ML15344A294

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

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

Text

Pre-Submittal Teleconference Millstone Power Station Unit 2 (MPS2) License Amendment Request (LAR) for Charging System in Response to Confirmatory Order EA-13-188 December 10, 2015 Pg. 2 Agenda *Purpose of LAR *Scope of LAR *AREVA Analysis for Long-Term IOPORV *Application of Single Failure Criterion *Applicable Regulatory Issue *Schedule Pg. 3 Purpose of LAR *LAR required by Confirmatory Order EA-13-188 (8/26/15) Compliance Item #2: "By no later than February 15, 2016, DNC will submit a license amendment request to the NRC addressing the use of charging pumps in the analysis of the inadvertent opening of the PORVs." *DNC has completed an analysis of the long-term response for FSAR Section 14.6.1, "Inadvertent Opening of a Pressurized Water Reactor Pressurizer Pressure Relief Valve" (IOPORV) with no credit for Charging flow *LAR will include proposed changes to Technical Specification (TS) Section 3/4.5.2 and FSAR Chapter 14 *LAR meets regulatory criteria and will preserve health and safety of the public Pg. 4 Scope of LAR *LAR will include more than the analysis of the FSAR Section 14.6.1 IOPORV event required by the Confirmatory Order *LAR will propose to remove Charging from TS 3/4.5.2, Emergency Core Cooling Systems -Charging pumps appear in Surveillance Requirement (SR) 4.5.2.e as an ECCS subsystem with Operability requirements: "By verifying the delivered flow of each charging pump at the required discharge pressure is greater than or equal to the required flow when tested pursuant to Specification 4.0.5." -LAR will demonstrate that Charging does not meet the four criteria in 10CFR50.36 for inclusion in the Technical Specifications -Change to TS 3/4.5.2 Bases will be provided for information Pg. 5 Scope of LAR (Continued) *LAR will request NRC review and approval of changes to FSAR Chapter 14 -Proposed FSAR changes are based on the FSAR prior to the 2009 FSAR change made by DNC under 10 CFR 50.59 -Proposed FSAR change reflects the new long-term IOPORV analysis, which does not credit charging (discussed on next slide) -Proposed change to FSAR Section 14.0.11 clarifies the application of single failure for MPS2 Pg. 6 AREVA Analysis for Long-Term IOPORV *Analysis completed for long-term response to an IOPORV for MPS2 -Uses NRC-approved S-RELAP5 SBLOCA methodology in EMF-2328, Rev. 0, with Supplement 1 -Assumes open pressurizer safety valve which bounds two open PORVs -Credits two HPSI pumps with no flow from charging pumps -Results demonstrate no core uncovery *LAR will include analysis description and plots of key results *With this new analysis, flow from the charging pumps is not credited in any FSAR Chapter 14 safety analyses for event mitigation Application of Single Failure Criterion *IOPORV event in FSAR Section 14.6.1 is a moderate frequency, or ANS Condition II, event *Single failure criterion does not apply to Moderate Frequency events -Consistent with MPS2 FSAR Section 14.0.11 -Consistent with NRC SRP (NUREG-0800) Chapter 15 *Postulating a single failure for the IOPORV event is a Small Break LOCA (FSAR Section 14.6.3) with acceptance criteria governed by 10 CFR 50.46 *MPS2 does not apply a single failure to the IOPORV event (with the exception of the reactor protection system) Pg. 7 Pg. 8 Applicable Regulatory Issue *Draft Revision 1 to RIS 2005-29 "Anticipated Transients That Could Develop Into More Serious Events" -Draft Revision 1 to RIS 2005-29 provides regulatory positions on the IOPORV event that is addressed in the MPS2 LAR. -Demonstration of no long term core uncovery demonstrates that the transient meets the non-escalation criteria Pg. 9 Schedule *DNC will submit the LAR by February 15, 2016 *Review schedule *To maintain compliance with the Confirmatory Order, Operability Determination and Standing Order are in place for the Charging system and will remain in place until NRC makes a final determination on the LAR Acronym List *ANS American Nuclear Society *CFR Code of Federal Regulations *DNC Dominion Nuclear Connecticut *ECCS Emergency Core Cooling System *FSAR Final Safety Analysis Report *IOPORV Inadvertent Opening of a Pressurizer Pressure Relief Valve *LAR License Amendment Request *MPS2 Millstone Power Station, Unit 2 *PWR Pressurized Water Reactor *RIS Regulatory Issue Summary *SBLOCA Small Break Loss of Coolant Accident *SR Surveillance Requirement *SRP Standard Review Plan *TS Technical Specifications Pg. 10