RA-10-009, Oyster Creek, License Amendment Request, Changes to Trunnion Room Secondary Containment Boundary

Oyster Creek, License Amendment Request, Changes to Trunnion Room Secondary Containment Boundary

ML100620011
Person / Time
Site:	Oyster Creek
Issue date:	02/25/2010
From:	Cowan P B Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML100620010	List: ML100620011 RA-10-009, Oyster Creek, License Amendment Request, Changes to Trunnion Room Secondary Containment Boundary
References
RA-10-009
Download: ML100620011 (8)

Text

Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 RA-10-009 February 25,2010 U.S.Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No.DPR-16 Docket No.50-219

Subject:

License Amendment Request Changes to Trunnion Room Secondary Containment Boundary Nuclear 10CFR50.90 Pursuant to 10 CFR 50.90,Application for amendment of license or construction permit, II Exelon Generation Company, LLC (Exelon), hereby requests an amendment to Appendix A, Technical Specifications (TS), of Renewed Facility Operating License No.DPR-16 for Oyster Creek Nuclear Generating Station (OCNGS).The proposed changes to the TS would allow the Reactor Building Secondary Containment boundary associated with the Trunnion Room to be relocated from the Trunnion Room outer wall and door, to the Reactor Building inner walls and penetrations located inside the Trunnion Room.The proposed changes would be instituted on a temporary basis during Cold Shutdown conditions in order to support refueling and maintenance outage related activities.

The proposed changes would modify the OCNGS TS and associated TS Bases to: 1)Revise TS Definition 1.14,"SECONDARY CONTAINMENT INTEGRITY," to include a requirement allowing the Trunnion Room door to remain open provided the Trunnion Room is isolated from the Secondary Containment and the Secondary Containment boundary is secure.The definition will also be revised to correct the misspelling of the word"integrity" as noted in the TS mark-Ups.2)Revise TS Surveillance ReqUirement(SR)4.5.G,"Reactor Building,"to include a requirement for Standby Gas Treatment System (SGTS)testing to ensure integrity of the relocated Secondary Containment boundary once instituted.

3)Revise TS Bases 3.5 to include the basis for conducting the SGTS testing for the relocated Secondary Containment boundary.4)Revise TS SR Bases 4.5 to include the basis for conducting the SGTS testing for the relocated Secondary Containment boundary.Figure 1 transmitted herewith in Attachment 1 contains Sensitive Unclassified Non-Safeguards Information (SUNSI).When separated, this transmittal document is decontrolled.

License Amendment Request Trunnion Room Secondary Containment Boundary Docket No.50-219 February 25, 2010 Page 2 An evaluation of the proposed changes is provided in Attachment 1.Markups of the proposed TS changes are provided in Attachment 2.Attachment 3 contains mark-ups of the proposed TS Bases changes.The proposed changes have been reviewed by the Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program.Exelon requests approval of the proposed amendments by August 25, 2010, in order to support activities planned for the Fall 2010 refueling outage.Once approved, the amendment shall be implemented within 60 days.Exelon has concluded that the proposed changes do not constitute a significant hazards consideration under the standards set forth in 10 CFR 50.92.There are no regulatory commitments contained in this submittal.

Pursuant to 10 CFR 50.91 (b)(1), a copy of this License Amendment Request is being provided to the designated representatives of the State of New Jersey.Should you have any questions concerning this letter, please contact Mr.Richard Gropp at (610)765-5557.I declare under penalty of perjury that the foregoing is true and correct.Executed on the 25th day of February 2010.Respectfully, Pamela B.Cowan Director-Licensing&Regulatory Affairs Exelon Generation Company, LLC Attachments:1-Evaluation of Proposed Changes2-Mark-ups of Technical Specification Pages3-Mark-ups of Technical Specification Bases Pages cc: NRC Regional Administrator,RegionI NRC Senior Resident Inspector, Oyster Creek NRC Project Manager, NRR, Oyster Creek Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Mayor of Lacey Township ATTACHMENT 2 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No.DPR*16"Changes to Trunnion Room Secondary Containment Boundary" Markup of Proposed Technical Specifications Page Changes REVISED TS PAGES 1.0-3 4.5-4 1.14 SECONDARY CONTAINMENT INTEGRITY Secondary containment integrity means that the reactor building is closed and the following conditions are met: A.At least one door at each access opening is closed.(Note: Momentary opening and closing of the trunnion room door does not constitute a loss of secondar containment inte rit B.The standby gas treatment system is operable.C.All automatic secondary containment isolation valves are operable or are secured in the closed position.1.15 (DELETED)1.16 RATED FLUX Rated flux is the neutron flux that corresponds to a steady state power level of 1930 MW(t).Use of the term 100 percent also refers to the 1930 thermal megawatt power level.1.17 REACTOR THERMAL POWER-TO-WATER Reactor thermal power-to-water is the sum of (1)the instantaneous integral over the entire fuel clad outer surface of the product of heat transfer area increment and position dependent heat flux and (2)the instantaneous rate of energy deposition by neutron and gamma reactions in all the water and core components except fuel rods in the cylindrical volume defined by the active core height and the inner surface of the core shroud.1.18 PROTECTIVE INSTRUMENTATION LOGIC DEFINITIONS A.Instrument Channel An instrument channel means an arrangement of a sensor and auxiliary equipment required to generate and transmit to a tripsystema single trip signal related to the plant parameter monitored by that instrument channel.B.Trip System A trip system means an arrangement of instrument channel trip signals and auxiliary equipment required to initiate action to accomplish a protective trip function.A trip system may require one or more instrument channel trip signals related to one or more plant parameters in order to initiate trip system action.Initiation of protective action may require the tripping of a single trip system (e.g., initiation of a core spray loop, automatic depressurization, isolation of an isolation condenser, offgas system isolation, reactor building isolation, standby gas treatment and rod block)or the coincident tripping of two trip systems (e.g., initiation of scram, isolation condenser, reactor isolation, and primary containment isolation).

OYSTER CREEK 1.0-3 Change 7, Amendment No.: 10, 160, 168,211,233 (3)At least four of the suppression chamber-drywell vacuum breakers shall be inspected.

If deficiencies are found, all vacuum breakers shall be inspected and deficiencies corrected such that Specification 3.5.A.5.a can be met.(4)A drywell to suppression chamber leak rate test shall be performed once every 24 months to demonstrate that with an initial differential pressure of not less than 1.0 psi, the differential pressure decay rate shall not exceed the equivalent of air flow through a 2-inch orifice.G.Reactor Building 1.Secondary containment capability tests shall be conducted after isolating the reactor building and placing either Standby Gas Treatment System filter train in operation.

2.The tests shall be performed at least once per operating cycle (interval not to exceed 20 months)and shall demonstrate the capability to maintain a 1/4 inch of water vacuum under calm wind conditions with a Standby Gas Treatment System Filter train flow rate of not more than 4000cfm.A secondary containment capability test shall be conducted at each refueling outage prior to refueling.

The results of the secondary containment capability tests shall be in the subject of a summary technical report which can be included in the reports specified in Section 6.H.Standby Gas Treatment System 1.The capability of each Standby Gas Treatment System circuit shall be demonstrated by: a.At least once per 18 months, after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation, and following significant painting, fire, or chemical release in the reactor building during operation of the Standby Gas Treatment System by verifying that: (1)The charcoal absorbers remove;::99%of a halogenated hydrocarbon refrigerant test gas and the HEPA filters remove;::99%of the DOP in a cold DOP test when tested in accordance with ANSI N510-1975.

OYSTER CREEK 4.5-4 Amendment No.: 144,186,193,219 ATTACHMENT 3 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No.DPR-16"Changes to Trunnion RoomSecondaryContainment Boundary" Markup of Proposed Technical Specifications Bases Page Changes REVISED TS BASES PAGES 3.5-11 4.5-13 Snubbers are designed to prevent unrestrained pipe motion under dynamic loads as might occur during an earthquake or severe transient, while allowing normal thermal motion during startup and shutdown.The consequence of an inoperable snubber is an increase in the probability of structural damage to piping as a result of a seismic or other event initiating dynamic loads.It is, therefore, required that all snubbers required to protect the primary coolant system or any other safety system or component be OPERABLE whenever the systems they protect are required to be OPERABLE.The purpose of an engineering evaluation is to determine if the components protected by the snubber were adversely affected by the inoperability of the snubber.This ensures that the protected component remains capable of meeting the designed service.A documented visual inspection will usually be sufficient to determine system OPERABILITY.

Because snubber protection is required only during low probability events, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed for repairs or replacements.

Secondary containment(5) is designed to minimize any ground level release of radioactive materials which might result from a serious accident.The reactor building provides secondary containment during reactor operation when the drywell is sealed and in service and provides primary containment when the reactor is shutdown and the drywell is open, as during refueling.

Because the secondary containment is an integral part of the overall containment system, it is required at all times that primary containment is required.Moreover, secondary containment is required during fuel handling operations and whenever work is being performed on the reactor or its connected systems in the reactor building since their operation could result in inadvertent release of radioactive material.When secondary containment is not maintained, the additional restrictions on operation and maintenance give assurance that the probability of inadvertent releases of radioactive material will be minimized.

Maintenance will not be performed on systems which connect to the reactor vessel lower thanthetop of the active fuel unless the system is isolated by at least one locked closed isolation valve.The trunnion room door is not an access opening for the passage of personnel and equipment into the reactor building.During all modes of operation, the trunnion room is a low traffic area and momentary openings of the door would be Iill1ited and administrativel controlled and have little effect on SGTS and HV A The standby gas treatment system(6)filters and exhausts the reactor building atmosphere to the stack during secondary containment isolation conditions, with a minimum release of radioactive materials from the reactor building to the environs.In Section 3.5.B.5 and 3.5.B.6 of the Technical Specification, the use of the word"Circuits" actually meansTrains

as the word trains is used in the following paragraph.

OYSTER CREEK 3.5-11 Amendment No.: 18,74,76,100,196,211, ECR OC 04-00842 Corrected:

12/24/84 During each refueling outage, four suppression chamber-drywell vacuum breakers will be inspected to assure components have not deteriorated.

Since valve internals are designed for a 40-year lifetime, an inspection program which cycles through all valves in about 1/1 Oth of the design lifetime is extremely conservative.

The alarm systems for the vacuum breakers will be calibrated during each refueling outage.This frequency is based on experience and engineering judgement.

Initiating reactor building isolation and operation of the standby gas treatment system to maintain a 1/4 inch of water vacuum, tests the operation of the reactor building isolation valves, leakage tightness of the reactor building and performance of the standby gas treatment system.Checking the initiating sensors and associated trip channels demonstrates the capability for automatic actuation.

Performing the reactor bUilding in leakage test prior to refueling demonstrates seconda containment ca ability prior to extensive fuel hand lin operations associated with the outage.Verifying the efficiency and operation of charcoal filters once per 18 months gives sufficient confidence of standby gas treatment system performance capability.

A charcoal efficiency of 99%for halogen removal is adequate.The in-place testing of charcoal filters is performed using halogenated hydrocarbon refrigerant which is injected into the system upstream of the charcoal filters.Measurement of the refrigerant concentration upstream and downstream of the charcoal filters is made using a gas chromatograph.

The ratio of the inlet and outlet concentrations gives an overall indication of the leak tightness of the system.Although this is basically a leak test, since the filters have charcoal of known efficiency and holding capacity for elemental iodine and/or methyl iodide, the test also gives an indication of the relative efficiency of the installed system.The test procedure is an adaptation of test procedures developed at the Savannah River Laboratory which were described in the Ninth AEC Cleaning Conference.

• High efficiency particulate filters are installed before and after the charcoal filters to minimize potential releases of particulates to the environment and to prevent clogging of the iodine filters.An efficiency of 99%is adequate to retain particulates that may be released to the reactor building following an accident.This will be demonstrated bytestingwith DOP at testing medium.The 95%methyl iodide removal efficiency is based on the formula in GL 99-02 for allowable penetration

[(100%-90%credited in DBA analysis)divided by a safety factor of 2].If the allowable penetration is:::;5%, the required removal efficiency is If laboratory tests for the adsorber material in one circuit of the Standby Gas Treatment System are unacceptable, all adsorber material in that circuit shall be replaced with adsorbent qualified according to Regulatory Guide 1.52.Any HEPA filters found defective shall be replaced with those qualified with Regulatory Position C.3.d of Regulatory Guide 1.52.*D.R.Muhabier."In Place Nondestructive Leak Test for Iodine Adsorbers." Proceedings of the Ninth AEC Air Cleaning Conference.

USAEC Report CONF-660904, 1966 OYSTER CREEK 4.5-13 Amendment No.: 186, 195,219