ML13281A536
| ML13281A536 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/15/2013 |
| From: | Ellen Brown Office of Nuclear Reactor Regulation |
| To: | FirstEnergy Nuclear Operating Co |
| Brown E | |
| References | |
| Download: ML13281A536 (9) | |
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 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.
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 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.
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.
NRC Regulatory Guidance and Staff Interpretations:
Current Proposed Comments NUREGs NUREG-1465, "Accident Source Terms for Light-Water Nuclear Power Plants" February 1995
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, "
A Simplified Model of Aerosol Removal by Natural Processes in Reactor Containments" July 1996
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.
RADTRAD was previous ly utilized for the FHA calculation, which does not require NRC review as part of this submittal.
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.
NRC Generic 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 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.
Facility Specific Licensing Basis:
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 Commitments Computer Codes STARDOSE (LOCA)
STARNAUA RADTRAD 3.0.3 (LOCA, CRDA) RADTRAD 3.0.2 (MSLB) STARNAUA Utilized for accident dose analysis.
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 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