ML053070482

RAI Regarding Use of Alternate Source Term

ML053070482
Person / Time
Site:	Millstone
Issue date:	11/18/2005
From:	George Wunder Plant Licensing Branch III-2
To:	Christian D Dominion Nuclear Connecticut
Wunder G, NRR/DLPM, 415-1494
References
TAC MC3333
Download: ML053070482 (5)

Text

November 18, 2005 Mr. David A. Christian Senior Vice President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING USE OF ALTERNATE SOURCE TERM (TAC NO. MC3333)

Dear Mr. Christian:

By letter dated May 27, 2004, you requested an amendment to the Millstone Power Station, Unit No. 3 (MP3) Technical Specifications. The amendment would allow the use of an alternate source term for MP3.

The Nuclear Regulatory Commission staff is reviewing your application and has determined that additional information is required. The enclosed request for additional information (RAI) was forwarded electronically to Mr. Paul Willoughby of your staff on November 18, 2005. We request that you respond to this request within 30 days of the date of this letter. If you cannot respond within 30 days, please inform us in writing. If you do no respond within 30 days, it may result in the rejection of your application under the provisions of Title 10 of the Code of Federal Regulations Section 2.108. If you have any questions, I can be reached at (301) 415-1494.

Sincerely,

/RA/

George F. Wunder, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423

Enclosure:

As stated cc w/encl: See next page

Millstone Power Station, Unit No. 3 cc:

Lillilan M. Cuoco, Esquire Mr. Joseph Roy, Senior Counsel Director of Operations Dominion Resources Services, Inc. Massachusetts Municipal Wholesale Building 475, 5th Floor Electric Company Rope Ferry Road Moody Street Waterford, CT 06385 P.O. Box 426 Ludlow, MA 01056 Edward L. Wilds, Jr., Ph.D.

Director, Division of Radiation Mr. J. Alan Price Department of Environmental Protection Site Vice President 79 Elm Street Dominion Nuclear Connecticut, Inc.

Hartford, CT 06106-5127 Building 475, 5th Floor Rope Ferry Road Regional Administrator, Region I Waterford, CT 06385 U.S. Nuclear Regulatory Commission 475 Allendale Road Mr. Chris Funderburk King of Prussia, PA 19406 Director, Nuclear Licensing and Operations Support First Selectmen Dominion Resources Services, Inc.

Town of Waterford 5000 Dominion Boulevard 15 Rope Ferry Road Glen Allen, VA 23060-6711 Waterford, CT 06385 Mr. David W. Dodson Mr. John Markowicz Licensing Supervisor Co-Chair Dominion Nuclear Connecticut, Inc.

Nuclear Energy Advisory Council Building 475, 5th Floor 9 Susan Terrace Rope Ferry Road Waterford, CT 06385 Waterford, CT 06385 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Senior Resident Inspector Millstone Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 Ms. Nancy Burton 147 Cross Highway Redding Ridge, CT 00870

ML053070482 *Memorandum dated October 20, 2005 OFFICE NRR/LPLI-2/PM NRR/LPLI-2/LA SPSB/SC NRR/LPLI-2/BC NAME GWunder CRaynor RDennig* VNerses for DRoberts DATE 11/17/05 11/16/05 10/20/05 11/18/05 REQUEST FOR ADDITIONAL INFORMATION MILLSTONE POWER STATION, UNIT NO. 3 DOCKET NO. 50-423 USE OF ALTERNATE SOURCE TERM By letter dated May 27, 2004, Dominion Nuclear Connecticut, Inc. requested an amendment to the Millstone Power Station, Unit No. 3 (MP3) Technical Specifications. The amendment would allow the use of an alternate source term for MP3.

The Nuclear Regulatory Commission (NRC) staff believes that MP3 wants to test to a higher penetration than that permitted by Regulatory Guide (RG) 1.52, Revision 2. The intent of using a safety factor of 2 as defined in Generic Letter (GL) 99-02 was not to permit use of degraded carbon adsorbers. Its purpose was to allow some additional margin in testing for those plants that were assuming the maximum value for efficiency for their carbon adsorbers, and were testing the filter efficiencies in accordance with American Society for Testing and Materials (ASTM) D-3803-1989. In RG 1.52, Revision 2, the assigned efficiency for a 2-inch bed filter is stated as 95 percent, and the test penetration criteria of 1 percent. Using the formula for safety factor, this would yield a safety factor of 5. GL 99-02 allowed a safety factor of 2 for those plants testing in accordance with ASTM D-3803-1989. The allowable penetration calculated by using a safety factor of 2 would be a test penetration of 2.5 percent. This increase in test penetration criteria was reflected in RG 1.52, Revision 3.

MP3 has chosen to use a lower assumed efficiency (i.e., 90 percent) for carbon adsorbers than the maximum that could be assumed (95 percent) since the lesser value produces acceptable analytical results in the design basis analysis. Then, on the basis of a safety factor of 2, MP3 is requesting that they be permitted to test the carbon adsorber in a degraded state (i.e., at 5 percent penetration).

The NRC staff has no information on how a degraded carbon adsorber would perform for the duration of a surveillance period or for the intended purpose of mitigating an event that required the use of the filters. All of the staff data on filter performance is based on efficiencies of 99 percent for 4-inch beds and 95 percent for 2-inch beds. At these efficiencies, there are many additional unused sites, and with a safety factor of 2, reasonable assurance exists that acceptable efficiency would be available at the end of the surveillance period and during a event that the filter could mitigate. If MP3 desires to test a higher penetration than that permitted in the RG, and thus use a degraded filter, the staff requests that MP3 provide sufficient data to assure that the filter will perform acceptably in the degraded state through the end of the surveillance period and for the event which requires mitigation.

Enclosure