ML082340796

Supplemental Response for License Amendment Request for Alternative Source Term

ML082340796
Person / Time
Site:	Peach Bottom
Issue date:	08/21/2008
From:	Cowan P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML082340796 (9)

Text

Exelon Nuclear www.exeloncorp.com 200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.90 August 21, 2008 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 50-277 and 50-278

Subject:

Supplemental Response for License Amendment Request for Alternative Source Term

References:

1. Letter from Pamela B. Cowan, Exelon Generation Company, LLC,to U. S. Nuclear Regulatory Commission, "License Amendment Request - Application of Alternative Source Term," dated July 13, 2007

2. U. S. Nuclear Regulatory Commission e-mail dated July 18, 2008, draft Request for Additional Information (RAI), Peach Bottom Atomic Power Station, Units 2 and 3, License Amendment Request (LAR), Alternative Source Term Application (five questions)

3. U. S. Nuclear Regulatory Commission updated e-mail dated July 25,2008, draft Request for Additional Information (RAI), Peach Bottom Atomic Power Station, Units 2 and 3, License Amendment Request (LAR), Alternative Source Term Application (one question)

4. Letter from Pamela B. Cowan, Exelon Generation Company, LLC, to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Concerning License Amendment Request - Application of Alternative Source Term,'* dated July 29, 2008

5. Letter from Pamela B. Cowan, Exelon Generation Company, LLC, to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Concerning License Amendment Request - Application of Alternative Source Term," dated August 7,2008

6. Teleconference between U. S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, dated August 12, 2008, draft Request for Additional Information (RAI),

Peach Bottom Atomic Power Station, Units 2 and 3, License Amendment Request (LAR), Alternative Source Term Application (two issues)

U.S. Nuclear Regulatory Commission License Amendment Request Alternative Source Term Docket Nos. DPR-44 and DPR-56 August 21, 2008 Page 2 In Reference 1, Exelon Generation Company, LLC (Exelon) submitted an application requesting a change to the Technical Specifications (TS), Appendix A, of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively. The proposed change was requested to support the application of Alternative Source Term (AST) methodology at PBAPS, Units 2 and 3.

In References 2 and 3, the U. S. Nuclear Regulatory Commission (NRC) issued draft requests for additional information (RAls) concerning the PBAPS License Amendment Request (LAR).

The NRC identified six questions in the draft RAls in which additional information was requested concerning meteorological and dose consequence aspects related to AST. In References 4 and 5, Exelon responded to the six RAI questions.

In the Reference 6 teleconference, the NRC requested further clarification with regard to: 1) the atmospheric dispersion factors (X/Qs) for the fuel handling accident (FHA) listed in Table 6 of the Reference 5 response, and 2) the basis for establishing an 84-hour decay period in the definition for RECENTLY IRRADIATED FUEL. To address these issues, Exelon has revised Table 6 to show the specific X/Q values used in the FHA analysis. The X/Q values depicted in Table 6 represent the most bounding condition for each of the release points identified. In addition, the definition of RECENTLY IRRADIATED FUEL has been revised to remove the reference to the 84-hour decay period. Therefore, Exelon is hereby replacing the proposed definition for RECENTLY IRRADIATED FUEL as described in Reference 1 with the following proposed definition.

Previous Proposed Definition (Reference 1)

RECENTLY IRRADIATED RECENTLY IRRADIATED FUEL is fuel that has FUEL occupied part of a critical reactor core within the previous 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. This 84-hour time period may be reduced to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if all outside secondary containment ground-level hatches (hatches H15 through H24 and Units 2 and 3 Torus room access hatches) are closed.

New Proposed Definition for Unit 2 and Unit 3 Unit 2 RECENTLY IRRADIATED FUEL is 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 />. When using this definition to suspend the Applicability of LCOs, secondary containment ground-level hatches H15, H16, H17, H18, H19, and H33 shall be closed during the movement of any irradiated fuel in Secondary Containment.

U.S. Nuclear Regulatory Commission License Amendment Request Alternative Source Term Docket Nos. DPR-44 and DPR-56 August 21,2008 Page 3 RECENTLY IRRADIATED FUEL is 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 />. When using this definition to suspend the Applicability of LCOs, secondary containment ground-level hatches H20, H21, H22, H23, H24, and H34 shall be closed during the movement of any irradiated fuel in Secondary Containment.

Attachment 1 of this letter contains. the Table 6 pages, which supercede the Table 6 contained in the Reference 5 response. Attachment 2 provides the revised Technical Specifications pages 1.1-5 for PBAPS, Units 2 and 3, which include the new proposed definition for RECENTLY IRRADIATED FUEL.

Exelon has concluded that the information provided in this response does not impact the conclusions of the: 1) Technical Analysis, 2) No Significant Hazards Consideration under the standards set forth in 10 CFR 50.92(c), or 3) Environmental Consideration as provided in the original submittal (Reference 1).

There are no regulatory commitments contained in this letter. If you have any further questions or require additional information, please contact Richard Gropp at 610-765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 21 st day of August 2008.

Respectfully, Pamela B. Cowan Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC : Supplemental Response to Request for Additional Information (Revised Table 6 from the Reference 5 Supplement) : Revised Technical Specifications Page Mark-ups (Pages 1.1-5 for Units 2 and 3) cc: Regional Administrator - NRC Region I wI Attachments NRC Senior Resident Inspector - PBAPS "

NRC Project Manager, NRR - PBAPS "

Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection "

S. T. Gray, State of Maryland "

ATTACHMENT 1 Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 License Amendment Request Supplemental Response Alternative Source Term (AST)

Table 6 (revised) from August 7, 2008 Supplemental Response

Attachment 1 Page 1 of 2 Table 6 3

XlQ (seclm ) Results Summary (from PM-lOSS Rev. 1 Table S-l and PM-10S9 Rev. 3 Table 4-1),

Meteorological Database Utilized, and Dose Calculation Application Bases Controlling Receptor I Release Point I 0-0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> I 0-2 hour I 2-8 hour 18-24 houri 1-4 day I 4-30 day I Meteorological Tower Database Justification for Usage I Used in Dose Calculation Utilized Tower 2 is the only representative database Off-Gas Stack 3.31E-06 I 1.00E-15 11.00E-1511.64E-Oal 4.54E-09 I Tower 2 I (See Calculation I PM-I077, Rev. 1 PM-lOSS, Rev 1, Sections 2.2.3 and 2.2.4)

The higher of the XlQs predicted by Tower 2 (0-2 hour) representative Towers PM-I077, Rev.l, Unit 2 Reactor Building Stack 2 and 1A databases PM-lOS?, Rev. 2, Control Room Intake I 1.18E-0319.08E-0414.14E-0412.90E-0412.26&041 Tower IA (all other penods) were sel~ted (See Calculatlon PM-1055, Rev 1, Sections l PM-1059 Rev 3 2.2.3 and 2.2.4)

The higher of the Unit 3 Reactor Building Stack 1.1SE-03 !S.91E-04!4.00E-04!2.51E-04\1.9SE-04 1 Tower 2 XlQs predicted by represeotative Towers 12 and 1A databases I PM-1077, Rev. I, PM-lOS?, Rev. 2, (Unit 2 is limiting) were sel~ted (See PM-1059 Rev 3 CalculatlOn PM- '

1055, Rev 1, Sections 2.2.3 and 2.2.4)

Ground-Level Hatches 1.2SE-02 Tower lA is the most representative and Reactor Building Personnel conservative database 1.04E-03 These are the maximum values for each.

Access Doors (See Calculation PM-I PM-1059, Rev 3 0-2 hour values conservatively utilized for the Tower 1A 1059, Rev 3, Roof Scuttles 1.90E-03 Fuel Handling Accident Attachment G, Section 3.1 and Table Railway Bay Doors 4.54E-04 I 1 14 -1)

Page 2 of 2 Table 6 (continued)

Controlling I 0-0.5 I

8-24 Meteorological Justification for I Used in Dose Receptor Release Point I 28 hour3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> I 0-2 hour 1 - hour hour Tower Database Usage Calculation Utilized Tower 2 is the only representative OfT-Gas Stack I 5.30E-05 I 9.17E-06 I 3.24E-06* I 1.92E-06 I 6.22E-07 I I.23E-07 I Tower 2 ,database. , PM-lOn, Rev. 1 (See CalculatIon PM-1055, Rev 1, Sections 3.2.3,3.2.4, and 4.1)

EAB I Units 2 and 3 Reactor Building The highest of the XJQs predicted by the (823 m)

Stacks, Turbine Building, and Personnel Access Doors, Railway Bay Doors, and Roof

9. llE-04 4.67E-04* 3.35E-04 l.64E-04 6.26E-05 Tower IA representative Towers 2, IA, and River Tower/lA databases I PM-1077, Rev. I, PM-1057, Rev. 2, were selected (See PM-1059, Rev 3 Scuttle, and Ground-Level Calculation PM-Hatches. 1055, Rev 1, Sections 3.2.4 and 4.1)

Tower 2 is the only Irepresentative OfT-Gas Stack I 1.75E-05 I 9.05E-06 14.0IE-06* 12.67E-0611.1OE-061 3.lOE-07 I Tower 2 ~tab~s~

ee a culatIon

' PM' - PM-IOn, Rev. 1 1055, Rev 1, Sections 3.2.3,3.2.4, and 4.1)

LPZ The higher of the (7,300 m) Units 2 and 3 Reactor Building XJQs predicted by the Stacks, Turbine Building, and Personnel Access Doors, representative Towers 2 and IA databases I PM-Ion, Rev. I, PM-105?, Rev. 2, I.38E-04 5.8IE-05* 3.77E-05 IA8E-05 4.15E-06 Tower lA Railway Bay Doors, and Roof were sel~cted (See PM-1059, Rev 3 Scuttle, and Ground-Level CalculatIon PM-Hatches. 1055, Rev 1, Sections 3.2.4 and 4.1)

ATTACHMENT 2 Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 License Amendment Request Supplemental Response Alternative Source Term (AST)

Revised Technical Specifications Page Mark-ups Unit 2 Unit 3 1.1-5 1.1-5

Definitions 1.1 1.1 Definitions PHYSICS TESTS b. Authorized under the provisions of (continued) 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Regulatory Commission.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 3514 MWt.

REACTOR PROTECTION SYSTEM The RPS RESPONSE TIME shall be that time interval RPS) RESPONSE TIME from the opening of the sensor contact up to and including the opening of the trip actuator contacts.

RECENTLY IRRADIATED RECENTLY IRRADIATED FUEL is fuel that has occupied FUEL 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 />. When using this definition to suspend the Applicability of LCOs, secondary containment ground-level hatches H15, H16, H17, H18, H19, and H33 shall be closed during the movement of any irradiated fuel in Secondary Containment.

SHUTDOWN MARGIN (SDM) SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical assuming that:

a. The reactor is xenon free;

b. The moderator temperature is 68°F; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.

With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

(continued)

PBAPS UNIT 2 1.1-5 Amendment No. -rl4+XXX

Definitions 1.1 1.1 Definitions PHYSICS TESTS b. Authorized under the provisions of (continued) 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Regulatory Cormnission.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 3514 MWt.

REACTOR PROTECTION SYSTEM The RPS RESPONSE TIME shall be that time interval RPS) RESPONSE TIME from the opening of the sensor contact up to and including the opening of the trip actuator contacts.

RECENTLY IRRADIATED RECENTLY IRRADIATED FUEL is fuel that has occupied FUEL 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 />. When using this definition to suspend the Applicability of LCOs, secondary containment ground-level hatches H20, H21, H22, H23, H24, and H34 shall be closed during the movement of any irradiated fuel in Secondary Containment.

SHUTDOWN MARGIN (SDM) SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical assuming that:

a. The reactor is xenon free;

b. The moderator temperature is 68°F; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.

With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

(continued)

PBAPS UNIT 3 1.1-5 Amendment No. ~XXX