ML091160002
ML091160002 | |
Person / Time | |
---|---|
Site: | Turkey Point |
Issue date: | 05/27/2009 |
From: | Plant Licensing Branch II |
To: | |
paige, Jason, NRR/DORL,301-415-5888 | |
References | |
Download: ML091160002 (25) | |
Text
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A.LTERNATIVE SOURCE TERM (AST)
Request for License Amendment Pre-Submittal Meeting Turkey Point Units 3 and 4 April 24, 2009
Turkey Point Units 3 and 4 - Alternative Source Term ATTENDEES FOR FPL
- Jim Harrell Contractor (Numerical Applications, Inc.)
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Turkey Point Units 3 and 4 - Alternative Source Term PURPOSE OF PRE-SUBMITTAL MEETING
- Achieve common understanding of the proposed scope of the Turkey Point application
- .Gain understanding regarding regulatory positions on specific Issues
- Understand the level of detail of information expected in the appl ication 3
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Turkey Point Units 3 and 4 - Alternative Source Term AGENDA
- Reason for Adopting Alternate Source Term (AST)
- Scope of Implementation
- Specific Aspects of Analyses
- Overview of Licensing Basis Changes
- Proposed Technical Specification Changes
- Submittal Content
- Schedules
- Summary fj 4 I=PL.
Turkey Point Units 3 and 4 - Alternative Source Term REASON FOR ADOPTING AST METHODOLGY
- To update Turkey Point Units 3 and 4 accident dose analyses using a consistent basis for all events as described by Regulatory Guide 1.183
- To obtain margin for Control Room inleakage
- To support a future extended power uprate 5
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Turkey Point Units 3 and 4 - Alternative Source Term SCOPE OF IMPLEMENTATION
- Postulated events analyzed
- Loss-ot-Coolant Accident
- Fuel Handling Accident
-- Separate analysis tor Containment and Fuel Handling Building Releases
- Main Steam Line Break
-- No Fuel Damage postulated
-- Pre-Accident and Concurrent Iodine Spikes 6 -FPL.
Turkey Point Units 3 and 4 - Alternative Source Term SCOPE OF IMPLEMENTATION
- Postulated events analyzed (continued)
- Steam Generator Tube Rupture
-- No Fuel Damage postulated
-- Pre-Accident and Concurrent Iodine Spikes
-- Considers pre-trip releases via condenser and post-trip releases via Steam Generator
- Locked Rotor
-- Postulated Fuel Damage Rod Cluster Control Assembly Ejection
-- Containment and Secondary Release Events
-- Postulated Fuel Damage 7 -F=PL.
Turkey Point Units 3 and 4 - Alternative Source Term SCOPE OF IMPLEMENTATION
- Postulated events analyzed (continued)
- Waste Gas Decay Tank Rupture
-- Utilizes Exclusion Area Boundary Limit of 0.1 rem TEDE consistent with RIS 2006-04
- Spent Fuel Cask Drop
- Postulated fuel damage 8 -F=PL.
Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES
- Turkey Point specific source term inventories calculated using ORIGEN 2
-- Considers conservative burnup ranges, enrichment ranges and power levels
-- Bounds both current operating conditions and future extended power uprate operating conditions (2652 MWt, including calorimetric uncertainties)
- Updated control room and offsite X/Q values based upon Reg. Guide 1.194 and Reg. Guide 1.145 using recent meteorological data 9
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Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cant)
- 10% of the total iodine activity in the EGCS leakage outside containment assumed airborne
- LOGA dose contribution from the EGCS back-leakage to RWST considers the effects of sump pH, back leakage temperature reduction, and total iodine distribution within the tank
- Analysis inputs and atmospheric steam releases are set conservatively to bound current plant operating conditions and future extended power uprate operating conditions (2652 MWt, including calorimetric uncertainties) 10
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Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cont)
- Preliminary dose analyses support increased Control Room unfiltered inleakage rates
-- Control Room inleakage testing performed in August 2003 indicated less than 10 cfm of unfiltered inleakage
-- Control Room is shared between Units 3 and 4
-- 150 cfm unfiltered inleakage assumed
- Containment sump pH will be confirmed via calculations considering NUREG/CR-5950 11
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Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cont)
Turkey Point AST Evaluation Preliminary Results Event EAB LPZ CR LOCA 5.66 1.54 4.81 FHA - in Containment 0.91 0.20 1.01 FHA - in Fuel Handling Building 0.91 0.20 3.95 MSLB - Pre-accident iodine spike 0.029 0.024 1.49 MSLB - Concurrent iodine spike 0.046 0.041 1.54 SGTR - Pre-accident iodine spike 0.82 0.18 2.85 SGTR - Concurrent iodine spike 0.28 0.07 1.10 All units are rem TEDE 12 GF=PL..
Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cont)
Turkey Point AST Evaluation Preliminary Results Event EAB LPZ CR Locked Rotor 0.57 0.60 1.48 RCCA Ejection - Containment 0.88 0.40 2.34 RCCA Ejection - Secondary 0.59 0.56 1.32 Waste Gas Decay Tank Rupture 0.08 0.02 0.04 Spent Fuel Cask Drop 0.26 0.06 2.51 All units are rem TEDE.
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Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cont)
Consideration of High Burnup Rods for Fuel Handling Accident
- To assure that failure of any offloaded fuel assembly is bounded by the Fuel Handling Accident, all of the rods in a single fuel assembly are conservatively assumed to exceed the burnup limits upon which the Reg. Guide 1.183 gap release fractions are based
- Guidance of NUREG/CR-5009 is used to determine the conservative gap release fractions
- NUREG/CR-5009 endorses the gap release fractions for fuel handling events outlined in Reg. Guide 1.25 with some modification for higher burnups 14
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Turkey Point Units 3 and 4 - Alternative Source Term OVERVIEW OF ANTICIPATED LICENSING BASIS CHANGES
- The total effective dose equivalent (TEDE) acceptance criterion of 10CFR50.67(b)(2) replaces the previous whole body and thyroid dose guidelines of 10CFR 100.11
- New onsite (Control Room) and offsite atmospheric dispersion factors are developed
- Dose conversion factors for inhalation and submersion are from Federal Guidance Reports (FGR) Nos. 11 and 12, respectively 15 -I=PL.
Turkey Point Units 3 and 4 - Alternative Source Term OVERVIEW OF ANTICIPATED LICENSING BASIS CHANGES (cont)
- A bounding value for control room unfiltered air inleakage was established by increasing the inleakage until the dose acceptance criteria for the limiting event (LOCA) was approached
- A primary coolant specific activity for Dose Equivalent 1 131 that is more restrictive than the current Technical Specification limit is utilized
- A steam generator tube leakage rate is used that is more restrictive than the current Technical Specification program limit for primary-to-secondary accident induced leakage
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Turkey Point Units 3 and 4 - Alternative Source Term OVERVIEW OF ANTICIPATED LICENSING BASIS CHANGES (cont)
- A containment leakage value that is more restrictive than the current Technical Specification limit is utilized
- Containment ESF filter units are not credited
- In accordance with TSTF-490, the Reactor Coolant System specific activity limit for gross radioactivity is changed from 1ODIE-bar to dose equivalent Xenon-133
- The 1ODIE-bar value is directly converted to dose equivalent Xenon-133, so this change is not required to implement AST 17
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Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED PHYSICAL PLANT CHANGES
- The Control Room Emergency Intakes are proposed to be relocated to reduce control room doses and support development of updated control room X/Q values
- Sodium tetraborate decahydrate (NaTB) baskets are proposed to be added to the containment for pH control fj 18 FPL.
Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED TECHNICAL SPECIFICATION CHANGES
- Definition of Dose Equivalent 1-131 in Section 1.10 is revised to reference Federal Guidance Report No. 11 (FGR 11), "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion" 1989, as the source of effective dose conversion factors.
- Reactor Coolant System (RCS) specific activity limit for dose equivalent lodine-131 gDE 1-131), stated in Limiting Condition for Operation(LC ) 3.4.8.a, is reduced from 1 microcurie per gram to 0.25 microcurie per gram.
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Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED TECHNICAL SPECIFICATION CHANGES (cont)
- Reactor Coolant System specific activity limit for gross radioactivity stated in Limiting Condition for Operation (LCO) 3.4.8.b is changed from 1ODIE-bar to dose equivalent Xenon-133.
- Terminology used in Limiting Condition for Operation (LCO) 3.7.9 to set the maximum contents of the Waste Gas Decay Tank is clarified to read 'DOSE EQUIVALENT Xe-133.'
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Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED TECHNICAL SPECIFICATION CHANGES (cont)
- Maximum allowable containment leakage rate acceptance criterion stated in TS 6.8.4.h, "Containment Leakage Rate Testing Program," is reduced from 0.25%
to 0.20% of containment air weight per day.
- Maximum allowable primary-to-secondary accident induced leakage rate acceptance criterion stated in TS 6.8.4.j.b.2, "Steam Generator Program," is reduced from 500 gpd to 300 gpd through anyone steam generator.
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Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED TECHNICAL SPECIFICATION CHANGES (cont)
- A method for controlling the pH of the post-LOCA containment sump solution using sodium tetraborate decahydrate (NaTB) is being proposed. This passive system will consist of baskets of NaTB in the lower regions of the containment. Appropriate Technical Specifications and Surveillance Requirements are proposed for Section 3/4.6 "Containment Systems."
- Operability requirements for emergency containment filter units in Section 3/4.6.3 will be deleted.
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Turkey Point Units 3 and 4 - Alternative Source Term SUBMITTAL CONTENT
- Licensing Technical Report which presents the analysis assumptions and documents conformance with Reg.
Guide 1.183
- Table addressing NRC Regulatory Issue Summary 2006-04 issues
- Analyses key input parameters and results tables
- Technical Specification changes
- No Significant Hazards Considerations Evaluation
- Plant modification descriptions 23
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Turkey Point Units 3 and 4 - Alternative Source Term SCHEDULE
- AST RLA provides dose analysis to support EPU
- EPU RLA will reference AST analyses provided in AST RLA
- Second review of dose analyses will not be required for EPU 24
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Turkey Point Units 3 and 4 - Alternative Source Term
SUMMARY
- Addresses control room inleakage margin
- Conformance with RG 1.183
- Addresses NRC RIS 2006-04 concerns
- Utilizes conservative inputs to bound current operating conditions and planned future extended power uprate operating conditions
- Can be implemented at current power level
- Planned submittal in June 2009 25 - FPL.