ML20205P686
| ML20205P686 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/27/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Butler W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| CON-#287-3287 OL, NUDOCS 8704030345 | |
| Download: ML20205P686 (5) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 121st e4150o1
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.Mr. W. R. Butler March 27, 1987 BWR Project Directorate M Docket No. 50-352 Division of Bolling Water Reactor Licensing U.S. Nuclear Regulatory Conmission ATTENTION: Docunent Control Desk Washington, DC 20555
Dear Mr. Butler:
The purpose of this letter is to provide additional information for Philadelphia Electric Company's January 30, 1987 Application for Amendment of Facility Operating License NPF-39. The Appilcation for Anendnent requested a change to the Limerick Technical Specifications relating to increased allowable control room leakage during operation of the Control Roan Emergency Fresh Air Supply (CREFAS) system in the radiation isolation mode.
The additional information was requested by the NRC staff during telephone conversations on March 12 and March 25, 1987. The questions are restated below followed by our responses:
Question 1 Provide clarification of the discussion of the FSAR and "SER-type" radiological analyses on pages 6 and 7 of the Appilcation and provide the results of the "SER-type" analyses.
Response 1 For the FSAR radiological analysis for control room doses discussed on page 6 of the Appilcation, the Limerick FSAR LOCA analysis methodology described in FSAR Section 15.6.5 is followed.
This analysis utilized the following infonnation as inputs:
i 1.
LOCA parameters from FSAR Table 15.6-13.
l 2.
Control room parameters from FSAR Table 15.6-21.
3.
Control roon atmospheric dispersion factors fran FSAR Section 15.10.2.1 and FSAR Table 15.10-2.
4.
Sequence of events shown in FSAR Table 15.6-27.
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Results of the FSAR LOCA analysis for control room doses are shown in the table below and in Table 1 of the Application.
The calculation of the control room doses using the "SER-type" methodology which includes "SER-type" conservatisms was a " modified" LOCA analysis..This analysis is based on the following:
1.
Limerick SER (NUREG-0991 Supplement 3) LOCA analysis description, parameters, and results obtained from SSER-3 Section 15.6, Table 15.1 and Table 15.5 were used to develop an "SER-type" offsite LOCA dose analysis.
2.
The methodology from the "SER-type" offsite LOCA dose analysis.was used to perform an "SER-type" control rocrn LOCA dose analysis.
3.
Control room parameters from FSAR Table 15.6-21.
4.
Control rocm atmospheric dispersion factors from FSAR Section 15.10.2.1 and FSAR Table 15.10-2.
Results of this "SER-type" analysis are shown in the table below:
Control Rocm Doses For Proposed Technical Specification Change To Increase Leakage Rate to 2100 CFM "SER-Type" 30-Day FSAR Analyses Analyses Integrated 10CFR50 Current New Current New Doses GDC 19 Tech Spe Tech Specs Tech Specs Tech Specs
.(525cfm)g) (2100 cfm)
(525 cfm)
(2100 cfm)
(Rem)
Requirement Thyroid 30"
.0043
.018 1.3 4.0 Bsta Skin 30" 7.6 8.9 7.6 8.9 Whole Body 5
.38
.47
.38
.47 NOTE:
(1) FSAR analysis current Technical Specification values were obtained
'from FSAR Table 15.6-22 "Although 10CFR50 GDC 19 does not explicitly give requirements for thyroid and beta skin doses, SRP 6.4 Section II.6 gives the listed values.
j
The "SER-type" analysis was perfonned to ' estimate the results of an NRC calculation of the control room operator doses resulting from the proposed higher leakage rate.
The results of the FSAR and the "SER-type" analyses Indicate that relative to the doses calculated at the original leakage rate, the thyroid doses have the largest increase but, as shown in the above table, are.still small in comparison to q
regulatory limits. The beta skin dose remains the largest l~
. percentage of the dose Ilmits, as it was under the' analysis fonning the. basis for the current Technical Specification, and the GDC-19 criteria are still met. Upon approval of the Application, FSAR Table 15.6-22 will be changed to the FSAR analysis results at 2100 cfm.
Question _2_
Provide clarification of the discussion of the limiting toxic chemical and calculated incapacitation times under the current and proposed control room leakage rates on page 11 of the Application.
Response 2 The limiting toxic chemical under the current analysis presented in FSAR Table 2.2-6 is ethylene oxide.with an incapacitation time of 2.6 minutes with the control room unisolated. Under the analysis for the increased Inleakage, the limiting chemical remains ethylene oxide with an incapacitation time of 2.1 minutes, with the control room unisolated. As with the current analysis, the results of the analysis supporting the Appilcation also provide nere than the two minutes required for operator protective action per Regulatory Guide 1.78.
The discussion on page 11 of the Appilcation for Amendment shows phosgene limiting.at 3.5 minutes with an isolated control room leakage rate of 525 cfm and ethylene oxide.
Ilmiting at no less than 2.3 minutes with an-isolated control room leakage rate of 2100 cfm. The assunption that the control room is manually isolated upon receipt of the toxic chemical alarm is inconsistent with. the assunption of an unisolated control room in FSAR Section 2.2.3.1.3.
Additionally it was noted that "NUREG/ control room-1741" on page 5 of the Appilcation is a typographical error. That portion of the Appilcation should have read "NUREG/CR-1741".
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This' additional information is bounded by the Safety Discussion
' and SIgnifIcant Hazards Consideration Determination in the Application.
If you have any questions or require additional information,-
please do not hesitate to contact us.
Very truly yours, k
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CWW/cb/03268705-Attachment Copy to:
Dr. T. E. Murley, Administrator, Region I, US NRC E. M. Kelly, Senior Resident Site-Inspector Mr. R. E. Martin, LGS Project Manager See Attached Service List 4
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COPHONWEALTH OF PEtNSYLVANIA ss.
COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Comany; that he'has read the foregoing response to the NRC Staff's request for additional information regarding Licensee's January 30, 1987, Application for Amendment of Facility Operating License NPF-39 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
l 0 0.G v
o Vice President Subscribed and sworn to P
before me this 27 day of March, 1987.
MEl.ANIE R. CAMPANELLA Notary Public, Philadelphia, Philadelphie Co.
My Commission Expires February 12,1990
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 12151 841 5001
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Mr. W. R. Butler March 27, 1987 BWR Project Directorate #4 Docket No. 50-352 Division of Bolling Water Reactor Licensing U.S. Nuclear Regulatory Conmission ATTENTION: Doctment Control Desk Washington, DC 20555
Dear Mr. Butler:
The purpose of this letter is to provide additional Information for Philadelphia Electric Ccmpany's January 30, 1987 App 1tcation for Anendment of Facility Operating License NPF-39. The Appilcation for Amendment requested a change to the Limerick Technical Specifications relating to increased allowable control room leakage during operation of the Control Room Emergency Fresh Air Supply (CREFAS) system in the radiation Isolation mode.
The additional information was requested by the NRC staff during telephone conversations on March 12 and March 25, 1987. The questions are restated below followed by our responses:
Question 1 Provide clarification of the discussion of the FSAR and "SER-type" radiological analyses on pages 6 and 7 of the Appilcation and provide the results of the "SER-type" analyses.
Response 1 For the FSAR radiological analysis for control room doses discussed on page 6 of the Appilcation, the Limerick FSAR LOCA analysis methodology described in FSAR Section 15.6.5 is followed.
This analysis utilized the following Information as inputs:
~
1.
LOCA parameters from FSAR Table 15.6-13.
2.
Control room parameters from FSAR Table 15.6-21.
3.
Control room atmospheric dispersion factors from FSAR Section 15.10.2.1 and FSAR Table 15.10-2.
4.
Sequence of events shown in FSAR Table 15.6-27.
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s Results of the FSAR LOCA analysis for control room doses are shown in the table below and in Table 1 of the Appilcation.
The calculation of the control room doses using the "SER-type" methodology which includes "SER-type" conservatisms was a " modified" LOCA analysis. This analysis is based on the following:
1.
Limerick SER (NUREG-0991 Supplement 3) LOCA.
analysis description, parameters, and results obtained from SSER-3 Section 15.6, Table 15.1 and Table 15.5 were used to develop an "SER-type" offsite LOCA dose analysis.
2.
The methodology from the "SER-type" offsite LOCA dose analysis was used to perform an "SER-type" control rocm LOCA dose analysis.
3.
Control room parameters from FSAR Table 15.6-21.
4.
Control room atmospheric dispersion factors from FSAR Section 15.10.2.1 and FSAR Table 15.10-2.
Results of this "SER-type" analysis are shown in the table below:
Control Room Doses For Proposed Technical Specification Change To Increase Leakage Rate to 2100 CFM "SER-Type"
~
30-Day FSAR Analyses Analyses Integrated 10CFR50 Current New Current New Dosts GDC 19 Tech Spe Tech Specs Tech Specs Tech Specs (525cfm)g) (2100 cfm)
(525 cfm)
(2100 cfm)
(Rem)
Requirement Thyroid 30'
.0043
.018 1.3 4.0 Bata Skin 30" 7.6 8.9 7.6 8.9 Whole Body 5
.38
.47
.38
.47 NOTE:
(1) FSAR analysis current Technical Specification values were obtained from FSAR Table 15.6-22 "Although 10CFR50 GDC 19 does not explicitly give requirements for thyroid and beta skin doses, SRP 6.4 Section II.6 gives the IIsted values.
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The "SER-type" analysis was performed to estimate the recults of an NRC calculation of the control room operator doses resulting frcm the proposed higher leakage rate.
The results of the FSAR and the "SER-type" analyses indicate that relative to the doses calculated at the original leakage rate, the thyroid doses have the largest increase but, as shown in the above table, are still small in comparison to regulatory limits. The beta skin dose remains the largest percentage of the dose limits, as it was under the analysis forming the basis for the current Technical Specification, and the GDC-19 criteria are still met. Upon approval of the Application, FSAR Table 15.6-22 will be changed to the FSAR analysis results at 2100 cfm.
Question 2 Provide clarification of the discussion of the Ilmiting toxic chemical and calculated incapacitation times under the current and proposed control room leakage rates on page 11 of the Appilcation.
Response 2 The limiting toxic chemical under the current analysis presented in FSAR Table 2.2-6 is ethylene oxide with an incapacitation time of 2.6 minutes with the control room unisolated. Under the analysis for the increased inleakage, the limiting chemical remains ethylene oxide with an incapacitation time of 2.1 minutes, with the control room unisolated. As with the current analysis, the results of the analysis supporting the Appilcation also provide more than the two minutes required for operator protective action per Regulatory Guide 1.78.
The discussion on page 11 of the Application for Amencknent shows phosgene Ilmiting at 3.5 minutes with an isolated i
control room leakage rate of 525 cfm and ethylene oxide
)
limiting at no less than 2.3 minutes with an isolated control room leakage rate of 2100 cfm. The assunptIon that the control room is manually isolated upon receipt of the toxic
)
chemical alarm is inconsistent with the assunption of an unisolated control room in FSAR Section 2.2.3.1.3.
Additionally It was noted that "NUREG/ control room-1741" on page 5 of the Appilcation is a typographical error. That portion of the Appilcation should have read "NUREG/CR-1741".
i
. t.:
This additional information is bounded by the-Safety Discussion and Significant Hazards Consideration Detennination in the Application.
If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, k 10~ L g3 c--
CWW/cb/03268705 Attachnent Copy to:
Dr. T. E. Murley, Administrator, Region I, US NRC E. M. Kelly, Senior Resident Site Inspector Mr. R. E. Martin, LGS Project Manager
'See Attached Service List
,