Letter Sequence Response to RAI |
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Category:Letter type:L
MONTHYEARL-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023 Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation L-23-215, Changes to Emergency Plan2023-10-19019 October 2023 Changes to Emergency Plan L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023 Submittal of Fifth Ten Year Inservice Testing Program L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023 Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023 Readiness for Resumption of NRC Supplemental Inspection L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022 L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023 Occupational Radiation Exposure Report for Year 2022 L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage L-23-059, Response to Apparent Violation in NRC Inspection Report 05000346/2022091; EA 23-0022023-03-0909 March 2023 Response to Apparent Violation in NRC Inspection Report 05000346/2022091; EA 23-002 L-22-212, CFR 50.55a Request RP-5 Regarding Inservice Pump Testing2023-03-0606 March 2023 CFR 50.55a Request RP-5 Regarding Inservice Pump Testing L-23-048, Response to Request for Additional Information Regarding Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report2023-03-0101 March 2023 Response to Request for Additional Information Regarding Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report L-23-057, Energy Harbor Nuclear Corp Retrospective Premium Guarantee2023-02-20020 February 2023 Energy Harbor Nuclear Corp Retrospective Premium Guarantee L-22-253, Submittal of Pressure and Temperature Limits Report, Revision 52023-01-10010 January 2023 Submittal of Pressure and Temperature Limits Report, Revision 5 L-22-284, Request for Notice of Enforcement Discretion for Technical Specification 3.7.9, Ultimate Heat Sink (UHS)2022-12-28028 December 2022 Request for Notice of Enforcement Discretion for Technical Specification 3.7.9, Ultimate Heat Sink (UHS) L-22-211, Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report2022-09-29029 September 2022 Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report L-22-216, Submittal of Pressure and Temperature Limits Report. Revision 42022-09-27027 September 2022 Submittal of Pressure and Temperature Limits Report. Revision 4 L-22-213, Occupational Radiation Exposure Report for Year 2021 - Correction2022-09-23023 September 2022 Occupational Radiation Exposure Report for Year 2021 - Correction L-22-129, Submittal of the Updated Final Safety Analysis Report, Revision 342022-09-20020 September 2022 Submittal of the Updated Final Safety Analysis Report, Revision 34 L-22-194, Submittal of Supplemental Information for the Reanalysis for Protection Against Low Temperature Reactor Coolant System Overpressure Events2022-09-19019 September 2022 Submittal of Supplemental Information for the Reanalysis for Protection Against Low Temperature Reactor Coolant System Overpressure Events L-22-203, Submittal of Evacuation Time Estimates2022-09-12012 September 2022 Submittal of Evacuation Time Estimates L-22-050, Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual2022-08-0909 August 2022 Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual L-22-152, Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan2022-07-0505 July 2022 Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan L-22-068, Cycle 22 and Refueling Outage 22 Inservice Inspection Summary Report2022-06-30030 June 2022 Cycle 22 and Refueling Outage 22 Inservice Inspection Summary Report L-22-037, 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2022-06-30030 June 2022 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models L-22-149, Post Accident Monitoring Report2022-06-23023 June 2022 Post Accident Monitoring Report L-22-153, Readiness for NRC Supplemental Inspection Required for a White Finding2022-06-22022 June 2022 Readiness for NRC Supplemental Inspection Required for a White Finding L-22-098, Withdrawal of Proposed Inservice Inspection Alternative RR-A22022-06-22022 June 2022 Withdrawal of Proposed Inservice Inspection Alternative RR-A2 L-22-136, Steam Generator Tube Circumferential Crack Report - Spring 2022 Refueling Outage2022-06-0707 June 2022 Steam Generator Tube Circumferential Crack Report - Spring 2022 Refueling Outage L-22-102, Report of Facility Changes, Tests, and Experiments2022-05-16016 May 2022 Report of Facility Changes, Tests, and Experiments L-22-092, Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 20212022-05-16016 May 2022 Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 2021 L-22-124, Response to Request for Additional Information Regarding License Amendment Request to Revise the Design Basis for the Shield Building2022-05-12012 May 2022 Response to Request for Additional Information Regarding License Amendment Request to Revise the Design Basis for the Shield Building L-22-047, Unit No.1 - Core Operating Limits Report, Cycle 23, Revision O and Revision 12022-05-10010 May 2022 Unit No.1 - Core Operating Limits Report, Cycle 23, Revision O and Revision 1 L-22-127, Readiness for NRC Supplemental Inspection Required for a Greater than Green Finding2022-05-0606 May 2022 Readiness for NRC Supplemental Inspection Required for a Greater than Green Finding L-22-089, Occupational Radiation Exposure Report for Year 20212022-04-12012 April 2022 Occupational Radiation Exposure Report for Year 2021 L-22-056, Energy Harbor Nuclear Corp., Annual Notification of Property Insurance Coverage2022-03-22022 March 2022 Energy Harbor Nuclear Corp., Annual Notification of Property Insurance Coverage L-22-059, Response to Request for Additional Information on Proposed Inservice Test Alternative RP-32022-03-21021 March 2022 Response to Request for Additional Information on Proposed Inservice Test Alternative RP-3 L-22-074, Response to Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-15015 March 2022 Response to Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations L-22-061, Ile Post Exam Letter L-22-0612022-02-24024 February 2022 Ile Post Exam Letter L-22-061 L-22-023, Retrospective Premium Guarantee2022-02-17017 February 2022 Retrospective Premium Guarantee L-21-266, Response to Request for Additional Information on Proposed Inservice Inspection Alternative RR-A22022-01-27027 January 2022 Response to Request for Additional Information on Proposed Inservice Inspection Alternative RR-A2 L-20-289, Emergency Plan Amendment Request2022-01-19019 January 2022 Emergency Plan Amendment Request L-21-290, Response to NRC Inspection Report 05000346/2021091, EA-21-1762021-12-21021 December 2021 Response to NRC Inspection Report 05000346/2021091, EA-21-176 2023-09-12
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5501 North State Route 2
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Oak Harbor, Ohio 43449 RrstEnergy Nuclear Operating Company Raymond A Lieb 419-321 -7676 Vice President, Nuclear Fax. 419-321 -7582 December 18, 2012 L-12-438 10 CFR 50.46(a)(3)(ii)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Davis-Besse Nuclear Power Station, Unit No.1 Docket No. 50-346, License No. NPF-3 Response to Request for Additional Information on 10 CFR 50.46 Report of Changes or Errors in ECCS Evaluation Models (TAC No. ME8411)
By letter dated March 16,2012 (Accession No. ML12076A237), FirstEnergy Nuclear Operating Company (FENOC) submitted a notification of a significant change and error to the large-break loss-of-coolant accident emergency core cooling model in accordance with Title 10 of the Code of Federal Regulations, Section 50.46(a)(3) for the Davis-Besse Nuclear Power Station, Unit No.1.
On November 16,2012, the Nuclear Regulatory Commission (NRC) staff requested additional information regarding this report (Accession No. ML12310A012). FENOC's response to the request, as discussed with NRC staff on October 29, 2012, is attached.
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -
Fleet Licensing, at (330) 315-6810.
Si~eIY' I~
Raymond A. Lieb
Attachment:
Response to Request for Additional Information on the Notification of Significant Change to the Large-Break Loss-of-Coolant Accident Emergency Core Cooling Model cc: NRC Region III Administrator NRC Resident Inspector Nuclear Reactor Regulation Project Manager Utility Radiological Safety Board
Attachment L-12-438 Response to Request for Additional Information on the Notification of Significant Change to the Large-Break Loss-of-Coolant Accident Emergency Core Cooling Model Page 1 of2 By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16, 2012, FirstEnergy Nuclear Operating Company (FENOC), sent a notice reporting a change or error discovered in an evaluation model, or in the application of such a model, that affects the peak cladding temperature (PCT) calculation for Davis-Besse Nuclear Power Station (DBNPS).
On November 16, 2012, the NRC requested additional information regarding this notice.
The NRC staff's request is presented in bold type, followed by FENOC's response.
- 1. There are two changes to PCT for large-break loss-of-coolant accident (LBLOCA) analysis discussed in the report submitted by the licensee. The first change is an Evaluation Model (EM) application error in the determination of the end of emergency core cooling system (ECCS) bypass, which resulted in an 80 of decrease in PCT. The second change is an EM modeling change to include the effects of the' upper plenum column weldments, which resulted in an 80 of increase in PCT.
Provide the analysis that lead to each change having an 80 of change in PCT.
Response
Details of the analyses performed by AREVA, the fuel vendor in evaluating the two EM changes, (in non-proprietary report ANP-3180, Revision 000, "177 Fuel-Assembly Plant RAI Responses to a 30-Day 50.46 Report of Significant PCT Change," December 2012) were submitted to the NRC by AREVA letter, "Generic RAI Response to a 30-Day 10 CFR 50.46 Report of Significant PCT Change," on December 6,2012. FENOC has reviewed ANP-3180, Revision 000, and has determined that the conclusions are applicable to DBNPS.
- 2. 10 CFR 50.46(a)(3)(ii) states: II *** If the change or error is significant, the applicant or licensee shall provide this report within 30 days and include with the report a proposed schedule for providing a reanalysis or taking other action as may be needed to show compliance with 50.46 requirements *** "
The PCT for LBLOCA for DBNPS has changed by an absolute value of 160 OF since the analysis was performed. Simply reporting the changes and errors in the methodology does not satisfy the intent of the regulation.
Justify not providing a schedule for reanalysis or taking other action to show compliance with 10 CFR 50.46
Attachment L-12-438 Page 2 of2
Response
In accordance with 10 CFR 50.46(a)(3)(ii), on May 27,2011 (Accession No.
ML111510642), FENOC submitted a Report of Changes or Errors for the current PCT for a large-break LOCA at DBNPS as being 2,119°F. By letter dated February 13,2012 (Accession No. ML120440609) FENOC discussed the basis for this value. This was the last reported value prior to the identification of these errors.
The AREVA report referenced in the response to Question 1 provides additional details regarding the analytical bases for the PCT error estimates, which were based upon explicit RELAP5/Mod2-B&W code runs for a Babcock & Wilcox (B&W)-designed nuclear steam supply systems (NSSS). The error that was corrected in the evaluation models was specific to the determination of the end of emergency core cooling system (ECCS) bypass. A separate change to the ECCS evaluation model was made based on the effects of the upper plenum column weldments.
As evidenced by the information provided by AREVA's response to Question 1, both of the EM items have been analyzed in detail. Furthermore, the impact on the ECCS evaluation model does not result in any challenge to the 10 CFR 50.46(b) acceptance criteria. As the individual items have been analyzed and there are no other known errors or changes to be evaluated at this time, the overall evaluation model is considered acceptable.
In summary, the responses to the NRC staff requests establish the following:
- The error-adjusted PCT for a large-break LOCA at DBNPS remains below the 10 CFR 50.46(b) acceptance criteria and is considered to be adequate.
- The SBLOCA analyses are not affected by the reported ECCS evaluation model errors.
- The AREVA response referenced in Question 1 provides additional information regarding the nature of the PCT change evaluations, which are supported by explicit analyses using the B&W plant ECCS evaluation model.
Based on the above, there are no adverse impacts to safety. Revision of the EM or design basis analysis-of-record for DBNPS is not warranted.