RS-09-179, Additional Information Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of Lsotope Test Assemblies

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Additional Information Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of Lsotope Test Assemblies
ML093510232
Person / Time
Site: Clinton Constellation icon.png
Issue date: 12/16/2009
From: Hansen J
Exelon Corp, Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-09-179
Download: ML093510232 (5)


Text

Exelon Generation 4300 Winfield Road Nuclear Warrenville, IL 60555 RS-09-179 10 CFR 50.90 December 16,2009 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Additional Information Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assemblies

References:

1. Letter from Mr. Jeffrey L. Hansen (Exelon Generation Company, LLC) to U. S. NRC, "License Amendment Request to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assernblies,"dated June 26, 2009
2. Letter from U. S. NRC to Mr. Charles G. Pardee (Exelon Generation Company, LLC), "Clinton Power Station, Unit No. 1 - Request for Additional lnformation Related to License Amendment Request to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assemblies (TAC No. ME1643)," dated November 2,2009 (ADAMS Accession No. ML093030218)
3. Letter from Mr. Jeffrey L. Hansen (Exelon Generation Company, LLC) to U. S. NRC, "Additional lnformation Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assemblies," dated November 20, 2009
4. Letter from Mr. Jeffrey L. Hansen (Exelon Generation Company, LLC) to U. S. NRC, "Additional lnformation Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assemblies," dated November 17, 2009 In Reference 1, Exelon Generation Company, LLC (EGC) requested an amendment to the facility operating license for Clinton Power Station (CPS), Unit 1. Specifically, the proposed change would modify CPS License Condition 2.8.(6) and create new License Conditions 1.J and 2.8.(7) as part of a pilot program to irradiate cobalt (Co)-59 targets to

December 16,2009 U. S. Nuclear Regulatory Commission Page 2 produce Co-60. In addition to the proposed license condition changes, EGC also requests an amendment to Appendix A, Technical Specifications (TS), of the CPS Facility Operating License. This proposed change would modify TS 4.2.1, "Fuel Assemblies," to describe the Isotope Test Assemblies (ITAs) being used. In Reference 2, the NRC requested that EGC provide additional information in support of their review of Reference 1. The NRC request for additional information and the specific EGC responses were provided in Reference 3.

On December 9,2009, EGC and the NRC conducted a conference call to discuss the responses provided in Reference 3 and some additional clarification of these responses were provided informally. During this conference call additional information was requested concerning the EGC response to RAI 2. This additional information is provided in the attachment to this letter.

EGC has reviewed the information supporting a finding of no significant hazards consideration that was provided to the NRC in Reference 4. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. No new regulatory commitments are established by this submittal.

If you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2804.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16'h day of December 2009.

ManageF Licensing Exelon Generation Company, LLC Attachments: Additional Information Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of Isotope Test Assemblies

ATTACHMENT Additional Information Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assemblies In Reference 1, Exelon Generation Company, LLC (EGC) provided responses to a request for additional information from the NRC in support of their review of a proposed license amendment request for Clinton Power Station (CPS), Unit 1 (Reference 2). In RAI 2 the NRC stated the following.

"Attachment 4, Section 4.3, "Evaluation of Design-Basis Accidents," of Reference 1 it states: The CPS Design-Basis Accidents (DBAs) to be evaluated are identified in Chapter 15.0 of the Clinton Power Station (CPS) Updated Safety Analysis Report (USAR). The Control Rod Drop Accident (CRDA), Main Steamline Break (MSLB) accident outside containment, Fuel Handling Accident (FHA), and Loss-of-Coolant Accident (LOCA) are licensed under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.67, "Accident Source Term," per Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors." In Reference 2, it states that the information needed includes a description of the analyses used to evaluate the impact of the proposed change on radiological consequences of DBAs in the CPS design bases. The proposed change only evaluates the impact on the DBAs described above. Please provide the information requested in Reference 2 for all DBAs in the CPS design bases or justify why this information is not needed."

EGC responded that in addition to the Design Basis Accidents (DBAs) analyzed in Reference 2, the CPS design bases include eight limiting fault accidents or DBAs.

These DBAs have been analyzed and were listed by Updated Safety Analysis Report (USAR) location. The response concluded that for each of the eight limiting fault accidents addressed in the Attachment to Reference 1, the radiological consequences are unchanged for a core operating with lsotope Test Assemblies (ITAs) for a DBA in which no fuel failures occur as a result of the event.

Following the review of this response by the NRC reviewer, additional clarification was requested concerning the evaluation of these 8 DBAs. The reviewer specifically requested that EGC (1) verify that the evaluation of these DBAs address the potential for failure of the isotope rods as well as fuel rods, and (2) identify the dose analysis licensing basis for these DBAs. The following provides the requested information.

Recirculation Pumrs Seizure (USAR 15.3.3)

The results of the CPS Recirculation Pump Seizure design basis radiological analysis concludes no fuel failures or isotope rod failures result due to the event. Therefore, the radiological consequences are unchanged for operation with ITAs. While the consequences of the events identified previously do not result in any fuel or isotope rod failures, radioactivity is nevertheless discharged to the suppression pool as a result of SRV activation. However, the mass input, and hence activity input, for this event is much less than those consequences evaluation for the Main Steam Line Isolation Valve Closure event (see USAR Section 15.2.4.5). Therefore, the radiological exposures noted in Section 15.2.4.5 cover the consequences of this event. The dose to personnel in unrestricted areas is shown to be within the limits of 10 CFR 20 applicable to CPS operation (as well as 10 CFR 50 and 40 CFR 190). These limits are more restrictive than 10 CFR 100 guidelines.

ATTACHMENT Additional Information Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of Isotope Test Assemblies Recirculation P u m Shaft

~ Break (USAR 15.3.4)

The results of the CPS Recirculation Pump Shaft Break design basis radiological analysis concludes no fuel failures or isotope rod failures result due to the event.

Therefore, the radiological consequences are unchanged for operation with ITAs. While the consequences of this event do not result in any fuel or isotope rod failures, radioactivity is nevertheless discharged to the suppression pool as a result of SRV activation. However, the mass input, and hence activity input, for this event is much less than those consequences identified in radiological consequences evaluation for the Main Steam Line Isolation Valve Closure event (see USAR Section 15.2.4.5). Therefore, the radiological exposures noted in Section 15.2.4.5 cover the consequences of this event.

The dose to personnel in unrestricted areas is shown to be within the limits of 10 CFR 20 applicable to CPS operation (as well as 10 CFR 50 and 40 CFR 190). These limits are more restrictive than 10 CFR 100 guidelines.

Feedwater Line Break Outside Containment (USAR 15.6.61 The results of the CPS Feedwater Line Break Outside Containment radiological analysis concludes no fuel failures or isotope rod failures result due to the event. Therefore, the radiological consequences are unchanged for operation with ITAs. The calculated exposures for the realistic analysis are a small fraction of 10 CFR 100 guidelines.

Main Condenser Offaas Treatment Svstem Failure (USAR 15.7.1.1)

The CPS Main Condenser Offgas Treatment System Failure design basis radiological analysis is based on a 100,000 ~Cilsecafter 30 minutes delay noble gas source term.

Particulates such as cobalt have no effect on the accident consequences. Therefore, the radiological consequences are unchanged for operation with ITAs. This design basis accident was evaluated against the guidelines of 10 CFR 100.

Malfunction of Main Turbine Gland Sealina Svstem (USAR 15.7.1.2)

The CPS Malfunction of Main Turbine Gland Sealing System design basis accident occurs outside the containment and does not involve any barrier integrity aspects including isotope rod failures. Therefore, the radiological consequences are unchanged for operation with ITAs. This accident was evaluated against the guidelines of 10 CFR 100.

Failure of Main Turbine Steam Air Eiector Lines (USAR 15.7.1.3)

The CPS Failure of Main Turbine Steam Air Ejector Lines design basis accident analysis concludes there is no radiological release due to the event. Therefore, the radiological consequences are unchanged for operation with ITAs. Since there is no release as a result of this event, there is no evaluation against the requirements of 10 CFR 100 or 10 CFR 50.67.

Liquid Radwaste Tank Failure (USAR 15.7.3)

The CPS Liquid Radwaste Tank Failure design basis accident analysis is based on a 100,000 ~Cilsecafter 30 minutes delay noble gas source term. Particulates such as cobalt have no effect on the accident consequences. Therefore, the radiological

ATTACHMENT Additional lnformation Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assemblies consequences are unchanged for operation with ITAs. This accident was evaluated against the guidelines of 10 CFR 100.

Cask Droo Accident (USAR 15.7.51 The CPS Cask Drop Accident analysis determined that a dropped cask would not rupture, and no radiological release is associated with this event. Therefore, the radiological consequences are unchanged for operation with ITAs. Since there is no radiological release as a result of this event, there is no evaluation against the requirements of 10 CFR 100 or 10 CFR 50.67.

The Control Rod Drop Accident, Main Steam Line Break Accident, Fuel Handling Accident, and Loss of Coolant Accident were analyzed under the Alternative Source Term methodology and therefore, are evaluated against the requirements of 10 CFR 50.67.

References:

1. Letter from Mr. Jeffrey L. Hansen (Exelon Generation Company, LLC) to U. S.

NRC, "Additional lnformation Supporting the Request for a License Amendment to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assemblies," dated November 20, 2009

2. Letter from Mr. Jeffrey L. Hansen (Exelon Generation Company, LLC) to U. S.

NRC, "License Amendment Request to Modify Clinton Power Station Facility Operating License in Support of the Use of lsotope Test Assemblies," dated June 26,2009