ML22061A139

Pre-submittal Meeting Slides for Planned License Amendment Request to Consolidate Fuel Decay Time Requirements

ML22061A139
Person / Time
Site:	Beaver Valley
Issue date:	03/02/2022
From:	Grabnar J Energy Harbor Nuclear Corp
To:	Sujata Goetz NRC/NRR/DORL/LPL1
Ballard B
References
Download: ML22061A139 (13)

Text

Energy Harbor Nuclear Corp. Beaver Valley Power Station Pre-submittal Meeting

~ energy

~ harbor

License Amendment Request to Consolidate Fuel Decay Time Requirements in a New Decay Time Limiting Condition for Operation 2

Agenda

• Regulatory History of Decay Time Requirements

• Current Decay Time Requirements

• Proposed Changes

• Submittal Schedule

• Questions and Comments 3

Regulatory History of Decay Time Requirements

• Fuel handling accident (FHA) analyses assume a minimum fuel decay time has occurred after irradiation in order to bound the potential accident source term.

• The BVPS FHA analysis assumes the accident involves fuel that has decayed greater than or equal to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

• Fuel decayed less than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> is defined as recently irradiated.

• Fuel decayed greater than or equal to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> is referred to as non-recently irradiated fuel.

• There is no analysis to support an FHA involving recently irradiated fuel.

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Regulatory History of Decay Time Requirements (contd)

• Prior to the Improved Technical Specification conversion, the Limiting Condition of Operation 3.9.3 required the reactor to be subcritical for at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> during movement of irradiated fuel assemblies in the reactor pressure vessel.

• This requirement was then moved to the Licensing Requirements Manual LR 3.9.3, Decay Time, for both units.

• However, Technical Specification (TS) requirements addressing the condition of moving recently irradiated fuel assemblies were retained.

The NRC staff determined that fuel handling limits should be retained in the TSs should the licensee develop future capability to move recently irradiated fuel.

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Current Decay Time Requirements The applicability statements for the following TS Limiting Conditions for Operations (LCOs) include referencing movement of recently irradiated fuel assemblies, and movement of fuel assemblies over recently irradiated fuel. Additionally, certain conditions and notes in the following TS LCOs reference recently irradiated fuel or non-recently irradiated fuel.

TS 3.3.6, Unit 2 Containment Purge and Exhaust Isolation Instrumentation; TS 3.3.7, Control Room Emergency Ventilation System (CREVS)

Actuation Instrumentation; TS 3.7.10, Control Room Emergency Ventilation System (CREVS);

TS 3.7.11, CR Emergency Air Cooling System; TS 3.7.12, Supplemental Leak Collection and Release System (SLCRS);

TS 3.8.2, AC Sources - Shutdown; TS 3.8.5, DC Sources - Shutdown; TS 3.8.8, Inverters - Shutdown; TS 3.8.10, Distribution Systems; TS 3.9.3, Containment Penetrations.

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Proposed Changes Add a new TS LCO 3.9.7, titled Decay Time:

LCO 3.9.7: The reactor shall be subcritical for greater than or equal to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> APPLICABILITY:

• During movement of irradiated fuel assemblies within the containment,

• During movement of fuel assemblies over irradiated fuel assemblies within the containment.

Condition A: Reactor subcritical less than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> requires immediate suspension of movement of irradiated fuel assemblies within containment.

SR 3.9.7.1: The reactor shall be determined to have been subcritical for at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> by verification of the date and time of subcriticality prior to movement of irradiated fuel assemblies within containment.

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Proposed Changes (contd) 8

Proposed Changes (contd)

• Addition of LCO 3.9.7, Decay Time allows deletion of:

3.3.6 - Unit 2 Containment Purge and Exhaust Isolation Instrumentation 3.7.12 - Supplemental Leakage Collection and Release System (SLCRS) 3.9.3 - Containment Penetrations (Refueling)

TS 5.5.7 - SLCRS testing from the Ventilation Filter Testing Program (VFTP) 9

Proposed Changes (contd)

• Addition of LCO 3.9.7, Decay Time allows references to recently irradiated fuel to be removed from:

TS 3.3.7, CREVS Actuation Instrumentation - Applicability, Condition D, Table 3.3.7-1, and SRs.

TS 3.7.10, CREVS - Applicability, and Conditions D and E.

TS 3.7.11, CR Emergency Air Cooling System - Applicability, Conditions C and D, and SR 3.7.11.1 Note.

TS 3.8.2, AC Sources - Shutdown - Applicability, Conditions A and B.

TS 3.8.5, DC Sources - Shutdown - Applicability, Condition A.

TS 3.8.8, Inverters - Shutdown - Applicability, Condition A.

TS 3.8.10, Distribution Systems - Shutdown - Applicability, Condition A.

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Conclusions

• The current TS requirements are in place to establish an initial condition in the fuel handling accident safety analysis. The proposed change maintains that initial condition.

• The addition of one new LCO would allow the removal of three LCOs, as well as simplifying several others.

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Schedule

• Plan to submit by April 8, 2022.

• Request NRC approval by April 28, 2023.

• Request a 60-day implementation period after amendments become effective.

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Question or Comments Please?

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