TMI-13-150, Response to Request for Additional Information - 10 CFR 50.46 30-Day Report

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Response to Request for Additional Information - 10 CFR 50.46 30-Day Report
ML13284A013
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 10/10/2013
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TMI-13-150
Download: ML13284A013 (4)


Text

10 CFR 50.46 TMI-13-150 October 10, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Response to Request for Additional Information - 10 CFR 50.46 30-Day Report

References:

1) Letter from M. D. Jesse (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "10 CFR 50.46 30-Day Report,"

dated March 21, 2012

2) Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1 - Request for Additional Information Regarding 30-Day Report for Emergency Core Cooling System Model Changes Pursuant to the Requirements of 10 CFR 50.46 (TAC NO. ME8237),"

dated November 13, 2012

3) Letter from P. Salas (AREVA NP Inc.) to U.S. Nuclear Regulatory Commission, "Generic RAI Response to a 30-Day 10 CFR 50.46 Report of Significant PCT Change," dated December 6, 2012
4) Letter from M. D. Jesse (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information - 10 CFR 50.46 30-Day Report," dated December 12, 2012
5) Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to M. J. Pacifio (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1 - Request for Additional Information Regarding 30-Day Report for Emergency Core Cooling System Model Changes Pursuant to the Requirements of 10 CFR 50.46 (TAC NO. ME8237),"

dated March 5, 2013

Response to Request for Additional Information 10 CFR 50.46 30~Day Report October 10, 2013 Page 2

6) Letter from P. Salas (AREVA NP Inc.) to U.S. Nuclear Regulatory Commission, "Generic RAI Response to a 30~Day 50.46 Report of Significant PCT Change," dated March 28, 2013
7) Letter from M. D. Jesse (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information - 10 CFR 50.46 30-Day Report," dated April 2, 2013
8) Internal Memorandum from R. Ennis (Senior Project Manager, U.S.

Nuclear Regulatory Commission) to V. Rodriguez (Acting Chief, U.S.

Nuclear Regulatory Commission), "Three Mile Island Nuclear Station, Unit 1, Draft Request for Additional Information (TAC NO. ME8237),"

ML13253A225, dated September 10, 2013 In the Reference 1 letter Exelon Generation Company, LLC (Exelon) submitted a 30-day 10 CFR 50.46 report for Three Mile Island Nuclear Station (TMI), Unit 1. This letter discussed an AREVA NP Inc. (AREVA) notification concerning two Evaluation Model (EM) error corrections. In the Reference 2 and 5 letters the U.S. Nuclear Regulatory Commission requested additional information. References 3, 4, 6, and 7 provided the responses to these requests.

In Reference 8, the U.S. Nuclear Regulatory Commission requested additional information.

Attached is our response.

No new regulatory commitments are established in this submittal. If any additional information is needed, please contact Tom Loomis at (610) 765-5510.

Respectfully, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information - 10 CFR 50.46 30-Day Report cc: USNRC Administrator, Region I USNRC Project Manager, TMI, Unit 1 USNRC Senior Resident Inspector, TMI, Unit 1

Attachment Response to Request for Additional Information - 10 CFR 50.46 aa-Day Report

Response to Request for Additional Information 10 CFR 50.46 30~Day Report October 10, 2013 Page 1 Question:

The RAJ response does not include a proposed schedule for providing a reanalysis. In the response, the licensee states that the PCT error evaluations are supported by explicit analyses using the Babcock and Wilcox (B&W) plant emergency core cooling system (ECCS) evaluation model. Since a schedule for reanalysis was not provided, justify how generic analysis for the B&W plant ECCS evaluation model constitutes "taking other action" to show compliance with 10 CFR 50.46. In particular, while the submitted RAI response addresses the acceptance criteria contained in 10 CFR 50.46(b), the response does not address the requirement, in 10 CFR 50.46(a)(1 )(i), to calculate ECCS cooling performance "in accordance with an acceptable evaluation model." In light of the presently reported, significant, estimated effects of errors and changes, explain how the present ECCS cooling performance has been calculated in accordance with an acceptable evaluation model, such that any other action, as provided in 10 CFR 50.46(a)(3), has been taken to show compliance with 10 CFR 50.46 requirements, including those contained in 10 CFR 50.46(a)(1). Alternatively, submit a schedule for providing a reanalysis or taking other action as may be necessary to show compliance with 10 CFR 50.46 requirements.

Response

The evaluation that supports the 201210 CFR 50.46 LOCA Report for B&W Plants denotes other actions taken to show compliance with 10 CFR 50.46 requirements. The evaluation demonstrated the requirements of 10 CFR 50, Appendix K for a conservative model were fully met based on a reported estimated net zero change in peak clad temperature (PCT).

The evaluation concluded the actual net PCT would decrease; therefore, the existing model results remain conservative and acceptable. As the reported net PCT did not change, local oxidation and whole core hydrogen generation from the original model are unaffected and remain in compliance. In addition, the coolable core geometry and long-term cooling impacts remain unchanged and fully meet 10 CFR 50.46(b) requirements. ECCS cooling performance was calculated with errors corrected and this result comes from an acceptable evaluation model that complies with 10 CFR 50.46(a)(1 )(i) and 50.46(a)(1 )(ii). The analytical technique used approximates realistically the behavior of the reactor system during a loss-of-coolant accident. As such, there is a high level of probability that the criteria will not be exceeded.

In lieu of submitting a proposed schedule for providing a reanalysis, the actions already taken as described above are considered sufficient to satisfy the intent of 10 CFR 50.46(a)(3)(ii), specifically, "or taking other action as may be needed to show compliance with § 50.46 requirements."