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TAC:MC8096, Revise Topical Report References in ITS 5.6.5, Colr (Approved, Closed) |
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Category:Letter type:LIC
MONTHYEARLIC-24-0007, License Amendment Request (LAR) to Revise License Termination Plan (LTP)2024-06-18018 June 2024 License Amendment Request (LAR) to Revise License Termination Plan (LTP) LIC-24-0008, Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (Dqap), Unit No. 1 and ISFSI2024-05-16016 May 2024 Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (Dqap), Unit No. 1 and ISFSI LIC-24-0003, Independent Spent Fuel Storage Installation - Radiological Effluent Release Report and Radiological Environmental Operating Report2024-04-25025 April 2024 Independent Spent Fuel Storage Installation - Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-24-0006, (Fcs), Unit 1, Independent Spent Fuel Storage Installation, Phase 1 Final Status Survey Report to Support Approved License Termination Plan2024-04-17017 April 2024 (Fcs), Unit 1, Independent Spent Fuel Storage Installation, Phase 1 Final Status Survey Report to Support Approved License Termination Plan LIC-24-0005, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2024-03-0101 March 2024 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-24-0002, Independent Spent Fuel Storage Installation - 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Review of License Termination Plan Requirements - Request for Additional Information2022-06-15015 June 2022 Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information LIC-22-0005, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2022-04-20020 April 2022 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-22-0009, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2022-03-30030 March 2022 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-22-0006, Reactor Head Disposition Project Overview2022-03-17017 March 2022 Reactor Head Disposition Project Overview LIC-22-0004, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2022-02-17017 February 2022 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-21-0008, Organizational and Management Change2021-10-28028 October 2021 Organizational and Management Change LIC-21-0007, ISFSI Only Emergency Plan Update2021-09-0808 September 2021 ISFSI Only Emergency Plan Update LIC-21-0004, Radiological Effluent Release Report and Radiological Environmental Operating Report2021-04-29029 April 2021 Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-21-0003, Independent Spent Fuel Storage Installation - 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Submittal of Revision 7 to Physical Security Plan2020-02-27027 February 2020 Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan LIC-20-0001, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-02-0606 February 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0025, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-12-19019 December 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0007, Post-Shutdown Decommissioning Activities Report2019-12-16016 December 2019 Post-Shutdown Decommissioning Activities Report LIC-19-0021, Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme2019-11-20020 November 2019 Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme LIC-19-0022, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-11-18018 November 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0018, Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2019-11-14014 November 2019 Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-19-0020, Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis2019-10-17017 October 2019 Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis LIC-19-0017, Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 20042019-08-0808 August 2019 Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 An LIC-19-0010, License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associa2019-05-20020 May 2019 License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated LIC-19-0008, Submittal of 2018 Annual Report2019-04-0404 April 2019 Submittal of 2018 Annual Report LIC-19-0004, Independent Spent Fuel Storage Installation - 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Transmittal of Emergency Plan Update2018-12-17017 December 2018 Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update LIC-18-0030, Request for Partial Site Release Phase 22018-11-12012 November 2018 Request for Partial Site Release Phase 2 LIC-18-0028, Letter of Intent to Submit Request for Additional Partial Site Release2018-10-18018 October 2018 Letter of Intent to Submit Request for Additional Partial Site Release 2024-06-18
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Omaha Public Power Di;tnct 444 South 16th street Mall Omaha NE 68102-2247 April 1.2, 2006 LIC-06-0032 U. S. Nuclear Regulatory Commission Attn: I)ocument Control Desk Washington, DC 20555-0001
Reference:
- 1. Docket No. 50-285
- 2. Letter from Ross Ridenoure (OPPD) to Document Control Desk (NRC) dated August 11, 2005, Fort Calhoun Station Unit No. 1 - License Amendment Request to Support Use of M5 Fuel Cladding, and 10 CFR 50.46 and 10 CFR Appendix K Exemption Request (LIC-05-0089)
(ML052240083)
- 3. Letter from Ross Ridenoure (OPPD) to Document Control Desk (NRC) dated November 8, 2005, Fort Calhoun Station Unit No. I - Revised License Amendment Request to Support Use of M5TM Fuel Cladding (LIC-05-0127) (ML053120421)
- 4. Letter from Alan Wang (NRC) to Ross Ridenoure (OPPD) dated March 2, 2006, "Fort Calhoun Station, Unit 1 - Request for Additional Information Related to the Use of M5 Fuel Cladding (TAC No. MC8096)" (NRC 0032) (ML060550294)
- 5. EMF-2103(P)(A), "Realistic Large Break LOCA Methodology,"
Framatome ANP, Inc.
SUBJECT:
Response to Request for Additional Information Related to the Use of M5 Fuel Cladding References 2 and 3 provided the Omaha Public Power District's request for a license amendment to permit the use of AREVA (Framatome ANP) M5Tm advanced alloy for fuel rod cladding and structural components such as guide tubes, intermediate spacer grids, end plugs and guide thimble tubes, beginning with Cycle 24. In Reference 4, the NRC requested additional information regarding Reference 3. Attachment 1 provides the response to the request of Reference 4.
In the answer to NRC Request #2 of Attachment 1, proprietary information has been withheld as indicated by empty brackets. This information is available in Reference 5.
I declare under penalty of perjury that the foregoing is true and correct. (Executed on April 12, 2006.)
5RO I Employment wvith Equal Opportunity 4171
U.S. Nuclear Regulatory Commission LIC-06-0032 Page 2 If you have additional questions, or require further information, please contact Thomas R. Byrne at (402) 533-7368.
Sincerely, Harry J. haber Division Manager Nuclear Engineering HJF/TRB/trb Attachment 1 - Response to Request for Additional Information Related to the Use of M5 Fuel Cladding
LIC-06-.0032 Page 1 ATTACHMENT 1 Response to Request for Additional Information Related to the Use of M5 Fuel Cladding
LIC-06-0032 Page 2 Response to Request for Additional Information Related to the Use of M5 Fuel Cladding NRC Request #1 To demonstrate compliance with 10 CFR 50.46 criteria, complete the tables below by providing the comparison results obtained using the base evaluation model methods with Zircaloy-4 cladding and the results obtained for an identical case using the M5 swelling and rupture mcdel.
Specifically, provide the LBLOCA and SBLOCA analysis results for calculated peak clad temperature (PCT), maximum local oxidation, and whole core hydrogen generation for both the M5 cladding (Mark-B-HTP fuel design) and the co-resident Zircaloy cladding. Also, state whether coolable geometry and long term cooling are demonstrated.
OPPD Response:
This question was discussed with the NRC in a telephone call on March 29, 2006. It was agreed that a summary of the large break LOCA (LBLOCA) results as presented below would be a sufficient response.
The results of the analysis of a large break loss of coolant accident for the Fort Calhoun Station Unit No. 1 (FCS) Cycle 24 reload using fuel assemblies with M5 cladding is presented in the report BAW-2502, "Fort Calhoun Station Realistic Large Break LOCA Summary Report." This report was provided to the NRC in Reference 1.
A summary of the results of the LBLOCA evaluation is presented below for each of the five criteria in 10 CFR 50.46:
Peak Cladding Temperature, 'F 1675 Maximum Local Oxidation, % 0.82 Total Oxidation (whole core hydrogen) % 0.02 Coolable geometry Confirmed Long Term Cooling Confirmed The LBLOCA results are for the fresh fuel in the core and are conservative relative to the once-burned and beyond fuel. The LBLOCA results are more limiting (higher PCT) than the small break LOCA (SBLOCA) results.
A comparison of the results for Zircaloy-4 and M5 cladding is provided in the table below. This data is obtained from topical report EMF-2103PA for LBLOCA and from BAW-10240PA for SBLOC'A. Similar results would be expected for FCS on a relative basis.
LIC-06 0032 Attachraent 1 Page 3 Differences LBLOCA SBLOCA Peak Cladding Temperature <10T <10T Maximum Local Oxidation <0.1% <0.3%
Total Oxidation (whole core hydrogen) <0.1% <0.1%
NRC Request #2 Does the LOCA Evaluation Model used consider both the pre-LOCA and LOCA oxidation in demonstrating compliance with 10 CFR 50.46 requirements? If not, provide justification why it does not.
OPPD Response:
The manner in which the Realistic Large Break LOCA evaluation model considers the initial cladding oxidation is described in the response to Question 28d in the NRC approved topical report EMF-2103(P)(A), "Realistic Large Break LOCA Methodology," Framatome ANP, Inc.
The question and response in the NRC approved topical report are repeated below:
Question 28d: In the time-in-life study, what inside and outside initial oxidation thickness were used for the BOL analysis. What oxide thickness is used for once and twice burned fuel?
Response 28d: The NRC reviewed and approved RODEX3A code is used to calculate an exposure dependent oxidation thickness that is transferred to S-RELAP5. S-RELAP5 uses this informationfor calculating cladding thermal conductivity which affects the initialstored energy results. However, a zero oxidation thickness is assumed to initialize the metal-water reaction rate calculation. Framatome ANP experience with regard to oxidation calculations has been that the oxidation calculatedfor a zero initial oxide thickness provides the largest oxidation thickness increase during the transient simulation. The results shown for maximum local and core-wide oxidation are those computedfor the high temperature mnetal-water reaction. This is the same approachtaken for FramnatomeANP Appendix K methodologies.
The response to this question was initiallyprovided in response to an RAI on the topical report EMF-2328PA, PWR Small Break LOCA Evaluation Model, S-RELAP5 Based. The response provided and accepted by the NRC is shown below followed by some additionalcomments.
"The Framatome ANP methodology described in EMF-2328(P), PWR Small Break LOCA Evaluation Model, S-RELAP5 Based, results in a conservative calculation of peak local oxidation for comparison to the 17% oxidation criteria of 10 CFR 50.46. The methodology assume.; that the pre-accident cladding oxidation is zero in order to maximize the rate and extent
LIC-06 0032 Attachrient 1 Page 4 of oxidation during a LOCA. This assumption results in higherpeak cladding temperatures and higherpeak local oxidation than assuming a non-zero pre-accidentoxidation value.
Cladding oxidationfrom two sources is considered: (1) pre-accident or pre-transientoxidation due to corrosion at operating conditions, and (2) transient oxidation which occurs at high temperature during the LOCA. Pre-transient oxidation is determined by a fuel performance calculaiion and is afunction of burnup. Over the burnup range that the fuel rod is at high power and can approach technical specification peaking limits, the pre-transientoxidation is small, however at high burnups,pre-transientoxidation can become significant.
Transient oxidation is calculated as part of the LOCA analyses. By nrle, this oxidation must be computed using the Baker-Just reaction rate equation. Using this equation, the calculated reaction rate decreases in directproportionto the increasein thickness of the layer oxidized and increases exponentially with absolute temperature. Therefore, the transient oxidation is maximized by minimizing the initial oxidation layer which yields the highest reaction rate. The increasedreaction rate produces higher temperatures which fiurther increases the reaction rate, thus compounding the effect.
The reason that the assumption of zero pre-accident oxidation value results in a conservative calculation of peak cladding temperature and total peak local oxidation is that Framatome's calculations show that a non-zero pre-accident oxidation assumption reduces the transient oxidation by an amount greater than the pre-accident oxidation. Therefore, the maximum oxidation; i.e., the sum of both pre-transient and transient oxidation is greatest when zero pre-transient oxidation is assumed. These results apply for conditions where the transient oxidation is the dominant contributor to the total oxidation, which is the case for calculated PCTs ik excess of 20007F and for burnups at which peaking can approach the technical specification limits. These are the most limiting casesfor both LBLOCA and SBLOCA.
Framatome also recognizes that conditions exist where the total oxidation is dominated by the pre-transient oxidation. This situation occurs when lower PCTs are calculated and at High burnups. For cases with low PCTs, the pre-accident oxidation becomes dominant because the transient oxidation is substantially reduced or effectively eliminated due to the low absolute temperature. For high burnups, the transientoxidation is reduced or effectively eliminated due to the inherent low power and associated low transient temperatures,and is further reduced by the presence of a significant initial oxide layer. For these cases, the maximum total oxidation is essentially equal to the initialpre-accident oxidation value. This oxidation value can exceed the value calculated using a zero initialpre-accident oxidation for these conditions; however, the total oxidation is precludedfrom approachingor exceeding the 17% value by the design limit on pre-acc.'dent oxidation. Framatomehas a design limit on pre-transientoxidation of I J microns defined on a 95/95 basis that cannot be exceeded. This limit corresponds to [ J of the thin.test cladding currently used by Framatome.
The above response is also applicable to the Realistic Large Break LOCA evaluation model. The key concept is that the metal water reaction rate models, Baker-Just and Cathcart-Pawel, are highly oxidation level dependent. If the transient starts with an oxidation level, the subsequent
LIC-06-0032 Page 5 oxidation formation is significantly reduced; the larger the initial level, the more the formation of additional oxidation during the transient is reduced. The reduction of the oxidation formation during the transient then leads to a reduction in the cladding temperature since a heat source, oxidation formation, is reduced.
Reference
- 1. Letter from Ross Ridenoure (OPPD) to Document Control Desk (NRC) dated September 30, 2005, Fort Calhoun Station Unit No. 1 - License Amendment Request to Support Use Df AREVA Realistic Large Break Loss of Coolant Accident Methodology (LIC-05-0].06)
(ML052770174 and ML052770176)