ML23019A013

NRR E-mail Capture - Final RAI Dresden 2 and 3 - License Amendment Pertaining to GNF3 Fuel Transition

ML23019A013
Person / Time
Site:	Dresden
Issue date:	01/12/2023
From:	Shilpa Arora NRC/NRR/DORL/LPL3
To:	Palutsis L Constellation Energy Generation
References
L-2022-LLA-0121
Download: ML23019A013 (4)

Text

From: Surinder Arora Sent: Thursday, January 12, 2023 2:08 PM To: Palutsis, Linda M:(Constellation Nuclear)

Subject:

FINAL RAI: Dresden 2 and 3 - License Amendment Pertaining to GNF3 Fuel Transition (EPID L-2022-LLA-0121)

By letter dated August 18, 2022, Constellation Energy Generation, LLC, (Constellation) submitted an amendment request regarding transition to GNF3 Fuel for Dresden Nuclear Power Station, Units 2 and 3. The Nuclear Regulatory Commission (NRC) staff has determined that additional information is required to complete its review of the proposed amendment. This email includes NRC staffs request for additional information (RAI).

The draft of this RAI was sent to you on December 22, 2022. A clarification call was held on January 10, 2023; however, no changes were made to the draft RAI. This email provides the final RAI requesting Constellation response within 30 days or sooner. Please let me know if you expect any delay in furnishing the response to the RAI question.

Thanks, Surinder Arora, PE Project Manager, NRR/DORL/LPL3 surinder.arora@nrc.gov 301-415-1421 REQUEST FOR ADDITIONAL INFORMATION BY THE NUCLEAR SYSTEMS PERFORMANCE BRANCH LICENSE AMENDMENT REQUEST REGARDING TRANSITION TO GNF3 FUEL DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOs. 50-237 AND 50-249 EPID: L-2022-LLA-0121 INTRODUCTION By letter dated August 18, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22230C927) (Reference 1), Constellation Energy Generation, LLC (CEG, the licensee), submitted a license amendment request (LAR) for amendment to the Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3, respectively. The proposed change supports the transition from Framatome, Inc. ATRIUM 10XM fuel to Global Nuclear Fuel - Americas, LLC (GNF) GNF3 fuel at DNPS Units 2 and 3.

After reviewing the LAR (Reference 1), the Nuclear Systems Performance Branch (SNSB) staff requests response to the request for additional information (RAI) given below.

SNSB-RAI 1 Regulatory Basis:

The following General Design Criteria of 10 CFR 50, Appendix A are applicable for containment design:

Criterion 16Containment design. Reactor containment and associated systems shall be provided to establish an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment and to assure that the containment design conditions important to safety are not exceeded for as long as postulated accident conditions require.

Criterion 38Containment heat removal. A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.

Criterion 50Containment design basis. The reactor containment structure, including access openings, penetrations, and the containment heat removal system shall be designed so that the containment structure and its internal compartments can accommodate, without exceeding the design leakage rate and with sufficient margin, the calculated pressure and temperature conditions resulting from any loss-of-coolant accident. This margin shall reflect consideration of (1) the effects of potential energy sources which have not been included in the determination of the peak conditions, such as energy in steam generators and as required by § 50.44 energy from metal-water and other chemical reactions that may result from degradation but not total failure of emergency core cooling functioning, (2) the limited experience and experimental data available for defining accident phenomena and containment responses, and (3) the conservatism of the calculational model and input parameters.

RAI:

Due to differences in the fuel decay heat and the stored sensible energy in the reactor internals (for example in fuel assemblies and other components), the fuel transition from the ATRIUM 10XM to GNF3 fuel may impact the small break and the following design basis accident (DBA) loss-of-coolant accident (LOCA) containment analysis of record (AOR):

(i). Small break and DBA mass and energy (M&E) release analysis, (ii). Containment Short-Term Response to a DBA (Updated Final Safety Analysis Report (UFSAR) Section 6.2.1.3.2.1),

(iii). Containment Long-Term Response to a DBA (UFSAR Section 6.2.1.3.2.2),

(iv). Containment Response to a DBA-LOCA for Minimum Net Positive Suction Head (NPSH)

(UFSAR Section 6.2.1.3.3),

(v). LOCA Transient Loads (UFSAR Section 6.2.1.3.5.2).

For a mixed core (ATRIUM 10XM and GNF3) and full core transition from ATRIUM 10XM to GNF3 fuel, provide the following:

(a) Provide justification that the five AOR above, (i) through (v), remain bounding, or (b) If any of the five AOR above, (i) through (v), are not bounding, provide a discussion of the impact, the AOR results, and revised results along with changes in the method(s) of analysis, inputs, and assumptions.

REFERENCE

1. Letter from Constellation Energy Generation, LLC to NRC, License Amendment Request Regarding Transition to GNF3 Fuel, August 18, 2022, ADAMS Accession No. ML22230C927.

Hearing Identifier: NRR_DRMA Email Number: 1915 Mail Envelope Properties (BY3PR09MB8225B2BC825841A88345A71A94FD9)

Subject:

FINAL RAI Dresden 2 and 3 - License Amendment Pertaining to GNF3 Fuel Transition (EPID L-2022-LLA-0121)

Sent Date: 1/12/2023 2:07:42 PM Received Date: 1/12/2023 2:07:00 PM From: Surinder Arora Created By: Surinder.Arora@nrc.gov Recipients:

"Palutsis, Linda M:(Constellation Nuclear)" <Linda.Palutsis@constellation.com>

Tracking Status: None Post Office: BY3PR09MB8225.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5441 1/12/2023 2:07:00 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: