RS-16-121, Response to Request for Additional Information Concerning License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAR

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Response to Request for Additional Information Concerning License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAR
ML16154A129
Person / Time
Site: Clinton  Constellation icon.png
Issue date: 06/02/2016
From: Simpson P
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CAC MF7336, RS-16-121
Download: ML16154A129 (16)
v • d • e


Text

{{#Wiki_filter:Exelon Generation 4300 Winfield Road Warrenville. IL 60555 www.exeloncorp com AS-16-121 10 CFR 50.90 June 2, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket Nos. 50-461 and 72-1046

Subject:

Response to Request for Additional Information Concerning License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAA

References:

1. Letter from P. R Simpson (Exelon Generation Company, LLC) to U.S. NRC, "License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation," dated January 29, 2016
2. Letter from E. Brown (U. S. NRC) to B. C. Hanson, "Clinton Power Station, Unit 1 - Request for Additional Information Related to Incorporation of Revised Alternative Source Term (CAC No MF7336)(RS-16-019)," dated May 11, 2016
3. Teleconference Between U.S. NRC (E. Brown, et al) and Exelon Generation Company, LLC (J. Schrage, et al) on May 5, 2016 In Reference 1, Exelon Generation Company, LLC (EGC) submitted a request to amend Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1.

The proposed amendment would revise an input parameter for the Loss-of-Coolant Accident (LOCA) dose calculation in the CPS Updated Safety Analysis Report (USAA) and the CPS Technical Specification (TS) Bases. The current LOCA dose calculation methodology was submitted and approved by the NRC in Amendment 167 to NPF-62, which implemented an alternative source term (AST} methodology in accordance with 10 CFR 50.67, "Accident source term." In Reference 2, the NRC provided five requests for additional information (RAls) related to the proposed license amendment. The RAls were based on draft questions that were provided to EGC in an email from E. Brown to T. Byam on April 29, 2016. The NRC provided additional clarification of the draft RAls during the Reference 3 teleconference.

June 2, 2016 U.S. Nuclear Regulatory Commission Page 2 As a preliminary response to this request, EGC is providing the information in the Attachment and Enclosure to this letter. EGC will provide the remaining requested information (i.e., EGC response to RAI 3.b and 3.c) on or before June 10, 2016, as specified in Reference 2. There are no regulatory commitments contained within this letter. If you have any questions concerning this letter, please contact Mr. John L. Schrage at (630) 657-2821. Respectfully, P~R Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information Related to License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAA cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - Clinton Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT Clinton Power Station, Unit 1 Response to Request for Additional Information Related to License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAR RA/ 1. Page 1of6 Section 3.2 of the attachment to the January 29, 2016 submittal states: "In addition, actual SGTS [standby gas treatment system] train performance history during TS [technical specification] 3.6.4.1.4 Secondary Containment drawdown surveillances indicates that the required negative pressure equivalent to ~ inch of water is achieved in approximately one half of the procedural acceptance criteria of 78 seconds. This acceptance criteria is based on the required drawdown time, without the post-LOCA [loss of coolant accident] heat loads. Although this surveillance is conducted with normal operating conditions (i.e., as opposed to LOCA conditions), the margin from the acceptance criteria of 78 seconds to the analytical drawdown time provides additional assurance that SGTS will achieve the required negative pressure within 19 minutes following a LOCA, assuming a fully loaded design basis cask in the FB [Fuel Building]. RA/ 1.a. Describe the relative contributions to the increased analytical drawdown time from the additional heat load in the railroad bay and the portion attributable to the addition of the railroad bay volume. Describe how the procedure acceptance criterion of 78 seconds was derived. Discuss the relationship between the analytical drawdown time and the procedure acceptance criterion/criteria. Address whether the assumed post-LOCA heat loads account for all the difference between the AST assumed drawdown times and the surveillance procedure acceptance criteria of 78 seconds. EGC Response to RAI 1.a As a conservative assumption, the revised CPS AST analyses for the increased drawdown time included the CPS Fuel Building (FB) Railroad (RR) Bay Airlock volume. However, the actual secondary containment physical design will not change. That is, the design basis configuration of secondary containment will not include the FB RR Airlock Bay volume. Given the small volume of the FB RR Bay Airlock, relative to the entire FB volume, the additional analytical post-LOCA drawdown time that is attributable to the added volume is a small fraction of the additional seven minutes. Although EGC has not specifically determined this contribution, actual drawdown time testing with the RR Bay Airlock, as described in the response to RAI 1.c, demonstrates that the additional volume of the RR Bay Airlock adds nine seconds to the actual drawdown time. The conditions under which drawdown testing is performed are different than those assumed for LOCA conditions. For this reason, and because test results are also influenced by certain plant and/or atmospheric conditions, it is necessary to adjust the test acceptance criteria to account for such test conditions. The current acceptance criterion for the drawdown test, which was implemented in 2011, is thus based on an analytical model, verified by actual performance of drawdown tests, in which the drawdown time determined for accident conditions is adjusted to account for performance of the test during normal plant conditions.

ATTACHMENT Clinton Power Station, Unit 1 Response to Request for Additional Information Related to License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAA Page 2 of 6 The additional post-LOCA drawdown time of 7 minutes, as the endpoint of the revised secondary containment drawdown curve, is a conservative bounding value. Based on both the revised drawdown curve and the analytical model described above, EGC has verified that the current surveillance acceptance criterion of 78 seconds will continue to demonstrate the ability of SGTS to achieve the required negative pressure within the revised post-LOCA drawdown time. RA/ 1.b. Address whether the acceptance criteria of 78 seconds will continue to be used for both the test not including the railroad bay volume, and the test including the railroad bay volume. EGC Response to RAI 1.b EGC will continue to utilize the current procedure and acceptance criteria to demonstrate compliance with TS Surveillance Requirement 3.6.4.1.4 for secondary containment. As stated in the EGC response to RAI 1.a, the design basis configuration of secondary containment will not include the FB RR Airlock Bay volume. RA/ 1.c. As stated above, the actual drawdown time is identified as about one half the 78 seconds. Address whether a drawdown time test has been performed for the railroad bay volume included configuration. If so, address the amount of additional drawdown time observed as a result of including the railroad bay volume. If no test was performed and the railroad volume is intended to be assumed included for this analyses, address the amount the test conditions drawdown time is expected to change with the additional volume. EGC Response to RAI 1.c In December 2014, EGC conducted a drawdown test of secondary containment for both configurations (i.e., with and without the FB RR Bay Airlock volume). The inclusion of the FB RR Bay Airlock volume added approximately nine seconds to the tested drawdown time (i.e., 37 seconds with the FB RR Bay Airlock inner door open compared to 28 seconds with the inner door closed).

ATTACHMENT Clinton Power Station, Unit 1 Response to Request for Additional Information Related to License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAR Page 3 of 6 RA/ 2. In Chapter 6.2.3.3. 1 of the Updated Safety Analysis Report (USAR), the licensee stated that calculations indicate that the SBGT fan has been adequately sized to achieve a 0.25-inch water gauge negative pressure in less than 12 minutes after the LOCA event. The licensee is proposing to increase the drawdown time for secondary containment from the current licensing basis value of 12 minutes to 19 minutes. RA/ 2.a. Address whether this change in parameters and operation will impact the emergency diesel generators (EDGs) capability and capacity. EGC Response to RAI 2.a The proposed change in secondary containment post-LOCA heat load and drawdown time does not affect the assumed operation of SGTS in the loading profiles of the emergency diesel generators (EDGs). EGC has verified that the Division 1 and Division 2 EOG loading profiles assume continuous, full load operation of SGTS following a design basis LOCA event. As such, the additional heat load and resultant drawdown time will not impact EOG capability and capacity. RA/ 2.b. Address whether any other loads are being added to the EDGs. If so, describe their impact on the capability and capacity of the EDGs. Also, describe changes, if any, being made to the EOG loading sequence to support the licensee amendment request. Explain if any loading change will impact the design margin of the EOG. EGC Response to RAI 2.b The proposed change in secondary containment heat load and drawdown time does not require the addition of any new loads to the CPS EDGs, nor does it result in any change to the EOG loading sequence. RA/ 2.c. Address whether any non-safety-related systems and components are credited in the alternative source term (AST) analyses. If so, describe the independence (electrical and physical separation) of these non-safety related systems from the safety-related systems. Provide a discussion on why a fault on the non-Class 1 E electrical circuit will not propagate to the Class 1 E electrical circuit. EGC Response to RAI 2.c The CPS AST analyses do not credit any non-safety-related systems or components.

ATTACHMENT Clinton Power Station, Unit 1 Response to Request for Additional Information Related to License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAA Page 4 of 6 RA/3 Address whether there is a change of equipment qualification (EQ) profile, by responding to the following: RA/ 3.a. Provide a list and description of components being added to your Section 50.49 to Title 10 to the Code of Federal Regulations (10 CFR) program due to this revised AST Dose calculation in the LAR. Confirm that these components are qualified for the environmental conditions they are expected to be exposed to. EGC Response to RAI 3.a. The revised CPS AST analyses do not result in the addition of any new components to the CPS 1 O CFR 50.49 EQ program. RA/ 3.b. In Enclosure 5 of the LAR, the licensee stated that its evaluation identified temperature increases in various areas within 15 of 20 secondary containment environmental zones. For the 15 environmental zones affected provide, in table form, a list of all the EQ components affected and their respective qualification levels and parameters (i.e., temperature, pressure, and radiation) that shows that the EQ limits remain bounding under the revised AST conditions for normal operation, accident (LOCA), and post-accident. Include the existing EQ limits and show how EQ margins (e.g., temperature, pressure, radiation, etc.) are being maintained. EGC Response to RAI 3.b. EGC will provide a response to this RAI in a subsequent transmittal. RA/ 3.c. Provide pre-and post-AST implementation figures of the worst case accident EQ temperature and pressure profiles for all the affected EQ zones, which demonstrate that the post AST profile is bounding. EGC Response to RAI 3.c. EGC will provide a response to this RAI in a subsequent transmittal. RA/ 3.d. Provide revised environmental zone map(s) of the secondary containment that show all the affected environmental zones. EGC Response to RAI 3.d. The Enclosure to this letter provides the Environmental Zone Maps for those areas of the FB that would experience an analytical increase in the post-LOCA temperature, due to the presence of a fully loaded cask. This enclosure also includes a list of the affected Environmental Zones and the expected post-LOCA temperature increase. The Environmental Zone Maps only provide zone boundaries. There are no changes in zone boundaries.

ATTACHMENT Clinton Power Station, Unit 1 Response to Request for Additional Information Related to License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAA Page 5 of 6 RA/ 3.e. In Chapter 3. 11.9 of the USAR the licensee stated that the CPS areas containing Class 1 E equipment are divided into two zones based on the environmental conditions that are expected to occur as a result of various plant events. These zone classifications are termed harsh and mild environmental zones. Address whether there are any reclassifications of the EQ equipment due to the revised AST. EGC Response to RAI 3.e. The environmental zones that are impacted by the proposed change (i.e., as delineated and described in the Enclosure) are currently classified as harsh. The revised CPS AST analyses do not result in the reclassification of any affected environmental zone, or the components within those zones. RA/ 4. On page 4 of the Attachment of the January 29, 2016 submittal, Section 3. 1, the licensee stated that in the previous AST LAR the licensee used AST methodology for design basis accidents, in accordance with 1 O CFR 50. 67, with the exception that Technical Information Document (TIO) 14844 "Calculation of Distance Factors for Power and Test Reactor Sites," continued to be used as the radiation dose basis for equipment environmental qualification. On page 2 of the Attachment of the January 29, 2016 submittal, Section 1.0, the licensee stated that evaluations were conducted to validate that the proposed configuration complies with the applicable general design criteria contained in Appendix A to 1 O CFR 50, as well as the requirements of 10 CFR 50.49, "Environmental qualification of electric equipment important to safety for nuclear power plants, "10 CFR 50.67, and Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors." Address whether the radiation dose basis for EQ of safety related equipment, will continue to be based on TID-14844, assumptions. EGC Response to RAI 4 The proposed change in secondary containment post-LOCA heat load and drawdown time (i.e., during ISFSI operations) does not result in any change to post-LOCA radiation dose levels or duration within secondary containment. The radiation dose basis for EQ of safety related equipment will continue to be based on TID-14844, assumptions.

ATTACHMENT Clinton Power Station, Unit 1 Response to Request for Additional Information Related to License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAA Page 6 of 6 RA/ 5. In a letter dated November 6, 2015 (Agencywide Document Access and Management System No. ML15313A464), the Nuclear Regulatory Commission staff issued an integrated inspection report for CPS. The report documents that the inspectors reviewed Engineering Change (EC) 395976, "ISFSl-Extended Secondary Containment Boundary to FB Outer Railroad Bay Doors" Revision O. This engineering change established the boundary of the secondary containment to include the fuel bundle (FB) railroad bay airlock. The NRG staff issued a finding for failure to obtain a license amendment prior to making modifications to secondary containment. Address whether there secondary containment has been changed to include the FB railroad bay airlock. If so, describe the impact on the EQ components in the FB railroad bay airlock and whether there is any change in seismic qualification of the affected equipment. EGC Response to RAI 5 The proposed change in secondary containment post-LOCA heat load and drawdown time (i.e., during ISFSI operations) does not require a change to the physical configuration of the secondary containment. Therefore, the FB Railroad Bay Airlock will not be incorporated into secondary containment.

ENCLOSURE Clinton Power Station, Unit 1 Response to RAl-3.d Environmental Zone Maps Page 1of2 The following provides the affected Environmental Zone Maps, and a list of zones and associated rooms that would experience an increase in the post-LOCA temperature due to the presence of a fully loaded spent fuel cask in the Fuel Building. This list also includes the current value for expected post-LOCA temperature (i.e., without a fuel cask) and the expected Post-LOCA temperature with the addition of a loaded cask. Zone Room Description Current Post-LOCA Post-LOCA Temperature (°F) Temperature with Cask (°F) H-4 F.2.1 General Area 147 155 H-5 F.1.1 General Area 147 155 H-5 F.1.2 Stairs 147 155 H-5 F.1.3 Gamma Scanner Room 147 155 H-5 F.1.4 Pipe Valve Room 147 155 H-5 F.1.5 FPI Coolino Pump Room 147 155 H-5 F.1.6 Fuel Cask Area Pumo Room 147 155 H-5 F.1.9 Floor Drain Pump Room 147 155 H-5 F.1.11 Eauioment Drain Pump Room 147 155 H-5 F.2.2 Stairs 147 155 H-5 F.2.3 Tunnel 147 155 H-5 F.2.4 Chanae Room 147 155 H-5 F.2.5 Chanae Room 147 155 H-5 F.2.6 Fuel Cask and Washdown Area 147 155 H-5 F.2.7 Ultrasonic Cleaner & Vault Room 147 155 H-5 F.3.1 General Area 147 155 H-7 F.1.8 Floor Drain Tank Room 147 155 H-7 F.1.10 Equipment Drain Tank Room 147 155 H-7 F.1.12 Tunnel 147 155 H-7 F.2.8 Fuel Pool Heat Exchanoer Room 147 155 H-9 A.1.1 Aisle 139 155 H-9 A.1.2 Floor Drain Pump Room 139 155 H-10 A.1.3 Floor Drain Tank Room 139 155 H-11 A.1.10 LPCS Pump Room 146 148 H-17 A.2.1 Access Aisle 148 155 H-17 A.3.1 Gas Control Boundarv 148 155 H-17 A.3.5 Gas Control Boundary 148 155 H-17 A.3.8 Air Lock 148 155 H-17 A.3.9 Gas Control Boundary 148 155 H-17 A.4.1 Gas Control Boundary 148 155 H-17 A.4.5 Gas Control Boundary 148 155

Zone Room H-17 A.4.10 H-19 A.2.5 H-20 A.2.6 H-22 A.2.9 H-22 A.2.19 H-23 A.2.12 H-24 A.2.13 H-24 A.2.14 H-25 A.2.16 H-25 A.2.17 H-25 A.2.18 H-38 C.5.2 H-52 A.2.2 ENCLOSURE Clinton Power Station, Unit 1 Response to RAl-3.d Environmental Zone Maps Page 2 of 2 Description Current Post-LOCA Temperature (°F) Air Lock 148 Access Aisle 148 Pipe Tunnel 148 Air Lock 148 Air Lock 148 Below Main Steam Tunnel 148 MSIV Room A 148 MSIV Room B 148 RWCU Pump Room C 148 RWCU Pump Room B 148 RWCU Pump Room A 148 Gas Control Boundary 147 Radwaste Pipe Tunnel 141 Environmental Zone Maps (attached); Drawing Number M01-1600 Post-LOCA Temperature with Cask (°F) 155 155 155 155 155 155 155 155 155 155 155 155 155 Sheet 6, Auxiliary, Fuel & Containment Basement Floor Plan EL 707'-6" & 712'-0" Sheet 7, Auxiliary, Fuel & Containment Grade Floor Plan EL 737-0" Sheet 8, Auxiliary, Fuel & Containment Mezz. Floor Plan EL 755'-0" & 762'-0" Sheet 9, Auxiliary, Fuel & Containment EL 778'-0" & 781'-0" Sheet 1 O, Containment Building Floor Plan EL 803'-3" Sheet 11, Containment Building Refueling Floor EL 828'-3"

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