ML051080341

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RAI, Amendment to Implement Alternative Source Term
ML051080341
Person / Time
Site: Salem  PSEG icon.png
Issue date: 05/05/2005
From: Dan Collins
NRC/NRR/DLPM/LPD1
To: Levis W
Public Service Enterprise Group
Wunder G, NRR/DLPM, 415-1494
References
TAC MC3094, TAC MC3095
Download: ML051080341 (6)


Text

May 5, 2005 Mr. William Levis Senior Vice President & Chief Nuclear Officer PSEG Nuclear, LLC - X04 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, REQUEST FOR ADDITIONAL INFORMATION RE: AMENDMENT TO IMPLEMENT ALTERNATIVE SOURCE TERM (TAC NOS. MC3094 AND MC3095)

Dear Mr. Levis:

By letter dated April 26, 2004, PSEG Nuclear, LCC submitted a request for changes to the Salem Nuclear Generating Station, Unit Nos. 1 and 2, Technical Specifications. The proposed changes would allow the use of an alternate source term.

The Nuclear Regulatory Commission has determined that responses to the questions in the enclosure to this letter are necessary in order for the staff to complete its review. The questions in the enclosure consolidate questions that were forwarded electronically or by fax to Mr. Jesus Arias on March 15, April 12, and April 25, 2005. These questions were discussed in several telephone calls with Mr. Arias and other members of your staff.

In order to complete our timely review of your amendment request, we require your response within 30 days from the date of this letter. If you cannot respond within 30 days, please inform us in writing why you cannot respond and provide an alternate response date. This alternate response date must be no later than 60 days from the date of this letter.

Please note that if you do not respond to this letter within 30 days or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, I can be reached at (301) 415-1494.

Sincerely,

/RA/

Daniel S. Collins, Sr. Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

Request for Additional Information cc w/encl: See next page

Mr. William Levis Senior Vice President & Chief Nuclear Officer PSEG Nuclear, LLC - X04 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, REQUEST FOR ADDITIONAL INFORMATION RE: AMENDMENT TO IMPLEMENT ALTERNATIVE SOURCE TERM (TAC NOS. MC3094 AND MC3095)

Dear Mr. Levis:

By letter dated April 26, 2004, PSEG Nuclear, LCC submitted a request for changes to the Salem Nuclear Generating Station, Unit Nos. 1 and 2, Technical Specifications. The proposed changes would allow the use of an alternate source term.

The Nuclear Regulatory Commission has determined that responses to the questions in the enclosure to this letter are necessary in order for the staff to complete its review. The questions in the enclosure consolidate questions that were forwarded electronically or by fax to Mr. Jesus Arias on March 15, April 12, and April 25, 2005. These questions were discussed in several telephone calls with Mr. Arias and other members of your staff.

In order to complete our timely review of your amendment request, we require your response within 30 days from the date of this letter. If you cannot respond within 30 days, please inform us in writing why you cannot respond and provide an alternate response date. This alternate response date must be no later than 60 days from the date of this letter.

Please note that if you do not respond to this letter within 30 days or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, I can be reached at (301) 415-1494.

Sincerely,

/RA/

Daniel S. Collins, Sr. Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION PUBLIC GMiller RDennig JRaval GMatakas, RI ACRS DCollins JLee OGC PDI-2 Reading DRoberts CRaynor DLPM DPR GWunder ADAMS Accession Number: ML051080341 OFFICE PDI-2/LA PDI-2/PM SPSB-C/SC PDI-2/SC NAME CRaynor DCollins A Drozd for RDenning DRoberts DATE 5/4/05 5/3/05 5/3/05 5/3/05 OFFICIAL RECORD COPY

Salem Nuclear Generating Station, Unit Nos. 1 and 2 cc:

Mr. Michael H. Brothers Vice President - Nuclear Assessments PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. Michael Gallagher Vice President - Eng/Tech Support PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. Thomas P. Joyce Site Vice President - Salem PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Ms. Christina L. Perino Director - Regulatory Assurance PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. George H. Gellrich Plant Support Manager PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Jeffrie J. Keenan, Esquire PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038 Ms. R. A. Kankus Joint Owner Affairs PECO Energy Company Nuclear Group Headquarters KSA1-E 200 Exelon Way Lower Alloways Creek Township c/o Mary O. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection and Energy CN 415 Trenton, NJ 08625-0415 Brian Beam Board of Public Utilities 2 Gateway Center, Tenth Floor Newark, NJ 07102 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector Salem Nuclear Generating Station U.S. Nuclear Regulatory Commission Drawer 0509 Hancocks Bridge, NJ 08038 Mr. Carl J. Fricker Plant Manager PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038

Enclosure REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED AMENDMENT REQUEST FOR IMPLEMENTATION OF ALTERNATIVE SOURCE TERM SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter dated April 26, 2004, PSEG Nuclear, LLC (PSEG) submitted a request for changes to the Salem Nuclear Generating Station, Units No. 1 and 2 (Salem), Technical Specifications (TSs). The proposed changes would revise the source term used for design-basis radiological analysis. The proposed change would also revise certain requirements in the TSs and Updated Final Safety Analysis Report based on the radiological dose analysis margins obtained in the Alternate Source Term application. The Nuclear Regulatory Commission (NRC) staff has been reviewing your submittal and has determined that the following additional information is required to complete our review:

(1)

With respect to TS 3/4.7.7, Auxiliary Building Exhaust Air filtration Ventilation System, you are requesting the removal of the TS requirements, including the existing 24-hour limiting condition for operation, for the auxiliary building ventilation filtration system. You stated that this change is justified under the Title 10 of the Code of Federal Regulations Section 50.36.

Provide a specific justification for the removal of the TS for the high-efficiency particulate air filter and adsorber. We are requesting a specific and detailed discussion of the rationale for maintaining TS requirements for fans that will maintain a negative pressure in the auxiliary building while not having a requirement to filter the building's exfiltration.

(2)

Page 12 of Attachment 1 to PSEG letter LR-N04-0021/LCR S03-05 dated April 26, 2004, states that the inleakage of unfiltered air into the control room was modeled using the control room intake /Q values. Based on the results of the tracer gas testing performed on the Salem control room envelope, please confirm that there are no potential unfiltered inleakage pathways during pressurization mode that could result in

/Q values that are higher than the control room intake /Q values.

(3)

It appears /Q values were calculated for each release-receptor combination to identify the more favorable air intake (i.e., the air intake with the lower /Q value) and the less favorable air intake (i.e., the air intake with the higher /Q value) for each of the three release scenarios. Please confirm that (1) the /Q values for the more favorable control room air intake were used to evaluate filtered air makeup during the pressurization mode, and (2) the /Q values for the least favorable control room air intake were used to evaluate unfiltered air makeup prior to the pressurization mode and unfiltered inleakage during the pressurization mode.

(4)

Some of the main steam safety valve (MSSV) release scenarios modeled with ARCON96 assumed a horizontal distance to the receptor from the release point of less than 10 meters. Section 3.4 of Regulatory Guide (RG) 1.194 states that if the distance to the receptor is less than about 10 meters, the ARCON96 code should not be used to assess /Q values. These situations should be addressed on a case-by-case basis.

(5)

Outside of containment, each steamline has one pneumatically operated atmospheric relief valve (ARV) and five self-actuated spring-loaded safety valves. The ARV can be manually operated, whereas the five MSSVs only open at or above their setpoint pressures. Because of the assumptions in design-basis calculations, a loss of offsite power and seismic or Q pedigree is required for accident mitigation. Since the ARVs are not fully Q, they are not considered in the analysis. However, the ARVs are diesel-backed and can be operated according to the emergency operating procedures to lower steam generator pressures. As the transient progresses, lower steam generator pressures will create ARV plumes with lower exit velocities. Please confirm that (1) a stuck-open ARV or MSSV is not part of Salems licensing basis, and (2) planned steam releases from the ARVs will result in lower doses as compared to automatic releases from the MSSVs.

(6)

The penetration area pressure relief panel (PAPRP) releases have been modeled as area source releases. How many pressure relief panels are there per unit, and how many of these panels are assumed to rupture? According to Section 3.2.4.5 of RG 1.194, the height and width of area sources should be taken as the maximum vertical and horizontal dimensions of the release area perpendicular to the line-of-sight from the center of the release area to the control room intake (see RG 1.194, Figure 2).

These dimensions should be projected onto a vertical plane perpendicular to the line-of-sight and located at the closest point on the release area to the control room intake. The release height should be set at the vertical center of the projected plane.

The source-to-receptor distance (slant path) should be measured from this point to the control room intake. Please confirm that this is the methodology used to model the PAPRP releases.

(7)

PSEG Calculation S-C-ZZ-MDC-1959 Revision 0IR1 presents /Q values for smoke hatch releases. Were these /Q values used in any of the control room dose assessments?

(8)

Page 25 of Attachment 1 to PSEG letter LR-N04-0021/LCR S03-05 dated April 26, 2004, states that the site boundary /Q values were accepted by the staff in a previous licensing proceeding. Please identify the licensing proceeding where these /Q values were approved by the NRC staff. Additionally, please confirm that these exclusion area boundary (EAB) and low-population zone (LPZ) /Q values remain applicable for use in the dose assessment related to this license amendment request.

(9)

Provide emergency core cooling system (ECCS) potential leakage pathways to the environment from the auxiliary building following the postulated loss-of-coolant accident (LOCA) with an isometric diagram (non-scaled sketch) showing, but not limited to, relative locations of potential leakage points (charging pumps, safety injection pumps, containment spray pumps, residual heat removal (RHR) pumps), RHR pump room, heat exchanger room, valve room, and the waste holdup tanks, including associated drain lines (open and closed), and vent lines.

In describing and depicting the pathways above, please consider various ECCS leakage rates of up to 2 gallons per minute (gpm) assumed in the radiological consequence analyses.

(10)

Provide the sump water pH and temperature as a function of time up to 30 days following the postulated LOCA.

(11)

Provide the radiological consequence doses at the EAB, at LPZ, and in the control room resulting from various postulated ECCS leakage rates (up to 2 gpm) for the duration of a 30-day accident period using:

a constant enthalpy equation based on Salems specific sump water temperature and pressure circulation outside the containment following the postulated LOCA for the duration of the sump water temperature greater than 190 EF to determine the amount of iodine that becomes airborne, 2% of iodine to become airborne from the ECCS leaking fluid during the entire duration of a 30-day accident period to bound uncertainty, no plate out of iodine in the auxiliary building, and corresponding iodine source terms and evaporation rates (to dryness) for each leakage rate assumed.

(12)

You have identified in your response to an NRC Request for Additional Information all possible post-accident liquid inputs to the cubicle where the ECCS leakage occurs.

Please state if there are any other chemical species and materials (e.g., lubricant, oil) in these liquid inputs to the RHR sumps and cubicles in a post-LOCA environment. Please state if you store any material in the RHR room and cubicles.