ML050330383

R. E. Ginna Nuclear Power Plant - Addendum to License Amendment Request Regarding Control Room Emergency Air Treatment System (Creats) Modification

ML050330383
Person / Time
Site:	Ginna
Issue date:	01/27/2005
From:	Korsnick M Constellation Energy Group
To:	Skay D Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML050330383 (8)

Text

Maria Korsnick 1503 Lake Road Vice President Ontario, New York 14519-9364 585.771.3494 585.771.3943 Fax maria.korsnickDconstellation.com Constellation Energy R.E. Ginna Nuclear Power Plant January 27, 2005 Ms. Donna M. Skay Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

Subject:

Addendum to License Amendment Request Regarding Control Room Emergency Air Treatment System (CREATS) Modification.

R.E. Ginna Nuclear Power Plant Docket No. 50-244

References:

1. Letter from Robert C. Mecredy (RG&E) to Robert L. Clark (NRC), dated September 30, 2003, uSummary of Public Meeting Between RG&E and NRC Staff Held on August 19, 2003."

2. Letter from Joseph A. Widay (Ginna) to Robert L. Clark (NRC) dated December 3, 2004, "Response to Request for Additional Information (RAI) dated November 9, 2004, Regarding the Proposed Control Room Emergency Air Treatment System (CREATS) Modification."

3. Letter from Joseph A. Widay (Ginna) to Robert L. Clark (NRC) dated December 6, 2004, "Addendum to License Amendment Request, dated March 1,2004."

Dear Ms. Skay:

On September 30, 2003, Ginna submitted Reference I including a commitment to provide CREATS system pressure drop information for Technical Specification 5.5.10.b, Item 1, after initial startup testing of the new system. This information has recently been determined, and is included in Attachment 1.

On the indicated dates for References 2 and 3, Ginna submitted information related to the Control Room Emergency Air Treatment System (CREATS) modification. Subsequent to those submittals, discussions with you and your staff resulted in minor changes and clarifications to proposed Technical Specification sections 3.3.6 (Table 1), 3.7.9, and 5.5.10.b. Attachment 1 to this letter reflects those agreed upon changes. Per your request, only the affected pages are included. This submittal contains no new commitments.

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If you have any questions regarding this submittal, please contact Mr. Mike Ruby at (585) 771-3572.

Very truly yours MaG. orsnick STATE OF NEW YORK TO WIT:

COUNTY OF WAYNE 1,Mary G. Korsnick, being duly sworn, state that I am Vice President - R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this response on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with mpany practice and I believe it to be reliable. //__1 1 /

Subscribed and sworn before me, a Notary Public in and for the State of New York and County of mi Oa OC , this !>1b day of Gag  ? , 2005.

WITNESS my Hand and Notarial Seal: AO 17 t )

Notary Public SHARON L MILLER Ndy Pd*, BthB d New Yft My Commission Expires: MeC6A017755 C*.srD21,20D!P Date Attachments:

1. Revised pages Cc: Ms. Donna M. Skay (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852

Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector Mr. Peter R. Smith New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy NYS Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Carey Fleming Counsel, Generation - Nuclear Constellation Energy 750 East Pratt Street, 17th Floor Baltimore, MD 21202

Attachment 1 Revised Submittal Section 3.3.6 - Correct minor typographical error in Table 3.3.6-1 Section 3.7.9 - Remove Core Alteration Applicability for consistency with Westinghouse Owners Group (WOG) Standard Tech Specs, NUREG 1431. This is consistent with our March 3, 2004 submittal.

Section 5.5.10.b.1 - Provide new value, per commitment in Reference 1.

Section 5.5.1 O.b.4 - Provide new and revised values, per discussion with NRC staff and interpolation of values in Regulatory Guide 1.52, Revision 3, Table 1.

CREATS Actuation Instrumentation 3.3.6 Table 3.3.6-1 CREATS Actuation Instrumentation APPLICABLE LIMITING MODES OR SFl OTHER SAFE SPECIFIED REQUIRED SURVEILLANCE SYSTEM FUNCTION CONDITIONS CHANNELS REQUIREMENTS SE1TINGS(8)

1. Manual Initiation 1,2.3,4, 2 trains SR 3.3.6.3 NA (b)

2. Automatic Actuation Logic and 1,2,3,4, 2 trains SR 3.3.6.5 NA Actuation Relays (b)

3. Control Room Radiation Intake 1,2,3,4, 2 SR 3.3.6.1 s .57 mR/hr Monitors (b) SR 3.3.6.2 SR 3.3.6.4

4. Safety Injection Refer to LCO 3.3.2, 'ESFAS Instrumentation," Function 1, for all Initiation functions and requirements.

(a)

A channel is OPERABLE when both of the following conditions are met:

1. The absolute difference between the as-found Trip Setpoint (TSP) and the previous as-left TSP is within the COT Acceptance Criteria. The COT Acceptance Criteria is defined as:

las-found TSP - previous as-left TSPI s COT uncertainty The COT uncertainty shall not Include the calibration tolerance.

2. The as-left TSP is within the established calibration tolerance band about the nominal TSP. The nominal TSP is the desired setting and shall not exceed the Limiting Safety System Setting (LSSS). The LSSS, COT uncertainty, and the established calibration tolerance band are defined in accordance with the Ginna instrument setpoint methodology. The channel Is considered operable even if the as-left TSP is non-conservative with respect to the LSSS provided that the as-left TSP is within the established calibration tolerance band.

(b) During movement of irradiated fuel assemblies R.E. Ginna Nuclear Power Plant 3.3.6-3 Amendment

CREATS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Control Room Emergency Air Treatment System (CREATS)

LCO 3.7.9 Two CREATS Trains shall be OP ERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, I During movement of irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREATS train A.1 Restore CREATS train to 7 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met in MODE 1, 2, 3, or 4.

B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C. Required Action and C.1 Suspend movement of Immediately associated Completion irradiated fuel assemblies.

Time of Condition A not met during movement of irradiated fuel assemblies.

D. Two CREATS trains D.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or4.

E. Two CREATS trains E.1 Suspend movement of Immediately inoperable during irradiated fuel assemblies.

movement of irradiated fuel assemblies.

R.E. Ginna Nuclear Power Plant 3.7.9-1 Amendment

CREATS 3.7.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I SR 3.7.9.1 Operate each CREATS filtration train 2 15 minutes. 31 days SR 3.7.9.2 Perform required CREATS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). VFTP I SR 3.7.9.3 Verify each CREATS train actuates on an actual or 24 months simulated actuation signal.

R.E. Ginna Nuclear Power Plant 3.7.9-2 Amendment

PrgasanIaul Programs and Manuals 5.5

b. Control Room Emergency Air Treatment System (CREATS)

1. Demonstrate the pressure drop across the combined HEPA filters, the prefilters, the charcoal adsorbers and the post-filters is < 11 inches of water at a design flow rate (+/- 10%).

2. Demonstrate that an in-place DOP test of the HE PA filter bank shows a penetration and system bypass < 0.05%.

3. Demonstrate that an in-place Freon test of the charcoal adsorber bank shows a penetration and system bypass J < 0.05%, when tested under ambient conditions.

4. Demonstrate that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows a methyl iodide penetration of less than 1.5% when tested in accorda nce with ASTM D3803-1989 at a test temperature of 300C (86 0 F), a relative humidity of 95%, and a face velocity of 61 ft/min.

c. SFP Charcoal Adsorber System

1. Demonstrate that the total air flow rate from the charcoal adsorbers shows at least 75% of that measured with a complete set of new adsorbers.

2. Demonstrate that an in-place Freon test of the charcoal adsorbers bank shows a penetration and system bypass

< 1.0%, when tested under ambient conditions.

3. Demonstrate that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows a methyl iodide penetration of less than 14.5% when tested in accord ance with ASTM D3803-1989 at a test temperature of 300C (860 F) and a relative humidity of 95%.

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

5.5.11 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the waste gas decay tanks and the quantity of radioactivity contained in waste gas decay tanks. The gaseous radioactivity quantities shall be determined following the methodology in NU REG-0133.

The program shall include:

R.E. Ginna Nuclear Power Plant 5.5-6 Amendment