ML15344A294

/12/10 Presentation Slides for Pre-Submittal Teleconference - Proposed LAR for Charging System in Response to Confirmatory Order EA-13-188

ML15344A294
Person / Time
Site:	Millstone
Issue date:	12/10/2015
From:	Craft W Dominion, Dominion Nuclear Connecticut
To:	Richard Guzman Plant Licensing Branch 1
Guzman R
References
TAC MF7108
Download: ML15344A294 (10)

Text

Pre-Submittal Teleconference Millstone Power Station Unit 2 (MPS2)

License Amendment Request (LAR) for Charging System in Response to Confirmatory Order EA-13-188 December 10, 2015

Agenda

• Purpose of LAR

• Scope of LAR

• AREVA Analysis for Long-Term IOPORV

• Application of Single Failure Criterion

• Applicable Regulatory Issue

• Schedule Pg. 2

Purpose of LAR

• LAR required by Confirmatory Order EA-13-188 (8/26/15)

Compliance Item #2:

By no later than February 15, 2016, DNC will submit a license amendment request to the NRC addressing the use of charging pumps in the analysis of the inadvertent opening of the PORVs.

• DNC has completed an analysis of the long-term response for FSAR Section 14.6.1, Inadvertent Opening of a Pressurized Water Reactor Pressurizer Pressure Relief Valve (IOPORV) with no credit for Charging flow

• LAR will include proposed changes to Technical Specification (TS) Section 3/4.5.2 and FSAR Chapter 14

• LAR meets regulatory criteria and will preserve health and safety of the public Pg. 3

Scope of LAR

• LAR will include more than the analysis of the FSAR Section 14.6.1 IOPORV event required by the Confirmatory Order

• LAR will propose to remove Charging from TS 3/4.5.2, Emergency Core Cooling Systems

- Charging pumps appear in Surveillance Requirement (SR) 4.5.2.e as an ECCS subsystem with Operability requirements:

By verifying the delivered flow of each charging pump at the required discharge pressure is greater than or equal to the required flow when tested pursuant to Specification 4.0.5.

- LAR will demonstrate that Charging does not meet the four criteria in 10CFR50.36 for inclusion in the Technical Specifications

- Change to TS 3/4.5.2 Bases will be provided for information Pg. 4

Scope of LAR (Continued)

• LAR will request NRC review and approval of changes to FSAR Chapter 14

- Proposed FSAR changes are based on the FSAR prior to the 2009 FSAR change made by DNC under 10 CFR 50.59

- Proposed FSAR change reflects the new long-term IOPORV analysis, which does not credit charging (discussed on next slide)

- Proposed change to FSAR Section 14.0.11 clarifies the application of single failure for MPS2 Pg. 5

AREVA Analysis for Long-Term IOPORV

• Analysis completed for long-term response to an IOPORV for MPS2

- Uses NRC-approved S-RELAP5 SBLOCA methodology in EMF-2328, Rev. 0, with Supplement 1

- Assumes open pressurizer safety valve which bounds two open PORVs

- Credits two HPSI pumps with no flow from charging pumps

- Results demonstrate no core uncovery

• LAR will include analysis description and plots of key results

• With this new analysis, flow from the charging pumps is not credited in any FSAR Chapter 14 safety analyses for event mitigation Pg. 6

Application of Single Failure Criterion

• IOPORV event in FSAR Section 14.6.1 is a moderate frequency, or ANS Condition II, event

• Single failure criterion does not apply to Moderate Frequency events

- Consistent with MPS2 FSAR Section 14.0.11

- Consistent with NRC SRP (NUREG-0800) Chapter 15

• Postulating a single failure for the IOPORV event is a Small Break LOCA (FSAR Section 14.6.3) with acceptance criteria governed by 10 CFR 50.46

• MPS2 does not apply a single failure to the IOPORV event (with the exception of the reactor protection system) Pg. 7

Applicable Regulatory Issue

• Draft Revision 1 to RIS 2005-29 Anticipated Transients That Could Develop Into More Serious Events

- Draft Revision 1 to RIS 2005-29 provides regulatory positions on the IOPORV event that is addressed in the MPS2 LAR.

- Demonstration of no long term core uncovery demonstrates that the transient meets the non-escalation criteria Pg. 8

Schedule

• DNC will submit the LAR by February 15, 2016

• Review schedule

• To maintain compliance with the Confirmatory Order, Operability Determination and Standing Order are in place for the Charging system and will remain in place until NRC makes a final determination on the LAR Pg. 9

Acronym List

• ANS American Nuclear Society

• CFR Code of Federal Regulations

• DNC Dominion Nuclear Connecticut

• ECCS Emergency Core Cooling System

• FSAR Final Safety Analysis Report

• IOPORV Inadvertent Opening of a Pressurizer Pressure Relief Valve

• LAR License Amendment Request

• MPS2 Millstone Power Station, Unit 2

• PWR Pressurized Water Reactor

• RIS Regulatory Issue Summary

• SBLOCA Small Break Loss of Coolant Accident

• SR Surveillance Requirement

• SRP Standard Review Plan

• TS Technical Specifications Pg. 10