Letter Sequence Acceptance Review |
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CAC:MF9307, Addition of New Tech Spec on RCS Boron Limits and Revisions to Tech Spec 3.3.1 to Address Rwfs (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
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MONTHYEARML17053B3932017-01-17017 January 2017 License Amendment Request for the Transition to Westinghouse Core Design and Safety Analyses Project stage: Request ML17054C2262017-01-17017 January 2017 License Amendment Request for the Transition to Westinghouse Core Design and Safety Analyses - WCAP-18083-NP, Rev 0, Westinghouse Revised Thermal Design Procedure Uncertainty Calculations. Project stage: Request ML17054C2292017-01-17017 January 2017 License Amendment Request for the Transition to Westinghouse Core Design and Safety Analyses - Responses to NRC RAIs on August 2013 Methodology Transition LAR Submittal Project stage: Response to RAI ML17054C2272017-01-17017 January 2017 License Amendment Request for the Transition to Westinghouse Core Design and Safety Analyses - Alternative Source Term, Rev 1 Project stage: Request ML17151A9972017-03-0909 March 2017 Wolf Creek Revision 30 to Updated Final Safety Analysis Report, Chapter 3.0, Design of Structures, Components, Equipment, and Systems Project stage: Request WO 17-0026, Errata for License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses2017-03-22022 March 2017 Errata for License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Project stage: Request ML17100A2662017-04-18018 April 2017 Supplemental Information Needed for Acceptance of Requested Licensing Action Transition to Westinghouse Core Design and Safety Analyses Project stage: Acceptance Review ET 17-0011, Response to Supplemental Information Needed for Acceptance of Requested Licensing Action Transition to Westinghouse Core Design and Safety Analyses2017-05-0404 May 2017 Response to Supplemental Information Needed for Acceptance of Requested Licensing Action Transition to Westinghouse Core Design and Safety Analyses Project stage: Request ML17132A3632017-05-15015 May 2017 Acceptance of Requested Licensing Action License Amendment Request for the Transition to Westinghouse Core Design and Safety Analyses in Addition to Adopting of Alternative Source Term Project stage: Acceptance Review ML17136A3592017-05-22022 May 2017 Request for Withholding Information from Public Disclosure, 11/14/2016(CAW-16-4499), Affidavit Executed by James A. Gresham, Westinghouse Electric Company LLC Enclosure I of the Letter Dated 01/17/2017 Project stage: Withholding Request Acceptance ML17137A2862017-05-22022 May 2017 Request for Withholding Information from Public Disclosure, 11/14/16 (CAW-16-4500) Affidavit Executed by James A. Gresham, Westinghouse Electric Company LLC for Enclosure VI to the Letter Dated 1/17/17 Project stage: Withholding Request Acceptance ML17166A0382017-06-14014 June 2017 NRR E-mail Capture - Request for Additional Information - License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term Project stage: RAI ET 17-0016, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses2017-07-13013 July 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Project stage: Response to RAI ML17265A0142017-09-21021 September 2017 NRR E-mail Capture - Request for Additional Information - License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Project stage: RAI ML17291A7102017-10-17017 October 2017 NRR E-mail Capture - Request for Additional Information - License Amendment Request (LAR) for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term Project stage: RAI ET 17-0024, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term2017-10-18018 October 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term Project stage: Response to RAI ML17297B7972017-10-31031 October 2017 Request for Withholding Information from Public Disclosure (CAC No. MF9307; EPID L 2017-LLA-0211) Project stage: Withholding Request Acceptance ET 17-0025, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term2017-11-14014 November 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term Project stage: Response to RAI ML17331A1782017-12-0404 December 2017 Request for Additional Information License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternate Source Term (CAC No. MF9307; EPID L-2017-LLA-0211) Project stage: RAI WO 18-0004, Response to Request for Additional Information Re License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of ...2018-01-15015 January 2018 Response to Request for Additional Information Re License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of ... Project stage: Response to RAI ET 18-0004, Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-01-29029 January 2018 Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term Project stage: Supplement L-2018-077, Schedule for Re-Analysis of Turkey Point Licensing Basis Analyses Affected by PAD5 Implementation2018-03-27027 March 2018 Schedule for Re-Analysis of Turkey Point Licensing Basis Analyses Affected by PAD5 Implementation Project stage: Request ML18114A1162018-04-19019 April 2018 SAP-18-34, Supplemental 30 Day Responses to NRC Request for Additional Information Regarding Wolf Creek Generating Station Transition to Westinghouse Safety Analysis and Alternate Source Term Methodologies. Project stage: Supplement ET 18-0012, Operating Corp., Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-04-19019 April 2018 Operating Corp., Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term Project stage: Supplement ML18115A3522018-05-0303 May 2018 Request for Withholding Information from Public Disclosure, Affidavit Dated April 16, 2018 Supplemental 30 Day Responses to NRC RAI WCGS Transition to Westinghouse Safety AST Methodolgies Project stage: RAI ML18107A7562018-05-0303 May 2018 Regulatory Audit Summary License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term (CAC MF9307; EPID L-2017-LLA-0211) Project stage: Other ET 18-0018, Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-06-19019 June 2018 Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term Project stage: Supplement ML18183A5832018-07-23023 July 2018 Request for Withholding Information from Public Disclosure - 6/18/18 Affidavit Executed by Edmond J. Mercier, Westinghouse Electric Company Adoption of AST Amendment Request(Cac No. MF9307; EPID L-2017-LLA-0211) Project stage: Withholding Request Acceptance WO 18-0034, Operating Corp., Additional Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-08-0909 August 2018 Operating Corp., Additional Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term Project stage: Supplement ML18270A0942018-10-0404 October 2018 Request for Additional Information License Amendment Request for Transition to Westinghouse Methodology for Selected Accident and Transient Analyses Project stage: RAI ML18332A1772018-10-25025 October 2018 Email Slides for 10/30 Public Meeting Project stage: Request ML18313A2252018-10-25025 October 2018 Westinghouse Affidavit CAW-18-4828 - Application for Withholding Proprietary Information from Public Disclosure Project stage: Request ML18299A0492018-10-30030 October 2018 Accident Analyses Methodology Transition LAR Public Meeting Project stage: Meeting ML18304A1052018-11-0505 November 2018 Request for Additional Information License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses and Alternative Source Term (CAC No. MF9307; EPID L-2017-LLA-0211) Project stage: RAI WO 18-0047, Timeline for Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-11-15015 November 2018 Timeline for Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term Project stage: Response to RAI WO 18-0044, Clean Revised Technical Specification Pages for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-11-15015 November 2018 Clean Revised Technical Specification Pages for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term Project stage: Request ML18313A2542018-11-16016 November 2018 Summary of Public Meeting with Wolf Creek Nuclear Operating Corporation Regarding License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses for Wolf Creek Generating Station Project stage: Meeting ML18327A1342018-11-30030 November 2018 Request for Withholding Information from Public Disclosure, Affidavit Dated October 25, 2018, Executed by Mr. Paul A. Russ, Westinghouse (CAC No. MF9307; EPID L-2017-LLA-0211) Project stage: Withholding Request Acceptance ET 18-0035, Operating Corp., Supplemental Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term2018-12-0606 December 2018 Operating Corp., Supplemental Response to RAI for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term Project stage: Supplement ML18360A0342018-12-21021 December 2018 NRR E-mail Capture - Review Schedule for Wolf Creek Generating Station License Amend Request (LAR) for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term Project stage: Other ML19070A1162019-03-0505 March 2019 Westinghouse, Responses to NRC Request for Additional Information Documented in ADAMS Accession No. ML 18270A094 on the Core Design and Safety Analyses Methodology Transition Program Project stage: Response to RAI ML19070A1392019-03-0505 March 2019 Response to Request for Additional Information Related to Thermal Conductivity Degradation for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption. Project stage: Request ET 19-0008, Response to Request for Additional Information Related to Thermal Conductivity Degradation for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption.2019-03-0505 March 2019 Response to Request for Additional Information Related to Thermal Conductivity Degradation for License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption. Project stage: Response to RAI ML19099A1772019-04-16016 April 2019 Request for Withholding Information from Public Disclosure, 2/13/19 Affidavit Executed by Stephen Rigby, Westinghouse Electric Company LLC RAI Response Related to Adoption of Alternative Source Term (CAC MF9307; EPID L-2017-LLA-0211) Project stage: RAI ML19100A1222019-05-31031 May 2019 Issuance of Amendment No. 221 License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term Project stage: Approval 2018-10-25
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Category:Letter
MONTHYEARML24025A0992024-01-25025 January 2024 Withdrawal of Request for Exemption from Specific 10 CFR Part 73 Requirements ML24018A0792024-01-22022 January 2024 Individual Notice of Consideration of Issuance of Amendment to Renewed Facility Operating License, Proposed Nshcd and Opportunity for a Hearing (EPID L-2024-LLA-0007) (Letter) ML24018A1382024-01-18018 January 2024 Inservice Inspection Request for Information ML24018A2482024-01-18018 January 2024 License Amendment Request to Modify the Implementation Date of License Amendment No. 238 IR 05000482/20230042024-01-11011 January 2024 Integrated Inspection Report 05000482/2023004 ML23356A0722024-01-0404 January 2024 Supplemental Information Needed for Acceptance of Requested Licensing Actions Exemption from Specific 10 CFR Part 73N Requirements (EPID L-2023-LLE-0048) (Redacted Version) WO 23-0002, Operating Corp., Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-0082023-12-26026 December 2023 Operating Corp., Summary of Actions Implemented for EA-18-165, Confirmatory Order, NRC Inspection Report 05000482/2019010 and NRC Investigation Report 4-2018-008 ML23348A3662023-12-18018 December 2023 Notification of an NRC Fire Protection Baseline Inspection (NRC Inspection Report 05000482 2024012) and Request for Information ML23334A2502023-11-30030 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23299A2662023-11-29029 November 2023 Issuance of Amendment No. 238 Modified Implementation Date of License Amendment No. 237 ML23331A4972023-11-27027 November 2023 Supplement to License Amendment Request to Modify the 90-Day Implementation of License Amendment No. 237 ML23325A2112023-11-20020 November 2023 Submittal of Request for Exemption from Specific Provisions in 10 CFR 73.55 ML23320A2772023-11-16016 November 2023 License Amendment Request to Revise Ventilation Filter Testing Program Criteria in Technical Specification 5.5.11.b and Administrative Correction of Absorber in Technical Specification 5.5.11 ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23305A3472023-11-0101 November 2023 Revision of One Form That Implements the Radiological Emergency Response Plan (RERP) ML23292A3592023-10-19019 October 2023 License Amendment Request to Modify the 90-Day Implementation of License Amendment No. 237 ML23292A3572023-10-19019 October 2023 Operating Corporation, Request for Correction in Response to Issuance of Amendment No. 237 and Corresponding Safety Evaluation ML23277A2772023-10-11011 October 2023 Regulatory Audit Summary Concerning Review of Request Number CI3R-01 for Proposed Alternative Inspection Frequency for Containment Unbonded Post Tensioning System Components ML23284A2392023-10-11011 October 2023 NRC Initial Operator Licensing Examination Approval 05000482/2023301 ML23276B4552023-10-0303 October 2023 Technical Specification 5.6.8 Post Accident Monitoring (PAM) Report ML23264A8682023-09-21021 September 2023 Independent Spent Fuel Storage Installation Registration of Dry Storage Canister WC-EOS-37PTH-008-B4L, WC-EOS-37PTH-007-B4L, and WC-EOS-37PTH-002-B4L ML23256A2062023-09-14014 September 2023 Withdrawal of Requested Licensing Action Exemption from Specific 10 CFR Part 73 Requirements ML23165A2502023-08-31031 August 2023 Issuance of Amendment No. 237 Request for Deviation from Fire Protection Requirements ML23243A0002023-08-31031 August 2023 Wolf Generating Station - Withdrawal of Request for Exemption from Specific 10 CFR Part 73 Requirements IR 05000482/20230052023-08-23023 August 2023 Updated Inspection Plan for Wolf Creek Nuclear Operating Corporation, Unit 1 (Report 05000482/2023005) - Mid-Cycle Letter 2023 ML23232A0012023-08-19019 August 2023 Revision of One Procedure That Implements the Radiological Emergency Response Plan (Rerp). Includes EPP 06-009, Rev. 13 ML23221A3932023-08-0909 August 2023 Submittal of Request for Exemption from Specific 10 CFR Part 73 Requirements ML23220A4222023-08-0808 August 2023 Supplement to License Amendment Request (LAR) for Deviation from Fire Protection Program Requirements ML23201A1212023-08-0707 August 2023 Issuance of Amendment No. 236 Revision to Technical Specifications to Adopt TSTF-554, Revise Reactor Coolant Leakage Requirements ML23130A2902023-07-26026 July 2023 Issuance of Amendment No. 235 Revision to Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections IR 05000482/20230022023-07-11011 July 2023 Integrated Inspection Report 05000482/2023002 ML23167A0042023-06-26026 June 2023 Audit Plan to Support Review of Request for Alternative Containment Inservice Inspection Frequency IR 05000482/20234012023-06-21021 June 2023 Security Baseline Inspection Report 05000482/2023401 ML23171B1312023-06-20020 June 2023 Additional Supplement to License Amendment Request to Adopt TSTF-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ML23151A4162023-05-31031 May 2023 Revision of One Form That Implements the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS) ET 23-0006, CFR 50.55a Request Number CI3R-01 for the Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded Post-Tensioning System Components2023-05-17017 May 2023 CFR 50.55a Request Number CI3R-01 for the Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded Post-Tensioning System Components WO 23-0014, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-17017 May 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23132A1532023-05-12012 May 2023 Transmittal of 2022 Annual Financial Reports WM 23-0009, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1)2023-05-10010 May 2023 Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1) ML23135A1172023-05-0808 May 2023 Redacted Version of Revision 36 to Updated Safety Analysis Report ML23117A2112023-04-27027 April 2023 Annual Exposure Report (2022) ML23117A1342023-04-27027 April 2023 2022 Annual Radioactive Effluent Release Report Report 46 2024-01-04
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 18, 2017 Mr. Adam C. Heflin President, Chief Executive Officer, and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839
SUBJECT:
WOLF CREEK GENERATING STATION-SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE:
TRANSITION TO WESTINGHOUSE CORE DESIGN AND SAFETY ANALYSES (CAC NO. MF9307)
Dear Mr. Heflin:
By letter dated January 17, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17054C103), Wolf Creek Nuclear Operating Corporation (WCNOC) submitted a license amendment request (LAR) for Wolf Creek Generating Station (WCGS). The proposed LAR would replace the existing WCNOC methodology for performing core design, non-loss-of-coolant-accident (non-LOCA) and LOCA safety analyses to the standard Westinghouse U.S. Nuclear Regulatory Commission (NRC)-approved methodologies for performing these analyses and associated technical specification (TS) changes at WCGS. In addition, the LAR proposes to revise the WCGS licensing basis for adopting the alternative source term radiological analysis methodology in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.67, "Accident source term."
The purpose of this letter is to provide the results of the NRC staff's acceptance review of this LAR. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review.
The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with 10 CFR 50.90, an amendment to the license (including the TSs) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed LAR in terms of regulatory requirements and the protection of public health and safety and the environment.
A. Heflin In order to make the application complete, the NRC staff requests that WCNOC supplement the application to address the information requested in the enclosure by May 5, 2017. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staff's detailed technical review by separate correspondence.
The information requested and associated timeframe in this letter were discussed with Mr. William Muilenburg of your staff on April 10, 2017.
If you have any questions, please contact me at 301-415-3016 or via e-mail at Balwant.Singal@nrc.gov.
Sincerely,
~-+~k,~
Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482 Enclosure Supplemental Information Needed cc w/encl: Distribution via Listserv
SUPPLEMENTAL INFORMATION NEEDED LICENSE AMENDMENT REQUEST TO TRANSITION TO WESTINGHOUSE CORE DESIGN AND SAFETY ANL YSES WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482 By letter dated January 17, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17054C103), Wolf Creek Nuclear Operating Corporation (WCNOC) submitted a license amendment request (LAR) for Wolf Creek Generating Station (WCGS). The proposed LAR would replace the existing WCNOC methodology for performing core design, non-loss-of-coolant-accident (non-LOCA) and LOCA safety analyses to the standard Westinghouse U.S. Nuclear Regulatory Commission (NRC)-approved methodologies for performing these analyses and associated technical specification (TS) changes at WCGS.
The proposed amendment also revises the Updated Safety Analysis Report, Chapter 15, radiological consequence analyses and associated TSs using an updated accident source term consistent with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.67, "Accident source term."
The NRC staff has reviewed your application and concluded that the following supplemental information is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed LAR in terms of regulatory requirements and the protection of public health and safety and the environment.
The NRC staff recognizes that the information being requested is likely to be part of the radiological accident analysis calculations performed by the licensee, but not submitted as part of the LAR documents. The licensee has the option of providing the NRC staff a detailed summary of the analyses including inputs, assumptions, methodology technical basis, and results or submit the analyses clearly identifying the requested information, as necessary.
The supplemental information needed to complete the acceptance review is as follows:
- 1. Page 87 of Enclosure VI I to the letter dated January 17, 2017 (ADAMS Accession No. ML17054C229), states, in part:
For the fuel handling accident, two possible accident types are considered: (1) in containment and (2) in fuel building. For a fuel handling accident occurring in containment, the transport path is through the open equipment hatch. For a fuel handling accident occurring in the fuel building, the radionuclides released are Enclosure
drawn by the building ventilation system to the unit vent stack and eventually exhausted to the environment through the unit vent stack [emphasis added].
Section 50.36, 'Technical specifications," of 10 CFR requires the TSs to be derived from the analyses and evaluation included in the safety analysis report. Per WCGS TS Bases B 3.7.13, the emergency exhaust system's design basis is established by the consequences of the limiting design-basis accidents including the fuel handling accident (FHA) analysis.
A note in WCGS TS 3.7.13, "Emergency Exhaust System (EES)," allows the fuel building boundary to be opened intermittently under administrative controls, and Condition E allows two EES trains to be inoperable (due to an inoperable fuel building boundary) for 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> during the movement of irradiated fuel (when an FHA could occur). Enclosure IV to the letter dated January 17, 2017 (ADAMS Accession No. ML17054C227), Table 15B-1, "Conformance with Regulatory Guide [RG] 1.183 Main Section," the licensee states that the WCGS analysis conforms to RG 1.183, Revision 0, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors" (ADAMS Accession No. ML003716792),
Regulatory Position 5.1.2, "Credit for Engineered Safeguard Features," which states, in part, that credit may be taken for accident mitigation features that are required to be operable by TS. Therefore, when the fuel building boundary is inoperable (during movement of irradiated fuel) it should not be credited in the FHA analysis.
However, the technical analysis section of the LAR does not include consideration for a scenario where the FHA occurs while the fuel handling building boundary is open or not operable as allowed by the WCGS TS 3.7.13. For example, Enclosure VII, Table 4.1.2-3(a), "Calculated xtQ (sec/m 3 ) for the Emergency Control Room Intake Vent," which includes the atmospheric dispersion factor (x/Q) values determined for the control room and technical support center (TSC) intakes does not contain an xtQ values for a release from the fuel building boundary location to the control room and TSC.
To be consistent with the allowances of TS 3. 7 .13:
- a. Please submit for the NRG staff's review, a detailed summary of the results of the radiological consequences of an FHA that supports: 1) the fuel building boundary being open intermittently under administrative control and closed during an FHA and 2) an inoperable fuel building boundary (as allowed by Condition E) for the duration of the event. Please show that the dose results for these scenarios meet the limits in General Design Criterion (GDC) 19, "Control room," of 10 CFR 50 Appendix A and 10 CFR 50.67. In addition, please provide the inputs, assumptions, methodology and technical basis for the analysis.
or
- b. Please provide a proposed change to TS 3. 7.13 that is consistent with the analysis proposed in the LAR for the FHA analysis.
- 2. Page 51 of Enclosure VII to the letter dated January 17, 2017, states:
The fuel handling accident (FHA) analysis conservatively assumed that 100% of the fuel will not [emphasis added] meet the Footnote 11 from Regulatory Position 3.2 of Regulatory Guide 1.183. Footnote 11 contains burnup and linear heat generation rate limits for the gap fractions contained in Table 3 of Regulatory Guide 1.183 as well as an alternative method for determining gap fractions provided they bound the limiting projected plant-specific power history for the specific load. The analysis conforms with the position such that alternative gap fractions were used which were appropriate for the assumption of not meeting the Footnote 11 limits. These gap fractions are obtained from Regulatory Guide 1.25, as modified by NUREG/CR-5009, which provides higher, i.e.,
more conservative gap fractions than Regulatory Guide 1.183, which are not constrained by the Footnote 11 burnup limits as they can be applied to higher burnup to bound power history [emphasis added].
RG 1.183, Footnote 11 for Table 3, "Non-LOCA Fraction of Fission Product Inventory in Gap," states, in part:
The release fractions listed here have been determined to be acceptable for use with currently approved LWR [light-water reactor] fuel with a peak burnup up to 62,000 MWD/MTU [megawatt-days per metric ton of uranium] provided that the maximum linear heat generation rate does not exceed 6.3 kw/ft [kilowatt per foot] peak rod average power for burnups exceeding 54 GWD/MTU [gigawatt-days per metric ton of uranium]. As an alternative, fission gas release calculations performed using NRG-approved methodologies may be considered on a case-by-case basis. To be acceptable, these calculations must use a projected power history that will bound the limiting projected plant-specific power history for the specific fuel load.
The LAR also proposes to use Table 2, "PWR [pressurized-water reactor] Core Inventory Fraction Released into Containment" of RG 1.183, which is contained in Regulatory Position 3.2, "Release Fractions." Regulatory Position 3.2 has a footnote (Footnote 10) that states, in part:
The release fractions listed here have been determined to be acceptable for use with currently approved LWR fuel with a peak burnup up to 62,000 MWD/MTU.
Because of the cited text above from the LAR, it is unclear whether the proposed LAR meets the burnup limits in Footnote 10. Please clearly state the peak proposed burnup limits assumed in support of the analyses. If it is not less than or equal to 62,000 MWD/MTU (peak rod burnup), please provide a technical justification why Table 2 in RG 1.183 is applicable to burnups higher than 62,000 MWD/MTU. Note that RG 1.183, Regulatory Position 2 provides attributes of an acceptable alternative source term (AST) that the NRC staff will use for its review of an AST different than the one provided in RG 1.183.
- 3. Enclosure IV, Table C, "Conformance with Regulatory Guide 1.183, Appendix B (Fuel Handling Accident)," of letter dated January 17, 2017, states that the analysis in the LAR conforms with RG 1.183 Appendix B, Regulatory Position 5.3, which states:
If the containment is open during fuel handling operations (e.g., personnel air lock or equipment hatch is open), the radioactive material that escapes from the reactor cavity pool to the containment is released to the environment over a 2-hour time period.
The Table entitled "Regulatory Guide 1.194 Comparison" in the LAR states that the analysis in the LAR conforms with RG 1.194, [Revision 0, "Atmospheric Relative Concentrations for Control Room Radiological Habitability Assessments at Nuclear Power Plants" (ADAMS Accession No. ML031530505), Regulatory Position 3.2.4.2, which states:
Since leakage is more likely to occur at a penetration, analysts must consider the potential impact of building penetrations exposed to the environment within this modeled area. If the penetration release would be more limiting, the diffuse area source model should not be used.
Releases from personnel air locks and equipment hatches exposed to the environment, or containment purge releases prior to containment isolation, may need to be treated differently. It may be necessary to consider several cases to ensure that the xtQ value for the most limiting location is identified.
Section 50.36 of 10 CFR requires the TSs to be derived from the analyses and evaluation included in the safety analysis report. Per WCGS TS Bases B 3.9.4, the applicable safety analysis for the containment penetrations is the most severe radiological consequences from an FHA.
WCGS TS 3.9.4, "Containment Penetrations," allows many different containment configurations during Core Alterations and during the movement of irradiated fuel assemblies within containment, including allowances for the equipment hatch, emergency air lock and other containment penetrations to be unisolated under administrative controls. However, the NRC staff could not locate a complete evaluation for the FHA occurring in containment with the individual penetrations (allowed to be unisolated under administrative controls by the Note in TS 3.9.4(c) open.
To be consistent with the allowances of TS 3.9.4:
- a. Please submit for the NRC staff's review a detailed summary of the radiological consequences of an FHA in containment that supports the containment penetrations being open under administrative control and closed during an accident to justify the most severe radiological consequences from an FHA.
Please show that the dose results for these scenarios meet the limits in GDC 19 of 10 CFR Part 50, Appendix A and 10 CFR 50.67. In addition, please provide the inputs, assumptions, methodology and technical basis for the analysis.
or
- b. Please provide a proposed change to TS 3.9.4 that is consistent with the analysis proposed in the LAR for the FHA in containment.
- 4. Consistent with 10 CFR 50.90, an amendment to the license (including the TSs) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Issue 1, "Level of Detail Contained in LARs" of the NRC's Regulatory Issue Summary 2006-04, "Experience with Implementation of Alternative Source Terms," dated March 7, 2006 (ADAMS Accession No. ML053460347) states, in part, that an "AST amendment request should describe the licensee's analyses of the radiological and non-radiological impacts and provide a justification [emphasis added] for the proposed modification in sufficient detail to support review by the NRC staff."
In Tables 4.3-5 through 4.3-16 of Enclosure VII to letter dated January 17, 2017, the licensee provided a brief generic "Reason for [the] Change." In some cases the reasons for the change provided can also be used as a justification for the change. For example, the NRC staff understands that some values are justified because they "allow for additional surveillance testing margin" or are a result of conforming to a "Regulatory Guide update."
In other cases the "Reasons for [the] Change" do not provide justifications for the changes. For example the "RCS [Reactor Coolant System] mass, maximum" in Table 4.3-6 for the AST is 8.42E+5 lbm [pounds mass] and the CLB [current licensing basis] is 4.94E+5 lbm. The "Reason for [the] Change" is specified as a "Modeling update (not AST specific)." While this is the reason for the change, the NRC staff needs to understand the technical basis behind the change and why the new value or assumption is acceptable. In Table 4.3-8, the "Time of Control room isolation (including delays) (sec)" for the AST is 120 seconds, but this parameter is marked N/A for the CLB.
The "Reasons for [the] Change" provided is "No Change" although this appears to be a change. In these cases and for several others in Tables 4.3-5 through 4.3-16, the information provided does not justify the proposed changes.
Please review the "Reasons for [the] Change" and update Tables 4.3-5 through 4.3-16 to include a justification (a technical basis that addresses why these changes are acceptable) for the changes made to the CLB.
ML17100A266 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DRA/ARCB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME BSingal PBlechman US hoop RPascarelli BSingal DATE 4/13/17 4/12/17 4/17/17 4/18/17 4/18/14