ML052280354

Report of Changes Pursuant to 10 CFR 50.46

ML052280354
Person / Time
Site:	Perry
Issue date:	08/08/2005
From:	Richard Anderson FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PY-CEI/NRR-2895L
Download: ML052280354 (4)

Text

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Perry Nuclear Power Plant 10 Center Road FirstEnergy Nuclear Operating Company Perry Ohio 44081 Richard'Anderson 440-280-5579 Vice President-Nuclear Fax: 440-280-8029 August 8, 2005 PY-CEI/NRR-2895L United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Perry Nuclear Power Plant Docket No. 50-440 Report of Changes Pursuant to 10 CFR 50.46 Ladies and Gentlemen:

In March 2001, during the 8th Refueling Outage at the Perry Nuclear Power Plant (PNPP), GEi4 fuel was loaded into the core. The PNPP-specific Loss of Coolant,

Accident (LOCA) analysis was revised to include use of this fuel type. The change in, Peak Clad Temperature (PCT) was larger than the 10 CFR 50.46(a)(3)(i) and (ii) - -

threshold value of ugreater than 50° F" for submitting a 30-day report. Since GE14 fuel was designed in accordance with NRC-approved topical reports and its use within the PNPP core was analyzed using NRC-approved methodologies, the PNPP staff did not believe the 30-day reporting criteria was applicable. The change was reported in the.

annual 10 CFR 50.46 report (reference PNPP letter PY-CEI/NRR-2613L, dated February 27, 2002).

On July 7, 2005, a teleconference was conducted between the Nuclear Regulatory Commission (NRC) and PNPP staffs to discuss the requirements contained within 10 CFR 50.46. Based upon this teleconference, the PNPP staff determined that in 2001, the NRC should have been notified of the use of GE14 fuel using the 30-day reporting criteria instead of the annual reporting criteria.-Furtherrmore,--subsequent changes or errors to the LOCA analysis reported in the annual 10 CFR 50.46 reports since that time should have been communicated via 30-day reports, since the original change (use of GE14 fuel) was not properly resolved.

This submittal is considered a 30-day report for the purposes of notifying the NRC of the use of GE14 fuel at PNPP and of other changes or errors to the LOCA analysis.

Attachment 1 contains a tabulation of each change, its impact upon PCT with a cross-reference the respective annual 10 CFR 50.46 submittal, which initially reported the change or error. Attachment 2 contains, for reference, the changes in the core composition that have occurred since 2001. -:

In-accordance with 10 CFR 50.46(a)(3)(ii), the 30-day report will iricldde a schedule for providing a reanalysis or taking other actions that show compliance with the 10 CFR 50.46 requirements. The PNPP staff has concluded that the use of GE14 fuel is in compliance with the requirements of 10 CFR 50.46 and a reanalysis is not required. GE14 fuel was

August 8, 2005 PY-CEI/NRR-2895L Page 2 of 2 designed in accordance with the NRC-approved General Electric Topical Report titled, "General Electric Standard Application for Reactor Fuel". The NRC-approved General Electric Topical Report, 'GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident" (SAFER-GESTR), was used to develop the PNPP-specific LOCA analysis. As shown in Attachment 1, the PCT for the GE14 is 15400 F, which satisfies the 10 CFR 50.46(b)(1) criteria of < 22000 F. This PCT value is also below the 16000 F analysis limit of the SAFER-GESTR model. The maximum local oxidation is 1.0% and the metal-water reaction is 0.1% which are both below the 10 CFR 50.46(b) acceptance criteria of 17% and 1.0%, respectively.

Based upon the July 7 teleconference, the PNPP staff understands that the NRC intends to issue a Regulatory Issue Summary (RIS) regarding the appropriate interpretations of the requirements of 10 CFR 50.46. The PNPP staff also understands that some of these inte-rpretati6ns may impact previ6u-s10 CFR 50.46 reports that have been made. Once the RIS is received and reviewed by the PNPP staff, any necessary actions will be documented and processed in accordance with the FirstEnergy Nuclear Operating Company Corrective Action Program.

There are no regulatory commitments included in this letter or its attachments. If you have any questions or require additional information, please contact Mr. Henry L. Hegrat, FirstEnergy Nuclear Operating Company, Fleet Licensing Supervisor, at (330) 315-6944.

Very truly yours, Attachments

1. Summary of Annual 10 CFR 50.46 Reporting

2. Changes in Core Composition cc: NRC Region ll NRC Resident Inspector NRC Project Manager

Attachment I PY-CEI/NRR-2895L Page 1 of 1 Summary of Annual 10 CFR 50.46 Reporting Reason for Peak Clad Temperature Date Licensee Notified Submittal Date and Change/Error (PCT) Impact of Change/Error Reference Power Uprate GE11 PCT is 13700 F June 1, 2000 February 23, 2001 Analysis related to PY-CEI/NRR-2548 Amendment 112 SAF time step size on PCT decrease for GE10, November 20,2000 February 23, 2001 PCT for jet pump GE11, and GE12 of -5° F PY-CEI/NRR-2548 plants. -

Incorporation of_ GE12 PCTis 1320°F_ December 2000- - February 27, 2002 GE14 Fuel. GE14 PCT is 15400 F Fuel loaded in PY-CEI/NRR-2613L March 2001 outage SAFER pressure PCT increase for both May 10, 2001 February 27, 2002 rate inconsistency GE12 and GE14 of 50 F PY-CEI/NRR-2613L error.

SAFER/GESTR PCT increase for both June 15, 2002 February 28, 2003 error in core spray GE12 and GE14 of 150 F PY-CEI/NRR-2695L elevation.

SAFER bulk water PCT increase for both June 15, 2002 February 28, 2003 level error. GE12 and GE14 of 00 F PY-CEI/NRR-2695L GESTR input file PCT increase for GE12 June 15, 2002 February 28, 2003 interpolation error. Of 00 F PY-CEI/NRR-2695L No impact on GE14 SAFER Computer PCT increase for both August 26, 2002 February 28, 2003 platform change. GE12 and GE14 of 00 F PY-CEI/NRR-2695L Error in WEVOL PCT increase for both August 26, 2002 February 28, 2003 calculation of down- GE12 and GE14 of 00 F PY-CEI/NRR-2695L comer free volume.

Issue with SAFER/ PCT increase for both May 6, 2003 March 1, 2004

-GESTR level/volume -GE12 and GE14 of-50 F- -_ - PY-CEI/NRR-2774L--

input table setup..

Issue with steam PCT increase for both May 6, 2003 March 1, 2004 separator pressure GE12 and GE14 of 00 F PY-CEI/NRR-2774L drop assumption used by SAFER.

Issue with SAFER/ PCT increase for both November 28, 2003 March 1, 2004 GESTR assumptions GE12 and GE14 of 00 F PY-CEI/NRR-2774L on post-LOCA recombination of oxygen and hydrogen

,Z-- -

Attachment 2 PY-CEI/NRR-2895L Page 1 of 1 Changes in Core Composition Refueling Outage 08 Spring 2001 Discharged remaining GE10 and GE11 fuel.

Loaded first reload batch of GE14 fuel.

Cycle 9 core contains GE12 and GE14 fuel.

Refueling Outage 09 Spring 2003 Discharged one reload batch of GE12 fuel.

Loaded a reload batch of GE14 fuel.

Cycle 10 core contains GE12 and GE14 fuel.

Refueling Outage 10 Spring 2005 Discharged remaining GE12 fuel.

Loaded a reload batch of GE14 fuel.

_ Cycle 11 core contains only GE14 fuel.