RA-16-0033, Duke Energy - Regulatory Commitment Change Related to Loss of Coolant Accident Reanalysis to Address Fuel Pellet Thermal Conductivity Degradation

Duke Energy - Regulatory Commitment Change Related to Loss of Coolant Accident Reanalysis to Address Fuel Pellet Thermal Conductivity Degradation

ML16271A357
Person / Time
Site:	Oconee
Issue date:	09/22/2016
From:	Elnitsky J Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-16-0033
Download: ML16271A357 (4)

Text

M. Christopher Nolan

(~ DUKE 526 South Church Street Charlotte, NC 28202 ENERGYdD MaiOng Address:

Mail Code EC2ZF /P.O. Box 1006 Charlotte, NC 28201-1006 704-382-7426 10 CFR 50.46(a)(3)

Serial: RA-16-0033 September 22, 2016 U.S. Nuclear Regulatory Attn: Document Control Desk Washington, DC 20555-0001 OCONEE NUCLEAR STATION, UNIT NOS. 1, 2 AND 3 DOCKET NOS. 50-269, 50-270 AND 50-287 I RENEWED LICENSE NOS. DPR-38, DPR-47 AND DPR-55

Subject:

DUKE ENERGY Regulatory Commitment Change Related to Loss of Coolant Accident Reanalysis to Address Fuel Pellet Thermal Conductivity Degradation

References:

1. Letter from Duke Energy (Ernest J. Kapopoulos, Jr.) to USNRC (Document Control Desk), "Duke Energy Carolinas, LLC (Duke Energy): 10 CFR 50.46 -

30-Day Report for Oconee Nuclear Station, Units 1, 2 and 3; Estimated Impacts to Peak Cladding Temperature due to Fuel Pellet Thermal Conductivity Degradation," dated, December 17, 2014(Ml14353A214)

2. Letter from Duke Energy (Regis T. Repko.) to USNRC (Document Control Desk), "Oconee Nuclear Station, Units 1, 2 and 3, Response to Request for Additional Information Re: 10 CFR 50.46 - 30 Day Report on Estimated Impacts to Peak Cladding Temperature due to Fuel Pellet Thermal Conductivity Degradation," dated, March 31 , 2015(ML15090A303)

3. Letter from AREVA (Gayle Elliott) to USNRC (Document Control Desk),

"Request for Review and Approval of BAW-10192PA-OO, Supplement 1, Revision 0 "BWNT LOCA - BWNT Loss-of-Coolant Accident Evaluation Model for Once-Through Steam Generator Plants," dated, November 25, 2015 (ML15337A242)

4. NRC Staff Regulatory Audit Report Regarding Topical Report BAW-1019PA-OO, Supplement 1, Revision O,"BWNT LOCA - BWNT LOSS-of-COOLANT Accident Evaluation Model for Once Through Steam Generator Plants," dated, August 22, 2016(ML16182A322) (Proprietary)

U.S. Nuclear Regulatory Commission RA-16-0033 Page 2 of 4 In Reference 1, Duke Energy Carolinas, LLC (Duke Energy) submitted a report describing a significant error identified in the emergency core cooling system (ECCS) evaluation model, and an estimate of the effect of the error on the predicted peak cladding temperature (PCT) for Oconee Nuclear Station (ONS) Units 1, 2 and 3. This report was submitted pursuant to 10 CFR 50.46(a)(3), and contained a regulatory commitment to perform a Large Break Loss of Coolant Accident (LBLOCA) reanalysis, accounting for the effects of fuel pellet thermal conductivity degradation (TCD). In Reference 2, this reanalysis commitment date was revised to 15 months after NRC approval of a supplement to BAW-10192P-A.

AREVA submitted the TCD supplement to BAW-1092P-A on November 25, 2015 per Reference

3. In April 2016, the NRC staff performed an audit of the TCD supplement and associated documentation. The audit (Proprietary) is contained in Reference 4.

The AREVA schedule to complete the ONS LBLOCA TCD reanalysis is approximately 30 months from the date of NRC approval of the TCD supplement to BAW-10192P-A. This duration takes into consideration AREVA ability to perform TCD reanalysis for the B&W fleet.

Based on this anticipated schedule, a revised commitment date of 32 months after NRC approval of a supplement to BAW-10192P-A is established. This date takes into consideration completion of the AREVA LBLOCA reanalysis using an NRG-approved evaluation model that explicitly accounts for the effects of TCD, and includes a two-month duration for Duke to perform an Owner Acceptance review of the Oconee LBLOCA TCD reanalysis, and develop the reanalysis implementation package including any necessary licensing submittals. This commitment supersedes that made in Reference 2.

The revised commitment per this letter:

The Oconee Large Break LOCA reanalysis incorporating the Thermal Conductivity Degradation (TCD) error correction will be performed within 32 months after NRC approval of the TCD supplement to BAW-10192P-A.

If you should have any questions regarding this submittal, or require additional information, please contact Art Zaremba, Manager - Nuclear Fleet Licensing, at 980-373-2062.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 09/22/2016.

Elnitsky nior Vice President - Nuclear Engineering

Enclosure:

U.S. Nuclear Regulatory Commission RA-16-0033 Page 3 of 4 xc:

C. Haney, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 R. Hall, Senior Project Manager (ONS)

U. S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 E.L. Crowe NRC Senior Resident Inspector Oconee Nuclear Station

U.S. Nuclear Regulatory Commission RA-16-0033 Enclosure Original Regulatory Commitment and Schedule "Duke Energy will perform a Large Break LOCA reanalysis for the highest PCT case at Middle-of-Life for Oconee Nuclear Station, Units 1, 2, and 3 by September 17, 2015. The effects of fuel pellet thermal conductivity degradation will be accounted for by use of a fuel temperature uncertainty adjustment factor based on COPERNIC2."

Revision 1 to Original Regulatory Commitment and Schedule "The Oconee Large Break LOCA reanalysis incorporating the Thermal Conductivity Degradation (TCD) error correction will be performed within 15 months after NRC approval of the supplement to BAW-10192P-A."

Revision 2 to Original Regulatory Commitment and Schedule

" The Oconee Large Break LOCA reanalysis incorporating the Thermal Conductivity Degradation (TCD) error correction will be performed within 32 months after NRC approval of the TCD supplement to BAW-10192P-A."