PLA-5861, Follow-Up Response to Generic Letter 2003-01 Control Room Habitability

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Follow-Up Response to Generic Letter 2003-01 Control Room Habitability
ML050530188
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 02/11/2005
From: Saccone R
Susquehanna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-03-001, PLA-5861
Download: ML050530188 (5)


Text

%I I j I R A.Saccone PPL Susquehanna, LLC . ' 1**i8 '

Vice President - Nuclear Operations 769 Salem Boulevard**

Berwick, PA 18603

  • Tel. 570.542.3959 Fax 570.542-1504 - -

rasaccone~pplweb.corn l FEB 1 1 2005 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION FOLLOW-UP RESPONSE TO GENERIC LETTER 2003-01 CONTROL ROOM HABITABILITY Docket Nos. 50-387 PLA-5861 and 50-388

References:

1) GenericLetter 2003-01 "ControlRoom Habitability," dated June 12, 2003.
2) PLA-5659, B. L Shriver(PPL) to USNRC Document ControlDesk, "Response to Generic Letter 2003-01 ControlRoom Habitability,"

dated August 11, 2003.

3) PLA-5711, B. L Shriver (PPL)to USNRC Document Control Desk, "Follow-tup Response to GenericLetter 2003-01, Control Room Habitability,"

dated February3, 2004.

The purpose of this letter is to revise the completion date of two of the commitments provided in Reference 3. Reference 3 provided a detailed description of the actions PPL Susquehanna, LLC (PPL) is committed to take to resolve the concerns identified in Generic Letter (GL) 2003-01 "Control Room Habitability (CRH)." The Attachment to this letter is an updated version of Attachment 2 from that submittal. The Attachment to this letter updates the status of three commitments which have been completed, and reflects the revised completion dates of two commitments.

Subsequent to development of the commitments delineated in Reference 3, PPL initiated plans for an Extended Power Uprate (EPU). To fully resolve the issues identified in the GL and to implement the EPU, conversion to the Alternate Source Term (AST) is required. Efficient use of both PPL and NRC resources in the development and review of the requisite AST analyses and AST license amendment request would be best served by a combined CRH and EPU license amendment request.

Document Control Desk PLA-5861 Thus, PPL is revising the completion date of the following two commitments:

"PPL commits to providing a dose consequence submittal to the NRC, using the methodology described in Regulatory Guide 1.183, Alternative Radiological Source Terms For Evaluating Design Basis Accidents at Nuclear Power Reactors."

and "PPL will perform an assessment of the AP Technical Specification and determine if changes to the Technical specification are required."

Both commitments will be completed by December 30, 2005 rather than June 30, 2005.

These changes will allow sufficient time for completion of one comprehensive AST analysis and AST license amendment request. The alternative to these commitment changes would be to make two AST submittals, one for the CRH GL and one forEPU, within less than six months of each other. This combined submittal constitutes more efficient use of both PPL and NRC resources.

Additionally, the revised commitment completion dates are believed acceptable based on the unfiltered in-leakage flow rates measured during tracer gas testing performed December 2005 that are bounded by preliminary dose consequence analyses previously performed that concluded high unfiltered in-leakage flow rates could be accommodated.

The contents of this letter have been discussed with Mr. Richard Guzman, the SSES NRR Project Manager.

Any questions regarding this information should be directed to Mr. Michael H. Crowthers at (610) 774-7766.

Sincerely, Rob A. Saccone Vice President - Nuclear Operations Attachment - List of Regulatory Commitments copy: NRC Region I Mr. A. J. Blamey, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP

,' !I :t .

Attachment to PLA-5861 List of Regulatory Commitments

1 Listof*to Re Comm. s Attachment to PLA-5861 Page I of 2 List of Regulatory Commitments

,- .i,5 -

-Regulatoiy Commitment I-- - -Due Date V . -

PPL commits to providing a dose December 30, 2005 consequence submittal to the NRC, using the methodology described in Regulatory Guide 1.183, "Alternative Radiological Source Terms For Evaluating Design Basis Accidents at Nuclear Power Reactors."

PPL will notify NRC if the release of an July 30, 2004 inventory of hazardous chemicals, The information on railroad shipments has transported by railroad, is not imminent. been received. This commitment has been met.

[or]

If the inventory of hazardous chemicals December 31, 2004 that are transported by the railway is A hazardous chemical control room received by July 30, 2004, PPL will habitability assessment has been -

complete the hazardous chemical control completed. This commitment has been room habitability assessment. met.

PPL will commit to comply with Revision December 31, 2004 1 of Regulatory Guide 1.78, "Evaluating An FSAR change notice has been the Habitability of a Nuclear Power Plant generated and approved updating the FSAR Control Room During a Postulated to reflect SSES commitment to Regulatory Hazardous Chemical Release." This Guide 1.78 revision 1. This commitment commitment will be incorporated into the has been met.

FSAR.

PPL commits to perform and transmit the June 30, 2005 results of an integrated tracer gas test using PPL completed the tracer gas test on the standard test method described in December 10, 2004. A final report has not American Society for Testing Materials yet been issued. The results will be (ASTM) consensus standard E741 transmitted to NRC as originally "Standard Test Method for Determining committed. The preliminary test results Air Change in a Single Zone by Means of a were acceptable.

Tracer Gas Dilution," and the results of the corresponding dose consequence analysis.

Attachment to PLA-5861 Page 2 of 2 Regulatory Commitment - -- Due-Date  :-:- -

PPL will perform an assess'.ment of the AP December 30, 2005 Technical Specification and determine if changes to the Technical Specification are required.

Text

%I I j I R A.Saccone PPL Susquehanna, LLC . ' 1**i8 '

Vice President - Nuclear Operations 769 Salem Boulevard**

Berwick, PA 18603

  • Tel. 570.542.3959 Fax 570.542-1504 - -

rasaccone~pplweb.corn l FEB 1 1 2005 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION FOLLOW-UP RESPONSE TO GENERIC LETTER 2003-01 CONTROL ROOM HABITABILITY Docket Nos. 50-387 PLA-5861 and 50-388

References:

1) GenericLetter 2003-01 "ControlRoom Habitability," dated June 12, 2003.
2) PLA-5659, B. L Shriver(PPL) to USNRC Document ControlDesk, "Response to Generic Letter 2003-01 ControlRoom Habitability,"

dated August 11, 2003.

3) PLA-5711, B. L Shriver (PPL)to USNRC Document Control Desk, "Follow-tup Response to GenericLetter 2003-01, Control Room Habitability,"

dated February3, 2004.

The purpose of this letter is to revise the completion date of two of the commitments provided in Reference 3. Reference 3 provided a detailed description of the actions PPL Susquehanna, LLC (PPL) is committed to take to resolve the concerns identified in Generic Letter (GL) 2003-01 "Control Room Habitability (CRH)." The Attachment to this letter is an updated version of Attachment 2 from that submittal. The Attachment to this letter updates the status of three commitments which have been completed, and reflects the revised completion dates of two commitments.

Subsequent to development of the commitments delineated in Reference 3, PPL initiated plans for an Extended Power Uprate (EPU). To fully resolve the issues identified in the GL and to implement the EPU, conversion to the Alternate Source Term (AST) is required. Efficient use of both PPL and NRC resources in the development and review of the requisite AST analyses and AST license amendment request would be best served by a combined CRH and EPU license amendment request.

Document Control Desk PLA-5861 Thus, PPL is revising the completion date of the following two commitments:

"PPL commits to providing a dose consequence submittal to the NRC, using the methodology described in Regulatory Guide 1.183, Alternative Radiological Source Terms For Evaluating Design Basis Accidents at Nuclear Power Reactors."

and "PPL will perform an assessment of the AP Technical Specification and determine if changes to the Technical specification are required."

Both commitments will be completed by December 30, 2005 rather than June 30, 2005.

These changes will allow sufficient time for completion of one comprehensive AST analysis and AST license amendment request. The alternative to these commitment changes would be to make two AST submittals, one for the CRH GL and one forEPU, within less than six months of each other. This combined submittal constitutes more efficient use of both PPL and NRC resources.

Additionally, the revised commitment completion dates are believed acceptable based on the unfiltered in-leakage flow rates measured during tracer gas testing performed December 2005 that are bounded by preliminary dose consequence analyses previously performed that concluded high unfiltered in-leakage flow rates could be accommodated.

The contents of this letter have been discussed with Mr. Richard Guzman, the SSES NRR Project Manager.

Any questions regarding this information should be directed to Mr. Michael H. Crowthers at (610) 774-7766.

Sincerely, Rob A. Saccone Vice President - Nuclear Operations Attachment - List of Regulatory Commitments copy: NRC Region I Mr. A. J. Blamey, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP

,' !I :t .

Attachment to PLA-5861 List of Regulatory Commitments

1 Listof*to Re Comm. s Attachment to PLA-5861 Page I of 2 List of Regulatory Commitments

,- .i,5 -

-Regulatoiy Commitment I-- - -Due Date V . -

PPL commits to providing a dose December 30, 2005 consequence submittal to the NRC, using the methodology described in Regulatory Guide 1.183, "Alternative Radiological Source Terms For Evaluating Design Basis Accidents at Nuclear Power Reactors."

PPL will notify NRC if the release of an July 30, 2004 inventory of hazardous chemicals, The information on railroad shipments has transported by railroad, is not imminent. been received. This commitment has been met.

[or]

If the inventory of hazardous chemicals December 31, 2004 that are transported by the railway is A hazardous chemical control room received by July 30, 2004, PPL will habitability assessment has been -

complete the hazardous chemical control completed. This commitment has been room habitability assessment. met.

PPL will commit to comply with Revision December 31, 2004 1 of Regulatory Guide 1.78, "Evaluating An FSAR change notice has been the Habitability of a Nuclear Power Plant generated and approved updating the FSAR Control Room During a Postulated to reflect SSES commitment to Regulatory Hazardous Chemical Release." This Guide 1.78 revision 1. This commitment commitment will be incorporated into the has been met.

FSAR.

PPL commits to perform and transmit the June 30, 2005 results of an integrated tracer gas test using PPL completed the tracer gas test on the standard test method described in December 10, 2004. A final report has not American Society for Testing Materials yet been issued. The results will be (ASTM) consensus standard E741 transmitted to NRC as originally "Standard Test Method for Determining committed. The preliminary test results Air Change in a Single Zone by Means of a were acceptable.

Tracer Gas Dilution," and the results of the corresponding dose consequence analysis.

Attachment to PLA-5861 Page 2 of 2 Regulatory Commitment - -- Due-Date  :-:- -

PPL will perform an assess'.ment of the AP December 30, 2005 Technical Specification and determine if changes to the Technical Specification are required.