrocarbon test of the carbon adsorber shows Ž 99% removal when tested in accordance with ANSI N51 0-1975 at the system design flow rate

+/- 10%.

OCONEE UNITS 1.2,

&3 5.0-20 Amendment Nos. XXX, XXX, & XXX I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Ventilation Filter Testing Program (VFTP) (continued)

c.

Demonstrate, for the CRVS Booster Fan Trains and SFPVS, that a laboratory test of a sample of the carbon adsorber shows Ž97.5% and 90% radioactive methyl iodide removal when tested in accordance with ASTM 03803-1989 (3000, 95% RH), respectively.

d.

Demonstrate, for the CRVS Booster Fan Trains, that the pressure drop across the pre-filter is

  • 1 in. of water and the pressure drop across the HEPA filters is
  • 2 in. of water at the system design flow rate +/- 10%.
e.

Demonstrate, for the SFP VS, that a dioctyl phthalate (DOP) test of the high efficiency particulate air (HEPA) filters shows Ž 99% removal when tested in accordance with ANSI N51 0-1 975 at the system design flow rate

+/- 10%.

f.

Demonstrate, for the SFPVS, that a halogenated hydrocarbon test of the carbon adsorber shows Ž 99% removal when tested in accordance with ANSI N51 0-1975 at the system design flow rate +/- 10%.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.13 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the waste gas holdup tanks and the quantity of radioactivity contained in waste gas holdup tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined. The liquid radwaste quantities shall be determined by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

OCONEE UNITS 1,2,

& 3 5.0-2 1

Amendment Nos. XXX, XXX, & XXX I

SEP VS B 3.7.17 BASES ACTIONS B.1 (continued)

When two trains of the SFPVS are inoperable during movement of recently irradiated fuel in the spent fuel pool, the unit must be placed in a condition in which the LCO does not apply. This Action involves immediately suspending movement of recently irradiated fuel assemblies in the spent fuel pool. This does not preclude the movement of recently irradiated fuel to a safe position.

SURVEILLANCE SR 3.7.17.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train within 31 days prior to moving recently irradiated fuel assemblies provides an adequate check on this system. The system is no longer credited in dose analysis calculations and is not required to maintain 10 CER 50.67 dose limits, but is required for ALARA purposes.

SR 3.7.17.2 This SR verifies that the required SFPVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in detail in the VFTP.

REFERENCES

1.

UFSAR, Section 9.4.2.

2.

UFSAR, Section 15.11.

3.

Regulatory Guide 1.183.

4.

10 CER 50.67.

5.

Dose Calculations.

OCONEE UNITS 1,2, & 3 B 3.7.17-3 Amendment Nos. XXX, XXX, & XXX I

ATTACHMENT 2 Duke Energy Corporation Mark-up of Technical Specifications

SFPVS B. TwoSFPVStrains inoperable.

B.1.1 Suspend movement of the spent fuel ApQrtion¶ lAtith toads

'.'or tho spent fuel

-peek--

SURVEILLANCE 3.7.17 COMPLETION TIME Immediately

mmediateIy-ri9c4

I%/ it-i-tad.*:

ass em bIe5 In accordance with the VFTP ndment Nos.

SR 3.7.17.2 Perform required SFPVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

OCONEE UNITS 1,2, & 3 3.7.17-2

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.11 Secondary Water Chemistry This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control points for these variables;

b.

Identification of the procedures used to measure the values of the critical variables;

c.

Identification of process sampling points;

d.

Procedures for the recording and management of data;

e.

Procedures defining corrective actions for all off control point chemistry conditions; and

f.

A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.12 Ventilation Filte A program hall be established to implement the following required testing of filter entilation system t the frequencies The VFTP is applicable to the rnctmtion*Room '.'zntiiation-SystemjPRVS}-the Control Room Ventilation System (CRVS) Booster Fan Trainsand the Spent Fuel P6oI Ventilation System (SFPVS).

a1-Bemonstrateirth1'RVS1hat-a-diootyI-phthalate-(QOP)4est-ef4he-high efficency.pa1ate..air..(NE-PA)-filter-shows--99%-removatwhentested-

..inaoeordance-with-ANSf-NSIOA97-5-at4he-system-design-llow-rate-a.

*.

Demonstrate, for the CRVS Booster Fan Trains, that a DOP test of the HEPA filters shows Ž 99.5% removal when tested (in accordance with

.ANSI N51 0-1 975 at the system design flow rate +/- 10%.

Anted hyrlrorsarhon test otthe al-when-tested-in-eeeerdafee-with OCONEE UNITS 1,2,

& 3 5.0-21 Amendment Nos. e1O7 1O731O I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Notiiation Filter Testina Proaram (VFTP) (continued)

I, if'.

Demonstrate, for the CRVS Booster Fan Trains, that a halogenated hydrocarbon test of the carbon adsorber shows Ž99% removal when tested at in accordance with ANSI N51 0-1975 at the system design flow rateilo%.

c 

Demonstrate, for the ORVS laboratory test of a sample of the carbon a b

ws Ž9 hi h efficiency particulate air (HEPA) filters sh moval when te ccordance with ANSI N51 0-1975 at design flow rate strate, for the t a halogenated hydrocarbon test of the 42/

carbon adsorber s.hwsŽ % rmoval when te in ordance with ANSI N510-1975 at design flow rat/

0.

The provisions of SR 3.0.2 and SR 3.0.3 are applica1te-tl1

VFTP test frequencies.

5.5.13 ExDloslve Gas and Storaae Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the waste gas holdup tanks and the quantity of radioactivity contained In waste gas holdup tanks, and the quantity of radioactivity contained In unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined. The liquid radwaste quantitIes shall be determined by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

OGONEE UNITS 1,2,

&3 5.0-22 Amendment Nos. 310, 310,310 I

SFPVS B 3.7.17 BASES ACTIONS (continued)

B.1 When two trains of the SFPVS are mo erable during movement of fuel ovement of fuel assemblies in the spent fuel pooL and cucponcion f rrn

nprnfinn with Ind nvr thA pAnt f"el pol. This does no

preclude the movement of 

SURVEILLANCE SR 3.7.17.1 REQUI REMENTS need nnly I0 operated through the esociatod roatGr building purge Iil'ere et a det9n flnw +1 fl% for  16 minutos to demnrtrntA th

fjnction of the sy!om. The 31 day Frequency Ic based on the known 4

'C-4 A-,4LAq

dApoaLoJ.

This SR verifies that the required SFPVS testing is performed in V

es testing HEP nce, charcoal adsorber efficiency, minimum system flow.rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in detail in the VFTP.

OCONEE UNITS 1,2,

& 3 B 3.7.17-3 Amendment Nos.

BGG, &

ATTACHMENT 3 TECHNICAL JUSTIFICATION

ATTACHMENT 3 TECHNICAL JUSTIFICATION BACKGROUND:

On October 16, 2001, the license amendment request (LAR) for approval of the Alternate Source Term (AST) analysis methodology for Oconee Nuclear Station (ONS) was submitted.

This license amendment will support simplification of Ventilation System testing requirements during core alterations or movement of irradiated fuel. Duke Energy Corporation (Duke) received additional questions from the NRC related to the AST submittal. Responses to these questions were submitted on May 20, 2002, September 12, 2002, November 21, 2002, September 22, 2003, and November 20, 2003.

In the submittal dated November 20, 2003, Duke removed Penetration Room Ventilation System (PRVS) from the technical specifications (TS) and adopted TSTF-51 for Spent Fuel Pool Ventilation System (SFPVS) with the exception of the surveillance requirement to run the SFPVS trains.

In a conference call with the NRC on February 3, 2004, additional justification to support the SFPVS changes was requested.

JUSTIFICATION FOR !EQUEST:

The submitted dose analysis does not credit removal of radiological contaminants by the PRVS subsequent to a Loss Of Coolant Accident (LOCA) or Fuel Handling Accident (FHA) inside containment, or by the SFPVS in the spent fuel pool building.

Because the analysis no longer credits the SFPVS, it no longer meets the criterion for inclusion in TS as defined in 10 CFR 50.36.

As a result of conversations with the NRC, Duke will retain and relax certain surveillance requirements for SFPVS TS.

Retaining the TS for SFPVS is for ALARA purposes.

Description of Changes and Justification:

TS 3.7.17, Spent Fuel Pool Ventilation System (SFPVS)

Deleting note 1 -

The TS is only applicable during movement of recently irradiated fuel which is a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period following reactor shutdown.

During this time period, fuel cannot be physically moved. These actions are controlled by

a selected licensee commitment (SLC).

The note is being deleted because in the short time it is applicable, it doesn't serve a function since there are no required actions as a result of entry into 3.0.3.

Deleting note 2 -

The TS is only applicable during movement of recently irradiated fuel which is a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period following reactor shutdown.

During this time period, fuel cannot be physically moved. These actions are controlled by a SLC.

The note is being deleted because in the short time it is applicable, it doesn't serve a function.

The APPLICABILILITY of 'During crane operations with loads over the spent fuel pool' is being deleted. This is acceptable because the revised fuel handling analysis does not take credit for SFPVS in the event of a Spent Fuel Pool building accident.

The analysis can be referenced in the submittal dated October 16, 2001, Attachment 3. For the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period following reactor shutdown in which the TS is applicable, fuel cannot be physically moved and is controlled by SLC.

The logical connectors AND for REQUIRED ACTIONS A.2.2 and B.1.2, REQUIRED ACTION (RA) A.2.2, RA B.1.2 and their associated COMPLETION TIMES are being deleted.

This is acceptable because the revised fuel handling analysis does not take credit for SFPVS in the event of an Spent Fuel Pool building accident.

The analysis can be referenced in the submittal dated October 16, 2001, Attachment 3. For the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period following reactor shutdown in which the TS is applicable, fuel cannot be physically moved and is controlled by SLC.

The Completion Time for SR 3.7.17.1 is being revised from 31 days to within 31 days prior to movement of recently irradiated fuel assemblies.

Because the analysis no longer credit SFPVS, the SR can be relaxed as long as the fans are proven OPERABLE prior to moving recently irradiated fuel.

TS 5.5.12 Ventilation Filter Testing Program (VFTP)

The testing requirements for the SFPVS are being returned to the original approved values.

TSB 3.7.17, SFPVS The 'LCO' is being revised to delete the NOTES in their entirety.

The justification is provided above in description of changes for TS.

The 'APPLICABILITY' is being revised to delete information related to crane operations with loads over the spent fuel pool.

The justification is provided above in description of changes for TS.

Action A.l and A.2 will be revised to delete reference to crane operations with loads over the spent fuel pool.

The justification is provided above in description of changes for TS.

Action B.1 will be revised to reflect to delete reference to crane operations with loads over the spent fuel pool.

The justification is provided in description of changes for TS.

The Completion Time for SR 3.7.17.1 was revised from 31 days to within 31 days prior to movement of recently irradiated fuel.

This will ensure the system is OPERABLE prior to movement of recently irradiated fuel.

Since, the system is no longer credited in dose analysis calculations and is not required to maintain 10 CFR 50.67 dose limits for fuel that has not been recently irradiated, a relaxed testing frequency is acceptable.

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