JAFP-18-0069, Submittal of 10 CFR 50.46 Annual Report

Submittal of 10 CFR 50.46 Annual Report

ML18213A011
Person / Time
Site:	FitzPatrick
Issue date:	08/01/2018
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-18-0069
Download: ML18213A011 (9)

Text

Exelon Generation ,~ 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp com 10 CFR 50.46 JAFP-18-0069 August 1, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

10 CFR 50.46 Annual Report

References:

1) Letter from James Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "10 CFR 50.46 Annual Report",

dated August 1, 2017(ML17213A012, JAFP-17-0076,)

2) Letter from GE Hitachi Nuclear Energy (GEH) to Exelon, "10 CFR 50.46 Notification Letter 2017-02, Fitzpatrick Nuclear Power Plant",

dated August 02, 2017 The purpose of this letter is to submit the 10 CFR 50.46 reporting information for James A.

FitzPatrick Nuclear Power Plant (JAF). The most recent 10 CFR 50.46 Annual Report for JAF (Reference 1), was provided on August 1, 2017.

Two attachments are included in this letter that provide the current JAF 10 CFR 50.46 status. Attachment 1, "Peak Cladding Temperature (PCT) Rack-Up Sheets", provides updated information regarding the PCT for the limiting analysis and Attachment 2, "Assessment Notes", contains a detailed description of each change or error reported.

Since the Reference 1 annual report was submitted, one (1) new error, 2017-02, was reported. This new error is included in the current LOCA model assessments with a zero PCT impact.

During the development of this submittal, legacy editorial errors were identified in the 2017 10 CFR 50.46 Annual Report (Reference 1) which originally occurred in the 2011 submittal. In the Reference 1 submittal, the information regarding the references cited in notes 2 and 3 of Attachment 2 contained errors. Specifically, the referenced letter in note 2 was from J. Pechacek as opposed to E. Dorman. Additionally, the title of the referenced letters for notes 2 and 3 should have been "10 CFR 50.46 Annual Report- Changes and

U.S. Nuclear Regulatory Commission 10 CFR 50.46 Annual Report August 1, 2018 Page 2 Errors in Emergency Core Cooling System (ECCS) Evaluation Models," as opposed to "10 CFR 50.46 Annual Report - Errors in Emergency Core Cooling System (ECCS) Evaluation Models." These errors are editorial in nature, are corrected for this submittal, and do not affect the technical information of Reference 1.

No new regulatory commitments are established in this submittal.

If any additional information is needed, please contact Christian Williams at (610) 765-5729.

Respectfully, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Peak Cladding Temperature Rack-Up Sheets

2) Assessment Notes cc: USNRC Administrator, Region I USNRC Project Manager, JAF, Unit 1 USNRC Senior Resident Inspector, JAF, Unit 1

ATTACHMENT 1 10 CFR 50.46 Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors Annual Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments Assessments as of August 1, 2018 Peak Cladding Temperature Rack-Up Sheets James A. FitzPatrick Nuclear Power Plant

Annual Report of the Emergency Core Cooling System Evaluation Model Changes and En-ors Assessments as of August 1, 2018 Attachment l Peak Cladding Temperature Rack-Up Sheet for JAF Page I of 2 PLANT NAME: James A. FitzPatrick ECCS EV ALUA TlON MODEL: SAFER/GESTR(PRIME)-LOCA REPORT REVISION DATE: August 1, 2018 CURRENT OPERA TING CYCLE: 23 ANALYSIS OF RECORD Evaluation Model:

I. B. S. Shiralkar et al, The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident: Volume III- SAFER/GESTR Application Methodology, February 1985 (NEDE-23 785-1-P-A and NED0-23 785-1-A)

2. Compilation of Improvements to GENE's SAFER ECCS-LOCA Evaluation Model, NEDC-32950P, January 2000 as reviewed by letter from S. A. Richards (NRC) to J.

F. Klapproth (GE), General Electric Nuclear Energy (GENE) Topical Reports NEDC-32950P and NEDC-32084P Acceptability Review, May 24, 2000

3. GESTR-LOCA and SAFER Models for Evaluation of Loss-of-Coolant Accident Volume lll, Supplement 1, Additional lnfonnation for Upper Bound PCT Calculation, NEDE-23785P-A, Supplement 1, Revision I, March 2002

4. Implementation of PRIME Models and Data in Downstream Methods, NED0-33173 Supplement 4-A, Revision l, November 2012 Calculations:

1. 0000-0076-4111-RO Rev 0, James A. Fitzpatrick Nuclear Power Plant GNF2 ECCS-LOCA Evaluation, August 2008 (JAF-RPT-08-00014 Rev 0)

Fuel: GNF2 Limiting Single Failure: Battery Failure Limiting Break Size and Location: Double-Ended Guillotine in a Recirculation Suction Pipe Reference Peak Cladding Temperature (PCT): GNF2 = 1800 °F MARGIN ALLOCATION A. PRIOR LOCA MODEL ASSESSMENTS 10 CFR 50.46 Repott dated December 22, 2008 (Note I) GNF2: ~PCT= 0 I 0 CFR 50.46 Report dated July 31. 2009 (Note 2) GNF2: ~PCT= 0

Annual Report of the Emergency Core Cooling System Evaluation Model Changes and EtTors Assessments as of August I, 2018 Attachment 1 Peak Cladding Temperature Rack-Up Sheet for JAF Page 2 of2 10 CFR 50.46 Report dated July 31 , 2010 (Note 3) GNF2: L1PCT = 0 I 0 CFR 50.46 Repo1t dated August 1, 2011 (Note 4) GNF2: L1PCT = 50 l 0 CFR 50.46 Report dated August I, 2012 (Note 5) GNF2: L1PCT = 0 l 0 CFR 50.46 Report dated August 1. 2013 (Note 6) GNF2: L1PCT = 40 10 CFR 50.46 Report dated August 1, 2014 (Note 7) GNF2: L1PCT = 35 I 0 CFR 50.46 Repo1t dated August 3, 2015 (Note 8) GNF2: ~PCT= -25 l 0 CFR 50.46 Report dated August 1, 2016 (Note 9) GNF2: L1PCT = 0 l 0 CFR 50.46 Repo1t dated August l, 2017 (Note I 0) GNF2: ~PCT = 0 NET PCT GNF2: 1900 °F B. CURRENT LOCA MODEL ASSESSMENTS Total PCT change from current assessments (Note 11) GNF2: L:L1PCT =0 Cumulative PCT change from current assessments GNF2: L:IL1PCT/ = O NET PCT GNF2: 1900 °F

ATTACHMENT 2 10 CFR 50.46 Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors Annual Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments Assessments as of August 1, 2018 Assessment Notes James A. FitzPatrick Nuclear Power Plant

Annual Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of August 1, 2018 Attachment 2 Assessment Notes for JAF Page l of 3 I) Prior LOCA Model Assessment GNF2 fuel was first installed during Refueling Outage 18, October 2008.

No changes or errors were repo1ted against GNF2 during this repo1ting period.

[

Reference:

Letter from E. Donnan (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission, JAFP-08-0133, "10 CFR 50.46 Annual Report - Errors in Emergency Core Cooling System (ECCS) Evaluation Models, dated December 22, 2008.]

2) Prior LOCA Model Assessment No changes or errors were repo1ted against GNF2 during this reporting period.

[

Reference:

Letter from J. Pechacek (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission. JAFP-09-0091. "I 0 CFR 50.46 Annual Report - Changes and Errors in Emergency Core Cooling System (ECCS) Evaluation Models, dated July 31, 2009.]

3) Prior LOCA Model Assessment No changes or errors were reported against GNF2 during this reporting period.

[

Reference:

Letter from J. Pechacek (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission, JAFP-10-0084, *' l 0 CFR 50.46 Annual Report - Changes and Errors in Emergency Core Cooling System (ECCS) Evaluation Models, dated July 31, 201 O.]

4) Prior LOCA Model Assessment Two errors were reported against GNF2 fuel during this repotting period.

Error 2011-02 described the database error for heat deposition on peak cladding temperature (PCT) for I Ox 10 fuel bundles. The error was estimated to increase the GNF2 PCT by +45 °F.

Error 2011-03 described the updated formulation for gamma heat deposition to the channel wall for 1Oxl0 fuel bundles. The error was estimated to increase the GNF2 PCT by +5 °F.

l

Reference:

Letter from Eugene W. Dorman (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission, JAFP-1 1-0097, *'I 0 CFR 50.46 Annual Report - Changes and Errors in Emergency Core Cooling System (ECCS) Evaluation Models," dated August 1, 2011.]

5) Prior LOCA Model Assessment No changes or errors were repo1ted against GNF2 during this repo1ting period.

[

Reference:

Letter from Jorge O'Farrill (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission, JAFP-12-0089, 10 CFR 50.46 Annual Report - Changes and Errors in Emergency Core Cooling System Evaluation Models, dated August 1, 2012.]

Annual Report of the Emergency Core Cooling System Evaluation Model Changes and Errors Assessments as of August 1, 2018 Attachment 2 Assessment Notes for JAF Page 2of3

6) Prior LOCA Model Assessment One change was repo1ted against GNF2 during this reporting period.

Change 2012-0 l described the impact from PRIME implementation to compute fuel properties.

The error was estimated to increase the GNF2 PCT by +40 °F.

[

Reference:

Letter from Chris M. Adner (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission, JAFP-13-0096, I 0 CFR 50.46 Annual Report - Changes and Errors in Emergency Core Cooling System Evaluation Models:' dated August l, 2013.]

7) Prior LOCA Model Assessment Four changes and errors were reported against GNF2 fuel during this reporting period.

Change 2014-01 described code maintenance changes. These changes were estimated to have no impact upon the GNF2 PCT.

Error 2014-02 described a mass non-conservatism. The e1rnr was estimated to increase the GNF2 PCT by +10 °F.

Error 2014-03 described an error in the minimum core differential pressure model. The error was estimated to increase the GNF2 PCT by +20 °F.

Error 2014-04 Rev 0 described an error in the bundle / lower plenum counter-current flow-limited head model. The error was estimated to increase the GNF2 PCT by +5 °F.

[

Reference:

Letter from Chris M. Adner (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission, JAFP-14-0094, 10 CFR 50.46 Annual Report- Changes and Errors in Emergency Core Cooling System Evaluation Models." dated August I. 2014.]

8) Prior LOCA Model Assessment One error was reported against GNF2 fuel during this reporting period.

Error 2014-04 Rev l was issued as a revision to error notification 2014-04 Rev 0 (Note 7). The revision identified a change to the hot bundle pressure head used as input to the counter-cunent flow-limited head model that resulted in a benefit (PCT reduction). With this revised notice, the prior PCT change of +5 °F was replaced by a PCT change of -20 °F. Consequently, the error was estimated to have a net change upon GNF2 PCT of-25 °F.

[

Reference:

Letter from Chris M. Adner (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission, JAFP-15-0092, "I 0 CFR 50.46 Annual Repo1t - Changes and Errors in Emergency Core Cooling System Evaluation Models," dated August 3, 2015.]

Annual Report of the Emergency Core Cooling System Evaluation Model Changes and EtTOrs Assessments as of August I, 2018 Attachment 2 Assessment Notes for JAF Page 3of3

9) Prior LOCA Model Assessment No changes or errors were reported against GNF2 during this reporting period.

[

Reference:

Letter from William C. Drews (Entergy Nuclear Operations) to the U.S. Nuclear Regulatory Commission, JAFP-16-0121, "10 CFR 50.46 Annual Report - Changes and Errors in Emergency Core Cooling System Evaluation Models," dated August 1, 2016.]

I 0) Prior LOCA Model Assessment One error was reported against GNF2 during this reporting period.

Error 2017-01 identifies that the GNF2 leakage paths between the bundle and the bypass (lower tie plate flow hole and channel to lower tie plate interface) were incorrectly modeled. The error was estimated to have no impact upon the GNF2 PCT.

[

Reference:

Letter from James Barstow (Exelon Generation) to the U.S. Nuclear Regulatory Commission, JAFP-17-0076. *'I 0 CFR 50.46 Annual Repo1t," dated August I, 2017.]

11) Current LOCA Model Assessment One error was reported against GNF2 during this reporting period.

Change 2017-02 describes a change in the GNF2 upper plenum model. The generic upper plenum model was changed to more explicitly model the GNF2 fuel design. The change was estimated to have no impact upon the GNF2 PCT.