ML061210471

License Amendment, Request to Change the Reactor Coolant System Leakage Detection Instrumentation Methodology

ML061210471
Person / Time
Site:	Callaway
Issue date:	05/16/2006
From:	Donohew J Plant Licensing Branch III-2
To:	Naslund C Union Electric Co
Donohew J N, NRR/DORL, 415-1307
References
TAC MC8220
Download: ML061210471 (4)

Text

May 16, 2006Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - LICENSE AMENDMENT REQUEST TOCHANGE THE REACTOR COOLANT SYSTEM LEAKAGE DETECTION INSTRUMENTATION METHODOLOGY (TAC NO. MC8220)

Dear Mr. Naslund:

In your license amendment request application dated August 26, 2005 (UL NRC-05197), youproposed to revise your commitment to Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," dated May 1973, in the Final Safety Analysis Report for the Callaway Plant. This revision would change the plant licensing basis to account for the containment atmosphere gaseous radioactivity monitor in Technical Specification (TS) 3.4.15, "RCS [Reactor Coolant System] Leakage Detection Instrumentation," not beingable to promptly detect a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at the levels of radioactivity that are currently normally present in the RCS. Because TS 3.4.16, "RCS Specific Activity," allowed plant operation at the RCS radioactivity levels where the containment atmosphere gaseousradioactivity monitor would be able to promptly detect a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the radioactivity monitor was not proposed to be removed from TS 3.4.15.On April 13, 2006, the basis for not removing the containment atmosphere gaseousradioactivity monitor (gaseous radmonitor) in TS 3.4.15 was discussed in a conference call with your staff. The other three instrumentations listed in TS 3.4.15, in addition to this monitor, are capable of promptly measuring a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for normal plant conditions and the gaseous radmonitor does not appear to be capable of doing this. This is also stated in your application dated August 26, 2005. Your staff did not explain in the call how the gaseousradioactivity monitor could promptly detect a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for normal plant conditions.RG 1.45 states that "in analyzing the sensitivity of leak detection systems using airborneparticulate or gaseous radioactivity, a realistic primary coolant radioactivity concentration assumption should be used" and a realistic concentration would be that which is currently normally expected to be present in the RCS coolant. Although RG 1.45 also states that thecoolant radioactivity concentration values in the plant environmental report would be acceptable as the realistic primary coolant radioactivity concentration, this statement would no longer be correct if the values in the plant environmental report are significantly higher than the valuesthat would be currently expected in the RCS coolant.It has always been the NRC's position that the instrumentation listed in TS 3.4.15 as a methodfor meeting Part 50, Appendix A, General Design Criterion (GDC) 30 of Title 10 of the Code ofFederal Regulations, "Quality of reactor coolant pressure boundary," should be capable ofdetecting a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for realistic or normal plant conditions. In the NRC C. Naslund- 2 -Standard Review Plan 5.2.5, "Reactor Coolant Pressure Boundary Leakage Detection," it isstated that RG 1.45 is an acceptable method to meet GDC 30 for RCS leak detection, and, in1973, when RG 1.45 was issued, the underlying assumption was that the acceptable detectionmethods would have that detection capability for the normal plant conditions that existed at thattime. The containment atmosphere gaseous radioactivity monitor was listed in RG 1.45 because the normal RCS radioactivity concentrations at that time were such that this monitor could detect a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Now that normal plant conditions have much lower RCS radioactivity concentrations, the monitor cannot meet this criterion. Therefore, the RCS detection instrumentation in TS 3.4.15 should be capable of promptly detecting RCSleakage for the current plant conditions.Because TS 3.4.15 defines the RCS leakage detection instrumentation being relied upon tomeet the criterion of detecting a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for normal plant conditions, we are requesting that you either provide justification that the containment gaseous radioactivitymonitor can meet this criterion or revise your amendment request dated August 26, 2005, to remove the containment gaseous radioactivity monitor from TS 3.4.15. We also request that you submit your response no later than June 30, 2006, so that we can complete our review in a timely manner.If you have any questions concerning this letter, you may contact me at (301) 415-1307, or viathe internet at jnd@nrc.gov

.Sincerely,/RA/Jack Donohew Senior Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-483 cc: See next page C. Naslund- 2 -Standard Review Plan 5.2.5, "Reactor Coolant Pressure Boundary Leakage Detection," it isstated that RG 1.45 is an acceptable method to meet GDC 30 for RCS leak detection, and, in1973, when RG 1.45 was issued, the underlying assumption was that the acceptable detectionmethods would have that detection capability for the normal plant conditions that existed at thattime. The containment atmosphere gaseous radioactivity monitor was listed in RG 1.45 because the normal RCS radioactivity concentrations at that time were such that this monitor could detect a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Now that normal plant conditions have much lower RCS radioactivity concentrations, the monitor cannot meet this criterion. Therefore, the RCS detection instrumentation in TS 3.4.15 should be capable of promptly detecting RCSleakage for the current plant conditions.Because TS 3.4.15 defines the RCS leakage detection instrumentation being relied upon tomeet the criterion of detecting a 1 gpm RCS leakrate in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for normal plant conditions, we are requesting that you either provide justification that the containment gaseous radioactivitymonitor can meet this criterion or revise your amendment request dated August 26, 2005, to remove the containment gaseous radioactivity monitor from TS 3.4.15. We also request that you submit your response no later than June 30, 2006, so that we can complete our review in a timely manner.If you have any questions concerning this letter, you may contact me at (301) 415-1307, or viathe internet at jnd@nrc.gov

.Sincerely,/RA/Jack Donohew Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-483cc: See next pageDISTRIBUTION:PUBLICLPLIV r/f RidsNrrDorl (CHaney/CHolden)RidsNrrDorlLpl4 (DTerao)

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