Letter Sequence Supplement |
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MONTHYEARML0507603812005-03-10010 March 2005
R. E. Ginna - Application for Amendment to Facility Operating License Proposed License Amendment to Provide a One-time Integrated Leak Rate Test (ILRT) Interval Extension
Project stage: Request
ML0516602822005-06-0808 June 2005
R. E. Ginna, Supplementary Information Associated with the Proposed License Amendment to Provide a One-Time Integrated Leak-Rate Test (ILRT) Interval Extension
Project stage: Supplement
ML0525104162005-08-31031 August 2005
Revised Supplementary Information Associated with the Proposed License Amendment to Provide a One-time Integrated Leak Rate Test (ILRT) Interval Extension
Project stage: Supplement
ML0534702012005-12-0808 December 2005
R. E. Ginna Nuclear Power Plant, 5.5.1 Offsite Dose Calculation Manual (ODCM)
Project stage: Other
ML0531303842005-12-0808 December 2005
R. E. Ginna Nuclear Power Plant - Amendment One-Time Extension of Containment Integrated Leakage Rate Test Interval
Project stage: Other
2005-03-10
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Text
Maria Korsnick 1503 Lake Road Vice President Ontario, New York 14519-9364 585.771.3494 585.771.3943 Fax maria.korsnick@ constellation.com Constellation Energy I R.E. Ginna Nuclear Power Plant August 31, 2005 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
R.E. Ginna Nuclear Power Plant Docket No. 50-244 Revised Supplementarv Information Associated with the Proposed License Amendment to Provide a One-time Integrated Leak Rate Test (ILRT) Interval Extension On June 8, 2005, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted additional information associated with a proposed license amendment request for a onetime extension to the ILRT interval frequency. Subsequent to the submittal of the additional information, as the result of recent discussions with the NRC staff, Ginna LLC would like to provide the attached update to the information provided in response to question 4 within the attachment to the June 28, 2005 correspondence.
There are no new commitments being made in this submittal. Should you have questions regarding the information in this submittal, please contact George Wrobel at (585) 771-3535 or george.wrobel~constellation.com.
Very truly yours Mary G. K nick P'oDi 100o13o 'L
STATE OF NEWYORK TO WIT:
COUNTY OF WAYNE I, Mary G. Korsnick, being duly sworn, state that I am Yice President - R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized-t6 execute and file this request on behalf of Ginna LLC.
To the best of my knowledge and belief, the statements contained in this document are true and correct.
To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees' and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
QAASL6 Subscribed and sworn before me, a Notary Public in and for the State of New York and County of m O r)Ito , this 3 ) dayof A~uA4U t 2005.
WITNESS my Hand and Notarial Seal:
, .Notary Public
-. ,,;,I . I
. 7. . - ' AON LAMER No"y RMe oNew i York Aqoad No' OlM16017755 UMe yt Ey&es Dom 21. 20.a
-Dis1io
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Attachment:
ILRT Frequency Extension Revised Supplemental Information cc: S. J. Collins, NRC D. M. Skay, NRC Resident Inspector, NRC t ,
.: 7 .,: , -,, ,
Peter R. Smith New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy NYS Department of Public Service 3 Empire Plaza, 10th Floor Albany, NY 12223-1350
ATTACHMENT ILRT Frequency Extension Revised Supplemental Information R.E. Ginna Nuclear Power Plant Page 1
ILRT Frequency Extension Revised Supplemental Information In response to Question 4, within the attachment to the June 28, 2005 supplemental information submittal, a table was provided comparing the risk assessment evaluation results for various methodologies. The methodologies included, the 1994 EPRI methodology, the NEI Interim Guidance from November 2001, and the EPRI "Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals", Document 1009325, Final Report, December 2003.
During the NRC staff review of the supplemental information the percentage increase in person-rem/yr associated with the proposed ILRT extension was questioned. The increase was higher than in other typical industry submittals.
As the result of the NRC staff question, Ginna LLC re-evaluated the basis for the dose results provided within the table. The increase was driven by the calculated 22,700 person-rem/accident with an intact containment. This value is obtained from a MACCS2 computer code using containment release fractions from the Severe Accident Mitigation Alternatives (SAMA) evaluation. In general, most release fractions less than 1E-5 were assigned a value of 1E-5 as a conservative lower limit. Further, a transcription error was made and the Csl release fraction was increased by several times. Using the correct Csl release fraction in the MACCS2 calculation caused the intact containment dose to drop by a factor of two. With the remaining radionuclides (i.e. Te, Ba, Sr, Mo, La, and Ce) limited to 1E-5, these radionuclides were contributing a substantial portion of the dose to the public. When other early release accidents were examined that contain a substantially higher amount of Csl released, the remaining "limited" radionuclides are one to three orders of magnitude lower than the Csl release fractions. Based on these other early release accidents, a ratioing approach was utilized to provide a more accurate estimate of release fractions that had been conservatively set to 1E-5, for the intact containment case.
The revised increase in person-rem/year over baseline for the NEI Interim Guidance methodology is 1.65%. In our last evaluation, the increase was 10.9%. The change from 10.9% to 1.65% is the result of adjusting the person-rem dose in a 50 miles radius as a result of each accident class. The 10.9% increase was based on 22,700 person-rem in a 50-mile radius/intact containment accident. The 1.65% increase was based on 3,270 person-rem in a 50-mile radius/intact containment accident, which results from the updated release fractions discussed above. The expected value in person-rem per year with the ILRT 3 times in ten years is 13.644. With the ILRT once per 15 yr, the value is 13.868 person-rem per year. This is a net change of 0.224 person-rem/yr in a 50 mile radius.
The power level was also adjusted to reflect a 17% Extended Power Uprate (EPU) versus a 10% EPU in the original SAMA evaluation. This change did not significantly affect the percentage increase in dose, but did slightly increase the overall dose. Other than the release fraction changes and power level changes, the remaining MACCS2 parameters used in the calculation remain the same. Attached are the revised results. The transcription error has been entered into the Ginna corrective action program.
R.E. Ginna Nuclear Power Plant Page 2
Attachment 1 NEI Interim EPRI to the March Guidance 1009325 10, 2005 Nov. 2001 Dec. 2003 letter When the ILRT interval is 15 years, the risk 0.61% of the 2.21% of 0.38% of the contribution of leakage (person-rem/yr) total risk. the total total risk.
represented by Class 3 accident scenarios risk.
is increased to:
The total integrated increase in risk 0.02% 0.68% 0.12%
contribution from reducing the ILRT test frequency from the once-per-1 0-year frequency to once-per-15 years is:
The total integrated increase in risk 0.07% 1.65% 0.28%
contribution from reducing the ILRT test frequency from 3-per-10-year (baseline) frequency to once-per-15 years is:
The risk increase in LERF from the original 2.44E-08/yr 5.20E-07/yr 4.67E-08/yr 3-in-10 years test frequency to once-per-15 years is:
The risk increase in LERF over the once- 7.38E-09/yr 2.17E-07/yr 1.95E-08/yr per-10 year test interval(per-year):
The increase in conditional containment 0.16% 0.4% 0.04%
failure probability (CCFP) from the once-per-10-year test interval:
The increase in conditional containment 0.49% 0.97% 0.09%
failure probability (CCFP) from the original 3-in-1 0 years test frequency to once-per-15 years is: . -
R.E. Ginna Nuclear Power Plant Page 3
