ML060890295

CFR 50.46 Annual Report

ML060890295
Person / Time
Site:	Limerick
Issue date:	12/01/2005
From:	Cowan P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML060890295 (10)

Text

1OCFR50.46 December I , 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000I Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Subject 10 CFR 50.46 Annual Report

Reference:

Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U. S.

Nuclear Regulatory Commission, 10 CFR 50.46 Reporting Requirements, dated December 3,2004 The purpose of this letter is to submit the 10 CFR 50.46 reporting information for Limerick Generating Station (LGS), Units 1 and 2. The most recent annual 50.46 Report for Limerick Generating Station, Units 1 and 2 (Reference 1) provided the cumulative Peak Cladding Temperature (PCT) errors for the most recent fuel designs through November 4, 2004.

In summary, the previously reported peak clad temperatures have not changed. No vendor 50.46 change/error notifications have been received since the last annual report.

Two attachments are included with this letter that provide the current Limerick Generating Station, Units 1 and 2, 10 CFR 50.46 status. Attachments 1 and 2 (Peak Cladding Temperature Rack-Up Sheet) provide updated information regarding the PCT for the limiting Large Break Loss of Coolant Accident (LOCA) analysis evaluations for Limerick Generating Station, Units 1 and 2, respectively. Attachment 3, Assessment Notes, contains a detailed description for each change or error reported.

If you have any questions, please contact Tom Loomis at 610-765-5510.

Respectfully, Pamela 8.Cowan Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Peak Cladding Temperature Rack-Up Sheet (Limerick Generating Station, Unit 1)

2) Peak Cladding Temperature Rack-Up Sheet (Limerick Generating Station, Unit 2)

3) Assessment Notes (Limerick Generating Station, Units 1 and 2) cc: S. J. Collins, USNRC Administrator, Region I G. Wunder, USNRC Project Manager, LGS S. Hansell, USNRC Senior Resident Inspector, LGS

ATTACHMENT 1 10 CFR 50.46 Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of November 30,2005 Peak Cladding Temperature Rack-Up Sheet Limerick Generating Station, Unit 1

Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of November 30,2005 Attachment 1 Peak Cladding Temperature Rack-Up Sheet, LGS U1 Page 1 of 2 PLANT NAME: Limerick Generatina Station, Unit 1 ECCS EVALUATION MODEL: SAFER/GESTR-LOCA REPORT REVISION DATE: 11/30/05 CURRENT OPERATING CYCLE: 11 ANALYSIS OF RECORD Evaluation Model:

1. NEDC-23785-1-PA Rev. 1, The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-Of-Coolant Accident Volume 11, SAFER - Long Term Inventory Model for BW R Loss-Of-Coolant Analysis, October 1984.

2. NEDC-30996P-AI SAFER Model for Evaluation of Loss-of-Coolant Accidents for Jet Pump and Non-jet Pump Plants, Volume I, SAFER - Long Term Inventory Model for BW R Loss-of-Coolant Analysis, October 1987.

3. NEDC-32950P, Compilation of Improvements to GENES SAFER ECCS-LOCA Evaluation Model, January 2000.

4. NEDC-23785-1-PA Rev. 1, The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-Of-Coolant Accident Volume Ill, SAFEWGESTR Application Methodology, October 1984.

(Jet Pump Plant - SAFER)

Calculations:

1. Limerick Generating Station, Units 1 and 2 SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis, NEDC-3217OP, May 1995.

2. Limerick Generating Station Units 1 and 2 ECCS-LOCA Evaluation for GE14, GE-NE-J1103793-09-01P, March 2001.

3. Letter from C. P. Bott to R. M. Butrovich, Limerick Units 1 and 2 SAFER/GESTR Analysis with GE13 Fuel, July 20, 1995.

Fuel Analyzed in Calculations: P8x8RI GE9, GE11/13 and GE14 Limiting Fuel Type: GE14 (note: P8x8R and GE9 are no longer in operation and are not considered for defining the limiting fuel type)

Limiting Single Failure: Div 2 DC Power Source Limiting Break Size and Location: Double-Ended Guillotine in a Recirculation Suction Pipe Reference Peak Cladding Temperature (PCT) - GE11/13 PCT = 1605°F Reference Peak Cladding Temperature (PCT) - GE14 PCT = 1670°F

Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of November 30,2005 Attachment 1 Peak Cladding Temperature Rack-Up Sheet, LGS U1 Page 2 of 2 MARGIN ALLOCATION A. PRIOR LOCA MODEL ASSESSMENTS 10 CFR 50.46 Report dated December 16,1996 (See Note 1) GE11/13 APCT = 45°F (GE11/13 only) 10 CFR 50.46 Report dated November 4, 1998 (See Note 2) GE11/13 APCT = -5°F (GE11/13 only) 10 CFR 50.46 Report dated July 22,1999 (See Note 3) GE11/13 APCT = 0°F (GE11113 only) 10 CFR 50.46 Regort dated December 18,2000 (See Note 41 G E l l / l 3 APCT = -5°F (GE11/13 only) 10 CFR 50.46 Report dated June 4,2001 (See Note 5) (GE11/13 G E l l / l 3 APCT = 5°F only) 10 CFR 50.46 Report dated December 18,2002 (See Note 6) G E l l / l 3 APCT = -5°F GE14 APCT = 10°F 10 CFR 50.46 Report dated December 16,2003 (See Note 7 ) GE11/13 APCT = -5°F GE14 APCT = -5°F 10 CFR 50.46 Report dated December 3,2004 (See Note 8) GE11/13 APCT = 0°F GE14 APCT = 0°F Net PCT (GE11/13) 1635 "F Net PCT (GE14) 1675 "F B. CURRENT LOCA MODEL ASSESSMENTS None Total PCT change from current assessments (GE11/13) CAPCT = 0°F Total PCT change from current assessments (GE14) CAPCT = 0°F Cumulative PCT change from current assessments (GE11/13) C I APCT I = 0°F Cumulative PCT change from current assessments (GE14) c, I APCT I = OOF Net PCT (GE11/13) 1635 "F Net PCT (GE14) 1675 "F

ATTACHMENT 2 10 CFR 50.46 Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of November 30,2005 Peak Cladding Temperature Rack-Up Sheet Limerick Generating Station, Unit 2

Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of November 30,2005 Attachment 2 Peak Cladding Temperature Rack-Up Sheet, LGS U2 Page I of 2 PLANT NAME: Limerick Generatina Station. Unit 2 ECCS EVALUATION MODEL: SAFERIGESTR-LOCA REPORT REVISION DATE: 11/30/05 CURRENT OPERATING CYCLE: 09 ANALYSIS OF RECORD Evaluation Model:

1. NEDC-23785-1-PA Rev. 1, The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-Of-Coolant Accident Volume 11, SAFER - Long Term Inventory Model for BW R Loss-Of-CoolantAnalysis, October 1984.

2. NEDC-30996P-A, SAFER Model for Evaluation of Loss-of-Coolant Accidents for Jet Pump and Non-jet Pump Plants, Volume I, SAFER - Long Term Inventory Model for BW R Loss-of-CoolantAnalysis, October 1987.

3. NEDC-32950P, Compilation of Improvements to GENES SAFER ECCS-LOCA Evaluation Model, January 2000.

4. NEDC-23785-1-PA Rev. 1, The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-Of-Coolant Accident Volume Ill, SAFER/GESTR Application Methodology, October 1984.

(Jet Pump Plant - SAFER)

Calculations:

1. Limerick Generating Station, Units 1 and 2 SAFERlGESTR-LOCA Loss-of-Coolant Accident Analysis, NEDC-3217OP, May 1995.

2. Limerick Generating Station Units 1 and 2 ECCS-LOCA Evaluation for GE14, GE-NE-J1103793-09-01P, March 2001.

3. Letter from C. P. Bott to R. M. Butrovich, Limerick Units 1 and 2 SAFER/GESTR Analysis with GE13 Fuel, July 20, 1995 Fuel Analyzed in Calculations: P8x8R, GE9, GE11/13 and GE14 Limiting Fuel Type: GE14 (note: P8x8R and GE9 are no longer in operation and are not considered for defining the limiting fuel type)

Limiting Single Failure: Div 2 DC Power Source Limiting Break Size and Location: Double-Ended Guillotine in a Recirculation Suction Pipe Reference Peak Cladding Temperature (PCT) - GEI 1/13 PCT = 1605°F Reference Peak Cladding Temperature (PCT) - GE14 PCT = 1670°F

Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of November 30,2005 Attachment 2 Peak Cladding Temperature Rack-Up Sheet, LGS U2 Page 2 of 2 MARGIN ALLOCATION A. PRIOR LOCA MODEL ASSESSMENTS 10 CFR 50.46 Report dated December 16,1996 (See Note 1) GEI 1/13 APCT = 45°F (GEI 1113 only) 10 CFR 50.46 Report dated November 4,1998 (See Note 2) GEI 1/13 APCT -5°F (GEI 1/13 only) 10 CFR 50.46 Report dated July 22,1999 (See Note 3) GEI 1/13 APCT = 0°F (GEI 1113 only) 10 CFR 50.46 Report dated December 18,2000 (See Note 4) GE11/13 APCT = -5°F (GEI 1113 only) 10 CFR 50.46 Report dated June 4,2001 (See Note 5) (GEI 1/13 GE11113 APCT = 5°F only) 10 CFR 50.46 Report dated December 18,2002 (See Note 6) GEI 1/13 APCT = -5°F GE14 APCT = 10°F 10 CFR 50.46 Report dated December 16,2003 (See Note 7) GE11/13 APCT = -5°F GE14 APCT = -5°F 10 CFR 50.46 Report dated December 3,2004 (See Note 8) GEI 1/13 APCT = 0°F GE14 APCT = 0°F Net PCT (GEI 1/13) 1635 OF Net PCT (GE14) 1675 OF B. CURRENT LOCA MODEL ASSESSMENTS None Total PCT change from current assessments (GEI If1 3)* CAPCT = 0°F Total PCT change from current assessments (GE14) CAPCT = 0°F Cumulative PCT change from current assessments (GEl1/13)* C , APCT, = 0°F Cumulative PCT change from current assessments (GEI4) C APCT =O"F Net PCT IGEI 1/13\* 1635 OF Net PCT (GE14) 1675 O F

• Limerick Generating Station, Unit 2 Cycle 9 core contains no GEI 1 or GE13 fuel. These fuel designs are tracked for purposes of potential re-insert in future cycles.

Attachment 3 10 CFR 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessment Notes Limerick Generating Station, Units 1 and 2

Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of November 4,2005 Attachment 3 Assessment Notes LGS U1 and U2 Page 1 of 2

1. Prior LOCA Assessment The referenced letter provided the total accumulation of peak clad temperature (PCT) changes or errors determined since the original 1995 SAFER analysis for Limerick Generating Station, Units 1 and 2. This letter reported that, since 1988, GE had been compiling changes and errors and provided that information to the NRC and licensees on an annual basis. The PCT impact for these errors for GE11/13 fuel was determined to be 45OF

[

Reference:

Letter from G. A. Hunger (PECO Nuclear) to U.S. NRC, Limerick Generating Station, Units 1 and 2 10 CFR 50.46 Reporting Requirements, dated December 16,1996.1

2. Prior LOCA Assessment The referenced letter provided clarification of the previous Limerick 50.46 report (see Note 1). This letter reported the previous GE LOCA errors to be related to SAFER omission of the bottom head drain and incorrect number of fuel rods error. This letter also reported that one of the errors contributing to the reported 45OF PCT impact in the previous Limerick Generating Station, Units 1 and 2 50.46 report (see Note 1) was actually corrected in the base analysis and identified a correction of -5OF PCT.

This letter constituted a 30 day report. The PCT impact for the correction for GE11/13 fuel was determined to be -5OF.

[

Reference:

Letter from G. D. Edwards (PECO Nuclear) to U.S. NRC, Limerick Generating Station, Units 1 and 2 10 CFR 50.46 Reporting Requirements, dated November 4, 1998.1

3. Prior LOCA Assessment The referenced letter reported a GE LOCA error related to SAFER CCFL at the upper spacer. This error was reported to be not applicable to GE11 and later fuel types. This letter constituted a 30 day report. The PCT impact for the new error for GE11/13 fuel was determined to be O°F.

[

Reference:

Letter from J. A. Hutton (PECO Nuclear) to US. NRC, Limerick Generating Station, Units 1 and 2 - Peach Bottom Atomic Power Station, Units 2 and 3 10 CFR 50.46 Reporting Requirements, dated July 22, 1999.1

4. Prior LOCA Assessment The referenced letter reported a GE LOCA error related to SAFER time steps. The PCT impact for the new error was determined to be -5OF for GE11/13 fuel.

[

Reference:

Letter from J. A. Hutton (PECO Nuclear) to U.S. NRC, Limerick Generating Station, Units 1 and 2 - Peach Bottom Atomic Power Station, Units 2 and 3 10 CFR 50.46 Reporting Requirements, dated December 18, 2000.1

Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of November 4,2005 Attachment 3 Assessment Notes Page 2 of 2

5. Prior LOCA Assessment The referenced letter reported the introduction of GE14 fuel at Limerick and the associated GE14 baseline PCT. The GE14 PCT (167OOF) bounds the G E l l f l 3 fuel.

The referenced letter also reported a GE LOCA error related to a SAFER pressure rate error. The PCT impact for this new error was determined to be 5OF. This PCT error applied only to the GEI 1/13 fuel types. This letter constituted a 30 day report.

The total PCT impact of this error on GE11/13 fuel was determined to be 5OF.

[

Reference:

Letter from J. A. Hutton (PECO Nuclear) to U.S. NRC, Limerick Generating Station, Units 1 and 2 10 CFR 50.46 Reporting Requirements, dated June 4, 2001.1

6. Prior LOCA Assessment The referenced letter provided an annual 50.46 report for Units 1 and 2. This letter reported GE LOCA errors related to a SAFER core spray sparger elevation error and a SAFER bulk water level error. The PCT impact for the new errors was determined to be O°F and -5OF, respectively, for GEI 1/13 fuel and 15OF and -5F, respectively, for GE14 fuel. The total PCT impact of these errors was determined to be -5OF for GEI 1/13 fuel and 70°F for GE14 fuel. The GE14 PCT continues to bound the GE11/13 PCT.

[

Reference:

Letter from Michael P. Gallagher (Exelon) to U.S. NRC, 10 CFR 50.46 Reporting Requirements, dated December 18, 2002.1

7. Prior LOCA Assessment The referenced letter provided an annual 50.46 report for Units 1 and 2. This letter reported a GE LOCA error related to a SAFER LevelNolume Table error. The PCT impact for the new error was determined to be -5OF for both GEI 1/13 fuel and GE14 fuel. The GE14 PCT continues to bound the GE11/13 PCT.

[

Reference:

Letter from Michael P. Gallagher (Exelon) to U S . NRC, 10 CFR 50.46 Reporting Requirements, dated December 16, 2003.1

8. Prior LOCA Assessment The referenced letter provided the annual 50.46 report for Units 1 and 2. This letter reported GE LOCA errors related to a GESTR file interpolation error, a SAFER computer platform change, a WEVOL S1 volume error, a SAFER separator pressure drop error and a new heat source. The PCT impact for the new errors was determined to be O°F for each error. The total PCT impact of these errors on GE11/13 fuel and GE14 fuel was determined to be O°F.

[

Reference:

Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. NRC, 10 CFR 50.46 Annual Report, dated December 03,2004.1

9. Current LOCA Assessment None