ML081990112

Stretch Power Uprate License Amendment Request - Supplement to DNC Comments on Draft Safety Evaluation - Stretch Power Uprate

ML081990112
Person / Time
Site:	Millstone
Issue date:	07/16/2008
From:	Gerald Bichof Dominion, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
08-0429
Download: ML081990112 (8)

Text

Dominion Nuclear Connecticut, Inc.

"uOO Dominion Boulevard, Glen Allen, Virginia 2 l060

\X'ch Address: www.dom.com July 16, 2008 U. S. Nuclear Regulatory Commission Serial No.: 08-0429 Attention: Document Control Desk NLOS/GAW: RO One White Flint North Docket No.: 50-423 11555 Rockville Pike License No.: NPF-49 Rockville, MD 20852-2738 DOMINION NUCLEAR CONNECTICUT. INC.

MILLSTONE POWER STATION UNIT 3 STRETCH POWER UPRATE LICENSE AMENDMENT REQUEST SUPPLEMENT TO DNC COMMENTS ON DRAFT SAFETY EVALUATION -

STRETCH POWER UPRATE Dominion Nuclear Connecticut, Inc. (DNC) submitted a stretch power uprate license amendment request (LAR) for Millstone Power Station Unit 3 (MPS3) in letters dated July 13, 2007 (Serial Nos. 07-0450 and 07-0450A). On June 12, 2008, the NRC issued a draft safety evaluation (SE) report and requested that DNC provide comments regarding the proprietary content in the draft SE. The NRC's letter also permitted comments regarding the factual accuracy of the information in the SE. Subsequently, in a July 11, 2008 letter, the NRC indicated that the SE will not be issued until DNC provided a letter regarding the proprietary content of the NRC draft SE.

DNC's letter dated July 10, 2008 (Serial No. 08-0369) provided DNC's comments regarding factual accuracy of the draft SE. Although the draft SE was reviewed regarding the proprietary content, DNC's letter did not specifically address the proprietary content of the draft SE in the July 10, 2008 letter. This letter corrects that omission. DNC has not identified any proprietary information contained in the NRC draft SE.

Furthermore, four inaccuracies were identified in the attachment to the July 10, 2008 letter, on pages 25, 41, 42, and 43. Corrected pages are attached to this letter. Please replace pages 25, 41, 42, and 43 in their entirety in the July 10, 2008 attachment. We regret any confusion this may have caused.

Serial No. 08-0429 Docket No. 50-423 Supplement to Comments on Draft Safety Evaluation Page 2 of 3 Should you have any questions in regard to this submittal, please contact Mr.

Geoffrey Wertz at 804-273-3572.

Sincerely,

fdd75-~

Gerald T. Bischof Vice President - Nude Engineering COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this If., "IJ, day of Cf~ ,2008.

My Commission Expires: ~t. 3 ft AtlB

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NOtary Public Commitments made in this letter: None Attachment ~SARE'I. lENNI" Notary Public J$t.J 30~

Commonwealth of Vlrglnta My CommlUlon bplr.. Aug 31. 2001 ~

Serial No. 08-0429 Docket No. 50-423 Supplement to Comments on Draft Safety Evaluation Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I Regional Administrator 475 Allendale Road King of Prussia, PA 19406-1415 Mr. J. G. Lamb Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 0-8B1A Rockville, MD 20852-2738 Ms. C. J. Sanders Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 0-8B3 Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No. 08-0429 Docket No. 50-423 ATTACHMENT LICENSE AMENDMENT REQUEST STRETCH POWER UPRATE LICENSE AMENDMENT REQUEST CORRECTED DNC COMMENTS ON DRAFT SAFETY EVALUATION REPORT MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC.

Serial No. 08-0429 Docket No. 50-423 Page 25 of 49 Page Location Sentence Comment 135 4tn paragraph in "However, the sequence of events Although the low steam line pressure setpoint is Technical Evaluation, (LR Table 2.8.5.1.2.2.1-1) lists low reached first, and it generates an 81 signal second sentence steam line pressure as the first (which initiates feedwater isolation), the analysis safety injection signaL" does not credit the initiation of SI flow until after the SI signal from low pressurizer pressure is generated at 25.8 seconds. This timing is reflected in the followinQ comment.

135 5In paragraph in "Although the safety injection system Per LR Table 2.8.5.1.2.2.1-1, the 81 flow starts Technical Evaluation, is actuated early in the transient (0.5 at 72.8 seconds.

first sentence seconds) the minimum ... "

Serial No. 08-0429 Docket No. 50-423 Page 41 of 49 On Page 219, Table 5, (page2 of 2):

Please replace the following Section:

CR ventilation timing for the LOCA, SGTR, MSLB, LRA and the REA:

T= 0 seconds Normal CR unfiltered intake flow: 1595 cfm T= 5 seconds CBI signal generated T= 10 seconds CR isolates on radiation monitor signal Intake flow: 0 cfm; neutral condition Assumed unfiltered inleakage: 350 cfm T= 1 minute, 5 seconds delay for CREPS response (Not credited)

Assumed unfiltered inleakage: 350 cfm T=1 hour, 41 min, 5 sec CREVS filtered intake flow: 230 cfm (1.685 hours0.00793 days <br />0.19 hours <br />0.00113 weeks <br />2.606425e-4 months <br />) Assumed unfiltered inleakage: 100 cfm CREVS filtered recirculation flow: 666 cfm With:

CR ventilation timing:

T=O seconds CR isolated on SI signal Intake flow: 0 cfm; neutral condition Assumed unfiltered inleakage: 350 cfm T=1 minute Delay for CREPS response (Not credited)

Assumed unfiltered inleakage: 350 cfm T=1 hour, 41 min CREVS filtered intake flow: 230 cfm (1.683 hours0.00791 days <br />0.19 hours <br />0.00113 weeks <br />2.598815e-4 months <br />) Assumed unfiltered inleakage: 100 cfm CREVS filtered recirculation flow: 666 cfm

Serial No. 08-0429 Docket No. 50-423 Page 42 of 49 The basis for the proposed change is contained in RAI Response to question AADB-07-0107, DNC letter dated January 18,2008 (Serial No. 07-0846), Attachment 3, Page 5 of 106; Also stated correctly on page 212, firstfull paragraph of the draft SER.

On Page 221, Table 7 (Page 1 of 2)

Please replace the following Section:

Table 7 (Page 1 of 2)

MPS3 SPU Data and Assumptions for the SGTR Accident Primary-to-secondary leak rate TS limit 1 gpm (to unaffected SGs)

LOOP Coincident with release ReS TS iodine limit for normal operation Gross gamma 100/ E-Bar Iodine 1.0 J,JCi/gm DEI With:

Table 7 (Page 1 of 2)

MPS3 SPU Data and Assumptions for the SGTR Accident Primary-to-secondary leak rate TS limit 150 gpd to any 1 SG LOOP Coincident with release RCS TS iodine limit for normal operation 1.0 J,JCi/gm DEI RCS Gross Gamma activity Equivalent to fuel failure associated with DEI limit Basis:

The SGTR does not use the 100/E-bar LCO. Instead, as indicated in RAI Response to question AADB-07-0107, DNC

Serial No. 08-0429 Docket No. 50-423 Page 43 of 49 letter dated January 18, 2008 (Serial No. 07-0846), Attachment 2, Page 54 of 95, the gross gamma activity was based upon the more operationally limiting Dose Equivalent 1-131 LCO. The discussion from Letter Serial No. 07-0846 , Page 54 of 95 is repeated below.

"Primary side iodine and gross gamma source concentrations are based on the more limiting Technical Specification limit of 1.0 IJCi/gm Dose Equivalent (DEQ) 1-131. The failed fuel equivalent associated with the iodine Technical Specification limit is 0.29%. The Technical Specification concentrations of the non-iodine isotopes at the 1OO/E-bar limit result in greater than 1 % failed fuel. Therefore the more limiting failed fuel percentage associated with the specific activity limit for the iodines is used for all primary coolant isotopes."

On Page 223, Table 8, 4th item on the table:

Please replace the following Section:

Table 8

• MPS3 SPU Data and Assumptions for the MSLB Accident RCS volume 11,750 ft3 RCS mass 5.216E+05 Ibm Primary-to-secondary leak rate TS limit 1 gpm (to unaffected SGs)

RCS TS limit for normal operation Gross gamma 1001 E-Bar Iodine 1.0 IJCi/gm DEI With:

Table 8

• MPS3 SPU Data and Assumptions for the MSLB Accident RCS volume 11,750 ft3 RCS mass 5.216E+05Ibm Primary-to-secondary leak rate TS limit 150 gpd to any 1 SG.

RCS TS iodine limit for normal operation 1.0 IJCi/gm DEI RCS Gross Gamma activity Equivalent to fuel failure associated with DEI limit