ML060610286

License Amendment 17 Regarding Revision of Secondary Containment Bypass Leakage Surveillance Requirement

ML060610286
Person / Time
Site:	Clinton
Issue date:	03/21/2006
From:	Jabbour K Plant Licensing Branch III-2
To:	Crane C AmerGen Energy Co
Jabbour K, NRR/DLPM, 415-1496
Shared Package
ML060610305	List: ML060610286
References
TAC MC6488
Download: ML060610286 (11)

Text

March 21, 2006Mr. Christopher M. Crane, President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, Illinois 60555

SUBJECT:

CLINTON POWER STATION, UNIT 1 - ISSUANCE OF AMENDMENT - RE: REVISION OF SECONDARY CONTAINMENT BYPASS LEAKAGE SURVEILLANCE REQUIREMENT (TAC NO. MC6488)

Dear Mr. Crane:

The Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 173 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit 1. Theamendment is in response to your application dated March 25, 2005.The amendment revises Technical Specification Surveillance Requirement (SR) 3.6.1.3.8 to exclude the containment purge valve leakage rates from the summation of secondary containment bypass leakage rates.A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's next biweekly Federal Register notice.Sincerely,/RA/Kahtan N. Jabbour, Senior Project ManagerPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-461

Enclosures:

1. Amendment No. 173 to NPF-62

2. Safety Evaluationcc w/encls: See next page Mr. Christopher M. Crane, PresidentMarch 21, 2006 and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, Illinois 60555

SUBJECT:

CLINTON POWER STATION, UNIT 1 - ISSUANCE OF AMENDMENT - RE: REVISION OF SECONDARY CONTAINMENT BYPASS LEAKAGE SURVEILLANCE REQUIREMENT (TAC NO. MC6488)

Dear Mr. Crane:

The Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 173 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit 1. Theamendment is in response to your application dated March 25, 2005.The amendment revises Technical Specification Surveillance Requirement (SR) 3.6.1.3.8 to exclude the containment purge valve leakage rates from the summation of secondary containment bypass leakage rates.A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's next biweekly Federal Register notice.Sincerely,/RA/Kahtan N. Jabbour, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-461

Enclosures:

1. Amendment No. 173 to NPF-62

2. Safety Evaluationcc w/encls: See next page DISTRIBUTION

PUBLICLPLIII-2 R/FGHill (2) RidsAcrsAcnwMailCenterRidsOgcRpRidsNrrLADClarke RidsNrrPMKJabbourRidsRgn3MailCenterRidsNrrDirsItsbDORL DPRRidsNrrDorlLplfRidsNrrDraAcvb JPulsipherRidsNrrCHarbuck TWengertRidsNRRMHartPackage: ML060610305Amendment: ML060610286 Tech Spec Page: ML061040207OFFICELPLIII-2/PMLPLIII-2/PELPLIII-2/LADRA/ACVB/BCNAMEKJabbourTWengertDClarkeRDennigDATE3/13/063/13/063/13/063/20/06OFFICEITSB/BCOGCLPLIII-2/BC(A)NAMETBoyceAHodgdonDCollins(EHackett for)DATE3/17/063/17/063/20/06OFFICIAL RECORD COPY AMERGEN ENERGY COMPANY, LLCDOCKET NO. 50-461CLINTON POWER STATION, UNIT 1AMENDMENT TO FACILITY OPERATING LICENSEAmendment No.173License No. NPF-621.The U.S. Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by AmerGen Energy Company, LLC (thelicensee), dated March 25, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 2.C.(2) of FacilityOperating License No. NPF-62 is hereby amended to read as follows: (2)Technical Specifications and Environmental Protection PlanThe Technical Specifications contained in Appendix A and the EnvironmentalProtection Plan contained in Appendix B, as revised through Amendment No.173 are hereby incorporated into this license. The licensee shall operate the facilityin accordance with the Technical Specifications and the Environmental Protection Plan.3.This license amendment is effective as of its date of issuance and shall be implementedwithin 60 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA by E.Hackett for/Daniel S. Collins, ChiefPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical SpecificationsDate of Issuance: March 21, 2006 ATTACHMENT TO LICENSE AMENDMENT NO. 173 FACILITY OPERATING LICENSE NO. NPF-62DOCKET NO. 50-461Replace the following page of Appendix "A," Technical Specifications, with the attached revisedpage. The revised page is identified by an amendment number and contains a marginal line indicating the area of change. Remove PageInsert Page3.6-193.6-19 Clinton Power Station, Unit 1 cc:

Senior Vice President of OperationsAmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 110 East Adams Street Springfield, IL 62701-1109Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Manager Licensing - Dresden, Quad Cities, and ClintonAmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Regulatory Assurance Manager - ClintonAmerGen Energy Company, LLC Clinton Power Station RR3, Box 228 Clinton, IL 61727-9351Director - Licensing and Regulatory AffairsAmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Document Control Desk - LicensingAmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Site Vice President - Clinton Power StationAmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351Clinton Power Station Plant M anagerAmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351Resident InspectorU.S. Nuclear Regulatory Commission RR #3, Box 229A Clinton, IL 61727Regional Administrator, Region IIIU.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville RoadLisle, IL 60532-4351Assistant General CounselExelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348R. T. HillLicensing Services Manager General Electric Company 175 Curtner Avenue, M/C 481 San Jose, CA 95125Chairman of DeWitt Countyc/o County Clerk's Office DeWitt County Courthouse Clinton, IL 61727J. W. BlattnerProject Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago, IL 60603 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 173 TO FACILITY OPERATING LICENSE NO. NPF-62AMERGEN ENERGY COMPANY, LLCCLINTON POWER STATION, UNIT 1DOCKET NO. 50-46

11.0INTRODUCTION

By letter to the Nuclear Regulatory Commission (NRC, Commission) dated March 25, 2005,(Agencywide Documents Access and Management System Accession Number ML050870603)

AmerGen Energy Company, LLC (the licensee), requested a technical specification (TS) change for Clinton Power Station, Unit 1 (Clinton). Specifically, the change would exclude theprimary containment purge valve leakage rates from the summation of secondary containment bypass leakage rates.TS Surveillance Requirement (SR) 3.6.1.3.8 states:Verify the combined leakage rate for all secondary containment bypass leakagepaths is 0.08 L a when pressurized to P a.L a is the maximum allowable primary containment leakage rate at pressure P

a. P a is thecalculated peak primary containment internal pressure related to the design basis loss-of-coolant accident (LOCA).The licensee proposes to add a note which states:Leakage through penetrations 1MC-101 and 1MC-102 is excluded.Penetrations 1MC-101 and 1MC-102 are the primary containment purge valve penetrations.

In addition, by this letter, the licensee requested withdrawal of its July 1, 2004, request forexemption from Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix J,"Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," which was submitted in support of its application for the alternative source term (AST). The NRC staff hadno objection to the withdrawal.

2.0BACKGROUND

The Clinton plant has a secondary containment, which encloses the primary containment. Itsfunction is to capture radioactive material leaking from the primary containment during an accident, and to reduce the radiological consequences of this leakage by hold-up, recirculation, and filtration before release. However, a small amount of primary containment leakage will bypass the secondary containment during an accident and be released directly to theenvironment. The licensee assumes a total secondary containment bypass leakage rate amount in its radiological consequences analysis, and then establishes a TS to verify and maintain that limit during plant operation.Licensees identify primary containment penetrations, which are potential secondarycontainment bypass leakage pathways, in accordance with the guidelines in Standard Review Plan, Section 6.2.3, "Secondary Containment Functional Design," and Branch TechnicalPosition CSB [Containment Systems Branch] 6-3, "Determination of Bypass Leakage Paths in Dual Containment Plants." The leakage rates through these penetrations are periodically measured and their sum must not exceed the TS limit for the total secondary containment bypass leakage rate.The leakage rate through a potential secondary containment bypass leakage pathway istypically measured by performing local leakage rate tests on the primary containment isolation valves (PCIVs) in the pathway.

2.0REGULATORY EVALUATION

10 CFR Part 50, Appendix J, contains requirements for performing local leakage rate tests oncertain penetrations (Type B tests) and PCIVs (Type C tests). In addition, it requires that the sum of the leakage rates from Types B and C tests not exceed a limit specified in TS 5.5.13.a.

(i.e., 0.6 L a). However, Appendix J does not directly address secondary containment bypassleakage rates or their limits. The PCIVs in potential secondary containment bypass leakage pathways are a subset of the PCIVs that are Type C tested.TS SR 3.6.1.3.8 specifies a limit of 0.08 L a for the sum of the leakage rates through thepotential secondary containment bypass leakage pathways. The Type C test results for the PCIVs are used to calculate the sum, which is then compared to the TS SR 3.6.1.3.8 limit of 0.08 L a for the total secondary containment bypass leakage rate. However, neither Appendix Jnor any other regulation controls which PCIVs are to be tested as potential secondary containment bypass leakage pathways. Further, no regulation specifies the TS limit for the sumof potential secondary containment bypass leakage rates.

3.0 TECHNICAL EVALUATION

Clinton has requested full implementation of the AST in accordance with 10 CFR 50.67,"Accident Source Term." License Amendment No. 167, dated September 19, 2005, approvedthe revised radiological consequence analysis for LOCAs associated with this request. In the revised analysis, the contribution to dose from the primary containment purge valves iscalculated separately from the other potential secondary containment bypass leakagepathways. All of the doses calculated from the various release terms (primary containment,main steam isolation valves, feedwater isolation valves, primary containment purge valves, and emergency core cooli ng system leakage outside primary containment) are added together andshown to be within the applicable regulatory limits (10 CFR 50.67, as supplemented in Regulatory Position 4.4 of Regulatory Guide 1.183 and 10 CFR Part 50, Appendix A, GeneralDesign Criterion 19, "Control Room"). Based on its review, the NRC staff finds that:1.The current TS combines primary containment purge valve leakage rates with theleakage rates of the other secondary containment bypass leakage pathways, in accordance with the pre-AST radiological consequence analysis for LOCA;2.The dose contribution of the primary containment purge valves is calculated separatelyfrom the other potential secondary containment bypass leakage pathways in the ASTanalysis;3.The total calculated LOCA dose is within regulatory limits; 4.The primary containment purge valves have their own separate TS leakage rate limit; and5.There is no regulatory requirement, other than the current Clinton TS, to sum theprimary containment purge valve leakage rates with other potential secondary containment bypass pathway leakage rates.Therefore, the NRC staff finds that the primary containment purge valve leakage rates may beexcluded from the combined leakage rate of the other potential secondary containment bypassleakage pathways, in TS SR 3.6.1.3.8.

4.0STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of theproposed issuance of the amendment. The State official had no comments.

5.0ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20, or changes a surveillance requirement. The NRC staff has determined that the amendment involves nosignificant increase in the amounts, and no significant change in the types, of any effluents thatmay be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been nopublic comment on such finding (70 FR 21451; April 26, 2005).Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0CONCLUSION

The NRC staff has concluded, based on the considerations discussed above, that: (1) there isreasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendments will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributor: J. Pulsipher Date: March 21, 2006