ML041120353
| ML041120353 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/14/2004 |
| From: | Rosalyn Jones Duke Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML041120353 (8) | |
Text
Ad Duke R. A.
JONES
-TWPowere Vice President A Duke'Energy Company Duke Power 29672 / Oconee Nuclear Site 7800 Rochester Highway Seneca, SC 29672 864 885 3158 864 885 3564 fax April 14, 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 Comments on License Amendment Request for Full-Scope Implementation of the Alternate Source Term Draft Safety Evaluation Report 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.
Supplements to the LAR were submitted on May 20, 2002, September 12, 2002, November 21, 2002, September 22, 2003, November 20, 2003, and February 18, 2004.
Because of the large number of supplements, and the duration and complexity of the review, the NRC is allowing Duke to review and comment on the draft AST Amendment that includes the Safety Evaluation Report (SER).
documents Duke's comments on the draft Amendment dated March 31, 2004.
R00 www. duke-energy. corn
U. S. Nuclear Regulatory Commission April 14, 2004 Page 2 If there are any questions regarding these comments, please contact Reene' Gambrell at (864) 885-3364.
Very ly yours, R A. Jones, Vice President Oconee Nuclear Site
9..;
U. S. Nuclear Regulatory Commission April 14, 2004 Page 3 cc:
Mr. L. N. Olshan, 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 Columbia, SC 29201
U. S. Nuclear Regulatory Commission April 14, 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 forth herein are true and correct to the best of his knowledge.
R. A. A e,
Vice President Oconee Nu ear Site
.ubscribed and sworn to before me this,/Z day of 2004 c>
-Notary-Public My Commission Expires:
/4// 9//.2
U. S. Nuclear Regulatory Commission April 14, 2004 Page 6 ATTACHMENT 1 Duke Energy Corporatioh COMMENTS ON DRAFT AMENDMENT
U. S. Nuclear Regulatory Commission April 14, 2004 Page 7 ATTACHMENT 1 COMMENTS ON DRAFT AMENDMEPT Page 1, Section 1.0,
Introduction:
Delete 'and' from between November 21, 2002 and September 22, 2003.
Page 3, Should 'NICAL EVALUATION' be 'TECHNICAL EVALUATION'?
Page 4, Section 3.1.1, Reactor Building Leakage Page 4, Delete 'latest' from the 4th paragraph, last sentence.
Page 5, 1st paragraph, flowrates listed in parentheses for the RBSS pumps are not correct (1350 gpm for one pump, 2700 for two).
During injection spray, each pump has a nominal flowrate of 1500 gpm, but the values used in the analyses are adjusted for uncertainty and for flow impacting the wall.
It may be simpler to not state the flowrates in this paragraph, since it's hard to match the numbers up with what is in the analysis.
The overall conclusion that two pump operation is more conservative is correct.
This is documented in the October 16, 2001 submittal.
Page 6, Section 3.1.4 Radiological Consequence of Loss-Of-Coolant Accident The SER states in section 3.1.4 that the LOCA results meet the dose criteria for the EAB and LPZ of 10 CFR 50.67 and control room dose limit in GDC19.
The SER should consistently refer to dose criteria only in 10 CFR 50.67 (not GDC19 and not SRP 15.0.1).
The dose limits are the same in each place, but ONS is not licensed to the SRP, and it's more consistent to refer to one document for the dose limits.
On page 3 of the SER, it is specifically stated that the TEDE acceptance criterion of 10 CFR 50.67 replaces the previous Whole-Body and thyroid dose guidelines of 10 CFR 100.11 and GDC 19.
U.
S. Nuclear Regulatory Commission April 14, 2004 Page 8 Section 3.2 Fuel Handling Accident Page 6, Paragraph 2 says the FHA meets the dose criteria in SRP 15.0.1 for the EAB and 10 CFR 50.67 for control room -
Same comment as above for Section 3.1.4.
Page 7, Item (4) should state..... 183 for iodine in elemental and organic forms.....
Since particulates are retained in the pool water, their effective DF is infinite.
The overall DF is a combination of elemental and organic species DFs.
This is documented in the submittal dated May 20, 2002.
Page 7, Item (6), the X/Qs described here (55/45 imbalance) were used for the LOCA analysis, but the doses reported in Table 1 for the FHA cases (CR doses of 2.2 rem and 3.4 rem) used the 60/40 imbalance X/Qs (along with the 10' higher intakes and unfiltered inleakage rates of 1075 / 90 cfm before / after booster fans).
The FHA reported doses came from the "sensitivity" study ONS did to demonstrate sensitivity of dose to changes in actual plant operating parameters after the modifications.
The final FHA doses calculated after all the modifications are complete will reflect the as-tested CR intake airflow imbalance and are expected to be lower than the values reported in Table 1.
Page 7, Last full paragraph, next to last sentence -
The decay times for fuel recently discharged from the core should be (55 to 70 days) instead of (55 to 57 days).
This is documented in the submittal dated May 20, 2002.
Page 7, last paragraph, Twelve different FHA cases were performed, not 18.
Page 8, 2nd and 3rd paragraphs, there is reference to SRP 15.0.1 and GDC 19 for dose criteria.
See applicable comment in Section 3.1.4.
Section 3.3, Control Room Habitability Page 9, 1st full paragraph, 3rd sentence, Delete 'for' between licensee and submitted.
., I U. S. Nuclear Regulatory Commission April 14, 2004 Page 9 Page 14, last paragraph, there is a r'eference to GDC
- 19.
See applicable comment in Section 3.1.4.
Section 4.0, Technical Specifications Page 19, TS 3.3.16, Action A.2.2 is renumbered to A.2.
Page 19, Summary paragraph, the SRP is referred to again.
See applicable comment in Section 3.1.4.
Table 1, Radiological Consequences Expressed as TEDE Page 23, the FHA CR doses reported used the ONS "sensitivity" study of 60/40 airflow imbalance, higher CR inleakages and 10' higher intakes.
The expectation is that these doses will go down with implementation of final modifications.
Page 23, Note (5) references SRP 15.0.1 -
see applicable comment in Section 3.1.4.
Table 2, Parameters and Assumptions Used in Radiological Consequence Calculations Loss-of-Coolant Accident Page 24, Containment leak rates should be for time periods 0 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 24 to 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> (not 0 to 1 and 1 to 720).
Page 24, Containment mixing rates should be 2 unsprayed volumes per hour (30,567 cfm or 1.83E+06 cu ft / hr).
It is the same from sprayed to unsprayed and unsprayed to sprayed.