ML21286A737

Additional Element Included in the Implementation Plan for the Surry Fuel Melt Safety Limit (SL) LAR

ML21286A737
Person / Time
Site:	Millstone, Surry, North Anna
Issue date:	10/13/2021
From:	Geoffrey Miller Dominion Energy
To:	John Klos NRC/NRR/DORL/LPL2-1
Klos, J
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Download: ML21286A737 (3)

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From: gary.d.miller@dominionenergy.com To: Klos, John

Subject:

[External_Sender] Additional Element Included in the Implementation Plan for the Surry Fuel Melt Safety Limit (SL) LAR Date: Wednesday, October 13, 2021 3:17:05 PM

John, In addition to the information provided below and as a result of the clarification call between Dominion Energy and the NRC this afternoon, this email is provided to identify an additional implementation plan item associated with the Surry Power Station Units 1 and 2 License Amendment Request to revise the TS 2.1.A.1.b safety limit for fuel melt. Specifically, UFSAR section 3.4.1.1 will be revised as part of the implementation plan for the license amendments following their issuance to include the revised fuel melt safety limit and its technical basis. Furthermore, the UFSAR will be reviewed and additional UFSAR changes will be implemented, if required, to reflect the revised fuel melt safety limit.

If you have any questions or require additional information, please do not hesitate to ask.

Respectfully, Gary D. Miller Consulting Engineer - Corporate Licensing Nuclear Regulatory Affairs Dominion Energy, Inc.

(804) 273-2771 From: Gary D Miller (Services - 6)

Sent: Tuesday, September 28, 2021 3:29 PM To: Klos, John <John.Klos@nrc.gov>

Subject:

Surry Fuel Melt Safety Limit (SL) LAR Question

John, Per our discussion this morning regarding the update of the UFSAR as a result of the Fuel Melt Safety Limit (SL) LAR, an UFSAR update is not required as a result of the revision of the SL. As noted in Attachment 1, page 3 of 10, of the LAR discussion of the change:

The peak fuel centerline temperature SL is independent of the PAD5 methodology (Reference 2). The current licensing basis safety analyses use the existing SL 2.1.A.1.b for fuel melt as an acceptance criterion as required by the current methodology. Thus, Dominion Energy Virginia will continue to meet the existing SL

when using its current licensing basis safety analyses even with the implementation of the proposed SL. Since the existing SL for peak fuel centerline temperature is more restrictive than the proposed limit, the current licensing basis safety analyses remain conservative with respect to the proposed SL.

Consequently, since we will continue to use the existing, more restrictive, SL, a UFSAR change is not necessary. However, the UFSAR Chapter 14 safety analysis will be reviewed and updated as required to address the implementation of PAD 5.

The non-LOCA analyses of record updates are part of the PAD 5 implementation which is planned in 2022.

Note that this approach is consistent with the NRC SER for Turkey Point dated August 15, 2019, TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 -

ISSUANCE OF AMENDMENT NOS. 288 AND 282 REGARDING REVISED REACTOR CORE SAFETY LIMIT TO REFLECT TOPICAL REPORT WCAP-17642-P-A, REVISION 1 (EPID L-2018-LLA-0120), [ML19031C891]

which states:

As previously discussed, the peak fuel centerline temperature SL is independent of the PADS methodology. Therefore, the NRC staff reviewed the proposed SL to ensure that it is supported by the current licensing basis safety analyses. The current licensing basis safety analyses use the existing SL 2.1.1.b for fuel melt as an acceptance criterion as required by the current methodology. Thus, the licensee will continue to be required to meet the existing SL when using its current licensing basis safety analyses even with the implementation of the proposed SL. Since the existing SL for peak fuel centerline temperature is more restrictive than the proposed limit, the current licensing basis safety analyses will remain conservative to the proposed SL Thus, the staff determined that the proposed limit is acceptable with the Turkey Point current licensing basis.

Please advise if you have any further questions.

Gary D. Miller Consulting Engineer - Corporate Licensing Nuclear Regulatory Affairs Dominion Energy, Inc.

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