ML15344A294

Millstone, Unit 2, 2015/12/10 Presentation Slides for Pre-Submittal Teleconference - Proposed LAR for Charging System in Response to Confirmatory Order EA-13-188

ML15344A294
Person / Time
Site:	Millstone
Issue date:	12/10/2015
From:	Craft W D Dominion, Dominion Nuclear Connecticut
To:	Guzman R V Plant Licensing Branch 1
Guzman R V
References
TAC MF7108
Download: ML15344A294 (10)

Text

Pre-Submittal Teleconference Millstone Power Station Unit 2 (MPS2)

License Amendment Request (LAR) for Charging System in Response to Confirmatory Order EA 188 December 10, 2015

Pg. 2 Agenda *Purpose of LAR

• Scope of LAR

• AREVA Analysis for Long

-Term IOPORV

• Application of Single Failure Criterion

• Applicable Regulatory Issue

• Schedule Pg. 3 Purpose of LAR

• LAR required by Confirmatory Order EA 188 (8/26/15)

Compliance Item #2:

"By no later than February 15, 2016, DNC will submit a license amendment request to the NRC addressing the use of charging pumps in the analysis of the inadvertent opening of the PORVs."

• DNC has completed an analysis of the long

-term response for FSAR Section 14.6.1, "Inadvertent Opening of a Pressurized Water Reactor Pressurizer Pressure Relief Valve" (IOPORV) with no credit for Charging flow

• LAR will include proposed changes to Technical Specification (TS) Section 3/4.5.2 and FSAR Chapter 14 *LAR meets regulatory criteria and will preserve health and safety of the public

Pg. 4 Scope of LAR

• LAR will include more than the analysis of the FSAR Section 14.6.1 IOPORV event required by the Confirmatory Order *LAR will propose to remove Charging from TS 3/4.5.2, Emergency Core Cooling Systems

-Charging pumps appear in Surveillance Requirement (SR) 4.5.2.e as an ECCS subsystem with Operability requirements:

"By verifying the delivered flow of each charging pump at the required discharge pressure is greater than or equal to the required flow when tested pursuant to Specification 4.0.5."

-LAR will demonstrate that Charging does not meet the four criteria in 10CFR50.36 for inclusion in the Technical Specifications

-Change to TS 3/4.5.2 Bases will be provided for information

Pg. 5 Scope of LAR (Continued)

• LAR will request NRC review and approval of changes to FSAR Chapter 14

-Proposed FSAR changes are based on the FSAR prior to the 2009 FSAR change made by DNC under 10 CFR 50.59

-Proposed FSAR change reflects the new long

-term IOPORV analysis, which does not credit charging (discussed on next slide) -Proposed change to FSAR Section 14.0.11 clarifies the application of single failure for MPS2

Pg. 6 AREVA Analysis for Long

-Term IOPORV

• Analysis completed for long

-term response to an IOPORV for MPS2 -Uses NRC-approved S

-RELAP5 SBLOCA methodology in EMF

-2328, Rev. 0, with Supplement 1

-Assumes open pressurizer safety valve which bounds two open PORVs

-Credits two HPSI pumps with no flow from charging pumps

-Results demonstrate no core uncovery

• LAR will include analysis description and plots of key results

• With this new analysis, flow from the charging pumps is not credited in any FSAR Chapter 14 safety analyses for event mitigation

Application of Single Failure Criterion

• IOPORV event in FSAR Section 14.6.1 is a moderate frequency, or ANS Condition II, event

• Single failure criterion does not apply to Moderate Frequency events

-Consistent with MPS2 FSAR Section 14.0.11

-Consistent with NRC SRP (NUREG

-0800) Chapter 15

• Postulating a single failure for the IOPORV event is a Small Break LOCA (FSAR Section 14.6.3) with acceptance criteria governed by 10 CFR 50.46

• MPS2 does not apply a single failure to the IOPORV event (with the exception of the reactor protection system)

Pg. 7 Pg. 8 Applicable Regulatory Issue

• Draft Revision 1 to RIS 2005

-29 "Anticipated Transients That Could Develop Into More Serious Events"

-Draft Revision 1 to RIS 2005

-29 provides regulatory positions on the IOPORV event that is addressed in the MPS2 LAR.

-Demonstration of no long term core uncovery demonstrates that the transient meets the non

-escalation criteria Pg. 9 Schedule *DNC will submit the LAR by February 15, 2016

• Review schedule

• To maintain compliance with the Confirmatory Order, Operability Determination and Standing Order are in place for the Charging system and will remain in place until NRC makes a final determination on the LAR Acronym List

• ANS American Nuclear Society

• CFR Code of Federal Regulations

• DNC Dominion Nuclear Connecticut

• ECCS Emergency Core Cooling System

• FSAR Final Safety Analysis Report

• IOPORV Inadvertent Opening of a Pressurizer Pressure Relief Valve *LAR License Amendment Request

• MPS2 Millstone Power Station, Unit 2

• PWR Pressurized Water Reactor

• RIS Regulatory Issue Summary

• SBLOCA Small Break Loss of Coolant Accident

• SR Surveillance Requirement

• SRP Standard Review Plan

• TS Technical Specifications Pg. 10