ML18239A309
| ML18239A309 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/21/2018 |
| From: | Dennis Galvin Plant Licensing Branch II |
| To: | Wooten B Duke Energy Progress |
| Hon A NRR/DORL/lpl2-1 301-415-8480 | |
| References | |
| EPID L-2017-LRM-0033, LIC-101, LIC-109, LIC-500 | |
| Download: ML18239A309 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 September 21, 2018 Mr. Bryon B. Wooten Director - Organizational Effectiveness Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 river Rd. SE (M/C BNP001)
Southport, NC 28461
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - REQUEST FOR ONE-TIME EXCEPTION TO NUCLEAR REACTOR REGULATION OFFICE INSTRUCTIONS LIC-109, LIC-101, AND LIC-500 ACCEPTANCE REVIEW CRITERIA (EPID L-2017-LRM-0033)
Dear Mr. Wooten:
By letter dated August 6, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML182208132), Duke Energy Progress, LLC (Duke Energy, the licensee) requested a one-time allowance to submit a license amendment request (LAR) referencing a topical report (TR) that is currently under review by the U.S. Nuclear Regulatory Commission (NRC) staff. The planned LAR to be submitted in September 2018, would enable the licensee to use Framatome ATRIUM 11 fuel to improve fuel cycle economics and safety margins. The specific TR currently under review is Framatome ANP-10332P, Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Loss of Coolant Accident (LOCA) Scenarios (AURORA-B LOCA TR). The purpose of this letter is to inform you of the NRC staff's acceptance of this request.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required.
This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations. For license amendment requests and other requested licensing actions (RLAs), the NRC staff conducts an acceptance review of RLAs to determine whether it provides technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment.
To aid the NRC staff in meeting requirements and performance goals, the Office of Nuclear Reactor Regulation has established procedures and guidance for the conduct of licensing reviews. For LARs and topical reports, the procedures and guidance for acceptance reviews are in Office Instructions (Ols) LIC-109, "Acceptance Review Procedures," LIC-101, "License Amendment Review Procedures," and LIC-500, "Topical Report Process." The Ols are available in ADAMS at Accession Nos. ML16144A521, ML16061A451, and ML13158A296, respectively. One of the purposes of the acceptance review is to verify that an application reasonably appears to contain sufficient technical information, both in scope and depth, for the
B. Wooten NRC staff to complete the detailed technical review and render, in an appropriate time frame for the associated action, an independent assessment of the proposed action with regard to applicable regulatory requirements and the protection of public health, safety, and security.
According to the acceptance review criteria for RLAs, RLAs that are linked to another action that is under NRC staff review should not be accepted unless the licensee has an urgent need and provides a full justification (page D-2 of LIC-109, Revision 2) or rare circumstance exists (page 10 of LIC-109, Revision 2).
From your letter dated August 6, 2018, your justification is summarized as follow:
- The September 2018 LAR submittal date is necessary to support a critical milestone in December 2018 for ATRIUM 11 fuel transition. The approval of the LAR will be needed by February 20, 2020, to support reactor startup following the scheduled Unit 1 refueling outage. (This challenging review timeline was discussed previously with the NRC staff at the October 26, 2017, pre-submittal public meeting.)
- The proposed LAR will reference eight (8) new TRs and the AURORA-B LOCA TR was projected to have the draft safety evaluation (SE) issued by March 30, 2018. However, due to the advanced nature of the methodology and associated additional review effort, the draft SE is projected to be issued on August 31, 2018. (The draft SE was issued to Framatome on August 31, 2018, ADAMS Accession No. ML18242A426.)
- Apart from the AURORA-B LOCA TR, all other elements of the LAR will use NRC-approved or detailed plant-specific methodology. The majority of the technical content does not directly involve the AURORA-B LOCA TR
- Including the entire AURORA-B LOCA TR in the LAR would significantly delay the LAR submittal without adding value to the review process in this circumstance.
- Duke Energy will address each limitation and condition in the draft SE for the AURORA-B LOCA TR in the LAR submittal. Duke Energy will supplement the LAR and address differences between the draft AURORA-B LOCA TR draft SE and the final approved version.
- Duke Energy acknowledges that this strategy will introduce additional uncertainty into the NRC staff's initial projection of the LAR review hours and duration as well as the remaining regulatory processes that need to be completed before the AURORA-B LOCA TR can be approved. Notwithstanding these schedule risks, Duke Energy believes submitting the LAR as originally planned but referencing the AURORA-B LOCA TR draft SE remains the best strategy to meet its need.
The NRC staff has reviewed your request for a one-time exception to the acceptance review criteria and identified the following schedule and resource estimate risks:
- Currently, the AURORA-B LOCA TR is scheduled for the Advisory Committee for Reactor Safeguards (ACRS) Thermal-Hydraulic Subcommittee briefing in December, 2018, and Full Committee briefing in February, 2019. Schedule slippage of either briefing or significant new issues raised by the ACRS that require resolution will adversely impact the LAR review schedule.
B. Wooten
- Licensee's inability to adequately address the original L&Cs for AURORA-B LOCA in a timely manner will adversely impact the LAR schedule.
- A change in the number or complexity of the L&Cs between the draft and final version of the AURORA-B LOCA SE, and ability for licensee to address the changes will adversely impact the LAR schedule.
These schedule risks are in addition to the inherent uncertainty associated with the first time application of ATRIUM 11 fuel methodologies, including the ACRS interest to review the NRC staff's conclusion of this proposed LAR (even though the NRC staff has planned for it, there is always a schedule risk due to the ACRS availability and comments resolutions).
The NRC staff also considered other alternatives, such as delaying the LAR until the AURORA-B LOCA-TR is finally approved or including it in the LAR as self-contained application.
The NRC staff concluded that it would be appropriate to accept for review the planned LAR that relies on the AURORA-B LOCA TR draft SE in this situation, provided that Duke Energy accepts the potential review schedule and staff-hours estimate uncertainties and other parts of the LAR meet the acceptance criteria. This approach enables the NRC staff to start to review the areas of the LAR referencing the other seven approved TRs. However, we cannot approve the LAR until the AURORA-B LOCA TR is finally approve. Furthermore, this one-time exception is for this unique situation only and should not be considered as precedence for other LARs.
If you have any questions, please contact me at (301) 415-8480 or Andrew.Hon@nrc.gov or Dennis Galvin at (301) 415-2871 or Dennis Galvin@nrc.gov.
Sincerely,
~P~n~
Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-324 and 50-325 cc: Listserv
ML18239A309 *via email OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA DSS/SRXB/BC DSS/SNPB/BC AHon BClayton. JWhitman Rluke NAME (ASallman for) (RAnzalone for)
DATE 08/28/18 08/28/18 08/29/18 08/29/18 OFFICE NRR/DSS/D DORL/LPL2-2/BC(A) NRR/DORL/D(A) DORL/LPL2-2/PM MGavrilas BVenkataraman KBrock DGalvin NAME (JMarshall for) (GSuber for) (AHon for)
DATE 08/29/18 09/03/18 09/21/18 09/21/18