Text

Response to Supplemental Information Needed for Acceptance of Requested Licensing Action Transition to Westinghouse Core Design and Safety Analyses
	ML17130A915
Person / Time
Site:	Wolf Creek
Issue date:	05/04/2017
From:	Mccoy J; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ET 17-0011
	Download: ML17130A915 (66)
	v • d • e

Jaime H. McCoy Vice President Engineering W$LFCREEK

'NUCLEAR OPERATING CORPORATION May 4, 2017 ET 17-0011 LI. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 17-0001, dated January 17, 2017, from J. H. McCoy, WCNOC, to USNRC

2) Letter dated April 18, 2017, from B. K. Singal, USNRC, to A. C. Heflin, WCNOC, "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)"

Subject:

Docket No. 50-482: Response to Supplemental Information Needed for Acceptance of Requested Licensing Action Re:

Transition to Westinghouse Core Design and Safety Analyses To Whom It May Concern:

Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) application to mvise the Technical Specifications to support transition to the Westinghouse Core Design and Safety Analysis methodologies.

The amendment request included revising the Wolf Creek Generating Station (WCGS) licensing basis by adopting the Alternative Source Term radiological analysis methodology in accordance with 10 CFR 50.67, "Accident Source Term."

Reference 2 provided a Nuclear Regulatory Commission (NRC) request for supplemental information related to the application. The Attachment and Enclosures to this letter provide V\\/CNOC's response to the request for additional information.

The additional information does not expand the scope of the application and does not impact the no significant hazards consideration determination presented in Reference 1. In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," a copy of this submittal is bBing provided to the designated Kansas State official.

P.O. Box 411 I Burlington, KS 66839 /Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

ET 17-0011 Page 2 of 3 This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Cynthia R. Hafenstine _(620) 364-4204.

Sincerely, Jaime H. McCoy JHM/rlt

Attachment:

Response to Supplemental Information Needed

Enclosures:

I Proposed Technical Specification Changes (Markup)

II Revised Technical Specification Pages Ill Proposed Technical Specification Bases Changes (for information only) cc:

K. M. Kennedy (NRC), w/a, w/e B. K. Singal (NRC), w/a, w/e K. S. Steves (KDHE), w/a, w/e (Non-Proprietary only)

N. H. Taylor (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

ET 17-0011 Page 3 of 3 STATE OF KANSAS

)

) SS COUNTY OF COFFEY )

Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By

~7f 7l147 Jaime Hfa.cCoy Vice President Engineerin~

SUBSCRIBED and sworn to before me this Jf'i day of ~, 2017.

~* (}

-()

qj.. :.*,*~fflf;:*...

GAYLE SHEPHEARD f- ' _ _xJ)~~jJ

j*e~~~):J MyAppointmen!Expires NQt8 ublic v

1..... t,~~.if.'......

July 24. 2019 Expiration Date 1

//~1j0!o!C/

Attachment to ET 17-0011 Page 1 of 52 Response to Supplemental Information Needed Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) application to revise the Wolf Creek Generating Station (WCGS) Technical Specifications (TS). The proposed amendment 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 TS changes at WCGS. In addition, Reference 1 proposed a revision tc1 the WCGS licensing basis by adopting the Alternative Source Term (AST) radiological analysis methodology in accordance with 10 CFR 50.67, "Accident Source Term." Reference 2 provided a request for supplemental information related to the application. The specific NRG re!quests are provided in italics.

Request:

1.

Page 87 of Enclosure VII to the Jetter dated January 17, 2017 (ADAMS Accessions 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 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 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during the movement of irradiated fuel (when an FHA could occur). Enclosure IV to the Jetter 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 x/Q (sec!m3J 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 x/Q values for a release from the fuel building boundary location to the control room and TSC.

Attachment to ET 17-0011 Page 2 of 52 To be -consistent with the allowances of TS 3. 7. 13:

a.

Please submit for the NRG staffs 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 (GOG) 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.

Response

a. Regarding the fuel building boundary being open intermittently under administrative controls and closed during an FHA, the referenced administrative controls are aligned with Standard Technical Specifications (STS) (NUREG-1431) and the STS Bases. Specifically, the STS Bases define the intended administrative controls:

The LCO is modified by a Note allowing the fuel building boundary to be opened intermittently under administrative controls. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for fuel building isolation is indicated.

As shown above, the STS Bases state that, any administrative controls implemented must require that a dedicated operator, who is in continuous communication with the control room, be able to rapidly close the opening when a need for fuel building isolation is indicated and thus any opening has no impact on the operability of the fuel building boundary.

Note that, while these specific administrative controls are associated with the fuel building boundary, the wording for the referenced administrative controls are specifically endorsed as an effective way to minimize the impact on the control room boundary within Section 2.7.2 of Regulatory Guide 1.196.

The referenced administrative controls for breaching a building boundary have been accepted by the NRC in order to credit a corresponding boundary. For example, WCGS's current licensing basis documented in Section 15.7.4 of the USAR credits the fuel building boundary for the duration of the event, consistent with the administrative controls defined in the Technical Specifications.

Thus, the current note in TS 3. 7.13, which allows for the fuel building boundary to be opened intermittently under administrative controls, ensures that any fuel building boundary opening will be rapidly closed at the beginning of an FHA. For

Attachment to ET 17-0011 Page 3 of 52 the proposed changes, the rapid closure will continue to ensure that the fuel building boundary will be operable for the duration of the FHA and therefore the proposed WCGS Technical Specifications are consistent with the analysis discussed in Section 4.3.12 of Enclosure IV to ET 17-0001.

b. In order to address the concern for the inoperable fuel building, as allowed in Condition 'E,' the Enclosures of this letter provide the TS proposed changes, TS markup, and Bases markup for TS 3. 7.13, as requested; Only the affected pages of the TS and Bases are provided. The changes proposed* and provided in Reference 1 are in BLUE colored font. The markups provided in response to Reference 2 are in RED colored font. The markups provided reflect a change in completion time of Condition 'E' from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to immediately and the deletion of Condition 'F.'

Request:

2.

Page 51 of Enclosure VII to the Jetter 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 qetermining 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 bumup 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 GWDIMTU [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 1 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 MWDIMTU.

Because of the cited text above from the LAR, it is unclear whether the proposed LAR meets the burn up limits in Footnote 10. Please clearly state the peak proposed burn up limits assumed in

L Attachment to ET 17-0011 Page 4 of 52 support of the analyses. If it is not Jess than or equal to 62,000 MWD/MTU (peak rod bumup),

please provide a technical justification why Table 2 in RG 1. 183 is applicable to bumups higher than 62, 000 MWDIMTU. Note that RG 1. 183, Regulatory Position 2 provides attributes of an acceptable alternative source term (AST) that the NRG staff will use for its review of an AST different than the one provided in RG 1. 183.

R.esponse:

The peak rod burnup limit of 62,000 MWD/MTU from Footnotes 10 and 11 of Regulatory Guide (RG) 1.183 remains applicable. The nuclide gap fractions modeled in the fuel handling accident (FHA) analysis are derived from RG 1.25 and NUREG/CR-5009 to provide increased operating margin for peak linear power density in assemblies with higher average burnup.

The gap fractions from RG 1.25 are applicable for a peak linear power density of 20.5 kW/ft for the highest power assembly and average burnup of 25,000 MWD/MTU.

NUREG/CR-5009 evaluated the RG 1.25 gap fractions for extended burnup conditions to a batch average burnup of 50 GWD/MTU with the only difference being a 20% increase in the 1-131 gap fraction.

Therefore, the gap fractions modeled in the Wolf Creek FHA, which are the RG 1.25 gap fractions as modified by NUREG/CR-5009, are applicable for a peak linear power density of 20.5 kW/ft for average burnups exceeding 50 GWD/MTU.

Request:

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 Jock 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 Jocks 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 x/Q 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

l Attachment to ET 17-0011 Page 5 of 52 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 NRG 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 NRG 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 GOG 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.

Response

The fuel handling accident (FHA) doses in the alternate source term (AST) license amendment request (LAR) consist of a simplified model of release from the fuel building to the environment through the unit vent. This bounds a similar release from the containment equipment hatch to the environment for a FHA occurring inside containment.

For the case of the containment being open, the release pathway is from containment to the auxiliary building through a limiting composite pathway and from the auxiliary building to the ccmtrol room via inleakage. The limiting composite pathway considered a conservatively low mixing volume available in both containment and the auxiliary building, the maximum expected ponetration flow area available, and the minimum travel distance of all containment penetrations at,>le to be unisolated under administrative controls and the personnel hatch. The containment volume of 1.25E +06 ft3 is 50% of the minimum free containment volume per RG 1.183, Appendix B, Position 5.5. A conservative auxiliary building volume of 7.0E+04 ft3 is modeled based on the volume of the rooms located between the containment penetration and the control room.

R13garding th_e emergency air lock, this pathway is isolated during fuel movement and will not serve as a release point following a FHA. Specifically, the note associated with LCO 3.9.4.b regarding temporary closure devices was approved per the Safety Evaluation for Amendment Number 74 (Accession Number ML02204037). As stated in the Safety Evaluation, The staff finds that the proposed change provides an effective means of preventing the release of

Attachment to ET 17-0011 Page 6 of 52 radioactive material following a fuel handling accident." Thus, a release from the emergency air lock is not analyzed for the FHA Since containment is not pressurized during a FHA, there may be two scenarios that act as a driving force for activity.

The heating, ventilation, and air conditioning (HVAC) system is operating in the auxiliary building with flows of 4875 cfm and 6675 cfm for normal mode and emergency mode, respectively, based on design flow rates. The HVAC exhausting to the environment from the auxiliary building would bring in an equivalent amount of flow from the containment to the auxiliary building. The activity would then be available for leakage into the control room directly from the auxiliary building without any dispersion or filtration credited. Exhausted activity from the auxiliary. building through the unit vent would also be available for inflow to the control room.

The HVAC system is not operating in the auxiliary building. There is no exhaust from the auxiliary building to the environment and the only driving force for flow from containment to the auxiliary building is the equivalent of assumed leakage from the auxiliary building to the control room.

For both scenarios, the containment is assumed to be isolated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after event initiation based on administrative controls maintained by Wolf Creek to close the containment penetrations following a FHA inside containment. This 2-hour time period is significantly longer than the 30 minute time for administrative controls defined in Footnote 3 of Appendix B in Regulatory Guide 1.183. Thus, it is acceptable to assume such a time.

Leakage into the control room from the auxiliary building is 60 cfm based on a conservative estimate of leakage through the airtight control room envelope door and leakage from the operating train of HVAC damper.

A~so, switchover from normal mode HVAC operation to emergency mode HVAC operation in both the auxiliary building and control room is assumed at 30 minutes after event initiation. This 30-minute time is significantly longer than the generally accepted time of 10 minutes, consistent with Section 3.1.2.d of the Wolf Creek USAR, to identify an event and manually switch to emergency mode. In emergency mode, the control room is pressurized such that inleakage from the auxiliary building to the control room is terminated.

The dose results of the scenarios compared to the dose result of the simplified release model from the fuel building is presented in the following table. As shown, the simplified release model from the fuel building remains bounding compared to the release of activity through the limiting composite pathway to the auxiliary building.

Attachment to ET 17-0011 Page 7 of 52 Control Room Doses from Simplified Environmental Release Model

..------1------

D o s e = 0.92 rem TEDE

!=~===?====

Limit =

5 rem TEDE Request:

Control Room Dose with Auxiliary Building Transfer Pathway Control Room Doses for HVAC in Operation 0.77 rem TEDE 5 rem TEDE Control Room Dose with Auxiliary Building Transfer Pathway Control Room Doses for HVAC not in Operation 0.012 rem TEDE 5 rem TEDE

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 NRG 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 NRG 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 NRG 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 NIA 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.

R1~sponse:

n1e following tables from the Wolf Creek Nuclear Operating Company AST LAR (Reference 1) were updated in order to expand the reason for input changes between the current licensing basis (CLB) and the alternate source term (AST) analyses. Updates to the 'Reason for Change' are provided in RED colored font.

For the 'Reason for Change' categorized as iUpdated Calculations' or 'Values were recalculated for the AST analysis', the intent is to clarify that the CLB input values were based upon historical Wolf Creek methodology and, in order to support

Attachment to ET 17-0011 Page 8 of 52 the AST project, the current Westinghouse methodology and current plant input values were used to update the parameter values in order to be aligned with Westinghouse methodology.

Doses Analvses Parameters Summary Tables (excerpt from Enclosure IV)

Table 4.3-5 Control Room and Control Building Parameters AST CLB Reason for Change Control room volume (ft3) 100,000 100,000 No change Control building volume (ft3) 239,000 239,000 No change Normal ventilation flow rates (cfm)

Unfiltered makeup flow rate from 13,050 13,050 No change environment to control building Unfiltered makeup flow rate from 1950 1950 No change environment to control room Unfiltered inleakage to control room 50 10 Increased to allow for additional surveillance testina marain Emergency mode of operation flow rates prior to operator action (cfm)

Filtered makeup flow rate from 1350 1350 No change environment to control building Filtered makeup flow rate from control 550 550 No change building to control room Unfiltered makeup flow rate from 400 300 Increased to allow for environment to control building additional surveillance testina marain Unfiltered makeup flow rate from control 550 550 No change building to control room Unfiltered inleakage to control room 50 20 Increased to allow for additional surveillance testina marain Filtered control room recirculation flow 1250 1250 No change Emergency mode of operation flow rates following operator action (cfm)

Filtered makeup flow rate from 675 675 No change environment to control building Filtered makeup flow rate from control 550 550 No change building to control room Unfiltered makeup flow rate from 400 300 Increased to allow for environment to control building additional surveillance testina marain Unfiltered makeup flow rate from control 0

0 No change building to control room

Attachment to ET 17-0011 Page 9 of 52 Table 4.3-5 Control Room and Control Building Parameters AST CLB Unfiltered inleakage to control room 50 20 Filtered control room recirculation flow 1250 1250 Operator action time to terminate failed train 90 90 of filtered makeup flow from start of event (minutes)

Filter efficiencies(%)

Elemental iodine 95 95 Organic iodine 95 95 Particulates 95 95 Isolation setpoint for control room air supply 2.12E-03 N/A radiation monitors (GKRE0004 and GKRE0005) (µCi/cc Xe-133)

Delay to switch to emergency mode of 60 N/A operation following receipt of isolation signal (seconds)

Control room breathing rate for duration of the 3.5E-04 3.47E-04 ewent (m3/sec)

Control room occupancy factors 0-24 hours 1.0 1.0 1 -4 days 0.6 0.6 4-30 days 0.4 0.4

/

Reason for Change Increased to allow for additional surveillance testing margin No change No change No change No change No change Change due to modeling of CR for all accidents (not AST specific)

Change due to modeling of CR for all accidents (not AST specific)

Regulatory Guide update (not AST soecific)

No change No change No change

Attachment to ET 17-0011 Page 10 of 52 Table 4.3-6 Assumptions Used for Main Steamline Break Analysis AST CLB l~CS activity See Table 4.3-1 a See Table 4.3-1 b Initial secondary system activity See Table 4.3-1a See Table 4.3-1 b Pre-accident iodine spike factor 60 60 Accident-initiated iodine spike appearance rate calculations Letdown flow, maximum (gpm) 132 75 Letdown flow decontamination 100 N/A

(%)

RCS leakage (gpm) 11 1

Spike factor 500 500 Duration of accident-initiated 8

8 iodine spike (hr)

RCS mass, maximum (lbm) 8.42E+05 4.94E+05 Equilibrium appearance rates (Ci/min) 1-130 9.87E-03 N/A 1-131 4.39E-01 N/A 1-132 1.98E+OO N/A 1-133 8.93E-01 N/A 1-134 9.65E-01 N/A 1-135 8.17E-01 N/A Iodine chemical form of releases

(%)

Elemental 97 N/A Reason for Change Updated calculations Updated calculations No change Modeling of maximum versus nominal value (not AST soecific)

Not modeled in current analysis of records (AORs)

Value increase to model both the identified and unidentified leakage from the RCS (not AST soecific)

No change No change Modeling of maximum versus nominal value (not AST soecific)

Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Attachment to ET 17-0011 Page 11 of 52 Table 4.3-6 Assumptions Used for Main Steamline Break Analysis AST CLB Organic 3

N/A Particulate 0

N/A Approximate timing of events Safety injection (SI) signal (sec) 30 N/A Control room isolation (including 90 N/A delay) (sec)

Faulted SG releases all initial 2

N/A activity (min)

RHR cooling takes over 12 N/A (releases from intact SGs terminated) (hr)

RCS cooled below 212°F 34 N/A (releases from faulted SG terminated) (hr)

Mass transfer data Initial faulted SG release (in first 165,000 164,500 2 minutes) (lbm)

Total primary-to-secondary leakage Leakage through faulted SG 1

1 to atmosphere (gpm)

Leakage into intact SGs 450 N/A (gpd, total)

Steam Released from Intact SGs to Atmosphere 0 to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 419,340 404,452 2 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (lbm) 1,310,269 945,973 Reason for Change Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Values were recalculated. The difference is not siqnificant.

No change Not modeled in current AORs Values were recalculated for the AST analysis.

Values were recalculated for the AST analvsis.

Attachment to ET 17-0011 Page 12 of 52 Table 4.3-6 Assumptions Used for Main Steamline Break Analysis AST CLB 3.99E+05 4.94E+05 RCS Mass, Minimum (lbm)

CLB does not use maximum and minimum Faulted SG Mass, Maximum (lbm) 1.65E+05 164,500 Intact SGs Mass, Minimum 2.47E+05 286,500 (lbm, Total)

SG iodine water/steam partition 100 100 coefficient Moisture carryover(%)

0.25 0.25 Control room atmospheric dispersion factors (sec/m3)

Intact SGs 0 - 0.025 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months 2.55E-02 N/A 0.025 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1.04E-03 N/A 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 7.46E-04 N/A 8-24 hours 3.03E-04 NIA 24-96 hours 1.90E-04 N/A 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 1.39E-04 N/A Faulted SG 0 - 0.025 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months 2.11 E-03 N/A 0.025 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 6.12E-04 N/A 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 4.38E-04 N/A 8-24 hours 1.79E-04 N/A 24-96 hours 1.14E-04 N/A 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 8.94E-05 N/A Reason for Change Input change (minimum vs nominal)

Values were recalculated. The difference is not sianificant.

Values were recalculated for the AST analysis.

No change No change Not modeled in current AO Rs Not modeled in current AO Rs Not modeled in current AO Rs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AO Rs Not modeled in current AO Rs Not modeled in current AORs Not modeled in current AO Rs Not modeled in current AORs Not modeled in current AO Rs

Attachment to ET 17-0011 Page 13 of 52 Table 4.3-6 Assumptions Used for Main Steamline Break Analysis AST CLB TSC atmospheric dispersion factors (sec/m3}

Intact SGs 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4.83E-04 N/A 2-8 hours 2.58E-04 N/A 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 9.63E-05 N/A 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 6.45E-05 NIA 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 4.89E-05 N/A Faulted SGs 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.BOE-04 N/A 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1.80E-04 N/A 8-24 hours 6.44E-05 N/A 24-96 hours 4.42E-05 N/A 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 3.22E-05 N/A Reason for Change Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AO Rs Not modeled in current AORs Not modeled in current AO Rs Not modeled in current AORs Not modeled in current AO Rs Not modeled in current AORs

Attachment to ET 17-0011 Page 14 of 52 Table 4.3-7 Assumptions Used for Loss of Non-Emergency AC Power Analysis Reason for AST CLB Change RCS activity See Table 4.3-1a See Table 4.3-1 b Updated calculations Initial secondary system activity See Table 4.3-1a See Table 4.3-1 b Updated calculations Accident-initiated iodine spike appearance rate calculations Letdown flow, maximum (gpm) 132 75 Modeling of maximum versus nominal value (not AST specific)

Letdown flow decontamination (%)

100 NIA Not modeled in current AORs RCS leakage (gpm) 11 1

Value increase to model both the identified and unidentified leakage from the RCS (not AST soecific)

Spike factor 500 NIA Not modeled in current AORs Duration of accident-initiated iodine 8

NIA Not modeled in spike (hr) current AORs RCS mass, maximum (lbm) 8.42E+05 4.94E+05 Modeling of CLB does not maximum versus use max and min nominal value (not AST specific)

Equilibrium appearance rates (Ci/min) 1-130 9.87E-03 NIA Not modeled in current AORs 1-131 4.39E-01 NIA Not modeled in current AORs 1-132 1.98E+OO NIA Not modeled in current AORs 1-133 8.93E-01 NIA Not modeled in current AORs 1-134 9.65E-01 NIA Not modeled in current AORs 1-135 8.17E-01 NIA Not modeled in current AORs

Attachment to ET 17-0011 Page 15 of 52 Table 4.3-7 Assumptions Used for Loss of Non-Emergency AC Power Analysis Reason for AST CLB Change Iodine chemical form of releases(%)

Elemental 97 N/A Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Organic 3

N/A Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Particulate 0

N/A Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Time RHR cooling matched decay heat 12 8

Updated (SG releases terminated) (hr) calculations showed an increase in the time necessary for RHR system heat removal capabilities to match decay heat.

Mass transfer data Total primary-to-secondary leakage 1

1 No change (gpm)

Steam released from SGs to atmosphere 0 to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 419,846 549,000 Values were recalculated for the AST analysis.

2 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (lbm) 1,352,918 1,030,000 Values were recalculated for the AST analysis.

RCS mass, minimum (lbm) 3.99E+05 4.94E+05 Input change CLB does not (minimum vs use max and min nominal)

Plant total SG mass, minimum (lbm)

Attachment to ET 17-0011 Page 16 of 52 Table 4.3-7 Assumptions Used for Loss of Non-Emergency AC Power Analysis Reason for AST CLB Change Until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 3.30E+05 382,000 Values were recalculated. A lower minimum is conservative.

After 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 4.85E+05 382,000 The updated mass is based on the operators maintaining the SG level on-span for a reasonable time following an event.

SG iodine water/steam partition 100 100 No change coefficient Moisture carryover(%)

0.25 0.25 No change Control room isolation None NIA No change Control room atmospheric dispersion factors (sec/m3)

O - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.55E-2 N/A Not modeled in current AO Rs 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1.84E-2 N/A Not modeled in current AORs 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 7.46E-3 N/A Not modeled in current AORs 24-96 hours 4.72E-3 NIA Not modeled in current AORs 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 3.43E-3 NIA Not modeled in current AORs TSC atmospheric dispersion factors (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4.83E-04 NIA Not modeled in current AORs 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2.58E-04 N/A Not modeled in current AORs 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 9.63E-05 NIA Not modeled in current AORs 24-96 hours 6.45E-05 N/A Not modeled in current AORs 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 4.89E-05 NIA Not modeled in current AORs

Attachment to ET 17-0011 Page 17 of 52 Table 4.3-8 Assumptions Used for Locked Rotor Analysis AST CLB Core activity See Table 4.3-1a See Table 4.3-1 b Failed fuel (% of Core) 5 5

Melted fuel(% of Core) 0 0

Peaking factor 1.65 1.65 Gap fractions 1-131 0.08 0.12 Kr-85 0.10 0.30 Other iodines and noble gases 0.05 0.10 Iodine chemical form of releases(%)

Elemental 97 NIA Organic 3

N/A Particulate 0

N/A Time RHR cooling matched decay 12 8

heat (SG releases terminated) (hr)

Mass transfer data Total primary-to-secondary 1

1 leakage (gpm)

Steam released from SGs to atmosphere Reason for Change Updated calculations No change No change No change Modeling change for AST based on requlatorv guidance.

Modeling change for AST based on requlatorv guidance.

Modeling change for AST based on regulatorv quidance.

Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Updated calculations showed an increase in the time necessary for RH R system heat removal capabilities to match decay heat.

No change

Attachment to ET 17-0011 Page 18 of 52 Table 4.3-8 Assumptions Used for Locked Rotor Analysis AST CLB 0 to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 419,846 5.49E+05 2 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (lbm) 1,352,918 1.03E+06 RCS mass, minimum (lbm) 3.99E+05 4.94E+05 Plant total SG mass, minimum (lbm)

Until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 3.30E+05 3.82E+05 After 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 4.85E+05 3.82E+05 SG iodine water/steam partition 100 100 coefficient Moisture carryover(%)

0.25 0.25 Time of Control room isolation 120 NIA (including delays) (sec)

Control room atmospheric dispersion factors (seclm3)

HVAC Flows Except for Control Room Unfiltered lnleakage 0 - 0.0333 hours0.00385 days 0.0925 hours 5.505952e-4 weeks 1.267065e-4 months 2.55E-02 NIA 0.0333 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1.04E-03 NIA 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 7.46E-04 NIA 8-24 hours 3.03E-04 NIA 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 1.90E-04 NIA 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 1.39E-04 NIA Control Room Unfiltered lnleakage 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.55E-02 NIA 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1.84E-02 NIA Reason for Change Values were recalculated for the AST analysis.

Values were recalculated for the AST analvsis.

Input change (minimum vs nominal)

Values were recalculated. A lower minimum is conservative.

The updated mass is based on the operators maintaining the SG level on-span for a reasonable time followina an event.

No change No change Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AO Rs Not modeled in current AO Rs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs

Attachment to ET 17-0011 Page 19 of 52 Table 4.3-8 Assumptions Used for Locked Rotor Analysis AST 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 7.46E-03 24-96 hours 4.72E-03 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 3.43E-03 TSC atmospheric dispersion factors (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4.83E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2.SBE-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 9.63E-05 24-96 hours 6.45E-05 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 4.89E-05 CLB Reason for Change NIA Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs

Attachment to ET 17-0011 Page 20 of 52 Table 4.3-9 Assumptions Used for Rod Ejection Analysis AST Core activity See Table 4.3-1a Failed fuel (%of core) 10 Melted fuel (% of core) 0.25 Peaking factor 1.65 Gap fractions Iodines and noble gases 0.10 Alkali metals 0.12 Containment Leakage Activity released to containment from failed fuel (%)

Iodines and noble gases 10 Alkali metals 12 Activity released to containment from melted fuel (%)

Iodines and alkali metals 50 Noble gas 100 Iodine chemical form of releases (%)

Elemental 4.85 Particulate 95 Organic 0.15 Containment leak rates (weight %/day) 0-24 hours 0.2 1 - 30 days 0.1 Containment volume (ft3) 2.5E+06 Reason for CLB Change See Table 4.3-1b Updated calculations 10 No change 0.25 No change 1.65 No change 0.10 No change N/A Not modeled in current AORs.

Alkali metals were included per regulatory auidance.

10 No change N/A Not modeled in current AORs.

Alkali metals were included per regulatory auidance.

50 No change 100 No change 91 Modeling change for AST 5

Modeling change for AST 4

Modeling change for AST 0.2 No change 0.1 No change 2.5E+06 No change

Attachment to ET 17-0011 Page 21 of 52 Table 4.3-9 Assumptions Used for Rod Ejection Analysis AST Removal of airborne activity in None containment (other than leakage or decay)

SI signal (sec) 150 Time of control room isolation (including 210 delays) (sec)

Control room atmospheric dispersion factors (sec/m3) 0 - 0.0583 hours0.00675 days 0.162 hours 9.63955e-4 weeks 2.218315e-4 months 2.11 E-03 0.0583 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

6. 12E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 4.38E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1.81 E-04 24-96 hours 1.29E-04 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 9.65E-05 TSC atmospheric dispersion factors (sec/m3}

0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 3.91 E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2.66E-04 8-24 hours 9.62E-05 24-96 hours 7.05E-05 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 5.52E-05 Primary-to-Secondary Leakage Activity released to RCS from failed fuel

(%)

Iodines and noble gases 10 Alkali metals 12 Reason for CLB Change None No change N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs 10 No change N/A Not modeled in current AO Rs.

Alkali metals were included per regulatory auidance.

Attachment to ET 17-0011 Page 22 of 52 Table 4.3-9 Assumptions Used for Rod Ejection Analysis AST Activity released to RCS from melted fuel

(%)

Iodines and alkali metals 50 Noble gas 100 Iodine chemical form of releases (%)

Elemental 97 Organic 3

Particulate 0

Time RHR cooling matched decay heat 12 (SG releases terminated) (hr)

Mass transfer data Total primary-to-secondary leakage 1

(gpm)

Steam released from SGs to atmosphere Reason for CLB Change 50 No change 100 No change N/A Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

N/A Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

8 Updated calculations showed an increase in the time necessary for RHR system heat removal capabilities to match decay heat.

1 No change

Attachment to ET 17-0011 Page 23 of 52 Table 4.3-9 Assumptions Used for Rod Ejection Analysis AST 0 to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 419,846 2 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (lbm) 1,352,918 RCS mass, minimum (lbm) 3.99E+05 Plant total SG mass, minimum (lbm)

Until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (lbm) 3.30E+05 After 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months {lbm) 4.85E+05 SG iodine water/steam partition 100 coefficient Moisture carryover(%)

0.25 Time of Control room isolation (including 120 delays) (sec)

Control room atmospheric dispersion factors (sec/m3)

HVAC Flows Except for Control Room Unfiltered lnleakage 0 - 0.0333 hours0.00385 days 0.0925 hours 5.505952e-4 weeks 1.267065e-4 months 2.55E-02 0.0333 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1.04E-03 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 7.46E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3.03E-04 24-96 hours 1.90E-04 Reason for CLB Change 48,600 (140 sec)

Values were recalculated for the AST analysis.

N/A Values were recalculated for the AST analysis.

CLB did not model releases for this time period.

4.94E+05 Input change (minimum vs nominal) 4.16E+05 Values were recalculated. A lower minimum is conservative.

4.16E+05 The updated mass is based on the operators maintaining the SG level on-span for a reasonable time following an event.

100 No change 0.25 No change N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AO Rs N/A Not modeled in current AO Rs N/A Not modeled in current AO Rs

Attachment to ET 17-0011 Page 24 of 52 Table 4.3-9 Assumptions Used for Rod Ejection Analysis AST 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 1.39E-04 Control Room Unfiltered lnleakage 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.55E-02 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1.84E-02 8-24 hours 7.46E-03 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 4.72E-03 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 3.43E-03 TSC atmospheric dispersion factors (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4.83E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2.58E-04 8-:- 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 9.63E-05 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 6.45E-05 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 4.89E-05 Reason for CLB Change N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AO Rs N/A Not modeled in current AO Rs N/A Not modeled in current AO Rs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs

Attachment to ET 17-0011 Page 25 of 52 Table 4.3-10 Assumptions Used for Letdown Line Break Analysis AST CLB RCS activity See Table 4.3-1a See Table 4.3-1 b Accident-initiated iodine spike appearance rate calculations Letdown flow, maximum (gpm) 132 195 Letdown flow decontamination(%)

100 N/A RCS leakage (gpm) 11 N/A Spike factor 500 N/A Duration of accident-initiated iodine 8

N/A spike (hr)

Reactor coolant mass, maximum 8.42E+05 4.94E+05 (lbm)

Equilibrium appearance rates (Ci/min) 1-130 9.87E-03 N/A 1-131 4.39E-01 N/A 1-132 1.98E+OO N/A 1-133 8.93E-01 N/A 1-134 9.65E-01 N/A 1-135 8.17E-01 N/A Iodine chemical form of releases(%)

I Reason for Change Updated calculations Value in AST analysis is the maximum flow through a pipe.

The CLB analysis value is the flow from both sides of a double ended rupture. For iodine spike calculations, a total flow from both sides of a rupture is not appropriate to assume.

Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Input change (maximum vs nominal)

Not modeled in current AO Rs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs Not modeled in current AORs

Attachment to ET 17-0011 Page 26 of 52 Table 4.3-10 Assumptions Used for Letdown Line Break Analysis AST CLB Elemental 97 N/A Organic 3

N/A Particulate 0

N/A Reactor coolant mass, minimum (lbm) 3.99E+05 NIA Flow rate out of broken line (gpm) 141 141 Iodine and alkali metal airborne fraction 0.18 N/A Maximum RCS letdown pressure 600 2200

{psig)

Maximum RCS letdown temperature 380 286 (oF)

Time to isolate break flow (terminating 30.167 30.167 releases) (min)

Control room isolation None N/A Control room atmospheric dispersion N/A factor (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.11 E-03 N/A Reason for Change Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

Not modeled in current AORs No change Not modeled in current AORs Modeling update to more accurately represent the conditions of the ruptured line (not AST specific)

Modeling update to more accurately represent the conditions of the ruptured line (not AST specific)

No change No change Not modeled in current AORs

Attachment to ET 17-0011 Page 27 of 52 Table 4.3-1 O Assumptions Used for Letdown Line Break Analysis AST CLB TSC atmospheric dispersion factor (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.80E-04 N/A Reason for Change Not modeled in current AORs

Attachment to ET 17-0011 Page 28 of 52 Table 4.3-11 Assumptions Used for SGTR Dose Analysis AST RCS activity See Table 4.3-1a Initial secondary system activity See Table 4.3-1a Pre-accident iodine spike factor 60 Accident-initiated iodine spike appearance rate calculations Letdown flow, maximum (gpm) 132 Letdown flow decontamination(%)

100 RCS leakage (gpm) 11 Spike factor 335 Reactor coolant mass, maximum 8.42E+05 (lbm)

Duration of accident-initiated iodine 8

spike (hr)

Equilibrium appearance rates (Ci/min) 1-130 9.87E-03 1-131 4.39E-01 1-132 1.98E+OO 1-133 8.93E-01 1-134 9.65E-01 1-135 8.17E-01 Iodine chemical form of releases(%)

Reason for CLB Change See Table 4.3-1c Updated calculations See Table 4.3-1c Updated calculations 60 No change 120 Modeling of maximum versus nominal value (not AST specific)

N/A Not modeled in current AORs 1

Value increase to model both the identified and unidentified leakage from the RCS (not AST specific) 335 No change 5.05E+5 Input change (maximum vs nominal) 8 No change N/A Not modeled in current AORs 3.54E-1 Values were recalculated for the AST analysis.

1.36E+OO Values were recalculated for the AST analysis.

7.72E+OO Values were recalculated for the AST analysis.

7.02E-01 Values were recalculated for the AST analysis.

6.63E-01 Values were recalculated for the AST analysis.

Attachment to ET 17-0011 Page 29 of 52 Table 4.3-11 Assumptions Used for SGTR Dose Analysis AST Elemental 97 Organic 3

Particulate 0

Approximate timing of events (sec)

See Table 2.7.3-2 in Enclosure I of this LAR (For dose input, exclude the 100 seconds of steady-state operation.)

Time of control room isolation (including 120 delay) (sec)

Time to complete control room isolation 600 with SI signal from event initiation (sec)

Reason for CLB Change N/A Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

N/A Updated consistent with Regulatory Guide 1.183. Specific chemical forms were not modeled in the CLB.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

N/A Not modeled in current AORs N/A Not modeled in current AORs

Attachment to ET 17-0011 Page 30 of 52 Table 4.3-11 Assumptions Used for SGTR Dose Analysis AST Transient mass transfer data Non-flashed break flow (lbm) 0 - 52 seconds 2227.5 52 - 1102 seconds 43, 129.9 1102 - 2902 seconds 88,387.2 2902 - 3502 seconds 32,991.2 3502 - 3846 seconds 18,224.8 3846 - 5155 seconds 61,523.0 CLB N/A N/A N/A N/A N/A N/A Reason for Change Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

Attachment to ET 17-0011 Page 31 of 52 Table 4.3-11 Assumptions Used for SGTR Dose Analysis AST 5155 - 7527 seconds 41, 166.4 Flashed break flow (lbm) 0 - 52 seconds 438.9 52 - 1102 seconds 2,901.8 1102 - 2902 seconds 13,432.1 2902 - 3502 seconds 2,635.6 3502 - 3846 seconds 606.1 Reason for CLB Change N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

Attachment to ET 17-0011 Page 32 of 52 Table 4.3-11 Assumptions Used for SGTR Dose Analysis AST Steam released from ruptured SG (lbm) 0 - 52 seconds 188, 100 52 - 1102 seconds 27,469.2 1102 - 2902 seconds 149,850.8 2902 - 7527 seconds 0

7527 - 43,200 seconds 2530 Reason for CLB Change N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

Attachment to ET 17-0011 Page 33 of 52 Table 4.3-11 Assumptions Used for SGTR Dose Analysis AST Steam released from intact SGs (lbm) 0 - 52 seconds 562,650 52 - 1102 seconds 69,877.5 1102 - 3502 seconds 0

3502 - 3846 seconds 94,307.4 3846 - 5155 seconds 130,799.9 5155 - 7527 seconds 98, 156.3 Reason for CLB Change N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

NIA Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

Attachment to ET 17-0011 Page 34 of 52 Table 4.3-11 Assumptions Used for SGTR Dose Analysis AST 7527 - 43,200 seconds 1,645,930 Reactor coolant mass, minimum (lbm) 3.99E+05 Ruptured SG mass, minimum (lbm) 7.00E+04 Intact SGs mass, minimum (lbm, total) 1.95E+05 Condenser iodine and alkali metal 100 removal factor SG iodine water/steam partition 100 coefficient Moisture carryover(%)

0.25 Control room atmospheric dispersion factors (sec/m3) 0 - 0.0333 hours0.00385 days 0.0925 hours 5.505952e-4 weeks 1.267065e-4 months 2.55E-02 0.0333 - 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months s<1>

1.04E-03 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 7.46E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3.03E-04 24-96 hours 1.90E-04 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 1.39E-04 l

Reason for CLB Change N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

5.05E+05 CLB Input change does not use (minimum vs max and min nominal)

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comoarison.

N/A Values were recalculated for the AST analysis.

CLB values did not provide a direct comparison.

N/A Not modeled in current AORs N/A Not modeled in current AORs 0.25 No change N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AO Rs

Attachment to ET 17-0011 Page 35 of 52 Table 4.3-11 Assumptions Used for SGTR Dose Analysis AST TSC atmospheric dispersion factors (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4.83E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2.58E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 9.63E-05 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 6.45E-05 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 4.89E-05 Reason for CLB Change N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs N/A Not modeled in current AORs Note: (1) The control room unfiltered inleakage continues to be associated with the normal mode xtQ of 2.55E-02 sec/m3 until completion of control room isolation from a safety injection signal at 10 minutes.

Attachment to ET 17-0011 Page 36 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST Core activity (containment See Table 4.3-1a leakage, ECCS leakage, and RWST back-leakage)

RCS activity (containment See Table 4.3-1a purge)

Fuel release fractions and timing Nuclide Group Gap Early Release In-Vessel Phase Phase Fraction Fraction Noble gases 0.05 0.95 Iodines 0.05 0.35 Alkali metals 0.05 0.25 Tellurium metals 0.00 0.05 Barium and strontium 0.00 0.02 Noble metals 0.00 0.0025 Cerium 0.00 0.0005 Lanthanides 0.00 0.0002 Duration of phases Phase Onset Duration Gap release 30 sec 0.49167 hr Early in-vessel 0.5 hr 1.3 hr SI signal (sec) 0 Reason for CLB Change See Table 4.3-1 b Updated calculations See Table 4.3-1 b Updated calculations 100% of the core activity is Modeling released immediately change for followinq event initiation AST Gap Early Release In-Vessel Phase Phase Fraction Fraction N/A N/A Modeling change for AST NIA N/A Modeling change for AST N/A N/A Modeling change for AST N/A N/A Modeling change for AST N/A N/A Modeling change for AST N/A N/A Modeling change for AST N/A N/A Modeling change for AST NIA N/A Modeling change for AST Onset Duration N/A N/A Modeling change for AST N/A N/A Modeling change for AST N/A Modeling update (not AST specific)

Attachment to ET 17-0011 Page 37 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST Time of control room 120 isolation (including delays)

(sec)

Containment Leakage Iodine chemical form of releases(%)

Elemental 4.85 Organic 0.15 Particulate 95 Containment volume, 2.7E+06 maximum (ft3)

% Sprayed 85

% Unsprayed 15 CLB 0

91 4

5 2.5E+06 85 15 Reason for Change Modeling update to conservatively model a delay in ventilation switchover (not AST specific)

Modeling change for AST Modeling change for AST Modeling change for AST Since a maximum volume is conservative, the larger value listed in USAR Section 6.2.1.5.3 was modeled.

No change No change

Attachment to ET 17-0011 Page 38 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST Mixing between sprayed 6.94E+04 and unsprayed containment volumes (cfm)

Start of fan cooler mixing 2

(min)

Containment leak rates (weight %/day) 0-24 hours 0.2 1 - 30 days 0.1 Spray timing Initiation (min) 2 Termination (hr) 5 Spray removal coefficients CLB 8.50E+04 N/A 0.2 0.1 0

9.55 Reason for Change The CLB value corresponds to two hydrogen mixing fans operating in slow speed.

While a mixing rate of 85,000 cfm will still be present following the event, the value has been conservatively reduced to the flow rate from one containment cooler fan.

Not modeled in current AO Rs.

No change No change The time to credit containment spray was conservatively increased to account for the delay to reaching full flow conditions.

Conservative time used in AST analysis.

Attachment to ET 17-0011 Page 39 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST Organic iodine spray 0.0 removal coefficient (hr *1)

Elemental iodine spray removal coefficient calculations Spray removal 10 coefficient (hr"\\

DF < 200 Gas phase mass 3

transfer coefficient (m/min)

Time of fall of the 0.146 spray drops (min)

Volume flow rate 658.66 of sprays (m3/hr)

Containment 6.5E+04 sprayed volume (m3)

Mass-mean 0.00116 diameter of the spray drops (m)

Particulate spray removal coefficient calculations Spray removal 5

coefficient (h-\\

DF < 50 Reason for CLB Change 0.0 No change 10 No change N/A Not modeled in current AO Rs.

N/A Not modeled in current AO Rs.

711.13 Conservative low flow modeled.

6.0E+04 The maximum containment volume increased from 2.5E+06 ft3 to 2. 7E+06 ft3. Since 85% of the containment is sprayed, the sprayed volume increased proportionally with the increase in total volume.

N/A Not modeled in current AO Rs.

0.45 Values (Used DFs up to 100) recalculated for the AST analysis.

Attachment to ET 17-0011 Page 40 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST Spray removal 0.5 coefficient (h(\\

DF > 50 Drop fall height 35.966 (m)

Volume flow rate 658.66 of sprays (m3/hr)

Containment 6.5E+04 sprayed volume (m3)

Ratio of dimensionless collection efficiency to average spray drop diameter Prior to DF 10 of 50 (m-1)

After DF of 1

50 (m-1)

Particulate sedimentation 0.1 removal coefficient (h(\\

DF < 1000 Reason for CLB Change N/A Not modeled in current AO Rs.

36.017 Conservative rounding 711.13 Conservative low flow modeled.

6.0E+04 WCGS input change The maximum containment volume increased from 2.5E+06 ft3 to 2. 7E+06 ft3. Since 85% of the containment is sprayed, the sprayed volume increased proportionally with the increase in total volume.

N/A Not modeled in current AO Rs.

Attachment to ET 17-0011 Page 41 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST pH of sump

~ 7.0 Control room atmospheric dispersion factors (sec/m3) 0 - 0.0333 hours0.00385 days 0.0925 hours 5.505952e-4 weeks 1.267065e-4 months 2.11 E-03 0.0333 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 6.12E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 4.38E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1.81 E-04 24-96 hours 1.29E-04 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 9.65E-05 TSC atmospheric dispersion factors (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 3.91 E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2.66E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 9.62E-05 24-96 hours 7.05E-05 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 5.52E-05 Reason for CLB Change

~ 8.5 The pH value was changed to 7.0 to be consistent with the iodine retention assumptions contained within the analysis.

5.30E-04 Updated calculations 5.30E-04 Updated calculations 5.30E-04 Updated calculations 3.6E-04 Updated calculations 6.60E-05 Updated calculations 0

Updated calculations 2.2E-04 Updated calculations 2.2E-04 Updated calculations 1.17E-04 Updated calculations 2.04E-05 Updated calculations 0

Updated calculations

Attachment to ET 17-0011 Page 42 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST ECCS Leakage Iodine chemical form of releases(%)

Elemental 97 Organic 3

Particulate 0

Sump volume (gal) 4.60E+05 Time to initiate ECCS 0

recirculation (min)

ECCS leakage to auxiliary 2

building (gpm)

Iodine airborne fraction 0.10 Auxiliary building exhaust 90 filter efficiency (all forms of iodine)(%)

Reason for CLB Change N/A Updated consistent with Regulatory Guide 1.183.

Specific chemical forms were not modeled in the CLB.

N/A Updated consistent with Regulatory Guide 1.183.

Specific chemical forms were not modeled in the CLB.

N/A Updated consistent with Regulatory Guide 1.183.

Specific chemical forms were not modeled in the CLB.

4.60E+05 No change 28.2 Conservative I y assume no delay in leakage in the AST analysis.

2 No change 0.10 No change 90 No change

Attachment to ET 17-0011 Page 43 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST Control room atmospheric dispersion factors (sec/m3)

O - 0.0333 hours0.00385 days 0.0925 hours 5.505952e-4 weeks 1.267065e-4 months 2.11E-03 0.0333 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 6.12E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 4.38E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1.79E-04 24-96 hours 1.14E-04 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 8.94E-05 TSC atmospheric dispersion factors (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.80E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1.80E-04 8-24 hours 6.44E-05 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 4.42E-05 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 3.22E-05 RWST Back-Leakage RWST initial gas volume, 3.54E+05 minimum (gal)

Time to initiate ECCS 0

recirculation (min)

ECCS leakage to RWST 3.8 (gpm)

Iodine airborne fraction 0.10 Release from RWST gas 3.8 space (gpm)

Iodine chemical form of releases (%)

Elemental 97 Reason for CLB Change 1.10E-04 Updated calculations 1.10E-04 Updated calculations 1.10E-04 Updated calculations 6.80E-05 Updated calculations 1.70E-05 Updated calculations 0

Updated calculations 2.2E-04 Updated calculations 2.2E-04 Updated calculations 1.17E-04 Updated calculations 2.04E-05 Updated calculations 0

Updated calculations NIA Not modeled in current AO Rs 28.2 Conservative I y assume no delay in leakage in the AST analysis.

3.8 No change 0.10 No change 3.8 No change 91 Regulatory Guide Update

Attachment to ET 17-0011 Page 44 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST Organic 3

Particulate 0

Control room atmospheric dispersion factors (sec/m3) 0 - 0.0333 hours0.00385 days 0.0925 hours 5.505952e-4 weeks 1.267065e-4 months 1.03E-03 0.0333 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 6.80E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 6.19E-04 8-24 hours 2.27E-04 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 1.96E-04 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 1.53E-04 TSC atmospheric dispersion factors (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1.87E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1.25E-04 8-24 hours 4.51 E-05 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 3.33E-05 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 2.61 E-05 Containment Purge RCS activity released(%)

100 Iodine chemical form of releases(%)

Elemental 97 Organic 3

Particulate 0

RCS mass, maximum 8.42E+05 (lbm)

Containment volume, 2.5E+06 minimum (ft3)

Reason for CLB Change 4

Regulatory Guide Update 5

Regulatory Guide Update 1.10E-04 Updated calculations 1.10E-04 Updated calculations 1.10E-04 Updated calculations 6.80E-05 Updated calculations 1.70E-05 Updated calculations 0

Updated calculations 2.2E-04 Updated calculations 2.2E-04 Updated calculations 1.17E-04 Updated calculations 2.04E-05 Updated calculations 0

Updated calculations 100 No change 91 Regulatory Guide Update 4

Regulatory Guide Update 5

Regulatory Guide Update 4.94E+05 Input change CLB does not use (maximum vs maximum and minimum nominal) 2.5E+06 No change

Attachment to ET 17-0011 Page 45 of 52 Table 4.3-12 Assumptions Used for LOCA Analysis AST Maximum purge flow rate, 4,680 unfiltered (cfm)

Duration of purge release 10 (sec)

Control room atmospheric dispersion factors (sec/m3) 0 - 0.0333 hours0.00385 days 0.0925 hours 5.505952e-4 weeks 1.267065e-4 months 2.11E-03 0.0333 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 6.12E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 4.38E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1.79E-04 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 1.14E-04 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 8.94E-05 TSC atmospheric dispersion factors (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.80E-04 2 - 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1.80E-04 8 - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 6.44E-05 24 - 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 4.42E-05 96 - 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 3.22E-05 Reason for CLB Change 4,680 No change 8

Conservative!

y longer purge time modeled in AST analysis.

1.10E-04 Updated calculations 1.10E-04 Updated calculations 1.10E-04 Updated calculations 6.80E-05 Updated calculations 6.60E-05 Updated calculations 0

Updated calculations 2.2E-04 Updated calculations 2.2E-04 Updated calculations 1.17E-04 Updated calculations 2.04E-05 Updated calculations 0

Updated calculations

Attachment to ET 17-0011 Page 46 of 52 Table 4.3-13 Assumptions Used for Waste Gas Decay Tank Failure Analysis AST CLB Reason for Change Activity in ruptured tank See Table 4.3-2a See Table 4.3-2b Updated calculations Iodine chemical form of releases(%)

Elemental 100 N/A Modeling update (not AST specific)

Duration of release (hr) 2 2

No change Control room isolation None N/A No change Control room atmospheric dispersion factor (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 7.17E-04 5.30E-04 Updated calculations TSC atmospheric dispersion factor (sec/m3)

O - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1.97E-04 N/A Not modeled in current AORs

Attachment to ET 17-0011 Page 47 of 52 Table 4.3-14 Assumptions Used for Liquid Waste Tank Failure Analysis AST CLB Activity in ruptured tank Recycle holdup tank See Table 4.3-2a See Table 4.3-2b Hypothetical tank maximizing See Table 4.3-2a N/A iodine Iodine chemical form of releases(%)

Elemental 100 NIA Duration of release (hr) 2 2

Control room isolation None N/A Control room atmospheric dispersion factor (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 7.17E-04 N/A TSC atmospheric dispersion factor (sec/m3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1.97E-04 N/A Reason for Change Updated calculations Updated calculations Not modeled in current AORs No change No change Not modeled in current AORs Not modeled in current AORs

Attachment to ET 17-0011 Page 48 of 52 Table 4.3-15 Assumptions Used for Fuel Handling Accident Analysis AST CLB Core activity for one assembly at minimum time prior to fuel movement (Ci)

Kr-85m 1.10E+OO See Table 4.3-4c Kr-85 5.69E+03 See Table 4.3-4c Xe-131 m 5.38E+03 See Table 4.3-4c Xe-133m 1.76E+04 See Table 4.3-4c Xe-133 8.19E+05 See Table 4.3-4c Xe-135m 5.58E+01 See Table 4.3-4c Xe-135 8.14E+03 See Table 4.3-4c 1-130 1.45E+02 See Table 4.3-4c 1-131 4.12E+05 See Table 4.3-4c 1-132 3.95E+05 See Table 4.3-4c 1-133 8.90E+04 See Table 4.3-4c 1-135 3.42E+02 See Table 4.3-4c Number of fuel assemblies damaged 1.2 1.2 Peaking factor 1.65 1.65 Time of Control room isolation 120 N/A (including delays) (sec)

Decay time prior to fuel movement, 76 76 minimum (hr)

Gap fractions 1-131 0.12 0.12 Kr-85 0.30 0.30 Other iodines and noble gases 0.10 0.10 Iodine chemical form in gap(%)

Elemental 99.85 N/A Organic 0.15 N/A Fuel pool water depth, minimum (ft) 23 23 Reason for Change Updated calculations Updated calculations Updated calculations Updated calculations Updated calculations Updated calculations Updated calculations Updated calculations Updated calculations Updated calculations Updated calculations Updated calculations No change No change Not modeled in current AORs No change No change No change No change Not modeled in current AORs Not modeled in current AORs No change

Attachment to ET 17-0011 Page 49 of 52 Table 4.3-15 Assumptions Used for Fuel Handling Accident Analysis AST CLB Fuel rod internal pressure, maximum 1500 1200 (psig)

Overall pool iodine DF 200 100 Iodine airborne fractions(%)

Elemental 70 NIA Organic 30 NIA Duration of release (hr) 2 2

Removal of airborne activity in None None containment/fuel building (other than decay)

Control room atmospheric dispersion factor (sec/m3)

Auxiliary Building Release HV AC Flows Except for Control Room Unfiltered lnleakage 0 - 0.0333 hours0.00385 days 0.0925 hours 5.505952e-4 weeks 1.267065e-4 months 2.11 E-03 5.30E-04 0.0333 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 6.12E-04 5.30E-04 Control Room Unfiltered lnleakage 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2.11 E-03 5.30E-04 Containment Release<1>

0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1.38E-03 NIA TSC atmospheric dispersion factor (seclm3) 0 - 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 3.91 E-04 NIA Reason for Change Applicability of increased rod internal pressure is justified in LAR Enclosure VI in the response to ARCS-RAl-20.

Regulatory Guide Update Updated consistent with Regulatory Guide 1.183.

Specific chemical forms were not modeled in the CLB.

Updated consistent with Regulatory Guide 1.183.

Specific chemical forms were not modeled in the CLB.

No change No change Updated calculations Updated calculations Updated calculations Not modeled in current AORs Not modeled in current AORs

Attachment to ET 17-0011 Page 50 of 52 Note: ( 1) The containment release xtQ is lower that the auxiliary building release xtQ; therefore the auxiliary building release xtQ is used in the calculation of the doses. The containment release xtQ is only used to determine the time the control room isolation setpoint is reached since it is lower than the containment leakage xtQ and results in a conservative isolation time.

Attachment to ET 17-0011 Page 51 of 52 Table 4.3-16 Technical Support Center Parameters AST TSC volume (ft3) 44,000 Normal ventilation flow rates (cfm)

Unfiltered makeup flow rate 550 Unfiltered inleakage 20 Emergency mode flow rates (cfm)

Filtered makeup flow rate 550 Unfiltered makeup flow rate 0

Unfiltered inleakage 20 Filtered recirculation flow 450 Filter efficiencies(%)

Elemental iodine 95 Organic iodine 95 Particulates 95 Delay to switch to emergency mode of 60 operation after event initiation (minutes)

TSC breathing rate for duration of the 3.5E-04 event (m3/sec)

TSC occupancy factors 0-24 hours 1.0 1 -4 days 0.6 4-30 days 0.4 CLB Reason for Change 52,800 The CLB value is based on a simple bounding one volume calculation (length x width x height). The more accurate AST value was calculated by determining the volume of all individual TSC rooms and then summinq them.

550 No change 20 No change 550 No change N/A Not modeled in current AO Rs 20 No change 450 No change 90 Test procedure revised to increase acceptance criterion to 95%

90 Test procedure revised to increase acceptance criterion to 95%

0 A delay of 60 minutes was added to ensure the analysis bounds the plant specific time to switch to the emergency mode of operation after event initiation 3.5E-04 No change 1.0 No change 0.6 No change 0.4 No change

Attachment to ET 17-0011 Page 52 of 52

References:

1. WCNOC letter ET 17-0001, "License Amendment Request for the Transition to Westinghouse Core Design and Safety Analyses," January 17, 2017.

ADAMS Accession No. ML17054C103.

2. Letter from B. K. Singal, USNRC, to A C. Heflin, WCNOC, "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)," April 18, 2017. ADAMS Accession No. ML17100A266.

'" ~

Enclosure I to ET 17-0011 Proposed Technical Specification Changes (Markup)

(2 pages)

ACTIONS continued CONDITION C.

Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or 4.

D.

Two EES trains inoperable in MODE 1, 2, 3, or4 for reasons other than Condition B.

Required Action and associated Completion Time of Condition A not met during movement of irradiated fuel assemblies in the fuel building.

C.1 AND C.2 D.1 OR D.2 E.

Two EES trains inoperable E.1 due to inoperable fuel buildin~ boundary during movement of irradiated fuel assemblies in the fuel building.

Wolf Creek - Unit 1 REQUIRED ACTION Be in MODE 3.

Be in MODE 5.

Place OPERABLE EES train in operation in FBVIS mode.

Suspend movement of irradiated fuel assemblies in the fuel building.

Restore fuel buildin~

boundary to OPERABLE status.

EES 3.7.1 3 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Immediately Immediately (continued)

3. 7-34 Amendment No. 12J, 1 J2, 1 J4, 171, 177, 4-84,-200

Delete ACTIONS continued CONDITION uired Action and F.1 assoc1 Completion Time of Con *

E not met.

Two EES trains inoperable during movement of irradiated fuel as lies in the fuel

ing for re s other than ondition E.

SURVEILLANCE REQUIREMENTS REQUIRED ACTION Suspend movement of irradiated fuel assemblies in the fuel building.

SURVEILLANCE EES 3.7.13 COMPLETION TIME FREQUENCY SR 3.7.13.1 Operate each EES train for ~ 15 continuous minutes 31 days with the heaters operating.

SR 3.7.13.2 Perform required EES filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP).

the VFTP SR 3.7.13.3 Verify each EES train actuates on an actual or 18 months simulated actuation signal.

(continued)

Wolf Creek - Unit 1 3.7-35 Amendment No. 123, 132, 134, 171, 177,

+84, ~

Enclosure II to ET 17-0011 Revised Technical Specification Pages (3 pages)

EES 3.7.13 3.7 PLANT SYSTEMS

3. 7.13 Emergency Exhaust System (EES)

LCO 3.7.13 Two EES trains shall be OPERABLE.

NOTE------------------------------------------------

The auxiliary building or fuel building boundary may be opened intermittently under administrative controls.

APPLICABILITY:

MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies in the fuel building.

NOTE-------------------------------------------------

The SIS mode of operation is required only in MODES 1, 2, 3, and 4. The FBVIS mode of operation is required only during movement of irradiated fuel assemblies in the fuel building.

ACTIONS

NOTE---------------------------------------------------------------

LCO 3.0.3 is not applicable to the FBVIS mode of operation.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One EES train inoperable.

A.1 Restore EES train to 7 days OPERABLE status.

B.

Two EES trains inoperable B.1 Restore auxiliary building 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months due to inoperable auxiliary boundary to OPERABLE building boundary in status.

MODE 1, 2, 3, or 4.

(continued)

Wolf Creek - Unit 1

3. 7-33 Amendment No. 123, 132, 134, 171, 177,

~.200

ACTIONS (continued)

CONDITION C.

Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or4.

OR Two EES trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

D.

Required Action and associated Completion Time of Condition A not met during movement of irradiated fuel assemblies in the fuel building.

E.

Two EES trains inoperable for reasons other than Condition B during movement of irradiated fuel assemblies in the fuel building.

Wolf Creek - Unit 1 C.1 AND C.2 D. 1 OR D.2 E.1 REQUIRED ACTION Be in MODE 3.

Be in MODE 5.

Place OPERABLE EES train in operation in FBVIS mode.

Suspend movement of irradiated fuel assemblies in the fuel building.

EES 3.7.13 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Immediately Immediately Immediately 3.7-34 Amendment No. 123, 132, 134, 171, 177, 184, 200,

SURVEILLANCE REQUIREMENTS SR 3.7.13.1 SR 3.7.13.2 SR 3.7.13.3 SR 3.7.13.4 SR 3.7.13.5 SURVEILLANCE Operate each EES train for ~ 15 continuous minutes with the heaters operating.

Perform required EES filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each EES train actuates on an actual or simulated actuation signal.

Verify one EES train can maintain a negative pressure ~ 0.25 inches water gauge with respect to atmospheric pressure in the auxiliary building during the SIS mode of operation.

Verify one EES train can maintain a negative pressure ~ 0.25 inches water gauge with respect to atmospheric pressure in the fuel building during the FBVIS mode of operation.

EES 3.7.13 FREQUENCY 31 days In accordance with the VFTP 18 months 18 months on a STAGGERED TEST BASIS 18 months on a STAGGERED TEST BASIS Wolf Creek - Unit 1 3.7-35 Amendment No. 123, 132, 134, 171, 177, 184, 208,

Enclosure Ill to ET 17-0011 Proposed Technical Specification Bases Changes (for information only)

(3 pages)

BASES BACKGROUND (continued) 15.6.5.4 EES B3.7.13 The Emergency Exhaust stem is discussed in the USAR, Sections 6.5.1, 9.4.2, 9.4.3, and 4&:+-4 (Refs. 1, 2, and 3, respectively) because it may be used for normal, as well as post accident, atmospheric cleanup functions.

APPLICABLE The Emergency Exhaust System design basis is established by the SAFETY ANALYSES consequences of the limiting Design Basis Accidents (DBAs), which are a loss of coolant accident (LOCA) and a fuel handling accident (FHA). +Re analysis of the fuel handling accident, given in Reference 3, assumes that all fuel rods in an assembly are damaged, and one of the Emergency Exhaust System filter adsorber unit is operating *.vith a failed heater or humidistat. A reduced efficiency in the removal of organic iodine would occur if the heater failure occurred concurrently with high ambient relative For the fuel handling accident (FHA) the Emergency Exhaust System is credited as the release point but no credit is taken for filtration of the release.

LCO Wolf Creek - Unit 1 humidity. The analysis of the LOC.A:

at radioactive materials leaked from the ECCS and Containment Spray System recirculation mode are filtered and adsorbed by the Emergency Exhaust (Ref. 3)

S s The OBA analysis of the LOGA assumes that only one train of the Emergency Exhaust System is functional due to a single failure that disables the other train. The accident analysis accounts for the reduction in airborne radioacti,.*e material provided by the one remaining train of this filtration system. The amount of fission products a*1ailable for rel~

from the fuel handling building is determined for a fuel~........:____

and for a LOGA. These assumptions and the analys+s"'fe'1T'C>w the guidance provided in Regulatory Guides 1.4 (Ref. 6) and 1.26 (Ref. 4). 11.183 (Ref. 4) I The Emergency Exhaust System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Two independent and redundant trains of the Emergency Exhaust System are required to be OPERABLE to ensure that at least one train is available, assuming a single failure that disables the other train, coincident with a loss of offsite power. Total system failure could result in the atmospheric release from the auxiliary building or fuel building exceeding the guideline limits of 10 CFI 100 (l ef. 5) ffffitts in the event of a LOCA or fuel handling accident.

50.67 The Emergency Exhaust System is considered OPERABLE when the individual components necessary to control releases from the auxiliary or fuel building are OPERABLE in both trains. An Emergency Exhaust System train is considered OPERABLE when its associated:

B 3.7.13-2 Revision 1

BASES ACTIONS immediately to suspend movement of irradiated fuel assemblies in the fuel building. This does not preclude the movement of fuel assemblies to a safe

!Delete l-----~1 SURVEILLANCE REQUIREMENTS Wolf Creek - Unit 1 D.1 and D.2 EES B3.7.13 When Required Action A.1 cannot be completed within the associated Completion Time during movement of irradiated fuel assemblies in the fuel building, the OPERABLE Emergency Exhaust System train must be started in the FBVIS mode immediately or fuel movement suspended.

This action ensures that the remaining train is OPERABLE, that no undetected failures preventing system operation will occur, and that any active failure will be readily detected.

If the system is not placed in operation, this action requires suspension of fuel movement, which precludes a fuel handling accident. This does not preclude the movement of fuel assemblies to a safe position.

OBA 0001:Jrring el1:Jring tt:iis tiR'le perioel anel the availability of the

~n=1ergenoy ~xha1:Jst Systen=1 to pro*1iele a filtereel release ~albeit with potential for soR'le 1:Jnfiltereel f1:Jel b1:Jileling leakage).

SR 3.7.13.1 Standby systems should be checked periodically to ensure that they function properly. As the environmental and normal operating conditions on this system are not severe, testing each train once every month, by initiating from the control room flow through the HEPA filters and charcoal adsorbers, provides an adequate check on this system.

B 3.7.13-5 Revision a+

BASES REFERENCES Wolf Creek - Unit 1

1.

USAR, Section 6.5.1.

2.

USAR, Section 9.4.2 and 9.4.3.

3.

USAR, Section~. I 15.6.5.4 I EES 83.7.13

4.

Regulatory Guide 1.26, Rev. O (Saf.ety G1::1iae 26). 11.183, Rev. 0

5.

10 CFR 400. IS0.67 I

6.

ASTM D 3803-1989.

7.

ANSI N510-1980.

8.

NUREG-0800, Section 6.5.1, Rev. 2, July 1981.

9.

Regulatory Guide 1.52, Rev. 2.

10.

Regulatory Guide 1.52, Rev. 3.

B 3.7.13-8 Revision 94

v t e Letter Sequence Request
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, Request, Request, Request Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance Meeting, Meeting Questions 14 June 2017 21 September 2017 17 October 2017 4 December 2017 3 May 2018 4 October 2018 5 November 2018 16 April 2019 Answers 13 July 2017 18 October 2017 14 November 2017 5 March 2019 17 January 2017 5 March 2019 15 January 2018 15 November 2018 Results Approval, Approval, Approval Other: ML18107A756
MONTHYEAR2018-10-30 [Table View]

ET 17-0011, Response to Supplemental Information Needed for Acceptance of Requested Licensing Action Transition to Westinghouse Core Design and Safety Analyses

Text

Reference:

Subject:

Attachment:

Enclosures:

Response

Response

References:

Navigation menu

ET 17-0011, Response to Supplemental Information Needed for Acceptance of Requested Licensing Action Transition to Westinghouse Core Design and Safety Analyses

Text

Reference:

Subject:

Attachment:

Enclosures:

Response

Response

References:

Navigation menu

Search