ML13281A536

Meeting Slide for FENOC Presubmittal Guidance Checklist Part I

ML13281A536
Person / Time
Site:	Perry
Issue date:	10/15/2013
From:	Ellen Brown Office of Nuclear Reactor Regulation
To:	FirstEnergy Nuclear Operating Co
Brown E
References
Download: ML13281A536 (9)

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Pre-submittal Guidance Checklist - Section I Licensee/Plant: Perry Nuclear Power Plant Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

License Amendment Application 10 CFR 50.55a Request Exemption Request Other ______________________

Detailed Description of the Proposed Licensing Action:

Transition to GNF2 fuel is planned for the spring 2015 refueling outage. As part of this transition process, the design basis accident analyses have been revised to incorporate the new core source term associated with GNF2 fuel, and to utilize the non-proprietary RADTRAD computer code to replace the proprietary Polestar Applied Technology model previously used in the late 1990s for PNPPs pilot plant alternative Accident Source Term (AST) analyses and in a subsequent five percent power uprate amendment.

The proposed amendment is based on full implementation of an alternative Accident Source Term in the dose calculations for the BWR-applicable design basis events that do not already fully utilize the alternative Accident Source Term and that are addressed by Regulatory Guide 1.183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. USAR updates to the loss of coolant accident, main steam line break accident, and control rod drop accident calculation summaries will be provided for Nuclear Regulatory Commission review, along with one associated Technical Specification change to update the definition of Dose Equivalent Iodine 131. This amendment is being made pursuant to Title 10 Code of Federal Regulations Sections 50.59 and 50.67.

Planned Submittal Date:

November 2013 Requested Approval Date & Basis:

2/27/2015; Based on Fifteenth Refuel Outage, which begins in mid-February, during which GNF2 fuel would be loaded into the core.

Topics Addressed in Checklist:

Checklist contains the comparison for the total licensing action. Specific topics are not separated.

Other:

N/A

Pre-submittal Guidance Checklist - Section I Licensee/Plant: Perry Nuclear Power Plant Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

Preliminary Bases for the Proposed Licensing Action:

Technical:

The applicable design basis accidents are recalculated using the GNF2 source term in place of the GE14 source term, the RADTRAD code and methodology instead of Polestar Applied Technology, and the guidance in RG 1.183, resulting in a full implementation of the alternative AST.

Safety:

A comprehensive review of accident analysis, component and system analysis, and radiological dose consequences is in progress. The results of the completed safety review will be included in the license amendment request submittal.

Security:

The proposed amendment does not change or impact the current PNPP Security Plan; final confirmation will be obtained during development of the license amendment request submittal.

No Significant Hazards Consideration:

FENOC will perform a No Significant Hazards Consideration Analysis upon completion of all evaluations supporting the license amendment request. Based on initial reviews, it is expected that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in the margin of safety. The results of the completed analysis will be included in the license amendment request submittal.

Environmental: FENOC will provide an environmental consideration discussion in the license amendment request submittal. Based on initial reviews, it is expected that the proposed change will not impact the environment or the Environmental Plan. The results of the completed review will be included in the license amendment request submittal.

Regulatory Organization Interface:

Reactor Systems Accident Dose Security Electrical Probabilistic Risk Assessment Emergency Planning Instrument and Controls Fire Protection Technical Specifications Mechanical and Civil Piping and NDE Special Projects Balance of Plant Steam Generator Tube Integrity Health Physics Containment and Ventilation Component and Performance Testing DORL - Projects NMSS Environmental OE NSIR OGC

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

Preliminary Bases for the Topic:

Technical:

The applicable design basis accidents are recalculated using the GNF2 source term in place of the GE14 source term, the RADTRAD code and methodology instead of Polestar Applied Technology, and the guidance in RG 1.183, resulting in a full implementation of the alternative AST.

Safety:

A comprehensive review of accident analysis, component and system analysis, and radiological dose consequences is in progress. The results of the completed safety review will be included in the license amendment request submittal.

Security:

The proposed amendment does not change or impact the current PNPP Security Plan; final confirmation will be obtained during development of the license amendment request submittal.

No Significant Hazards Consideration:

FENOC will perform a No Significant Hazards Consideration Analysis upon completion of all evaluations supporting the license amendment request. Based on initial reviews, it is expected that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in the margin of safety. The results of the completed analysis will be included in the license amendment request submittal.

Precedent Relevance and Deltas to Proposed Licensing Action:

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Regulatory Current Proposed Comments Guidance and Staff Interpretations:

Standard Review Plan Section 6.5.2, Containment Spray As A Fission Product Cleanup System March 2007 15.6.5, Appendix B, Radiological 15.6.5, Appendix B, Radiological Consequences of a Design Basis Loss- Consequences of a Design Basis of-Coolant Accident: Leakage from Loss-of-Coolant Accident: Leakage Engineered Safety Feature from Engineered Safety Feature Components Outside Containment July Components Outside Containment 1981 July 1981 Regulatory Guide 1.183 is used in lieu of various Standard Review Plans, circa 1980s, that were previously used.

Branch Technical Positions Review Standards

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Regulatory Current Proposed Comments Guidance and Staff Interpretations:

Regulatory Guides 1.3, Assumptions Used for Evaluating 1.3, Assumptions Used for Evaluating No change in how Regulatory Guide (RG) the Potential Radiological the Potential Radiological 1.3 is utilized. RG 1.3 is used for equipment Consequences of a Loss of Coolant Consequences of a Loss of Coolant qualification (EQ), vital area access, post Accident for Boiling Water Reactors Accident for Boiling Water Reactors accident sampling system access, and June 1974 June 1974 containment purge isolation.

1.5, Assumptions Used for Evaluating RG 1.5 is replaced by RG 1.183.

the Potential Radiological Consequences of a Steam Line Break Accident for Boiling Water Reactors (Safety Guide 5) March 1971 1.52, "Design, Testing, and 1.52, "Design, Testing, and No change for RG 1.52.

Maintenance Criteria for Post Accident Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Engineered-Safety-Feature Cleanup System Air Filtration and Atmosphere Cleanup System Air Adsorption Units of Light-Water-Cooled Filtration and Adsorption Units of Light-Nuclear Power Plants March 1978 Water-Cooled Nuclear Power Plants March 1978 1.183, Alternative Radiological Source RG 1.183 replaces RG 1.5, TID-14844, and Terms for Evaluating Design Basis various Standard Review Plan sections and Accidents at Nuclear Power Reactors provides updated source term release July 2000 fractions, chemical species distribution, and removal mechanisms.

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Regulatory Current Proposed Comments Guidance and Staff Interpretations:

NUREGs NUREG-1465, Accident Source Terms Current LOCA calc methodology uses a for Light-Water Nuclear Power Plants Revised Accident Source Term (RAST)

February 1995 methodology developed by Polestar Applied Technology, based on the guidance given in NUREG-1465, to determine the post-accident radiological consequences. In the revised LOCA dose analysis based on the GNF2 source term, the RADTRAD computer code (NUREG/CR-6604) was used to estimate the containment release using RG 1.183 recommended source terms and assumptions. The control rod drop accident analysis replaces TID-14844 source term with a GNF2 source term using RADTRAD.

NUREG/CR-6604, RADTRAD: A RADTRAD was previously utilized for the Simplified Model for RADionuclide FHA calculation, which does not require NRC Transport and Removal And Dose review as part of this submittal.

Estimation June 1997 with Supplement 1, June 1999, and Supplement 2, October 2002 NUREG/CR-6189, A Simplified Model of Aerosol Removal by Natural Processes in Reactor Containments July 1996 NUREG/CR-5966, A Simplified Model NUREG/CR-5966 is used in place of of Aerosol Removal by Containment STARNAUA methodology for spray removal Sprays coefficient in the revised LOCA analysis.

Interim Staff Guidance

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Regulatory Current Proposed Comments Guidance and Staff Interpretations:

Other TID 14844, Calculation of Distance RG 1.183 replaces TID-14844 methodology Factors for Power and Test Reactor and provides updated source term release Sites, J. J. Nunno, et al March 23, fractions, chemical species distribution, and 1962 removal mechanisms.

Current LOCA calc methodology uses a Revised Accident Source Term (RAST) developed by Polestar Applied Technology, based on the guidance given in NUREG-1465, to determine the post-accident radiological consequences. In the revised LOCA dose analysis based on the GNF2 source term, the RADTRAD computer code (NUREG/CR-6604) was used to estimate the containment release using the RG 1.183 recommended source terms and assumptions.

NRC Generic Current Proposed Comments Communications:

NRC Bulletins NRC Generic Letters 2003-01 2003-01 GL 2003-1, Control Room Habitability

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Generic Current Proposed Comments Communications:

Regulatory Information 2001-19 RIS 2001-19, Deficiencies in the Documentation of Design Basis Radiological Analyses Submitted in Conjunction with Summaries License Amendment Requests 2006-04 RIS 2006-04, Experience With Implementation of Alternative Source Terms NRC Information Notices Other Facility Specific Current Proposed Comments Licensing Basis:

Numerous USAR sections are impacted by this change, including Updated Final Safety 1.8, 3.2, 3.5, 3.7, 3.10, 3.11, 6.2, 6.4, 6.5, 9.1, 9.3, 9A, 11.3, 12.3, Analysis Report 15.0, 15.4, 15.6, and 15A. Applicable USAR markups will be included with the amendment application.

Any TS Bases changes will be processed in accordance with the TS Technical Specifications Bases Control Program following NRC approval of the amendment Bases application. Examples of the changes will be included in the amendment application.

Technical Requirements Manual Fire Hazards Analysis Report

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

Facility Specific Current Proposed Comments Licensing Basis:

NRC Safety Evaluation Reports Previous NRC Safety Evaluations for Amendment 103, 112, and NRC Correspondence 122 discuss current design basis radiological consequences.

Regulatory Commitments STARDOSE (LOCA) RADTRAD 3.0.3 (LOCA, CRDA) Utilized for accident dose analysis.

Computer Codes RADTRAD 3.0.2 (MSLB)

STARNAUA STARNAUA Existing STARNAUA data is used in calculating main steam line deposition.

Other Industry Guidance: Current Proposed Comments Codes and Standards Topical Reports NEDO-31400A, Safety NEDO-31400A, Safety Evaluation for Eliminating the Evaluation for Eliminating the Boiling Water Reactor Main Boiling Water Reactor Main Steam Isolation Valve Steam Isolation Valve Closure Function and Scram Closure Function and Scram Function of the Main Steam Function of the Main Steam Line Radiation Monitor Line Radiation Monitor October 1992 October 1992 Industry Initiatives and Guidelines Other