ML052200226

E-Mail Ennis, NRR, to Abdullahi, NRR, Et. AL, VY EPU SE Template

ML052200226
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	08/05/2005
From:	Richard Ennis Office of Nuclear Reactor Regulation
To:	Zena Abdullahi Office of Nuclear Reactor Regulation
References
Download: ML052200226 (157)

Text

I Rick Ennis~ - Revised VY EPq SE Tiernpplte R E!Re PS m - Page 1 From: Rick Ennis To: George Thomas; Leonard Ward; Muhammad Razzaque; Tai Huang; Zena Abdullahi Date: 8/5/05 1:39PM

Subject:

Revised VY EPU SE Template SRXB staff, Attached for your use is an updated Vermont Yankee Safety Evaluation template. I've revised the template to reflect the changes shown in Supplement 30 in response to RAI SRXB-A-18.

Please let me know if you have any questions.

thanks, Rick CC: Darrell Roberts; Frank Akstulewicz

I remP\GWV}00001 *TMP Page I s c:\temp\GWIOOOO1 .TMP Page 1 Mail Envelope Properties (42F3A437.467: 11: 372)

Subject:

Revised VY EPU SE Template Creation Date: 8/5/05 1:39PM From: Rick Ennis Created By: RXE@nrc.gov Recipients Action Date & Time OWGWPO01.HQGWDO0I Delivered 08/05/05 1:39 PM FMA CC (Frank Akstulewicz)

ZXA (Zena Abdullahi)

TWGWPOOI.HQGWDOOI Delivered 08/05/05 1:39PM MMRI (Muhammad Razzaque) Opened 08/05/05 1:42 PM oivf2_po.OWFNDO Delivered 08/05/05 1:39 PM GXT (George Thomas)

LWW (Leonard Ward)

TLH I (Tai Huang) oNwf4_po.OWFNDO Delivered 08/05/05 1:39 PM DJR CC (Darrell Roberts) verizon.net Transferred 08/05/05 1:39 PM ennis.rick BC (Rick)

Post Office Delivered Route OWGWPOO1.HQGWDOO1 08/05/05 1:39 PM TWGNNPOOI.HQGWDOOI 08/05/05 1:39 PM ouNf2_po.OWFNDO 08/05/05 1:39PM owf4_po.OWFNDO 08/05/05 1:39 PM verizon.net Files Size Date & Time MESSAGE 847 08/05/05 01:39PM rs-001 vy se template.wpd 417840 08/05/05 01:33PM Options Auto Delete: No Expiration Date: None Notify Recipients: Yes Priority: Standard Reply Requested: No Return Notification: None

I c:\temp\GWO00001.TMP Pace2i2 Concealed

Subject:

No Security: Standard To Be Delivered: Immediate Status Tracking: Delivered & Opened

SECTION 3.2 of RS-001 TEMPLATE SAFETY EVALUATION for BOILING-WATER REACTOR EXTENDED POWER UPRATE

RS-001, REVISION 0 REVIEW STANDARD FOR EXTENDED POWER UPRATES SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION TABLE OF CONTENTS

1.0 INTRODUCTION

................... ........... ........... 1.1 Application .................... ........... ........... 1.2 Background 1.3 Licensee's Approach ............. .......................... ............ 1.4 Plant Modifications .................................................... 1.5 Method of NRC Staff Review ............................................ 2.0 EVALUATION ........................................................... 2.1 Materials and Chemical Engineering ....................................... 2.2 Mechanical and Civil Engineering ......................................... 2.3 Electrical Enaineering ..................................................

3-2.4 Instrumentation and Controls ............................................ 2.5 Plant Svstems. ....................................................... 2.6 Containment Review Considerations ...................................... 2.7 Habitability, Filtration. and Ventilation ...................................... 2.8 Reactor Svstems ..................................................... ........... ...........

2.9 'Source Terms and Radiological Consequences Analyses ........... ...........

2.10 Health Physics .................. . . .. ... ........... ...........

2.11 Human Performance .............. . . .. ... ...........

2.12 Power Ascension and Testing Plan ... . . .. ...

2.13 Risk Evaluation .................. 3.0 FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATION CHANGES ......

RS-001, REVISION 0 REVIEW STANDARD FOR EXTENDED POWER UPRATES SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION 4.0 REGULATORY COMMITMENTS ............................................. 5.0 RECOMMENDED AREAS FOR INSPECTION ..................................

Attachment:

List of Acronyms

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. TO FACILITY OPERATING LICENSE NO. rXXX-XXI

[NAME OF LICENSEE]

NAME _ FACILITY1 DOCKET NO. 50-fXXX1

1.0 INTRODUCTION

1.1 Application By application dated [ ], as supplemented by letter[s] dated [ ], the [Name of Licensee]

(the licensee) requested changes to the Facility Operating License and Technical Specifications (TSs) for the [Plant Name]. The supplemental letter[s] dated [ ], provided additional clarifying information that did not expand the scope of the initial application and did not change the Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on [date] (XX FR XXXX).

The proposed changes would increase the maximum steady-state reactor core power level from [current licensed power level] megawatts thermal (MWt) to [power level proposed by the licensee] MWt, which is an increase of approximately [##] percent. The proposed increase in power level is considered an extended power uprate (EPU).

1.2 Background

[Plant Name] is a boiling-water reactor (BWR) plant of the BWR/[#] design with a Mark-[#]

containment. [Plant Name] has the following special features/unique designs:

[Insert any special features/unique designs]

The NRC originally licensed [Plant Name] on [date] for operation at [original licensed power level] MWt. [By Amendment No. [###] dated [ ], the NRC granted a power uprate to

[Plant Name] of [##] percent, allowing the plant to be operated at [current licensed power level] MWt.] Therefore, the proposed EPU would result in an increase of approximately

[##] percent over the original licensed power level [and [##] percent over the current licensed power level] for [Plant Name].]

SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

1.3 Licensee's ApDroach The licensee's application for the proposed EPU follows the guidance in the Office of Nuclear Reactor Regulation's (NRR's) Review Standard (RS)-001, "Review Standard for Extended Power Uprates," to the extent that the review standard is consistent with the design basis of the plant. Where differences exist between the plant-specific design basis and RS-001, the licensee described the differences and provided evaluations consistent with the design basis of the plant. The licensee also used [Identify topical reports or other documents used by the licensee for guidance related to the scope of the proposed EPU; NRC staff approvals, ranges of applicability, any limitations/restrictions associated with the documents; and consistency of the licensee's application with the ranges of applicability and limitations/restrictions. The discussion in this section is to cover topical reports and other documents referenced for the overall power uprate process. It is not intended to cover topical reports and other documents for specific methods of analyses. Topical reports and other documents referenced for specific methods of analyses are to be covered in the applicable technical evaluation section of this safety evaluation].

Insert this sentence if the licensee is planning to implement the EPU in one stage.

[The licensee plans to implement the EPU in one step. The licensee plans to make the modifications necessary to implement the EPU during the refueling outage in

[season year (e.g., fall 2003)]. Subsequently, the plant will be operated at [##] MWt starting in Cycle [##].]

Insert this paragraph if the licensee is planning to implement the EPU in stages:

[The licensee plans to implement the EPU in [#] steps of [## and ##] percent. The licensee plans to make modifications necessary to implement the first step during the refueling outage in [season year (e.g., fall 2003)]. Subsequently, the plant will be operated at [##] MWt during Cycle [##]. The remainder of the modifications will be completed during the refueling outage in [season year (e.g., fall 2003)], with subsequent operation at [##] MWt starting in Cycle [##].

1.4 Plant Modifications The licensee has determined that several plant modifications are necessary to implement the proposed EPU. The following is a list of these modifications and the licensee's proposed schedule for completing them.

[Provide a list of plant modifications.]

The NRC staff's evaluation of the licensee's proposed plant modifications is provided in Section 2.0 of this safety evaluation.

SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

-_3-1.5 Method of NRC Staff Review The NRC staff reviewed the licensee's application to ensure that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) activities proposed will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public. The purpose of the NRC staff's review is to evaluate the licensee's assessment of the impact of the proposed EPU on design-basis analyses. The NRC staff evaluated the licensee's application and supplements. The NRC staff also evaluated [Include additional review items, as necessary (e.g., audits of certain information at the plant and vendor sites, and independent analyses), for areas where such analyses were deemed appropriate by the NRC staff].

In areas where the licensee and its contractors used NRC-approved or widely accepted methods in performing analyses related to the proposed EPU, the NRC staff reviewed relevant material to ensure that the licensee/contractor used the methods consistent with the limitations and restrictions placed on the methods. In addition, the NRC staff considered the affects of the changes in plant operating conditions on the use of these methods to ensure that the methods are appropriate for use at the proposed EPU conditions. Details of the NRC staff's review are provided in Section 2.0 of this safety evaluation.

Audits of analyses supporting the EPU were conducted in relation to the following topics:

[Provide a list of areas for which audits were performed.]

The results of the audits are discussed in section 2.0 of this safety evaluation.

Independent NRC staff calculations were performed in relation to the following topics:

[Provide a list of areas for which independent NRC staff calculations were performed.]

The results of the calculations are discussed in section 2.0 of this safety evaluation.

2.0 EVALUATION 2.1 Materials and Chemical Engineering SEE INSERT 1 FOR SECTION 3.2 OF RS-001 2.2 Mechanical and Civil Engineerinq SEE INSERT 2 FOR SECTION 3.2 OF RS-001 SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.3 Electrical Engineering SEE INSERT 3 FOR SECTION 3.2 OF RS-001 2.4 Instrumentation and Controls SEE INSERT 4 FOR SECTION 3.2 OF RS-001 2.5 Plant Systems SEE INSERT 5 FOR SECTION 3.2 OF RS-001 2.6 Containment Review Considerations SEE INSERT 6 FOR SECTION 3.2 OF RS-001 2.7 Habitability. Filtration. and Ventilation SEE INSERT 7 FOR SECTION 3.2 OF RS-001 2.8 Reactor Svstems SEE INSERT 8 FOR SECTION 3.2 OF RS-001 2.9 Source Terms and Radiological Consequences Analyses SEE INSERT 9 FOR SECTION 3.2 OF RS-001 2.10 Health Phvsics SEE INSERT 10 FOR SECTION 3.2 OF RS-001 2.11 Human Performance SEE INSERT 11 FOR SECTION 3.2 OF RS-001 2.12 Power Ascension and Testinq Plan SEE INSERT 12 FOR SECTION 3.2 OF RS-001 2.13 Risk Evaluation SEE INSERT 13 FOR SECTION 3.2 OF RS-001 SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

3.0 FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATION CHANGES To achieve the EPU, the licensee proposed the following changes to the Facility Operating License and TSs for [Plant Name].

[Provide a list of license and TSs changes (including license conditions) and an NRC staff evaluation of each.]

4.0 REGULATORY COMMITMENTS Insert the following sentence if the licensee has not made any regulatory commitments in support of the EPU.

The licensee has made no regulatory commitments in its application for the EPU.

Insert the following if the licensee has made regulatory commitments in support of the EPU.

The licensee has made the following regulatory commitment(s):

[Provide a summary of each regulatory commitment made by the licensee.]

The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitment(s) are best provided by the licensee's administrative processes, including its commitment management program. The above regulatory commitments do not warrant the creation of regulatory requirements (items requiring prior NRC approval of subsequent changes).

5.0 RECOMMENDED AREAS FOR INSPECTION As described above, the NRC staff has conducted an extensive review of the licensee's plans and analyses related to the proposed EPU and concluded that they are acceptable. The NRC staff's review has identified the following areas for consideration by the NRC inspection staff during the licensee's implementation of the proposed EPU. These areas are recommended based on past experience with EPUs, the extent and unique nature of modifications necessary to implement the proposed EPU, and new conditions of operation necessary for the proposed EPU. They do not constitute inspection requirements, but are intended to give inspectors insight into important bases for approving the EPU.

[Provide list of recommended areas for inspection.]

SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

-E6-

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, the [Name of State] State official was notified of the proposed issuance of the amendment. The State official had [no] comments.

[If comments were received, address them here.]

7.0 ENVIRONMENTAL CONSIDERATION

Pursuant to 10 CFR 51.21, 51.32, 51.33, and 51.35, a draft Environmental Assessment and finding of no significant impact was prepared and published in the Federal Register on

[Date] ( FR ). The draft Environmental Assessment provided a 30-day opportunity for public comment. If no comments were received, use the following sentence: [No comments were received on the draft Environmental Assessment.] If comments were received, use the following sentence: [The NRC staff received comments which were addressed in the final environmental assessment.] The final Environmental Assessment was published in the Federal Register on [Date] ( FR ). Accordingly, based upon the environmental assessment, the Commission has determined that the issuance of this amendment will not have a significant effect on the quality of the human environment.

8.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

9.0 REFERENCES

1. RS-001, Revision 0, "Review Standard for Extended Power Uprates," December 2003.

2. [Insert additional references as necessary]

Attachment:

List of Acronyms Principal Contributors:

Date:

SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

LIST OF ACRONYMS MC alternate ac sources ac alternating current AFDL acceptable fuel damage limit ALARA as low as reasonably achievable ARAVS auxiliary and radwaste area ventilation system ARI alternate rod insertion ASME American Society of Mechanical Engineers ATWS anticipated transient without scram B&PV boiler and pressure vessel BL bulletin BOP balance-of-plant BTP branch technical position BWR boiling-water reactor BWRVIP Boiling Water Reactor Vessel and Internals Project CDF core damage frequency CFR Code of Federal Reguations CFS condensate and feedwater system CRAVS control room area ventilation system CRDA control rod drop accident CRDM control rod drive mechanism CRDS control rod drive system CUF cumulative usage factor MWS circulating water system DBA design-basis accident DBLOCA design-basis loss-of-coolant accident dc direct current DG draft guide SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

EAB exclusion area boundary ECCS emergency core cooling system EFDS equipment and floor drainage system EPG emergency procedure guideline EPRI Electric Power Research Institute EPU extended power uprate EQ environmental qualification ESF engineered safety feature ESFAS engineered safety feature actuation system ESFVS engineered safety feature ventilation system FAC flow-accelerated corrosion FHA fuel handling accident FPP fire protection program GDC general design criterion (or criteria)

GL generic letter I&C instrumentation and controls IN information notice IPE individual plant examination IPEEE individual plant examination of external events LERF large early release frequency LLHS light load handling system LOCA loss-of-coolant accident LOOP loss of offsite power LPZ low population zone MC main condenser MCES main condenser evacuation system MOV motor-operated valve MSIV main steam isolation valve MSIVLCS main steam isolation valve leakage control system SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

MSLB main steamline break MSSS main steam supply system MWt megawatts thermal NEI Nuclear Energy Institute NPSH net positive suction head NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NSSS nuclear steam supply system O&M operations and maintenance P-T pressure-temperature PWSCC primary water stress-corrosion cracking RCIC reactor core isolation cooling RCPB reactor coolant pressure boundary RCS reactor coolant system RG regulatory guide RHR residual heat removal RS review standard RWCS reactor water cleanup system SAG severe accident guideline SAR Safety Analysis Report SBO station blackout SFP spent fuel pool SFPAVS spent fuel pool area ventilation system SGTS standby gas treatment system SLCS standby liquid control system SRP Standard Review Plan SSCs structures, systems, and components SSE safe-shutdown earthquake SWMS solid waste management system SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

SWS service water system TAVS turbine area ventilation system TBS turbine bypass system TCV turbine control valve TEDE total effective dose equivalent TS technical specification UHS ultimate heat sink SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

INSERT 1 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.1 Materials and Chemical Engineering 2.1.1 Reactor Vessel Material Surveillance Program Regulatory Evaluation

[Note: VYNPS intends to participate in the BWR Integrated Surveillance Program. A license amendment request is currently pending in this regard.]

The reactor vessel material surveillance program provides a means for determining and monitoring the fracture toughness of the reactor vessel beitline materials to support analyses for ensuring the structural integrity of the ferritic components of the reactor vessel. The NRC staff's review primarily focused on the effects of the proposed EPU on the licensee's reactor vessel surveillance capsule withdrawal schedule. The NRC's acceptance criteria are based on (1) draft General Design Criterion' (GDC)-9, insofar as it requires that the reactor coolant pressure boundary (RCPB) be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage; (2) draft GDC-33, insofar as it requires that the RCPB be capable of accommodating without rupture, and with only limited allowance for energy absorption through plastic deformation, the static and dynamic loads imposed on any boundary component as a result of any inadvertent and sudden release of energy to the coolant; (3) draft GDC-34 insofar as it requires that the RCPB be designed to minimize the probability of rapidly propagating type failures; (4) 10 CFR Part 50, Appendix H, which provides for monitoring changes in the fracture toughness properties of materials in the reactor vessel beltline region; and (5) 10 CFR 50.60, which requires compliance with the requirements of 10 CFR Part 50, Appendix H. Specific review criteria are contained in Standard Review Plan (SRP) Section 5.3.1 and other guidance provided in Matrix 1 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluation of the effects of the proposed EPU on the reactor vessel surveillance withdrawal schedule and concludes that the licensee has adequately addressed changes in neutron fluence and their effects on the schedule. The NRC staff further concludes that the reactor vessel capsule withdrawal schedule is appropriate to ensure that the material surveillance program will continue to meet the requirements of 10 CFR Part 50, Appendix H, and 10 CFR 50.60, and will provide the licensee with information to ensure continued compliance with draft GDC-9, 33, and 34 in this respect following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect INSERT 1 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

to the reactor vessel material surveillance program.

INSERT 1 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.1.2 Pressure-Temperature Limits and Upper-Shelf Energy Regulatory Evaluation Pressure-temperature (P-T) limits are established to ensure the structural integrity of the ferritic components of the RCPB during any condition of normal operation, including anticipated operational occurrences and hydrostatic tests. The NRC staff's review of P-T limits covered the P-T limits methodology and the calculations for the number of effective full power years specified for the proposed EPU, considering neutron embrittlement effects and using linear elastic fracture mechanics. The NRC's acceptance criteria for P-T limits are based on (1) draft GDC-9, insofar as it requires that the RCPB be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage; (2) draft GDC-33, insofar as it requires that the RCPB be capable of accommodating without rupture, and with only limited allowance for energy absorption through plastic deformation, the static and dynamic loads imposed on any boundary component as a result of any inadvertent and sudden release of energy to the coolant; (3) draft GDC-34 insofar as it requires that the RCPB be designed to minimize the probability of rapidly propagating type failures; (4) draft GDC-35 insofar as it requires that service temperatures for RCPB components constructed of ferritic materials ensure the structural integrity of such components when subjected to potential loadings; (5)10 CFR Part 50, Appendix G, which specifies fracture toughness requirements for ferritic components of the RCPB; and (6) 10 CFR 50.60, which requires compliance with the requirements of 10 CFR Part 50, Appendix G. Specific review criteria are contained in SRP Section 5.3.2 and other guidance provided in Matrix 1 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluation of the effects of the proposed EPU on the P-T limits for the plant and concludes that the licensee has adequately addressed changes in neutron fluence and their effects on the P-T limits. The NRC staff further concludes that the licensee has demonstrated the validity of the proposed P-T limits for operation under the proposed EPU conditions. Based on this, the NRC staff concludes that the proposed P-T limits will continue to meet the requirements of 10 CFR Part 50, Appendix G, and 10 CFR 50.60 and will enable the licensee to comply with draft GDC-9, 33, 34, and 35 in this respect following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the proposed P-T limits.

INSERT 1 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.1.3 Reactor Internal and Core Support Materials Regulatory Evaluation The reactor internals and core supports include structures, systems, and components (SSCs) that perform safety functions or whose failure could affect safety functions performed by other SSCs. These safety functions include reactivity monitoring and control, core cooling, and fission product confinement (within both the fuel cladding and the reactor coolant system (RCS)). The NRC staff's review covered the materials' specifications and mechanical properties, welds, weld controls, nondestructive examination procedures, corrosion resistance, and susceptibility to degradation. The NRC's acceptance criteria for reactor internal and core support materials are based on draft GDC-1 and 10 CFR 50.55a for material specifications, controls on welding, and inspection of reactor internals and core supports. Specific review criteria are contained in SRP Section 4.5.2 and Boiling Water Reactor Vessel and Internals Project (BWRVIP)-26.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluation of the effects of the proposed EPU on the susceptibility of reactor internal and core support materials to known degradation mechanisms and concludes that the licensee has identified appropriate degradation management programs to address the effects of changes in operating temperature and neutron fluence on the integrity of reactor internal and core support materials. The NRC staff further concludes that the licensee has demonstrated that the reactor internal and core support materials will continue to be acceptable and will continue to meet the requirements of draft GDC-1 and 10 CFR 50.55a with respect to material specifications, welding controls, and inspection following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to reactor internal and core support materials.

INSERT 1 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.1.4 Reactor Coolant Pressure Boundary Materials Regulatory Evaluation The RCPB defines the boundary of systems and components containing the high-pressure fluids produced in the reactor. The NRC staff's review of RCPB materials covered their specifications, compatibility with the reactor coolant, fabrication and processing, susceptibility to degradation, and degradation management programs. The NRC's acceptance criteria for RCPB materials are based on (1) 10 CFR 50.55a and draft GDC-1, insofar as they require that SSCs important to safety be designed, fabricated, erected, constructed, tested, and inspected to quality standards commensurate with the importance of the safety functions to be performed; (2) draft GDC-40 and 42, insofar as they require that protection be provided for engineered safety features (ESFs) against the dynamic effects and missiles that might result from plant equipment failures, as well as the effects of a loss-of-coolant accident; (3) draft GDC-9 and 33, insofar as they require that the RCPB be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage; (4) draft GDC-34 insofar as it requires that the RCPB be designed to minimize the probability of rapidly propagating type failures; (5) draft GDC-35 insofar as it requires that service temperatures for RCPB components constructed of ferritic materials ensure the structural integrity of such components when subjected to potential loadings; and (6) 10 CFR Part 50, Appendix G, which specifies fracture toughness requirements for ferritic components of the RCPB. Specific review criteria are contained in SRP Section 5.2.3 and other guidance provided in Matrix 1 of RS-001.

Additional review guidance for thermal embrittlement of cast austenitic stainless steel components is contained in a letter from C. Grimes, NRC, to D. Walters, Nuclear Energy Institute (NEI), dated May 19, 2000.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluation of the effects of the proposed EPU on the susceptibility of RCPB materials to known degradation mechanisms and concludes that the licensee has identified appropriate degradation management programs to address the effects of changes in system operating temperature on the integrity of RCPB materials. The NRC staff further concludes that the licensee has demonstrated that the RCPB materials will continue to be acceptable following implementation of the proposed EPU and will continue to meet the requirements of draft GDC-1, 9, 33, 34, 35, 40, and 42, 10 CFR Part 50, Appendix G, and 10 CFR 50.55a. Therefore, the NRC staff finds the proposed EPU acceptable with respect to RCPB materials.

INSERT 1 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

INSERT 1 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.1.5 Protective Coating Systems (Paints) - Organic Materials Regulatory Evaluation Protective coating systems (paints) provide a means for protecting the surfaces of facilities and equipment from corrosion and contamination from radionuclides and also provide wear protection during plant operation and maintenance activities. The NRC staff's review covered protective coating systems used inside the containment for their suitability for and stability under design-basis loss-of-coolant accident (DBLOCA) conditions, considering radiation and chemical effects. The NRC's acceptance criteria for protective coating systems are based on (1) 10 CFR Part 50, Appendix B, which states quality assurance requirements for the design, fabrication, and construction of safety-related SSCs and (2) Regulatory Guide 1.54, Revision 1, for guidance on application and performance monitoring of coatings in nuclear power plants.

Specific review criteria are contained in SRP Section 6.1.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluation of the effects of the proposed EPU on protective coating systems and concludes that the licensee has appropriately addressed the impact of changes in conditions following a DBLOCA and their effects on the protective coatings. The NRC staff further concludes that the licensee has demonstrated that the protective coatings will continue to be acceptable following implementation of the proposed EPU and will continue to meet the requirements of 10 CFR Part 50, Appendix B. Therefore, the NRC staff finds the proposed EPU acceptable with respect to protective coatings systems.

INSERT 1 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.1.6 Flow-Accelerated Corrosion Regulatory Evaluation Flow-accelerated corrosion (FAC) is a corrosion mechanism occurring in carbon steel components exposed to flowing single- or two-phase water. Components made from stainless steel are immune to FAC, and FAC is significantly reduced in components containing small amounts of chromium or molybdenum. The rates of material loss due to FAC depend on velocity of flow, fluid temperature, steam quality, oxygen content, and pH. During plant operation, control of these parameters is limited and the optimum conditions for minimizing FAC effects, in most cases, cannot be achieved. Loss of material by FAC will, therefore, occur.

The NRC staff has reviewed the effects of the proposed EPU on FAC and the adequacy of the licensee's FAC program to predict the rate of loss so that repair or replacement of damaged components could be made before they reach critical thickness. The licensee's FAC program is based on NUREG-1344, GL 89-08, and the guidelines in Electric Power Research Institute (EPRI) Report NSAC-202L-R2. It consists of predicting loss of material using the CHECWORKS computer code, and visual inspection and volumetric examination of the affected components. The NRC's acceptance criteria are based on the structural evaluation of the minimum acceptable wall thickness for the components undergoing degradation by FAC.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusions The NRC staff has reviewed the licensee's evaluation of the effect of the proposed EPU on the FAC analysis for the plant and concludes that the licensee has adequately addressed changes in the plant operating conditions on the FAC analysis. The NRC staff further concludes that the licensee has demonstrated that the updated analyses will predict the loss of material by FAC and will ensure timely repair or replacement of degraded components following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to FAC.

INSERT 1 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.1.7 Reactor Water Cleanup System Regulatory Evaluation The reactor water cleanup system (RWCS) provides a means for maintaining reactor water quality by filtration and ion exchange and a path for removal of reactor coolant when necessary.

Portions of the RWCS comprise the RCPB. The NRC staff's review of the RWCS included component design parameters for flow, temperature, pressure, heat removal capability, and impurity removal capability; and the instrumentation and process controls for proper system operation and isolation. The review consisted of evaluating the adequacy of the plant's TSs in these areas under the proposed EPU conditions. The NRC's acceptance criteria for the RWCS are based on (1) draft GDC-9, insofar as it requires that the RCPB be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage; (2) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents; and (3) draft GDC-51, insofar as it requires that systems that contain radioactivity be designed with appropriate confinement. Specific review criteria are contained in SRP Section 5.4.8.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluation of the effects of the proposed EPU on the RWCS and concludes that the licensee has adequately addressed changes in impurity levels and pressure and their effects on the RWCS. The NRC staff further concludes that the licensee has demonstrated that the RWCS will continue to be acceptable following implementation of the proposed EPU and will continue to meet the requirements of draft GDC-9, 51, and 70. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the RWCS.

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[2.1.8 Additional Review Areas (Materials and Chemical Engineering)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT I FOR SECTION 3.2 - BWRTEMPLATE SAFETY EVALUATION DECEMBER 2003

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2.2 Mechanical and Civil Engineerinq 2.2.1 Pipe Rupture Locations and Associated Dynamic Effects Regulatory Evaluation SSCs important to safety could be impacted by the pipe-whip dynamic effects of a pipe rupture.

The NRC staff conducted a review of pipe rupture analyses to ensure that SSCs important to safety are adequately protected from the effects of pipe ruptures. The NRC staff's review covered (1) the implementation of criteria for defining pipe break and crack locations and configurations, (2) the implementation of criteria dealing with special features, such as augmented inservice inspection (ISI) programs or the use of special protective devices such as pipe-whip restraints, (3) pipe-whip dynamic analyses and results, including the jet thrust and impingement forcing functions and pipe-whip dynamic effects, and (4) the design adequacy of supports for SSCs provided to ensure that the intended design functions of the SSCs will not be impaired to an unacceptable level as a result of pipe-whip or jet impingement loadings. The NRC staff's review focused on the effects that the proposed EPU may have on items (1) thru (4) above. The NRC's acceptance criteria are based on draft GDC-40 insofar as it requires that protection be provided for ESFs against the dynamic effects and missiles that might result from plant equipment failures. Specific review criteria are contained in SRP Section 3.6.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluations related to determinations of rupture locations and associated dynamic effects and concludes that the licensee has adequately addressed the effects of the proposed EPU on them. The NRC staff further concludes that the licensee has demonstrated that ESFs will continue to meet the requirements of draft GDC-40 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the determination of rupture locations and dynamic effects associated with the postulated rupture of piping.

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2.2.2 Pressure-Retaining Components and Component Supports Regulatory Evaluation The NRC staff has reviewed the structural integrity of pressure-retaining components (and their supports) designed in accordance with the American Society of Mechanical Engineers (ASME)

Boilerand Pressure Vessel Code (B&PV Code),Section III, Division 1, and draft GDC 1, 2, 9, 33, 40 and 42. The NRC staff's review focused on the effects of the proposed EPU on the design input parameters and the design-basis loads and load combinations for normal operating, upset, emergency, and faulted conditions. The NRC staff's review covered (1) the analyses of flow-induced vibration and (2) the analytical methodologies, assumptions, ASME Code editions, and computer programs used for these analyses. The NRC staff's review also included a comparison of the resulting stresses and cumulative fatigue usage factors (CUFs) against the code-allowable limits. The NRC's acceptance criteria are based on (1) 10 CFR 50.55a and draft GDC-1, insofar as they require that those systems and components which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences be designed, fabricated, erected, constructed, tested, and inspected to quality standards commensurate with the importance of the safety functions to be performed; (2) draft GDC-2, insofar as it requires that those systems and components which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences be designed to withstand the effects of earthquakes combined with the effects of normal or accident conditions; (3) draft GDC-40 and 42, insofar as they require that protection be provide for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident; and (4) draft GDC-9 and 33, insofar as they require that the RCPB be designed and constructed so as to have an exceedingly low probability of RCPB gross rupture or significant leakage; and (5) draft GDC-34 insofar as it requires that the RCPB be designed to minimize the probability of rapidly propagating type failures. Specific review criteria are contained in SRP Sections 3.9.1, 3.9.2, 3.9.3, and 5.2.1.1; and other guidance provided in Matrix 2 of RS-001.

Technical Evaluation Nuclear Steam Supply System Piping. Components, and Supports

[Insert technical evaluation for nuclear steam supply system (NSSS) piping, components, and supports. Include an intermediate conclusion in the form of "Because

[summarize reasons], the NSSS piping, components, and supports are adequate under the proposed EPU conditions."]

Balance-of-Plant Piping, Components, and Supports

[Insert technical evaluation for balance-of-plant piping, components, and supports.

Include an intermediate conclusion in the form of "Because [summarize reasons], the balance-of-plant piping, components, and supports are adequate under the proposed INSERT2 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

EPU conditions."]

Reactor Vessel and Supports

[Insert technical evaluation for reactor vessel and supports. Include an intermediate conclusion in the form of "Because [summarize reasons], the reactor vessel and supports are adequate under the proposed EPU conditions."]

Control Rod Drive Mechanism

[Insert technical evaluation for control rod drive mechanism. Include an intermediate conclusion in the form of "Because [summarize reasons], the control rod drive mechanism is adequate under the proposed EPU conditions."]

Recirculation Pumps and Supports

[Insert technical evaluation for reactor coolant pumps and supports. Include an intermediate conclusion in the form of "Because [summarize reasons], the recirculation pumps and supports are adequate under the proposed EPU conditions."]

Conclusion The NRC staff has reviewed the licensee's evaluations related to the structural integrity of pressure-retaining components and their supports. For the reasons set forth above, the NRC staff concludes that the licensee has adequately addressed the effects of the proposed EPU on these components and their supports. Based on the above, the NRC staff further concludes that the licensee has demonstrated that pressure-retaining components and their supports will continue to meet the requirements of 10 CFR 50.55a, draft GDC-1, 2, 9, 33, 34, 40, and 42 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the structural integrity of the pressure-retaining components and their supports.

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2.2.3 Reactor Pressure Vessel Internals and Core Supports Regulatory Evaluation Reactor pressure vessel internals consist of all the structural and mechanical elements inside the reactor vessel, including core support structures. The NRC staff reviewed the effects of the proposed EPU on the design input parameters and the design-basis loads and load combinations for the reactor internals for normal operation, upset, emergency, and faulted conditions. These include pressure differences and thermal effects for normal operation, transient pressure loads associated with loss-of-coolant accidents (LOCAs), and the identification of design transient occurrences. The NRC staff's review covered (1) the analyses of flow-induced vibration for safety-related and non-safety-related reactor internal components and (2) the analytical methodologies, assumptions, ASME Code editions, and computer programs used for these analyses. The NRC staff's review also included a comparison of the resulting stresses and CUFs against the corresponding Code-allowable limits. The NRC's acceptance criteria are based on (1) 10 CFR 50.55a and draft GDC-1, insofar as they require that those systems and components which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences be designed, fabricated, erected, constructed, tested, and inspected to quality standards commensurate with the importance of the safety functions to be performed; (2) draft GDC-2, insofar as it requires that those systems and components which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences be designed to withstand the effects of earthquakes combined with the effects of normal or accident conditions; (3) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects and missiles that might result from plant equipment failures, as well as the effects of a loss of coolant accident; and (4) draft GDC-6, insofar as it requires that the reactor core be designed with appropriate margin to assure that acceptable fuel damage limits (AFDLs) are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. Specific review criteria are contained in SRP Sections 3.9.1, 3.9.2, 3.9.3, and 3.9.5; and other guidance provided in Matrix 2 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluations related to the structural integrity of reactor internals and core supports and concludes that the licensee has adequately addressed the effects of the proposed EPU on the reactor internals and core supports. The NRC staff further concludes that the licensee has demonstrated that the reactor internals and core INSERT2 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

supports will continue to meet the requirements of 10 CFR 50.55a, draft GDC-1, 2, 6, 40, and 42 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the design of the reactor internal and core supports.

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2.2.4 Safety-Related Valves and Pumps Regulatory Evaluation The NRC's staff's review included certain safety-related pumps and valves typically designated as Class 1, 2, or 3 under Section III of the ASME B&PV Code and within the scope of Section XI of the ASME B&PV Code and the ASME Operations and Maintenance (O&M) Code, as applicable. The NRC staff's review focused on the effects of the proposed EPU on the required functional performance of the valves and pumps. The review also covered any impacts that the proposed EPU may have on the licensee's motor-operated valve (MOV) programs related to GL 89-10, GL 96-05, and GL 95-07. The NRC staff also evaluated the licensee's consideration of lessons learned from the MOV program and the application of those lessons learned to other safety-related power-operated valves. The NRC's acceptance criteria are based on (1) draft GDC-1, insofar as it requires that those systems and components which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed; (2) draft GDC-38, 46, 47, 48, 59, 60, 61, 63, 64, and 65 insofar as they require that the emergency core cooling system (ECCS), the containment heat removal system, the containment atomospheric cleanup systems, and the cooling water system, respectively, be designed to permit appropriate periodic testing to ensure the leak-tight integrity and performance of their active components; (3) draft GDC-57, insofar as it requires that piping systems penetrating containment be designed with the capability to periodically test the operability of the isolation valves to determine if valve leakage is within acceptable limits; and (4) 10 CFR 50.55a(f), insofar as it requires that pumps and valves subject to that section must meet the inservice testing program requirements identified in that section. Specific review criteria are contained in SRP Sections 3.9.3 and 3.9.6; and other guidance provided in Matrix 2 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessments related to the functional performance of safety-related valves and pumps and concludes that the licensee has adequately addressed the effects of the proposed EPU on safety-related pumps and valves. The NRC staff further concludes that the licensee has adequately evaluated the effects of the proposed EPU on its MOV programs related to GL 89-10, GL 96-05, and GL 95-07, and the lessons learned from those programs to other safety-related, power-operated valves. Based on this, the NRC staff concludes that the licensee has demonstrated that safety-related valves and pumps will INSERT 2 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

continue to meet the requirements of draft GDC-1, 38, 46, 47, 48, 57, 59, 60, 61, 63, 64, and 65, and 10 CFR 50.55a(f) following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to safety-related valves and pumps.

INSERT2 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.2.5 Seismic and Dynamic Qualification of Mechanical and Electrical Equipment Regulatory Evaluation Mechanical and electrical equipment covered by this section includes equipment associated with systems that are essential to emergency reactor shutdown, containment isolation, reactor core cooling, and containment and reactor heat removal. Equipment associated with systems essential to preventing significant releases of radioactive materials to the environment are also covered by this section. The NRC staff's review focused on the effects of the proposed EPU on the qualification of the equipment to withstand seismic events and the dynamic effects associated pipe-whip and jet impingement forces. The primary input motions due to the safe shutdown earthquake (SSE) are not affected by an EPU. The NRC's acceptance criteria are based on (1) draft GDC-1, insofar as it requires that that those systems and components which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed; (2) draft GDC-2, insofar as it requires that those systems and components which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences be designed to withstand the effects of earthquakes combined with the effects of normal or accident conditions; (3) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects and missiles that might result from plant equipment failures, as well as the effects of a loss of coolant accident; (4) draft GDC-9 and 33, insofar as they require that the RCPB be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage; (5) draft GDC-34 insofar as it requires that the RCPB be designed to minimize the probability of rapidly propagating type failures; and (6) 10 CFR Part 50, Appendix B, which sets quality assurance requirements for safety-related equipment. Specific review criteria are contained in SRP Section 3.1 0.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's evaluations of the effects of the proposed EPU on the qualification of mechanical and electrical equipment and concludes that the licensee has (1) adequately addressed the effects of the proposed EPU on this equipment and (2) demonstrated that the equipment will continue to meet the requirements of draft GDC-1, 2, 9, 33, 34, 40, and 42; 10 CFR Part 100, Appendix A; and 10 CFR Part 50, Appendix B, following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed INSERT 2 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

EPU acceptable with respect to the qualification of the mechanical and electrical equipment.

INSERT 2 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

[2.2.6 Additional Review Areas (Mechanical and Civil Engineering)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

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2.3 Electrical Engineering 2.3.1 Environmental Qualification of Electrical Equipment Regulatory Evaluation Environmental qualification (EQ) of electrical equipment involves demonstrating that the equipment is capable of performing its safety function under significant environmental stresses which could result from DBAs. The NRC staff's review focused on the effects of the proposed EPU on the environmental conditions that the electrical equipment will be exposed to during normal operation, anticipated operational occurrences, and accidents. The NRC staff's review was conducted to ensure that the electrical equipment will continue to be capable of performing its safety functions following implementation of the proposed EPU. The NRC's acceptance criteria for EQ of electrical equipment are based on 10 CFR 50.49, which sets forth requirements for the qualification of electrical equipment important to safety that is located in a harsh environment. Specific review criteria are contained in SRP Section 3.11.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the EQ of electrical equipment and concludes that the licensee has adequately addressed the effects of the proposed EPU on the environmental conditions for and the qualification of electrical equipment. The NRC staff further concludes that the electrical equipment will continue to meet the relevant requirements of 10 CFR 50.49 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the EQ of electrical equipment.

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2.3.2 Offsite Power System Regulatory Evaluation The offsite power system includes two or more physically independent circuits capable of operating independently of the onsite standby power sources. The NRC staff's review covered the descriptive information, analyses, and referenced documents for the offsite power system; and the stability studies for the electrical transmission grid. The NRC staff's review focused on whether the loss of the nuclear unit, the largest operating unit on the grid, or the most critical transmission line will result in the loss of offsite power (LOOP) to the plant following implementation of the proposed EPU. The NRC's acceptance criteria for offsite power systems are based on draft GDC-39. Specific review criteria are contained in SRP Sections 8.1 and 8.2, Appendix A to SRP Section 8.2, and Branch Technical Positions (BTPs) PSB-1 and ICSB-1 1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the offsite power system and concludes that the offsite power system will continue to meet the requirements of draft GDC-39 following implementation of the proposed EPU. Adequate physical and electrical separation exists and the offsite power system has the capacity and capability to supply power to all safety loads and other required equipment. The NRC staff further concludes that the impact of the proposed EPU on grid stability is insignificant.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to the offsite power system.

INSERT 3 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.3.3 AC Onsite Power System Regulatory Evaluation The alternating current (ac) onsite power system includes those standby power sources, distribution systems, and auxiliary supporting systems provided to supply power to safety-related equipment. The NRC staff's review covered the descriptive information, analyses, and referenced documents for the ac onsite power system. The NRC's acceptance criteria for the ac onsite power system are based on draft GDC-24 and 39, insofar as they require the system to have the capacity and capability to perform its intended functions during anticipated operational occurrences and accident conditions. Specific review criteria are contained in SRP Sections 8.1 and 8.3.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the ac onsite power system and concludes that the licensee has adequately accounted for the effects of the proposed EPU on the system's functional design. The NRC staff further concludes that the ac onsite power system will continue to meet the requirements of draft GDC-24 and 39 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the ac onsite power system.

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2.3.4 DC Onsite Power System Regulatory Evaluation The direct current (dc) onsite power system includes the dc power sources and their distribution and auxiliary supporting systems that are provided to supply motive or control power to safety-related equipment. The NRC staff's review covered the information, analyses, and referenced documents for the dc onsite power system. The NRC's acceptance criteria for the dc onsite power system are based on draft GDC-24 and 39, insofar as they require the system to have the capacity and capability to perform its intended functions during anticipated operational occurrences and accident conditions. Specific review criteria are contained in SRP Sections 8.1 and 8.3.2 Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the dc onsite power system and concludes that the licensee has adequately accounted for the effects of the proposed EPU on the system's functional design. The NRC staff further concludes that the dc onsite power system will continue to meet the requirements of draft GDC-24 and 39 following implementation of the proposed EPU. Adequate physical and electrical separation exists and the system has the capacity and capability to supply power to all safety loads and other required equipment. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the dc onsite power system.

INSERT 3 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.3.5 Station Blackout Regulatory Evaluation Station blackout (SBO) refers to a complete loss of ac electric power to the essential and nonessential switchgear buses in a nuclear power plant. SBO involves the LOOP concurrent with a turbine trip and failure of the onsite emergency ac power system. SBO does not include the loss of available ac power to buses fed by station batteries through inverters or the loss of power from "alternate ac sources" (AACs). The NRC staff's review focused on the impact of the proposed EPU on the plant's ability to cope with and recover from an SBO event for the period of time established in the plant's licensing basis. The NRC's acceptance criteria for SBO are based on 10 CFR 50.63. Specific review criteria are contained in SRP Sections 8.1 and Appendix B to SRP Section 8.2; and other guidance provided in Matrix 3 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the plant's ability to cope with and recover from an SBO event for the period of time established in the plant's licensing basis. The NRC staff concludes that the licensee has adequately evaluated the effects of the proposed EPU on SBO and demonstrated that the plant will continue to meet the requirements of 10 CFR 50.63 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to SBO.

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[2.3.6 Additional Review Areas (Electrical Engineering)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

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2.4 Instrumentation and Controls 2.4.1 Reactor Protection. Safety Features Actuation, and Control Systems Regulatory Evaluation Instrumentation and control systems are provided (1) to control plant processes having a significant impact on plant safety, (2) to initiate the reactivity control system (including control rods), (3) to initiate the engineered safety features (ESF) systems and essential auxiliary supporting systems, and (4) for use to achieve and maintain a safe shutdown condition of the plant. Diverse instrumentation and control systems and equipment are provided for the express purpose of protecting against potential common-mode failures of instrumentation and control protection systems. The NRC staff conducted a review of the reactor trip system, engineered safety feature actuation system (ESFAS), safe shutdown systems, control systems, and diverse instrumentation and control systems for the proposed EPU to ensure that the systems and any changes necessary for the proposed EPU are adequately designed such that the systems continue to meet their safety functions. The NRC staff's review was also conducted to ensure that failures of the systems do not affect safety functions. The NRC's acceptance criteria related to the quality of design of protection and control systems are based on 10 CFR 50.55a(a)(1), 10 CFR 50.55a(h), and draft GDC-1, 11, 12, 14, 15, 19, 20,22, 23, 25, 26, 40, and 42. Specific review criteria are contained in SRP Sections 7.0, 7.2, 7.3, 7.4, 7.7, and 7.8.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's application related to the effects of the proposed EPU on the functional design of the reactor trip system, ESFAS, safe shutdown system, and control systems. The NRC staff concludes that the licensee has adequately addressed the effects of the proposed EPU on these systems and that the changes that are necessary to achieve the proposed EPU are consistent with the plant's design basis. The NRC staff further concludes that the systems will continue to meet the requirements of 10 CFR 50.55a(a)(1),

10 CFR 50.55(a)(h), and draft GDC-1, 11, 12,14,15,19, 20,22, 23, 25, 26, 40, and 42.

Therefore, the NRC staff finds the licensee's proposed EPU acceptable with respect to instrumentation and controls.

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[2.4.2 Additional Review Areas (Instrumentation and Controls)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT4 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

INSERT 5 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION

2.5 Plant Systems 2.5.1 Internal Hazards 2.5.1.1 Flooding 2.5.1.1.1 Flood Protection Regulatory Evaluation The NRC staff conducted a review in the area of flood protection to ensure that SSCs important to safety are protected from flooding. The NRC staff's review covered flooding of SSCs important to safety from internal sources, such as those caused by failures of tanks and vessels. The NRC staff's review focused on increases of fluid volumes in tanks and vessels assumed in flooding analyses to assess the impact of any additional fluid on the flooding protection that is provided. The NRC's acceptance criteria for flood protection are based on draft GDC-2. Specific review criteria are contained in SRP Section 3.4.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the proposed changes in fluid volumes in tanks and vessels for the proposed EPU. The NRC staff concludes that SSCs important to safety will continue to be protected from flooding and will continue to meet the requirements of draft GDC-2 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to flood protection.

INSERT 5 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.5.1.1.2 Equipment and Floor Drains Regulatory Evaluation The function of the equipment and floor drainage system (EFDS) is to assure that waste liquids, valve and pump leakoffs, and tank drains are directed to the proper area for processing or disposal. The EFDS is designed to handle the volume of leakage expected, prevent a backflow of water that might result from maximum flood levels to areas of the plant containing safety-related equipment, and protect against the potential for inadvertent transfer of contaminated fluids to an uncontaminated drainage system. The NRC staff's review of the EFDS included the collection and disposal of liquid effluents outside containment.

The NRC staff's review focused on any changes in fluid volumes or pump capacities that are necessary for the proposed EPU and are not consistent with previous assumptions with respect to floor drainage considerations. The NRC's acceptance criteria for the EFDS are based on draft GDC-2 insofar as it requires the EFDS to be designed to withstand the effects of earthquakes and to be compatible with the environmental conditions (flooding) associated with normal operation, maintenance, testing, and postulated accidents (pipe failures and tank ruptures). Specific review criteria are contained in SRP Section 9.3.3.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the EFDS and concludes that the licensee has adequately accounted for the plant changes resulting in increased water volumes and larger capacity pumps or piping systems. The NRC staff concludes that the EFDS has sufficient capacity to (1) handle the additional expected leakage resulting from the plant changes, (2) prevent the backflow of water to areas with safety-related equipment, and (3) ensure that contaminated fluids are not transferred to noncontaminated drainage systems. Based on this, the NRC staff concludes that the EFDS will continue to meet the requirements of draft GDC-2 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the EFDS.

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2.5.1.1.3 Circulating Water System Regulatory Evaluation The circulating water system (CWS) provides a continuous supply of cooling water to the main condenser to remove the heat rejected by the turbine cycle and auxiliary systems. The NRC staff's review of the CWS focused on changes in flooding analyses that are necessary due to increases in fluid volumes or installation of larger capacity pumps or piping needed to accommodate the proposed EPU. The NRC's acceptance criteria for the CWS are based on draft GDC-40 for the effects of flooding of safety-related areas due to leakage from the CWS and the effects of malfunction or failure of a component or piping of the CWS on the functional performance capabilities of safety-related SSCs. Specific review criteria are contained in SRP Section 10.4.5.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the modifications to the CWS and concludes that the licensee has adequately evaluated these modifications. The NRC staff concludes that, consistent with the requirements of draft GDC-40, the increased volumes of fluid leakage that could potentially result from these modifications would not result in the failure of safety-related SSCs following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the CWS.

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2.5.1.2 Missile Protection 2.5.1.2.1. Internally Generated Missiles Regulatory Evaluation The NRC staff's review concerns missiles that could result from in-plant component overspeed failures and high-pressure system ruptures. The NRC staff's review of potential missile sources covered pressurized components and systems, and high-speed rotating machinery. The NRC staff's review was conducted to ensure that safety-related SSCs are adequately protected from internally generated missiles. In addition, for cases where safety-related SSCs are located in areas containing non-safety-related SSCs, the NRC staff reviewed the non-safety-related SSCs to ensure that their failure will not preclude the intended safety function of the safety-related SSCs. The NRC staff's review focused on any increases in system pressures or component overspeed conditions that could result during plant operation, anticipated operational occurrences, or changes in existing system configurations such that missile barrier considerations could be affected. The NRC's acceptance criteria for the protection of SSCs important to safety against the effects of internally generated missiles that may result from equipment failures are based on draft GDC-40. Specific review criteria are contained in SRP Sections 3.5.1.1 and 3.5.1.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the changes in system pressures and configurations that are required for the proposed EPU and concludes that SSCs important to safety will continue to be protected from internally generated missiles and will continue to meet the requirements of draft GDC-40 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to internally generated missiles.

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2.5.1.2.2 Turbine Generator Regulatory Evaluation The turbine control system, steam inlet stop and control valves, low pressure turbine steam intercept and inlet control valves, and extraction steam control valves control the speed of the turbine under normal and abnormal conditions, and are thus related to the overall safe operation of the plant. The NRC staff's review of the turbine generator focused on the effects of the proposed EPU on the turbine overspeed protection features to ensure that a turbine overspeed condition above the design overspeed is very unlikely. The NRC's acceptance criteria for the turbine generator are based on draft GDC-40, and relates to protection of ESFs from the effects of turbine missiles by providing a turbine overspeed protection system (with suitable redundancy) to minimize the probability of generating turbine missiles. Specific review criteria are contained in SRP Section 10.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the turbine generator and concludes that the licensee has adequately accounted for the effects of changes in plant conditions on turbine overspeed. The NRC staff concludes that the turbine generator will continue to provide adequate turbine overspeed protection to minimize the probability of generating turbine missiles and will continue to meet the requirements of draft GDC-40 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the turbine generator.

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2.5.1.3 Pipe Failures Regulatory Evaluation The NRC staff conducted a review of the plant design for protection from piping failures outside containment to ensure that (1) such failures would not cause the loss of needed functions of safety-related systems and (2) the plant could be safely shut down in the event of such failures.

The NRC staff's review of pipe failures included high and moderate energy fluid system piping located outside of containment. The NRC staff's review focused on the effects of pipe failures on plant environmental conditions, control room habitability, and access to areas important to safe control of postaccident operations where the consequences are not bounded by previous analyses. The NRC's acceptance criteria for pipe failures are based on draft GDC-40 and 42, insofar that they require that ESFs be designed to accommodate the dynamic effects of postulated pipe ruptures, as well as the effects of a loss of coolant accident. Specific review criteria are contained in SRP Section 3.6.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the changes that are necessary for the proposed EPU and the licensee's proposed operation of the plant, and concludes that SSCs important to safety will continue to be protected from the dynamic effects of postulated piping failures in fluid systems outside containment and will continue to meet the requirements of draft GDC-40 and 42 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to protection against postulated piping failures in fluid systems outside containment.

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2.5.1.4 Fire Protection Regulatory Evaluation The purpose of the fire protection program (FPP) is to provide assurance, through a defense-in-depth design, that a fire will not prevent the performance of necessary safe plant shutdown functions and will not significantly increase the risk of radioactive releases to the environment. The NRC staff's review focused on the effects of the increased decay heat on the plant's safe shutdown analysis to ensure that SSCs required for the safe shutdown of the plant are protected from the effects of the fire and will continue to be able to achieve and maintain safe shutdown following a fire. The NRC's acceptance criteria for the FPP are based on (1) 10 CFR 50.48 and associated Appendix R to 10 CFR Part 50, insofar as they require the development of an FPP to ensure, among other things, the capability to safely shut down the plant; and (2) draft GDC-3, insofar as it requires that the reactor facility be designed (a) to minimize the probability of events, such as fire and explosions, and (b) to minimize the potential effects of such events to safety. Specific review criteria are contained in SRP Section 9.5.1, as supplemented by the guidance provided in Attachment 2 to Matrix 5 of Section 2.1 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's fire-related safe shutdown assessment and concludes that the licensee has adequately accounted for the effects of the increased decay heat on the ability of the required systems to achieve and maintain safe shutdown conditions.

The NRC staff further concludes that the FPP will continue to meet the requirements of 10 CFR 50.48, Appendix R to 10 CFR Part 50, and draft GDC-3 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to fire protection.

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2.5.2 Fission Product Control 2.5.2.1 Fission Product Control Systems and Structures Regulatory Evaluation The NRC staff's review for fission product control systems and structures covered the basis for developing the mathematical model for DBLOCA dose computations, the values of key parameters, the applicability of important modeling assumptions, and the functional capability of ventilation systems used to control fission product releases. The NRC staff's review primarily focused on any adverse effects that the proposed EPU may have on the assumptions used in the analyses for control of fission products. The NRC's acceptance criteria are based on draft GDC-70, insofar as it requires that the facility design include those means necessary to maintain radioactivity control on the basis of 10CFR50.67 dose guidelines for potential reactor accidents. Specific review criteria are contained in SRP Section 6.5.3.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on fission product control systems and structures. The NRC staff concludes that the licensee has adequately accounted for the increase in fission products and changes in expected environmental conditions that would result from the proposed EPU. The NRC staff further concludes that the fission product control systems and structures will continue to provide adequate fission product removal in postaccident environments following implementation of the proposed EPU. Based on this, the NRC staff also concludes that the fission product control systems and structures will continue to meet the requirements of draft GDC-70. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the fission product control systems and structures.

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2.5.2.2 Main Condenser Evacuation System Regulatory Evaluation The main condenser evacuation system (MCES) generally consists of two subsystems:

(1) the hogging" or startup system which initially establishes main condenser vacuum and (2) the system which maintains condenser vacuum once it has been established. The NRC staff's review focused on modifications to the system that may affect gaseous radioactive material handling and release assumptions, and design features to preclude the possibility of an explosion (if the potential for explosive mixtures exists). The NRC's acceptance criteria for the MCES are based on (1) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents; and (2) draft GDC-17, insofar as it requires that means be provided for monitoring effluent discharge paths and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences and postulated accidents. Specific review criteria are contained in SRP Section 10.4.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of required changes to the MCES and concludes that the licensee has adequately evaluated these changes. The NRC staff concludes that the MCES will continue to maintain its ability to control and provide monitoring for releases of radioactive materials to the environment following implementation of the proposed EPU. The NRC also concludes that the MCES will continue meet the requirements of draft GDC-17 and 70. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the MCES.

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2.5.2.3 Turbine Gland Sealing System Regulatory Evaluation The turbine gland sealing system is provided to control the release of radioactive material from steam in the turbine to the environment. The NRC staff reviewed changes to the turbine gland sealing system with respect to factors that may affect gaseous radioactive material handling (e.g., source of sealing steam, system interfaces, and potential leakage paths). The NRC's acceptance criteria for the turbine gland sealing system are based on (1) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents; and (2) draft GDC-17, insofar as it requires that means be provided for monitoring effluent discharge paths and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences and postulated accidents. Specific review criteria are contained in SRP Section 10.4.3.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of required changes to the turbine gland sealing system and concludes that the licensee has adequately evaluated these changes.

The NRC staff concludes that the turbine gland sealing system will continue to maintain its ability to control and provide monitoring for releases of radioactive materials to the environment consistent with draft GDC-17 and 70. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the turbine gland sealing system.

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2.5.2.4 Main Steam Isolation Valve Leakage Control System

['Not applicable. VYNPS does not have a MSIV leakage control system.1 Regulatory Evaluation Technical Evaluation Conclusion INSERT 5 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.5.3 Component Cooling and Decay Heat Removal 2.5.3.1 Spent Fuel Pool Cooling and Cleanup System Regulatory Evaluation The spent fuel pool provides wet storage of spent fuel assemblies. The safety function of the spent fuel pool cooling and cleanup system is to cool the spent fuel assemblies and keep the spent fuel assemblies covered with water during all storage conditions. The NRC staff's review for the proposed EPU focused on the effects of the proposed EPU on the capability of the system to provide adequate cooling to the spent fuel during all operating and accident conditions. The NRC's acceptance criteria for the spent fuel pool cooling and cleanup system are based on (1) draft GDC-67, insofar as it requires that reliable decay heat removal systems be designed to prevent damage to the fuel in storage. Specific review criteria are contained in SRP Section 9.1.3, as supplemented by the guidance provided in Attachment 1 to Matrix 5 of Section 2.1 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to the spent fuel pool cooling and cleanup system and concludes that the licensee has adequately accounted for the effects of the proposed EPU on the spent fuel pool cooling function of the system. Based on this review, the NRC staff concludes that the spent fuel pool cooling and cleanup system will continue to provide sufficient cooling capability to cool the spent fuel pool following implementation of the proposed EPU and will continue to meet the requirements of draft GDC-

67. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the spent fuel pool cooling and cleanup system.

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2.5.3.2 Station Service Water System Regulatory Evaluation The station service water system (SWS) provides essential cooling to safety-related equipment and may also provide cooling to non-safety-related auxiliary components that are used for normal plant operation. The NRC staff's review covered the characteristics of the station SWS components with respect to their functional performance as affected by adverse operational (i.e., water hammer) conditions, abnormal operational conditions, and accident conditions (e.g., a LOCA with the LOOP). The NRC staff's review focused on the additional heat load that would result from the proposed EPU. The NRC's acceptance criteria are based on draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident. Specific review criteria are contained in SRP Section 9.2.1, as supplemented by GL 89-13 and GL 96-06.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to the effects of the proposed EPU on the station SWS and concludes that the licensee has adequately accounted for the increased heat loads on system performance that would result from the proposed EPU. The NRC staff concludes that the station SWS will continue to be protected from the dynamic effects associated with flow instabilities and provide sufficient cooling for SSCs important to safety following implementation of the proposed EPU. Therefore, the NRC staff has determined that the station SWS will continue to meet the requirements of draft GDC-40 and

42. Based on the above, the NRC staff finds the proposed EPU acceptable with respect to the station SWS.

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2.5.3.3 Reactor Auxiliary Cooling Water Systems Regulatory Evaluation The NRC staff's review covered reactor auxiliary cooling water systems that are required for (1) safe shutdown during normal operations, anticipated operational occurrences, and mitigating the consequences of accident conditions, or (2) preventing the occurrence of an accident. These systems include closed-loop auxiliary cooling water systems for reactor system components, reactor shutdown equipment, ventilation equipment, and components of the ECCS. The NRC staff's review covered the capability of the auxiliary cooling water systems to provide adequate cooling water to safety-related ECCS components and reactor auxiliary.

equipment for all planned operating conditions. Emphasis was placed on the cooling water systems for safety-related components (e.g., ECCS equipment, ventilation equipment, and reactor shutdown equipment). The NRC staff's review focused on the additional heat load that would result from the proposed EPU. The NRC's acceptance criteria for the reactor auxiliary cooling water system are based on draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident. Specific review criteria are contained in SRP Section 9.2.2, as supplemented by GL 89-13 and GL 96-06.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the reactor auxiliary cooling water systems and concludes that the licensee has adequately accounted for the increased heat loads from the proposed EPU on system performance. The NRC staff concludes that the reactor auxiliary cooling water systems will continue to be protected from the dynamic effects associated with flow instabilities and provide sufficient cooling for SSCs important to safety following implementation of the proposed EPU. Therefore, the NRC staff has determined that the reactor auxiliary cooling water systems will continue to meet the requirements of draft GDC-40 and 42. Based on the above, the NRC staff finds the proposed EPU acceptable with respect to the reactor auxiliary cooling water systems.

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2.5.3.4 Ultimate Heat Sink Regulatory Evaluation The ultimate heat sink (UHS) is the source of cooling water provided to dissipate reactor decay heat and essential cooling system heat loads after a normal reactor shutdown or a shutdown following an accident. The NRC staff's review focused on the impact that the proposed EPU has on the decay heat removal capability of the UHS. Additionally, the NRC staff's review included evaluation of the design-basis UHS temperature limit determination to confirm that post-licensing data trends (e.g., air and water temperatures, humidity, wind speed, water volume) do not establish more severe conditions than previously assumed. Specific review criteria are contained in SRP Section 9.2.5.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the information that was provided by the licensee for addressing the effects that the proposed EPU would have on the UHS safety function, including the licensee's validation of the design-basis UHS temperature limit based on post-licensing data.

Based on the information that was provided, the NRC staff concludes that the proposed EPU will not compromise the design-basis safety function of the UHS, and that the UHS will continue to satisfy applicable safety requirements following implementation of the proposed EPU.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to the UHS.

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2.5.4 Balance-of-Plant Systems 2.5.4.1. Main Steam Regulatory Evaluation The main steam supply system (MSSS) transports steam from the NSSS to the power conversion system and various safety-related and non-safety-related auxiliaries. The NRC staff's review focused on the effects of the proposed EPU on the system's capability to transport steam to the power conversion system, provide heat sink capacity, supply steam to drive safety system pumps, and withstand adverse dynamic loads (e.g., water steam hammer resulting from rapid valve closure and relief valve fluid discharge loads). The NRC's acceptance criteria for the MSSS are based on draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects and missiles that might result from plant equipment failures, as well as the effects of a loss of coolant accident. Specific review criteria are contained in SRP Section 10.3.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the MSSS and concludes that the licensee has adequately accounted for the effects of changes in plant conditions on the design of the MSSS. The NRC staff concludes that the MSSS will maintain its ability to transport steam to the power conversion system, provide heat sink capacity, supply steam to steam-driven safety pumps, and withstand steam hammer. The NRC staff further concludes that the MSSS will continue to meet the requirements of draft GDC-40 and 42. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the MSSS.

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2.5.4.2 Main Condenser Regulatory Evaluation The main condenser (MC) system is designed to condense and deaerate the exhaust steam from the main turbine and provide a heat sink for the turbine bypass system (TBS). For BWRs without an MSIV leakage control system, the MC system may also serve an accident mitigation function to act as a holdup volume for the plateout of fission products leaking through the MSIVs following core damage. The NRC staff's review focused on the effects of the proposed EPU on the steam bypass capability with respect to load rejection assumptions, and on the ability of the MC system to withstand the blowdown effects of steam from the TBS. The NRC's acceptance criteria for the MC system are based on draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents. Specific review criteria are contained in SRP Section 10.4.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the MC system and concludes that the licensee has adequately accounted for the effects of changes in plant conditions on the design of the MC system. The NRC staff concludes that the MC system will continue to maintain its ability to withstand the blowdown effects of the steam from the TBS and thereby continue to meet draft GDC-70 with respect to controlling releases of radioactive effluents. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the MC system.

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2.5.4.3 Turbine Bypass Regulatorv Evaluation The TBS is designed to discharge a stated percentage of rated main steam flow directly to the MC system, bypassing the turbine. This steam bypass enables the plant to take step-load reductions up to the TBS capacity without the reactor or turbine tripping. The system is also used during startup and shutdown to control reactor pressure. For a BWR without an MSIV leakage control system, the TBS could also provide an accident mitigation function. A TBS, along with the MSSS and MC system, may be credited for mitigating the effects of MSIV leakage during a LOCA by the holdup and plateout of fission products. The NRC staff's review for the TBS focused on the effects that the proposed EPU have on load rejection capability, analysis of postulated system piping failures, and the consequences of inadvertent TBS operation. The NRC's acceptance criteria for the TBS are based on draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident.

Specific review criteria are contained in SRP Section 10.4.4.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the TBS. The NRC staff concludes that the licensee has adequately accounted for the effects of changes in plant conditions on the design of the TBS. The NRC staff concludes that the TBS will continue to mitigate the effects of MSIV leakage during a LOCA and provide a means for shutting down the plant during normal operations. The NRC staff further concludes that TBS failures will not adversely affect essential SSCs. Based on this, the NRC staff concludes that the TBS will continue to meet draft GDC-40 and 42. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the TBS.

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2.5.4.4 Condensate and Feedwater Regulatorv Evaluation The condensate and feedwater system (CFS) provides feedwater at a particular temperature, pressure, and flow rate to the reactor. The only part of the CFS classified as safety-related is the feedwater piping from the NSSS up to and including the outermost containment isolation valve. The NRC staff's review focused on how the proposed EPU affects previous analyses and considerations with respect to the capability of the CFS to supply adequate feedwater during plant operation and shutdown, and isolate components, subsystems, and piping in order to preserve the system's safety function. The NRC's acceptance criteria for the CFS are based on draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident. Specific review criteria are contained in SRP Section 10.4.7.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the CFS and concludes that the licensee has adequately accounted for the effects of changes in plant conditions on the design of the CFS. The NRC staff concludes that the CFS will continue to maintain its ability to satisfy feedwater requirements for normal operation and shutdown, withstand water hammer, maintain isolation capability in order to preserve the system safety function, and not cause failure of safety-related SSCs. The NRC staff further concludes that the CFS will continue to meet the requirements of draft GDC 40 and 42.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to the CFS.

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2.5.5 Waste Management SVstems 2.5.5.1 Gaseous Waste Management Systems Regulatory Evaluation The gaseous waste management systems involve the gaseous radwaste system, which deals with the management of radioactive gases collected in the offgas system or the waste gas storage and decay tanks. In addition, it involves the management of the condenser air removal system; the gland seal exhaust and the mechanical vacuum pump operation exhaust; and the building ventilation system exhausts. The NRC staff's review focused on the effects that the proposed EPU may have on (1) the design criteria of the gaseous waste management systems, (2) methods of treatment, (3) expected releases, (4) principal parameters used in calculating the releases of radioactive materials in gaseous effluents, and (5) design features for precluding the possibility of an explosion if the potential for explosive mixtures exists. The NRC's acceptance criteria for gaseous waste management systems are based on (1) 10 CFR 20.1302, insofar as it provides for demonstrating that annual average concentrations of radioactive materials released at the boundary of the unrestricted area do not exceed specified values; (2) draft GDC-3, insofar as it requires that the reactor facility shall be designed (1) to minimize the probability of events, such as fire and explosions and (2) to minimize the potential effects of such events to safety; (3) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents; (4) draft GDC-67, 68, and 69, insofar as they require that systems that contain radioactivity be designed with appropriate confinement; and (5) 10 CFR Part 50, Appendix I, Sections ll.B, II.C, and IL.D, which set numerical guides for design objectives and limiting conditions for operation to meet the 'as low as is reasonably achievable" (ALARA) criterion. Specific review criteria are contained in SRP Section 11.3.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to the gaseous waste management systems. The NRC staff concludes that the licensee has adequately accounted for the effects of the increase in fission product and amount of gaseous waste on the abilities of the systems to control releases of radioactive materials and preclude the possibility of an explosion if the potential for explosive mixtures exists. The NRC staff finds that the gaseous waste management systems will continue to meet their design functions following implementation of the proposed EPU. The NRC staff further concludes that the licensee has INSERT 5 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

demonstrated that the gaseous waste management systems will continue to meet the requirements of 10 CFR 20.1302; draft GDC-3, 67, 68, 69, and 70; and 10 CFR Part 50, Appendix I, Sections I.B, I1.C, and II.D. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the gaseous waste management systems.

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2.5.5.2 Liquid Waste Management Systems Regulatorv Evaluation The NRC staff's review for liquid waste management systems focused on the effects that the proposed EPU may have on previous analyses and considerations related to the liquid waste management systems' design, design objectives, design criteria, methods of treatment, expected releases, and principal parameters used in calculating the releases of radioactive materials in liquid effluents. The NRC's acceptance criteria for the liquid waste management systems are based on (1) 10 CFR 20.1302, insofar as it provides for demonstrating that annual average concentrations of radioactive materials released at the boundary of the unrestricted area do not exceed specified values; (2) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents; (3) draft GDC-67, 68, and 69, insofar as they require that systems that contain radioactivity be designed with appropriate confinement; and (4) 10 CFR Part 50, Appendix I, Sections Il.A and 1l.D, which set numerical guides for dose design objectives and limiting conditions for operation to meet the ALARA criterion. Specific review criteria are contained in SRP Section 11.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to the liquid waste management systems. The NRC staff concludes that the licensee has adequately accounted for the effects of the increase in fission product and amount of liquid waste on the ability of the liquid waste management systems to control releases of radioactive materials. The NRC staff finds that the liquid waste management systems will continue to meet their design functions following implementation of the proposed EPU. The NRC staff further concludes that the licensee has demonstrated that the liquid waste management systems will continue to meet the requirements of 10 CFR 20.1302; draft GDC-67, 68, 69, and 70; and 10 CFR Part 50, Appendix I, Sections ll.A and ll.D. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the liquid waste management systems.

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2.5.5.3 Solid Waste Management Systems Regulatory Evaluation The NRC staff's review for the solid waste management systems (SWMS) focused on the effects that the proposed EPU may have on previous analyses and considerations related to the design objectives in terms of expected volumes of waste to be processed and handled, the wet and dry types of waste to be processed, the activity and expected radionuclide distribution contained in the waste, equipment design capacities, and the principal parameters employed in the design of the SWMS. The NRC's acceptance criteria for the SWMS are based on (1) 10 CFR 20.1302, insofar as it provides for demonstrating that annual average concentrations of radioactive materials released at the boundary of the unrestricted area do not exceed specified values; (2) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents; (3) draft GDC-18, insofar as it requires that systems be provided in waste handling areas to detect conditions that may result in excessive radiation levels, (4) draft GDC-17, insofar as it requires that means be provided for monitoring effluent discharge paths and the plant environs for radioactivity that may be released from normal operations, including A0Os, and postulated accidents; and (5) 10 CFR Part 71, which states requirements for radioactive material packaging. Specific review criteria are contained in SRP Section 11.4.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to the SWMS. The NRC staff concludes that the licensee has adequately accounted for the effects of the increase in fission product and amount of solid waste on the ability of the SWMS to process the waste. The NRC staff finds that the SWMS will continue to meet its design functions following implementation of the proposed EPU. The NRC staff further concludes that the licensee has demonstrated that the SWMS will continue to meet the requirements of 10 CFR 20.1302, draft GDC-17, 18, and 70, and 10 CFR Part 71. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the SWMS.

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2.5.6 Additional Considerations 2.5.6.1 Emergency Diesel Engine Fuel Oil Storage and Transfer System Regulatory Evaluation Nuclear power plants are required to have redundant onsite emergency power supplies of sufficient capacity to perform their safety functions (e.g., power diesel engine-driven generator sets), assuming a single failure. The NRC staff's review focused on increases in emergency diesel generator electrical demand and the resulting increase in the amount of fuel oil necessary for the system to perform its safety function. The NRC's acceptance criteria for the emergency diesel engine fuel oil storage and transfer system are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects, including missiles associated with pipe breaks, as well as the effects of a loss of coolant accident; and (2) draft GDC-39, insofar as it requires onsite power supplies to have sufficient independence and redundancy to perform their safety functions, assuming a single failure.

Specific review criteria are contained in SRP Section 9.5.4.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to the amount of required fuel oil for the emergency diesel generators and concludes that the licensee has adequately accounted for the effects of the increased electrical demand on fuel oil consumption. The NRC staff concludes that the fuel oil storage and transfer system will continue to provide an adequate amount of fuel oil to allow the diesel generators to meet the onsite power requirements of draft GDC-39, 40, and 42. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the fuel oil storage and transfer system.

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2.5.6.2 Light Load Handling System (Related to Refueling)

Regulatory Evaluation The light load handling system (LLHS) includes components and equipment used in handling new fuel at the receiving station and the loading of spent fuel into shipping casks. The NRC staff's review covered the avoidance of criticality accidents, radioactivity releases resulting from damage to irradiated fuel, and unacceptable personnel radiation exposures. The NRC staff's review focused on the effects of the new fuel on system performance and related analyses. The NRC's acceptance criteria for the LLHS are based on (1) draft GDC-67, 68, and 69, insofar as they require that systems that contain radioactivity be designed with appropriate confinement and with suitable shielding for radiation protection; and (2) draft GDC-66, insofar as it requires that criticality be prevented. Specific review criteria are contained in SRP Section 9.1.4.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the new fuel on the ability of the LLHS to avoid criticality accidents and concludes that the licensee has adequately incorporated the effects of the new fuel in the analyses. Based on this review, the NRC staff further concludes that the LLHS will continue to meet the requirements of draft GDC-66, 67, 68, and 69 for radioactivity releases and prevention of criticality accidents. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the LLHS.

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[2.5.7 Additional Review Areas (Plant Systems)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERTS FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

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2.6 Containment Review Considerations 2.6.1 Primary Containment Functional Design Regulatory Evaluation The containment encloses the reactor system and is the final barrier against the release of significant amounts of radioactive fission products in the event of an accident. The NRC staff's review for the primary containment functional design covered (1) the temperature and pressure conditions in the drywell and wetwell due to a spectrum of postulated LOCAs, (2) the differential pressure across the operating deck for a spectrum of LOCAs (Mark II containments only),

(3) suppression pool dynamic effects during a LOCA or following the actuation of one or more RCS safety/relief valves, (4) the consequences of a LOCA occurring within the containment (wetwell), (5) the capability of the containment to withstand the effects of steam bypassing the suppression pool, (6) the suppression pool temperature limit during RCS safety/relief valve operation, and (7) the analytical models used for containment analysis. The NRC's acceptance criteria for the primary containment functional design are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident; (2) draft GDC-1 0, insofar as it requires that reactor containment be designed to sustain the initial effects of gross equipment failures, such as a large coolant boundary break, without loss of required integrity and, together with other engineered safety features as may be necessary, to retain for as long as the situation requires the functional capability; (3) draft GDC-49, insofar as it requires that the containment and its associated heat removal systems be designed so that the containment structure can accommodate, without exceeding the design leakage rate the pressures and temperatures resulting from the largest credible energy release following a loss-of-coolant accident, including considerable margin for effects from metal-water or other chemical reactions that could occur as a consequence of failure of emergency core cooling systems; (4) draft GDC-12, insofar as it requires that instrumentation and controls be provided as required to monitor and maintain variables within prescribed operating ranges; and (5) draft GDC-17, insofar as it requires that means be provided to monitor the reactor containment atmosphere for radioactivity that may be released from normal operations and from postulated accidents. Specific review criteria are contained in SRP Section 6.2.1.1.C.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the containment temperature and INSERT 6 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

pressure transient and concludes that the licensee has adequately accounted for the increase of mass and energy resulting from the proposed EPU. The NRC staff further concludes that containment systems will continue to provide sufficient pressure and temperature mitigation capability to ensure that containment integrity is maintained. The NRC staff also concludes that containment systems and instrumentation will continue to be adequate for monitoring containment parameters and release of radioactivity during normal and accident conditions and the containment and associated systems will continue to meet the requirements of draft GDC-10, 12, 17, 40, 42, and 49 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to primary containment functional design.

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2.6.2 Subcompartment Analyses Regulatory Evaluation A subcompartment is defined as any fully or partially enclosed volume within the primary containment that houses high-energy piping and would limit the flow of fluid to the main containment volume in the event of a postulated pipe rupture within the volume. The NRC staff's review for subcompartment analyses covered the determination of the design differential pressure values for containment subcompartments. The NRC staff's review focused on the effects of the increase in mass and energy release into the containment due to operation at EPU conditions, and the resulting increase in pressurization. The NRC's acceptance criteria for subcompartment analyses are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident; and (2) draft GDC-49, insofar as it requires that the containment structure, including access openings and penetrations, and any necessary containment heat removal systems be designed so that the containment structure can accommodate without exceeding the design leakage rate the pressures and temperatures resulting from the largest credible energy release following a loss-of-coolant accident. Specific review criteria are contained in SRP Section 6.2.1.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the subcompartment assessment performed by the licensee and the change in predicted pressurization resulting from the increased mass and energy release.

The NRC staff concludes that containment SSCs important to safety will continue to be protected from the dynamic effects resulting from pipe breaks and that the subcompartments will continue to have sufficient margins to prevent fracture of the structure due to pressure difference across the walls following implementation of the proposed EPU. Based on this, the NRC staff concludes that the plant will continue to meet draft GDC-40, 42, and 49 for the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to subcompartment analyses.

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2.6.3 Mass and Energy Release 2.6.3.1 Mass and Energy Release Analysis for Postulated Loss of Coolant Regulatory Evaluation The release of high-energy fluid into containment from pipe breaks could challenge the structural integrity of the containment, including subcompartments and systems within the containment. The NRC staff's review covered the energy sources that are available for release to the containment and the mass and energy release rate calculations for the initial blowdown phase of the accident. The NRC's acceptance criteria for mass and energy release analyses for postulated LOCAs are based on (1) draft GDC-49, insofar as it requires that the containment structure be designed to accommodate, without exceeding the design leakage rate, the pressures and temperatures resulting from the largest credible energy release following a LOCA; and (2) 10 CFR Part 50, Appendix K, insofar as it identifies sources of energy during a LOCA. Specific review criteria are contained in SRP Section 6.2.1.3.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's mass and energy release assessment and concludes that the licensee has adequately addressed the effects of the proposed EPU and appropriately accounts for the sources of energy identified in 10 CFR Part 50, Appendix K.

Based on this, the NRC staff finds that the mass and energy release analysis meets the requirements in draft GDC-49 for ensuring that the analysis is conservative. Therefore, the NRC staff finds the proposed EPU acceptable with respect to mass and energy release for postulated LOCA.

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2.6.4 Combustible Gas Control in Containment Regulatory Evaluation Following a LOCA, hydrogen and oxygen may accumulate inside the containment due to chemical reactions between the fuel rod cladding and steam, corrosion of aluminum and other materials, and radiolytic decomposition of water. If excessive hydrogen is generated, it may form a combustible mixture in the containment atmosphere. The NRC staff's review covered (1) the production and accumulation of combustible gases, (2) the capability to prevent high concentrations of combustible gases in local areas, (3) the capability to monitor combustible gas concentrations, and (4) the capability to reduce combustible gas concentrations. The NRC staff's review primarily focused on any impact that the proposed EPU may have on hydrogen release assumptions, and how increases in hydrogen release are mitigated. The NRC's acceptance criteria for combustible gas control in containment are based on (1) 10 CFR 50.44, insofar as it requires that plants be provided with the capability for controlling combustible gas concentrations in the containment atmosphere; (2) draft GDC-62, insofar as it requires that all critical parts of containment air cleanup systems, such as ducts, filters, fans, and dampers be designed to permit physical inspection; and (3) draft GDC-63, 64, and 65, insofar as they require that active components of the air cleanup systems be designed to permit appropriate periodic testing. [Include the followingsentence for BWRs with Mark 11 containments: Additional requirements based on 10 CFR 50.44 for control of combustible gas apply to plants with a Mark IlIl type of containment that do not rely on an inerted atmosphere to control hydrogen inside the containment.] Specific review criteria are contained in SRP Section 6.2.5.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to combustible gas and concludes that the plant will continue to have sufficient capabilities consistent with the requirements in 10 CFR 50.44 and draft GDC-62, 63, 64, and 65 as discussed above.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to combustible gas control in containment.

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2.6.5 Containment Heat Removal Regulatory Evaluation Fan cooler systems, spray systems, and residual heat removal (RHR) systems are provided to remove heat from the containment atmosphere and from the water in the containment wetwell.

The NRC staff's review in this area focused on (1) the effects of the proposed EPU on the analyses of the available net positive suction head (NPSH) to the containment heat removal system pumps and (2) the analyses of the heat removal capabilities of the spray water system and the fan cooler heat exchangers. The NRC's acceptance criteria for containment heat removal are based on draft GDC-41 and 52, insofar as they require that a containment heat removal system be provided, and that its function shall be to prevent exceeding containment design pressure under accident conditions. Specific review criteria are contained in SRP Section 6.2.2, as supplemented by Draft Guide (DG) 1107.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the containment heat removal systems assessment provided by the licensee and concludes that the licensee has adequately addressed the effects of the proposed EPU. The NRC staff finds that the systems will continue to meet draft GDC-41 and 52 with respect to limiting the containment pressure and temperature following a LOCA and maintaining them at acceptably low levels. Therefore, the NRC staff finds the proposed EPU acceptable with respect to containment heat removal systems.

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2.6.6 Secondary Containment Functional Design Regulatory Evaluation The secondary containment structure and supporting systems of dual containment plants are provided to collect and process radioactive material that may leak from the primary containment following an accident. The supporting systems maintain a negative pressure within the secondary containment and process this leakage. The NRC staff's review covered (1) analyses of the pressure and temperature response of the secondary containment following accidents within the primary and secondary containments; (2) analyses of the effects of openings in the secondary containment on the capability of the depressurization and filtration system to establish a negative pressure in a prescribed time; (3) analyses of any primary containment leakage paths that bypass the secondary containment; (4) analyses of the pressure response of the secondary containment resulting from inadvertent depressurization of the primary containment when there is vacuum relief from the secondary containment; and (5) the acceptability of the mass and energy release data used in the analysis. The NRC staff's review primarily focused on the effects that the proposed EPU may have on the pressure and temperature response and drawdown time of the secondary containment, and the impact this may have on offsite dose. The NRC's acceptance criteria for secondary containment functional design are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident; and (2) draft GDC-10, insofar as it requires that reactor containment be designed to sustain the initial effects of gross equipment failures, such as a large coolant boundary break, without loss of required integrity and, together with other engineered safety features as may be necessary, to retain functional capability for as long as the situation requires. Specific review criteria are contained in SRP Section 6.2.3.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to the secondary containment pressure and temperature transient and the ability of the secondary containment to provide an essentially leak-tight barrier against uncontrolled release of radioactivity to the environment.

The NRC staff concludes that the licensee has adequately accounted for the increase of mass and energy that would result from the proposed EPU and further concludes that the secondary containment and associated systems will continue to provide an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment following implementation of the proposed EPU. Based on this, the NRC staff also concludes that the secondary INSERT6 FOR SECTION 3.2-BWRTEMPLATESAFETY EVALUATION DECEMBER 2003

containment and associated systems will continue to meet the requirements of draft GDC-10, 40, and 42. Therefore, the NRC staff finds the proposed EPU acceptable with respect to secondary containment functional design.

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[2.6.7 Additional Review Areas (Containment Review Considerations)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

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2.7 Habitability. Filtration, and Ventilation 2.7.1 Control Room Habitability System Regulatory Evaluation The NRC staff reviewed the control room habitability system and control building layout and structures to ensure that plant operators are adequately protected from the effects of accidental releases of toxic and radioactive gases. A further objective of the NRC staff's review was to ensure that the control room can be maintained as the backup center from which technical support center personnel can safely operate in the case of an accident. The NRC staff's review focused on the effects of the proposed EPU on radiation doses, toxic gas concentrations, and estimates of dispersion of airborne contamination. The NRC's acceptance criteria for the control room habitability system are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident; and (2) draft GDC-1 1 and 10CFR50.67, insofar as they require that adequate radiation protection be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident.

Specific review criteria are contained in SRP Section 6.4 and other guidance provided in Matrix 7 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment related to the effects of the proposed EPU on the ability of the control room habitability system to protect plant operators against the effects of accidental releases of toxic and radioactive gases. The NRC staff concludes that the licensee has adequately accounted for the increase of toxic and radioactive gases that would result from the proposed EPU. The NRC staff further concludes that the control room habitability system will continue to provide the required protection following implementation of the proposed EPU. Based on this, the NRC staff concludes that the control room habitability system will continue to meet the requirements of draft GDC-1 1, 40, and 42, and 10CFR50.67.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to the control room habitability system.

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2.7.2 Engineered Safety Feature Atmosphere Cleanup Regulatory Evaluation ESF atmosphere cleanup systems are designed for fission product removal in postaccident environments. These systems generally include primary systems (e.g., in-containment recirculation) and secondary systems (e.g., standby gas treatment systems and emergency or postaccident air-cleaning systems) for the fuel-handling building, control room, shield building, and areas containing ESF components. For each ESF atmosphere cleanup system, the NRC staff's review focused on the effects of the proposed EPU on system functional design, environmental design, and provisions to preclude temperatures in the adsorber section from exceeding design limits. The NRC's acceptance criteria for ESF atmosphere cleanup systems are based on (1) draft GDC-1 1 and 10CFR50.67, insofar as they require that adequate radiation protection be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident; (2) draft GDC-67, 68, and 69, insofar as they require that systems that may contain radioactivity be designed to assure adequate safety under normal and postulated accident conditions; and (4) draft GDC-17, insofar as it requires that means be provided for monitoring effluent discharge paths and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences (AOOs), and postulated accidents. Specific review criteria are contained in SRP Section 6.5.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the ESF atmosphere cleanup systems. The NRC staff concludes that the licensee has adequately accounted for the increase of fission products and changes in expected environmental conditions that would result from the proposed EPU, and the NRC staff further concludes that the ESF atmosphere cleanup systems will continue to provide adequate fission product removal in postaccident environments following implementation of the proposed EPU.

Based on this, the NRC staff concludes that the ESF atmosphere cleanup systems will continue to meet the requirements of draft GDC-11, 17, 67, 68, and 69; and 10CFR50.67. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the ESF atmosphere cleanup systems.

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2.7.3 Control Room Area Ventilation System Regulatorv Evaluation The function of the control room area ventilation system (CRAVS) is to provide a controlled environment for the comfort and safety of control room personnel and to support the operability of control room components during normal operation, A0Os, and DBA conditions. The NRC's review of the CRAVS focused on the effects that the proposed EPU will have on the functional performance of safety-related portions of the system. The review included the effects of radiation, combustion, and other toxic products; and the expected environmental conditions in areas served by the CRAVS. The NRC's acceptance criteria for the CRAVS are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident; (2) draft GDC-1 1 and 10CFR50.67, insofar as they require that adequate radiation protection be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident; and (3) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents. Specific review criteria are contained in SRP Section 9.4.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the ability of the CRAVS to provide a controlled environment for the comfort and safety of control room personnel and to support the operability of control room components. The NRC staff concludes that the licensee has adequately accounted for the increase of toxic and radioactive gases that would result from a DBA under the conditions of the proposed EPU, and associated changes to parameters affecting environmental conditions for control room personnel and equipment. Accordingly, the NRC staff concludes that the CRAVS will continue to provide an acceptable control room environment for safe operation of the plant following implementation of the proposed EPU. The NRC staff also concludes that the system will continue to suitably control the release of gaseous radioactive effluents to the environment.

Based on this, the NRC staff concludes that the CRAVS will continue to meet the requirements of draft GDC-1 1, 40, 42, and 70, and 10CFR50.67. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the CRAVS.

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2.7.4 Spent Fuel Pool Area Ventilation System Regulatory Evaluation The function of the spent fuel pool area ventilation system (SFPAVS) is to maintain ventilation in the spent fuel pool equipment areas, permit personnel access, and control airborne radioactivity in the area during normal operation, AO0s, and following postulated fuel handling accidents. The NRC staff's review focused on the effects of the proposed EPU on the functional performance of the safety-related portions of the system. The NRC's acceptance criteria for the SFPAVS are based on (1) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents, and (2) draft GDC-67, 68, and 69, insofar as they require that systems which contain radioactivity be designed with appropriate confinement and containment. Specific review criteria are contained in SRP Section 9.4.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the SFPAVS. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on the system's capability to maintain ventilation in the spent fuel pool equipment areas, permit personnel access, control airborne radioactivity in the area, control release of gaseous radioactive effluents to the environment, and provide appropriate containment. Based on this, the NRC staff concludes that the SFPAVS will continue to meet the requirements of draft GDC-67, 68, 69, and 70. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the SFPAVS.

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2.7.5 Auxiliary and Radwaste Area and Turbine Areas Ventilation Systems Regulatory Evaluation The function of the auxiliary and radwaste area ventilation system (ARAVS) and the turbine area ventilation system (TAVS) is to maintain ventilation in the auxiliary and radwaste equipment and turbine areas, permit personnel access, and control the concentration of airborne radioactive material in these areas during normal operation, during A0Os, and after postulated accidents. The NRC staff's review focused on the effects of the proposed EPU on the functional performance of the safety-related portions of these systems. The NRC's acceptance criteria for the ARAVS and TAVS are based on draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents. Specific review criteria are contained in SRP Sections 9.4.3 and 9.4.4.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the ARAVS and TAVS. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on the capability of these systems to maintain ventilation in the auxiliary and radwaste equipment areas and in the turbine area, permit personnel access, control the concentration of airborne radioactive material in these areas, and control release of gaseous radioactive effluents to the environment. Based on this, the NRC staff concludes that the ARAVS and TAVS will continue to meet the requirements of draft GDC-70. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the ARAVS and the TAVS.

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2.7.6 Engineered Safety Feature Ventilation System Regulatory Evaluation The function of the engineered safety feature ventilation system (ESFVS) is to provide a suitable and controlled environment for ESF components following certain anticipated transients and DBAs. The NRC staff's review for the ESFVS focused on the effects of the proposed EPU on the functional performance of the safety-related portions of the system. The NRC staff's review also covered (1) the ability of the ESF equipment in the areas being serviced by the ventilation system to function under degraded ESFVS performance; (2) the capability of the ESFVS to circulate sufficient air to prevent accumulation of flammable or explosive gas or fuel-vapor mixtures from components (e.g., storage batteries and stored fuel); and (3) the capability of the ESFVS to control airborne particulate material (dust) accumulation. The NRC's acceptance criteria for the ESFVS are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects and missiles that might result from plant equipment failures, as well as the effects of a loss of coolant accident; (2) draft GDC-24 and 39, insofar as they require onsite and offsite electric power systems be provided to permit functioning of the ESFs and protection systems; and (3) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents.

Specific review criteria are contained in SRP Section 9.4.5.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on the ESFVS. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on the ability of the ESFVS to provide a suitable and controlled environment for ESF components. The NRC staff further concludes that the ESFVS will continue to assure a suitable environment for the ESF components following implementation of the proposed EPU. The NRC staff also concludes that the ESFVS will continue to suitably control the release of gaseous radioactive effluents to the environment following implementation of the proposed EPU. Based on this, the NRC staff concludes that the ESFVS will continue to meet the requirements of draft GDC-24, 39, 40, 42, and 70. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the ESFVS.

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[2.7.7 Additional Review Areas (Habitability, Filtration, and Ventilation)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT 7 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

INSERT 8 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION

2.8 Reactor Systems 2.8.1 Fuel System Design Regulatory Evaluation The fuel system consists of arrays of fuel rods, burnable poison rods, spacer grids and springs, end plates, channel boxes, and reactivity control rods. The NRC staff reviewed the fuel system to ensure that (1) the fuel system is not damaged as a result of normal operation and A0Os, (2) fuel system damage is never so severe as to prevent control rod insertion when it is required, (3) the number of fuel rod failures is not underestimated for postulated accidents, and (4) coolability is always maintained. The NRC staff's review covered fuel system damage mechanisms, limiting values for important parameters, and performance of the fuel system during normal operation, A0Os, and postulated accidents. The NRC's acceptance criteria are based on (1) 10 CFR 50.46, insofar as it establishes standards for the calculation of emergency core cooling system (ECCS) performance and acceptance criteria for that calculated performance; (2) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime, without exceeding acceptable fuel damage limits; and (3) draft GDC-37, 41, and 44, insofar as they require that a system to provide abundant emergency core cooling be provided to prevent fuel damage following a LOCA. Specific review criteria are contained in SRP Section 4.2 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effects of the proposed EPU on the fuel system design of the fuel assemblies, control systems, and reactor core. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on the fuel system and demonstrated that (1) the fuel system will not be damaged as a result of normal operation and A0Os, (2)the fuel system damage will never be so severe as to prevent control rod insertion when it is required, (3) the number of fuel rod failures will not be underestimated for postulated accidents, and (4) coolability will always be maintained. Based on this, the NRC staff concludes that the fuel system and associated analyses will continue to meet the requirements of 10 CFR 50.46, draft GDC-6, 37, 41, and 44 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the fuel system design.

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2.8.2 Nuclear Design Regulatory Evaluation The NRC staff reviewed the nuclear design of the fuel assemblies, control systems, and reactor core to ensure that fuel design limits will not be exceeded during normal operation and anticipated operational transients, and that the effects of postulated reactivity accidents will not cause significant damage to the RCPB or impair the capability to cool the core. The NRC staff's review covered core power distribution, reactivity coefficients, reactivity control requirements and control provisions, control rod patterns and reactivity worths, criticality, burnup, and vessel irradiation. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits during any condition of normal operation, including the effects of A0Os; (2) draft GDC-8, insofar as it requires that the reactor core be designed so that the overall power coefficient in the power operating range shall not be positive; (3) draft GDC-7, insofar as it requires that the reactor core be designed to ensure that power oscillations, which could cause damage in excess of acceptable fuel damage limits, are not possible or can be readily suppressed; (4) draft GDC-12, insofar as it requires that instrumentation and controls be provided as required to monitor and maintain variables within prescribed operating ranges; (5) draft GDC-14 and 15, insofar as they require that the protection system be designed to initiate the reactivity control systems automatically to prevent or suppress conditions that could result in exceeding acceptable fuel damage limits and to initiate operation of ESFs under accident situations; (6) draft GDC-31, insofar as it requires that the reactivity control systems be capable of sustaining any single malfunction without causing a reactivity transient which could result in exceeding acceptable fuel damage limits; (7) draft GDC-27 and 28, insofar as they require that at least two independent reactivity control systems be provided, with both systems capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits; (8) draft GDC-29, insofar as it requires that at least one of the reactivity control systems be capable of making the core subcritical under any condition sufficiently fast to prevent exceeding acceptable fuel damage limits; and (9) draft GDC-32, insofar as it requires that limits, which include considerable margin, be placed on the maximum reactivity worth of control rods or elements and on rates at which reactivity can be increased to ensure that the potential effects of a sudden or large change of reactivity cannot (a) rupture the reactor coolant pressure boundary or (b) disrupt the core, its support structures, or other vessel internals sufficiently to impair the effectiveness of emergency core cooling. Specific review criteria are contained in SRP Section 4.3 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

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INSERT 8 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

Conclusion The NRC staff has reviewed the licensee's analyses related to the effect of the proposed EPU on the nuclear design of the fuel assemblies, control systems, and reactor core. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on the nuclear design and has demonstrated that the fuel design limits will not be exceeded during normal or anticipated operational transients, and that the effects of postulated reactivity accidents will not cause significant damage to the RCPB or impair the capability to cool the core. Based on this evaluation and in coordination with the reviews of the fuel system design, thermal and hydraulic design, and transient and accident analyses, the NRC staff concludes that the nuclear design of the fuel assemblies, control systems, and reactor core will continue to meet the applicable requirements of draft GDC-6, 7, 8, 12, 14, 15, 27, 28, 29, 31, and 32.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to the nuclear design.

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2.8.3 Thermal and Hydraulic Design Regulatory Evaluation The NRC staff reviewed the thermal and hydraulic design of the core and the RCS to confirm that the design (1) has been accomplished using acceptable analytical methods, (2) is equivalent to or a justified extrapolation from proven designs, (3) provides acceptable margins of safety from conditions which would lead to fuel damage during normal reactor operation and A0Os, and (4) is not susceptible to thermal-hydraulic instability. The review also covered hydraulic loads on the core and RCS components during normal operation and DBA conditions and core thermal-hydraulic stability under normal operation and anticipated transients without scram (ATWS) events. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits during any condition of normal operation, including the effects of A0Os; and (2) draft GDC-7, insofar as it requires that the reactor core, together with reliable controls, ensure that power oscillations, which could cause damage in excess of acceptable fuel damage limits, are not possible or can be readily suppressed. Specific review criteria are contained in SRP Section 4.4 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effects of the proposed EPU on the thermal and hydraulic design of the core and the RCS. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on the thermal and hydraulic design and demonstrated that the design (1) has been accomplished using acceptable analytical methods, (2) is [equivalent to or a justified extrapolation from] proven designs, (3) provides acceptable margins of safety from conditions that would lead to fuel damage during normal reactor operation and A0Os, and (4) is not susceptible to thermal-hydraulic instability. The NRC staff further concludes that the licensee has adequately accounted for the effects of the proposed EPU on the hydraulic loads on the core and RCS components. Based on this, the NRC staff concludes that the thermal and hydraulic design will continue to meet the requirements of draft GDC-6 and 7 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to thermal and hydraulic design.

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2.8.4 Emergency Systems 2.8.4.1 Functional Design of Control Rod Drive System Regulatory Evaluation The NRC staff's review covered the functional performance of the control rod drive system (CRDS) to confirm that the system can effect a safe shutdown, respond within acceptable limits during A0Os, and prevent or mitigate the consequences of postulated accidents. The review also covered the CRDS cooling system to ensure that it will continue to meet its design requirements. The NRC's acceptance criteria are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects and missiles that might result from plant equipment failures, as well as the effects of a loss of coolant accident; (2) draft GDC-26, insofar as it requires that the protection system be designed to fail into a safe state; (3) draft GDC-31, insofar as it requires that the reactivity control systems be capable of sustaining any single malfunction without causing a reactivity transient which could result in exceeding acceptable fuel damage limits; (4) draft GDC-27 and 28, insofar as they require that at least two independent reactivity control systems be provided, with both systems capable of making and holding the core subcritical from any hot standby or hot operating condition, sufficiently fast to prevent exceeding acceptable fuel damage limits; (5) draft GDC-29, insofar as it requires that at least one of the reactivity control systems be capable of making the core subcritical under any condition sufficiently fast to prevent exceeding acceptable fuel damage limits; (6) draft GDC-32, insofar as it requires that limits, which include considerable margin, be placed on the maximum reactivity worth of control rods or elements and on rates at which reactivity can be increased to ensure that the potential effects of a sudden or large change of reactivity cannot (a) rupture the reactor coolant pressure boundary or (b) disrupt the core, its support structures, or other vessel internals sufficiently to impair the effectiveness of emergency core cooling; and (7) 10 CFR 50.62(c)(3), insofar as it requires that all BWRs have an alternate rod injection (ARI) system diverse from the reactor trip system, and that the ARI system have redundant scram air header exhaust valves. Specific review criteria are contained in SRP Section 4.6.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effects of the proposed EPU on the functional design of the CRDS. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on the system and demonstrated INSERT8 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

that the system's ability to effect a safe shutdown, respond within acceptable limits, and prevent or mitigate the consequences of postulated accidents will be maintained following the implementation of the proposed EPU. The NRC staff further concludes that the licensee has demonstrated that sufficient cooling exists to ensure the system's design bases will continue to be followed upon implementation of the proposed EPU. Based on this, the NRC staff concludes that the fuel system and associated analyses will continue to meet the requirements of draft GDC-26, 27,28, 29, 31, 32,40, and 42, and 10 CFR 50.62(c)(3) following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the functional design of the CRDS.

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2.8.4.2 Overpressure Protection During Power Operation Regulatorv Evaluation Overpressure protection for the RCPB during power operation is provided by relief and safety valves and the reactor protection system. The NRC staff's review covered relief and safety valves on the main steamlines and piping from these valves to the suppression pool. The NRC's acceptance criteria are based on (1) draft GDC-9, insofar as it requires that the RCPB be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; and (2) draft GDC-33, 34, and 35, insofar as they require that the RCPB be designed to assure that it behaves in a nonbrittle manner and that the probability of rapidly propagating type failures is minimized. Specific review criteria are contained in SRP Section 5.2.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effects of the proposed EPU on the overpressure protection capability of the plant during power operation. The NRC staff concludes that the licensee has (1) adequately accounted for the effects of the proposed EPU on pressurization events and overpressure protection features and (2) demonstrated that the plant will continue to have sufficient pressure relief capacity to ensure that pressure limits are not exceeded. Based on this, the NRC staff concludes that the overpressure protection features will continue to meet draft GDC-9, 33, 34, and 35 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to overpressure protection during power operation.

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2.8.4.3 Reactor Core Isolation Cooling System Regulatory Evaluation The reactor core isolation cooling (RCIC) system serves as a standby source of cooling water to provide a limited decay heat removal capability whenever the main feedwater system is isolated from the reactor vessel. In addition, the RCIC system may provide decay heat removal necessary for coping with a station blackout. The water supply for the RCIC system comes from the condensate storage tank, with a secondary supply from the suppression pool. The NRC staff's review covered the effect of the proposed EPU on the functional capability of the system. The NRC's acceptance criteria are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a loss of coolant accident; (2) draft GDC-37, insofar as it requires that ESFs be provided to back up the safety provided by the core design, the RCPB, and their protective systems; (3) draft GDC-51 and 57, insofar as they require that piping systems penetrating containment be designed with appropriate features as necessary to protect from an accidental rupture outside containment and the capability to periodically test the operability of the isolation valves to determine if valve leakage is within acceptable limits; and (4) 10 CFR 50.63, insofar as it requires that the plant withstand and recover from an SBO of a specified duration. Specific review criteria are contained in SRP Section 5.4.6 Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effects of the proposed EPU on the ability of the RCIC system to provide decay heat removal following an isolation of main feedwater event and a station blackout event and the ability of the system to provide makeup to the core following a small break in the RCPB. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on these events and demonstrated that the RCIC system will continue to provide sufficient decay heat removal and makeup for these events following implementation of the proposed EPU. Based on this, the NRC staff concludes that the RCIC system will continue to meet the requirements of draft GDC-37, 40, 42, 51, and 57, and 10 CFR 50.63 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the RCIC system.

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2.8.4.4 Residual Heat Removal System Regulatory Evaluation The RHR system is used to cool down the RCS following shutdown. The RHR system is typically a low pressure system which takes over the shutdown cooling function when the RCS temperature is reduced. The NRC staff's review covered the effect of the proposed EPU on the functional capability of the RHR system to cool the RCS following shutdown and provide decay heat removal. The NRC's acceptance criteria are based on draft GDC-40 and 42, insofar as they require that ESFs be protected against dynamic effects; . Specific review criteria are contained in SRP Section 5.4.7 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effects of the proposed EPU on the RHR system. The NRC staff concludes that the licensee has adequately accounted for the effects of the proposed EPU on the system and demonstrated that the RHR system will maintain its ability to cool the RCS following shutdown and provide decay heat removal. Based on this, the NRC staff concludes that the RHR system will continue to meet the requirements of draft GDC-40 and 42 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the RHR system.

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2.8.4.5 Standby Liquid Control System Regulatory Evaluation The standby liquid control system (SLCS) provides backup capability for reactivity control independent of the control rod system. The SLCS functions by injecting a boron solution into the reactor to effect shutdown. The NRC staff's review covered the effect of the proposed EPU on the functional capability of the system to deliver the required amount of boron solution into the reactor. The NRC's acceptance criteria are based on (1) draft GDC-27 and 28, insofar as they require that at least two independent reactivity control systems, preferably of different design principles, be provided, with both systems capable of making and holding the core subcritical from any hot standby or hot operating condition, sufficiently fast to prevent exceeding acceptable fuel damage limits; (2) draft GDC-29, insofar as it requires that at least one of the reactivity control systems be capable of making the core subcritical under any condition sufficiently fast to prevent exceeding acceptable fuel damage limits; and (3) 10 CFR 50.62(c)(4), insofar as it requires that the SLCS be capable of reliably injecting a borated water solution into the reactor pressure vessel at a boron concentration, boron enrichment, and flow rate that provides a set level of reactivity control. Specific review criteria are contained in SRP Section 9.3.5 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effects of the proposed EPU on the SLCS and concludes that the licensee has adequately accounted for the effects of the proposed EPU on the system and demonstrated that the system will continue to provide the function of reactivity control independent of the control rod system following implementation of the proposed EPU. Based on this, the NRC staff concludes that the SLCS will continue to meet the requirements of draft GDC-27, 28, and 29, and 10 CFR 50.62(c)(4) following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the SLCS.

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2.8.5 Accident and Transient Analyses 2.8.5.1 Decrease in Feedwater Temperature, Increase in Feedwater Flow, Increase in Steam Flow, and Inadvertent Opening of a Main Steam Relief or Safety Valve Regulatory Evaluation Excessive heat removal causes a decrease in moderator temperature which increases core reactivity and can lead to a power level increase and a decrease in shutdown margin. Any unplanned power level increase may result in fuel damage or excessive reactor system pressure. Reactor protection and safety systems are actuated to mitigate the transient. The NRC staff's review covered (1) postulated initial core and reactor conditions, (2) methods of thermal and hydraulic analyses, (3) the sequence of events, (4) assumed reactions of reactor system components, (5) functional and operational characteristics of the reactor protection system, (6) operator actions, and (7) the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-9, insofar as it requires that the reactor coolant pressure boundary shall be designed and constructed as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; (3) draft GDC-14 and 15, insofar as they require that the core protection system be designed to act automatically to prevent or suppress conditions that could result in exceeding acceptable fuel damage limits and that protection systems be provided for sensing accident situations and initiating the operation of necessary ESFs; and (4) draft GDC-27 and 28, insofar as they require that at least two reactivity control systems be provided and be capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits. Specific review criteria are contained in SRP Section 15.1.1-4 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the excess heat removal events described above and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the AFDLs and the RCPB pressure limits will not be exceeded as a result of these events. Based on this, the NRC staff INSERT 8 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

concludes that the plant will continue to meet the requirements of draft GDC-6, 9, 14, 15, 27, and 28 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the events stated.

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2.8.5.2 Decrease in Heat Removal by the Secondary System 2.8.5.2.1 Loss of External Load; Turbine Trip; Loss of Condenser Vacuum; Closure of Main Steam Isolation Valve; and Steam Pressure Regulator Failure (Closed)

Regulatory Evaluation A number of initiating events may result in unplanned decreases in heat removal by the secondary system. These events result in a sudden reduction in steam flow and, consequently, result in pressurization events. Reactor protection and safety systems are actuated to mitigate the transient. The NRC staff's review covered the sequence of events, the analytical models used for analyses, the values of parameters used in the analytical models, and the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-9, insofar as it requires that the reactor coolant pressure boundary shall be designed and constructed as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; and (3) draft GDC-27 and 28, insofar as they require that at least two reactivity control systems be provided and be capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits.

Specific review criteria are contained in SRP Section 15.2.1-5 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the decrease in heat removal events described above and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the AFDLs and the RCPB pressure limits will not be exceeded as a result of these events. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-6, 9, 27, and 28 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the events stated.

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2.8.5.2.2 Loss of Nonemergency AC Power to the Station Auxiliaries Regulatory Evaluation The loss of nonemergency ac power is assumed to result in the loss of all power to the station auxiliaries and the simultaneous tripping of all reactor coolant circulation pumps. This causes a flow coastdown as well as a decrease in heat removal by the secondary system, a turbine trip, an increase in pressure and temperature of the coolant, and a reactor trip. Reactor protection and safety systems are actuated to mitigate the transient. The NRC staff's review covered (1) the sequence of events, (2) the analytical model used for analyses, (3) the values of parameters used in the analytical model, and (4) the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-9, insofar as it requires that the reactor coolant pressure boundary shall be designed and constructed as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; and (3) draft GDC-27 and 28, insofar as they require that at least two reactivity control systems be provided and be capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits. Specific review criteria are contained in SRP Section 15.2.6 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the loss of nonemergency ac power to station auxiliaries event and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the AFDLs and the RCPB pressure limits will not be exceeded as a result of this event. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-6, 9, 27, and 28 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the loss of nonemergency ac power to station auxiliaries event.

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2.8.5.2.3 Loss of Normal Feedwater Flow Regulatory Evaluation A loss of normal feedwater flow could occur from pump failures, valve malfunctions, or a LOOP.

Loss of feedwater flow results in an increase in reactor coolant temperature and pressure which eventually requires a reactor trip to prevent fuel damage. Decay heat must be transferred from fuel following a loss of normal feedwater flow. Reactor protection and safety systems are actuated to provide this function and mitigate other aspects of the transient. The NRC staff's review covered (1) the sequence of events, (2) the analytical model used for analyses, (3) the values of parameters used in the analytical model, and (4) the results of the transient analyses.

The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-9, insofar as it requires that the reactor coolant pressure boundary shall be designed and constructed as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; and (3) draft GDC-27 and 28, insofar as they require that at least two reactivity control systems be provided and be capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits. Specific review criteria are contained in SRP Section 15.2.7 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the loss of normal feedwater flow event and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the AFDLs and the RCPB pressure limits will not be exceeded as a result of the loss of normal feedwater flow. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-6, 9, 27, and 28 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the loss of normal feedwater flow event.

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2.8.5.3 Decrease in Reactor Coolant System Flow 2.8.5.3.1 Loss of Forced Reactor Coolant Flow Regulatory Evaluation A decrease in reactor coolant flow occurring while the plant is at power could result in a degradation of core heat transfer. An increase in fuel temperature and accompanying fuel damage could then result if AFDLs are exceeded during the transient. Reactor protection and safety systems are actuated to mitigate the transient. The NRC staff's review covered (1) the postulated initial core and reactor conditions, (2) the methods of thermal and hydraulic analyses, (3) the sequence of events, (4) assumed reactions of reactor systems components, (5) the functional and operational characteristics of the reactor protection system, (6) operator actions, and (7) the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-9, insofar as it requires that the reactor coolant pressure boundary shall be designed and constructed as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; and (3) draft GDC-27 and 28, insofar as they require that at least two reactivity control systems be provided and be capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits. Specific review criteria are contained in SRP Section 15.3.1-2 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the decrease in reactor coolant flow event and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models.

The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the AFDLs and the RCPB pressure limits will not be exceeded as a result of this event. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-6, 9, 27, and 28 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the decrease in reactor coolant flow event.

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2.8.5.3.2 Reactor Recirculation Pump Rotor Seizure and Reactor Recirculation Pump Shaft Break Regulatory Evaluation The events postulated are an instantaneous seizure of the rotor or break of the shaft of a reactor recirculation pump. Flow through the affected loop is rapidly reduced, leading to a reactor and turbine trip. The sudden decrease in core coolant flow while the reactor is at power results in a degradation of core heat transfer which could result in fuel damage. The initial rate of reduction of coolant flow is greater for the rotor seizure event. However, the shaft break event permits a greater reverse flow through the affected loop later during the transient and, therefore, results in a lower core flow rate at that time. In either case, reactor protection and safety systems are actuated to mitigate the transient. The NRC staff's review covered (1)the postulated initial and long-term core and reactor conditions, (2) the methods of thermal and hydraulic analyses, (3) the sequence of events, (4) the assumed reactions of reactor system components, (5) the functional and operational characteristics of the reactor protection system, (6) operator actions, and (7) the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-32, insofar as it requires that limits, which include considerable margin, be placed on the maximum reactivity worth of control rods or elements and on rates at which reactivity can be increased to ensure that the potential effects of a sudden or large change of reactivity cannot (a) rupture the reactor coolant pressure boundary or (b) disrupt the core, its support structures, or other vessel internals sufficiently to impair the effectiveness of emergency core cooling; and (2) draft GDC-33, 34, and 35, insofar as they require that the RCPB be designed with margin sufficient to assure that, under specified conditions, it will behave in a nonbrittle manner and the probability of rapidly propagating fractures is minimized. Specific review criteria are contained in SRP Section 15.3.3-4 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the sudden decrease in core coolant flow events and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the ability to insert control rods is maintained, the RCPB pressure limits will not be exceeded, the RCPB will behave in a nonbrittle manner, the probability of propagating fracture of the RCPB is minimized, and INSERT 8 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

adequate core cooling will be provided. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-32, 33, 34, and 35 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the sudden decrease in core coolant flow events.

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2.8.5.4 Reactivity and Power Distribution Anomalies 2.8.5.4.1 Uncontrolled Control Rod Assembly Withdrawal from a Subcritical or Low Power Startup Condition Regulatory Evaluation An uncontrolled control rod assembly withdrawal from subcritical or low power startup conditions may be caused by a malfunction of the reactor control or rod control systems. This withdrawal will uncontrollably add positive reactivity to the reactor core, resulting in a power excursion. The NRC staff's review covered (1) the description of the causes of the transient and the transient itself, (2) the initial conditions, (3) the values of reactor parameters used in the analysis, (4) the analytical methods and computer codes used, and (5) the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-14 and 15, insofar as they require that the core protection systems be designed to act automatically to prevent or suppress conditions that could result in exceeding acceptable fuel damage limits and that protection systems be provided for sensing accident situations and initiating the operation of necessary ESFs; and (3) draft GDC-31, insofar as it requires that the reactivity control systems be capable of sustaining any single malfunction without causing a reactivity transient which could result in exceeding acceptable fuel damage limits. Specific review criteria are contained in SRP Section 15.4.1 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the uncontrolled control rod assembly withdrawal from a subcritical or low power startup condition and concludes that the licensee's analyses have adequately accounted for the changes in core design necessary for operation of the plant at the proposed power level. The NRC staff also concludes that the licensee's analyses were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure the AFDLs are not exceeded. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-6, 14, 15, and 31 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the uncontrolled control rod assembly withdrawal from a subcritical or low power startup condition.

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INSERT 8 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.8.5.4.2 Uncontrolled Control Rod Assembly Withdrawal at Power Regulatory Evaluation An uncontrolled control rod assembly withdrawal at power may be caused by a malfunction of the reactor control or rod control systems. This withdrawal will uncontrollably add positive reactivity to the reactor core, resulting in a power excursion. The NRC staff's review covered (1) the description of the causes of the AOO and the description of the event itself, (2) the initial conditions, (3) the values of reactor parameters used in the analysis, (4) the analytical methods and computer codes used, and (5) the results of the associated analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-14 and 15, insofar as they require that the core protection systems be designed to act automatically to prevent or suppress conditions that could result in exceeding acceptable fuel damage limits and that protection systems be provided for sensing accident situations and initiating the operation of necessary ESFs; and (3) draft GDC-31, insofar as it requires that the reactivity control systems be capable of sustaining any single malfunction without causing a reactivity transient which could result in exceeding acceptable fuel damage limits. Specific review criteria are contained in SRP Section 15.4.2 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the uncontrolled control rod assembly withdrawal at power event and concludes that the licensee's analyses have adequately accounted for the changes in core design required for operation of the plant at the proposed power level. The NRC staff also concludes that the licensee's analyses were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure the AFDLs are not exceeded. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-6, 14, 15, and 31 following implementation of the proposed EPU.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to the uncontrolled control rod assembly withdrawal at power.

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2.8.5.4.3 Startup of a Recirculation Loop at an Incorrect Temperature and Flow Controller Malfunction Causing an Increase in Core Flow Rate Regulatory Evaluation A startup of an inactive loop transient may result in either an increased core flow or the introduction of cooler water into the core. This event causes an increase in core reactivity due to decreased moderator temperature and core void fraction. The NRC staff's review covered (1) the sequence of events, (2) the analytical model, (3) the values of parameters used in the analytical model, and (4) the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-9, insofar as it requires that the reactor coolant pressure boundary shall be designed and constructed as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; (3) draft GDC-14 and 15, insofar as they require that the core protection systems be designed to act automatically to prevent or suppress conditions that could result in exceeding acceptable fuel damage limits and that protection systems be provided for sensing accident situations and initiating the operation of necessary ESFs; (4) draft GDC-32, insofar as it requires that limits, which include considerable margin, be placed on the maximum reactivity worth of control rods or elements and on rates at which reactivity can be increased to ensure that the potential effects of a sudden or large change of reactivity cannot (a) rupture the reactor coolant pressure boundary or (b) disrupt the core, its support structures, or other vessel internals sufficiently to impair the effectiveness of emergency core cooling; and (5) draft GDC-27 and 28, insofar as they require that at least two reactivity control systems be provided and be capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits.

Specific review criteria are contained in SRP Section 15.4.4-5 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the increase in core flow event and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the AFDLs and the RCPB pressure limits will not be exceeded as a result of this event. Based on this, the NRC staff concludes that the plant will INSERT 8 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

continue to meet the requirements of draft GDC-6, 9, 14, 15, 27, 28, and 32 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the increase in core flow event.

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2.8.5.4.4 Spectrum of Rod Drop Accidents Regulatory Evaluation The NRC staff evaluated the consequences of a control rod drop accident in the area of reactor physics. The NRC staff's review covered the occurrences that lead to the accident, safety features designed to limit the amount of reactivity available and the rate at which reactivity can be added to the core, the analytical model used for analyses, and the results of the analyses.

The NRC's acceptance criteria are based on draft GDC-32, insofar as it requires that limits, which include considerable margin, be placed on the maximum reactivity worth of control rods or elements and on rates at which reactivity can be increased to ensure that the potential effects of a sudden or large change of reactivity cannot (a) rupture the reactor coolant pressure boundary or (b) disrupt the core, its support structures, or other vessel internals sufficiently to impair the effectiveness of emergency core cooling. Specific review criteria are contained in SRP Section 15.4.9 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the rod drop accident and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that appropriate reactor protection and safety systems will prevent postulated reactivity accidents that could (1) result in damage to the RCPB greater than limited local yielding, or (2) cause sufficient damage that would significantly impair the capability to cool the core. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-32 following implementation of the EPU.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to the rod drop accident.

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2.8.5.5 Inadvertent Operation of ECCS or Malfunction that Increases Reactor Coolant Inventory Regulatory Evaluation Equipment malfunctions, operator errors, and abnormal occurrences could cause unplanned increases in reactor coolant inventory. Depending on the temperature of the injected water and the response of the automatic control systems, a power level increase may result and, without adequate controls, could lead to fuel damage or overpressurization of the RCS. Alternatively, a power level decrease and depressurization may result. Reactor protection and safety systems are actuated to mitigate these events. The NRC staff's review covered (1) the sequence of events, (2) the analytical model used for analyses, (3) the values of parameters used in the analytical model, and (4) the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-9, insofar as it requires that the reactor coolant pressure boundary shall be designed and constructed as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; and (3) draft GDC-27 and 28, insofar as they require that at least two reactivity control systems be provided and be capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits. Specific review criteria are contained in SRP Section 15.5.1-2 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the inadvertent operation of ECCS or malfunction that increases reactor coolant inventory and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the AFDLs and the RCPB pressure limits will not be exceeded as a result of this event. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-6, 9, 27, and 28 following implementation of the proposed EPU.

Therefore, the NRC staff finds the proposed EPU acceptable with respect to the inadvertent operation of ECCS or malfunction that increases reactor coolant inventory.

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2.8.5.6 Decrease in Reactor Coolant Inventory 2.8.5.6.1 Inadvertent Opening of a Pressure Relief Valve Regulatory Evaluation The inadvertent opening of a pressure relief valve results in a reactor coolant inventory decrease and a decrease in RCS pressure. The pressure relief valve discharges into the suppression pool. Normally there is no reactor trip. The pressure regulator senses the RCS pressure decrease and partially closes the turbine control valves (TCVs) to stabilize the reactor at a lower pressure. The reactor power settles out at nearly the initial power level. The coolant inventory is maintained by the feedwater control system using water from the condensate storage tank via the condenser hotwell. The NRC staff's review covered (1) the sequence of events, (2) the analytical model used for analyses, (3) the values of parameters used in the analytical model, and (4)the results of the transient analyses. The NRC's acceptance criteria are based on (1) draft GDC-6, insofar as it requires that the reactor core be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits; (2) draft GDC-9, insofar as it requires that the reactor coolant pressure boundary shall be designed and constructed as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime; and (3) draft GDC-27 and 28, insofar as they require that at least two reactivity control systems be provided and be capable of making and holding the core subcritical from any hot standby or hot operating condition sufficiently fast to prevent exceeding acceptable fuel damage limits. Specific review criteria are contained in SRP Section 15.6.1 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the inadvertent opening of a pressure relief valve event and concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection and safety systems will continue to ensure that the AFDLs and the RCPB pressure limits will not be exceeded as a result of this event. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-6, 9, 27, and 28 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the inadvertent opening of a pressure relief valve event.

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2.8.5.6.2 Emergency Core Cooling System and Lossof_Coolant Accidents Regulatory Evaluation LOCAs are postulated accidents that would result in the loss of reactor coolant from piping breaks in the RCPB at a rate in excess of the capability of the normal reactor coolant makeup system to replenish it. Loss of significant quantities of reactor coolant would prevent heat removal from the reactor core, unless the water is replenished. The reactor protection and ECCS systems are provided to mitigate these accidents. The NRC staff's review covered (1) the licensee's determination of break locations and break sizes; (2) postulated initial conditions; (3) the sequence of events; (4) the analytical model used for analyses, and calculations of the reactor power, pressure, flow, and temperature transients; (5) calculations of peak cladding temperature, total oxidation of the cladding, total hydrogen generation, changes in core geometry, and long-term cooling; (6) functional and operational characteristics of the reactor protection and ECCS systems; and (7) operator actions. The NRC's acceptance criteria are based on (1) 10 CFR § 50.46, insofar as it establishes standards for the calculation of ECCS performance and acceptance criteria for that calculated performance; (2) 10 CFR Part 50, Appendix K, insofar as it establishes required and acceptable features of evaluation models for heat removal by the ECCS after the blowdown phase of a LOCA; (3) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects that might result from plant equipment failures, as well as the effects of a LOCA; and (4) draft GDC-37, 41, and 44, insofar as they require that a system to provide abundant emergency core cooling be provided so that fuel and clad damage that would interfere with the emergency core cooling function will be prevented. Specific review criteria are contained in SRP Sections 6.3 and 15.6.5 and other guidance provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses of the LOCA events and the ECCS. The NRC staff concludes that the licensee's analyses have adequately accounted for operation of the plant at the proposed power level and that the analyses were performed using acceptable analytical models. The NRC staff further concludes that the licensee has demonstrated that the reactor protection system and the ECCS will continue to ensure that the peak cladding temperature, total oxidation of the cladding, total hydrogen generation, and changes in core geometry, and long-term cooling will remain within acceptable limits. Based on this, the NRC staff concludes that the plant will continue to meet the requirements of draft GDC-37, 40, 41, 42, and 44, and 10 CFR 50.46 following implementation of the proposed EPU. Therefore, INSERT 8 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

the NRC staff finds the proposed EPU acceptable with respect to the LOCA.

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2.8.5.7 Anticipated Transients Without Scrams Regulatory Evaluation ATWS is defined as an AOO followed by the failure of the reactor portion of the protection system specified in draft GDC-14 and 15. The regulation at 10 CFR 50.62 requires that:

• each BWR have an ARI system that is designed to perform its function in a reliable manner and be independent (from the existing reactor trip system) from sensor output to the final actuation device.

• each BWR have a standby liquid control system (SLCS) with the capability of injecting into the reactor vessel a borated water solution with reactivity control at least equivalent to the control obtained by injecting 86 gpm of a 13 weight-percent sodium pentaborate decahydrate solution at the natural boron-1 0 isotope abundance into a 251-inch inside diameter reactor vessel. The system initiation must be automatic.

• each BWR have equipment to trip the reactor coolant recirculation pumps automatically under conditions indicative of an ATWS.

The NRC staff's review was conducted to ensure that (1) the above requirements are met, (2) sufficient margin is available in the setpoint for the SLCS pump discharge relief valve such that SLCS operability is not affected by the proposed EPU, and (3) operator actions specified in the plant's Emergency Operating Procedures are consistent with the generic emergency procedure guidelines/severe accident guidelines (EPGs/SAGs), insofar as they apply to the plant design. In addition, the NRC staff reviewed the licensee's ATWS analysis to ensure that (1) the peak vessel bottom pressure is less than the ASME Service Level C limit of 1500 psig; (2) the peak clad temperature is within the 10 CFR 50.46 limit of 2200 OF; (3) the peak suppression pool temperature is less than the design limit; and (4) the peak containment pressure is less than the containment design pressure. The NRC staff also evaluated the potential for thermal-hydraulic instability in conjunction with ATWS events using the methods and criteria approved by the NRC staff. For this analysis, the NRC staff reviewed the limiting event determination, the sequence of events, the analytical model and its applicability, the values of parameters used in the analytical model, and the results of the analyses. Insert the following sentence if the licensee relied upon generic vendor analyses [The NRC staff reviewed the licensee's justification of the applicability of generic vendor analyses to its plant and the operating conditions for the proposed EPU.] Review guidance is provided in Matrix 8 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in INSERT 8 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

the conclusion section.]

INSERT 8 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

Conclusion The NRC staff has reviewed the information submitted by the licensee related to ATWS and concludes that the licensee has adequately accounted for the effects of the proposed EPU on ATWS. The NRC staff concludes that the licensee has demonstrated that ARI, SLCS, and recirculation pump trip systems have been installed and that they will continue to meet the requirements of 10 CFR 50.62 and the analysis acceptance criteria following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to ATWS.

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2.8.6 Fuel Storace 2.8.6.1 New Fuel Storage Regulatory Evaluation Nuclear reactor plants include facilities for the storage of new fuel. The quantity of new fuel to be stored varies from plant to plant, depending upon the specific design of the plant and the individual refueling needs. The NRC staff's review covered the ability of the storage facilities to maintain the new fuel in a subcritical array during all credible storage conditions. The review focused on the effect of changes in fuel design on the analyses for the new fuel storage facilities. The NRC's acceptance criteria are based on draft GDC-66, insofar as it requires the prevention of criticality in fuel storage systems by physical systems or processes, preferably utilizing geometrically safe configurations. Specific review criteria are contained in SRP Section 9.1.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effect of the new fuel on the analyses for the new fuel storage facilities and concludes that the new fuel storage facilities will continue to meet the requirements of draft GDC-66 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to the new fuel storage.

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2.8.6.2 Spent Fuel Storage Regulatory Evaluation Nuclear reactor plants include storage facilities for the wet storage of spent fuel assemblies.

The safety function of the spent fuel pool and storage racks is to maintain the spent fuel assemblies in a safe and subcritical array during all credible storage conditions and to provide a safe means of loading the assemblies into shipping casks. The NRC staff's review covered the effect of the proposed EPU on the criticality analysis (e.g., reactivity of the spent fuel storage array and boraflex degradation or neutron poison efficacy). The NRC's acceptance criteria are based on (1) draft GDC-40 and 42, insofar as they require that protection be provided for ESFs against the dynamic effects and missiles that might result from plant equipment failures, as well as the effects of a loss of coolant accident; and (2) draft GDC-66, insofar as it requires that criticality in the fuel storage systems be prevented by physical systems or processes, preferably by use of geometrically safe configurations. Specific review criteria are contained in SRP Section 9.1.2.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's analyses related to the effects of the proposed EPU on the spent fuel storage capability and concludes that the licensee has adequately accounted for the effects of the proposed EPU on the spent fuel rack temperature and criticality analyses.

The NRC staff also concludes that the spent fuel pool design will continue to ensure an acceptably low temperature and an acceptable degree of subcriticality following implementation of the proposed EPU. Based on this, the NRC staff concludes that the spent fuel storage facilities will continue to meet the requirements of draft GDC-40, 42, and 66 following implementation of the proposed EPU. Therefore, the NRC staff finds the proposed EPU acceptable with respect to spent fuel storage.

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[2.8.7 Additional Review Areas (Reactor Systems)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT8 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

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2.9 Source Terms and Radiological Consequences Analyses 2.9.1 Source Terms for Radwaste Systems Analyses Regulatory Evaluation The NRC staff reviewed the radioactive source term associated with EPUs to ensure the adequacy of the sources of radioactivity used by the licensee as input to calculations to verify that the radioactive waste management systems have adequate capacity for the treatment of radioactive liquid and gaseous wastes. The NRC staff's review included the parameters used to determine (1) the concentration of each radionuclide in the reactor coolant, (2) the fraction of fission product activity released to the reactor coolant, (3) concentrations of all radionuclides other than fission products in the reactor coolant, (4) leakage rates and associated fluid activity of all potentially radioactive water and steam systems, and (5) potential sources of radioactive materials in effluents that are not considered in the plant's [Updated Safety Analysis Report or Updated Final Safety Analysis Report] related to liquid waste management systems and gaseous waste management systems. The NRC's acceptance criteria for source terms are based on (1) 10 CFR Part 20, insofar as it establishes requirements for radioactivity in liquid and gaseous effluents released to unrestricted areas; (2) 10 CFR Part 50, Appendix I, insofar as it establishes numerical guides for design objectives and limiting conditions for operation to meet the "as low as is reasonably achievable" criterion; and (3) draft GDC-70, insofar as it requires that the plant design include means to control the release of radioactive effluents.

Specific review criteria are contained in SRP Section 11.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the radioactive source term associated with the proposed EPU and concludes that the proposed parameters and resultant composition and quantity of radionuclides are appropriate for the evaluation of the radioactive waste management systems.

The NRC staff further concludes that the proposed radioactive source term meets the requirements of 10 CFR Part 20, 10 CFR Part 50, Appendix I, and draft GDC-70. Therefore, the NRC staff finds the proposed EPU acceptable with respect to source terms.

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NOTE: Use Sections 2.9.2 and2.9.3 below if the licensee's radiological consequences analyses are based on an alternative source term.

2.9.2 Radiological Consequences Analyses Using Alternative Source Terms NOTE: There are two cases that may be encountered here: (1) a licensee may be implementing an alternative source term for the first time, or (2) a licensee may have already fully implemented an alternative source term and is revising the previously approved dose analyses that use alternative source term methodologies. The second paragraph for each heading is only needed for a first-time implementation of an alternative source term (either partial or full implementations). Several accidents may have been analyzed - see corresponding SRP sections for further regulatory evaluation text (to be modified), as needed.

Regulatory Evaluation The NRC staff reviewed the DBA radiological consequences analyses. The radiological consequences analyses reviewed are the LOCA, fuel handling accident (FHA), control rod drop accident (CRDA), and main steamline break (MSLB). The NRC staff's review for each accident analysis included (1) the sequence of events; and (2) models, assumptions, and values of parameter inputs used by the licensee for the calculation of the total effective dose equivalent (TEDE). The NRC's acceptance criteria for radiological consequences analyses using an alternative source term are based on (1) 10 CFR 50.67, insofar as it sets standards for radiological consequences of a postulated accident, and (2) draft GDC-1 1, insofar as it requires that adequate radiation protection be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem TEDE, as defined in 10 CFR 50.2, for the duration of the accident. Specific review criteria are contained in SRP Section 15.0.1.

NOTE: Use the following paragraph for a first implementation of an alternative source term:

The NRC staff reviewed the implementation of alternative source terms. The NRC's acceptance criteria for implementation of alternative source terms are based on (1) 10 CFR 50.67, insofar as it sets standards for the implementation of an alternative source term in current operating nuclear power plants; (2) 10 CFR 50.49, insofar as it requires qualification of safety-related equipment, as defined in that section, including and based on integrated radiation dose during normal and accident conditions; (3) draft GDC-1 1, insofar as it requires that adequate radiation protection be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem TEDE, as defined in 10 CFR 50.2, for the duration of the accident; (4) Paragraph IV.E.8 of 10 CFR Part 50, Appendix E, insofar as it requires a licensee onsite technical support center and a licensee near-site emergency operations facility from which effective direction can be given and effective control can be exercised during an emergency; and (5) plant-specific licensing commitments made in response to NUREG-0737 (Items ll.B.2, ll.B.3, ll.F.1, lll.D.1.1, III.A.1.2, and lll.D.3.4). Specific review criteria are contained in INSERT 9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

SRP Sections 15.0.1.

INSERT9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has evaluated the licensee's revised accident analyses performed in support of the proposed EPU and concludes that the licensee has adequately accounted for the effects of the proposed EPU. The NRC staff further concludes that the plant site and the dose-mitigating ESFs remain acceptable with respect to the radiological consequences of postulated DBAs since, as set forth above, the calculated total effective dose equivalent (TEDE) at the exclusion area boundary (EAB), at the low population zone (LPZ) outer boundary, and in the control room meet the exposure guideline values specified in 10 CFR 50.67 and draft GDC-1 1, as well as applicable acceptance criteria denoted in SRP Section 15.0.1. Therefore, the NRC staff finds the licensee's proposed EPU acceptable with respect to the radiological consequences of DBAs.

NOTE: Use the following paragraph for a first implementation of an alternative source term:

The NRC staff has reviewed the alternative source term methodology used by the licensee in evaluating the effects of the proposed EPU and concludes that changes continue to provide a sufficient margin of safety with adequate defense-in-depth to address unanticipated events and to compensate for uncertainties in accident progression, analysis assumptions, and parameter inputs. Therefore, the NRC staff finds the licensee's proposed EPU acceptable with respect to the implementation of an alternative source term.

INSERT 9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

[2.9.3 Additional Review Areas (Radiological Consequences Analyses)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT 9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

NOTE: Use Sections 2.9.2 - 2.9.8 below if the licensee's radiological consequences analyses are not based on an alternative source term (i.e., if the analyses are based on a traditional source term (i.e., TID-14844) 2.9.2 Radiological Consequences of Control Rod Drop Accident

[This section is not applicable because the Vermont Yankee Nuclear Power Station is implementing an alternative source term.]

INSERT 9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.9.3 Radiological Consequences of the Failure of Small Lines Carrying Primary Coolant Outside Containment

[This section is not applicable because the Vermont Yankee Nuclear Power Station is implementing an alternative source term.]

INSERT 9 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.9.4 Radiological Consequences of Main Steamline Failure Outside Containment

[This section is not applicable because the Vermont Yankee Nuclear Power Station is implementing an alternative source term.]

INSERT 9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.9.5 Radiological Consequences of a Design-Basis Loss-of-Coolant Accident

[This section is not applicable because the Vermont Yankee Nuclear Power Station is implementing an alternative source term.]

INSERT 9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.9.6 Radiological Consequences of Fuel Handling Accidents

[This section is not applicable because the Vermont Yankee Nuclear Power Station is implementing an alternative source term.]

INSERT9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

2.9.7 Radiological Consequences of Spent Fuel Cask Drop Accidents

[This section is not applicable because the Vermont Yankee Nuclear Power Station is implementing an alternative source term.]

INSERT 9 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

[2.9.8 Additional Review Areas (Source Terms and Radiological Consequences Analyses)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT 9 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

INSERT 10 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION

2.10 Health Physics 2.10.1 Occupational and Public Radiation Doses Regulatory Evaluation The NRC staff conducted its review in this area to ascertain what overall effects the proposed EPU will have on both occupational and public radiation doses and to determine that the licensee has taken the necessary steps to ensure that any dose increases will be maintained as low as is reasonably achievable. The NRC staff's review included an evaluation of any increases in radiation sources and how this may affect plant area dose rates, plant radiation zones, and plant area accessibility. The NRC staff evaluated how personnel doses needed to access plant vital areas following an accident are affected. The NRC staff considered the effects of the proposed EPU on nitrogen-16 levels in the plant and any effects this increase may have on radiation doses outside the plant and at the site boundary from skyshine. The NRC staff also considered the effects of the proposed EPU on plant effluent levels and any effect this increase may have on radiation doses at the site boundary. The NRC's acceptance criteria for occupational and public radiation doses are based on 10 CFR Part 20 10 CFR 50.67, and draft GDC-11. Specific review criteria are contained in SRP Sections 12.2, 12.3,12.4, and 12.5, and other guidance provided in Matrix 10 of RS-001.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the effects of the proposed EPU on radiation source terms and plant radiation levels. The NRC staff concludes that the licensee has taken the necessary steps to ensure that any increases in radiation doses will be maintained as low as reasonably achievable. The NRC staff further concludes that the proposed EPU meets the requirements of 10 CFR Part 20 and draft GDC-11. Therefore, the NRC staff finds the licensee's proposed EPU acceptable with respect to radiation protection and ensuring that occupational radiation exposures will be maintained as low as reasonably achievable.

INSERT 10 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

[2.10.2 Additional Review Areas (Health Physics)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT 10 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

INSERT 11 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION

2.11 Human Performance 2.11.1 Human Factors Regulatory Evaluation The area of human factors deals with programs, procedures, training, and plant design features related to operator performance during normal and accident conditions. The NRC staff's human factors evaluation was conducted to ensure that operator performance is not adversely affected as a result of system changes made to implemented the proposed EPU. The NRC staff's review covered changes to operator actions, human-system interfaces, and procedures and training needed for the proposed EPU. The NRC's acceptance criteria for human factors are based on draft GDC-11, 10 CFR 50.120, 10 CFR Part 55, and the guidance in GL 82-33. Specific review criteria are contained in SRP Sections 13.2.1, 13.2.2, 13.5.2.1, and 18.0.

Technical Evaluation The NRC staff has developed a standard set of questions for the review of the human factors area. The licensee has addressed these questions in its application. Following are the NRC staff's questions, the licensee's responses, and the NRC staff's evaluation of the responses.

1. Changes in Emergency and Abnormal Operating Procedures Describe how the proposed EPU will change the plant emergency and abnormal operating procedures. (SRP Section 13.5.2.1)

[Insert licensee's response followed by NRC staff statement on why the response is acceptable]

2. Changes to Operator Actions Sensitive to Power Uprate Describe any new operator actions needed as a result of the proposed EPU. Describe changes to any current operator actions related to emergency or abnormal operating procedures that will occur as a result of the proposed EPU. (SRP Section 18.0)

(i.e., Identify and describe operator actions that will involve additional response time or will have reduced time available. Your response should address any operator workarounds that might affect these response times. Identify any operator actions that are being automated or being changed from automatic to manual as a result of the power uprate. Provide justification for the acceptability of these changes).

[insert licensee's response followed by NRC staff statement on why the response is INSERT 11 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

acceptable]

INSERT 11 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

3. Chanqes to Control Room Controls. Displays and Alarms Describe any changes the proposed EPU will have on the operator interfaces for control room controls, displays, and alarms. For example, what zone markings (e.g. normal, marginal and out-of-tolerance ranges) on meters will change? What setpoints will change?

How will the operators know of the change? Describe any controls, displays, alarms that will be upgraded from analog to digital instruments as a result of the proposed EPU and how operators will be tested to determine they could use the instruments reliably. (SRP Section 18.0)

[Insert licensee's response followed by NRC staff statement on why the response is acceptable]

4. Changes on the Safety Parameter Display System Describe any changes to the safety parameter display system resulting from the proposed EPU. How will the operators know of the changes? (SRP Section 18.0)

[Insert licensee's response followed by NRC staff statement on why the response is acceptable]

5. Changes to the Operator Training Program and the Control Room Simulator Describe any changes to the operator training program and the plant referenced control room simulator resulting from the proposed EPU, and provide the implementation schedule for making the changes. (SRP Sections 13.2.1 and 13.2.2)

[Insert licensee's response followed by NRC staff statement on why the response is acceptable]

Conclusion The NRC staff has reviewed the changes to operator actions, human-system interfaces, procedures, and training required for the proposed EPU and concludes that the licensee has (1) appropriately accounted for the effects of the proposed EPU on the available time for operator actions and (2) taken appropriate actions to ensure that operator performance is not adversely affected by the proposed EPU. The NRC staff further concludes that the licensee will continue to meet the requirements of draft GDC-11, 10 CFR 50.120, and 10 CFR Part 55 following implementation of the proposed EPU. Therefore, the NRC staff finds the licensee's proposed EPU acceptable with respect to the human factors aspects of the required system changes.

INSERT 11 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

[2.11.2 Additional Review Areas (Human Performance)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT 11 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

INSERT 12 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION

2.12 Power Ascension and Testing Plan 2.12.1 Approach to EPU Power Level and Test Plan Regulatory Evaluation The purpose of the EPU test program is to demonstrate that SSCs will perform satisfactorily in service at the proposed EPU power level. The test program also provides additional assurance that the plant will continue to operate in accordance with design criteria at EPU conditions. The NRC staff's review included an evaluation of: (1) plans for the initial approach to the proposed maximum licensed thermal power level, including verification of adequate plant performance, (2) transient testing necessary to demonstrate that plant equipment will perform satisfactorily at the proposed increased maximum licensed thermal power level, and (3) the test program's conformance with applicable regulations. The NRC's acceptance criteria for the proposed EPU test program are based on 10 CFR Part 50, Appendix B, Criterion Xl, which requires establishment of a test program to demonstrate that SSCs will perform satisfactorily in service.

Specific review criteria are contained in SRP Section 14.2.1.

Technical Evaluation

[Insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The staff has reviewed the EPU test program, including plans for the initial approach to the proposed maximum licensed thermal power level, transient testing necessary to demonstrate that plant equipment will perform satisfactorily at the proposed increased maximum licensed thermal power level, and the test program's conformance with applicable regulations. The staff concludes that the proposed EPU test program provides adequate assurance that the plant will operate in accordance with design criteria and that SSCs affected by the proposed EPU, or modified to support the proposed EPU, will perform satisfactorily in service. Further, the staff finds that there is reasonable assurance that the EPU testing program satisfies the requirements of 10 CFR Part 50, Appendix B, Criterion Xl. Therefore, the NRC staff finds the proposed EPU test program acceptable.

INSERT 12 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

[2.12.2 Additional Review Areas (Power Ascension and Testing Plan)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT 12 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

INSERT 13 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION

2.13 Risk Evaluation 2.13.1 Risk Evaluation of EPU Regulatory Evaluation The licensee conducted a risk evaluation to (1) demonstrate that the risks associated with the proposed EPU are acceptable and (2) determine if "special circumstances" are created by the proposed EPU. As described in Appendix D of SRP Chapter 19, special circumstances are present if any issue would potentially rebut the presumption of adequate protection provided by the licensee to meet the deterministic requirements and regulations. The NRC staff's review covered the impact of the proposed EPU on core damage frequency (CDF) and large early release frequency (LERF) for the plant due to changes in the risks associated with internal events, external events, and shutdown operations. In addition, the NRC staff's review covered the quality of the risk analyses used by the licensee to support the application for the proposed EPU. This included a review of the licensee's actions to address issues or weaknesses that may have been raised in previous NRC staff reviews of the licensee's individual plant examinations (IPEs) and individual plant examinations of external events (IPEEE), or by an industry peer review. The NRC's risk acceptability guidelines are contained in RG 1.174. Specific review guidance is contained in Matrix 13 of RS-001 and its attachments.

Technical Evaluation

[insert technical evaluation. The technical evaluation should (1) clearly explain why the proposed changes satisfy each of the requirements in the regulatory evaluation and (2) provide a clear link to the conclusions reached by the NRC staff, as documented in the conclusion section.]

Conclusion The NRC staff has reviewed the licensee's assessment of the risk implications associated with the implementation of the proposed EPU and concludes that the licensee has adequately modeled and/or addressed the potential impacts associated with the implementation of the proposed EPU. The NRC staff further concludes that the results of the licensee's risk analysis indicate that the risks associated with the proposed EPU are acceptable and do not create the "special circumstances" described in Appendix D of SRP Chapter 19. Therefore, the NRC staff finds the risk implications of the proposed EPU acceptable.

INSERT 13 FOR SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

[2.13.2 Additional Review Areas (Risk Evaluation)]

[Insert Regulatory Evaluation, Technical Evaluation, and Conclusion sections as necessary]

INSERT 13 FOR SECTION 3.2- BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003

' The Vermont Yankee Nuclear Power Station was licensed in accordance with the 70 draft General Design Criteria proposed by the Atomic Energy Commission in Federal Register32FR10213, July 11, 1967.

SECTION 3.2 - BWR TEMPLATE SAFETY EVALUATION DECEMBER 2003