Information Notice 2011-21, Realistic Emergency Core Cooling System Evaluation Model Effects Resulting from Nuclear Fuel Thermal Conductivity Degradation

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Realistic Emergency Core Cooling System Evaluation Model Effects Resulting from Nuclear Fuel Thermal Conductivity Degradation
ML113430785
Person / Time
Issue date: 12/13/2011
From: Laura Dudes, Mcginty T
Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking
To:
alexion T W, NRR/DPR 415-1326
References
TAC ME7686 IN-11-021
Download: ML113430785 (6)


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

OFFICE OF NEW REACTORS

WASHINGTON, DC 20555-0001 December 13, 2011 NRC INFORMATION NOTICE 2011-21: REALISTIC EMERGENCY CORE COOLING

SYSTEM EVALUATION MODEL EFFECTS

RESULTING FROM NUCLEAR FUEL THERMAL

CONDUCTIVITY DEGRADATION

ADDRESSEES

All holders of an operating license or construction permit for a nuclear power reactor under

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of

Production and Utilization Facilities, except those who have permanently ceased operations

and have certified that fuel has been permanently removed from the reactor vessel.

All holders of or applicants for an early site permit, standard design certification, standard

design approval, manufacturing license, or combined license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to notify

addressees of recent information obtained concerning the impact of irradiation on fuel thermal

conductivity, and its potential to cause errors (specifically, higher predicted peak clad

temperature results) in realistic emergency core cooling system (ECCS) evaluation models.

[This IN uses the term error consistent with applicable NRC regulations described below

regarding the effect of any change to or error in an acceptable evaluation model. The

modeling error in this IN was discovered as a result of research that provided new data and

greater understanding of the phenomenon and as such, the word error in this IN is not intended

to convey culpability.] The NRC expects the recipients to review the information within this IN

for applicability to their facilities and consider actions, as appropriate, for their facility. However, suggestions contained in this IN are not NRC requirements; therefore, no specific action or

written response is required.

DESCRIPTION OF CIRCUMSTANCES

An NRC licensee recently sponsored an analysis to determine the effect that accounting for fuel

thermal conductivity degradation due to irradiation would have on the results of a realistic

emergency core cooling evaluation that it was proposing to implement. The analysis

determined that the effect would be significant in that the predicted peak fuel cladding

temperature from the most severe postulated loss-of-coolant accident would increase by more

than 50 degrees Fahrenheit (°F).

The licensee asked for this analysis during the NRC staffs review of its request to implement

the ASTRUM realistic Westinghouse Electric Company (WEC) ECCS evaluation model. The

licensees analysis addressed issues discussed in IN 2009-23, Nuclear Fuel Thermal

Conductivity Degradation, dated October 8, 2009. As discussed in IN 2009-23, currently

approved fuel performance codes that provide input to realistic ECCS models may not account

for fuel thermal conductivity degradation.

Because the licensee currently uses an evaluation model that treats fuel thermal conductivity

degradation differently than does the evaluation model that it is proposing to use, there is no

immediate safety concern for this licensee. Also, because the results of the licensees analysis

do not cause its proposed results to exceed the acceptance criteria at 10 CFR 50.46(b), the

NRCs review of the licensees request is not affected.

BACKGROUND

IN 2009-23 describes how legacy fuel performance codes may overpredict fuel rod thermal

conductivity at higher burn-ups based on new experimental data.

Since the NRCs issuance of IN 2009-23, the vendors of fuel performance analysis codes, and

the downstream safety analyses that rely on their results, have engaged with the NRC through

numerous public meetings and written correspondence. The vendors have adjusted legacy

codes so that the codes correlate better with more recent fuel performance data. The vendors, and the NRC licensees that use these vendors analytic methods, have been working to quantify

the impact of the issue identified in IN 2009-23 on downstream safety analyses.

The operating experience described above indicates that the realistic emergency core cooling

evaluation models developed by WEC, which rely on the Fuel Rod Performance and Design

(PAD) Code for fuel thermal mechanical performance data, are susceptible to errors of similar

magnitude to the plant-specific results described above. As described by 10 CFR 50.46(a)(3)(i),

these errors may be significant. Note that the analytic treatment of fuel burnup differs among

the realistic ECCS evaluation models, and the impact described in this IN pertains to results

obtained using the ASTRUM model.

DISCUSSION

Based on the conclusions reached by this licensees analyses, the NRC believes that correcting

for the effect of this error could cause a number of plant-specific ECCS evaluations to predict

significantly higher peak cladding temperatures that exceed the 10 CFR 50.46(b)(1) acceptance

criterion.

WEC has indicated that the approved evaluation models contain substantial conservatisms that

would more than compensate for this issue, and that as a result, there is no issue of immediate

safety concern. The NRC is currently verifying WECs claims that the evaluation model conservatisms compensate for the ECCS evaluation model error caused by fuel thermal

conductivity degradation.

WEC has stated that the impact of modeling thermal conductivity degradation needs to be

considered in the realistic evaluation model methodology because research has provided new

data and greater understanding of the phenomenon. According to the vendor, explicit

incorporation of thermal conductivity degradation modeling would represent an enhancement to

analytic capabilities and not correction of an error. The NRC staff does not agree with WECs

characterization.

Applicable Regulatory Requirements

In 10 CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light-Water

Nuclear Power Reactors, the NRC provides the requirements for ECCSs and their evaluations;

specifically, 10 CFR 50.46(a)(1)(i) requires the following of realistic ECCS models:

Each boiling or pressurized light-water nuclear power reactor must be provided with

an emergency core cooling system (ECCS) that must be designed so that its calculated

cooling performance following postulated loss-of-coolant accidents conforms to the

criteria set forth in paragraph (b) of this section. ECCS cooling performance must be

calculated in accordance with an acceptable evaluation model

According to 10 CFR 50.46(a)(1)(i), an acceptable evaluation model has the following

characteristics:

the analytical technique realistically describes the behavior of the reactor system

during a loss-of-coolant accident

when the calculated ECCS cooling performance is compared to the criteria set forth in

paragraph (b) of this section, there is a high level of probability that the criteria would not

be exceeded.

According to 10 CFR 50.46(b)(1), the calculated maximum fuel element cladding temperature

shall not exceed 2,200 °F.

Under 10 CFR 50.46(a)(3)(i), the NRC requires licensees to estimate the effect of any change to

or error in an acceptable evaluation model or in the application of such a model to determine

whether the change or error is significant. For the purposes of 10 CFR 50.46, a significant

change or error is one that results in a calculated peak fuel cladding temperature different by

more than 50 °F from the temperature calculated for the limiting transient using the last

acceptable model, or that is a cumulation of changes and errors such that the sum of the

absolute magnitudes of the respective temperature changes is greater than 50 °F. Finally, 10 CFR 50.46(a)(3)(ii) promulgates requirements for reporting estimated changes to or

errors in ECCS evaluation models, or applications thereof, to the Commission, stating the

following:

If the change or error is significant, the applicant or licensee shall provide this report

within 30 days and include with the report a proposed schedule for providing a

reanalysis or taking other action as may be needed to show compliance with §50.46 requirements

Any change or error correction that results in a calculated ECCS performance that does

not conform to the criteria set forth in paragraph (b) of this section is a reportable event

as described in §§ 50.55(e), 50.72, and 50.73. The affected licensee shall propose

immediate steps to demonstrate compliance or bring plant design or operation into

compliance with § 50.46 requirements.

GENERIC IMPLICATIONS

The NRC has initiated conversations with WEC to address the generic implications of this

information. Specifically, these discussions involve other susceptible plants and licensee

requirements as provided in 10 CFR 50.46. The NRC will continue considering the safety and

regulatory aspects of the information.

CONCLUSION

A potentially significant, as described in 10 CFR 50.46(a)(3)(i), ECCS evaluation model error

has been identified. Licensees using WEC realistic ECCS evaluation models may wish to

contact the vendor for assistance in estimating the effect this error may have on plant-specific

ECCS evaluation results.

CONTACT

This IN requires no specific action or written response. Please direct any questions about this

matter to the technical contacts listed below or to the appropriate project managers in the Office

of Nuclear Reactor Regulation or Office of New Reactors.

/RA/ /RA/

Timothy J. McGinty, Director Laura A. Dudes, Director

Division of Policy and Rulemaking Division of Construction Inspection

Office of Nuclear Reactor Regulation and Operational Programs

Office of New Reactors

Technical Contacts: Benjamin Parks, NRR

301-415-6472 E-mail: Benjamin.Parks@nrc.gov

Yi-Hsiung Hsii, NRO

301-415-2877 E-mail: Yi-Hsiung.Hsii@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under NRC Library.

ML113430785 *via e-mail **via phone TAC No. ME7686 OFFICE NRR/DSS/SRXB Tech Editor BC:NRR/DSS/SRXB BC:NRR/DSS/SNPB D:NRR/DSS

NAME BParks* JDougherty* AUlses* AMendiola WRuland*

DATE 12/12/11 12/12/11 12/12/11 12/12/11 12/13/11 OFFICE D:NRO/DSA D:RES/DSA LA:PGCB:NRR PM:PGCB:NRR BC:PGCB:NRR

NAME CAder** KGibson CHawes TAlexion SRosenberg

DATE 12/13/11 12/12/11 12/13/11 12/13/11 12/13/11 OFFICE D:DCIP:NRO D:DPR:NRR

NAME LDudes TMcGinty

OFFICE 12/13/11 12/13/11