3F0509-09, Response to Request for Additional Information to License Amendment Request 307, Revision 0: Methodology for Rod Ejection Accident Analysis Under Extended Power Uprate Conditions
| ML091530015 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/29/2009 |
| From: | Franke J Progress Energy Florida |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 3F0509-09, TAC ME0730 | |
| Download: ML091530015 (11) | |
Text
Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 May 29, 2009 3F0509-09 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ref: 10 CFR 50.90
Subject:
Crystal River Unit 3 -
License Amendment Request #307, Methodology for Rod Ejection Accident Analysis Under Extended Conditions - Response to Request for Additional Information Revision 0:
Reference:
Crystal River Unit 3 to NRC Letter dated February 26, 2009, "Crystal River Unit 3 - License Amendment Request #307, Revision 0: Methodology for Rod Ejection Accident Analysis Under Extended Power Uprate Conditions (TAC NO.
ME0730)
Dear Sir:
Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., in accordance with 10 CFR 50.90, hereby provides a response to a request for additional information (RAI) related to License Amendment Request (LAR) #307, Revision 0. This RAI was received by electronic mail on May 6, 2009.
Attachment B contains proprietary information.
AREVA NP Inc. requests the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4).
An Affidavit supporting the request is provided in Attachment A. A non-proprietary version of the response is attachecdin Attachment C.
In accordance with 10 CFR 50.91, a copy of the RAI response is being provided to the designated State of Florida Official.
This correspondence contains no new regulatory commitments.
If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Supervisor, Licensing and Regulatory Programs at (352) 563-4796.
'Jon A. Franke Vice President Crystal River Unit 3 JAF/rt Attachments:
A.
B.
C.
Affidavit for Withholding Proprietary Information from Public Disclosure Response to Request for Additional Information (Proprietary)
Response to Request for Additional Information (non-Proprietary) xc:
NRR Project Manager Regional Administrator, Region II Senior Resident Inspector State Contact Progress Energy Florida, Inc.
Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428 A- 00/
k9,K,
U. S. Nuclear Regulatory Commission 3F0509-09 Page 2 of 2 STATE OF FLORIDA COUNTY OF CITRUS Jon A. Franke states that he is the Vice President, Crystal River Nuclear Plant for Florida Power Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
Vrisce President P
~Crystal River Nuclear Plant The foregoing document was acknowledged before me this day of S,2009, by Jon A. Franke.
Signature of Notary Public Sta -
CAROLYN E. PORTMANN Commission D
OD 524380 F
.49uF By F
Naunal Notary (Print, type, or stamp Commissioned Name of Notary Public)
Personally Known Ir Produced
-OR-Identification
PROGRESS ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET Number 50-302 /License Number DPR-72 LICENSE AMENDMENT REQUEST #307, Revision 0 Attachment A Affidavit for Withholding Proprietary Information from Public Disclosure
AFFIDAVIT COMMONWEALTH OF VIRGINIA
)
) ss.
CITY OF LYNCHBURG
)
- 1.
My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3.
I am familiar with the AREVA NP information contained in the attachment to a letter to the U.S. Nuclear Regulatory Commission from Mr. Jon A. Franke (Progress Energy) entitled, "Crystai River Unit 3 - License Amendment Request: License Amendment Request No.
307, Revision 0: Methodology for Rod Ejection Accident Analysis Under Extended Power Uprate Conditions - Response to Request for Additional Information," Docket No. 50-302, Operating License No. DPR-72, Letter No. 3F0609-01, and referred to herein as "Document."
Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.
- 4.
This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
- 6.
The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:
(a)
The information reveals details of AREVA NP's research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.
The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(c) above.
- 7.
In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available,
on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
SUBSCRIBED before me this _
day of May 2009.
Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/10 Reg. # 7079129 SHERRY L. MCPADEN Notary Public I
Commonwealth of Virginia 7079129 My Commission Expires Oct 31. 2010 1----
PROGRESS ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET Number 50-302 /License Number DPR-72 LICENSE AMENDMENT REQUEST #307, Revision 0 Attachment C Response to Request for Additional Information (non-Proprietary)
U. S. Nuclear Regulatory Commission 3F0509-09 Attachment C Page 1 of 4 Response to Request for Additional Information Based on an electronic mail transmission that was received from the NRC on May 6, 2009, the following additional information is provided by Crystal River Unit 3 (CR-3).
NRC Request RAI-01:
Fig. 7-5 shows temperatures of Gadolinia containing fuel, which indeed is lower than fuel containing no Gadolinia. How does the melt temperature offuel vary with Gadolinia content? How close to the limit are the temperatures shown on Fig. 7-5 to melting, despite the fact that they are lower than that with no Gadolinia?
CR-3 Response:
As given on Page 10-3 of the COPERNIC Fuel Rod Design Computer Code Topical Report (Reference 2 of ANP-2788P, Revision 0, Crystal River Unit 3 Rod Ejection Accident Methodology Report), the melting temperature of U0 2 and U0 2 -Gd2O3 is [
- 1. The main effect of Gadolinia additions is to reduce the thermal conductivity of the fuel pellets. This reduction in thermal conductivity is accounted for in COPERNIC (Section 4.3.3.2 of the COPERNIC Topical Report) and it is countered by reduced U2 35 enrichments that lower the power level capability in the Gadolinia fuel rods.
As shown in Figure 7-5 of ANP-2788P, Revision 0, the temperatures of the fuel containing Gadolinia are [.
For this sample case, the temperature differences from the minimum fuel melt limit temperature specified in Section 7.3 of ANP-2788P, Revision 0, for each of the fuel rod types shown in Figure 7-5 of ANP-2788P, Revision 0, are provided in Table RAI-01-1 at the event termination time of 19 seconds.
Table RAI-01 Fuel Temperature Differences from Fuel Melt Limit Temperature Fuel Rod Rod Power Level Centerline Temperature Difference from Melt Limit Type Ratio to U0 2 Rod at 19 sec (°F)
Temperature (°F) 0 w/o 1.00
[
[
Gadolinia 3 w/o I
I I
1 Gadolinia 8w/o I
w I
1 Gadolinia
U. S. Nuclear Regulatory Commission Attachment C 3F0509-09 Page 2 of 4 NRC Request RAI-02:
Figs. 7-6 to 7-8 show pre-to post-power curves determined using static and dynamic calculations for Ref 5. Are the corresponding curves for Crystal River 3 similar?
CR-3 Response:
For the cases analyzed, no Departure from Nucleate Boiling (DNB) related failures were predicted during the pulse so these curves were not generated for Crystal River Unit 3. If Departure from Nucleate Boiling Ratio (DNBR) failures were predicted to fail during the pulse, a curve similar to Figure 7-6 of ANP-2788P, Revision 0, would be generated to count the number of failures. The behavior is expected to be similar to those illustrated in Figures 7-6 through 7-8 of ANP-2788P, Revision 0.
NRC Request RAI-03:
The 20% power EOC case analyzed in Chapter 8 has a power pulse peak of 187% (Table 8-6), which is beyond the 112% high flux,trip point (Table 8-1). Why was this transient analyzed assuming no trip during the first 5s, but instead continued using the system code and terminated using one of the other trip signals?
CR-3 Response:
The core power listed in Table 8-6 of ANP-2788P, Revision 0,. is the core power and is not the indicated power of the excore detectors. The plant trip employs the indicated power from the measured signals of the excore detectors. The trip depends on the excore signal response to the ejected rod event. The excore signal response has two dependencies that are discussed in this response. First, the excore signal depends upon the proximity of the detector to the location of the ejected rod. Second, the maximum excore power signal from the circuitry is 125 percent power. Both of these dependencies can be modeled in NEMO-K. The End Of Cycle (EOC) ejected rod simulation from 20 percent power is shown in Figure RAI-03-1.
As described in Table 8-1 of ANP-2788P, Revision 0, three analyzed signals must be above 112 percent power to trip the plant. In this figure, two of the signals reach the maximum indicated power. The third highest signal reaches approximately 114 percent power which would have tripped the plant.
However, this value is close enough to the trip value of 112 percent, that minor variations in the major variables that control the peak power could result in lower powers and not trip the plant.
For example, if the mean generation time (or inverse average thermal neutron velocity) was 3 percent higher, then the peak power would be approximately 3 percent lower and this plant transient would not have induced a reactor trip. Rather than fine tuning which conditions would not cause the trip, the analysis for the EOC 20 percent power case was conservatively run with no high flux trip.
U. S. Nuclear Regulatory Commission 3F0509-09 Attachment C Page 3 of 4 Figure RAI-03-1 Power and Excore Signals 0.
a-200 180 160 140 120 100 80 60 40 20 0
NI-I NI-2
- NQ-
-NI-4 Power 0
0.05 0.1*
0.15, Time, sec 0.2; 0.25 0.3
U. S. Nuclear Regulatory Commission Attachment C 3F0509-09 Page 4 of 4 NRC Request RAI-04:
Is there an intermediate point between BOC and EOC that will result in input parameters that will yield a more severe transient response than those corresponding to those at each end of the cycle?
CR-3 Response:
The Moderator Temperature Coefficient (MTC) is the only input variable in Table 9-1 of ANP-2788P, Revision 0, that may not change monotonically with burnup.
It could become more positive with cycle burnup if the burnable absorbers burn out faster than the fuel. This is evidenced by an increase of the critical boron concentration with cycle bumup early in the cycle.
A more positive MTC could have less feedback, if it is higher than the value analyzed for the ejected rod accident, and could result in a more severe power transient. This behavior is not typical of the current designs employed. However, future changes in core design could lead to this condition. The current design process does examine the cycle lifetime for maximum MTC, and if the maximum MTC occurs later than Beginning Of Cycle (BOC), the ejected rod checks would be performed at this burnup and compared with the BOC conditions defined in Table 9-1 of ANP-2788P, Revision 0. If not acceptable, the design would be rejected or an analysis would need to be performed with the new limiting conditions as stated in Section 9.0 of ANP-2788P, Revision 0.