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Category:Exemption from NRC Requirements
MONTHYEARML24044A0732024-02-28028 February 2024 Federal Register Notice - Issuance of Multiple Exemptions Regarding 10 CFR Part 73 - January 2024 ML24004A0792024-01-18018 January 2024 – Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0041 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) U-604780, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-17017 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML22034A9832022-02-15015 February 2022 FRN - Notice of Issuance of COVID-19 Exemptions Issued in January 2022 ML22013B2772022-01-14014 January 2022 Exemption from Specific Requirements of 10 CFR Part 26 (EPID L-2022-LLE-0003 (COVID-19)) ML21112A0072021-04-29029 April 2021 Exemption from Specific Requirements of 10 CFR Part 26 (EPID L-2021-LLE-0027 (COVID-19)) ML20339A5382020-12-16016 December 2020 Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLE-0232 (COVID-19)) ML20323A4342020-12-11011 December 2020 Exemption from Annual Force-on-Force Exercise Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel, Subsection VI.C.3(l)(1) (EPID L-2020-LLE-0200 (COVID-19)) ML20339A3182020-12-0303 December 2020 Incoming Request-Clinton-Exelon Generation Co., LLC NMP1L3362, Request for an Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to COVID- 19 Public Health Emergency2020-11-13013 November 2020 Request for an Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to COVID- 19 Public Health Emergency ML20243A0002020-09-23023 September 2020 FRN - Notice of Issuance of Multiple Exemptions Regarding Various Parts of 10 CFR Due to COVID-19 Impacts for August 2020 ML20209A0002020-08-13013 August 2020 Exemption Request from Certain Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel (EPID-L-2020-LLE-0119 (COVID-19)) ML19092A2622019-07-15015 July 2019 Exemption from 10 CFR 2.109 (B)(Epid L-L-2018-LLE-0018) ML19092A2582019-07-11011 July 2019 Letter, Exemption from the Requirements of 10 CFR Part 54, Section 54.17(A) ML19193A0152019-07-11011 July 2019 Exemption from the Requirements of 10 CFR 54.17(A) RS-18-137, Request for Exemption from 10 CFR 2.109(b)2018-11-0808 November 2018 Request for Exemption from 10 CFR 2.109(b) ML16257A4802017-01-23023 January 2017 Letter Exemption from the Requirements of 10 CFR Part 73, Sections 55(p)(1)(i) and (p)(1)(ii) Related to the Suspension of Security Measures in an Emergency or During Severe Weather (CAC Nos. MF8275 - MF8278) ML0614302462006-06-27027 June 2006 TMI and Zion - Exemption from the Requirements of 10 CFR 50.54(a)(3) Re Submittal of Changes to Quality Assurance Topical Report RS-04-086, Request for Exemption from 10 CFR 50 Appendix J in Support of Request for License Amendment Related to Application of Alternative Source Term2004-07-0101 July 2004 Request for Exemption from 10 CFR 50 Appendix J in Support of Request for License Amendment Related to Application of Alternative Source Term ML0233805002002-11-25025 November 2002 Exemption Request from the Requirements of 10 CFR 50.36(C)(1) 2024-02-28
[Table view] Category:Letter type:RS
MONTHYEARRS-24-087, Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station2024-09-0909 September 2024 Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station RS-24-061, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations2024-06-14014 June 2024 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations RS-24-055, 2023 Corporate Regulatory Commitment Change Summary Report2024-05-17017 May 2024 2023 Corporate Regulatory Commitment Change Summary Report RS-24-050, Additional Information Supporting Request for License Amendment to Revise Technical Specifications Related to Reactor Water Cleanup Isolation Instrumentation2024-05-0909 May 2024 Additional Information Supporting Request for License Amendment to Revise Technical Specifications Related to Reactor Water Cleanup Isolation Instrumentation RS-24-041, Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests2024-04-30030 April 2024 Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests RS-24-002, Constellation Energy Generation, LLC - Annual Property Insurance Status Report2024-04-0101 April 2024 Constellation Energy Generation, LLC - Annual Property Insurance Status Report RS-24-023, Report on Status of Decommissioning Funding.2024-03-22022 March 2024 Report on Status of Decommissioning Funding. RS-24-005, Additional Information Supporting Request for Partial Site Release2024-02-0808 February 2024 Additional Information Supporting Request for Partial Site Release RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans RS-23-090, Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station2023-09-0707 September 2023 Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs RS-23-081, Request for License Amendment to Revise Technical Specifications Related to Reactor Water Cleanup Isolation Instrumentation2023-08-21021 August 2023 Request for License Amendment to Revise Technical Specifications Related to Reactor Water Cleanup Isolation Instrumentation RS-23-085, Supplemental Information Related to Request for Partial Site Release2023-08-0303 August 2023 Supplemental Information Related to Request for Partial Site Release RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations RS-23-073, Request for Partial Site Release2023-06-0707 June 2023 Request for Partial Site Release RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling RS-23-049, Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-23023 March 2023 Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations RS-23-039, Request for License Amendment to Revise Technical Specifications Section 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air2023-03-0101 March 2023 Request for License Amendment to Revise Technical Specifications Section 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air RS-23-045, Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.2032023-02-28028 February 2023 Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.203 RS-23-003, Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-102023-01-31031 January 2023 Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-10 RS-23-002, Application to Adopt TSTF-332, ECCS Response Time Testing2023-01-13013 January 2023 Application to Adopt TSTF-332, ECCS Response Time Testing RS-22-126, Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2022-11-30030 November 2022 Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI RS-22-121, Notice of Intent to Pursue Subsequent License Renewal Applications2022-11-0909 November 2022 Notice of Intent to Pursue Subsequent License Renewal Applications RS-22-092, Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration2022-10-0303 October 2022 Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration RS-22-107, Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station2022-09-29029 September 2022 Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station RS-22-093, Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans2022-08-18018 August 2022 Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans RS-22-089, Additional Information Supporting Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock2022-07-25025 July 2022 Additional Information Supporting Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock RS-22-060, Request for License Amendment to Adopt TSTF-230, Revision 1, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2022-05-24024 May 2022 Request for License Amendment to Adopt TSTF-230, Revision 1, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling RS-22-061, Request for License Amendment to Adopt TSTF-269, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves2022-05-24024 May 2022 Request for License Amendment to Adopt TSTF-269, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves RS-22-068, Constellation Radiological Emergency Plan Addendum Revision2022-05-19019 May 2022 Constellation Radiological Emergency Plan Addendum Revision RS-22-055, Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan2022-04-18018 April 2022 Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan RS-22-051, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-04-12012 April 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-020, Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock2022-04-0707 April 2022 Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock RS-22-049, Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for2022-04-0404 April 2022 Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for V RS-22-045, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-25025 March 2022 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P RS-22-023, Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement2022-02-23023 February 2022 Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement RS-22-019, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-02-16016 February 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-015, Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC2022-02-0101 February 2022 Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC RS-22-004, Supplement to Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2022-01-0404 January 2022 Supplement to Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RS-21-121, Proposed Changes to Decommissioning Trust Agreements and Master Terms2021-12-15015 December 2021 Proposed Changes to Decommissioning Trust Agreements and Master Terms RS-21-102, Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors2021-09-29029 September 2021 Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors RS-21-091, Implementation of Insider Threat Program Requirements Associated with the Voluntary Security Clearance Program and Advisement of Leadership Changes2021-09-13013 September 2021 Implementation of Insider Threat Program Requirements Associated with the Voluntary Security Clearance Program and Advisement of Leadership Changes RS-21-087, Additional Information Supporting Request for License Amendment to Revise Degraded Voltage Relay Allowable Values2021-08-31031 August 2021 Additional Information Supporting Request for License Amendment to Revise Degraded Voltage Relay Allowable Values RS-21-078, Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel2021-08-19019 August 2021 Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel RS-21-076, Application to Adopt TSTF-273, Safety Function Determination Program Clarifications2021-07-30030 July 2021 Application to Adopt TSTF-273, Safety Function Determination Program Clarifications RS-21-063, Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2021-06-30030 June 2021 Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RS-21-070, Proposed Alternative to Utilize Code Case N-8932021-06-30030 June 2021 Proposed Alternative to Utilize Code Case N-893 RS-21-069, Third Inservice Inspection Interval Relief Request I3R-182021-06-28028 June 2021 Third Inservice Inspection Interval Relief Request I3R-18 RS-21-054, Response to NRC Regulatory Issue Summary 2021-01, Preparation and Scheduling of Operator Licensing Examinations2021-04-29029 April 2021 Response to NRC Regulatory Issue Summary 2021-01, Preparation and Scheduling of Operator Licensing Examinations 2024-09-09
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AmerGen Energy Company, LLC www.exeloncorp.com AmerGen M An Exelon Company 4300 Winfield Road Warrenville, IL60555 10 CFR 50.12 RS-04-086 July 1, 2004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461
Subject:
Request for Exemption from 10 CFR 50 Appendix J in Support of Request for License Amendment Related to Application of the Alternative Source Term
References:
(1) Letter from Michael J. Pacilio (AmerGen Energy Company, LLC) to U. S.
NRC, "Request for License Amendment Related to Application of Alternative Source Term, a dated April 3, 2003 (2) Letter from U. S. NRC to John L. Skolds (AmerGen Energy Company, LLC), "Clinton Power Station, Unit I - Corrected Request for Additional Information Regarding Alternate Source Term Submittal (TAC No.
MB8365)," dated November 18, 2003 (3) Letter from Keith R. Jury (Exelon Generation Company, LLC) to U. S.
NRC, "Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term," dated December 23, 2003 In accordance with 10 CFR 50.12, "Specific exemptions," paragraph (a)(2)(ii), AmerGen Energy Company, LLC (AmerGen) Is requesting NRC approval of a permanent exemption from 10 CFR 50, Appendix J, Option B, "Performance-Based Requirements," paragraph Ill.B, which requires demonstration "that the sum of the leakage rates at accident pressure of Type B tests, and pathway leakage rates from Type C tests, is less than the performance criterion (La) with margin, as specified in the Technical Specifications." With respect to this requirement, AmerGen requests an exemption to exclude the leakage rates for the containment purge lines associated with containment penetrations 1MC-101 and 1MC-102. The details of the exemption request are attached.
July 1, 2004 U. S. Nuclear Regulatory Commission Page 2 In Reference 1, AmerGen requested a change to the Technical Specifications (TS) for Facility Operating License No. NPF-62 for Clinton Power Station (CPS). Specifically, the proposed change supported application of an alternative source term (AST) methodology in accordance with 10 CFR 50.67, "Accident source term," with the exception that Technical Information Document (TID) 14844, "Calculation of Distance Factors for Power and Test Reactor Sites," will continue to be used as the radiation dose basis for equipment qualification.
In Reference 2, AmerGen received a request for additional Information from the NRC. The initial response to this request was provided in Reference 3. Question 2 of Reference 2 requested an explanation of how the proposed change to the CPS TS will meet the 10 CFR 50, Appendix J, requirements for summing the leakage from all pathways subject to testing. As noted in the Attachment to Reference 3, it has been determined that the proposed change constitutes an exception to this requirement and an exemption is required to allow separate evaluation of the leakage of the containment purge penetrations. This letter provides the required exemption request discussed In Reference 3.
AmerGen requests approval of the subject exemption request consistent with the schedule for review of the Reference I amendment request.
If you should have any questions concerning this submittal, please contact Mr. Timothy A. Byam at (630) 657-2804.
Respectfully, Patrick R. Simpson Manager - Licensing
Attachment:
10 CFR 50.12 Exemption Request cc: Regional Administrator - NRC Region IlIl NRC Senior Resident Inspector - Clinton Power Station Office of Nuclear Facility Safety - IEMA Division of Nuclear Safety
ATTACHMENT 10 CFR 50.12 Exemption Request SPECIFIC EXEMPTION REQUEST In accordance with 10 CFR 50.12, Specific exemptions," paragraphs (a)(1) and (a)(2)(ii),
AmerGen Energy Company (AmerGen), LLC, is requesting NRC approval of a permanent exemption from 10 CFR 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," Option B, "Performance-Based Requirements,"
paragraph III.B, which requires demonstration "that the sum of the leakage rates at accident pressure of Type Btests, and pathway leakage rates from Type C tests, is less than the performance criterion (La) with margin, as specified in the Technical Specifications." Specifically with respect to this requirement, AmerGen requests a permanent exemption to exclude the leakage rates for the containment purge lines associated with Clinton Power Station (CPS) containment penetrations 1MC-1 01 and 1MC-1 02 from the secondary containment bypass leakage total and the primary containment leakage rate total.
BASIS FOR EXEMPTION REQUEST The criteria for granting specific exemptions from 10 CFR 50 regulations are stated in 10 CFR 50.12. In accordance with 10 CFR 50.12(a)(1), the NRC is authorized to grant an exemption upon determining that the exemption Isauthorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. Furthermore, as stated In 10 CFR 50.12(a)(2), special circumstances must exist for the NRC to consider granting an exemption. According to 10 CFR 50.12(a)(2)(ii),
special circumstances are present whenever the application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or Is not necessary to achieve the underlying purpose of the rule.
According to 10 CFR 50 Appendix J, the purpose of the leak test requirements is to ensure the following.
(a) Leakage through the primary reactor containment or systems and components penetrating the containment does not exceed allowable leakage rates specified in the Technical Specifications (TS).
(b) Integrity of the containment structure is maintained during Its service life.
The first purpose of 10 CFR 50 Appendix J Is served primarily by the performance of Integrated Leak Rate Tests (ILRTs). Leakage through the subject penetrations would continue to be Included in the containment leakage measured during ILRTs following approval of this proposed exemption.
The second purpose of 10 CFR 50 Appendix J is served primarily by the performance of Local Leak Rate Tests (LLRTs). In accordance with 10 CFR 50 Appendix J Option B, paragraph 111.1, performance of Type B and Type C containment leakage tests (i.e.,
LLRTs) are required. The Type B pneumatic tests detect and measure local leakage rates across pressure retaining, leakage-limiting boundaries while Type C pneumatic tests measure containment isolation valve leakage rates. These tests are required to be performed prior to initial criticality and periodically thereafter at Intervals based on the safety significance and historical performance of each boundary and isolation valve. The intent of these tests is to ensure the integrity of the overall containment system as a barrier to fission product release to reduce the risk from reactor accidents. 10 CFR 50, Appendix J goes on to require that the tests must demonstrate that the sum of the leakage rates at Page 1 of 3
ATTACHMENT 10 CFR 50.12 Exemption Request accident pressure of Type B tests, and pathway leakage rates from Type C tests, is less than the performance criterion (i.e., maximum allowable primary containment leakage rate, La) with margin, as specified in the Technical Specifications.
The CPS containment purge lines (i.e., penetrations IMC-101 and 1MC-102) are currently subject to leakage rate testing under TS Surveillance Requirement (SR) 3.6.1.3.5, with a current leakage rate acceptance criterion of *0.01 La for each penetration. As part of the Alternative Source Term (AST) analysis, the dose consequences from leakage through the primary containment purge lines have been evaluated based on a leak rate of 0.02 La for each penetration. The AST analysis (Reference 1) demonstrated that the consequences due to a LOCA, including the assumed separate containment purge line leak rate, are within regulatory limits and are therefore acceptable. Therefore, Reference I proposes a revised acceptance criterion of *0.02 La for SR 3.6.1.3.5. Since a separate dose analysis has been performed for the primary containment purge lines, these penetrations no longer need to be considered Indetermining compliance with the secondary containment bypass leakage path SR 3.6.1.3.8 limit of *0.08 La, or the primary containment leakage rate acceptance criterion in TS 5.5.13 of *1.0 La.
The proposed exemption does not change the requirement to perform the ILRT. The leakage through the subject potential leakage paths will continue to be Included Inthe containment leakage measured during the ILRT. CPS will continue to perform Type C leakage testing on 1MC-101 and IMC-102. The proposed exemption does not change the TS or the required surveillance requirement. CPS will evaluate the measured leakage results against the specified 0.02 La acceptance criterion. This acceptance criterion is a small fraction of the secondary containment bypass and primary containment leakage rate limits. This methodology is consistent with that of the CPS main steam line penetration leakage, which Is also evaluated separately from the overall La calculation by virtue of having a separate dose analysis and separate TS surveillance criteria. This exemption was found to be acceptable in Section 6.2.6 of Reference 2 and Is documented in CPS Updated Safety Analysis Report (USAR) Table 6.2-1. The containment purge penetrations will continue to be leak tested in accordance with a separate TS SR and will be evaluated against specified acceptance criteria based on analysis and therefore, application of the regulation in this case Is not necessary to achieve the underlying purpose of the rule. Therefore, It has been demonstrated that the criteria of 10 CFR 50.12(a)(2)(ii) are satisfied.
The criteria of 10 CFR 50.12(a)(1) have been satisfied. The requested exemption is authorized by law in that no law precludes the activities covered by this exemption request. In addition, the requested exemption will not present an undue risk to the public health and safety and Is consistent with the common defense and security.
Ill. ENVIRONMENTAL ASSESSMENT In accordance with 10 CFR 51.30, "Environmental assessment," and 51.32, "Finding of no significant impact," the following information is provided in support of an environmental assessment and finding of no significant impact for the proposed change.
A permanent exemption Is requested to exclude the leakage rates for the containment purge lines associated with Clinton Power Station (CPS) containment penetrations 1MC-101 and 1MC-102 from the secondary containment bypass leakage total and the primary containment leakage rate total. The altemative measures described above for measuring and evaluating containment purge line leakage, will provide assurance that the primary Page 2 of 3
ATTACHMENT 10 CFR 50.12 Exemption Request reactor containment Is an essentially leak tight barrier against the uncontrolled release of radioactivity to the environment. CPS will continue to measure the leakage through the subject penetrations in accordance with TS SR 3.6.1.3.5 and will evaluate the measured leakage results against a specified 0.02 La acceptance criterion. The 0.02 La acceptance criterion is a fraction of the acceptable secondary containment bypass leakage and primary containment leakage limits and will therefore be effective and reliable in determining the status of the leakage through these penetrations as well as verifying that substantial degradation of the valves Inthese lines has not occurred since the last ILRT.
Based on the above discussion, there is no increase in the probability of higher post accident offsite or onsite doses related to the exemption and therefore, no increase In environmental Impact beyond that experienced with no exemption.
IV. CONCLUSION 10 CFR 50.12 authorizes the NRC, upon application by any Interested person, to grant exemption from the requirements of the regulations when special circumstances are present. AmerGen concludes that such special circumstances are present in this Instance to warrant exemption from the regulatory requirements of 10 CFR 50 Appendix J pertaining to inclusion of the total Type B and C leakage in the secondary containment bypass leakage and the primary containment leakage rate totals. Granting this exemption will allow tracking the leakage associated with the containment purge line penetrations separately from the total containment leakage rates. Specifically, Section (ii) of 10 CFR 50.12(a)(2) applies.
The proposed exemption 1) is authorized by law in that no law exists which precludes the activities covered by this exemption request, 2) will not present an undue risk to the public health and safety, and 3) Is consistent with the common defense and security. Since the containment purge line penetrations will continue to be leak tested in accordance with a separate TS SR and will be evaluated against a specified acceptance criterion based on analysis, application of the regulation Inthis case is not necessary to achieve the underlying purpose of the rule. Therefore, it has been demonstrated that the criteria of 10 CFR 50.12(a)(2)(ii) are satisfied.
V. REFERENCES
- 1. Letter from M.J. Pacilio (AmerGen Energy Company, LLC) to U. S. Nuclear Regulatory Commission, "Request for License Amendment Related to Application of Alternative Source Term," dated April 3, 2003
- 2. NUREG-0853, 'Safety Evaluation Report Related to the Operation of Clinton Power Station, Unit No. I," Supplement No. 6, dated July 1986 Page 3 of 3