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FE1'l0C' Perry Nuclear Power Plant PO Box 97 10 Center Road Perry, Ohio 44081 FirstEnergy Nuclear Operating Company David B. Hamilton 440-280-5382 Vice President August 21, 2017 L-17-261 10 CFR 50.46 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Report of ECCS Model Changes Pursuant to 10 CFR 50.46 On August 2, 2017, Global Nuclear Fuel -Americas, LLC issued a notification that identified a change in the evaluation model regarding the emergency core cooling system (ECCS) - loss of coolant accident (LOCA) analyses for the Perry Nuclear Power Plant (PNPP). Pursuant to 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," FirstEnergy Nuclear Operating Company is notifying the Nuclear Regulatory Commission (NRC) of the change.
The change notification stated that fuel rod temperature modeling was based on historic fuel rod designs, which featured a getter for hydrogen absorption. The change notification also stated that advances in fuel rod design have altered the fuel rod geometry and have removed the getter, such that the original model is not viewed as representative of the modern core. The GE14 and GNF2 fuel rods currently installed at the PNPP were designed without hydrogen getters. As a result, there is a slightly larger free volume inside the GE14 and GNF2 fuel rods that was not factored into the LOCA analysis for both GE14 and GNF2 fuel assemblies. Evaluation of test cases, without the getter included in the fuel rod plenum, have confirmed that this change would not show an appreciable effect and that the licensing basis peak cladding temperature (PCT) under the current methodology would remain unchanged. The effect on calculated PCT is reported as O degrees Fahrenheit (°F).
The attachment contains a summary of the 10 CFR 50.46 changes and errors, including the most recent change, applicable to the GE14 fuel in use at the PNPP. The summation of the absolute values of these changes and errors results in a value that
Perry Nuclear Power Plant L-17-261 Page 2 meets the definition of a significant change as defined by 10 CFR 50.46(a)(3)(i).
Therefore, pursuant to 10 CFR 50.46(a)(3)(ii), NRC notification of the recent change is required within 30 days, relative to the GE14 fuel. Although there is the same effect on the PCT for GNF2 fuel, NRC notification is not required, since the summation of absolute values of the changes and errors applicable to GNF2 fuel does not meet the definition of a significant change.
As a result of this change, along with previously reported changes and errors, the PNPP PCT for GE14 fuel remains 1555°F and continues to satisfy the 10 CFR 50.46(b)(1) criteria of PCT not to exceed 2200°F.
The impact on the ECCS evaluation model does not result in any challenge to the 10 CFR 50.46(b) acceptance criteria. The change has been evaluated, and there are no other known changes or errors to be evaluated at this time. The overall evaluation model is considered acceptable; therefore, a reanalysis is not required.
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.
Sincerely, David B. Hamilton
Attachment:
Perry Nuclear Power Plant 10 CFR 50.46 Changes and Errors cc: NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager
Attachment L-17-261 Perry Nuclear Power Plant 10 CFR 50.46 Changes and Errors Page 1 of 2 Vendor Summary of Change/Error Licensing Basis Peak Licensee Report of Notification Clad Temperature (PCT) Notification Number Impact (Accession No.)
2001-02 Impact of SAFER 1 pressure PCT impact for GE14 ML020710641 rate inconsistency error. fuel is +5 degree Fahrenheit (°F).
2002-01 Impact of SAFER core spray PCT impact for GE14 ML030710170 injection elevation error. fuel is +15°F.
2002-02 Impact of SAFER bulk water PCT impact for GE14 ML030710170 level error. fuel is 0°F.
2002-04 Impact of SAFER04 PCT impact for GE14 ML030710170 computer platform change. fuel is 0°F 2002-05 Impact of error in WEVOL 2 PCT impact for GE14 ML030710170 calculation of downcomer free fuel is 0°F.
volume.
2003-01 Impact of SAFER level/ PCT impact for GE14 ML040710502 volume table error. fuel is +5°F.
2003-03 Impact of SAFER initial steam PCT impact for GE14 ML040710502 separator pressure drop fuel is 0°F.
error.
2003-05 Impact of postulated PCT impact for GE14 ML040710502 post-LOCA3 hydrogen-oxygen fuel is 0°F.
recombination.
2006-01 Impact of top peaked power PCT impact for GE14 ML062490520 shape for small break LOCA fuel is 0°F. ML070390113 analysis.
2011-02 Impact of database error for PCT impact for GE14 ML112290919 heat deposition for fuel is +25°F.
1OX10 fuel bundles.
2011-03 Impact of updated formulation PCT impact for GE14 ML112290919 gamma heat deposition to fuel is -40°F.
channel wall for 1OX10 fuel bundles.
2012-01 Impact of change in fuel PCT impact for GE14 ML12353A320 properties from GESTR fuel is +20°F.
to PRIME
Attachment L-17-261 Page 2 of 2 Perry Nuclear Power Plant 10 CFR 50.46 Changes and Errors (Continued)
Vendor Summary of Change/Error Licensing Basis Peak Licensee Report of Notification Clad Temperature (PCT) Notification Number Impact (Accession No.)
2014-01 Impact of use of a new PCT impact for GE14 ML14170A178 version of SAFER04A. fuel is 0°F 2014-02 Impact of system mass PCT impact for GE14 ML14170A178 divergence error. fuel is 0°F 2014-03 Impact of minimum delta PCT impact for GE14 ML14170A178 pressure error. fuel is -15°F.
2014-04 Impact of counter current flow PCT impact for GE14 ML14170A178 limitation (CCFL) error. fuel is 0°F 2017-02 Impact of fuel rod plenum PCT impact for GE14 This submittal temperature update. fuel is 0°F TOTAL Summation of the absolute 125°F values of the changes/errors.
Notes: 1. SAFER - Name of the code developed by General Electric Company that calculates long term reactor vessel inventory and peak cladding temperature for LOCA and loss of inventory events.
- 2. WEVOL - Name of a code that is used to calculate the weight and volume inputs for jet pump plant SAFER analyses.
- 3. LOCA - Loss of coolant accident.