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| number = ML13281A536
| number = ML13281A536
| issue date = 10/15/2013
| issue date = 10/15/2013
| title = 10/15/13 Meeting Slide for FENOC Presubmittal Guidance Checklist Part I
| title = Meeting Slide for FENOC Presubmittal Guidance Checklist Part I
| author name = Brown E A
| author name = Brown E
| author affiliation = NRC/NRR
| author affiliation = NRC/NRR
| addressee name =  
| addressee name =  
Line 9: Line 9:
| docket = 05000440
| docket = 05000440
| license number = NPF-058
| license number = NPF-058
| contact person = Brown E A
| contact person = Brown E
| document type = License-Application for Facility Operating License (Amend/Renewal) DKT 50
| document type = License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 9
| page count = 9
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=Text=
=Text=
{{#Wiki_filter:Pre-submittal Guidance Checklist - Section I Licensee/Plant:
{{#Wiki_filter:Pre-submittal Guidance Checklist - Section I Licensee/Plant: Perry Nuclear Power Plant Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
Perry Nuclear Power Plant Proposed Licensing Action:
License Amendment Application                         10 CFR 50.55a Request                           Exemption Request                     Other     ______________________
Updated dose calculations to support use of GNF2 fuel.
Detailed Description of the Proposed Licensing Action:
License Amendment Application 10 CFR 50.55a Request Exemption Request Other   ______________________ Detailed Description of the Proposed Licensing Action: Transition to GNF2 fuel is planned for the spring 2015 refueling outage. As part of this transition process, the design basis accident analyses have been revised to incorporate the new core source term associated with GNF2 fuel, and to utilize the non-proprietary RADTRAD computer code to replace the proprietary Polestar Applied Technology model previously used in the late 1990s for PNPP's pilot plant alternative Accident Source Term (AST) analyses and in a subsequent five percent power uprate amendment. The proposed amendment is based on full implementation of an alternative Accident Source Term in the dose calculations for the BWR-applicable design basis events that do not already fully utilize the alternative Accident Source Term and that are addressed by Regulatory Guide 1.183 "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors."  USAR updates to the loss of coolant accident, main steam line break accident, and control rod drop accident calculation summaries will be provided for Nuclear Regulatory Commission review, along with one associated Technical Specification change to update the definition of Dose Equivalent Iodine 131. This amendment is being made pursuant to Title 10 Code of Federal Regulations Sections 50.59 and 50.67.
Transition to GNF2 fuel is planned for the spring 2015 refueling outage. As part of this transition process, the design basis accident analyses have been revised to incorporate the new core source term associated with GNF2 fuel, and to utilize the non-proprietary RADTRAD computer code to replace the proprietary Polestar Applied Technology model previously used in the late 1990s for PNPPs pilot plant alternative Accident Source Term (AST) analyses and in a subsequent five percent power uprate amendment.
The proposed amendment is based on full implementation of an alternative Accident Source Term in the dose calculations for the BWR-applicable design basis events that do not already fully utilize the alternative Accident Source Term and that are addressed by Regulatory Guide 1.183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. USAR updates to the loss of coolant accident, main steam line break accident, and control rod drop accident calculation summaries will be provided for Nuclear Regulatory Commission review, along with one associated Technical Specification change to update the definition of Dose Equivalent Iodine 131. This amendment is being made pursuant to Title 10 Code of Federal Regulations Sections 50.59 and 50.67.
Planned Submittal Date:
Planned Submittal Date:
November 2013 Requested Approval Date & Basis:
November 2013 Requested Approval Date & Basis:
2/27/2015; Based on Fifteenth Refuel Outage, which begins in mid-February, during which GNF2 fuel would be loaded into the core. Topics Addressed in Checklist: Checklist contains the comparison for the total licensing action. Specific topics are not separated.
2/27/2015; Based on Fifteenth Refuel Outage, which begins in mid-February, during which GNF2 fuel would be loaded into the core.
Topics Addressed in Checklist:
Checklist contains the comparison for the total licensing action. Specific topics are not separated.
Other:
Other:
N/A  
N/A


Pre-submittal Guidance Checklist - Section I Licensee/Plant:
Pre-submittal Guidance Checklist - Section I Licensee/Plant: Perry Nuclear Power Plant Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
Perry Nuclear Power Plant Proposed Licensing Action:
Preliminary Bases for the Proposed Licensing Action:
Updated dose calculations to support use of GNF2 fuel.
Technical:
Preliminary Bases for the Proposed Licensing Action: Technical:   The applicable design basis accidents are recalculated using the GNF2 source term in place of the GE14 source term, the RADTRAD code and methodology instead of Polestar Applied Technology, and the guidance in RG 1.183, resulting in a full implementation of the alternative AST. Safety: A comprehensive review of accident analysis, component and system analysis, and radiological dose consequences is in progress. The results of the completed safety review will be included in the license amendment request submittal.
The applicable design basis accidents are recalculated using the GNF2 source term in place of the GE14 source term, the RADTRAD code and methodology instead of Polestar Applied Technology, and the guidance in RG 1.183, resulting in a full implementation of the alternative AST.
Safety:
A comprehensive review of accident analysis, component and system analysis, and radiological dose consequences is in progress. The results of the completed safety review will be included in the license amendment request submittal.
Security:
Security:
The proposed amendment does not change or impact the current PNPP Security Plan; final confirmation will be obtained during development of the license amendment request submittal. No Significant Hazards Consideration:
The proposed amendment does not change or impact the current PNPP Security Plan; final confirmation will be obtained during development of the license amendment request submittal.
No Significant Hazards Consideration:
FENOC will perform a No Significant Hazards Consideration Analysis upon completion of all evaluations supporting the license amendment request. Based on initial reviews, it is expected that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in the margin of safety. The results of the completed analysis will be included in the license amendment request submittal.
FENOC will perform a No Significant Hazards Consideration Analysis upon completion of all evaluations supporting the license amendment request. Based on initial reviews, it is expected that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in the margin of safety. The results of the completed analysis will be included in the license amendment request submittal.
Environmental:   FENOC will provide an environmental consideration discussion in the license amendment request submittal. Based on initial reviews, it is expected that the proposed change will not impact the environment or the Environmental Plan. The results of the completed review will be included in the license amendment request submittal.
Environmental: FENOC will provide an environmental consideration discussion in the license amendment request submittal. Based on initial reviews, it is expected that the proposed change will not impact the environment or the Environmental Plan. The results of the completed review will be included in the license amendment request submittal.
Regulatory Organization Interface:   Reactor Systems   Accident Dose Security Electrical   Probabilistic Risk Assessment Emergency Planning Instrument and Controls   Fire Protection Technical Specifications Mechanical and Civil   Piping and NDE Special Projects Balance of Plant   Steam Generator Tube Integrity Health Physics Containment and Ventilation   Component and Performance Testing DORL - Projects NMSS   Environmental OE   NSIR   OGC Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
Regulatory Organization Interface:
Preliminary Bases for the Topic: Technical:   The applicable design basis accidents are recalculated using the GNF2 source term in place of the GE14 source term, the RADTRAD code and methodology instead of Polestar Applied Technology, and the guidance in RG 1.183, resulting in a full implementation of the alternative AST. Safety: A comprehensive review of accident analysis, component and system analysis, and radiological dose consequences is in progress. The results of the completed safety review will be included in the license amendment request submittal.
Reactor Systems                                       Accident Dose                                                     Security Electrical                                             Probabilistic Risk Assessment                                     Emergency Planning Instrument and Controls                               Fire Protection                                                   Technical Specifications Mechanical and Civil                                   Piping and NDE                                                   Special Projects Balance of Plant                                       Steam Generator Tube Integrity                                   Health Physics Containment and Ventilation                           Component and Performance Testing                                 DORL - Projects NMSS                                                   Environmental                                                     OE NSIR                                                   OGC
 
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
Preliminary Bases for the Topic:
Technical:
The applicable design basis accidents are recalculated using the GNF2 source term in place of the GE14 source term, the RADTRAD code and methodology instead of Polestar Applied Technology, and the guidance in RG 1.183, resulting in a full implementation of the alternative AST.
Safety:
A comprehensive review of accident analysis, component and system analysis, and radiological dose consequences is in progress. The results of the completed safety review will be included in the license amendment request submittal.
Security:
Security:
The proposed amendment does not change or impact the current PNPP Security Plan; final confirmation will be obtained during development of the license amendment request submittal. No Significant Hazards Consideration: FENOC will perform a No Significant Hazards Consideration Analysis upon completion of all evaluations supporting the license amendment request. Based on initial reviews, it is expected that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in the margin of safety. The results of the completed analysis will be included in the license amendment request submittal.
The proposed amendment does not change or impact the current PNPP Security Plan; final confirmation will be obtained during development of the license amendment request submittal.
Precedent Relevance and Deltas to Proposed Licensing Action:  
No Significant Hazards Consideration:
 
FENOC will perform a No Significant Hazards Consideration Analysis upon completion of all evaluations supporting the license amendment request. Based on initial reviews, it is expected that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in the margin of safety. The results of the completed analysis will be included in the license amendment request submittal.
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action:  Updated dose calculations to support use of GNF2 fuel.
Precedent                                                                       Relevance and Deltas to Proposed Licensing Action:
NRC Regulatory Guidance and Staff Interpretations:
Current  Proposed Comments  Standard Review Plan
 
15.6.5, Appendix B, "Radiological Consequences of a Design Basis Loss-of-Coolant Accident: Leakage from Engineered Safety Feature Components Outside Containment" July 1981 Section 6.5.2, "Containment Spray As A Fission Product Cleanup System" March 2007 15.6.5, Appendix B, "Radiological Consequences of a Design Basis Loss-of-Coolant Accident: Leakage from Engineered Safety Feature Components Outside Containment" July 1981
 
Regulatory Guide 1.183 is used in lieu of various Standard Review Plans, circa 1980s, that were previously used. Branch Technical Positions Review Standards
 
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action:  Updated dose calculations to support use of GNF2 fuel.
NRC Regulatory Guidance and Staff Interpretations:
Current  Proposed Comments  Regulatory Guides 1.3, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors" June 1974
 
1.5, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Steam Line Break Accident for Boiling Water Reactors (Safety Guide 5)" March 1971 1.52, "Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants" March 1978 1.3, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors" June 1974
 
1.52, "Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants" March 1978
 
1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors" July 2000 No change in how Regulatory Guide (RG) 1.3 is utilized. RG 1.3 is used for equipment qualification (EQ), vital area access, post accident sampling system access, and containment purge isolation.
 
RG 1.5 is replaced by RG 1.183.


No change for RG 1.52.  
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
NRC Regulatory                          Current                            Proposed                                Comments Guidance and Staff Interpretations:
Standard Review Plan                                          Section 6.5.2, Containment Spray As A Fission Product Cleanup System March 2007 15.6.5, Appendix B, Radiological    15.6.5, Appendix B, Radiological Consequences of a Design Basis Loss- Consequences of a Design Basis of-Coolant Accident: Leakage from    Loss-of-Coolant Accident: Leakage Engineered Safety Feature            from Engineered Safety Feature Components Outside Containment July Components Outside Containment 1981                                July 1981 Regulatory Guide 1.183 is used in lieu of various Standard Review Plans, circa 1980s, that were previously used.
Branch Technical Positions Review Standards


RG 1.183 replaces RG 1.5, TID-14844, and various Standard Review Plan sections and provides updated source term release fractions, chemical species distribution, and removal mechanisms.
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
NRC Regulatory                           Current                              Proposed                                      Comments Guidance and Staff Interpretations:
NRC Regulatory Guidance and Staff Interpretations:
Regulatory Guides        1.3, Assumptions Used for Evaluating  1.3, Assumptions Used for Evaluating    No change in how Regulatory Guide (RG) the Potential Radiological            the Potential Radiological                1.3 is utilized. RG 1.3 is used for equipment Consequences of a Loss of Coolant      Consequences of a Loss of Coolant        qualification (EQ), vital area access, post Accident for Boiling Water Reactors   Accident for Boiling Water Reactors      accident sampling system access, and June 1974                              June 1974                                containment purge isolation.
Current   Proposed Comments  NUREGs NUREG-1465, "Accident Source Terms for Light-Water Nuclear Power Plants" February 1995
1.5, Assumptions Used for Evaluating                                            RG 1.5 is replaced by RG 1.183.
the Potential Radiological Consequences of a Steam Line Break Accident for Boiling Water Reactors (Safety Guide 5) March 1971 1.52, "Design, Testing, and            1.52, "Design, Testing, and              No change for RG 1.52.
Maintenance Criteria for Post Accident Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere  Engineered-Safety-Feature Cleanup System Air Filtration and      Atmosphere Cleanup System Air Adsorption Units of Light-Water-Cooled Filtration and Adsorption Units of Light-Nuclear Power Plants March 1978      Water-Cooled Nuclear Power Plants March 1978 1.183, Alternative Radiological Source  RG 1.183 replaces RG 1.5, TID-14844, and Terms for Evaluating Design Basis        various Standard Review Plan sections and Accidents at Nuclear Power Reactors      provides updated source term release July 2000                                fractions, chemical species distribution, and removal mechanisms.


NUREG/CR-6604, "RADTRAD: A Simplified Model for RADionuclide Transport and Removal And Dose Estimation" June 1997 with Supplement 1, June 1999, and Supplement 2, October 2002 NUREG/CR-6189, "
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
A Simplified Model of Aerosol Removal by Natural Processes in Reactor Containments" July 1996  
NRC Regulatory                          Current                            Proposed                                Comments Guidance and Staff Interpretations:
NUREGs                    NUREG-1465, Accident Source Terms                                        Current LOCA calc methodology uses a for Light-Water Nuclear Power Plants                                    Revised Accident Source Term (RAST)
February 1995                                                            methodology developed by Polestar Applied Technology, based on the guidance given in NUREG-1465, to determine the post-accident radiological consequences. In the revised LOCA dose analysis based on the GNF2 source term, the RADTRAD computer code (NUREG/CR-6604) was used to estimate the containment release using RG 1.183 recommended source terms and assumptions. The control rod drop accident analysis replaces TID-14844 source term with a GNF2 source term using RADTRAD.
NUREG/CR-6604, RADTRAD: A         RADTRAD was previously utilized for the Simplified Model for RADionuclide   FHA calculation, which does not require NRC Transport and Removal And Dose     review as part of this submittal.
Estimation June 1997 with Supplement 1, June 1999, and Supplement 2, October 2002 NUREG/CR-6189, A Simplified Model of Aerosol Removal by Natural Processes in Reactor Containments July 1996 NUREG/CR-5966, A Simplified Model  NUREG/CR-5966 is used in place of of Aerosol Removal by Containment  STARNAUA methodology for spray removal Sprays                            coefficient in the revised LOCA analysis.
Interim Staff Guidance


NUREG/CR-5966, "A Simplified Model of Aerosol Removal by Containment Sprays" Current LOCA calc methodology uses a Revised Accident Source Term (RAST) methodology developed by Polestar Applied Technology, based on the guidance given in NUREG-1465, to determine the post-accident radiological consequences. In the revised LOCA dose analysis based on the GNF2 source term, the RADTRAD computer code (NUREG/CR-6604) was used to estimate the containment release using RG 1.183 recommended source terms and assumptions. The control rod drop accident analysis replaces TID-14844 source term with a GNF2 source term using RADTRAD.
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
RADTRAD was previous ly utilized for the FHA calculation, which does not require NRC review as part of this submittal.
NRC Regulatory                           Current                              Proposed                              Comments Guidance and Staff Interpretations:
 
Other TID 14844, Calculation of Distance                                         RG 1.183 replaces TID-14844 methodology Factors for Power and Test Reactor                                         and provides updated source term release Sites, J. J. Nunno, et al March 23,                                       fractions, chemical species distribution, and 1962                                                                        removal mechanisms.
NUREG/CR-5966 is used in place of STARNAUA methodology for spray removal coefficient in the revised LOCA analysis.
Interim Staff Guidance
 
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
NRC Regulatory Guidance and Staff Interpretations:
Current  Proposed Comments  Other     TID 14844, "Calculation of Distance Factors for Power and Test Reactor Sites," J. J. Nunno, et al March 23, 1962  RG 1.183 replaces TID-14844 methodology and provides updated source term release fractions, chemical species distribution, and removal mechanisms.
Current LOCA calc methodology uses a Revised Accident Source Term (RAST) developed by Polestar Applied Technology, based on the guidance given in NUREG-1465, to determine the post-accident radiological consequences. In the revised LOCA dose analysis based on the GNF2 source term, the RADTRAD computer code (NUREG/CR-6604) was used to estimate the containment release using the RG 1.183 recommended source terms and assumptions.
Current LOCA calc methodology uses a Revised Accident Source Term (RAST) developed by Polestar Applied Technology, based on the guidance given in NUREG-1465, to determine the post-accident radiological consequences. In the revised LOCA dose analysis based on the GNF2 source term, the RADTRAD computer code (NUREG/CR-6604) was used to estimate the containment release using the RG 1.183 recommended source terms and assumptions.
NRC Generic Communications:
NRC Generic                             Current                      Proposed                              Comments Communications:
Current  Proposed Comments  NRC Bulletins NRC Generic Letters 2003-01 2003-01 GL 2003-1, "Control Room Habitability" Pre-submittal Guidance Checklist - Section II Proposed Licensing Action:  Updated dose calculations to support use of GNF2 fuel.
NRC Bulletins NRC Generic Letters         2003-01                           2003-01                 GL 2003-1, Control Room Habitability
NRC Generic Communications:
Current  Proposed Comments  Regulatory Information Summaries 2001-19    2006-04 RIS 2001-19, "Deficiencies in the Documentation of Design Basis Radiological Analyses Submitted in Conjunction with License Amendment Requests" RIS 2006-04, "Experience With Implementation of Alternative Source Terms" NRC Information Notices Other     
 
Facility Specific Licensing Basis:
Current  Proposed Comments  Updated Final Safety Analysis Report Numerous USAR sections are impacted by this change, including 1.8, 3.2, 3.5, 3.7, 3.10, 3.11, 6.2, 6.4, 6.5, 9.1, 9.3, 9A, 11.3, 12.3, 15.0, 15.4, 15.6, and 15A. Applicable USAR markups will be included with the amendment application.
Technical Specifications
 
Bases  Any TS Bases changes will be processed in accordance with the TS Bases Control Program following NRC approval of the amendment application. Examples of the changes will be included in the amendment application.
Technical Requirements Manual    Fire Hazards Analysis


Report Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
Facility Specific Licensing Basis:
NRC Generic                          Current                    Proposed                                      Comments Communications:
Current  Proposed Comments  NRC Safety Evaluation Reports    NRC Correspondence Previous NRC Safety Evaluations for Amendment 103, 112, and 122 discuss current design basis radiological consequences.
Regulatory Information                                  2001-19                  RIS 2001-19, Deficiencies in the Documentation of Design Basis Radiological Analyses Submitted in Conjunction with Summaries                                                                        License Amendment Requests 2006-04                  RIS 2006-04, Experience With Implementation of Alternative Source Terms NRC Information Notices Other Facility Specific                     Current                    Proposed                                      Comments Licensing Basis:
Regulatory Commitments Computer Codes STARDOSE (LOCA)
Numerous USAR sections are impacted by this change, including Updated Final Safety                                                             1.8, 3.2, 3.5, 3.7, 3.10, 3.11, 6.2, 6.4, 6.5, 9.1, 9.3, 9A, 11.3, 12.3, Analysis Report                                                                  15.0, 15.4, 15.6, and 15A. Applicable USAR markups will be included with the amendment application.
STARNAUA RADTRAD 3.0.3 (LOCA, CRDA) RADTRAD 3.0.2 (MSLB) STARNAUA Utilized for accident dose analysis.
Any TS Bases changes will be processed in accordance with the TS Technical Specifications                                                          Bases Control Program following NRC approval of the amendment Bases                                                                            application. Examples of the changes will be included in the amendment application.
Existing STARNAUA data is used in calculating main steam line deposition.
Technical Requirements Manual Fire Hazards Analysis Report
Other      Industry Guidance:
Current  Proposed Comments  Codes and Standards Topical Reports NEDO-31400A, "Safety Evaluation for Eliminating the Boiling Water Reactor Main Steam Isolation Valve Closure Function and Scram Function of the Main Steam Line Radiation Monitor" October 1992 NEDO-31400A, "Safety


Evaluation for Eliminating the Boiling Water Reactor Main Steam Isolation Valve Closure Function and Scram Function of the Main Steam Line Radiation Monitor" October 1992 Industry Initiatives and Guidelines Other}}
Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.
Facility Specific                    Current                      Proposed                                        Comments Licensing Basis:
NRC Safety Evaluation Reports Previous NRC Safety Evaluations for Amendment 103, 112, and NRC Correspondence                                                                        122 discuss current design basis radiological consequences.
Regulatory Commitments STARDOSE (LOCA)                RADTRAD 3.0.3 (LOCA, CRDA)    Utilized for accident dose analysis.
Computer Codes                                            RADTRAD 3.0.2 (MSLB)
STARNAUA                      STARNAUA                      Existing STARNAUA data is used in calculating main steam line deposition.
Other Industry Guidance:                    Current                      Proposed                                        Comments Codes and Standards Topical Reports            NEDO-31400A, Safety          NEDO-31400A, Safety Evaluation for Eliminating the Evaluation for Eliminating the Boiling Water Reactor Main    Boiling Water Reactor Main Steam Isolation Valve          Steam Isolation Valve Closure Function and Scram     Closure Function and Scram Function of the Main Steam    Function of the Main Steam Line Radiation Monitor       Line Radiation Monitor October 1992                  October 1992 Industry Initiatives and Guidelines Other}}

Latest revision as of 11:20, 5 December 2019

Meeting Slide for FENOC Presubmittal Guidance Checklist Part I
ML13281A536
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 10/15/2013
From: Ellen Brown
Office of Nuclear Reactor Regulation
To:
FirstEnergy Nuclear Operating Co
Brown E
References
Download: ML13281A536 (9)
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Text

Pre-submittal Guidance Checklist - Section I Licensee/Plant: Perry Nuclear Power Plant Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

License Amendment Application 10 CFR 50.55a Request Exemption Request Other ______________________

Detailed Description of the Proposed Licensing Action:

Transition to GNF2 fuel is planned for the spring 2015 refueling outage. As part of this transition process, the design basis accident analyses have been revised to incorporate the new core source term associated with GNF2 fuel, and to utilize the non-proprietary RADTRAD computer code to replace the proprietary Polestar Applied Technology model previously used in the late 1990s for PNPPs pilot plant alternative Accident Source Term (AST) analyses and in a subsequent five percent power uprate amendment.

The proposed amendment is based on full implementation of an alternative Accident Source Term in the dose calculations for the BWR-applicable design basis events that do not already fully utilize the alternative Accident Source Term and that are addressed by Regulatory Guide 1.183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. USAR updates to the loss of coolant accident, main steam line break accident, and control rod drop accident calculation summaries will be provided for Nuclear Regulatory Commission review, along with one associated Technical Specification change to update the definition of Dose Equivalent Iodine 131. This amendment is being made pursuant to Title 10 Code of Federal Regulations Sections 50.59 and 50.67.

Planned Submittal Date:

November 2013 Requested Approval Date & Basis:

2/27/2015; Based on Fifteenth Refuel Outage, which begins in mid-February, during which GNF2 fuel would be loaded into the core.

Topics Addressed in Checklist:

Checklist contains the comparison for the total licensing action. Specific topics are not separated.

Other:

N/A

Pre-submittal Guidance Checklist - Section I Licensee/Plant: Perry Nuclear Power Plant Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

Preliminary Bases for the Proposed Licensing Action:

Technical:

The applicable design basis accidents are recalculated using the GNF2 source term in place of the GE14 source term, the RADTRAD code and methodology instead of Polestar Applied Technology, and the guidance in RG 1.183, resulting in a full implementation of the alternative AST.

Safety:

A comprehensive review of accident analysis, component and system analysis, and radiological dose consequences is in progress. The results of the completed safety review will be included in the license amendment request submittal.

Security:

The proposed amendment does not change or impact the current PNPP Security Plan; final confirmation will be obtained during development of the license amendment request submittal.

No Significant Hazards Consideration:

FENOC will perform a No Significant Hazards Consideration Analysis upon completion of all evaluations supporting the license amendment request. Based on initial reviews, it is expected that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in the margin of safety. The results of the completed analysis will be included in the license amendment request submittal.

Environmental: FENOC will provide an environmental consideration discussion in the license amendment request submittal. Based on initial reviews, it is expected that the proposed change will not impact the environment or the Environmental Plan. The results of the completed review will be included in the license amendment request submittal.

Regulatory Organization Interface:

Reactor Systems Accident Dose Security Electrical Probabilistic Risk Assessment Emergency Planning Instrument and Controls Fire Protection Technical Specifications Mechanical and Civil Piping and NDE Special Projects Balance of Plant Steam Generator Tube Integrity Health Physics Containment and Ventilation Component and Performance Testing DORL - Projects NMSS Environmental OE NSIR OGC

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

Preliminary Bases for the Topic:

Technical:

The applicable design basis accidents are recalculated using the GNF2 source term in place of the GE14 source term, the RADTRAD code and methodology instead of Polestar Applied Technology, and the guidance in RG 1.183, resulting in a full implementation of the alternative AST.

Safety:

A comprehensive review of accident analysis, component and system analysis, and radiological dose consequences is in progress. The results of the completed safety review will be included in the license amendment request submittal.

Security:

The proposed amendment does not change or impact the current PNPP Security Plan; final confirmation will be obtained during development of the license amendment request submittal.

No Significant Hazards Consideration:

FENOC will perform a No Significant Hazards Consideration Analysis upon completion of all evaluations supporting the license amendment request. Based on initial reviews, it is expected that the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in the margin of safety. The results of the completed analysis will be included in the license amendment request submittal.

Precedent Relevance and Deltas to Proposed Licensing Action:

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Regulatory Current Proposed Comments Guidance and Staff Interpretations:

Standard Review Plan Section 6.5.2, Containment Spray As A Fission Product Cleanup System March 2007 15.6.5, Appendix B, Radiological 15.6.5, Appendix B, Radiological Consequences of a Design Basis Loss- Consequences of a Design Basis of-Coolant Accident: Leakage from Loss-of-Coolant Accident: Leakage Engineered Safety Feature from Engineered Safety Feature Components Outside Containment July Components Outside Containment 1981 July 1981 Regulatory Guide 1.183 is used in lieu of various Standard Review Plans, circa 1980s, that were previously used.

Branch Technical Positions Review Standards

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Regulatory Current Proposed Comments Guidance and Staff Interpretations:

Regulatory Guides 1.3, Assumptions Used for Evaluating 1.3, Assumptions Used for Evaluating No change in how Regulatory Guide (RG) the Potential Radiological the Potential Radiological 1.3 is utilized. RG 1.3 is used for equipment Consequences of a Loss of Coolant Consequences of a Loss of Coolant qualification (EQ), vital area access, post Accident for Boiling Water Reactors Accident for Boiling Water Reactors accident sampling system access, and June 1974 June 1974 containment purge isolation.

1.5, Assumptions Used for Evaluating RG 1.5 is replaced by RG 1.183.

the Potential Radiological Consequences of a Steam Line Break Accident for Boiling Water Reactors (Safety Guide 5) March 1971 1.52, "Design, Testing, and 1.52, "Design, Testing, and No change for RG 1.52.

Maintenance Criteria for Post Accident Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Engineered-Safety-Feature Cleanup System Air Filtration and Atmosphere Cleanup System Air Adsorption Units of Light-Water-Cooled Filtration and Adsorption Units of Light-Nuclear Power Plants March 1978 Water-Cooled Nuclear Power Plants March 1978 1.183, Alternative Radiological Source RG 1.183 replaces RG 1.5, TID-14844, and Terms for Evaluating Design Basis various Standard Review Plan sections and Accidents at Nuclear Power Reactors provides updated source term release July 2000 fractions, chemical species distribution, and removal mechanisms.

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Regulatory Current Proposed Comments Guidance and Staff Interpretations:

NUREGs NUREG-1465, Accident Source Terms Current LOCA calc methodology uses a for Light-Water Nuclear Power Plants Revised Accident Source Term (RAST)

February 1995 methodology developed by Polestar Applied Technology, based on the guidance given in NUREG-1465, to determine the post-accident radiological consequences. In the revised LOCA dose analysis based on the GNF2 source term, the RADTRAD computer code (NUREG/CR-6604) was used to estimate the containment release using RG 1.183 recommended source terms and assumptions. The control rod drop accident analysis replaces TID-14844 source term with a GNF2 source term using RADTRAD.

NUREG/CR-6604, RADTRAD: A RADTRAD was previously utilized for the Simplified Model for RADionuclide FHA calculation, which does not require NRC Transport and Removal And Dose review as part of this submittal.

Estimation June 1997 with Supplement 1, June 1999, and Supplement 2, October 2002 NUREG/CR-6189, A Simplified Model of Aerosol Removal by Natural Processes in Reactor Containments July 1996 NUREG/CR-5966, A Simplified Model NUREG/CR-5966 is used in place of of Aerosol Removal by Containment STARNAUA methodology for spray removal Sprays coefficient in the revised LOCA analysis.

Interim Staff Guidance

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Regulatory Current Proposed Comments Guidance and Staff Interpretations:

Other TID 14844, Calculation of Distance RG 1.183 replaces TID-14844 methodology Factors for Power and Test Reactor and provides updated source term release Sites, J. J. Nunno, et al March 23, fractions, chemical species distribution, and 1962 removal mechanisms.

Current LOCA calc methodology uses a Revised Accident Source Term (RAST) developed by Polestar Applied Technology, based on the guidance given in NUREG-1465, to determine the post-accident radiological consequences. In the revised LOCA dose analysis based on the GNF2 source term, the RADTRAD computer code (NUREG/CR-6604) was used to estimate the containment release using the RG 1.183 recommended source terms and assumptions.

NRC Generic Current Proposed Comments Communications:

NRC Bulletins NRC Generic Letters 2003-01 2003-01 GL 2003-1, Control Room Habitability

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

NRC Generic Current Proposed Comments Communications:

Regulatory Information 2001-19 RIS 2001-19, Deficiencies in the Documentation of Design Basis Radiological Analyses Submitted in Conjunction with Summaries License Amendment Requests 2006-04 RIS 2006-04, Experience With Implementation of Alternative Source Terms NRC Information Notices Other Facility Specific Current Proposed Comments Licensing Basis:

Numerous USAR sections are impacted by this change, including Updated Final Safety 1.8, 3.2, 3.5, 3.7, 3.10, 3.11, 6.2, 6.4, 6.5, 9.1, 9.3, 9A, 11.3, 12.3, Analysis Report 15.0, 15.4, 15.6, and 15A. Applicable USAR markups will be included with the amendment application.

Any TS Bases changes will be processed in accordance with the TS Technical Specifications Bases Control Program following NRC approval of the amendment Bases application. Examples of the changes will be included in the amendment application.

Technical Requirements Manual Fire Hazards Analysis Report

Pre-submittal Guidance Checklist - Section II Proposed Licensing Action: Updated dose calculations to support use of GNF2 fuel.

Facility Specific Current Proposed Comments Licensing Basis:

NRC Safety Evaluation Reports Previous NRC Safety Evaluations for Amendment 103, 112, and NRC Correspondence 122 discuss current design basis radiological consequences.

Regulatory Commitments STARDOSE (LOCA) RADTRAD 3.0.3 (LOCA, CRDA) Utilized for accident dose analysis.

Computer Codes RADTRAD 3.0.2 (MSLB)

STARNAUA STARNAUA Existing STARNAUA data is used in calculating main steam line deposition.

Other Industry Guidance: Current Proposed Comments Codes and Standards Topical Reports NEDO-31400A, Safety NEDO-31400A, Safety Evaluation for Eliminating the Evaluation for Eliminating the Boiling Water Reactor Main Boiling Water Reactor Main Steam Isolation Valve Steam Isolation Valve Closure Function and Scram Closure Function and Scram Function of the Main Steam Function of the Main Steam Line Radiation Monitor Line Radiation Monitor October 1992 October 1992 Industry Initiatives and Guidelines Other

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