RS-09-091, Stations, Units 1 and 2 - Additional Information Supporting License Amendment Request to Adopt TSTF-490

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Stations, Units 1 and 2 - Additional Information Supporting License Amendment Request to Adopt TSTF-490
ML092090437
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 07/27/2009
From: Simpson P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-09-091, TSTF-490
Download: ML092090437 (17)
v • d • e


Text

www.exe]oncorp.com Exelon@

Exelon Nuclear 4300 Winfield Road Nuclear Warrenville, IL 60555 RS-09-091 July 27,2009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Additional Information Supporting License Amendment Request to Adopt TSTF-490

References:

1. Letter from P. A. Simpson (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "License Amendment Request to Adopt TSTF-490 Deletion of E Bar Definition and Revision to RCS Specific Activity Technical Specification," dated December 4,2008

2. Letter from M. J. David (U.S. Nuclear Regulatory Commission) to C. G. Pardee (Exelon Nuclear), "Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2 - Request for Additional Information Related to Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification (TAC Nos. ME0206, ME0207, ME0208, and ME0209)," dated June 19,2009
3. Letter from M. J. David (U.S. Nuclear Regulatory Commission) to C. G. Pardee (Exelon Nuclear), "Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2 - Issuance of Amendments Re: Clarification of Operating License and Technical Specifications (TAC Nos. MD9360, MD9361, MD9362, and MD9363)," dated July 22,2009 In Reference 1, Exelon Generation Company, LLC (EGG) requested a license amendment for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, to revise Technical Specifications (TS) to replace the current limit on Reactor Coolant System (RCS) gross specific activity with a new limit on RCS noble gas-specific activity. The NRC requested additional

July 27, 2009 U.S. Nuclear Regulatory Commission Page 2 information to complete review of the proposed license amendment in Reference 2. In response to this request, EGC is providing the attached information.

Attachments 2 and 3 provide revised markups of TS page 1.1-3 for Braidwood Station and Byron Station, respectively. Retyped TS pages with the proposed changes incorporated are provided in Attachments 4 and 5 for Braidwood Station and Byron Station, respectively.

However, Attachments 4 and 5 do not include TS Table of Contents page vi, which was identified as a proposed change in Reference 1, since this page was deleted in Reference 3.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Kenneth M. Nicely at (630) 657-2803.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of July 2009.

ReiiC~UIIY, I

(~ ~'

Patrick R. Simpson Manager - Licensing Attachments:

1. Response to Request for Additional Information
2. Revised Markup of Proposed Technical Specifications Page for Braidwood Station
3. Revised Markup of Proposed Technical Specifications Page for Byron Station
4. Retyped Technical Specifications Pages for Braidwood Station
5. Retyped Technical Specifications Pages for Byron Station

ATTACHMENT 1 Response to Request for Additional Information NRC Request The Nuclear Regulatory Commission (NRC) staff is reviewing Exelon Generation Company, LLC's (the licensee's) license amendment request (LAR) dated December 4,2008 (Agencywide Documents Access and Management System Accession No. ML083390706). The LAR requests to revise Technical Specifications (TSs) 1.1, "Definitions," and 3.4.16, "RCS [Reactor Coolant System] Specific Activity," and Surveillance Requirements 3.4.16.1 and 3.4.16.3. The requested changes would replace the current TS 3.4.16 limit on RCS gross specific activity with a new limit on RCS noble gas-specific activity. The LAR states that the changes are consistent with NRC-approved TS Task Force (TSTF) Change Traveler, TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec." The NRC staff has determined that following additional information is required to complete its review.

The proposed Inserts A and B contained in the LAR provide definitions for "dose equivalent 1-131" (DEI) and "dose equivalent Xe-133," respectively. Insert A indicates that DEI may be determined using several references for dose conversion factors (DCFs). However, the purpose of the limiting condition for operation (LCO) for DEI is to satisfy Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Criterion 2, which establishes, in part, an operating restriction that is an initial condition of a design-basis accident (DBA). When surveillance of the RCS' radionuclides is performed, each acceptable set of DCFs will yield a different DEI. As approved by the NRC staff, the intent of TSTF-490 was to allow the licensee to select, from the acceptable list, one DCF reference for the calculation of DEI. Therefore, consistent with 10 CFR 50.36 and TSTF-490, the licensee should specify one DCF reference for DEI, which will be consistent with the specified LCO and DBA analysis, or justify why a list of several DCFs is consistent with the specified LCO and DBA analysis. Therefore, please justify how the use of multiple DCFs maintains consistency with the specified LCO values and DBA analyses, or provide a revised definition that incorporates the DCFs appropriate for both the Braidwood and the Byron TSs.

Response

The proposed TS pages have been revised to clarify the definition of DEI to specify one DCF reference that is consistent with the applicable LCO and associated DBA analyses.

Attachments 2 and 3 provide revised markups of the affected TS pages for Braidwood Station and Byron Station, respectively. Attachments 4 and 5 provide retyped TS pages for Braidwood Station and Byron Station, respectively, with all proposed changes incorporated.

Page 1 of 1

ATTACHMENT 2 Revised Markup of Proposed Technical Specifications Page for Braidwood Station Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 REVISED TECHNICAL SPECIFICATIONS PAGES 1.1-3

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT I 131 DOSE EQUIVALENT I 131 shall be that concentration of I 131 (ffiicrocuries/graffi) that alone would

f~~~;~ :~els~~i,dysi3~~ ihi3j~a~ti~~,a~~diioi~~

actually present. The dose conversion factors used for this calculation shall be those listed in INSERT 1.1-1 Table III of TID 14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites," or those listed in Table E 7 of Regulatory Gui de 1.109, Rev. 1, ~lRC, 1977, or ICRP 30,

~G~~i:i~~ 6gs~a~~utva~~~i t~2T~;~etTo~~;n~i:;ed, Tissues per Intake of Unit /\ctivity," or Federal Gui dance Report 11, "Liffiiti ng Val ues of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Subffiersion and Ingestion," 1988; (Table 2.1, Exposure To Dose Conversion Factors for Inhalation).

-t- ,WER/\GE -t-shall be the average (weighted in proportion to DISINTEGR/\TION ENERGY the concentration of each radionuclide in the reactor coolant at the tiffie of saffipling) of the SUffi of the average beta and gaffima energies (in

~i~~ g;ffd1r~~~e;r~gi:rn~::s~~~~f~~n=pi~:tf:i~t 95% of the total non iodine activity in the coolant.

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time FEATURE (ESF) RESPONSE interval from when the monitored parameter TIME exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i .e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

BRAIDWOOD - UNITS 1 &2 1.1-3 Amendment 140

INSERT 1.1-1 DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes 1-131,1-132,1-133,1-134, and 1-135 actually present.

The determination of DOSE EQUIVALENT 1-131 shall be performed using the Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11, 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil."

ATTACHMENT 3 Revised Markup of Proposed Technical Specifications Page for Byron Station Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 REVISED TECHNICAL SPECIFICATIONS PAGES 1.1-3

Definitions 1.1 1.1 Defi niti ons DOSE EQUIVALE~IT I 131 DOSE EQUIVALENT I 131 shall be that concentration of I 131 (microcuries!gram) that alone would produce the same dose as the quantity and isotopic mixture of I 131, I 132, I 133, I 134, and I 135 actually present. The dose conversion factors used for this calculation shall be those listed in INSERT 1.1-1 Table III of TID 14g44, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites," or those listed in Table E 7 of Regulatory Guide 1.109, Rev. 1, NRC, 1977, or ICRP 30,

~G~~t:f~a 6gs~a~:u}~a~~~f }~2T~~;etTg~~;n:i~~ed, Tissues per Intake of Unit i\ctivity," or Federal Gui dance Report 11 "Limiti ng Val yes of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion", 1999; (Table 2.1, Exposure To Dose Conversion Factors for Inhalation).

~ IWERi\GE ~shall be the average (weighted in proportion to DISINTEGRATIO~1 ENERGY the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies (in

~t~~ ~;rfdi~~~:e;rr8i:fn~=s~~a~f~~n~pi~~t?g~~t 95% of the total non iodine activity in the coolant.

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time FEATURE (ESF) RESPONSE interval from when the monitored parameter TIME exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i .e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

BYRON - UNITS 1 &2 1.1-3 Amendment 147

INSERT 1.1-1 DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes 1-131,1-132,1-133,1-134, and 1-135 actually present.

The determination of DOSE EQUIVALENT 1-131 shall be performed using the Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11, 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and SoiL"

ATTACHMENT 4 Retyped Technical Specifications Pages for Braidwood Station Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF*72 and NPF*77 REVISED TECHNICAL SPECIFICATIONS PAGES 1.1-3 3.4.16-1 3.4.16-2

Defi niti ons 1.1 1.1 Definitions DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The determination of DOSE EQUIVALENT 1-131 shall be performed using the Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11, 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil. "

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time FEATURE (ESF) RESPONSE interval from when the monitored parameter TIME exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i .e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

BRAIDWOOD - UNITS 1 &2 1.1-3 Amendment

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQU IRED ACTI ON COMPLETION TIME A. DOSE EQUIVALENT 1-131 ------------NOTE------------

not within limit. LCO 3.0.4.c is applicable.

A.l Verify DOSE Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> EQUIVALENT 1-131 s 60 ~i/gm.

AND A.2 Restore DOSE 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> EQUIVALENT 1-131 specific activity to within limit.

B. DOSE EQUIVALENT XE-133 ------------NOTE------------

not within limit. LCO 3.0.4.c is applicable.

B.l Restore DOSE 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> EQUIVALENT XE-133 to within 1imit.

(continued)

BRAIDWOOD - UNITS 1 &2 3.4.16-1 Amendment

RCS Specific Activity 3.4.16 ACTIONS (continued)

CONDITION REQU IRED ACTI ON COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A AND or B not met.

C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR DOSE EQUIVALENT 1-131

> 60 ~i/gm.

SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.4.16.1 -------------------NOTE-------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 7 days XE-133 specific activity $ 603 ~i/gm.

SR 3.4.16.2 -------------------NOTE-------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 14 days 1-131 specific activity ~ 1.0 ~i/gm.

AND Between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after a THERMAL POWER change of

~ 15% RTP within a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period BRAIDWOOD - UNITS 1 &2 3.4.16-2 Amendment

ATTACHMENT 5 Retyped Technical Specifications Pages for Byron Station Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 REVISED TECHNICAL SPECIFICATIONS PAGES 1.1-3 3.4.16-1 3.4.16-2

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The determination of DOSE EQUIVALENT 1-131 shall be performed using the Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11, 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil. "

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time FEATURE (ESF) RESPONSE interval from when the monitored parameter TIME exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

BYRON - UNITS 1 &2 1.1-3 Amendment

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQU IRED ACTI ON COMPLETION TIME A. DOSE EQUIVALENT 1-131 ------------NOTE------------

not within limit. LCO 3.0.4.c is applicable.

A.1 Verify DOSE Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> EQUIVALENT 1-131

s; 60 j..lC i / gm.

AND A.2 Restore DOSE 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> EQUIVALENT 1-131 specific activity to within limit.

B. DOSE EQUIVALENT XE-133 ------------NOTE------------

not within limit. LCO 3.0.4.c is applicable.

B.1 Restore DOSE 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> EQUIVALENT XE-133 to within limit.

(contlnued)

BYRON - UNITS 1 &2 3.4.16-1 Amendment

RCS Specific Activity 3.4.16 ACTIONS (continued)

CONDITION REQU IRED ACTI ON COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A AND or B not met.

C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR DOSE EQUIVALENT 1-131

> 60 ~i/gm.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 -------------------NOTE-------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 7 days XE-133 specific activity ~ 603 ~i/gm.

SR 3.4.16.2 -------------------NOTE-------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 14 days 1-131 specific activity ~ 1.0 ~i/gm.

AND Between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after a THERMAL POWER change of

~ 15% RTP within a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period BYRON - UNITS 1 &2 3.4.16-2 Amendment

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