Closure Option 1
GSI-191 Workshop
October 18-19,2012
Overview
 Background
 Available guidance documents
 Template format and considerations
 Beaver Valley Unit 2 Example
 Summary
Option 1 Overview
 This is the most straightforward of the three available
options to close GSI-191
– Deterministic and NRC approved methods
– Expect plants using this option are generally complete
except for in-vessel effects
 Fibrous debris is limited to 15 g/FA
 Sump strainer and Invessel loading can be shown to be
acceptable through meeting clean plant criteria or by
supported testing
 Fibrous debris either meets a 15 g/FA In-vessel limit
or will meet the limit following modifications
Guidance Documents
 SECY 12-0093, ‘Closure Options for GSI-191’
 May 2, 2012 letter from NRC to NEI, ‘Clean Plant
Acceptance Criteria’
 December 22, 2011 letter from NEI to NRC, ‘GSI-191
Resolution Criteria for “Low Fiber” Plants’
 WCAP-16793 Rev. 2 [SE pending]
Clean Plant Criteria


theoretical thin bed is 1/16” or less, (using total fiber = generated +
latent) and (100% transport, p = 2.4 lbs/ft3)
Sump Strainer Head loss testing is not required if,
– No problematic insulation within ZOI
– Measures taken to reduce debris source term (e.g. double banding)
– Credit total area of all trains (provided that operating procedures direct
prompt restoration for return to service or other justification)
– Consideration of paint chips for strainers in pits
– Sacrificial area accounted for (e.g. tags, labels)
– Maintain cleanliness program (define if NEI guidance or plant specific)
– Satisfactorily addressed NPSH, vortexing, upstream effects and structural
integrity
– Strainer Head loss = clean Hl + debris Hl (where Hl can be assumed to be
2 ft. unless other representative testing is cited / applicable)
OR

Acceptable head loss test
Clean Plant Criteria
Rx In-vessel





Credit for WCAP 16793 Rev. 2
Demonstrate that the 15 g/FA is valid for the plant specific fuel design
Plants may apply relevant assumptions (strainer bypass fraction, debris
transport fraction) provided they are adequately justified for their plant
design (could be based upon information of similar design)
Can use 45% bypass assumption if it can be shown to be valid for plant
conditions
For total containment fiber (in order to have less than 15 g/FA to the
core);
– Use 45% bypass, 75% transport provided the assumptions are valid for
the plant
• (simply stated):

Acceptable bypass test
15.7 lbs. total fiber = 157 fuel assemblies
20.0 lbs. total fiber = 200 fuel assemblies
OR
Template Attributes
 Resolution Status
 Identify method of compliance with 15 g/FA
criteria
– Clean plant criteria or plant specific bypass testing
– Modifications if currently not met
 Licensing Basis Commitments
 Resolution schedule
– Meet SECY 12-0093 for open items (e.g. modifications)
• 2 outages from 1/1/13 [no later than 1/1/17]
– Licensing basis update following completion of open
items and NRC acceptance
BV-2 Example
 Resolution Status
– No further questions except for in-vessel
• Reference to previous submittals, including RAI
responses
– Emphasis on Modifications
• Insulation (extensive change out to RMI)
• Buffer replacement from NaOH to NaTb
– Containment coating / cleaning program
• use NEI 04-07 quantities for latent debris
 Credit for bypass testing to derive in-vessel load
– Enercon strainer with bypass eliminators
BV-2 Example
 Rx invessel load
(36.4  30)  66.4 lbs.
66.4 lbs  0.042  453.6
157 FA
g
lbs  8.1 g
FA
 Existing commitment to resolve Rx in-vessel based upon
WCAP-16793 Rev. 1
– Need to reconcile to Rev. 2 and any limitations
associated with SE
 New commitment to update licensing basis following
NRC review / approval
Summary
 For the BV2 example, closure is based upon low
fiber loading and credit for bypass testing
 For RMI plants, a strict containment cleanliness
program or credit for plant specific bypass testing
would be required
 Expect that if plants need to make modifications or
perform additional testing to meet 15 g/FA, they
would defer to Option 2