Text

Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term
	ML050900165
Person / Time
Site:	Clinton
Issue date:	03/30/2005
From:	Jury K; AmerGen Energy Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-05-033
	Download: ML050900165 (56)
	v • d • e

{{#Wiki_filter:RS-05-033 10 CFR 50.90 March 30, 2005 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 References : Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Subject : Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term (2) Letter from U. S. NRC to John L. Skolds (AmerGen Energy Company, LLC), "Clinton Power Station, Unit 1 - Corrected Request for Additional Information Regarding Alternative Source Term Submittal (TAC No. MB8365)," dated November 18, 2003 Letter from Michael J. Pacilio (AmerGen Energy Company, LLC) to U. S. NRC, "Request for License Amendment Related to Application of Alternative Source Term," dated April 3, 2003 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 (4) 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 Alternative Source Term," dated December 17, 2004 In Reference 1, AmerGen Energy Company, LLC (AmerGen) submitted a request for a change to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-62 for Clinton Power Station (CPS). Specifically, the proposed change is requested to support 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.

March 30, 2005 U. S. Nuclear Regulatory Commission Page 2 The NRC, in Reference 2, provided AmerGen with a request for additional information. The initial response to this request was provided in Reference 3. The response to Question 1, provided in Reference 3, indicated that ArnerGen would be revising the piping deposition calculation supporting the AST loss of coolant accident (LOCA) analysis to use the well-mixed modeling assumptions identified in NRC Staff Report AEB-98-03, "Assessment of the Radiological Consequences for the Perry Pilot Plant Application Using the Revised (NUREG-1465) Source Term." As a result of the need to perform this calculation revision, AmerGen committed to provide the response to Questions 4, 5, and 12 following completion of the reanalysis. Subsequent to receipt of Reference 2, the NRC requested additional information concerning the proposed approach for the reanalysis effort. This request was provided electronically from Douglas V. Pickett (U. S. NRC) to Timothy A. Byam (AmerGen) on May 4, 2004. Specifically, the NRC was concerned with the possibility of a main steam line break and the effect this would have on the deposition assumed in the main steam piping, as well as the assumed mixing rate between the drywell and containment during the first 2 hours of the LOCA. AmerGen committed to address these issues as part of the LOCA reanalysis. In addition to the above, the NRC also requested additional information related to crediting the standby liquid control system for pH control of the suppression pool and included a request for additional information concerning filter test criteria. This request was provided electronically from Douglas V. Pickett (U. S. NRC) to Timothy A. Byarn (AmerGen) on March 25, 2004. The response to the request for crediting the standby liquid control system for pH control in the suppression pool was provided in Reference 4. As stated in Reference 4, AmerGen indicated that the LOCA reanalysis would address the assumptions for filter test criteria and that the response to the request for information concerning the filter test criteria would be provided as part of the response to the requests in Reference 2. ArnerGen has completed the revision of the AST LOCA analysis. Attachment 1 to this letter provides the requested information associated with the LOCH reanalysis. provides the tables from the original amendment request revised to reflect changes based on the reanalysis. There are no regulatory commitments contained in this letter. AmerGen has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Reference 1. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. If you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2804.

March 30, 2005 U. S. Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of March 2004. Respectfully, Keith R. Jury Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC Attachments: 1. Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term

2. Revised Inputs, Assumptions, Results, and Regulatory Guide 1.183 Conformance Tables cc:

Regional Administrator - NRC Region III NRC Senior Resident Inspector - Clinton Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term The following requests (i.e., 4, 5, and 12) are from NRC letter to John L. Skolds (AmerGen Energy Company, LLC), "Clinton Power Station, Unit 1 - Corrected Request for Additional Information Regarding Alternative Source Term Submittal (TAC No. MB8365)," dated November 18, 2003. Request 4: On Page 11 of Attachment 2 to the submittal, the second paragraph states that AmerGen has used the Brockmann-Bixler model for main steamline deposition. The discussion and the data in Table 6 are insufficient to support staff confirmation. Please provide the following information.

a.

A single-line sketch of the four main steamlines and the isolation valves. Annotate this sketch to identify each of the control volumes assumed by AmerGen in the deposition model.

b.

A tabulation of all of the parameters input into the Brockmann-Bix/er model for each control volume shown in the sketch (and time step) for which AmerGen is crediting deposition. This includes: Flow rate Gas pressure Gas temperature Volume Inner surface area Total pipe bend angle ATTACHMENT 1 C. For each of the parameters in 4.b, provide a brief derivation and an explanation why that assumption is adequately conservative for a design-basis calculation. Address changes in parameters over time, e.g., plant cooldown.

d.

Since the crediting of main steamline deposition effectively establishes the main steam piping as a fission product mitigation system, the staff expects the piping to meet the requirements of an engineered safety feature system, including seismic and single-failure considerations. Your submittal does not appear to address a single-failure of one of the main steam isolation valve (MSIVs). Such a failure could change the control volume parameters that are input to the deposition model. Previous implementations of main steam deposition have been found acceptable only if the licensee had modeled a limiting single-failure. Please explain why AmerGen feels that such a limiting failure need not be considered.

e.

Please confirm that the main steam piping and isolation valves that establish the control volumes for the modeling of deposition were designed and constructed to maintain integrity in the event of the safe shutdown bask; earthquake for Clinton. If the design-basis for the piping and components does not include integrity during earthquakes, please provide an explanation of how the Clinton design satisfies the prerequisites of the staff-approved NEDC-31858P-A, "BWROG Report for Increasing MSIV Leakage Rate Limits and Elimination of Leakage Control Systems." If piping systems and components at Clinton were previously found by Page 1 of 11

ATTACHMENT I Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term the staff to be seismically rugged using the methodology of this Boiling Water Reactor Owners Group report, please provide a specific reference to the staffs approval. On page 24 of 30 in Table 2, you state that your submittal is in compliance with Paragraph 6.3 of Appendix A to regulatory guide (RG) 1.183, and reference the RADTRAD Brockman-Bixler approach apparently as establishing that conformance. However, Paragraph 6.3 of RG 1.183 states that the model should be based on well-mixed volumes, but other models such as slug flow may be used if justified. The Brockman-Bixler model is a slug-flow model. This paragraph did not endorse RADTRAD as an acceptable approach. RG 1.183 states that main steamline deposition will be considered on a case-by-case basis. The staff documented its evaluation of the first application of main steamline deposition credit in an alternate source term in Appendix A of the staff report: AEB-98-03, "Assessment of the Radiological Consequences for the Perry Pilot Plant Application using the Revised (NUREG-1465) Source Term." The methodology of this report, which can be found online in ADAMS at ML011230531, was used by at least two additional licensees. The staff did accept one application of plug flow in which the licensee has committed to maintaining a seismically rugged drain path from the 3rd MSIV to and through the condenser. This safety evaluation is on ADAMS at ML011660142. Please provide a justification for your proposed modeling approach or re-perform the analyses. Response 4: As committed to in the AmerGen Energy Company, LLC (AmerGen) letter dated December 23, 2003 (Reference 1), AmerGen has revised the alternative source term (AST) loss of coolant accident (LOCA) analysis. As part of this calculation revision, the AST LOCA calculation pipe deposition credit has been revised to replace the Brockmann-Bixler methodology for deposition of iodine in piping with a nodalized, well-mixed model, consistent with that used and described in P&C staff report AEB-98-03. In addition, for added conservatism, a worst-case rupture of the longest credited steam line upstream of the inboard IVISIV is assumed, thereby making that line segment non-mechanistically unavailable for deposition credit. The following is provided in support of the NRC Request 4. 4.a A single-line sketch of the four main steamlines and the isolation valves is provided as attached Figure 4a, "Post-LOCA IVISIV Leakage Pathway Nodalization." This figure has been annotated to identify each of the control volumes assumed in the deposition model. 4.b Tabulation of the key deposition parameters input into the model for each control volume, as a function of time into the accident, is provided in the attached Table 1, "Parameters for IVISIV Piping Deposition Credit." Pipe bend angles are not credited, and therefore are not included in this table. For additional detail, a spreadsheet (including formulas) of the piping volume and surface areas, flow rate, gas pressure and temperature correction factors, and deposition Page 2 of 11

ATTACHMENT 1 Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term decontamination factors (and filter efficiency equivalents as RADTRAD input) is provided as Appendix A to this attachment. 4.c For each of the parameters in Table 1, a brief derivation and an explanation as to why that assumption is conservative for the AST LOCH calculation is provided. Where relevant the effects of timing are also included in Table 1. For plant cooldown, additional timing considerations are documented in page 1 of the spreadsheet provided in Appendix A to this attachment. 4.d The Clinton Power Station (CPS) main steam piping does meet the requirements of an engineered safety feature system including seismic and single-failure considerations. As noted in Table 1 and shown on Figure 4a, limiting single failures of be main steam isolation valves (MSIVs) have been considered in the AST LOCH reanalysis. Outboard MSIV failure was conservatively assumed as the single active failure since this maximizes the volume of piping in which the fluid is depressurized. This in turn minimizes deposition. For conservatism, for consistency with AEB-98-03, and because of limits in the number of RADTRAD compartments, this treatment is used for all steam lines. In addition, as described in Table 1, all of this modeled piping is Seismic Category 1. 4.e The main steam piping and isolation valves were designed and constructed to maintain integrity in the event of a safe shutdown basis earthquake. As described in CPS Updated Safety Analysis Report (USAR) Section 5.4.9, the main steam lines have been designed to accommodate operational stresses, such as internal pressures, safe shutdown earthquake, and other dynamic loads, without a failure that could lead to the release of radioactivity in excess of the guideline values in published regulations. The main steam piping from the reactor vessel to the shutoff valves is designed and constructed as Seismic Category 1. The main steam isolation valve installations are designed as Seismic Category I equipment as described in CPS USAR Section 5.4.5. The valve assembly is manufactured to withstand the safe shutdown earthquake forces applied at the mass center of the extended mass of the valve operator, assuming the cylinder/spring operator is cantilevered from the valve body and the valve is located in a horizontal run of pipe. The parts of the main steam isolation valves that constitute a process fluid pressure boundary are designed, fabricated, inspected, and tested as required by the ASME Code, Section Ill. 4.f AmerGen has revised the LOCA analysis including the piping deposition and plateout model used (see Appendix A of this attachment). Modeling was done using RADTRAD with the piping treated as well mixed volumes. As noted in Request 4.f, this approach is consistent with Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," Appendix A and AEB-98-03. The original inputs, assumptions and results of the AST LOCA analysis were provided in the license amendment request submitted in the AmerGen letter dated April 3, 2003 (Reference 2). The revised AST COCA calculation utilized updated inputs and assumptions to determine the dose contributors and radiological consequences Page 3 of 11

ATTACHMENT 1 Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term associated with the LOCA event. As a result of the LOCA reanalysis, Tables 4, 5, 6, 10 and 11 of Attachment 2 to Reference 2, have been revised to reflect the new inputs, assumptions, and results. In the AmerGen response to Request 1, as provided in the Attachment to Reference 1, an error in the wording in Table 4 was identified. AmerGen committed in Reference 1 to provide a revised Table 4 correcting this error. Therefore, correction of the wording error is also reflected in the attached Table 4. The revised tables are provided in Attachment 2 to this letter and supersede the versions provided in Reference 2. Attachment 5 to Reference 2 provided tables documenting CPS conformance with RG 1.183. As a result of the revision to the LOCA analysis, the table showing conformance with RG 1.183 Appendix A (Loss of Coolant Accident) was updated. The revised portions of this table are also provided in Attachment 2 to this letter and supersede the portions of Attachment 5 to Reference 2. Request 5: Provide the corresponding information requested in Item 4 for the containment purge penetrations. Response 5: As discussed above in the response to Request 4, AmerGen committed in Reference 1 to revise the AST COCA analysis. As part of this revision, the pipe deposition credit has been revised to replace the Brockmann-Bixler methodology for deposition of iodine in piping with a nodalized, well-mixed model, consistent with that used and described in NRC staff report AEB-98-03. The following is provided in support of NRC Request 5. 5.a A single-line sketch of the two containment purge penetrations and their isolation valves is provided as attached Figure 5a, "Post-LOCA Purge Penetration Leakage Pathway Nodalization." This figure has been annotated to identify each of the control volumes assumed in the deposition model. 5.b The tabulation of the key deposition parameters input into the model for each control volume, as a function of time into the accident, is provided as Table 2, "Parameters for Purge Piping Deposition Credit." Pipe bend angles are not credited, and therefore are not considered. For additional detail, a spreadsheet (including formulas) of the piping volume and surface areas, flow rates, pressures and temperatures utilized, and deposition decontamination factors (and filter efficiency equivalents as RADTRAD input) is provided as Appendix B to this attachment. 5.c For each of the parameters identified in Table 2, a brief derivation and an explanation as to why that assumption is conservative for the AST LOCH calculation is also provided. Where relevant the effects of timing are also included in Table 2. Additional timing considerations are documented in page 1 of the spreadsheet provided in Appendix B of this attachment. Page 4 of 11

ATTACHMENT 1 Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term 5.d The CPS containment purge piping does meet the requirements of an engineered safety feature system including seismic and single-failure considerations. As noted in Table 2 and shown on Figure 5a, failure of the outside containment isolation valve on each purge line was conservatively assumed as the single active failure. This assumption maximizes the flow and imizes the deposition in the piping. The conservative and NRC-recommended well-mixed methodology of AEB-98-03 is used for deposition modeling. In addition, as described in Table 2, all of the credited piping is Seismic Category 1. 5.e CPS USAR Section 9.4.6.1.1.2 states that the primary containment purge system isolation valves at the containment penetration and the intermediate pipe between the valves are required during and after all abnormal station operating conditions to maintain the containment boundary integrity. This part of the system is designed as Seismic Category 1. Seismic Category I systems and components are analyzed under the loading conditions of the safe shutdown earthquake. 5.f AmerGen has revised the LOCA analysis including the piping deposition and plateout model used (see Appendix B of this attachment). Modeling was done g RADTRAD with the piping treated as well mixed volumes. This approach is consistent with RG 1.183, Appendix A and AEB-98-03. Tables 4, 5, 6, 10 and 11 from Attachment 2 of Reference 1 have been updated to reflect the changes for the containment purge lines that support the revised LOCA analysis. These revised tables are provided in Attachment 2 to this letter. The affected portions of the table, addressing conformance with RG 1.183 Appendix A (i.e., to Reference 1), have been revised and are also provided in Attachment 2. Request 12: In Table 5 of Attachment 2 to the submittal, the last table entry refers to inleakage control necessary to maintain constant iodine protection factor (IPF). Please explain how these data are being used to show compliance with control room habitability requirements. Were these two expressions used to establish the 650 cfm filtered and 600 cfm unfiltered inleakage rates shown in Table 5? If these expressions were used as pad of me basis for the inleakage rates, please provide the following information:

a.

The derivation of the numeric constants in the two expressions.

b.

An explanation of how these expressions were verified and validated. C. An explanation of how AmerGen resolved the IPF caveat provided in Footnote 15 on Page 1.183-98 of RG 9.983 in finding (as expressed in Table I of Attachment 5 of the submittal) that the AmerGen submittal conformed with Paragraph 4.2.3 of RG 1.183. Page 5 of 11

ATTACHMENT 1 Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term Response 12: CPS has a pressurized control room with vestibule entries to minimize inleakage potential during ingress/egress. Therefore, leakage is generally expected to be out of the control room, and even ingress/egress intake effects will be minimized due to mixing and dilution in the vestibule air. However, a portion of the control room heating, ventilating, and air conditioning (HVAC) recirculation filter inlet ducting is at a negative pressure with respect to the surrounding air space, and so there is some potential for inleakage that would be filtered by the recirculation filters. The November 2004 tracer gas test results provided to the NRC in Reference 3 demonstrate that there is no measurable unfiltered inleakage into the CPS control room. Therefore, the AST LOCA calculation has been re-analyzed to assume no unfiltered inleakage coupled with a filtered inleakage allowance of 2250 cubic feet per minute (cfm), which bounds the measured values. This inleakage allowance is an assumed value shown to be acceptable by the revised LOCA analysis. Associated with this filtered inleakage, an iodine removal efficiency credit of 68% for all chemical forms is used. This efficiency accounts for 2% bypass and 30% penetration for the 70% efficient carbon (charcoal) recirculation filter. Additionally, a conservative approximation to convert between filtered and unfiltered inleakage flow parameters while maintaining the same or lower post-LOCA dose consequences was developed to give flexibility in future applications. The basis of this approximation is that with a total nominal bypass of the inleakage filtration of 32%, 0.32 times every unit of filtered inleakage flow equals 1 unit of unfiltered inleakage on a conservative dose consequence bats. Therefore, (IDF - IKF)

0.32 = ICU where:

IDF = Design Basis Filtered Inleakage IKF = Known Filtered Inleakage Icu = Calculated Allowable Unfiltered Inleakage As an example using the previously assumed 650 cfm of filtered inleakage, the conservative allowable unfiltered inleakage would be calculated to be the following. (2250 -- 650)

0432 =: 512 (tam This simplified conversion has been confirmed to be conservative using RADTRAD sensitivity analyses. This conversion was also shown to be conservative while avoiding steady-state control room modeling concerns as stated in Footnote 15 of RG 1.183.

This correlation replaces the approach based on iodine protection factor (IPF) used previously. The questions above are therefore considered no longer applicable. Table 5 of Attachment 2 to Reference 2 has been revised to reflect the new relationship for determining the control room unfiltered inleakage allowance. The revised Table 5 is provided in Attachment 2 of this letter and supersedes the Table 5 provided in Reference

2.

Page 6 of 11

ATTACHMENT 1 Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term The following requests were provided electronically from Douglas V. Pickett (U. S. NRC) to Timothy A. Byam (AmerGen) on May 4, 2004. In its RAI dated October 30, 2003, the staff requested additional information regarding several aspects of AmerGen's DBA analyses supporting the proposed license amendment. The staff issued a corrected set K fits on November 18. Questions four and five addressed AmerGen's modeling of fission product deposition in piping systems. Those questions challenged the appropriateness of the analysis approach used by the AmerGen contractor. The staff had previously discussed similar issues with analyses performed by the same contractor for DTE Energy's Fermi facility. AmerGen did not request to discuss the 1141 questions with the staff but indicated that they would respond to the questions. By letter dated December 23, 2003, AmerGen provided a response to the RAI, deferring the responses for Questions 4, 5, and 12 to a later correspondence. In the intervening period, DTE Energy outlined, via teleconferences, a re-analysis approach intended to address the staff's concerns regarding fission product deposition in piping. The staff indicated that the proposed approach appeared to address many of the staff's concerns, but would not take a position on its acceptability until the staff had the opportunity to review the docketed re-analyses. Shortly thereafter, the staff obtained information that two aspects of DTE Energy's proposed re-analysis approach were questionable. Since the DTE Energy and AmerGen re-analyses were being performed by the same contractor, it was determined that the following concerns apply to the AmerGen re-analyses: Request 7 : With regard to AmerGen's modeling of the deposition of fission products in piping, the staff is of the opinion that credit for deposition cannot be taken for one of the main steam lines between the reactor pressure vessel and the inboard main steam isolation valve (MSIV). AmerGen's analysis credited deposition in all four steam lines. NRC regulations and regulatory guidance require an evaluation of a spectrum of potential break sizes and locations within the reactor coolant pressure boundary with regard to emergency core coolant system (ECCS) performance. Analyses of design basis LOCA radiological consequences stylistically assume that the ECCS fails resulting in the substantial release of fission products, regardless of break size or location. Although the rupture of recirculation system piping was used as the limiting case in the licensing of Clinton, AmerGen's proposal to credit fission product deposition in the main steam lines raises the possibility that a rupture of one of the main steam lines upstream of the inboard MSIV could be more limiting since crediting deposition in the ruptured line would be inappropriate. The in-containment main steam line assumed to fail should be selected so as to minimize the assumed deposition credit. Note that the assignment of the limiting single failure of an MSIV to close may change as a result of the assumed main steam line failure. Please update your analyses and submittal or provide further justification why you believe your proposed approach is adequately conservative. Page 7 of 11

ATTACHMENT 1 Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term Response 1 : As described above in the response to Request 4, the analyses have been updated to incorporate an assumed rupture of the limiting main steam line inside containment with an assumed limiting single failure. As proposed in the requested Technical Specification (TS) change and described in Reference 2, the analyses assume IVISIV leakage at a maximum of 100 standard cubic foot per hour (scfh) per steam line and a total of no more than 250 scfh in all four lines. Therefore, piping deposition credit is minimized by maximizing flow through the shorter team lines and by the assumption of the LOCK pipe rupture between the reactor vessel and inboard IASIV. Intact main steam lines B and C are the longest. The revised analysis assumes no flow through line C and the in-containment rupture in line B. As described in Table 1, the analysis assumes 100 scfh through line A, 50 scfh through line D, and 100 safh through the remainder of the ruptured line B. Each of the main steam lines with assumed flow (i.e., lines A, B, and D) is modeled as three, well mixed nodes. As shown on Figure 4a, the first node represents the piping from the reactor pressure vessel to the inboard IVISIV, the second node represents the piping from the inboard IVISIV to the outboard IVISIV, and the third node represents the piping from the outboard IVISIV to the Turbine/Auxiliary Building (secondary containment) wall. This nodalization is conservative since it results in the depressurization of the penetration piping section between the inboard and outboard IVISIVs; therefore, higher flow velocities leading to less settling and deposition are applied in the nodes downstream of the inboard IVISIV. In the updated analyses, a main steam line break is assumed to be located in the first node of main steam line B. Intact line B is the longest steam line and therefore, represents the worst scenario since it minimizes the assumed deposition by not crediting any deposition in the first node of that line. In addition, an outboard IVISIV failure is assumed as the single active failure since this maximizes the volume of piping in which the fluid is depressurized. Table 1 provides a summary of the main steam line deposition credit parameters used in the revised analysis. Request 2: AmeWen's modeling of the MSIV leakage pathway appears to had the dy,well and primary containment as a single well-mixed volume from the start of the event. This assumption may not be supportable during the early stages of the event. The initial bAwdown of the reactor coolant system would have occurred prior to the onset of the in vessel release phase. Thus, the driving force for mixing between the two volumes will be less. Since the LOCA break communicates with the drywefi volume only the use of the total containment free volume has the effect of reducing the concentration of the fission products available for release via MSIV leakage, a non-conservative situation. Because of this uncertainty, the staff deterministically assumes that complete mixing does not occur until 2 hours when core reflood is projected. For BWR Mark /// containments, the staff has previously found a mixing rate of 3000 cfm between the drywell and containment acceptable for the 0 to 2-hour period. Please update your analyses and submittal or provide further justification why you believe your proposed approach is adequately conservative. Page 8 of 11

ATTACHMENT 1 Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term Response 2 : As stated in Table 2 of Attachment 5 to Reference 2, CPS is a BWR with a Mark III Containment. RG 1.183, Appendix A, Section 3.7 states that for BWRs; with Mark III containments, the leakage from the drywell into the primary containment should be based on the steaming rate of the heated reactor core, with no credit for core debris relocation. This leakage should be assumed during the two-hour period between the initial blowdown and termination of the fuel radioactivity release. This is the approach that AmerGen used in the CPS AST LOCA analysis in Reference 2 and therefore, there was no need to update the analysis. As described in Reference 2, AmerGen used a drywell bypass leakage rate of 3000 cfm for the first two hours, followed by an assumption of well mixed drywell-containment conditions thereafter. This approach is consistent with the approach reviewed and approved for the Perry Nuclear Power Plant (also a Mark III containment) in Reference 4. The following requests were provided electronically from Douglas V. Pickett (U. S. NRC) to Timothy A. Byam (AmerGen) on March 25, 2004. Responses to the additional RAI's on Filter Test Criteria were deferred as part of the AmerGen response provided in Reference 5. The following response is provided for the deferred requests. Request! 1: Regulatory Guide 1.52, establishes the criterion for penetration in the laboratory testing of ESF filter systems. In Revision 2 (referenced in your specification), the allowable penetration for a 4 inch bed filter (SGTS or CRV Makeup Filter) is 0.1751. Thus the current technical specification for these two filters is in compliance with the Regulatory Guide. In Revision 3 of Regulatory Guide 1.52, some relaxation was allowed and the penetration criterion for a 4 inch bed during a laboratory test was increased to 0.5%. The staff would find compliance with either Revision 2 or Revision 3 to be acceptable. In the submittal, a change for an allowable penetration to 1.5% was requested. Please justify why it is necessary to deviate from the Regulatory Guide criterion for laboratory testing. Request 2: Regulatory Guide 1.52, establishes the criterion for penetration in the laboratory testing of ESF filter systems. In Revision 2 (referenced in your specification), the allowable penetration for a 2 inch bed filter (CR V Recirculation filter) is less than I%. In Revision 3 of Regulatory Guide 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%. The current technical specification for this filter which allows 6% is not in compliance with the Regulatory Guide. In the submittal, a change for an allowable penetration to 15% was requested. Please justify why it is necessary to increase the testing criterion which exceeds the requirements of Regulatory Guide 1.52. Response I and 2: The proposed allowable penetration acceptance criteria are based on the reduced credit taken for filter efficiency in addition to the safety factors allowed in accordance with NRC Generic Letter (GL) 9902, "Laboratory Testing of Nuclear-Grade Activated Charcoal." GL 99-02 indicates that the test method referred to in RG 1.52, "Design, Testing, and Page 9 of 11

ATTACHMENT 1 Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," Revision 2 (i.e., Test 5.b from Table 5-1 of ANSI N509-1976) provides a less accurate and less realistic indication of the charcoal's capability than testing performed in accordance with American Society for Testing and Materials (ASTM) D3803-1989, "Standard Test Method for Nuclear-Grade Activated Carbon." GL 99-02 states that testing nuclear-grade activated charcoal to standards other than ASTM D3803-1989 does not provide assurance for complying with the current licensing basis as it relates to the dose limits of GIDC 19 and Subpart A of 10 CFR 100. CPS currently performs charcoal testing in accordance with the requirements of GL 99-02 and tests the charcoal adsorber samples in accordance with ASTM D3803-1989. To provide guidance for addressing filter testing in plant TS, Attachment 2 to GL 99-02 provides sample TS for use by plants with Improved Standard Technical Specifications. This TS wording has been incorporated into the current approved version of the BWR/6 Standard Technical Specifications (i.e., NUREG-1434 Revision 3). Attachment 2 to GL 99-02 and NUREG-1434 provide an equation for determining the appropriate penetration acceptance criterion in the TS for the representative sample tested in accordance with ASTM D3803-1989. As noted in Attachment 2 to Reference 2, the revised penetration acceptance criteria were based on the reduced credit taken for filter efficiency, and safety factors allowed in accordance with GL 99-02. The following equation, taken from GL 99-02, was used to determine the proposed penetration acceptance criteria. Allowable = (100% - Methyl Iodide Efficiency for charcoal in Licensee Accident Analysis) Penetration Safety Factor As stated in GL 99-02, when testing is performed in accordance with ASTIVI D3803-1989 at a temperature of 300C and 95% relative humidity (or 70% relative humidity with humidity control), the NRC will accept a safety factor ~! 2. Therefore, based on the above formula and assuming a charcoal efficiency in the radiological analysis of 97% (as documented in Attachment 2 to Reference 2), the allowable penetration for the standby gas treatment system and control room ventilation system make up filter unit was determined to be the following. Allowable penetration = (100-97) / 2 = 1.5% Similarly, assuming a charcoal efficiency in the radiological analysis of 70%, the allowable penetration for the control room ventilation system recirculation filter was determined to be the following. Allowable penetration = (100-70)/2 = 15% In summary, the proposed filter penetration acceptance criteria were identified based on the direction provided in GL 99-02. The GL methodology was used to determine the allowable penetration based on the filter efficiency and an acceptable safety factor. The Page 10 of 11

ATTACHMENT I Additional Information Supporting the Request for License Amendment Related to Application of the Alternative Source Term proposed filter penetration acceptance criteria are consistent with GL 99-02 and the wording in the Standard Technical Specifications. References : 1 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

2.

Letter from Michael J. Pacilio (AmerGen Energy Company, LLC) to U. S. NRC, "Request for License Amendment Related to Application of Alternative Source Term," dated April 3, 2003

3.

Letter from Robert S. Bement (AmerGen Energy Company, LLC) to U. S. NRC, "Control Room Envelope Unfiltered Air Inleakage Test Results in Response to Generic Letter 2003-01, 'Control Room Habitability'," dated February 8, 2005 Letter from U. S. NRC to Lew W. Myers (FirstEnergy Nuclear Operating Company), "Amendment No. 103 to Facility Operating License No. NPF Perry Nuclear Power Plant, Unit 1 (TAC No. M96931)," dated March 26, 1999

5.

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 Alternative Source Term," dated December 17, 2004 6. NEDC-32091, WSIV Leakage Radiological Dose Assessment Code Version 1.1 - Users Manual," Revision 0 dated August 1992

7.

NEDC-31858P, "BWROG Report for Increasing MSIV Leakage Rate Limits and Elimination of Leakage Control Systems," dated September 1993 Page 1 1 of 11

Table 1 Parameters for MSIV Piping Deposition Credit Parameter Value(s) Bats, Conse"atisms Leakage Distribution 100 scfh in MS Line B Leakage limits are 250 scfh total, and 100 scfh for any 100 scfh in MS Line A one line. Piping deposition credit is minimized by 50 scfh in MS Line D maximizing flow through shorter lines, and by the 0 scfh in MS Line C assumption of the LOCA pipe rupture to be located in the first node of the longest Line B (prior to the break), with no deposition credited in this node. When intact, lines B and C are the longest. Nodalization ; Three node treatment is used for each Outboard MSIV failure is assumed as the Single Active Single Active Failure steam line in which flow occurs. The Failure since this maximizes the volume of piping in Assumptions; Seismic Design first node is from the reactor vessel to which the fluid is depressurized. This in turn minimizes of Credited Piping the inboard MSIV. The second node is deposition. The conservative and NRC-recommended the penetration piping from the inboard well-mixed methodology of AEB-98-03 is used for MSIV to the assumed failed outboard deposition modeling. For conservatism, for consistency MSIV. The third node is from the with AEB-98-03, and because of limits in the number of outboard MSIV to the Turbine/Auxiliary RADTRAD compartments, this treatment is used for all Building (secondary containment) Wall. steam lines. All of this modeled piping is Seismic The LOCA pipe rupture is conservatively considered to Category 1. be in the first node of Line B, with no deposition credited in this node but full MSIV leakage flow from containment to downstream nodes. Node 1 Piping Volumes and For Aerosol Settling For Aerosols, settling only considers horizontal piping. Surface Areas Credited LINE Vol (ft) Area(m) Settling area is bottom half of horizontal piping. MS A 86 91.5 MS D 86 91.5 No credit is taken for deposition of organics. For Elemental Iodine Deposition LINE Vol (ft) Area(ft2 For elemental, deposition considers total piping area and MS A 157 334 volume. MS D 157 334

Table Parameters for NASIV g Deposition Credit Page 2 of 3 Parameter Value(s) Basis, Conservatisms Node 2 Piping Volumes and For Aerosol Settling For Aerosols, settling only considers horizontal piping. Surface Areas Credited LINE Vol (ft') Area(ft) Settling area is bottom half of horizontal piping. MS A 151 159.9 MS D 151 159.9 MS B 151 159.9 For Elemental Iodine Deposition No credit is taken for deposition of organics. LINE Vol (ft) Area(ft) MS A 151 320 For elemental, deposition considers total piping area and MS D 151 320 volume. MS B 151 320 Node 3 Piping Volumes and For Aerosol Settling For Aerosols, settling only considers horizontal piping. Surface Areas Credited LINE Vol (ft) Area(ft) Settling Area is Bottom Half of Pipe. MS A 117 123.9 MS D 117 123.9 MS B 117 123.9 For Elemental Iodine Deposition No credit is taken for deposition of organics. LINE Vol (ft) Area(ft2) MS A 117 248 For elemental, deposition considers total piping area and MS D 117 248 volume. MS B 117 248 Leak Rate from Containment Leak Rate (cfh) = The methodology, as detailed in BWROG NEDC-32091 through MS Lines for first 24 Measured MSIV Leakage limit (scfh) and NEDC-31858P (References 6 and 7) and hours [Pc,*(T.d/Tc.)] implemented in the Appendix A spreadsheet, accounts for post-LOCA containment response considering partial where: pressures of water vapor, initial containment non-P,= total containment pressure (atm) condensables, plus H2 from Zirconium-Water reaction. T,d= standard temperature, absolute (OR) T,= bulk containment temperature, absolute (OR) Leak Rates LINE (scfh) (cfh) (chn) MS A 100 93.5 1.558 MS D 50 46.7 0.779 MS B 100 93.5 1.558

Table 1 Parameters for MSIV Piping Deposition Credit Parameter Value (s) Basis, Conservatisms, Fluid Temperature for first 24 550 OF The normal operation steam line temperature is used for hours for flow rate and conservatism. deposition velocity assessment Node 1 Flow Rate for first 24 LINES Flow Rate (cfm) Values are as determined from the containment leak rate hours MS A 1158 as documented in Appendix A. MS D 0.779 MS EB 1158 No deposition is credited in Node 1 of MS B. Nodes 2 and 3 Flow Rates for LINES Flow Rate (cfm) Values are conservatively expanded based on initial first 24 hours MS A 1188 steam line pipe wall temperatures of 550 OF, compared MS D 1194 with standard conditions at 68 OF. Therefore, leakage MS B 1188 flow rates in scfh are multiplied by: (550+460)/[(68+460)-60] = 1.913 / 60 = 0.03188 Pressures are conservatively assumed to be atmospheric so the flow is fully exj*anded. Node 1 Leak Rate and flow Leak Roes and how roes are assumed Containment pressures at 24 hours are approximately rates after 24 hours to be reduced to 64% of the initial 18.4 psia (17 psQ) for minimum ECCS in operation. For values after 24 hours. POSIV leakage testing performed at the CPS Pa of 9 PSig, (3.7 / 9)0.5 = 0.64 Conservatively, no credit is taken for the continued pressure reduction after 24 hours, or for the drywell and wetwell pressures well below 9 psig during the first 24 hours after the first approximately one minute of the accident. Nodes 2 and 3 flow rates after Flow rates are assumed to be reduced Flow rates are conservatively expanded based on a 24 hours to 64% of the initial values after 24 conservative representation of steam line pipe wall hours, with steam line wall temperatures indicated from J. E. Cline's August 20, temperatures of 410 OF from 24 to 96 1990 "MSIV Leakage - Iodine Transport Analysis". hours and 200 OF from 96 to 720 hours.

Table 2 Parameters for Purge Piping Deposition Credit Parameter Values) Basis, Conservatisms Leakage Distribution 100% (of 0.16 cfm) through Purge Leakage limit is 0.16 cfm, or 2% L,, per purge line. Penetration 101 100% (of 0.16 cfm) through Purge Penetration 102 Nodalization for AEB-98-03 A one node treatment is used for the air For simplicity and conservatism, only a single node was well mixed modeling ; leakage through the purge lines. The credited due to the small contribution of this pathway to Single Active Failure node is conservatively assumed to be the total calculated dose. Failure of the outside Assumptions; from containment to the outboard containment isolation valve on each line is assumed as Seismic Design of Credited isolation valve. All of the credited the Single Active Failure since this maximizes the flow Piping piping is Seismic Category 1. and minimizes deposition. The conservative and NRC-recommended well-mixed methodology of AEB-98-03 is used for deposition modeling Piping Volumes and Surface For Aerosol Settling For Aerosols, settling only considers horizontal piping. Areas LINE Vol (ft3) Area(ft2) Settling area is bottom half of horizontal piping. Purge Penetration 101 373 259.25 Purge Penetration 102 330 229.45 No credit is taken for deposition of organics. For Elemental Iodine Deposition For elemental, deposition considers total piping area and LANE Vol (ft) Area volume. Purge Penetration 101 373 518.00 Purge Penetration 102 349 486.00

Table ;2 Parameters for Purge Piping Deposition Credit Parameter Value(s) Basis, Conservatisms Leak Rate From Containment CPS isolation valves are tested at a Pa of 9 Psig-to Purge Penetrations Leak Rate = (Total Primary Containment Volume)

0.02 La (0.65 % /day) / 1440 min1day

= 1.754E+06 ft" 0.02

0.0065 / 1440 0.158 cfm, rounded to 0.16 cfm.

LINES Flow Rate (cfm) Purge Penetration 101 0.16 Purge Penetration 102 0.16 Piping Node Flow Rate LINES Flow Rate (cfm) To correct for upstream pressure and temperature Purge conditions, 0.16 scfm is multiplied by (see Appendix B Penetration 101 0.325 for values): Purge Penetration 102 0.325 (14.7 psia+9 psig)(206 + 460) / [(14.7 psia) (68 + 460)] Therefore the flowrate becomes 0.325 cfm. Leak Rate and flow rates after Leak Rates and flow rates are assumed As shown in USAR Figure 6.2-6a, containment 24 hours to be reduced by 50% after 24 hours. pressures at 24 hours are less than 50°l0 of Pa. Conservatively, no credit is taken for the continued pressure reduction after 24 hours, or for the drywell and wetwell pressures well below 9 psig during the first 24 hours after the first approximately one minute of the accident.

Figure 4a : Post-LOCA MSIV Leakage Pathway Nodalization REACTOR PRESSURE VESSEL INBOARD MSIV Note : Aerosol iodine deposition parameters only include horizontal pipe lengths. Flows above correspond to a measured total of 250 scfh distributed as 100 scfh for Lines A & B, and 50 scfh for Line D. Line A: 93.46 cfh NODE 1 Line B: 93.46 cfh ) Line C : No Flow Line D : 46.73 cfh DEPOSITION NOT CREDITED IN FAULTED INBOARD LINE B OUTBOARD MSIV (FAILED) Line A: 191.29 cfh NODE 2 Line B:191.29 cfh )Line C : No Flow Line D : 95.64 cfh SHUT-OFF Line A: 191.29 cfh NODE 3 Line B: 191.29 cfh )Line C : No Flow Line D : 95.64 cfh TURBINE/AUXILIARY (SECONDARY CONTAINMENT) BUILDING WALL

gure 5a : Post-LOCA Purge Penetration Leakage Pathway Nodalization NODE 1 (for Supply Line) Leak Rate : 2% La = 0.16 scfm NODE 1 (for Exhaust Line) Leak Rate: 2% La = 0.16 scfm ISOLATION VALVE (FAILED) SECONDARY CONTAINMENT WALL SECONDARY CONTAINMENT WALL Note: Due to a conservative failed valve assumption on both Lines, the two available nodes are effectively modeled by using only one.

APPENDIX A MSIV Piping Deposition Credit Spreadsheets

of November 18, 2003, Question #4 Page 1 of 1 K L M N O P 0 a - I-o e- .. itOn 3 Inboard A . "inboard B Inboard C Inboard D Penetration A "Penetration B Penetration C I Penetration D Outboard A "Outboard B Outboard C Outboard D 4 Total Pipe Surface Area (ft2 334 Q 397 _- ~ 334 320 320 320 320 248 248 248 248 ©, 'Total Pipe Volume (f03 157 l 0 187 157 f 151 j 151 151 151 117 1 17 117 117 6 'Horizontal Total Pipe Surface Area (_)i 183 0 246 183 320 320 320 j i 320 248 248 248 248 _ 7 Horizontal Settling Pie Surface Area ft2 91.46 0.00 _112103 91.46 159.92 159. 92 ll 159.92 15999. 2 123.89 123.89 123.89 ( 123.89 8 'Horizontal Pie Volume (ft) 86 1 0 116 86 151 151 151 151 117 1 117 _ ! 117 117 9 AAerosol Settling Velocity m/s 1.170E-03 1.170E-03 1.170E-03 1.170E-03 1.170E-03 1.170E-03 1.170E-03 1.170E-03 1.170E-03 1.170E-03 1.170E-03 1.170E-03 10 Aerosol Settling Velocity ftls ! 3.839E-03 3.839E-03 3.839E-03 3.839E-03 j 3.839E-03 3.839E-03 3.839E-03 3.839E-03 3.839E-03 3.839E-03 3.839E-03 3.839E-03 ssElemental Deposition Velocity 0-24hrs (mlsec)! 5.574E -06 5.574E-06 5.574E-06 5.574&06 5.574E-06 5.574E-06 5.574E-06 5.574E-06 j 5.574E-06 5.574E-06 5.574E-06 5.574E-06 °sElemental Deposition Velocity 24-48hrs (mtsec) 1.248E-05 1.248E-05 1.248E-05 1.248E-05 1.245E-05 1.248E-05 1.248E-05 1.248E-05 1.248E-05 1.248E-05 1.248E-05 j 1.248E-05 ©' "Elemental Deposition Velocity 48 "72hrs (m/s 2.897E-05 2.897E-05 2.897E-05 2.897E-05 2.897E-05 2.897&05 2.897E-05 2.897E-05 2.897E-05 2.897E-05 12.897E-05 ! 2.897E-05 14 "Elemental De osition Ye" oci 72-96hrs m/seer ', 4.630E-05 4.630E-05 4.630E-05 4.630E-05 4.630E-05 4.630E-05 4.630E-05 4.630E-05 4.630E-05 4.630E-05 4.630E-05 4.630E-05 15 "Elemental De osition Veloci 96-275hrs mlsec 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7. 945E-05 7.945E-0 5 7.945E-05 16 "Elemental De osition Veloci 275-720hrs mtsec . 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 7.945E-05 17 Elemental De osition Veloci 0-24h,- ft's I j 1.829E-05 1.829E-05 1.829E-05 1.829E-05 1.829E-05 1.829E-05 1.829E-05 1.829E-05 1.829E-05 1.829E-05 1.829E-05 1.829E-05 18 Elemental De osition Velocity 24-48hrs ftlsec 4.095E-05 4.095E-05 4.095E-05 4.095E-05 4.095E-05 4.095E-05 4.095&05 4.095E-05 4.095E-05 4.095E-05 4.095E-05 4.095E-05 Elemental D.... ition Veloci _ 48-72hrs ft/sec j 9.503E-05 9.503E-05 1 9.503E-05 9.503E-05 j 9.503E-05 9.503E-05 9.503E-05 I 9.503E-05 9.503E-05 9.503E-05 9.503E-05 9.503E-05 20 21 Elemental De osition Veloci 72-96hrs ftlsec Elemental Deposition Velocity 96-275hrs ftlsec 1.519E-04 2.607E-04 1.519&04 2.607E-04 1.519E-04 2.607E-04 1.519E-04 2.607E-04 1.519E-04 2.607E-04 ( 1.519E-04 Z607E-04 1.519E-04 2.607E-04 i 1.519E-04 2.607E-04 j 1.519E-04 2.607E-04 1.519E-04 2.607E-04 1.519E-04 2.607E-04 1.519E-04 2.607E-04 22 Elemental e position Velocity 275"720hrs ft/sec ! 2.607E-04 j 2.607E-04 I 2.607E-04 2.607E-04 2.607E-04 2.607E-04 2.607E-04 2.607E-04 2.607E-04 2.607E-04 2.607E-04 2.607E-04 © "Or ganic Deposition Velocity 0-24hrs (mlsec)! 6.208E-09 6.208E-09 6.208E-09 1 6.208E-09 ~ 6.208E-09 ~ 6.208E-09 I 6.208E-09 6-2208E-09 I i i 9 I 6.208E--96,208E-09 6.208E-09 6.208E-09 124 ] "Organic Deposition Velocity 24-48hrs (mlsec 1.390E -08 1.390E-08 1.390E -OS 1.390E-08 1.390E-08 1.390E-08 1.390E-08 1.390E-08 1.390E-08 1.390E-08 1.390E-08 1.390E-08 ©' "Organic Deposition Velocity 48-72hrs (m/sec 3.226E-08 3.226E-08 _ 3.226E-08 3.226E-08 3.226E-08 3.226E-08 3.226E-08 3.226E-08 3.226E-08 3.226E-08 3.226E-08 3.226E-08 m l s1sprganic Deposition Velocity 72-96hrs (m/sec j 5.156E-08 5.156E-08 5.156E-08 5.156E-08 5.156E-08 5.156E-08 5.156E-08 5.156E-08 5.156E-08 _'5, 156E-08 5.156E-08 _ 5.156E-08 "Organic Deposition Velocity 96-275hrs m/sec j, ! 8.849E-08 8.849E-08 8.849E-08 8.849E-08 j 8.849E-08 8.849E-08 8.849E-08 8.849E-08 8.849E-08 8.849E-08 8.849E-08 8.849E-08 m,..__-, s_rganic Depo sition Velocity 275-720hrs (m/sec) Organic Deposition Velocity 0-24hrs (ftlsec) 18.849E-08 2.037E-08 8.849E-08 2.037E-08 8.849E-08 2.037E-08 8.849E-08 2.037E-08 8.849E-08 2.037E-08 8.849E-08 2.037E-08 i 8.849E-08 2.037E-08 I 8.849E-08 2.037E-08 8.849E-08 2.037E-08 8.849E-08 2.037E-08 8.849E-08 2.037E-08 8.849E-08 2.037E-08 ©, Organic Deposition Velocity 24-48hrs (ftJsec) 4,561E-08 4.56_1 E-08 4.561 E-08 j 4.561E-0$ 4.561E-08 4.561 E-08 4.561E-08 4.561 E-08 4.561E-08 4.561E-08 4.561E-08 4.561E-08 manic Deposition Velocity 48-72h rs (fUsecj -07 1.058E-`7 1.058E-07 1.058E-( 1.058E-07 1.058E-07 I 1.058E-07 1.058E-07 1.058E -07 1321 _Or o i fe: Deposition Velocity 72-96hrs ( ftlsec1 1 ' c

E-)7 1,692E-(

1 H9?E-0' 1 8°^5 1.692E-07 1.692E-07 1.692E-07 110 - "Peak P. Containment Pressure, constant (psig) 11.4 ..-..,. 111 Atmospheric Pressure constant (psia) 14.7 j I t -+ [112 "Extrapolation Factor, constant 1.00 ~I L j! 115 IIII III T--I j 116 ( (

8 8 94 0 20 201 Decontamination Factors Due to Iodine Deposition _~27,7 3048 .;049 i-11345-vROG Leak Rate ConectionlC45. 1JIA NpA NiA NrA NiA N;A NiA NiA 3`'S 60 60 (J.- J34YJ$5f3600 (J18'J$4yj$5f3600 (J20'J$4)/J$5)'3600 ,(J21 -J$4)/J$5)"3600 =((J22'J$4yJ$5)"3600 -,.(J29'J$4)/J$5)`3600 (J30'J$4yJ$5)"3600 (J31 -J$4YJ$5)"3600 =~.(J32-J$4YJ$5)"3600 -:(J33"J$4yJ$5)"3600 (J34'J$4yJ$5) -3600 3 b ea (f~)I 5 me (0, ea (ft) 7 sa (it') a rme (n') s , ty(ml,) 10 ity (fus) 11 (mlsec) 12 (mlsec) 13 ymlsec) 14 (mlsec) 15 Imlsec) 18 (mlsecl 17 lfllsec) ) c) 22 (ft!3 (mlaec), 24 (mfaey '..25 (m/sec) 26 _(rn/aec) 27 (Meecl ec) ec) c) 1 1 ) 58 59 at (h, ') hr (hr) In (hr') hr(hr') hr (hr) hr(hr') In (hr' ) hr(hr') hr (hr ') 64 hr (h, :) 65 hr (hi') 66 hr(hr) 67 hr(hr')~ 160' 161 62 68

69) 3a 1

. ~,;) 84 85 95 26 97 100 10 10 10 10 r (FI r( K1-~ shr!F) hr (h) r (F) hr fK) 5hr (!r) r (F) nt V) (K) - (F) -24h r 1 -Ash, 36 2h, 1 -6 75hr 636 201,/ 036 lPsi9)'.' 1 (p,-) - -PJ40G Leak Rate CorrechonlAl1 tantl RA1 of November 18, 2003, Question #4 Page I of 2 itration 8. Penetration C. = MS Piping Summary'!C36 J$6/2 ° MS Piping Summary'!C37 1,00117 J$91Uo4a - 10 = EXP((2e0s/$B$89}175)MOO -XP 2809/$B$91~125)/100 - =XP((2809/$B$93)-12.5)1100 " x) EXP((2809/$B$95}12.5)1100 ' 10 EXP((2809/$B$97)-12.5)/100 )0 8XP((2a0s/$8$99}12.5)/100 =J1210.3048 =J1310.3048 =J1410.1048 EXP((2809/$B$89}19.3)/100 )0 FXP((2809/$B$91}19.3)1100 )9 _XP((28os/$B$93}is.a)/100 )0 =:XP ((2ao91$S$95yl9.s)r100 )0 -XP((2809/$B$97}19.3)/100 1,0 vXP((2809/$8$99}19.3)/100 .:'23/0.3048 . ?4/0.3048 .51/00.3048 ~, ta Corre tion IA5 ~ ..avacti.n'lA6 3.15 H.' 15 -i 3.15 -- Rate Coffection'WO _ ~" " 1 Credited', 'Not Credited", (8100-32)"(5/9)+273.15). -~2AeCorreetionlA4

RAI of November 18, 2003, Question #4 Page 2 of 3

RAI of November 18, 2003, of I Determination of Inboard MSIV Leak Rates using NEDC11858P and U091 Methodology i H I-i Constants 4 68 i Standard Temperature ('F) 550,Main Steam Temp 0-24 6 IF-410~!N 4MWain ain Steam Pipe Wall Temp 24-48 hours ('F) 30M Main Steam PWe Wall Temp 48-72 hours ('F) 8 2% Win Steam Pipe Wall Amp 72-96 hours (*F) 9 1 2MMain Swam Pipe Wall Amp 10 ~ Main Steam Pi-W.11 Temp 10ownverwy Facto r (at; to psi) Containment Volumes 1141 208,204 Drywall Volume (ft'} CPS Value; UFSAR Table 6.2-52 1,512 3_41 ~Wetwell Volume (ft') __ACPS Value; UFSAR Table 6.2-52 14,0001 Reactor Vessel My paw Move nmomminal _water level {from GE 1 UOomofwt' vwaluee ~awssumpt~ion 1,734,545~Total Volume (ft) "1Q"!%aIVolume {M) 7M61 A= of Total Volume to Qwd Volume including RPV Containment Temperatures and Pressures Per Containment Analy I, k-0-- 2331DW Temp C9 M minimum DW -W differential at - 69 seconds !{CPS Value, Figure 5.6 __ 24] 146': WW Tern e, oF at minimum OW-WkAI differential (at - 69 seconds) ICPS Value

Figure 5A--

OF 15 A Average Bulk Tmyeralmre oF) L 22',DW Pressure (psia) {Use for pressure vesse l as well (CPS PSVafue, Figure 5.5 _ 17,81WW Pressure (pwq T 1 I'VIANG, Figure 15 1.25 IAverage Bulk Pressure (atmospheres) Hydrogen Contribution from - Zirconium Water Reaction 624 _a.sembl,.s 95.16~lbsZr/assembly ,{CPS Value ; UFSAR Section 1.1.5 !!!!!Calculated CPS V-a 7.87! cubic feet H2 per it qNEDC-31858P} 0.009451fraction of Zr undent-oing metal water reaction !(CPS Value ; UFSA 40115970otalRydirogen(W ~ff~fwff {Calculated CPS Value} 5539.4793', Corrected to bulk average temperature _' Calculated CPS Value OMT19NPartial Pressure of Hydrogen (atmospheres) {Calculated CPS Valuel 41 ~ 1.25jotall (H2, N2, H20) Pressure (atmospheres) ,{Calculated CPS Value} Inboard leak Rate Determination per INIEDC-32091, Section 8.1.3, Duane Arnold de based. Containment leak Rate scfh) {use as basis r outboard flow rate}- ~ 0.0000 0.0647 Leak Rate - IIIIIJEW 0.0000 1 0.7788 Inboard 93.4560 nMWF-IWwj 46.7280 Inboard Leak Flow Rate (cfh) InNote that no extrapolation from test pressure to Pa is required based on the NEDC-31858P note that these containment conditions. conditions are essentially equivalent to test

RAI of November 18, 2003, Question #4 Page 1 of 1 MSIV Leak Rates using NEDC-31858P and Constants 68 Standard Temperature ('F) © ',550 Main Steam Pipe Wall Tame TM hours ( ° F) Immil ~Main Steam Pipe Wall Temp 24-48 hours (T) 300 . Main Steam Pipe Wall Temp 48-72 hours - F) 250 Nam Steam Pipe Wall Temp 72-96 hours (°F) 200 !Main Steam Pipe Wall Temp 96-275 hours (*F) i m ..200 !Main Steam Pipe Wa1I Temp 275-720 hours (° F) 1001.7 immersion Factor (atm to psi) containment volumes 208204 Volume (it') (CPS V 1512341 WetwellVolume (it wMV M 14000 Reactor Vessel MQ space above nominal water level (fro. "Total Volume (it') iTotal Volume (m) IH=A171(Al4+A16) !no or Total Volume to Dy"ll Volu me including R PV ontal 233 t minimum DW-WW differential (at - 69 s (CPS V 1 0 146 jWW Temp ('F) at minimum DW-WW differential (at - 69 (CPS V 0 =(A23'(A1*A1YVAA----- ~I Average Bulk Temperature (oF) 10 W22 - US ', DW Pressure (psia) {use W pressure vessel W1111

WW Pressure (psia) 1 1JC-PS V

! CPS V jM"WAl6)+A28'A15)/A17 (Average Buik Pressure (psia) ',Average Bulk Pressure (atmospheres) Hydrogen Contretbu-NMorn Zirconium Water Reactic 90624 assemblies (CPS V KI=59380/624 lbas Zzrws, REA CalculE IET 87 (cubic leetHowbZr i i jUSV (NWEDC m.0 00945 ~fraction of Zr undergoing metal water reaction 'I i A33*A34*A35*A36 T Total Hydrogen (it') HmlculE =A37*(460+A25)/(460+32) Corrected to bulk avers +.e temperature , Cawlwuk Ea=A38/A17 (Partial Pressure of Hydrogen (atmospheres) Icalcul

wcul,

=A39-A30 ITOW {H 2, N2, H20} Pressure (atmospheres) j{Calcul Inboard leak Rate Determination per NEDC-32091, SO =A45*24'100/($A$17'$A$4-4i6~+$A$ + + L =A4 A 1 14401100 =B46*$A$17114401100 I=C46*$A$17114401100 j=D46*$A$,t7/,i44oi,ioo Inboard Leak Flow Ry 8 =A47*60 =8=60 k Flow R 50 Note that no extrapolation from test pressure to Pa is required based on the NEDC-31858P note that these containment conditions are essentially equivalent to test conditions.

03, Question #4 Page 1 of I 1 CPS Main Steam Piping Summary 2 22.624 Main Steam 24 inch pipe ID 3 4 TOTAL MS PIPING 6 1 i B 1826.98 1954.91 1954.91 1826.981 24 inch piping, etc from vessel nozzle to discharge middle of reducing elbow (inches) 8 902 965 965 902 24 inch piping inside surface area (sq. ft.) 9 425 455 455 425 24 i 10 902 965 965 902 Tot all inside surface area ( q. i 11 425 ilk 455 ~--05 1 allS

Total inside volume (cu. ft.)

12 13 HORIZONTAL MS PIPING ONLY 14 A C D l1W@ 152011 164813 1648.531 1520.6 24 inch piping, etc from vessel nozzle to discharge middle of reducing elbow (inches) 16 751 814 814 751 24 inch piping inside surface area (sq. ft.) IMOU 354 384 384 354 24 inch piping. inside volume (cu. ft.) 18 19 20 751 I 814 814 IM Total inside surface area (sq. ft.) ""354 -T 384 384 1 354 I Total inside volume (cu. ft.) 100 50 50 100 Flow rate (_scfh) r2~4 t-fl~ 162.9 777T7.4 1 1619 1 137.4 1 152.2 Ifeet of pipo total 1207 Ifeet of pipe, horizontal 28 29 30 Nodalizatli n (Horizontals ) IRMO (AnAeso 32 370.6000 498.5300 498 5300 370,6000 Node 1 Length Im 183 246 246 183 Node I Surface Area (s q. ft.) 34 86 116 116 86 Node I Volume (cu. ft.) I 648.0000 648.0000 648-0000 648.0000 Node 2 Length ( inches )l 36 320 320 320 320 Node 2 Surface Area (sq. ft............. 37 151 151 1 151 151 Node 2 Volume (cu. ft.) 38 5020000 502.0000 5024000 502.0000 Node 3 Length (Kcheyl 33 99 248 248 248 248 Node 3 Surface Area V1 ft. 0 117 117 117 117 Node 3 Volume (cu. ft.) 41 44 22 43 Nodnizati n (Totals) 44 44 45 676.9800 804.9100 804.9100 676.9 Node 1 Length (inches) 46 334 397 397 334 Node 1 Surface Area (s q. ft.) 47 157 187 187 157 Node 1 Volume (cu. ft.) I ,f8-6480000 648.0000 648.0000 648.0000 Node 2 Length (inches l 49 320 320 320 320 Node 2 Surface Area (s q. ft.) 50 151 151 151 151 Node 2 Volume (cu. ft. I 101 502.0000 502.0000 502.0000 502.0000 Node 3 Len th (inches) 248 248 248 248 Node 3 Surface Area (sq. ft. 53 117 117 117 117 Node 3 Volume (cu, ft.) RAI of November 18, 2(

RAI of November 18, 2003, Question #4 Page I of 1 A B C D E F 1 NOZZLE No' DWG No !PIPE DIA ',LENGTH (IN) COMMENTS ©,TIE-IN © N3A-A1 762E902 24" 4 68.500 HORZ PIPE LENGTH OUT OF REACTOR 5 306.380',VERT PIPE LENGTH 6 302.100~HORZ PIPE FROM VERT PIPE TO INBOARD VALVE I I 7 f i 648.0001 INBOARD VALVE TO OUTBOARD VALVE I 8 i SubTotal 1324.980', Includes lower drywell vert ~ run, inboard MSIV; Penetration piping, & outboard M S IV I E 10 MOI-1109 24" 502.000 1 HORZ PIPE LENGTH FROM OUTBOARD VALVE TO TURBINE BLDG. © 13 II iSubTotal 502.000 ; Other dr ell MS.i in and fittings dimensions from iso details 14 TOTAL', I Vertical Horizontal Segments' Only 16 1826.980 Total Inches 306.380 1 520.600 17 152.248'Total Feet 25.532 126.71 7 18 19, 20 'INBOARD 21 1 Horizontal 370.600

Inches li 22

~ Total 676.980 Inches 23 56.415' Feet 24 i 25 I PENETRATION E ( This Line is assumed 26 I Horizontal 1 648.000

Inches Ito have the worst-case 27

Total 648.000 ',Inches (failed Penetration 28 54.000 Feet MSIV. 29 -_ i 30 31 !OUTBOARD 1 Horizontal 502.000 (,Inches I 32 Total 502.000 Inches 41.8331 Feet

R13 of November 18, 2003, soon #4 Page I of I A A B C D K 1 NOZZLE NOZZLE NoIDWG No PIPE DIA LENGTH (IN) ' COMMENTS 2 TIE-IN N3B-B1 1762E902 124" 68.5WHORZ PIPE LENGTH OUT OF REACTOR 1 3003801VERT PIPE LENGTH 6 430.030 , HORZ PIPE FROM VERT PIPE TO INBOARD VALVE 7 648.000)NBO'\\RD VALVE TO OUTBOARD VALVE 8 ISubTotal 1 1452.9101 Includes lower drVwell vert run ; inboard MSIV ; Penetration piping ; & outboard MSIV 9 I~, 1100 M01-1109 24 502.0001 HORZ PIPE LENGTH FROM OUTBOARD VALVE TO TURBINE BLDG. SubTotal 502.000 Vertical Horizontal 15 TOTAL 1 Sements Only 16 1954.910~ Total Inches 306.3801 16481301, 17 162001 Total Feet 25.53166667 137.3781 18 19 201 ( INBOARD 21 Horizontal 498.530 ; Inches 22 Total 804.9101 Inches 23 67.076 Feet 24 25, PENETRATION 261 Horizontal 648.000 Inches 271 Total 648.000 i Inches 28 54.1000 Feet 29 30 31 Horizontal 502. 000 Inches 1321 Tota 1 502. 000 Inches 41.833 Feet

RAI of November 18, 2003, Question #4 Page I of 1 A NOZZLE lslo ' DWG No !PIPE DIA ~LENGTH (IN)

COMMENTS 7

TIE-IN N3B-C1 11A66-2E902 124" 68.5001 HORZ PIPE LENGTH OUT OF REACTOR 5 .. 306.3801VERT PIPE LENGTH 6 430.030 HORZ PIPE FROM VERT PIPE TO INBOARD VALVE 7 648.000 INBOARD VALVE TO OUTBOARD VALVE SubTotal 1452.91 0 9 10 1-1109 124" 502.000 -HORZ PIPE LENGTH FROM OUTBOARD VALVE TO TURBINE BLDG. 11 f 12 !SubTotal 502.000 Other drywell MS piping and fittings dimensions from iso details 13 14 I Vertical Horizontal 15 TOTAL Segments Only 16 1954.9 Total Inches 306.3801 1648.530 17 II 162.909I Total Feet 25Z321 137378 18 191 201 INBOARD 21 1 Horizontal 498.530 Inches 22 !Total I 804.910 Inches 23 67.076 Feet 24 25, 261 PENETRATION Horizontal 648.000" Inches 271 [Total i 648.000' Inches 281 54.000 Feet 29 301 ', OUTBOARD 1 31 1 Horizontal 502.0001 Inches 312 Total 5021001 Inches 33 41.833! Feet

RAI of November 18, 2003, Question #4 Page I of I A B C D _© H 1 NOZZLE Noi DWG No PIPE DIA LENGTH (IN) COMMENTS © TIE-IN 3 N3D-51762E902 4 68.5001 HORZ PIPE LENGTH OUT OF REACTOR 5 306.380'VERT PIPE LENGTH 6 302.100iHORZ PIPE FROM VERT PIPE TO INBOARD VALVE 7 648.000 INBOARD VALVE TO OUTBOARD VALVE 8 'SubTotal 1324.980, Includes lower drywell vert run ; inboard MSIV ; Penetration piping ; & outboard MSIV 9 I 1 24" 10 M01-1109 502.000' HORZ PIPE LENGTH FROM OUTBOARD VALVE TO TURBINE BLDG. 11 ~ 12 SubTotal 502.000 Other d ell MS piping and fittings dimensions from iso details 13 14 'Vertical Horizontal 1 1 TOTAL{ !Segments (Only 16 1826.980 Total Inches 306.380 1520.6001, 17 152.248 Total Feet 25.5321 126.717', 18 19 20 ( INBOARD y 21 Horizontal i 370.600 ~ Inches 22 ( Total 676.980 ; Inches 23 ( 56.415 i Feet I 24 ( i ` 25 PENETRATION j 26 ~ Horizontal ; 648.000 i I nches i 27 j Total 648.000 I nches 54.000' Feet 29 30 31 OUTBOARD Horizontal 502.0001: Inches 32

Total 502.000' Inches 33 41.833 Feet

RAI of November 18, 2003, Question #4 Page 1 of 1 I I A 1 ~~= - 0 i D E L19PS-Main - Steam Piping Summary IM121624 Main Steam 24 inch pipe 0 IM17TOTAL MS PIPING A B C D 6 =NozzN3A!D8+NozzN3A!Dl2 =NozzN3B!D8+NozzN3B!D12 =NozzN3C!D8+NozzN3C!Dl2 =NozzN3D!D8+NoZZN3D!Dl2 piping, etc from vessel nozzle to discharge middle of reducing elbow (inches) 7 =A6*PIO*$A$21144 =B6*PI()*$A$21144 =C6*P[O*$A$2/144 '=D6*Pl()*$A$2/144 24 inch piping inside surface area (sq. R.) 8 =A6-Pl()'($A$2/2)A 2/1728 =B6*PI()*($A$2/2)A 2/1728 =C6-PI()-($A$2/2)-2/1728 =D6*PI()*($A$212)A 2/1728 24 inch piping inside volume (cu. ft.) 9 70 =A7 =A ~=B7 --OC7

B8 OCR

!=D7 OD8 ',Total inside surface area (sq. ft.) Total inside volume cu. ft. 11 12 HORIZONTAL MS PIPING ONLY II j 131 A B C D i 114 =A6-SUM(No zN3A! z~~D5 ~=B6-SUM(NozzN3B!D5) ! =C6-SUM(NozzN3C!D5) i=D6-SUM (NozzN3D!D5 24 inch going, etc from vessel nozzle to discharge middle of reducinjk elbow (inches) 0 = 'Pl()-$A$2/144 OB14'PI( '$A$2/144 =C14*PI0*$A$21144 =D14*PI()*$A$21144 24 inch piping inside surface area (sq. ft.) 0 =MvPI()-($A$2/2)-2/1728 =Bl4*Pl()*($A$2/2)-2/1728 =C14-PI()*($A$2/2)-211728 I=DI4-Pl()*($A$2/2)A 2/1728 24 inch piping inside volume (cu. ft.) 18 19 =M5 =B15 OCIS =D15 Total inside surface area (sq. ft.) 20 =M6 =B16 =C16 =13116 Total inside volume {cu. ft.) ©100 !,100 ' 100 !Flow rate (scfh) 26 =A&12 =M?12 "1=B6112

1716/12 1=131012 J=C114/12

[=D6/12 I=DIO12 feet of 've total Ifeet of wipe, horizontal 27 28-29 30 Nodalization (Horizontals) 311 1 =WOWOD21

No

=N=N3DID21 Nod" Lee M (inches) A D144 =C32'PI '$A$2!144 7~7- ,,.pj~rW2044 Node I Surface Area (s q . ft.) =1332'Pl~)($A$2 / 2)'2i1728 =C32`PI "($A$212 ^2/1728 =M2*Pfl'($A$212 ) A 211728 Node I Volume (cu. ft.) zNozzN3B'D26 =No7zN3C!D26 -- NozzN3D1D26 Node 2 LenUth (inches) ~-B$35*P[()*SAS2/144 =C$35*P!~)*$A$2/144 = D$35*Pl ' )*$A$2/144 Node 2 Surface Area ~sq . ft.) P1()($A$2/2)'2/1728 =D35TIO*~$A$2/2~'2/1728 Node 2 Volume (cu. ft.) 38 =NozzN3AlD31 FNo7zN3B1D31 =No,,N3C1D31 A 'N =D38qP1~)'$A$2,'144 3DID31 Node 3 Length (inches) 39 4 8 -MWPV$MDM4 -0WVWxM2qT1W8 I=B38-Pl~)- $A$2/144 jMW"MMVqWW28 =C 38*L!~4 CWIMMVMM1728 Node 3 Surface Area (s q . ft.) j Node 3 Volume (cu. ft.) 41 42 4 3 Nodalization (Walks) IM jMj=No7zN3MD22 -NowNWD22 =NozzNKID22 =N=NMID22 Node 1 Length (inches) g3V"WP1()WUW14 =B45*PU-W2044 =C45'P10*$A$2,'144 = D45'PI ( `$A$2,1 144 Node 1 Surface Area (s q . K) 47 jF-AM4TPi0 - ($A$2/2)^2/I728 =B45'P1() - ~$A$2/2) 1 2/I728 = C45*P1~)- ($A$2/2)1 2/InS 1NIVEIAMEW1 M Node 1 Volume cu. H.) 148 =N=NWD27 =No=N3B!D27 =Na7zN3C!D27 V=WDID27 Node 2 Length (inches) . - A48*P1()*W2/144 =B4TP10*$A$2/144 - C48'P1() " $A$2i144 =D48*P10*$A$2/144 Node 2 Surface Area (sq . ft.) I =WPI(DSMMEIM8 =848"MMUMOV28 'WTP2jAWlMMWB =048'Kj ($MDjA 2M72B 122.1c 2 Volume cu. R.) = NozzN3AID32 =NozzN3BID32 N3 D11 ID e 3 Length inches) -A5VP1()jA$W44 =B51*P101AS2/144 1 -N2, _C5F MUM44 'S' A$2f144 Node 3 Surface Area Q q . ft. ) L53 -A51 -E, 51 *P[()*($A$2/2)'2 -C51TYM$M21rW28 l=D51 -Pi(1*($A$2/2)'Tl 728 Node 3 Volume (cu. ft.)

RAI of November 18, 2003, Question #4 Page 1 of 1 NOZZLE No DWG No PIPE DIA LENGTH (IN) 'COMMENTS 2 TIE-IN 3 N3A-A1 1762E902 124" 4 168.5 HORZ PIPE LENGTH OUT OF REACTOR 5 1306.38 VERT PIPE LENGTH 6 I 1302.1 HORZ PIPE FROM VERT PIPE TO INBOARD VALVE 7

648 INBOARD VALVE TO OUTBOARD VALV E 8

SubTotal I=SUM(D4:D7) Includes lower drywell vent run; inboard MSIV ; Penetration piping ; & outboard MSIV 9 10 IM01-1109 4" x502 ~HORZ PIPE LENGTH FROM OUTBOARD VALVE TO TURB I NE BLDG. 12 SubTotal =SUM(D10) Other d ell MS piping and fittings dimensions from iso details 13 14 (Vertical iHorizontal 15 TOTAL' 1 Segments Only 16 =D8+D12 !Total Inches 1=D5 =D16-F16 17 ( 1=D16i12 Total eet 1=F16/12 =D17-F17 18 19 - ( 20 INBOARD 21 j Horizontal

=D4+D6 Inches i

i 22 (Total i= D21+D5 IInches E 23 =D22/12 ' Feet 24 ©I. _ PENETRATION i !This Line is assumed to 26 Horizontal =D7 Inches have the worst-case 27 Total F=D26 IInches (failed Penetration MSIV. 28 _=D27/12 Feet 29 i 30 OUTBOARD I 4 31 ( Horizontal =D10 E Inches 32 III Total !=D31 !Inches 33 1=D32/12 j Feet

RAI of November 18, 2003, Question #4 Page I of I A I B 1~113=1 a M - 1 NOZZLE No DWG No ', PIPE DIA ~ LENGTH (IN) ' COMMENTS 2 TI E04 - 3 1-- 1762E90-77--124;' 4 68.5 1HORZ PIPE LENGTH OUT OF REACTOR - 5 130&38 AVERT PIPE LENGTH 6 1430.03 1 HOW PIPE FROM VERT PIPE TO INBOARD VALVE 7 648 INBOARD VALVE TO OUTBOARD - VALVE 8 SubTotal i=SUM(D4 :D7) Includes lower drywell Vert run ; inboard MSIV ; Penetration piping ; & outboard MSIV 9 yo 09 24" 502 ' HORZ PIPE LENGTH FROM OUTBOARD VALVE TO TURBINE BLDG-. i SubTotal - j=SUM(D10) 174 Vertical Lftrizontal 15 Segments l Only 161 =D8+D12 =D5 I=DISF16 171 _j=D16/12 Total Feet =F16/12 =D17-F17 181 191 20 i INBOARD I NMI !Horizontal !=D4+D6 1 Inches 2 I j =D21 +135 Inches 23 V 1 =D22/12 Feet 24 PENETRATION 26 Horizontal 1 =D7 Inches 27 Total =D26 Inches 28 !=D27/12 'Feet 30 OUTBOARD 31 t i Horizontal [=D10 Inches 32 Total =D31 33 =D32/12 . ;.Feet

RAI of November 18, 2003, Question #4 Page 1 of 1 A I B C I D I E 1 NOZZLE No DWG No PIPE DIA LENGTH (IN) COMMENTS 2 TIE-IN 3 N3BV1 1762E902 py, 4 168.5 HORZ PIPE LENGTH OUT OF REACTOR 5 1306.38 RT PRE LENGTH 6 1430.03 i HORZ PIPE FROM VERT PIPE TO INBOARD VALVE 7 648 INBOARD VALVE TO OUTBOARD VALVE 8 !SubTotal !=SUM(D4:D7) 9 10 1109 124'~--1502 HORZ PIPE LENGTH FROM OUTBOARD VALVE TO TURBINE BLDG. 12 SubTotal =SUM(D10) Other drywell AS pieing and fittin2s dimensions from iso details 13 14 Vertical Horizontal-TOTAL, Segments !Only 16 =D8+D12 Total Inches 4=D5 =D101716 17 =D16/12 Total Feet =F16/12 =D17-1717 18 19 20 INBOARD 21 Horizontal =D4+D6 Inches 22 total =D21+D5 es 23 =D22/12 IFeet 24 25 I PENETRATION 26 Horizontal =D7 Inches 27 !Total !=D26 Inches 28 29 L =D27/12 !Feet 30 !OUTBOARD 31 !Horizontal 1=010 Inches 32 Total =D31 Inches I 33 1=032M2 feet

RAI of November 18, 2003, Question #4 Page 1 of 1 A B C D I NOZZLE No DWG No PIPE DIA jENGT1H (IN) COMMENTS 2 TIE-IN 3 N3D-1 02 4 168.5 HORZ PIPE LENGTH OUT OF REACTOR 5 306.38 ~VERT PIPE LENGTH 6 302.1 !HORZ PIPE FROM VERT PIPE TO INBOARD VALVE 7 648 INBOARD VALVE TO OUTBOARD VALVE --------- 8 SubTotal =8UM(D4:D7) Includes lower drvwell vert run ; inboard MSIV ; Penetration piping ; & outboard M 9 -To-M01-1109 ]24" 502 PE LENGTH FROM OUTBOARD VALVE TO TURBINE BLDG. 11 12 SubTotal =§UM(D10) ?Other drywell MS pTwing and fittings dimensions from iso details 13 14 Vertical Horizontal Segments lOnly 16 =D8+D12 I Total Inches =D5 =1316-F16 17 =D16/12 Total Feet .=F16/12 =D17-1717 18 19 201 INIBOARD 21 izontal l=D4+D6 Inches 22 !Total 1=D21+D5 Inches 23 1 =D22/12 Feet 24 25 ! PENETRATION 261 !Horizontal I =D7 Inches 271 ITotal =D20 Inches 28 1_ =D27/12 Feet 291 30 !OUTBOARD 31 Horizontal =D10 Inches 32 To 33 1=13=12 Feet

APPENDIX B Purge Piping Deposition Credit Spreadsheets

2 3 5 6 7 8 9 10 12 13 14 15 16 17 is 19 20 21 22 23 24 25 26 27 28 29 30 32 33 34 35 36 37 38 39 40 A I B I C I D I E I F I G I H ontal Surface Area Determination of Purge Line Decontamination Factors Due to Iodine Deposition - Leak Rate @ 0.16scfm Node 1 Node I Node 2 Node 2 manual (note unit conversion to meters) manual (note unit conversion to meters) A-3 Median val ue on at U d for Containment Pressure con"ons: - hrs 0.000 0.000 Inboard Fl c 4m Corrected for Containment Pressure Conditions. - 50% Reduction at 24 hrs Row Rate 044 hrs (0m) 0.325 MY Flow Rate 24-720 hrSOfmy 0.163 0.163 6.000 0.000 Flow Rate 0-24 hrs {cfh) 19.523 19.523 0.000 0.000 Unit Conversion 01" Rate 21-729 hrs (dh) 9,761 61101 6106 6066 unit Conversion !but for Elemental but for organic `Pipe Wall Temperature, constant (F) 206.00 Pipe Wall Temperature, constant (K) 369.82 Containment Temperature, constant (F) 68.00 131!a) 14.70 Clinton Purge IV -Test-Pressure, constant psig) 9.00 Because of a failed valve assumption, deposition in only one Node is-creNte-T-11 Conservatively High q ell 27 t Applicablest-LOCA Min ECCS Temperature F _(USAR Fig. 627a) Reductions With Time Seconds ; No R e me AIter~ppmc 900 RAI of November 18, 2003, Question # 5 Page 1 of 7 Total Horizontal Pipe Surface Area (ft) 518 459 0 Horizontal Settling Pipe Surface Area _(ft2 ) -259.25 -12016 010 010 it 16 Two! Pipe Surface Area (ft') 6

Total _Pipe Volume (ft) 373 349 0

9 112 of the above Horiz Inboard A Inboard B Outboard A Outboard B From Piping Tak 01 From Piping Take-offs, - From Piping Take-offs e Horizontal Pipe Volume (ft) 373 330 0 From Piping lak"~s --Aerosol Settling Velocity(T/s) 1.170E-03 -11ME-03 1.170E-03 1_.170E_-03 From -98 Page "AE13 Aerosol Settling Velocity (15) 3.839E-03 3.839E-03 3.839E-03 3.839E-03 unit conversion Elemental Settling Velocity (m/sec) 7.414E-05 7.414E-05 7.414E-05 7.414E-05 Cline, RADTRAD 3.03 --- Elemental --SSettling Velocity (ft/secy 2A33E-04 2.433E-04 2.433E-64 Unit Conversion Organic Settling Velocity (m/s ec) EME-68 i3. 258E-08 8.258E O8 Cline, RADT RAD 3.03 $.258E-08 1 Organic 07 2.7691f-67 2.709E-07 2.709E-07 Unit Conversion Settling Velocity (Wsec) 2369001 Uncorrected Flow Rate Ncl#,, 0.11 0.16 0.00 0.00 0.16scfm Leak Rate Sim ReductiFrom Containment Flow Rate 044 hrs OAQ, 7 77 Mill bill N/A N/A inboard Flow CorrecteFrom Containment t Flow Rate 24-720 hrs (cfrn) 0.163 6.163 N/A N/A Aerosol Settling Rate Constant9.61 E+00 9:131066 From AEME17021, Page A-2, Formula 2 Elemental Settling Rate Constant (he) 122000 1.22E+00

DIW01 001w0 From AEB-98-03, Page A-2, Formula

?Organic Settling RablConstant May, 1.36E-03 1.36E-03

DIV/O!
DIV/O!

From AEB-98-03, Page Formula 2Aerosol Filter Efficiency (0-24 hrs) 99.46% 99.39% 0.6661. 6.00 0% From AEB-98-03, Page A-2,formulait Efficiency (24-720 ` -720 Aerosol Filter hrs) 99.73% 99.69% 0.00% 0.00% From AEB-98-0, Page Formula 4 Elemental Filter Efficiency (0-24jFs) _..._..o 95.88 /0 11M 94 6, /. wm o/. From AEB-98-0, Page A-,zF ormula 4 Elemental Filler Efficiency P4420 hm) 97.90% 97.76% 0.00% 0.00% From AEIB-91143, Page A-2, Formula 4 j jjOQQFilter Efficiency (0-2.52% 2.37% 61161 Obft From AEB-98-03, Page ",foninula4 Organic Filter Efficiency y{24-720 4.936 hrs) /6 4.153% 0.00% 0.00% From AEB-98-03, Page A-2, Formula 4

A Determination of Purge Line Decontamination Factors Due to lod-Node l Node l Inboard A - Inboard dill-Total Aloe Surface Area {ft l 06ryweiRye Piping Surninary'S19 ='Drywell Purge Piping SumrnarylM Two Pipe Volume (ft) ='Drywellpurge Piping Smniary841 =Iprywell Purge Piping Summary'!C41 otal Horizontal Pipe Surface Area (W) ODI&a Purge Piping Surrtrttary'!1330 ='Drywell Purge Piping SurnrnaryMO Horizontal Settling Pipe Surface Area (ft) =C$7/2 =D$7/2 Horizontal Pipe Volume (ft) _ _ - "" ------ - --- -='Drywell one Piping Suri=JRB31 ='Drywell Purge Piping Surnmary'Ml Aerosol Settling Velocity (m/s) 0.00117 0.00117 Aerosol Settling Velocity (ft!s} =C$1010.3048 Elemental i lSettling Velocity (m/sec) =EXjP(N8dWBWQ2.5)/10 Aerosol Settling Rate Constant (hr)_ Organic Settling Rate Constant (hr') - `Pipe ~Wall Temperature, constant (f)206 Pipe Wall Temperature, constant (K)=(B36-32)-(519)- Containment Temperature, constant (F) 68 Atmospheric Pressure, constant (psia) 14.7 Clinton Purge IV Test Pressure, constant (psig} 9 D =D$10/0.3048 Elemental Settling Velocity (ft/sec) --------- - Organic Settling Velocity (rnksiac) Organic Settling Velocity (ft/sec) Uncorrected Raw Rate (scfm) From Containment Flow Rate 044 hm WWI From Containment Flow Rate 24-720 hra MM Row Roe 044 hm (Am) 16*(($B$39t$B$40)/$B$39)'($8$36+460){qB$380+0460) =$C!6 (($B$39+$B$40)/$B$39) ($B$3U+460)i{$8$38 +460) Flow Rate 24-720 hrs (cfm) =C1912 =DIW2 ~:W6*6b Flow Rate 0-24 hrs {cfh} Mum Flow Rate 24-720hm(cfh) =D21/2 =((q$jj*C$8)/MrW00 VDhj1*D$8YD$9r3qM3 Elemental Settling Rate Constant (hr"')_ =((q$13-C$5)/q$6)-3i360- ~=((D$13*D$5)M$6)*3600 =QWWW)Tj6rj600 Aerosol Filter Efficiency o-2 4 hrs) =IF(D$l6((M24~~b$9)/Mj)))) A to T Aerosol Filter Efficiencv (24-720 hrs) =IF(C$16=0,0,1 -(l/(l +((C$24*C$9)/C$22)))) =IF(D$l 6=0,0, 1 -(1/(j+((D$24*D$9)/M?2)))) Elemental Filter titciency (q-24 tirs~ =IF(C$16=0,0,1-(I/(1+((C$25*C$6)/C$21))))

=IF(D$16=0,9,,I-(I/(l+((D$25*D$6)/D$21))))

Wmendal FHWr Mciency (24420 hrQ &F§j6-M0J-oq1+QC$2TC$GYCj2j)P _=IF(D$16=0,0,1-(I/(l+((D$25 D$6)M$22)))) __organic Filter Efficienicy(0-24 hrs)__ Organic Filter Efficiency (24-720 hrs) =IF(C$16=q,0,1-(l/(I+((q$26*C$6)/CS22))p, =IF(D$16=0,0,1-(V(1+((D$26 M6)/D$22)))) RAI of November 18, 2003, Question #5 Page 2 of 7 =C$12/0.3048 =EXP((28094B$37)-19. /166 =D$1213048 =EXP((2809/$B$37Y!90)/IUU =D$14/0 AAAO 6.16 0.16 =tCi6*(($B$394:$B$40)/$p!p9)`($B$3646g)/($B$38+469) =C17/2 =107/2

2 3 6 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 E ine Deposition -- Leak Rate @ 0.16scfm Node_ 2 -Node 2 Outboard A Outboard B Drywell Purge Piping Summary'!B43 ='Drywell Purge Piping Summary'!C43 From Piping Takeoffs =Drywell Purge Piping Summary!B44 ='Drywell Purge Piping Summary'!C44 From Piping Take-offs ='Drywell Purge Piping Summary'!B33 ='Drywell Purge Piping Summary'!C33 From, Piping Takeoffs onversion to meters) =F21/2 =G21/2 Unit Conversion =((F$11'F$8)/F$9)'3600 - -((G$11*G$8)/G$9)*3600.__ =IF(F$16 0,0,1-(1/(1+((F$24*F$9)/F$21))))--1F(G$16 0,0,1-(1/(1+((G$24*G$9)/G$21))))-From AEB98-03, Page -A-2, Formula 4- =IF(F$16=0,, 01-(1/(1+((F$24*F$9)IF$22)))) =IF(G$16=0,0,1-(1/(1+((G$24*G$9)/G$22)))) From AEB98-03 Page A-2,Formula 4 =IF(F$16=0,0,1-(1 /(1+((F$25*F$6)/F$21)))) =IF{G$16=0,0,1-(1/(1+((G$25*G$6)/G$21)))). From AEB 98-03, Page A-2, Formula 4 IF(F$16 00,1-(1/(1+((F$25`F$6)/F$22)))),=IF{G$16=0,0,1-{1/(1+((G$25*G$6)/G$22)))). From AEB98-03, Page A-2,Formula 4 =IF(F$16.0,0,111-(1/(1+((F$26*F$6)/F$21))))- =IF(G$16 0,0,1-(1/(1+((G$26*G$6)/G$21)))). From AEB98-03, Page A-2,Formula 4 =IF(F$16=0,0,1-(1/(1+((F$26*F$6)/F$22)))) =IF(G$16=0,0,1-(1i{1+((G$26*G$6)IG$22))))- From AEB98-03,Page A-2,Formula 4 onversion to meters) =F$14/0.3048 =G$14I0.3048 Unit Conversion 0 O .._0.16scfm Leak Rate N/A N/A Inboard Flow Corrected for Containment Pressure Conditions. - 50% N/A N/A Reduction at 24 hrs =F16*(($B$36+460)/($B$38+460)) =G16*({$B$36+460)/($B$38+460)) Inboard Flow Corrected for Containment Pressure Conditions. -50% =F1912 =G19/2 Reduction at 24 hrs =F$19*60.__ =G$19*60 Unit Conversion om AEB 98-03, Page A-2, Formula 2._ --((F$13-F$5)/F$6)-3600 =((G$13*G$5)/G$6)*3600. From AEB-98-03, Page A-2, Formula 2, but for Elemental =((F$15*F$5)/F$6)*3600-((G$15*G$5)/G$6)*3600.. From AEB 98-03,-Page A-2, Formula 2, but for Organic, Note : Because of a failed valve assumption, deposition in only one N z' Conservatively High Drywell PostLOCA Min ECCS Temperatu 6.2-7a) Applicable After Approx. 900 Seconds; No Reductions of November 18, 2003, Question #5 Page 3 of 7 =F$7/2 =G$7/2 112 of the above Horizontal Surface Area 0.00117 0.00117 From AEB-98-03, Page A-3, Median Value 1 =F$1010.3048 =G $1010.3048 -Unit Conversion -EXP((2809/$B$37)-12.5)/100 =EXP{(2809/$B$37)-12.5)/100 Cline, RADTRAD-3.03 manual (note unit =F$1210.3048 =G$12/0.3048 Unit Conversion EXP((2809/$B$37)-19.3)/100 =EXP((2809/$B$37)-19.3)/100 Cline, RADTRAD 3.03 manual ote unit

3 4 5 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 -- - -] T A B I C I D I JEE - F D"ell Purge Piping Summary __ 34.5 DryWell Purge 36 inch pipe ID TOTAL PIPING HORIZONTAL PIPING ONLY A -6M.875 609.6M Segment 1 Length

518 459 piping inside surface area (sq. ft.)

571 hid 36 inch piping inside volume (cu. ft.) 57.40625 5310729 Ifeet of pipe, total 4121 4150 Ifeet of pipe, horizontal Nodalization (Horizontals) 688.8750 6090875 Node 1 Length (inches) Nodalization (Totals) 6881750 645.6875 Node 1 Len RAI of November 18, 2003, Question #5 Page 4 of 7 6 Containment Penet. No. 7 01 8 9 M Segment I_Lenqth 10 518 486 36 inch piping inside surface area (sq. Q 11 M 349 36 inch piping inside volume (cu. ft.) 12 13 518 486 Node 1 Surface Area (sq. ft.) 373 349 Node 1 Volume (cu. ft.) 00000 01000 Node 2 Length- (inches ) Node 2 Surface Area (sq. ft.) Node 2 Volume (cu. ft.) 518 459 Node 1 Surface Area (sq. ft.) 373 330 Node 1 Volume (cu. ft.) 0.0000 0.0000 Node 2 Length (inches) Node 2 Surface Area (sq._ft.1 Node 2 Volume (cu. ft.)

3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 A B -F---C --j _L B NOZZLE N DWG No PIPE DIA _ LENGTH (IN) _ COMMENTS ELEV/DTL WALL THK KA-A! V07 B 102 17T-5---j A 101 V-R2 A 101 Fv-R1 36 inch 35.750 HORIZONTAL PIPE AT ELEV 769'-6 36 inch 36.000 VERTICAL PIPE FORM ELEV 769'-6" TO E LE V 772'-6" PIPE - ~ 36 inch 108063 HORIZONTAL AT ELtV 772~-6 SubTotal 179.813 25 HORIZONTAL P1 AT ELEV 72' 36inch 310. -6 w inch 155.625 jHORIZONTAL -PIPE SubTotal 46&875 SubTotal 180.500 HORIZONTAL PIPE FROM btbRi!CkttN ukow to DEBRIS SCREEN IVR62M 36 inch 268.375 HORIZONTAL PIPE AT ELEV 775'-9" ANGLED AT 34 DEG 36 - 6ATAuNREAbA6Lt ~ovALuEWA~~ PRoxmATEJ 9, - - I inch 240.006 HoRizoNtkLpipEATtLEvff!~- ~ SubTotal 5011375 Vertical Horizontal Segments___ 1334.563 Total Inches 36.660 1298.5625 iltiu total Feet --- --3.bdb-- 108.214 --- RAI of November 18, 2003, Question #5 Page 5 of 7

A 34.5 DryWell Purge 36 inch pipe ID - Containment Pene .t. No. - A =NozzN3ADN+NozzNWID26 =NozzN3A!D9+NozzN3A!bl4 Segment 1*gth 36ihiig insidefacearea (sq =B1O-Pl()*M$2/144 -=C161N()*$A$21144nc ppn -r . nq -=B1O--PlO'($A$2/2)A2/1728 7qjO-Pl()-(t4t2/2)-2/W28 36 inch piping inside volume (cu.-ft.)--_ _ =NozzN3A!bl II4wwaA3A!D24+NozzN3A!D25 =BW*PIWW2/144 =B17*Pl()*($A$W2)A2/1728 =C17*Pl ()*($A$2/2) /11728 36 inch piping irtside volume cu. it.) =NozzN3A!b5-+NozzN3AiD7+Noz2~N3A!DI2+NozzN3A!D13 Segment 1 Length n *,--I, piping inside surface area (sq. ft.).. =0.1V66-((14.7+6)/14.7) Row rate (scfh) RAI of November 18, 2003, Question #5 Page 6 of 7

2 3 4 6 7 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 A I B E G NOZZLE No DWG No PIPE DIA LENGTH (IN) COMMENTS TIE-IN rV-Q7 B 102 VQ-5 A101 pm FV-Rl inch 35.75 HORIZONTAL PIPE AT ELEV 76WA" 36 inch36 VERTICAL PIPE FORM ELEV 769'-6" TO ELEVn2' --6'- 36 inch 108.0625 HORIZONTAL PIPE AT ELEV77Z-e SubTotal =SUM(D5 :D7) 36 inch 155.625 HORIZONTAL PIPE SubTotal =SUM(Dl2 :DI3) 268.375 HORIZONTAL PIPE AT ELEV 775'-9" ANGLED AT 34 DEG 240 HORIZONTAL PIPE AT ELEV77F4" =SUM(D24 :D25) 36 inch 180.5 HORIZONTAL PIPE FROM DEBRIS SCREEN IVR03M TO DEBRIS SCI =SUM(D18 :D18) Segments nfy =D9+D20+DI4+D26 Total Inches =D6 32+32 Total Feet =F32/12 =W3-F33 TOTAL Vertical Horizontal RAI of November 18, 2003, Question #5 Page 7 of 7

ATTACHMENT 2 Revised Inputs, Assumptions, Results, and Regulatory Guide 1.183 Conformance Tables (Note : These tables supersede the tables provided in the original AST amendment request) Revised Tables Table 4 : Key LOCA Analysis Inputs and Assumptions Release Inputs - Primary and Secondary Containment Parameters Table 5 : Key LOCA Inputs and Assumptions Transport Inputs - Control Room Parameters Table 6 : Key LOCA Analysis Inputs and Assumptions Removal Inputs Table 10 : COCA Radiological Consequence Analysis - Dose Contributors Table 11 : LOCA Radiological Consequence Analysis - Totals Table 2 : Conformance with RG 1.183 Appendix A (Loss-of-Coolant Accident)

Table 4 : Key LOCA Analysis Inputs and Assumptions Release Inputs - Primary and Secondarry Containment Parameters In puVAssumption Value Radionuclide Release Pathways See Figure 1 Drywell Free Volume 241,699 cubic feet Containment Air Space Volume 1,512,341 cubic feet Minimum Suppression Pool Volume 146,400 cubic feet Primary Containment Leak Rate 0.65% per day for first 24 hours (L.) (SGTS Filtered and SC Bypass) 0.325% per day thereafter Total MSIV leak rate 250 scfh (100 scfh assumed for the two shortest lines) 159 scfh after 24 hours FWIV leak rate (Total for Two Penetrations) Containment atmosphere : 10.98 cfm from 21.15 minutes to 1 hour ECCS Water : 2 gpm from 1 hour to 24 hours 1 gpm after 24 hours Secondary Containment (SC) 10 minutes from start of gap release Drawdown Time Primary Containment Bypassing 8.0% L,, for first day Secondary Containment 4.0% La after first day ECCS Systems Leakage into Secondary Containment Time of Unfiltered Release : 10 minutes Leak Rate: 5 gpm Flashing Fraction : 1.365% High Volume Purge Penetrations (101 10% La / penetration for first day and 102) Leak Rate 1101 La / penetration after first day

(1) Sensitivity analyses determine that the - 10% limit is the bounding intake flow rate, but the effect of the variation is small Table 5: Key LOCA Analysis Inputs and Assumptions Transport Inputs - Control Room Parameters Input/Assumption Value Control Room Filtered Intake and 20 minutes Recirculation Air Filtration Initiation Time During this period of no filtration and (manual) no CR pressurization, an inleakage of 1650 cfm is assumed, which is 1/2 of assumed filter makeup value required for CR pressurization. Control Room Volume 324,000 cubic feet Control Room Filtered Air Intake Flow Rate : 3000 - 10% = 2700 cfm(l ) Elemental and Organic Iodine Efficiencies : 975% Aerosols Efficiencies : 995% Control Room Filtered Recirculation Rate 61,000 -- 10% = 54,900 cfm and Efficiency 70% - 2% (bypass) = 68% Allowable Control Room Filtered 2250 cfm Inleakage Rate (value assumed for the LOCH analysis) Control Room Unfiltered Inleakage Conservative Unfiltered Inleakage Allowance for a Known Filtered Allowance [cfm] = Inleakage ODF - IKF) 0.32 where : IDF = Allowable Filtered Inleakage 2250 cfm IKF = Known Filtered Inleakage

Table 6 : Key LOCA Analysis Inputs and Assumptions Removal Inputs Input/Assumption Value Containment Spray Removal Rates Not Credited Aerosol Natural Deposition Coefficients Credit is taken for natural deposition of Used in the Containment aerosols based on equations for the Power's model in NUREG/CR 6189 and input directly into RADTRAD as natural deposition time dependent lambdas. No credit is assumed for natural deposition of elemental or organic iodine, or for suppression pool scrubbing. Aerosol Deposition/Plate-out (where Calculated for horizontal segments only credited) using AEB-98-03 well-mixed model. Main Steam Line and Condenser No credit is taken for plate-out Deposition Credit for MSIV Leakage downstream of the MSIVs or in the condenser since these components have not been evaluated for seismic ruggedness. SGTS Filter Efficiencies - Elemental and Organic Iodine 97% Aerosols 99%

Including margin of 10%

Table 11 : LOCA Radiological Consequence Analysis - Totals* Location Duration TEDE (rem) Regulatory Limit TEDE (rem) Control Room 30 days 4.86 5 EAB Maximum, 2 hours 12.1 25 LPZ 30 days -105 25 Table 10: LOCA Radiological Consequence Analysis - Dose Contributors Dose Contributor Control EAB LPZ Room TEDE TEDE TEDE (rem) (rem) (rem) Filtered Primary Containment (PC) 1.327 2.912 1.059 Leakage PC Leakage bypassing SC, with no 0023 1976 (1964 piping deposition credit MSIV Leakage, without LCS but with 0.806 1.401 0.873 piping deposition credit FWIV LCS Leakage of ECCS Water 0.474 0.394 0.495 (unfiltered) FWIV Air Leakage before fill with 0.112 1.119 0.113 ECCS Water by LCS (unfiltered) PC Leakage through purge 0.0315 0.028 0.030 penetrations 101 and 102, with piping deposition credit ECCS Leakage in Secondary 0.155 0.139 0.146 Containment (SC) (unfiltered for 10 minutes, SGTS filtered thereafter) Gamma Shine to Control Room 0.590 100 t Total Calculated Value 4.42 3.68

17 of 30 Table 2: Conformance with RG 1.183 Appendix A (Loss-of-Coolant Accident) RG RG Position CPS Analysis Comments Section 4.3 The effect of high wind speeds on the ability of the secondary Conforms The potential for high wind containment to maintain a negative pressure should be evaluated on an speeds impacting the ability of individual case basis. The wind speed to be assumed is the 1-hour secondary containment to average value that is exceeded only 5% of the total number of hours in maintain negative pressures the data set. Ambient temperatures used in these assessments should for wind speeds has been be the 1-hour average value that is exceeded only 5% or 95% of the previously evaluated as total numbers of hours in the data set, whichever is conservative for the discussed in USAR Section intended use (e.g., if high temperatures are limiting, use those exceeded 6.5.1.1.1, where it is shown only 5%). that bypass of SGTS would not occur for wind speeds up to approximately 30 miles per hour. Inspection of the data set used in the development of the AST X/Qs shows that 30 mph is exceeded less than 5% of the time. 4.4 Credit for dilution in the secondary containment may be allowed when Conforms No credit is taken for adequate means to cause mixing can be demonstrated. Otherwise, the dilution/mixing in secondary leakage from the primary containment should be assumed to be containment. transported directly to exhaust systems without mixing. Credit for mixing, if found to be appropriate, should generally be limited to 50%. This evaluation should consider the magnitude of the containment leakage in relation to contiguous building volume or exhaust rate, the location of exhaust plenums relative to projected release locations, the recirculation ventilation systems, and internal walls and floors that impede stream flow between the release and the exhaust. 4.5 Primary containment leakage that bypasses the secondary containment Conforms Bypass leakage has been should be evaluated at the bypass leak rate incorporated in the technical analyzed at 8% of La. specifications. If the bypass leakage is through water, e.g., via a filled Additionally, the penetration piping run that is maintained full, credit for retention of iodine and 101 and 102 purge supply

18 of 30 Table 2 : Conformance with RG 1.183 Appendix A (Loss-of-Coolant Accident) RG RG Position CPS Analysis Comments Section aerosols may be considered on a case-by-case basis. Similarly, and exhaust penetrations are deposition of aerosol radioactivity in gas-filled lines may be considered analyzed separately with an on a case-by-case basis. additional 2% of La each, with deposition of radioactivity analyzed using RADTRAD with equivalent filter efficiencies developed from well mixed models and parameters described in AEB-98-03 with median settling velocities. Since doses through the 101 and 102 penetrations are analyzed separately, they need no longer be considered as among the penetrations controlled under the 8% of La bypass leakage limit. Release of MSIV leakage at CPS has previously been based on the use of the MSIVLCS to assure filtration by the SGTS. This system is no longer credited. MSIV leakage will have a separate technical specification limit of 250 scfh total leakage with not more that 100 scfh per line. The dose consequences for releases through this pathway (with piping

19 of 30 Table 2: Conformance with RG 1 :183 Appendix A (Loss-of-Coolant Accident) RG RG Position CPS Analysis Comments Section deposition credit) are separately calculated. Since doses from MSIV leakage are analyzed separately, they need not be considered as among the penetrations controlled under the 8% of L,, bypass leakage limit. Feedwater piping deposition has also been evaluated for the 1 hour period before the lines are filled using the FWLCS. As discussed above, piping deposition credit is determined using the well mixed models and parameters described in AEB-98-03, with median settling velocities as identified as acceptable. Delay in transit through these piping system is not credited. 4.6 Reduction in the amount of radioactive material released from the Conforms SGTS filters meet these secondary containment because of ESF filter systems may be taken into criteria and are therefore account provided that these systems meet the guidance of Regulatory credited at an efficiency of Guide 1.52 and Generic Letter 99-02. 99% for all iodine chemical forms. 5.1 With the exception of noble gases, all the fission products released from Conforms With the exception of noble the fuel to the containment as defined in Tables 1 and 2 of this guide) I I gases, all the fission products

22 of 30 Table 2: Conformance with RG 1.183 Appendix A (Loss-of-Coolant Accident) RG RG Position CPS Analysis Comments Section I i hf1 -hf2 FF = h f9 Where: hf, is the enthalpy of liquid at system design temperature and pressure ; hf2 is the enthalpy of liquid at saturation conditions (14.7 psia, 212°F) ; and hf9 is the heat of vaporization at 212°F. 5.5 If the temperature of the leakage is less than 212°F or the calculated Conforms An airborne release fraction of flash fraction is less than 10%, the amount of iodine that becomes 1.36% is used. Suppression airborne should be assumed to be 10% of the total iodine activity in the water pH is maintained above leaked fluid, unless a smaller amount can be justified based on the 7 for the entire 30 days actual sump pH history and area ventilation rates. accident dose assessment period. Under these conditions virtually none of the iodine will be in elemental form, and organic iodine formation will be inhibited. Because of the subcooled condition, the slow (on the order of one per day) air change rates, and the readily settleable nature of aerosol particulates that may spray from a leakage point, no flashing is expected. Nevertheless, the current design basis value, derived based on ORNL-TM-2412 methodology for iodine partition factor determination, 1 I i is used.

24 of 30 Table 2 : Conformance with RG 1.183 Appendix A (Loss-of-Coolant Accident) RG RG Position CPS Analysis Comments Section homogeneously mix throughout the drywell air space. Mixing of this activity into the containment air space is as discussed under Item 3.7 above. 6.2 All the MSIVs should be assumed to leak at the maximum leak rate Conforms MSIV leakage assumed in above which the technical specifications would require declaring the this accident analysis is 250 MSIVs inoperable. The leakage should be assumed to continue for the scfh for all steam lines and duration of the accident. Postulated leakage may be reduced after the 100 scfh for anyone line. A first 24 hours, if supported by site-specific analyses, to a value not less reduction in leakage of 50% is than 50% of the maximum leak rate. assumed at 24 hours, based on expected containment pressures at that time. 6.3 Reduction of the amount of released radioactivity by deposition and Conforms Modeling is with RADTRAD plateout on steam system piping upstream of the outboard MSIVs may with piping treated as well be credited, but the amount of reduction in concentration allowed will be mixed nodes. Equations for evaluated on an individual case basis. Generally, the model should be effective filter credit are per based on the assumption of well-mixed volumes, but other models such AEB-98-03. Settling as slug flow may be used if justified. velocities are median values per AEB-98-03. Organic iodine deposition is not credited. No credit is taken for deposition in the assumed broken inboard pipe segment. 6.4 In the absence of collection and treatment of releases by ESFs such as Conforms Since MSIVLCS is no longer the MSIV leakage control system, or as described in paragraph 6.5 credited, no ESFs are below, the MSIV leakage should be assumed to be released to the assumed to be available to environment as an unprocessed, ground-level release. Holdup and collect or treat MSIV leakage. dilution in the turbine building should not be assumed. Releases are assumed to be

25 of 30 Table 2 : Conformance with RG 1.183 Appendix A (Loss-of-Coolant Accident) RG RG Position C CPS Analysis Comments E Section from the combined exhaust stack, without credit for holdup or dilution in the condenser or turbine building. 6.5 A reduction in MSIV releases that is due to holdup and deposition in Conforms Main steam piping main steam piping downstream of the MSIVs and in the main downstream of the MSIVs is condenser, including the treatment of air ejector effluent by offgas credited for piping that is systems, may be credited if the components and piping systems used in capable of performing their the release path are capable of performing their safety function during safety function during and and following a safe shutdown earthquake (SSE). The amount of following an SSE. No credit is reduction allowed will be evaluated on an individual case basis. taken for deposition in piping Regulatory Guide 1.187 References A-9 and A-10 provide guidance on downstream of this, or in the acceptable models. condenser. 7.0 The radiological consequences from post-LOCA primary containment Conforms Containment purging as a purging as a combustible gas or pressure control measure should be combustible gas or pressure analyzed. If the installed containment purging capabilities are control measure is not maintained for purposes of severe accident management and are not required nor credited in any credited in any design basis analysis, radiological consequences need design basis analysis for 30 not be evaluated. If the primary containment purging is required within days following a design basis 30 days of the LOCA, the results of this analysis should be combined LOCA at CPS. with consequences postulated for other fission product release paths to Also see the Regulatory determine the total calculated radiological consequences from the Guide Section 3.8 discussion LOCA. Reduction in the amount of radioactive material released via in this Table. ESF filter systems may be taken into account provided that these systems meet the guidance in Regulatory Guide 1.52 and Generic Letter 99-02.}}

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