ML043510039

Request for Additional Information Regarding Use of Alternate Source Term

ML043510039
Person / Time
Site:	Millstone
Issue date:	12/29/2004
From:	George Wunder NRC/NRR/DLPM/LPD1
To:	Christian D Dominion Nuclear Connecticut
Wunder G, NRR/DLPM, 415-1494
References
TAC MC3333
Download: ML043510039 (5)

Text

December 29, 2004 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING USE OF ALTERNATE SOURCE TERM (TAC NO.

MC3333)

Dear Mr. Christian:

By letter dated May 27, 2004, you requested an amendment to the technical specifications for the Millstone Power Station, Unit No. 3. The proposed amendment would allow the use of an alternate source term.

The Nuclear Regulatory Commission staff has determined that the enclosed questions must be addressed before we can complete our review. These questions were forwarded electronically to Mr. Paul Willoughby of your staff on December 6, 2004. Additionally, they were discussed in a telephone call with Mr. Willoughby and other members of your staff on December 14, 2004. I understand that you intend to respond to this request for additional information within 30 days of the date of this letter. If you have any questions, I can be reached at (301) 415-1494.

Sincerely,

/RA/

George F. Wunder, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-423 cc: See next page

Enclosure:

Request for Additional Information

REQUEST FOR ADDITIONAL INFORMATION MILLSTONE POWER STATION, UNIT NO. 3 USE OF ALTERNATE SOURCE TERM Regulatory Guide (RG) 1.52 establishes the criterion for penetration in the laboratory testing of engineered safety feature filter systems. In Revision 2 of RG 1.52, the allowable penetration for a 2-inch bed filter is less than 1 percent. In Revision 3 of RG 1.52, some relaxation was allowed and the penetration criterion for a 2-inch bed during a laboratory test was increased to less than 2.5 percent, based in part on maintaining a safety factor of 2. The current Millstone Power Station, Unit No. 3 technical specification (TS) for the control room emergency ventilation filter allows 2.5 percent penetration and is in compliance with RG 1.52, Revision 3.

The submittal requests a TS surveillance change to allow a 5-percent penetration test criteria.

The Nuclear Regulatory Commission staff does not have sufficient information on filter performance for test penetration criteria lower than specified in your existing TSs.

The fact that lower filter efficiencies were assumed in the design basis analysis does not necessarily support reducing filter efficiency test requirements. The surveillance requirement is based on system parameters for a 2-inch deep filter considering residence time and other parameters using clean carbon adsorbers.

In addition, consideration is given to the change in efficiency over time so that there will be reasonable assurance that the filter will have the required efficiency at the end of the test interval, as well as at the beginning of the test interval. Performance of carbon adsorbers at other efficiencies as a result of depletion of adsorber sites over the time of the test interval have not been evaluated. Please justify the acceptability of reducing the testing criteria in your existing TS.

Enclosure

Millstone Power Station, Unit No. 3 cc:

Lillilan M. Cuoco, Esquire Senior Resident Inspector Senior Counsel Millstone Power Station Dominion Resources Services, Inc. c/o U.S. Nuclear Regulatory Commission Rope Ferry Road P. O. Box 513 Waterford, CT 06385 Niantic, CT 06357 Edward L. Wilds, Jr., Ph.D. Mr. G. D. Hicks Director, Division of Radiation Director - Nuclear Station Safety Department of Environmental Protection and Licensing 79 Elm Street Dominion Nuclear Connecticut, Inc.

Hartford, CT 06106-5127 Rope Ferry Road Waterford, CT 06385 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Ms. Nancy Burton 475 Allendale Road 147 Cross Highway King of Prussia, PA 19406 Redding Ridge, CT 00870 First Selectmen Mr. William D. Meinert Town of Waterford Nuclear Engineer 15 Rope Ferry Road Massachusetts Municipal Wholesale Waterford, CT 06385 Electric Company Moody Street Mr. P. J. Parulis P.O. Box 426 Manager - Nuclear Oversight Ludlow, MA 01056 Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Mr. J. Alan Price Waterford, CT 06385 Site Vice President Dominion Nuclear Connecticut, Inc.

Mr. W. R. Matthews Rope Ferry Road Senior Vice President - Nuclear Operations Waterford, CT 06385 Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Mr. Chris Funderburk Waterford, CT 06385 Director, Nuclear Licensing and Operations Support Mr. John Markowicz Dominion Resources Services, Inc.

Co-Chair 5000 Dominion Boulevard Nuclear Energy Advisory Council Glen Allen, VA 23060-6711 9 Susan Terrace Waterford, CT 06385 Mr. David W. Dodson Licensing Supervisor Mr. Evan W. Woollacott Dominion Nuclear Connecticut, Inc.

Co-Chair Rope Ferry Road Nuclear Energy Advisory Council Waterford, CT 06385 128 Terry's Plain Road Simsbury, CT 06070

Millstone Power Station, Unit No. 3 cc:

Mr. S. E. Scace Assistant to the Site Vice President Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Mr. M. J. Wilson Manager - Nuclear Training Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Mr. A. J. Jordan, Jr.

Director - Nuclear Engineering Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Mr. S. P. Sarver Director - Nuclear Station Operations and Maintenance Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385

Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING USE OF ALTERNATE SOURCE TERM (TAC NO.

MC3333)

Dear Mr. Christian:

By letter dated May 27, 2004, you requested an amendment to the technical specifications for the Millstone Power Station, Unit No. 3. The proposed amendment would allow the use of an alternate source term.

The Nuclear Regulatory Commission staff has determined that the enclosed questions must be addressed before we can complete our review. These questions were forwarded electronically to Mr. Paul Willoughby of your staff on December 6, 2004. Additionally, they were discussed in a telephone call with Mr. Willoughby and other members of your staff on December 14, 2004. I understand that you intend to respond to this request for additional information within 30 days of the date of this letter. If you have any questions, I can be reached at (301) 415-1494.

Sincerely,

/RA/

George F. Wunder, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-423 cc: See next page

Enclosure:

Request for Additional Information DISTRIBUTION:

PUBLIC CRaynor ACRS PDI-2 R/F GWunder GMatakas DRoberts OGC DLPM DPR ADAMS Accession Number: ML043510039 OFFICE PDI-2/PM PDI-2/LA PDI-2/SC NAME GWunder CRaynor DCollins for DRoberts DATE 12/28/04 12/27/04 12/29/04 OFFICIAL RECORD COPY