ML070920067

Additional Information - License Amendment Request No. 315, Application of Alternative Source Term

ML070920067
Person / Time
Site:	Oyster Creek
Issue date:	03/23/2007
From:	Cowan P AmerGen Energy Co
To:	Document Control Desk, NRC/NRR/ADRO
References
2130-07-20478, TAC MC6519
Download: ML070920067 (9)

Text

AmerGen Energy Company, LLC www.exeloncorp.com Amer(5eý An Exelon Company 2oo Exelon Way Kennett Square, PA 19348 10 CFR 50.90 10 CFR 50.67 March 23, 2007 2130-07-20478 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219

Subject:

Additional Information - License Amendment Request No. 315, "Application of Alternative Source Term" (TAC No. MC6519)

References:

(1) AmerGen letter to USNRC, "License Amendment Request No. 315-Application of Alternative Source Term," dated March 28, 2005.

(2) AmerGen letter to USNRC, "Additional Information - License Amendment Request No. 315, "Application of Alternative Source Term" (TAC No.

MC6519)," dated March 16, 2007.

(3) GPU Nuclear letter to USNRC, "Control Room Habitability (NUREG-0737 Item III.D.3.4) Results of Whole Body and Beta Skin Dose Analysis," dated June 17, 1985.

(4) USNRC letter to AmerGen, "Clarification of Response to Request for Additional Information Regarding License Amendment Request for Application of the Alternate Source Term Methodology (TAC No. MC6519),"

dated March 21, 2007.

This letter provides the additional information discussed in a conference call held on March 15, 2007, and clarified in accordance with Reference 4, regarding Oyster Creek License Amendment Request No. 315, submitted in Reference 1.

As discussed on March 15, 2007, the radiological dose analysis supporting the Oyster Creek application for alternative source term has been revised to: (1) eliminate the previously assumed credit for secondary containment mixing, (2) replace the previous assumption of Main Steam Isolation Valve (MSIV) leak rate based on containment pressure with an assumption of constant MSIV leak rate at the Technical Specification (TS) value of 11.9 scfh for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a 50% reduction after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, (3) credit delayed release for MSIV leakage travel time from the outboard MSIV to the turbine/condensers of 8.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> for the line with single isolation and 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> for the line with double isolation, (4) assume control room maximum exposed operator occupancy based on 100% occupancy for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 25% occupancy thereafter representing a four crew, eight hour shift rotation, and (5) utilize updated offsite atmospheric dispersion values (X/Qs), previously submitted to the NRC in Reference 2. Items (3) and (4) above, regarding the revised assumptions for delayed release for MSIV travel time and control A /

U.S. Nuclear Regulatory Commission March 23, 2007 Page 2 room occupancy, are consistent with the assumptions described in the Oyster Creek control room habitability radiological analysis previously submitted to the NRC in Reference 3. provides the revised Oyster Creek licensing basis offsite and control room operator radiological dose consequences utilizing alternative source terms. All calculated radiological dose consequence results remain below the acceptance criteria of 10 CFR 50.67 and General Design Criterion (GDC) 19. contains proprietary information as defined in 10 CFR 2.390(a)(4). Accordingly, it is requested that Enclosure 1 be withheld from public disclosure. An affidavit certifying the basis for this application for withholding as required by 10 CFR 2.390(b)(1) is also enclosed with this letter (Enclosure 3). Enclosure 2 provides a non-proprietary version of Enclosure 1.

The revised calculated maximum offsite and control room operator dose values identified in replace the corresponding values originally proposed in the Oyster Creek TS Bases page 4.5-10 markup previously submitted in Reference 1. A revised TS Bases page 4.5-10 is provided in Enclosure 4 and supersedes the corresponding page submitted in Reference 1.

No new regulatory commitments are established by this submittal. If any additional information is needed, please contact David J. Distel at (610) 765-5517.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2 3 rd day of March, 2007.

Respectfully, Pamela B. Cowan Director - Licensing & Regulatory Affairs AmerGen Energy Company, LLC

Enclosure:

1) Calculation No. PSAT 05201 H.08, Revision 3, "Dose Assessment for Oyster Creek Control Room Habitability" (Proprietary Version)

2) Calculation No. PSAT 05201 H.08, Revision 3, "Dose Assessment for Oyster Creek Control Room Habitability" (Non-Proprietary Version)

3) Polestar Applied Technology, Inc. Affidavit Certifying Request For Withholding From Public Disclosure

4) Revised Technical Specification Bases Page Markup (Page 4.5-10) cc: S. J. Collins, USNRC Administrator, Region I G. E. Miller, USNRC Project Manager, Oyster Creek M. S. Ferdas, USNRC Senior Resident Inspector, Oyster Creek File No. 03079

ENCLOSURE 3 POLESTAR APPLIED TECHNOLOGY, INC.

AFFIDAVIT CERTIFYING REQUEST FOR WITHHOLDING FROM PUBLIC DISCLOSURE

Polestar Applied Technology, Inc.

AFFIDAVIT I, David E.W. Leaver, being duly sworn, depose and state as follows:

(1) I am a Principal and an Officer of Polestar Applied Technology, Inc. ("Polestar")

and am responsible for the function of reviewing the information described in paragraphs (2) and (8) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in portions of Polestar report PSAT 05201H.08, Rev. 3 (see paragraph (8)). This report is being prepared for Exelon Nuclear in support of an Exelon submittal to NRC on alternate source term (AST). The Polestar report addresses the DBA-LOCA dose calculation at the Oyster Creek Generating Station.

(3) In making this application for withholding of proprietary information of which it is the owner, Polestar relies upon the exemption from disclosure set forth in the NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and 2.790(d)(1) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 2.790(a)(4)). The material for which exemption from disclosure is here sought is all "confidential commercial information".

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process or method, including supporting data and analyses, where prevention of its use by Polestar's competitors without license from Polestar constitutes a competitive economic advantage over other companies.

b. Information which, if used by a competitor, would significantly reduce his expenditure of resources or improve his competitive position in the analysis, design, assurance of quality, or licensing of a similar product;

c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of Polestar, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future Polestar customer-funded development plans and programs, of potential commercial value to Polestar; 1

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in both paragraphs (4)a and (4)b, above.

(5) The information sought to be withheld is being submitted to Exelon Nuclear (and, we trust, to NRC) in confidence. The information is of a sort customarily held in confidence by Polestar, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Polestar, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.

Distribution of such documents within Polestar is limited to those with a need to know.

(7) The approval of external release of such a document typically requires review by the project manager, and the Polestar Principal closest to the work, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside. Polestar are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed information on and results from trade secret methodologies developed by Polestar and applied under the Polestar 10 CFR 50, Appendix B Quality Assurance Program. The trade secret information is identified in ((double bold brackets)) in the calculations. Specifically:

" PSAT 05201H.08, Appendix A, pages 1 Polestar has developed unique insights on determination of iodine re-evolution from pools with varying pH

• PSAT 05201H.08, Appendix B, pages 1 Polestar has developed unique insights on dose conversion factors for certain isotopes as a function of the chemical form of the isotopes 2

The trade secrets used in this Oyster Creek Generating Station work are several of a number of Polestar developed methods, models, and codes. Development of these methods, models, and codes was achieved at a significant cost to Polestar over the 14 years of Polestar's existence, well over $400,000, which is a significant fraction of internal research and development resources available to a company the size of Polestar.

The development of the methods, models and codes, along with the interpretation and application of the results, is derived from the extensive experience database that constitutes a major Polestar asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Polestar's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Polestar's comprehensive technology base on application of the AST to operating plants and advanced light water reactors, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with methods which have been developed and are being maintained in accordance with 10 CFR 50, Appendix B requirements.

The research, development, engineering, analytical and review costs comprise a substantial investment of time and money by Polestar.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

Polestar's competitive advantage will be lost if its competitors are able to use the results of the Polestar experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to Polestar would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Polestar of the opportunity to exercise its competitive advantage to seek an adequate return on its relatively large investment in developing these very valuable analytical tools.

3

STATE OF CALIFORNIA )

) ss:

COUNTY OF SANTA CLARA )

David E.W. Leaver, is being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

Executed at Los Altos, California, this 23 "tday of M" 2007.

David E.W. Leaver Polestar Applied Technology, Inc.

Subscribed and sworn before me this 4" day of 2007.

Cormis~sion # 1439944 Notary Public - California Santa Clara County _ _._ _

Xomm.

ExPires Oct 8, 2007 Notary Public, State of California 4

ENCLOSURE 4 OYSTER CREEK Revised Technical Specification Bases Page Markup Technical Specification Bases Page 4.5-10

4. 5 CONTAINMIENT S'rSTEMI In the ec,ent oK' oss-of-coolant accident. the peak dr-, .\ell pressure would be 18 psig which

,,ould rapiJd[ reducea to 20 psi,-, within 100 seconds tbllo,.%ing the pipe break. The total time the drvwell pressure would be above 35 psig is calculated to be about 7 seconds. Following the pipe break, absorption chamber pressure rise3.to 20 psig within 8 seconds. equalizes \xith dr*well pressure at 25-psig within 60 seconds and thereafter rapidly decays with the dry-well pressure decav.y)

The design pressures of the drvw.vell and absorption chamber are 62 psig and 35 psig.

resoecti,, v.-' The original calculated 38 psig peak dr.,ell pressure was subsequently reconfirmed. .- ' margin.was applied to revise the drywell design pressure to 44 psig. The A51 design leak rate is 0.5_,,%/day at a pressure of 35 psig. As pointed out above, the pressure response of the dr'well and absorption chamber following an accident would be the same after about 60 seconds. Based on the calculated primary containment pressure response discussed above and the absorption chamber design pressure. primary containment pre-operational test pressures were chosen. Also. based on the primary containment pressure response and the fact that the drywell and absorption chamber function as a unit. the primary containment will be tested as a unit. rather than testing the individual comronents separate!.. Ael'oIja,) Ccu;ee_

The desicn basis loss-of-coolant acci ent was evaluate at ! irar' contian. .ent maximar,,n allowable accident leak rate of 1.0%/dav at 35 psiy. The analyis ,wed that izh this leak rate and a standby gas treatment system filter efficiency of 90 percent for for particulates. and assuming the, fission product release fractions stated in maximum .... l, .. o.l: boa.: p 'i c!oud doeis abu *rem,*and the.... mu to.....l th*-...:-

dese-i- abeu-: 1;9 rein at the site boundary considering fumigation conditions over an exposure duration of ti.%o hours. The resultant doses that would occur for the duration of the acciden: a.

,:,-o-::on dismance of 2 miles are Io,- er than t.ose stated deA r,.aaoi.- tc the o0

..eteor*ica! conditions that would.be excected to occu.-r o\ era 3-da. period. Tfus. t:.e doses re~orted are :he maximum that would be expected in the unl;ikely even: of a design basis loss-or-coolant accident. These doses are also based on the assumption of no hoidup in the second,"-.

containnent resulting in a direct release of fission product from the primary. containment through the filters and stack ta the environs. Therefore, the specified primary containment Leak rate and filter efficiency are conser,'ative and provide margin between expected offsite doses and 10 CFR 0-o, +4.ý?.gu!deline limits. 7Xe m c~x:,ia,,*,,, ,e.. -h c,,fr/-,-* ,,3,,D,, ,o, ,/, det".. o,,. ct-,'d,4t

'* - p ,4'-,*,; .r .% 63' TE-D "

7.7,.

Althouzh the dose ca.cu-2:ions suoqest tnat the allo,.kable :es: lea!, rate cu; be a'lowex

. ........t......... d: before the .uidehtn.- ,.. _eo-s.

hlimt .. P) CFR. wv,. be exceeded es~ablishing the limit of 1.0%,day provides an adequate margin of safetv to assure the health and saft.,y ofCEe general public. It is further considered that the allowable leak rate should not devl.te sinificantl, from the containment desigr ,.alue to take advantage of the design leak-t.a-aoiljtv of the structure over Iits service ught_-Ssca-.

I I Of le 1 -ta

. Additional! macý:in to maintain c*he I lt,,elimt.

containment in the "as-built" condition is achieved bv establishin- the ob,, , ocerationa! I-a,,k

-IatC.-T>. o~e",tiona'liri: is derived bv' multipiying the " ti . :.ca:k rae e

.. th....e_..5 providin. a 25% margin to allow for leaka.e2 deterioration which ma. occur durin: the perod between Ieak rate tests.

OYSTER CREEK 4.5-10 Amendment No.: 165. 186, 219,