ML060460538

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Request for Additional Information Alternate Source Term for Reevaluation of the Fuel Handling Accident Dose Consequences
ML060460538
Person / Time
Site: Cooper Entergy icon.png
Issue date: 02/09/2006
From: Brian Benney
Plant Licensing Branch III-2
To: Edington R
Nebraska Public Power District (NPPD)
Benney B, NRR/DLPM, 415-3764
References
TAC MC8566
Download: ML060460538 (6)


Text

February 9, 2006 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION RE: ALTERNATE SOURCE TERM FOR REEVALUATION OF THE FUEL HANDLING ACCIDENT DOSE CONSEQUENCES (TAC NO. MC8566)

Dear Mr. Edington:

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in the September 29, 2005, submittal and has determined that the additional information identified in this enclosure is required in order for the NRC staff to complete its review. The licensee requested NRC staff approval of the subject relief request by September 1, 2006. To meet that target date, the NRC staff requests that the licensee provide its response no later than March 30, 2006.

Sincerely,

/RA/

Brian Benney, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosure:

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

February 9, 2006 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION RE: ALTERNATE SOURCE TERM FOR REEVALUATION OF THE FUEL HANDLING ACCIDENT DOSE CONSEQUENCES (TAC NO. MC8566)

Dear Mr. Edington:

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in the September 29, 2005, submittal and has determined that the additional information identified in this enclosure is required in order for the NRC staff to complete its review. The licensee requested NRC staff approval of the subject relief request by September 1, 2006. To meet that target date, the NRC staff requests that the licensee provide its response no later than March 30, 2006.

Sincerely,

/RA/

Brian Benney, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosure:

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

PUBLIC RidsNrrDorl (CHaney/CHolden)

LPLIV r/f RidsRgn4MailCenter (KKennedy)

RidsNrrLALFeizollahi RidsNrrDpr RidsNrrPMBBenney RidsOgcRp RidsNrrDorlLplg (DTerao)

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RidsAcrsAcnwMailCenter ADAMS ACCESSION NO: ML060460538 NRR-106 OFFICE LPL4/PM LPL4/LA AADB/BC LPL4/BC NAME BBenney LFeizollahi MKotzalas DTerao DATE 02/09/06 02/09/06 1/25/06 02/09/06 OFFICIAL RECORD COPY G:\\ADRO\\DORL\\LPLG\\Cooper\\MC8566RAI.wpd

REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FUEL HANDLING ACCIDENT - ALTERNATIVE SOURCE TERM AMENDMENT FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298 1.

The radiological dose analysis submitted in support of this license amendment request assumed the Regulatory Guide (RG) 1.183, Table 3, non-loss-of-coolant accident gap fractions. The release fractions listed in RG 1.183, Table 3, are acceptable for use with fuels having a peak burnup up to 62 gigawatt days per metric ton uranium (GWD/MTU) provided that the maximum linear heat generation rate does not exceed the 6.3 kilowatt per foot peak rod average power for burnups exceeding 54 GWD/MTU. Please verify that the fuel used at Cooper Nuclear Station (CNS) meets these criteria.

2.

The radiological dose analysis assumed that there is no means of isolating the radiological activity associated with a fuel handling accident (FHA) release within the reactor building (i.e., no credit is taken for maintaining the secondary containment boundary). Please identify all the possible release points for the FHA, when the reactor building is open to the environment and the standby gas treatment system and secondary containment are inoperable. Also, justify why the reactor building vent release pathway is assumed to bound all these other possible release pathways for the control room dose assessment. Provide a figure, or figures, showing structures and assumed paths of air flow in your response.

3.

Item 2 of Section 10.4.2 (Main Control Room Air Conditioning and Habitability Controls - Safety Design Basis) of the CNS Updated Safety Analysis Report (USAR) states that the main control room air-conditioning system and habitability controls isolate the main control room outside air intake on a Group 2 or Group 6 primary containment isolation system isolation signal. This statement appears to conflict with CNS USAR Section 10.4.5.2 (Main Control Room Air Conditioning and Habitability Controls -

Control Room Emergency Filter [CREF] System) which states that the control room envelope remains pressurized during a radiological emergency mode of operation by channeling all outside air through the CREF system. Please explain this apparent discrepancy.

4.

The term recently irradiated fuel assemblies is being introduced in the applicability and action statements for several technical specifications (TSs). In some cases (i.e., TSs 3.3.6.2, 3.6.4.1, 3.6.4.2, and 3.6.4.3), this term is defined in the corresponding TS bases as fuel that has occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; in other cases (i.e., TSs 3.3.7.1 and 3.7.4), this term is defined in the corresponding TS bases as fuel that has occupied part of a critical reactor core within the previous 7 days.

Please explain how using the same term (i.e., recently irradiated fuel assemblies) with different definitions within the TSs will not cause confusion.

5.

A commitment has been made (i.e., Commitment Number NLS2005075-02) to ensure that either a reactor building exhaust fan, a standby gas treatment (SGT) system fan, or the CREF system is in operation prior to conducting fuel handling operations when less than a 7-day decay time has elapsed. Since the CREF system initiates on high radiation detected in the reactor building exhaust plenum, either a reactor building exhaust fan or an SGT system fan must be operational to ensure ventilation flow in the exhaust plenum at the start of the FHA. Please describe the TSs or administrative controls that will be implemented to ensure that either a reactor building exhaust fan, an SGT system fan, or the CREF system will be in operation for the entire 7-day decay time period after fuel handling operations have begun.

6.

The two commitments that have been made (i.e., Commitment Numbers NLS2005075-01 and NLS2005075-02) are to be implemented within 30 days of issuance of the requested license amendment. Could the movement of recently irradiated fuel assemblies in secondary containment occur prior to the implementation of these two commitments?

February 2006 Cooper Nuclear Station cc:

Mr. William J. Fehrman President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. Gene Mace Nuclear Asset Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. John C. McClure Vice President and General Counsel Nebraska Public Power District P. O. Box 499 Columbus, NE 68602-0499 Mr. Paul V. Fleming Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. Michael J. Linder, Director Nebraska Department of Environmental Quality P. O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Mr. H. Floyd Gilzow Deputy Director for Policy Missouri Department of Natural Resources P. O. Box 176 Jefferson City, MO 65102-0176 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Director, Missouri State Emergency Management Agency P. O. Box 116 Jefferson City, MO 65102-0116 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson Suite 310 Topeka, KS 66612-1366 Mr. Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319 Mr. Keith G. Henke, Planner Division of Community and Public Health Office of Emergency Coordination 930 Wildwood P.O. Box 570 Jefferson City, MO 65102 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. John F. McCann, Director Licensing, Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601-1813