RS-06-008, Partial Withdrawal of Changes Related to Request for License Amendment Related to Application of Alternative Source Term
| ML060790055 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 03/17/2006 |
| From: | Bauer J Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-06-008 | |
| Download: ML060790055 (19) | |
Text
RS-06-008 March 17, 2006 U. S. Nuclear Regulatory Commission Attn : Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 10 CFR 50.90 Subject :
Partial Withdrawal of Changes Related to Request for License Amendment Related to Application of Alternative Source Term References :
(1)
Letter from K. R. Jury (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Request for License Amendment Related to Application of Alternative Source Term," dated February 15, 2005 (2)
Letter from J. A. Benjamin (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to U. S. Nuclear Regulatory Commission, "Exelon/Amergen Request for Amendment to Technical Specifications Administrative Controls to Incorporate Requirement for Control Room Envelope Integrity Program," dated November 29, 2004 Letter from K. R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to U. S. Nuclear Regulatory Commission, "Withdrawal of Exelon/AmerGen License Amendment Request Related to Administrative Controls Incorporating Requirements for Control Room Envelope Integrity Program," dated July 11, 2005 In Reference 1, Exelon Generation Company, LLC (EGC) requested an amendment to Appendix A Technical Specifications (TS), of Facility Operating License Nos. NPF-72, NPF-77, NPF-37, and NPF-66 for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, respectively. The proposed changes were requested to support application of an alternative source term methodology in accordance with 10 CFR 50.67, "Accident Source Term." The proposed TS changes included changes to TS 3.7.10, "Control Room Ventilation (VC) Filtration System," Surveillance Requirement (SR) 3.7.10.4. The proposed changes to TS SR 3.7.10.4 were justified, in part, by the requirements of the Braidwood Station and Byron Station Control Room Envelope Integrity Program proposed in Reference 2.
U. S. Nuclear Regulatory Commission March 17, 2006 Page 2 In Reference 3, Exelon Generation Company, LLC/AmerGen Energy Company, LLC, at the request of the NRC, withdrew the proposed license amendment request to incorporate the Control Room Envelope Integrity Program into the TS. Because the Control Room Envelope Integrity Program license amendment request was withdrawn, EGC has determined that the proposed associated changes to TS SR 3.7.10.4 should also be withdrawn. EGC intends to re-evaluate the change to TS SR 3.7.10.4 for possible submittal at a later date.
To aid in your review of the license amendment request provided in Reference 1, the following information is attached to this submittal : shows page 5 of 72 of Reference t Attachment 1 with the proposed change to TS SR 3.7.10.4 marked for deletion. provides a revised version of Reference 1, Attachment 1, page 5 of 72, following deletion of the text associated with the change to TS SR 3.7.10.4.
Enclosures 3-A and 3-13 provide revised Reference 1, Attachments 3A, 3B, 2A, 213 cover pages and TS Bases pages, for information only, affected by the withdrawal of the Control Room Envelope Integrity Program for Braidwood Station and Byron Station, respectively.
Replacement pages for Braidwood Station and Byron Station TS page 3.7.10-4 are not included because this withdrawal restores TS page 3.7.10-4 to the current requirements. Changes to the requirements specified on TS page 33.10-4 are not required to support application of an alternative source term methodology.
This partial withdrawal does not affect the supporting analyses for the original license amendment request as described in Reference 1. No other information submitted with Reference 1 is affected by this change. The No Significant Hazards Consideration and the Environmental Consideration provided in Attachment 1 of Reference 1 are not affected by this change.
EGC is notifying the State of Illinois of this partial withdrawal by sending a copy of this letter and its attachments to the designated State Official.
If you have any questions about this letter, please contact David Chrzanowski at (630) 657-2816.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17`" day of March 2006.
Respectfully, Joseph A. Bauer Manager - Licensing
U. S. Nuclear Regulatory Commission March 17, 2006 Page 3 : Markup of Attachment 1, Page 5 : Revised Attachment 1, Page 5 -A: Revised Attachments and Typed Technical Specifications Bases Pages for Braidwood Station -B: Revised Attachments and Typed Technical Specifications Bases Pages for Byron Station BRAIDWOOD STATION UNITS 1 AND 2 Docket Nos. STN 50-456 and STN 50-457 License Nos. NPF-72 and NPF-77 and BYRON STATION UNITS 1 AND 2 Docket Nos. STN 50-454 and STN 50-455 License Nos. NPF-37 and NPF-66 Partial Withdrawal of Changes Related to Request for License Amendment Related to Application of Alternative Source Term Markup of Attachment 1, Page 5 of "Request for License Amendment Related to Application of Alternative Source Term," dated February 15, 2005 (Reference 1)
TTACHMENTI of Proposed Changes TS 3.7.10, WC Filtration System" Condition -C-age 3.7.10-2)
REQUIRED ACTION C.2.1 and its completion time regarding suspension of CORE ALTERATIONS are deleted. REQUIRED ACTION C.2.2 and C.2.3 are renumbered to support deletion of C.2.1. This is done in accordance with the guidance in TSTF-51 and supported by the AST analysis, TS 3.7.10, "VC Filtration System Condition fpaq Q
_Q3.7,10-3I REQUIRED ACTION DA and its completion time regarding suspension of CORE ALTERATIONS are removed.
REQUIRED ACTION D.2 and D.3 are renumbered to support deletion of D.1. This is done in accordance with the guidance in TSTF-51 and supported by the AST analysis.
(page 3.7.10-4) cable spreading room at positive pressq
. The word "area" (i.e., in the sta area during...") is replaced with the word NUREG 1431, "Standard Tec justified by the req Room En 0-s-111VID pressure.
TS LCO 3.7.13 Applicability Statement (page 3.7.13-1) inches water gauge
...adjacent to the control room his change is consistent with pecifications, Westinghouse Plants," and is fort the proposed Byron Station and Braidwood Sjat4onl ;ontrol which verifies that the control roo 5 of 72 TS LCO 3.7.11, "VC Temperature Control System" Condition image 3_._7._11_-2}
aq__ __ _
REQUIRED ACTION C.2.1 and its completion time regarding suspension of CORE ALTERATIONS are removed. Required Action C.2.2 and C.2.3 are renumbered to support deletion of C.2.1. This is done in accordance with the guidance in TSTF-51 and supported by the AST analysis.
TS LCO 3.7.11, "VC Temperature Control System" Condition D (page 3.7.11-3)
REQUIRED ACTION DA and its completion time regarding suspension of CORE ALTERATIONS are removed. Required Action D.2 and D.3 are renumbered to support deletion of D.1. This is done in accordance with the guidance in TSTF-51 and supported by the AST analysis.
The term "irradiated fuel" is replaced with the words "RECENTLY IRRADIATED FUEL" accordance with the guidance in TSTF-51. The reference to suspension of CORE ALTERATIONS is removed. This change is supported by the AST analysis.
TS LCO 3.7.13 Required Actions for Condition B (continued) (page 3.7.13-2)
The term "irradiated fuel" in REQUIRED ACTION 8.2.1 and 8.2.2 is replaced with the term "RECENTLY IRRADIATED FUEL". REQUIRED ACTION 8.2.3 regarding the suspension of CORE ALTERATIONS is deleted. These changes are in accordance with the guidance in TSTF-51 and supported by the AST analysis.
BRAIDWOOD STATION UNITS 1 AND 2 Docket Nos. STN 50-456 and STN 50-457 License Nos. NPF-72 and NPF-77 and BYRON STATION UNITS 1 AND 2 Docket Nos. STN 50-454 and STN 50-455 License Nos. NPF-37 and NPF-66 Partial Withdrawal of Changes Related to Request for License Amendment Related to Application of Alternative Source Term Revised Attachment 1, Page 5 of "Request for License Amendment Related to Application of Alternative Source Term," dated February 15, 2005 (Reference 1)
TS 3.7.10, WC Filtration System" Condition C (page 3.7,10-2 REQUIRED ACTION C.2.1 and its completion time regarding suspension of CORE ALTERATIONS are deleted. REQUIRED ACTION C.2.2 and C.2.3 are renumbered to support deletion of G.2.1. This is done in accordance with the guidance in TSTF-51 and supported by the AST analysis.
TS 3.7.10, WC ATTACHMENT 1 Evaluation of Proposed Changes n System"' Condition D (page 3.7.10-3)
REQUIRED ACTION DA and its completion time regarding suspension of CORE ALTERATIONS are removed, REQUIRED ACTION D.2 and D.3 are renumbered to support deletion of D.1. This is done in accordance with the guidance in TSTF-51 and supported by the AST analysis.
TS LCO3.7.11, "VC Temperature Control System" Condition C (page 3.7.11-2)
REQUIRED ACTION C.2.1 and its completion time regarding suspension of CORE ALTERATIONS are removed. Required Action C.2.2 and C.2.3 are renumbered to support deletion of C.2.1. This is done in accordance with the guidance in TSTF-51 and supported by the AST analysis.
TS LCO 3.7.11, "VC Temperature Control System" Condition D (page 3.7.11-3}
REQUIRED ACTION DA and its completion time regarding suspension of CORE ALTERATIONS are removed.
Required Action D.2 and D.3 are renumbered to support deletion of D.1. This is done in accordance with the guidance in TSTF-51 and supported by the AST analysis.
TS LCO 3.7.13 Applicability Statement (page alAl-n The term "irradiated fuel" is replaced with the words "RECENTLY IRRADIATED FUEL" i accordance with the guidance in TSTF-51. The reference to suspension of CORE ALTERATIONS is removed. This change is supported by the AST analysis.
TS LCO 31.13 Required Actions for Condition B (continued) (page 3.7.13-2)
The term "irradiated fuel" in REQUIRED ACTION 8.2.1 and 8.2.2 is replaced with the term "RECENTLY IRRADIATED FUEL". REQUIRED ACTION 8.2.3 regarding the suspension of CORE ALTERATIONS is deleted. These changes are in accordance with the guidance in TSTF-51 and supported by the AST analysis.
-A BRAIDWOOD STATION UNITS 1 AND 2 Docket Nos. STN 50-456 and STN 50-457 License Nos. NPF-72 and NPF-77 Partial Withdrawal of Changes Related to Request for License Amendment Related to Application of Alternative Source Term Revised Reference 1, Attachments 213 and 313 and Typed Technical Specifications Bases Pages (For Information only)
B 3.7-10-2 B 3.7.10-4 B 3.7.10-8
ATTACHMENT 2B BRAIDWOOD STATION UNITS 1 AND 2 Docket Nos. 50-456 and 50-457 License Nos. NPF-72 and NPF-77 License Amendment Request "Alternative Source Term Implementation" Markup of Technical Specification Pages 1.1-3 1.1-6 3.3.7-2 3.3.7-3 3.3.7-4 3.3.8-2 3.3.8-4 3.7.10-2 3.7.10-3 3.7.11-2 3.7.11-3 3.7.13-1 3.7.13-2 3.7.13-3 3.7.13-4 3.9.4-1 3.9.4-2 3.9.7-1 5.5-17 5.5-18 5.5-24
ATTACHMENT 3B BRAIDWOOD STATION UNITS 1 AND 2 Docket Nos. 50-456 and 50-457 License Nos. NPF-72 and NPF-77 License Amendment Request "Alternative Source Term Implementation" Typed Technical Specification Pages 1.1-3 1.1-6 3.3.7-2 3.3.7-3 3.3.8-2 3.3.8-4 3.7.10-2 3.7.10-3 3.7.11-2 3.7.11-3 3.7.13-1 3.7.13-2 3.7.13-3 3.7.13-4 3.9.4-1 3.9.4-2 3.9.7-1 5.5-17 5.5-18 5.5-24
BASES BACKGROUND (continued)
VC Filtration System B 3.7.10 Actuation of the VC Filtration System places the system in the emergency mode of operation.
Actuation of the system to the emergency mode of operation ; starts the makeup fan, opens the turbine building intake damper, isolates the normal intake from outside dampers, isolates the purge dampers (if open), opens the recirculation charcoal adsorber dampers, and closes the recirculation charcoal adsorber bypass dampers.
The operating supply and return fans continue to operate.
Interlocks are provided such that the makeup fan will not start unless the associated supply fan is in operation.
Outside air is filtered and then mixed with the air being recirculated through the control room.
Pressurization of the control room minimizes infiltration of unfiltered air from the areas adjacent to the control room envelope.
The air entering the control room is continuously monitored by radiation detectors.
One outside air intake detector output above the alarm setpoint will cause actuation of the emergency mode of operation and trip the Control Room Offices HVAC (VV), Laboratory HVAC AL), and Radwaste Building Ventilation AW) Systems.
The VC Filtration System will not automatically realign to the Turbine Building makeup air intake upon receipt of a high radiation or Safety Injection (SI) signal when a VC Filtration System Emergency Makeup Filter unit is in operation and aligned to the outside air intake.
One VC Filtration System train can pressurize the control room to ? 0.125 inches water gauge, relative to areas adjacent to the control room envelope.
The control room and the control room envelope are defined in UFSAR Section 6.4 (Ref. 1).
The control room is contained within the control room envelope.
The areas within the control room envelope, external to the control room, are maintained at a positive pressure.
Redundant filter trains are provided such that if an excessive pressure drop develops across one filter train, the other train is available to provide the required filtration.
BRAIDWOOD - UNITS 1 & 2 B 3.7.10 - 2 Revision xx
BASES VC Filtration System B 3.7.10 LCO Two independent and redundant VC Filtration System trains are required to be OPERABLE to ensure that at least one is available assuming a single failure disables the other train.
Total system failure could result in exceeding a TEDE dose of 5 rem to the control room operator in the event of a large radioactive release.
The VC Filtration System is considered OPERABLE when the individual components necessary to limit operator exposure are OPERABLE in both trains.
A VC Filtration System train is OPERABLE when the associated :
Makeup air fan is OPERABLE ;
b.
Supply fan is OPERABLE ;
C.
Return air fan is OPERABLE ;
d.
HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions ; and e.
Makeup filter unit heater, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.
In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.
APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and at all times during movement of irradiated fuel assemblies in the fuel handling building or containment, the VC Filtration System must be OPERABLE to control operator exposure during and following a DBA, including the release from a fuel handling accident.
In MODE 5 or 6, the VC Filtration System provides protection from significant radioactive releases.
BRAIDWOOD - UNITS 1 & 2 B 3.7.10 - 4 Revision x
BASES SURVEILLANCE REQUIREMENTS (continued)
REFERENCES 1.
2.
3.
4.
5.
6.
7.
SR 3.7.10.4 UFSAR, Section 6.4.
UFSAR, Section 9.4.
UFSAR, Chapter 15.
UFSAR, Section 2.2.
Regulatory Guide 1.52, Rev. 2.
NUREG-0800, Section 6.4, Rev. 2, July 1981.
VC Filtration System B 3.7.10 This SR verifies the integrity of the control room enclosure, and the assumed inleakage rates of the potentially contaminated air.
The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the VC Filtration System.
During the emergency mode of operation, the VC Filtration System is designed to pressurize the upper cable spreading room to ? 0.02 inches water gauge and the control room to ? 0.125 inches water gauge, relative to areas adjacent to the control room area in order to minimize unfiltered inleakage.
The VC Filtration System is designed to maintain this positive pressure with one train at a makeup flow rate ~! 5400 cfm and
<_ 6600 cfm.
The Frequency of 18 months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800 (Ref. 6).
BRAIDWOOD - UNITS 1 & 2 B 3.7.10 - 8 Revision x
-13 BYRON STATION UNITS 1 AND 2 Docket Nos. STN 50-454 and STN 50-455 License Nos. NPF-37 and NPF-66 Partial Withdrawal of Changes Related to Request for License Amendment Related to Application of Alternative Source Term Revised Reference 1, Attachments 2A and 3A and Typed Technical Specifications Bases Pages (For Information only)
B 3.7.10-2 B 3.7.10-4 B 3.7.10-8
ATTACHMENT 2A BYRON STATION UNITS 1 AND 2 Docket Nos. 50-454 and 50-455 License Nos. NPF-37 and NPF-66 License Amendment Request "Alternative Source Term Implementation" Markup of Technical Specification Pages 1.1-3 1.1-6 3.3.7-2 3.3.7-3 3.3.7-4 3.3.8-2 3.3.8-4 3.7.10-2 3.7.10-3 3.7.11-2 3.7.11-3 3.7.13-1 3.7.13-2 3.7.13-3 3.7.13-4 3.9.4-1 3.9.4-2 3.9.7-1 5.5-17 5.5-18 5.5-24
ATTACHMENT 3A BYRON STATION UNITS 1 AND 2 Docket Nos. 50-454 and 50-455 License Nos. NPF-37 and NPF-66 License Amendment Request "Alternative Source Term Implementation" Typed Technical Specification Pages 1.1-3 1.1-6 3.3.7-2 3.3.7-3 3.3.8-2 3.3.8-4 3.7.10-2 3.7.10-3 3.7.11-2 3.7.11-3 3.7.13-1 3.7.13-2 3.7.13-3 3.7.13-4 3.9.4-1 3.9.4-2 3.9.7-1 5.5-17 5.5-18 5.5-24
BASES BACKGROUND (continued)
VC Filtration System B 3.7.10 Actuation of the VC Filtration System places the system in the emergency mode of operation.
Actuation of the system to the emergency mode of operation ; starts the makeup fan, opens the turbine building intake damper, isolates the normal intake from outside dampers, isolates the purge dampers (if open), opens the recirculation charcoal adsorber dampers, and closes the recirculation charcoal adsorber bypass dampers.
The operating supply and return fans continue to operate.
Interlocks are provided such that the makeup fan will not start unless the associated supply fan is in operation.
Outside air is filtered and then mixed with the air being recirculated through the control room.
Pressurization of the control room minimizes infiltration of unfiltered air from the areas adjacent to the control room envelope.
The air entering the control room is continuously monitored by radiation detectors.
One outside air intake detector output above the alarm setpoint will cause actuation of the emergency mode of operation and trip the Control Room Offices HVAC (VV) System.
The VC Filtration System will not automatically realign to the Turbine Building makeup air intake upon receipt of a high radiation or Safety Injection (SI) signal when a VC Filtration System Emergency Makeup Filter unit is in operation and aligned to the outside air intake.
One VC Filtration System train can pressurize the control room to ! 0.125 inches water gauge, relative to areas adjacent to the control room envelope.
The control room and the control room envelope are defined in UFSAR Section 6.4 (Ref. 1).
The control room is contained within the control room envelope.
The areas within the control room envelope, external to the control room, are maintained at a positive pressure.
Redundant filter trains are provided such that if an excessive pressure drop develops across one filter train, the other train is available to provide the required filtration.
BYRON - UNITS 1 & 2 B 3.7.10 - 2 Revision xx
BASES LCO Two independent and redundant VC Filtration System trains are required to be OPERABLE to ensure that at least one is available assuming a single failure disables the other train.
Total system failure could result in exceeding a TEDE dose of 5 rem to the control room operator in the event of a large radioactive release.
a.
Makeup air fan is OPERABLE ;
b.
Supply fan is OPERABLE ;
C.
Return air fan is OPERABLE ;
VC Filtration System B 3.7.10 The VC Filtration System is considered OPERABLE when the individual components necessary to limit operator exposure are OPERABLE in both trains.
A VC Filtration System train is OPERABLE when the associated :
d.
HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions ; and e.
Makeup filter unit heater, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.
In addition, the control room boundary must be maintained, including the integrity of the walls, floors, ceilings, ductwork, and access doors.
APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and at all times during movement of irradiated fuel assemblies in the fuel handling building or containment, the VC Filtration System must be OPERABLE to control operator exposure during and following a DBA, including the release from a fuel handling accident.
In MODE 5 or 6, the VC Filtration System provides protection from significant radioactive releases.
BYRON - UNITS 1 & 2 B 3.7.10 - 4 Revision xx
BASES SURVEILLANCE REQUIREMENTS (continued)
REFERENCES 1.
2.
3.
4.
5.
6.
7.
SR 3.7.10.4 VC Filtration System B 3.7.10 This SR verifies the integrity of the control room enclosure, and the assumed inleakage rates of the potentially contaminated air.
The control room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify proper functioning of the VC Filtration System.
During the emergency mode of operation, the VC Filtration System is designed to pressurize the upper cable spreading room to ? 0.02 inches water gauge and the control room to ~! 0.125 inches water gauge, relative to areas adjacent to the control room area in order to minimize unfiltered inleakage.
The VC Filtration System is designed to maintain this positive pressure with one train at a makeup flow rate ? 5400 cfm and
- ~- 6600 cfm.
The Frequency of 18 months on a STAGGERED TEST BASIS is consistent with the guidance provided in NUREG-0800 (Ref. 6).
UFSAR, Section 6.4.
UFSAR, Section 9.4.
UFSAR, Chapter 15.
UFSAR, Section 2.2.
Regulatory Guide 1.52, Rev. 2.
NUREG-0800, Section 6.4, Rev. 2, July 1981 10 CFR 50.67 BYRON - UNITS 1 & 2 B 3.7.10 - 8 Revision xx