L-2013-292, Units I and 2 - Response to Request for Additional Information (RAI) - Application for Technical Specification Change Regarding Moderator Temperature Coefficient (Mtc) Surveillance for Startup Test Activity Reduction (STAR) Program
| ML13289A179 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/04/2013 |
| From: | Jensen J Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2013-292 | |
| Download: ML13289A179 (8) | |
Text
0 October 4, 2013 FPL. L-2013-292 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 Response to Request for Additional Information (RAI) - Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) program References I. FPL Letter L-2013-160 dated May 21, 2013, "Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) program Using the Consolidated Line Item Improvement Process." [Accession Number ML13144A166]
- 2. Email from Siva Lingam, NRC to Ken Frehafer (FPL) dated September 5, 2013 "St.
Lucie Units 1 and 2 License Amendment Request to Modify Technical Specification Regarding Moderator Temperature Coefficient Surveillance for Startup Test Activity Reduction Program (TAC Nos. MF 1888 and MF 1889)"
In Reference 1, Florida Power & Light (FPL) requested to amend Facility Operating License DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2 in order to modify the Technical Specification (TS) requirements for moderator temperature coefficient (MTC) surveillance requirements (SR) associated with implementation of WCAP-1601 1-P-A, "Startup Test Activity Reduction Program."
The NRC Staff provided a request for additional information in Reference 2. FPL's response to the RAT is provided in the enclosure to this letter. The No Significant Hazards evaluation in Reference 1 bounds this RAI Reply.
Please contact Mr. Eric Katzman, Licensing Manager at 772-467-7734 if there are any questions about this submittal.
Florida Power & Light Company B 4 6501 S. Ocean Drive, Jensen Beach, FL 34957
L-2013-292 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on October ] ,2013.
Sincerely, Joseph Jensen Site Vice President St. Lucie Plant
Enclosure:
Response to Request for Additional Information (RAI) - Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) program cc: Ms. Cynthia Becker, Chief- Florida Bureau of Radiation Control
L-2013-292 Enclosure Page 1 of 6 Response to Request for Additional Information (RAI) - Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC)
Surveillance for Startup Test Activity Reduction (STAR) program RAI Reply Page 2 Attachment Page 5 Email from Siva Lingam, NRC to Ken Frehafer (FPL) dated September 5, 2013 "St. Lucie Units 1 and 2 License Amendment Request to Modify Technical Specification Regarding Moderator Temperature Coefficient Surveillance for Startup Test Activity Reduction Program (TAC Nos.
MF1 888 and MF1 889)"
L-2013-292 Enclosure Page 2 of 6 Request for Additional Information (RAI)
By letter dated May 21, 2013 (Agencywide Documents Access and Management Accession No. ML13144A166), Florida Power & Light Company (the licensee) proposed a license amendment request to modify Technical Specifications (TSs) moderator temperature coefficient (MTC) surveillance requirements (SRs) associatedwith implementation of Topical Report WCAP-1601 1-P-A, "Startup Test Activity Reduction (STAR) Program," which describes the methods to be used for implementation of reduction in the startup testing requirements. The changes are consistent with the Nuclear Regulatory Commission (NRC)-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-486, Revision 2 as included in NUREG-1432, Revision 4.0, Standard Technical Specifications -
Combustion Engineering (CE) Plants. In orderto complete its review of the above documents, the NRC staff needs the following additionalinformation:
RAI I The licensee claimed that the proposed changes for St. Lucie Units I and 2 are consistent with the NRC-approved TSTF STS change TSTF-486, Revision 2 such as:
SR 4.1.1.4.2 Verify MTC is within the lower limit specified in the COLR [core operatinglimit report].
Each fuel cycle within 7 EFPD[effective full power days] of reaching 2/3 of expected core burnup.
TSTF-486, Rev. 2, SR 3.1.3.2 in its entirety states, "If the MTC is more negative than the limit specified in the COLR when extrapolatedto the end of cycle, SR 3.1.3.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentrationat which MTC is projected to exceed the lower limit. Verify MTC is within the lower limit specified in the COLR. Each fuel cycle within 7 EFPD of reaching 40 EFPD core burnup AND Each fuel cycle within 7 EFPDof reaching 2/3 of expected core bumup."
Please provide clarificationfor the discrepancyfrom the TSTF-486, Rev. 2, SR 3.1.3.2, why the first part of frequency statement "Eachfuel cycle within 7 EFPDof reaching 40 EFPDcore burnup AND" is not included in the licensee's SR 4.1.1.4.2.
RAI 1 Response Section 3.3 of the license amendment request submitted in L-2013-160 (May 21, 2013),
identifies the difference between the proposed SR 4.1.1.4.2 and the TSTF-486, Rev. 2, SR 3.1.3.2. Specifically, the MTC lower limit verification by extrapolation is not included in the proposed SR 4.1.1.4.2 for the surveillance done within 7 EFPD of reaching 40 EFPD. Lower limit verification is more appropriately performed at the surveillance done
L-2013-292 Enclosure Page 3 of 6 within 7 EFPD of reaching 2/3 of expected core burnup. The verification of lower limit by extrapolation from the surveillance done within 7 EFPD of reaching 40 EFPD, which is early in the cycle, is considered to add no technical value, when the surveillance done within 7 EFPD of reaching 2/3 of expected core burnup will more appropriately verify the lower limit, well in advance of reaching the expected end-of-life core burnup and well in advance of approaching the lower limit.
RAI 2
The proposed TS changes are relating to MTC as specified in the COLR. Please provide the MTC lower limit that will be used for the first cycle this revised TS is effective.
RAI 2 Response The current MTC lower limit specified in the COLR is -32 pcm/OF for both St. Lucie Units, and is not expected to change for the first cycle implementing the revised TS for the respective Unit.
RAI 3
Please provide an evaluation against the conditions and limitations stated in the NRC safety evaluation on WCAP-160 11-P-A, Rev 0, STAR Program.
RAI 3 Response There are three conditions and limitations stated in the NRC safety evaluation on WCAP-1 6011-P-A, Rev 0.
Condition and Limitation 1 The STAR program is applicable only to the participatingplants as defined in Table 3-1 of the TR.
Condition and limitation 1 restricts the use of STAR only to the participating plants. St.
Lucie Units 1 and 2 are in the list of participating plants defined in Table 3-1 of the TR (Reference 1) and thus may implement STAR without further licensing action.
Condition and Limitation 2 Should any of the STAR test results fall outside of the test criteria, either ascertain that the safety analysis and STAR applicability requirements are satisfied, or discontinue use of the STAR program for that fuel cycle.
L-2013-292 Enclosure Page 4 of 6 The STAR program, other than the aspects related to the MTC test, was implemented for St. Lucie Unit 1 beginning with Cycle 21 and for St. Lucie Unit 2 beginning with Cycle 17.
A detailed evaluation has been performed for each of the St. Lucie Units with respect to the STAR applicability requirements to verify compliance to the requirements for Core Design, Fabrication, Refueling, Startup Testing and CEA Lifetime. Based on these evaluations, checklists have been generated to verify compliance to these requirements for each cycle to continue the use of STAR program for that cycle. Compliance to the checklists and STAR tests acceptance criteria are covered in the plant procedures. If any of the checklist items or STAR test results fall outside of the acceptance criteria, STAR program for that cycle will be discontinued or an evaluation will be performed to demonstrate compliance to the safety analysis and STAR applicability requirements for that cycle.
Condition and Limitation 3 The Staff requires each licensee using STAR to submit a summary report following the first application, either successful or not, of STAR to its plant. The report should (a) identify the core design method used, (b) compare the measured and calculated values and the differences between these values to the corresponding core design method uncertainties and (c) show compliance with the STAR applicabilityrequirements. If the application of STAR is unsuccessful, identify the reasons why the STAR applicationfailed.
As stated above, the STAR program, other than the aspects related to the MTC test, was implemented for St. Lucie Unit 1 beginning with Cycle 21 and for St. Lucie Unit 2 beginning with Cycle 17. The initial application of STAR for these cycles was successful and a summary report was provided to the NRC in L-2007-121 (Reference 2) for St. Lucie Unit 1 and in L-2008-052 (Reference 3) for St. Lucie Unit 2. The report for each of the St. Lucie Units included a) the identification of core design method used, b) a comparison of the measured and calculated values along with the differences between these values and the applicable core design method uncertainties and c) tables showing compliance to each of the STAR applicability requirements.
References
- 1. Westinghouse Topical WCAP-16011-P-A, Rev. 0, "Startup Test Activity Reduction Program," February 2005.
- 2. Letter L-2007-121, G. Johnston (FPL) to USNRC Document Control Desk, "St. Lucie Unit 1 Docket No. 50-335 Cycle 21 Startup Report, August 9, 2007
- 3. Letter L-2008-052, G. Johnston (FPL) to USNRC Document Control Desk, "St. Lucie Unit 2 Docket No. 50-389 Cycle 17 Startup Report, March 26, 2008
L-2013-292 Enclosure Page 5 of 6 Frehafer, Ken From: Lingam, Siva <Siva.Lingam@nrc.gov>
Sent: Thursday, September 05, 2013 4:09 PM To: Frehafer, Ken Cc: Broaddus, Doug; Jackson, Christopher, Elliott, Robert; Huang, Tai; Grover, Ravinder
Subject:
St. Lucie Units 1 and 2 License Amendment Request to Modify Technical Specification Regarding Moderator Temperature Coefficient Surveillance for Startup Test Activity Reduction Program (TAC Nos. MF1888 and MF1889)
Please note the following ofcal request for additional information on the subject matter, and provide your responses within 30 days from this date.
By letter dated May 21, 2013 (Agencywide Documents Access and Management Accession No. ML13144A166), Florida Power & Light Company (the licensee) proposed a license amendment request to modify Technical Specifications (TSs) moderator temperature coefficient (MTC) surveillance requirements (SRs) associated with implementation of Topical Report WCAP-16011-P-A, "Startup Test Activity Reduction (STAR) Program," which describes the methods to be used for implementation of reduction in the startup testing requirements. The changes are consistent with the Nuclear Regulatory Commission (NRC)-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-486, Revision 2 as included in NUREG-1432, Revision 4.0, Standard Technical Specifications -Combustion Engineering (CE) Plants. In order to complete its review of the above documents, the NRC staff needs the following additional information:
- 1. The licensee claimed that the proposed changes for St. Lucie Units 1 and 2 are consistent with the NRC-approved TSTF STS change TSTF-486, Revision 2 such as:
SR 4.1.1.4.2 Verify MTC is within the lower limit specified inthe COLR [core operating limit report].
Each fuel cycle within 7 EFPD [effective full power days] of reaching 2/3 of expected core burnup.
TSTF-486, Rev. 2, SR 3.1.3.2 in its entirety states, "Ifthe MTC is more negative than the limit specified inthe COLR when extrapolated to the end of cycle, SR 3.1.3.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit. Verify MTC is within the lower limit specified inthe COLR. Each fuel cycle within 7 EFPD of reaching 40 EFPD core burnup AND Each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup."
Please provide clarification for the discrepancy from the TSTF-486, Rev. 2, SR 3.1.3.2, why the first part of frequency statement "Each fuel cycle within 7 EFPD of reaching 40 EFPD core burnup AND" is not included in the licensee's SR 4.1.1.4.2.
- 2. The proposed TS changes are relating to MTC as specified inthe COLR. Please provide the MTC lower limit that will be used for the first cycle this revised TS is effective.
- 3. Please provide an evaluation against the conditions and limitations stated inthe NRC safety evaluation on WCAP-1 6011-P-A, Rev 0, STAR Program.
Siva P. Lingam U.S. Nuclear Regulatory Commission Project Manager (NRR/DORRL/LPL2-2)
L-2013-292 Enclosure Page 6 of 6 Sequoyah Nuclear Plant St. Lucie Plant Robinson Steam Electric Plant Location: 08-D5; Mail Stop: 08-G9a Telephone: 301-415-1564; Fax: 301-415-1222 E-mail address: siva.lineam(,nrc.eov 2