ML23297A231

E-mail to File - Summary of September 13, 2023, Meeting with Dominion to Discuss Proposed LAR to Support Cycle Reloads Using Framatome Gaia Fuel

ML23297A231
Person / Time
Site:	Millstone
Issue date:	10/24/2023
From:	Richard Guzman NRC/NRR/DORL/LPL1
To:	Gonzales H NRC/NRR/DORL/LPL1
References
EPID L-2023-LRM-0068
Download: ML23297A231 (1)

Text

From: Richard Guzman To: Hipo Gonzalez

Subject:

Millstone Unit 3 LAR to Support Cycle Reloads Using Framatome GAIA Fuel Date: Tuesday, October 24, 2023 2:33:30 PM

Hipo, For your information, shown below is a summary of the September 13, 2023, observation meeting with Dominion Energy Nuclear Connecticut, Inc. to discuss the licensees proposed license amendment request for reload of Framatome GAIA fuel at Millstone Power Station, Unit No. 3. The licensees LAR is on track for submission by the end of this month.

Please let me know if you have any questions regarding this meeting.

Thanks, Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov From: Richard Guzman Sent: Monday, September 25, 2023 9:30 AM To: Shayan.Sinha@dominionenergy.com

Subject:

Millstone Unit 3 LAR to Support Cycle Reloads Using Framatome GAIA Fuel - Summary of Pre-Submittal Meeting

Shayan, Below is a summary of the subject pre-submittal meeting. Please let me know if you have any concerns/questions.

Thanks, Rich

~~~~~~~~~~~~

Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov

=========================================================

OBSERVATION PUBLIC MEETING WITH DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC),

TO DISCUSS PROPOSED, RELOAD LICENSING REQUEST TO IMPLEMENT BATCH FRAMATOME 17X17 GAIA FUEL AT MILLSTONE POWER STATION, UNIT NO. 3 PRE-APPLICATION MEETING MEETING

SUMMARY

SEPTEMBER 13, 2023 DOCKET NO. 50-423 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Dominion Energy Nuclear Connecticut, Inc. (DENC, the licensee) held a public meeting via teleconference call on September 13, 2023, to discuss the licensees proposed license amendment request to support cycle reloads using Framatome (FRM) GAIATM fuel at Millstone Power Station, Unit No. 3 (MPS3). The licensees meeting slides are available in ADAMS at Accession No. ML23254A056. The licensees presentation is summarized as follows:

The licensee presented an overview of the following areas:

Description and Purpose of the Reload LAR Schedule for all licensing actions supporting GAIA fuel transition Proposed Items for Approval in the Reload LAR Technical Basis Expected Attachments in the Reload LAR Description and Purpose of the Reload LAR DENC stated that the purpose of the LAR is to support the cycle fuel reloads at Millstone Unit 3 (MPS3) using Framatome (FRM) GAIATM fuel, hereafter referred as the Reload LAR. The licensee also indicated that the staffs safety evaluation (SE) for the Dominion Generic Fleet LAR with DOM-NAF-2, Appendix F would need to be in place to implement the technical specification (TS) changes being proposed in the Reload LAR.

GAIA LAR Review Status and Schedule DENC presented a Gantt chard showing all in-house submittals that will support the MPS3 FRM GAIA fuel implementation. The submittals that have been submitter are (1)

Spent Fuel Pool Criticality Safety Analysis Supplement, (2) VIPRE-D Computer Code Generic Fleet Report (DOM-NAF-2-P-A); (3) GAIA Fuel & Thermal-Mechanical Design LAR

& Exemption Request; and (4) LAR for FRM Small Break and Large Break Methods and site-specific application with GAIA. Item (1) is on track for completion by the end of September. The licensee acknowledged that the SE for item (2) is not expected to be issued prior to the submission of the Reload LAR; however, there are no technical issues identified in the DOM NAF-2 SE at this time that are expected to conflict with the planned Reload LAR submittal. Items 3 and 4 are projected for review completion by May 2024.

Proposed Items for Approval in the Reload LAR DENC provided an overview of its plans to submit the following items for staffs approval as part of the Reload LAR:

1. TS change to add Dominion Fleet Report DOM-NAF-2, App. F (Qualification of the Framatome ORFEO-GAIA and ORFEO-NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code) to the Core Operating Limits Report (COLR) list of methodologies

2. TS 2.1.1.1 (Reactor Core Safety Limit) change to add ORFEO-GAIA Deterministic Design Limit (DDL) of 1.13

3. TS change to the P-8 setpoint (conservative reduction from current 50% to 35%) in TS Table 2.2-1 (Reactor Trip System Instrumentation Trip Setpoints)

4. Design Basis Limits for Fission Product Barriers (DBLFPBs) associated with the implementation of the FRM AREA method consistent with ANP-10388-P-A and the Dominion Fleet Report VEP-NE-2-A.

For item 3, the staff requested the licensee to clarify whether the need for the proposed change to the P-8 setpoint due to GAIA fuel. The licensee stated that while the setpoint is not technically dependent on the fuel itself, it is based on the correlation associated with the fuel. The licensees preliminary analysis shows that the ORFEO correlation is not providing as much margin in departure from nucleate boiling (DNB) space as what was expected based on historical correlations used. Therefore, the analysis in the MPS3 design basis was already very limiting in DNB space at the 50% power level and with the loss of margin going from the existing to the new correlations, the licensee is proposing to reduce the setpoint to provide some additional margin in the analysis. The licensee also provided further clarification on item 4 regarding how the correlation uncertainty is treated in terms of the Monte Carlo method sampling in the statistical DNB.

Technical Basis and Expected Attachments of Reload LAR DENC provided an overview of the following technical basis items that will be discussed in the LAR:

1. Addition of DOM-NAF-2, App. F to the COLR list This will be reliant on the pending approval of the Dominion Fleet Report, DOM-NAF-2, Appendix F Discussion of the development of the ORFEO-GAIA SDL (1.26) and ORFEO-NMGRID SDL (1.31) for MPS3 with GAIA fuel based on NRC-approved topical VEP-NE-2

2. Addition of ORFEO-GAIA DDL (1.13) to TS 2.1.1.1 Safety Limit (also reliant on pending approval of DOM-NAF-2, App. F)

3. Revision of P-8 setpoint to 35% (results in an earlier trip than current setpoint)

4. Approval of AREA Design Basis Limits for Fission Product Barriers (analysis available for audit)

Compliance with RG 1.236 acceptance criteria (criteria met)

Compliance with ANP-10338-P-A Limitations and Conditions Qualitative assessment for maintaining WEC Overpressure Analysis (WCAP-7588) as the AOR

5. Additional analyses/results

Statement that limited setpoint changes (e.g., k terms for OTT/OPT) are required for implementation of GAIA and will be implemented in accordance with 10 CFR 50.59 Mixed core DNB penalty developed for transition core effects The licensee indicated there will be two deviations in the LAR with respect to item 4. The staff requested what the timeline was for the associated Framatome letter describing the referenced calculation method. The licensee clarified the letter is expected in the near term.

For item 5, the staff requested the licensee to clarify the mixed core penalty and whether it was part of a generic method for deriving the penalty. The licensee stated that it was a conservative, licensee-developed method and will provide a description of the method in the LAR. The staff also requested the licensee to specify whether it is requesting the NRC to approve the proposed mixed core penalty itself or the proposed methodology it is using to develop the mixed core penalty. The licensee also provided a description of the following expected attachments to be included in the LAR:

1. Discussion of changes and technical basis, excluding SDL development

2. SDL development

3. Proposed mark-up of TS pages

4. FRM affidavit (LAR is expected to contain proprietary information)

Finally, the staff asked whether the licensee plans to submit any information to address containment analysis for the use of FRM GAIA fuel. The licensee responded that it has performed an internal assessment of the existing containment mass and energy releases and determined them to be bounding of the use of GAIA fuel; therefore, there is no planned changes needed to the methods or analysis results in terms of containment analysis for the proposed LAR.

Conclusion DENC completed its presentation with no open/unanswered questions from the staff and summarized its conclusion by stating that the planned submittal is on track for submission by October 2023. The submittal will have a requested approval date one year from the submission date to support full implementation by the MPS3 spring 2025 outage. No decisions were made regarding the acceptability of the licensees proposed submittal.

There were no members of the public in attendance. To date, no public meeting feedback forms have been submitted through the NRC public meeting feedback system.

LIST OF ATTENDEES SEPTEMBER 13, 2023, OBSERVATION MEETING WITH DOMINION ENERGY NUCLEAR CONNECTICUT, INC.,

TO DISCUSS PLANNED RELOAD LICENSE AMENDMENT REQUEST TO IMPLEMENT FRAMATOME GAIA FUEL MILLSTONE POWER STATION, UNIT NO. 3 DOCKET NO. 50-423

ATTENDEE ORGANIZATION Richard Guzman U.S. Nuclear Regulatory Commission (NRC)

Richard Fu NRC Josh Kaizer NRC John Lehning NRC Summer Sun NRC Santosh Bhatt NRC Chris Clemens Dominion Energy Nuclear Connecticut, Inc.(DENC)

Dan Smith DENC Scott Luchau DENC Brian Mount DENC Ruxandra Bobolea DENC Brian Vitiello DENC Brian Kinney DENC Rich Ridder DENC Dave van Schooneveld DENC Shayan Sinha DENC Richard V. Guzman Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov