RA-10-079, Supplemental Information Regarding License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions

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Supplemental Information Regarding License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions
ML102880123
Person / Time
Site: Oyster Creek
Issue date: 10/14/2010
From: Cowan P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-10-079, TAC ME3475
Download: ML102880123 (5)


Text

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Nuclear Nuclear Son nett Sq i i ePA ii 10 CFR 50.90 10 CFR 50.90 RA-10-079 RA- 10-079 October 14,2010 14, 2010 U. S. Nuclear Regulatory Commission U.S.

AnN: Document Control Desk ATTN:

Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219

Subject:

Supplemental Information Regarding License Amendment Request to Allow Supplemental Changes to Secondary Containment Boundary During Shutdown Conditions Conditions

References:

1) Letter from Pamela B. Cowan to U.S. Nuclear Regulatory Commission License Amendment Request - Changes to Trunnion Room Secondary Containment Boundary, dated February 25, 2010 Regulatory Commission facsimile dated June 18, 2010, Oyster
2) U.S. Nuclear Regulatory Creek Nuclear Generating Station - Electronic Transmission, Transmission, Draft Request for Additional Information Regarding License Amendment Request to Allow Temporary Changes to Secondary Containment Boundary During Shutdown Conditions Conditions (TAC (TAG No. ME3475) 3)
3) Letter Letter from Pamela B.

from Pamela B. Cowan to U.S. Nuclear Regulatory Commission, Commission,

Response

Response to Draft Request for Additional Information - License Amendment Draft Request Request Request to to Allow Changes to Allow Changes to Secondary Containment Boundary During Conditions, dated July 9, 2010 Shutdown Conditions, Shutdown By By letter letter dated dated February February 25,25, 2010 (Reference 1),

2010 (Reference 1), Exelon Company, LLC (Exelon)

Generation Company, Exelon Generation submitted submitted aa requestrequest to revise the to revise the Oyster Generating Nuclear Generating Creek Nuclear Oyster Creek Station (OCNGS) Technical Specifications Specifications (TS) (TS) to to allow the Reactor allow the Secondary Containment Building Secondary Reactor Building associated with the Containment associated Trunnion Trunnion Room boundary to Room boundary to be relocated on be relocated basis during temporary basis on aa temporary during Cold Shutdown Cold Shutdown conditions conditions to to support refueling and support refueling maintenance outage and maintenance outage related activities.

related activities.

Subsequently, Subsequently, during during teleconference Exelon and between Exelon discussions between teleconference discussions U.S. Nuclear and U.S. Regulatory Nuclear Regulatory Commission Commission (NRC) representatives on (NRC) representatives 14, 2010, Exelon agreed October 14, 2010, Exelon agreed to provide on October to provide supplemental information to supplemental information the proposed clarify the to clarify in the wording in proposed wording the affected Technical affected Technical Specifications Specifications (TS) (TS) sections (i.e., TS sections (Le., 1.14, "Secondary Definition 1.14, TS Definition Containment Integrity,"

Secondary Containment the and the Integrity, and revised revised TS TS Surveillance 4.5.G.3).

Requirement 4.5.G.3).

Surveillance Requirement

u.s.

U.S. Nuclear Regulatory Commission License Amendment Request Trunnion Room Secondary Containment Boundary Supplemental Response Docket No. 50-219 October 14, 2010 Page 2 Exelon has concluded that the information provided in this response does does not impact the not impact the under the conclusions of the: 1) Technical Analysis, 2) No Significant Hazards Consideration under the provided in 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 submittal.

Should you have any questions concerning this letter, please contact Mr. Gropp at Richard Gropp Mr. Richard at (610) 765-5557.

II declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th 14th day of October 2010.

Respectfully, Pamela B. Cowan Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Revised Technical Specifications Pages (Mark-ups) cc: Regional Administrator - NRC Region II Regional -

NRC Senior Resident Inspector - OCNGS NRC Project Manager, NRR - OCNGS Director, Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection

ATTACHMENT Oyster Creek Nuclear Generating Station Supplemental Response License Amendment Request Trunn ion Room Secondary Containment Boundary Changes to Trunnion During Shutdown Conditions Revised Technical Specifications Pages (Mark-ups) 1.0-3 4.5-4

1.14 114 SECONDARY CONTAINMENT SECONDARY CONTAINMENT INTEGRITY INTEGRITY Secondary containment integrity means that that the building is the reactor building is closed closed and and the the following conditions are met:

A. At least one door at each access opening opening isis closed.

closed.

Momentary opening (Note: Momentary opening and closing of of the trunnion trunnion room room door does not door does not constitute a loss of secondary containment intergrity. intergrity. In In Cold Shutdown, the the trunnion trunn ion room door may remain open provided the the trunnion room isolated from room is isolated from the secondary containment through the reactor building building walls, penetrations and and either the inboard or outboard valves to the main main steam and mf!a\l\'8H~r piping and feedwater being secured in the closed position)position.)

B. The standby gas treatment system is operable.

C. All automatic secondary containment isolation valves are operable operable or or are secured in the closed position.

1.15 115 (DELETED) 1.16 RATED FLUX Rated flux is the neutron flux that corresponds to a steady state power level of 1930 1930 MW(t). Use of the term 100 percent also refers to the 1930 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 1.18 PROTECTIVE INSTRUMENTATION LOGIC DEFINITIONS A. Instrument Instrument Channel An instrument channel means an arrangement of a sensor and auxiliary equipment required to generate and transmit to a trip system a single trip signal related to the plant parameter monitored by that instrument channel.

B. Trip System B.

means an arrangement of instrument channel trip signals and auxiliary trip system means A trip equipment required to initiate action to accomplish a protective trip function. A trip equipment system may system may require one or more instrument channel trip signals related to one or more plant parameters plant parameters in in order to initiate trip system action. Initiation of protective action may the tripping of a single trip system (e.g., initiation of a core spray loop, automatic require the require isolation of an isolation condenser, offgas system isolation, reactor depressurization, isolation depressurization, building isolation, building isolation, standby gas treatment and rod block) or the coincident tripping of two two trip systems trip systems (e.g., initiation of scram, isolation condenser, reactor isolation, and primary (e.g., initiation isolation).

containment isolation).

containment CREEK OYSTER CREEK OYSTER 1.0-3 1.0-3 7, Amendment Change 7, Change Amendment No.: No.: 10, 10, 160, 160, 168, 211, 233, 168, 211, 233,

(3) At least four of the suppression chamber - drywell vacuum breakers shall be inspected.

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 the frequency specified in the Surveillance Frequency Control Program 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 4000 cfm.
3. When in Cold Shutdown condition, with the trunnion room door open after the secondary containment boundary has been moved to the penetrations inside the trunnion room and the trunnion room is isolated from the secondary containment in support of outage activities Standby Gas Treatment System testing shall be performed to demonstrate

"..j,", .._,", ... ,..,~ ,...~ the capabihty 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 4000 cfm.

34, A secondary containment capability test shall be conducted at each refueling 34.

outage prior to refueling.

45. 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 1.

demonstrated by:

a. At the frequency specified in the Surveillance Frequency Control Program, 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% 2':990/0 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 2':990/0 accordance with ANSI N510-1975.

N51 0-1 975.

OYSTER CREEK 4.5-4 Amendment No.: 144,186,193,219,276, 144,186,193,219,276,