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| | number = ML16278A077 | | | number = ML16278A077 |
| | issue date = 11/07/2016 | | | issue date = 11/07/2016 |
| | title = R.E. Ginna Nuclear Power Plant - Request for Additional Information Regarding: Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specifications (CAC No. MF7339) | | | title = Request for Additional Information Regarding: Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specifications |
| | author name = Mozafari B | | | author name = Mozafari B |
| | author affiliation = NRC/NRR/DORL/LPLI-1 | | | author affiliation = NRC/NRR/DORL/LPLI-1 |
| | addressee name = Hanson B C | | | addressee name = Hanson B |
| | addressee affiliation = Exelon Nuclear | | | addressee affiliation = Exelon Nuclear |
| | docket = 05000244 | | | docket = 05000244 |
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| | page count = 4 | | | page count = 4 |
| | project = CAC:MF7339 | | | project = CAC:MF7339 |
| | stage = | | | stage = RAI |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear R. E. Ginna Nuclear Power Plant 4300 Winfield Road Warrenville, IL 60555 November 7, 2016 SUBJECT: RE. GINNA NUCLEAR POWER PLANT -REQUEST FOR ADDITIONAL INFORMATION REGARDING: DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATIONS (CAC NO. MF7339) Dear Mr. Hanson: By application dated February 4, 2016, as supplemented by letters dated April 14 and June 28, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Numbers ML 16035A015, ML 16105A243, and ML 16180A448, respectively), Exelon Generation Company, LLC, the licensee, propose changes to R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications (TSs). The license amendment would revise Ginna's TS Reactor Coolant System (RCS) specific activity definition and associated surveillance requirements. The proposed changes would replace the current TS limit for RCS gross specific activity with a new limit for RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent Xenon-133 definition that would replace the current E-Bar average disintegration energy definition. The changes are consistent with Technical Specification Task Force (TSTF) Standard Technical Specification Traveler, TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec." The Nuclear Regulatory Commission staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). We understand that you plan to respond to the enclosed RAI within 30 days of the date of this letter. | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 7, 2016 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear R. E. Ginna Nuclear Power Plant 4300 Winfield Road Warrenville, IL 60555 |
| B. Hanson -2 -Please contact me at (301) 415-2020 if you have any questions on this issue. Docket No. 50-244 Enclosure: As stated cc w/encl: Distribution via Listserv Brenda Mozafari, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION REGARDING DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATIONS R. E. GINNA NUCLEAR POWER PLANT. LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-244 R. E. GINNA NUCLEAR POWER PLANT By letter dated February 4, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML 16035A015), Exelon Generation Company, LLC the licensee, proposes changes to the R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications (TSs). The licensee's amendment would revise Ginna's TS Reactor Coolant System (RCS) Specific Activity definition and associated surveillance requirements. The proposed changes would replace the current TS limit for RCS gross specific activity with a new limit for RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent Xenon-133 definition that would replace the current E-Bar (E) average disintegration energy definition. The changes are consistent with Technical Specification Task Force (TSTF) Standard Technical Specification Traveler, TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec." During the Nuclear Regulatory Commission (NRC) staff's review of the impact of implementing TSTF-490 the NRC staff determined that more information was needed to complete the review. The NRC staff requested the licensee provide additional justification for the proposed change to increase the Completion Time of Required Action B.1 to 48 hours and why it is acceptable to be in an unanalyzed condition for 48 hours (ADAMS accession Number ML 16075A119). On April 14, 2016, the licensee responded to the NRC staff's request and on June 28, 2016, submitted a supplement to its response (ADAMS Accession Numbers ML 16105A243 and ML 16180A448). The licensee's response provided a sensitivity analysis that varied dose equivalent Xenon-133 (DEX). The sensitivity analysis concluded that the DEX necessary to challenge the limits within Title 1 O of the Code of Federal Regulations (1 O CFR) Part 50, Section 50.67, is substantially greater than the proposed DEX TS limit, and without further dose equivalent lodine-131 spiking, would require more than 100 percent of fuel rods to be failed. This analysis was performed specifically for the steam generator tube rupture and main steam link break accidents. The NRC staff has reviewed the licensee's response and has determined that the sensitivity analysis is not complete because it lacks an evaluation of the failure of small lines carrying primary coolant outside containment comparison to the 1 O CFR 100 limits. Enclosure | | |
| -2 -Ginna's updated final safety analysis report (UFSAR) Section 9.3.4.4.6.1, "Suction Lines," states: Under SEP Topic XV-16, RG&E reviewed the radiological consequences of failure of small lines carrying primary coolant outside containment. The case break was taken to be the chemical and volume control system letdown line break, with a break flow, rate of 60 gpm, and the assumption that the flash fraction of fission products contained in the leaked coolant was released. Assuming a previous iodine spike, the primary coolant activity was set at 60 µCi/g lodine-131 dose equivalent. After a 20-min delay, operator action to isolate the break was assumed, based on available information such as volume control tank level, letdown line flow and pressure, and radiation monitors in the auxiliary building. The conclusion of this review, confirmed by an independent review by the NRC, was that the offsite radiological consequences are 1 rem whole body and 12 rem thyroid, a small fraction of the 10 CFR 100 guidelines. Ginna's UFSAR Section 15.6.2, "Radiological Consequences of Small Lines Carrying Primary Coolant outside Containment," states: An analysis was conducted by the NRC under the Systematic Evaluation Program (Topic XV-16), to ensure that any release of radioactivity from a postulated failure of small lines carrying primary coolant outside containment would result in limited exposure, well within 10 CFR 100 exposure guidelines. The doses calculated by the NRC (Reference 2) were 12 rem thyroid and 1 rem whole body which were below 10% of the 10 CFR 100 exposure guidelines. A review of Ginna's updated final safety analysis report appears to show that the failure of small lines carrying coolant outside containment is part of Ginna's current licensing basis. The NRC staff notes that further review determined that an alternative source term was not implemented for this failure analysis. Therefore, the failure of small lines carrying coolant outside containment utilizes Ginna's original license source term and the doses calculated must continue to remain below 10 percent of the thyroid and whole body doses stated 10 CFR 100, as stated in Standard Review Plan 15.6.2, "Radiological Consequences of the Failure of Small Lines Carrying Primary Coolant outside Containment." ARCB-RAI The NRC staff is requesting that the licensee please provide a sensitivity analysis similar to that provided for the steam generator tube rupture and main steam link break accidents in letter dated June 28, 2016, that discusses the radiological consequences of the failure of small lines carrying primary coolant outside containment for the proposed change to increase the TS Completion Time of Required Action B.1 from 8 hours to 48 hours; or explain why the discussion provided in UFSAR sections 9.3.4.4.6.1 and 15.6.2 do not apply to this license amendment request.
| | ==SUBJECT:== |
| B. Hanson -2 -Please contact me at (301) 415-2020 if you have any questions on this issue. Docket No. 50-244 Enclosure: As stated cc w/encl: Distribution via Listserv DISTRIBUTION: Sincerely, IRA/ Brenda Mozafari, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation PUBLIC LPL 1-1 R/F RidsNrrDorlLpl1-1 Resource RidsNrrPMREGinna Resource KBucholtz, NRR RidsNrrDorlDpr Resource RidsACRS_MailCTR Resource RidsNrrLAKGoldstein Resource RidsRgn1 MailCenter Resource ADAM s Accession No.: ML 16278A077 *b *1 1yema1 OFFICE LPL 1-1/PM LPL 1-1/LA DRA/ARCB NAME BMozafari KGoldstein* UShoop* DATE 10/05/16 10/05/16 10/03/16 OFFICIAL RECORD COPY BMozafari, NRR RidsNrrDraArcb Resource LPL 1-1/BC(A) LPL 1-1/PM DPickett BMozafari 11/07/16 11/07/16 | | RE. GINNA NUCLEAR POWER PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING: DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATIONS (CAC NO. MF7339) |
| }} | | |
| | ==Dear Mr. Hanson:== |
| | |
| | By application dated February 4, 2016, as supplemented by letters dated April 14 and June 28, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Numbers ML16035A015, ML16105A243, and ML16180A448, respectively), Exelon Generation Company, LLC, the licensee, propose changes to R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications (TSs). The license amendment would revise Ginna's TS Reactor Coolant System (RCS) specific activity definition and associated surveillance requirements. The proposed changes would replace the current TS limit for RCS gross specific activity with a new limit for RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent Xenon-133 definition that would replace the current E-Bar average disintegration energy definition. The changes are consistent with Technical Specification Task Force (TSTF) Standard Technical Specification Traveler, TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec." |
| | The Nuclear Regulatory Commission staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). We understand that you plan to respond to the enclosed RAI within 30 days of the date of this letter. |
| | |
| | B. Hanson Please contact me at (301) 415-2020 if you have any questions on this issue. |
| | Brenda Mozafari, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244 |
| | |
| | ==Enclosure:== |
| | |
| | As stated cc w/encl: Distribution via Listserv |
| | |
| | REQUEST FOR ADDITIONAL INFORMATION REGARDING DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATIONS R. E. GINNA NUCLEAR POWER PLANT. LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-244 R. E. GINNA NUCLEAR POWER PLANT By letter dated February 4, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML16035A015), Exelon Generation Company, LLC the licensee, proposes changes to the R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications (TSs). The licensee's amendment would revise Ginna's TS Reactor Coolant System (RCS) |
| | Specific Activity definition and associated surveillance requirements. The proposed changes would replace the current TS limit for RCS gross specific activity with a new limit for RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent Xenon-133 definition that would replace the current E-Bar (E) average disintegration energy definition. The changes are consistent with Technical Specification Task Force (TSTF) |
| | Standard Technical Specification Traveler, TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec." |
| | During the Nuclear Regulatory Commission (NRC) staff's review of the impact of implementing TSTF-490 the NRC staff determined that more information was needed to complete the review. |
| | The NRC staff requested the licensee provide additional justification for the proposed change to increase the Completion Time of Required Action B.1 to 48 hours and why it is acceptable to be in an unanalyzed condition for 48 hours (ADAMS accession Number ML16075A119). On April 14, 2016, the licensee responded to the NRC staff's request and on June 28, 2016, submitted a supplement to its response (ADAMS Accession Numbers ML16105A243 and ML16180A448). |
| | The licensee's response provided a sensitivity analysis that varied dose equivalent Xenon-133 (DEX). The sensitivity analysis concluded that the DEX necessary to challenge the limits within Title 1O of the Code of Federal Regulations (1 O CFR) Part 50, Section 50.67, is substantially greater than the proposed DEX TS limit, and without further dose equivalent lodine-131 spiking, would require more than 100 percent of fuel rods to be failed. This analysis was performed specifically for the steam generator tube rupture and main steam link break accidents. The NRC staff has reviewed the licensee's response and has determined that the sensitivity analysis is not complete because it lacks an evaluation of the failure of small lines carrying primary coolant outside containment comparison to the 10 CFR 100 limits. |
| | Enclosure |
| | |
| | Ginna's updated final safety analysis report (UFSAR) Section 9.3.4.4.6.1, "Suction Lines," |
| | states: |
| | Under SEP Topic XV-16, RG&E reviewed the radiological consequences of failure of small lines carrying primary coolant outside containment. The worst-case break was taken to be the chemical and volume control system letdown line break, with a break flow, rate of 60 gpm, and the assumption that the flash fraction of fission products contained in the leaked coolant was released. |
| | Assuming a previous iodine spike, the primary coolant activity was set at 60 |
| | µCi/g lodine-131 dose equivalent. After a 20-min delay, operator action to isolate the break was assumed, based on available information such as volume control tank level, letdown line flow and pressure, and radiation monitors in the auxiliary building. The conclusion of this review, confirmed by an independent review by the NRC, was that the offsite radiological consequences are 1 rem whole body and 12 rem thyroid, a small fraction of the 10 CFR 100 guidelines. |
| | Ginna's UFSAR Section 15.6.2, "Radiological Consequences of Small Lines Carrying Primary Coolant outside Containment," states: |
| | An analysis was conducted by the NRC under the Systematic Evaluation Program (Topic XV-16), to ensure that any release of radioactivity from a postulated failure of small lines carrying primary coolant outside containment would result in limited exposure, well within 10 CFR 100 exposure guidelines. |
| | The doses calculated by the NRC (Reference 2) were 12 rem thyroid and 1 rem whole body which were below 10% of the 10 CFR 100 exposure guidelines. |
| | A review of Ginna's updated final safety analysis report appears to show that the failure of small lines carrying coolant outside containment is part of Ginna's current licensing basis. The NRC staff notes that further review determined that an alternative source term was not implemented for this failure analysis. Therefore, the failure of small lines carrying coolant outside containment utilizes Ginna's original license source term and the doses calculated must continue to remain below 10 percent of the thyroid and whole body doses stated 10 CFR 100, as stated in Standard Review Plan 15.6.2, "Radiological Consequences of the Failure of Small Lines Carrying Primary Coolant outside Containment." |
| | ARCB-RAI The NRC staff is requesting that the licensee please provide a sensitivity analysis similar to that provided for the steam generator tube rupture and main steam link break accidents in letter dated June 28, 2016, that discusses the radiological consequences of the failure of small lines carrying primary coolant outside containment for the proposed change to increase the TS Completion Time of Required Action B.1 from 8 hours to 48 hours; or explain why the discussion provided in UFSAR sections 9.3.4.4.6.1 and 15.6.2 do not apply to this license amendment request. |
| | |
| | B. Hanson Please contact me at (301) 415-2020 if you have any questions on this issue. |
| | Sincerely, IRA/ |
| | Brenda Mozafari, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244 |
| | |
| | ==Enclosure:== |
| | |
| | As stated cc w/encl: Distribution via Listserv DISTRIBUTION: |
| | PUBLIC LPL 1-1 R/F RidsNrrDorlLpl1-1 Resource RidsNrrPMREGinna Resource RidsNrrDorlDpr Resource RidsACRS_MailCTR Resource KBucholtz, NRR RidsNrrLAKGoldstein Resource RidsRgn1 MailCenter Resource BMozafari, NRR RidsNrrDraArcb Resource ADAM s Accession No.: ML16278A077 *b1yema1*1 OFFICE LPL 1-1/PM LPL 1-1/LA DRA/ARCB LPL 1-1/BC(A) LPL 1-1/PM NAME BMozafari KGoldstein* UShoop* DPickett BMozafari DATE 10/05/16 10/05/16 10/03/16 11/07/16 11/07/16 OFFICIAL RECORD COPY}} |
Letter Sequence RAI |
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|
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MONTHYEARML16035A0152016-02-0404 February 2016 Application to Revise Technical Specifications to Adopt TSTF-490, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec. Project stage: Request ML16053A1272016-03-0303 March 2016 Acceptance of Requested Licensing Action Application to Review Technical Specifications to Adopt TSTF-490 Project stage: Acceptance Review ML16075A1192016-03-17017 March 2016 Request for Additional Information Regarding: Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specifications Project stage: RAI ML16180A4482016-06-28028 June 2016 Supplement to Response to Request for Additional Information for the Review of TSTF-490, Deletion of E-Bar Definition and Revision to RCS Specific Activity Tech Spec Project stage: Supplement ML16279A3812016-10-0505 October 2016 NRR E-mail Capture - Ginna Nuclear Power Plant - Request for Additional Information Regarding: Deletion of E BAR Definition and Revision to Reactor Coolant System Specific Activity Technical Specifications Project stage: RAI ML16278A0772016-11-0707 November 2016 Request for Additional Information Regarding: Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specifications Project stage: RAI ML16336A0482016-11-30030 November 2016 Response to Request for Additional Information for the Review of TSTF-490, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec. Project stage: Response to RAI ML16358A4242017-02-0909 February 2017 R. E. Ginna Nuclear Power Plant - Issuance of Amendment to Adopt TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec Project stage: Approval 2016-02-04
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[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML24197A0162024-07-12012 July 2024 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-591 ML24073A3602024-03-13013 March 2024 Request for Additional Information (RAI) Alternative Request PR-03 Sixth Interval Inservice Testing Program ML23312A1302023-11-0707 November 2023 Final Rci/Rai - Constellation – R. E. Ginna Nuclear Power Plant - Exemption from Security Rule (EPID L-2023-LLE-0029) (Email) ML22160A3962022-06-0909 June 2022 R. E. Ginna Nuclear Power Plant, LLC - Request for Information for a Biennial Problem Identification and Resolution Inspection; Inspection Report 05000244/2022010 ML22271A0772022-05-0606 May 2022 NRR E-mail Capture - Final RAIs 9.1.2021 Constellation Relief Request ML22129A0132022-05-0606 May 2022 NRR E-mail Capture - Draft RAIs for Requests for Alternatives I4R-17, I4R-23, ISI-05-018, I6R-10 ML22041B5362022-02-10010 February 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541 ML21308A5592021-11-0404 November 2021 NRR E-mail Capture - NRC Request for Additional Information for Ginna Biennial EP Exercise Exemption Request ML21256A1902021-09-10010 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21189A1602021-07-0808 July 2021 NRR E-mail Capture - Request for Additional Information - Braidwood, Byron, and Ginna - Amendment to Address the Issues in Westinghouse NSALs ML21144A2132021-05-24024 May 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21119A1082021-04-27027 April 2021 Ti 2515/194 Inspection Documentation Request ML21076A5152021-03-17017 March 2021 R. E. Ginna Nuclear Power Plant - RAI Steam Generator LAR to Revise Technical Specifications for Steam Generator Tube Inspection Frequency (EPID L-2020-LLA-0207) (e-mail) ML21062A0652021-03-0101 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21049A2572021-02-18018 February 2021 Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237) ML21029A3302021-01-29029 January 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Fleet Alternative Request to Use ASME Code Case N-885 ML20357A2232020-12-17017 December 2020 Update on Ginna POV - 3504A and 4562 (Email Request for Inspection Information) ML20218A6422020-08-0505 August 2020 R. E. Ginna Nuclear Power Plant - Request for Additional Information (RAI) for LAR to Implement WCAP, TSTF-411, and TSTF-418 ML20153A7042020-06-0101 June 2020 NRR E-mail Capture - Preliminary RAI for Fleet Request to Use Alternative OMN-26 ML19120A3862019-04-30030 April 2019 Request for Additional Information to Revise Emergency Plan Response Organization Staffing and Augmentation ML18228A5242018-08-15015 August 2018 R. E. Ginna Nuclear Power Plant - TSTF 547 Adoption, Request for Additional Information (RAI) EPID L-2018-LLA-0179 ML18102A2372018-04-12012 April 2018 NRR E-mail Capture - Calvert Cliffs, Ginna, and Nine Mile Point - Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Schemes (EPID-L-2017-LLA-0237) ML18067A1482018-03-0808 March 2018 Enclosurequest for Additional Information (Letter to P. R. Simpson Request for Additional Information Regarding Exelon Generating Company, Llc'S Decommissioning Funding Plan Update for Independent Spent Fuel Storage Installation) ML17331B1342017-12-12012 December 2017 2, and R.E. Ginna Nuclear Power Plant - Request for Additional Information - Regarding ML17277A2052017-10-0202 October 2017 Email - Ginna: Request for Additional Information (RAI) for NFPA-805 LAR RS-17-026, Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 3, Flooding Focused Evaluation Summary Submittal2017-03-10010 March 2017 Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 3, Flooding Focused Evaluation Summary Submittal ML17062A4912017-03-0303 March 2017 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Fleet Alternative to RPV Threads in Flange Examination (CAC Nos. MF8712-MF8729) ML16278A0772016-11-0707 November 2016 Request for Additional Information Regarding: Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specifications ML16075A1192016-03-17017 March 2016 Request for Additional Information Regarding: Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specifications ML16077A1082016-03-17017 March 2016 NRR E-mail Capture - (External_Sender) Email Clarification and Supplementation to AMP RAI ML15349B0252016-01-0707 January 2016 Request for Additional Information Regarding Reactor Vessels Internals Program ML15344A3532016-01-0707 January 2016 Request for Additional Information Regarding Risk-Informed Technical Specifications Initiative 5B CAC No. MF6358) ML15100A2112015-04-28028 April 2015 RAI Regarding License Amendment Request to Adopt Technical Specification Task Force Traveler-523 ML14093A6772014-05-0101 May 2014 SONGS - Request for Additional Information Concerning Pre-Emption Authority ML13337A6252013-12-0505 December 2013 Constellation Energy Nuclear Group, R.E. Ginna Nuclear Power Plant, Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instru ML13337A3902013-12-0505 December 2013 Request for Additional Information Regarding Order Approving Direct Transfer of Renewed Facility Operating License and Conforming Amendments ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13261A0612013-09-24024 September 2013 R. E. Ginna Nuclear Power Plant - Request for Additional Information Regarding Amendment to Revise Technical Specification 3.6.5. Containment Air Temperature. ML13261A1142013-09-12012 September 2013 R. E. Ginna Nuclear Power Plant, E-mail Re. NFPA 805 License Amendment Request, Audit RAIs ML13226A3822013-08-29029 August 2013 Request for Additional Information Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051) ML13108A0682013-04-23023 April 2013 (Security Related) Request for Additional Information for Review of Security Plan Changes in Revision 5 ML12264A6192012-09-20020 September 2012 RAI for the CRDM Nozzle Examination Relief Request ML12234A5172012-08-21021 August 2012 Physical Security Plan Change Per 10 CFR 50.54(p)(2) ML12228A6182012-08-15015 August 2012 Re_ Ginna-BMI Flaw Evaluation(ME8247) ML12178A1922012-06-25025 June 2012 Gina_ TAC Nos. ME8000 and ME8001-Relief Ginna Relief Request ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness 2024-07-12
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 7, 2016 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear R. E. Ginna Nuclear Power Plant 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
RE. GINNA NUCLEAR POWER PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING: DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATIONS (CAC NO. MF7339)
Dear Mr. Hanson:
By application dated February 4, 2016, as supplemented by letters dated April 14 and June 28, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Numbers ML16035A015, ML16105A243, and ML16180A448, respectively), Exelon Generation Company, LLC, the licensee, propose changes to R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications (TSs). The license amendment would revise Ginna's TS Reactor Coolant System (RCS) specific activity definition and associated surveillance requirements. The proposed changes would replace the current TS limit for RCS gross specific activity with a new limit for RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent Xenon-133 definition that would replace the current E-Bar average disintegration energy definition. The changes are consistent with Technical Specification Task Force (TSTF) Standard Technical Specification Traveler, TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec."
The Nuclear Regulatory Commission staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). We understand that you plan to respond to the enclosed RAI within 30 days of the date of this letter.
B. Hanson Please contact me at (301) 415-2020 if you have any questions on this issue.
Brenda Mozafari, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
As stated cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION REGARDING DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATIONS R. E. GINNA NUCLEAR POWER PLANT. LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-244 R. E. GINNA NUCLEAR POWER PLANT By letter dated February 4, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML16035A015), Exelon Generation Company, LLC the licensee, proposes changes to the R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications (TSs). The licensee's amendment would revise Ginna's TS Reactor Coolant System (RCS)
Specific Activity definition and associated surveillance requirements. The proposed changes would replace the current TS limit for RCS gross specific activity with a new limit for RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent Xenon-133 definition that would replace the current E-Bar (E) average disintegration energy definition. The changes are consistent with Technical Specification Task Force (TSTF)
Standard Technical Specification Traveler, TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec."
During the Nuclear Regulatory Commission (NRC) staff's review of the impact of implementing TSTF-490 the NRC staff determined that more information was needed to complete the review.
The NRC staff requested the licensee provide additional justification for the proposed change to increase the Completion Time of Required Action B.1 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and why it is acceptable to be in an unanalyzed condition for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (ADAMS accession Number ML16075A119). On April 14, 2016, the licensee responded to the NRC staff's request and on June 28, 2016, submitted a supplement to its response (ADAMS Accession Numbers ML16105A243 and ML16180A448).
The licensee's response provided a sensitivity analysis that varied dose equivalent Xenon-133 (DEX). The sensitivity analysis concluded that the DEX necessary to challenge the limits within Title 1O of the Code of Federal Regulations (1 O CFR) Part 50, Section 50.67, is substantially greater than the proposed DEX TS limit, and without further dose equivalent lodine-131 spiking, would require more than 100 percent of fuel rods to be failed. This analysis was performed specifically for the steam generator tube rupture and main steam link break accidents. The NRC staff has reviewed the licensee's response and has determined that the sensitivity analysis is not complete because it lacks an evaluation of the failure of small lines carrying primary coolant outside containment comparison to the 10 CFR 100 limits.
Enclosure
Ginna's updated final safety analysis report (UFSAR) Section 9.3.4.4.6.1, "Suction Lines,"
states:
Under SEP Topic XV-16, RG&E reviewed the radiological consequences of failure of small lines carrying primary coolant outside containment. The worst-case break was taken to be the chemical and volume control system letdown line break, with a break flow, rate of 60 gpm, and the assumption that the flash fraction of fission products contained in the leaked coolant was released.
Assuming a previous iodine spike, the primary coolant activity was set at 60
µCi/g lodine-131 dose equivalent. After a 20-min delay, operator action to isolate the break was assumed, based on available information such as volume control tank level, letdown line flow and pressure, and radiation monitors in the auxiliary building. The conclusion of this review, confirmed by an independent review by the NRC, was that the offsite radiological consequences are 1 rem whole body and 12 rem thyroid, a small fraction of the 10 CFR 100 guidelines.
Ginna's UFSAR Section 15.6.2, "Radiological Consequences of Small Lines Carrying Primary Coolant outside Containment," states:
An analysis was conducted by the NRC under the Systematic Evaluation Program (Topic XV-16), to ensure that any release of radioactivity from a postulated failure of small lines carrying primary coolant outside containment would result in limited exposure, well within 10 CFR 100 exposure guidelines.
The doses calculated by the NRC (Reference 2) were 12 rem thyroid and 1 rem whole body which were below 10% of the 10 CFR 100 exposure guidelines.
A review of Ginna's updated final safety analysis report appears to show that the failure of small lines carrying coolant outside containment is part of Ginna's current licensing basis. The NRC staff notes that further review determined that an alternative source term was not implemented for this failure analysis. Therefore, the failure of small lines carrying coolant outside containment utilizes Ginna's original license source term and the doses calculated must continue to remain below 10 percent of the thyroid and whole body doses stated 10 CFR 100, as stated in Standard Review Plan 15.6.2, "Radiological Consequences of the Failure of Small Lines Carrying Primary Coolant outside Containment."
ARCB-RAI The NRC staff is requesting that the licensee please provide a sensitivity analysis similar to that provided for the steam generator tube rupture and main steam link break accidents in letter dated June 28, 2016, that discusses the radiological consequences of the failure of small lines carrying primary coolant outside containment for the proposed change to increase the TS Completion Time of Required Action B.1 from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />; or explain why the discussion provided in UFSAR sections 9.3.4.4.6.1 and 15.6.2 do not apply to this license amendment request.
B. Hanson Please contact me at (301) 415-2020 if you have any questions on this issue.
Sincerely, IRA/
Brenda Mozafari, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL 1-1 R/F RidsNrrDorlLpl1-1 Resource RidsNrrPMREGinna Resource RidsNrrDorlDpr Resource RidsACRS_MailCTR Resource KBucholtz, NRR RidsNrrLAKGoldstein Resource RidsRgn1 MailCenter Resource BMozafari, NRR RidsNrrDraArcb Resource ADAM s Accession No.: ML16278A077 *b1yema1*1 OFFICE LPL 1-1/PM LPL 1-1/LA DRA/ARCB LPL 1-1/BC(A) LPL 1-1/PM NAME BMozafari KGoldstein* UShoop* DPickett BMozafari DATE 10/05/16 10/05/16 10/03/16 11/07/16 11/07/16 OFFICIAL RECORD COPY