ML091310384

Clarification of Response to Request for Additional Information Regarding License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 0.422-Inch 14x14 Vantage+ Fuel

ML091310384
Person / Time
Site:	Prairie Island
Issue date:	05/04/2009
From:	Wadley M D Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML091310392	List: L-PI-09-066, 422V+Fuel Transition Project RAI Response-EMCB RAI-1(a) ML091310384
References
L-PI-09-066, TAC MD9142, TAC MD9143
Download: ML091310384 (5)

Text

WITHHOLD FROM PUBLIC DISCLOSURE PER 10 CFR 2.390 L-PI-09-066 10 CFR 50.90 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Clarification of Response To Request For Additional lnformation Regardinq License Amendment Request For Technical Specifications Changes To Allow Use Of Westinghouse 0.422-Inch 14x14 Vantage+ Fuel (TAC Nos.

MD9142 and MD9143)

References:

1) Letter from M. Wadley (Nuclear Management Company) to Document Control Desk (NRC), L-PI-08-047, License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 0.422-inch OD 14x14 VANTAGE+

Fuel, dated June 26,2008 (ADAMS Accession No. ML081820137) 2) Letter from T. Wengert (NRC) to M. Wadley (Northern States Power Company - Minnesota), Prairie Island Nuclear Generating Plant, Units 1 and 2 Request For Additional lnformation Related to License Amendment Request For Technical Specifications Changes to Allow Use of Westinghouse 0.422-Inch OD 14x14 Vantage+ Fuel (TAC Nos. MD9142 and MD9143), dated February I I, 2009 (ADAMS Accession No. ML0901403,34)

3) ~etter from M. Wadley (Northern States Power Company - Minnesota) to Document Control Desk (NRC), L-PI-09-034, Response To Request For Additional lnformation Regarding License Amendment Request For Technical Specifications Changes To Allow Use Of Westinghouse 0.422-Inch 14x14 Vantage+ Fuel (TAC Nos.

MD9142 and MD9143), dated March 12,2009 (ADAMS Accession No. ML090721087)

When separated from Enclosure 3, this letter may be made publicly available. 171 7 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1 121 Document Control Desk Page 2 By letter dated June 26,2008 (Reference I), Nuclear Management Company, LLC, (now Northern States Power Company, a Minnesota corporation (NSPM)) requested approval of amendments to the Operating Licenses and associated Technical Specifications (TS) for Prairie Island Nuclear Generating Plant (PINGP or "Prairie Island"), Units 1 and 2, as well as certain supporting analyses, in support of the transition from Westinghouse 0.400-inch outside diameter (OD) VANTAGE+ (hereinafter referred to as 400V+) fuel to 0.422-inch OD VANTAGE+ (hereafter referred to as 422V+) fuel. On February I I, 2009, the NRC staff notified NSPM (Reference 2) that additional information was necessary for the staff to complete its review. NSPM responded on March 12, 2009 (Reference 3);

however, the response regarding the specific section, subsection, and edition of the American Society of Mechanical Engineers (ASME) code utilized to evaluate cladding stress and strain requires further amplification. This additional information is held proprietary by Westinghouse Electric Company, LLC (Westinghouse), as supported by an affidavit signed by Westinghouse, the owner of the information (Enclosure 2). Accordingly, it is requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosure 1 provides a non-proprietary version of the clarified response while Enclosure 3 provides the proprietary response to be withheld. The supplemental information provided in this letter does not impact the conclusions of the Determination of No Significant Hazards Consideration and Environmental Assessment presented in the June 26, 2008 submittal as supplemented by letters dated August 4,2008, August 26,2008, November 14,2008, January 30,2009, February 9,2009, February 20, 2009 and March 12,2009. In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this License Amendment Request supplement by transmitting a copy of this letter and non- proprietary enclosures to the designated State Official.

Summarv of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 4 2089 Michael D. Wadley Site Vice-President Prairie Island Nuclear Generating Plant Northern States Power Company-Minnesota Document Control Desk Page 3 Enclosures (3)

cc: Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota (Enclosures 1 and 2 only)

ENCLOSURE 1 Non-Proprietary Revised Response to Request for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel Page 1 of 2 By letter dated June 26, 2008 (ADAMS Accession No. ML081820137), Nuclear Management Company, LLC, (now Northern St ates Power Company, a Minnesota corporation (NSPM)) requested approval of amendments to t he Operating Licenses and associated Technical Specific ations (TS) for Prairie Island Nuclear Generating Plant (PINGP or "Prairie Island"), Units 1 and 2, as well as certain supporting analyses, in support of the transition from Westi nghouse 0.400-inch outsi de diameter (OD) VANTAGE+ (hereinafter referred to as 400V+) fuel to 0.422-inch OD VANTAGE+ (hereafter referred to as 422V+) fuel.

On February 11, 2009 (ADAMS Accession No.

ML090140334

), the NRC staff notified NSPM that additional information was necessary for the staff to complete its review.

NSPM responded on March 12, 2009 M090721087); however, the response regarding the specific section, subsection, and edition of the American Society of Mechanical Engineers (ASME) code utilized to evaluate cladding stress and strain requires further amplification. The NRC request for additional information (RAI) is repeated below with the NSPM response following:

Mechanical and Civil Engineering Branch (EMCB) RAIs EMCB RAI-1:

(a) Section 2.4, Cladding Stress and Strain, first bullet, page 2-6 of Reference 1 mentions that the stress limit is based on the American Society of Mechanical Engineers (ASME) code. Provide the sp ecific section, subsect ion, and edition of the ASME code utilized. NSPM Supplemental Response:

EMCB RAI-1 requested the specific secti on, subsection and edition of the ASME code utilized for Section 2.4 of the Prairie Island Units 1&2 422V+ Fuel Transition Licensing Report, Cladding Stress and Strain. NSPM responded that ASME Boiler and Pressure Vessel Code, Section VIII: Pressure Vessels , Division 2: Rules for Construction of Pressure Vessels - Alternate Rules, Append ix 4: Mandatory Design Based on Stress Analysis, (2001 version) was used as this was the reference cited in the corresponding Westinghouse calculation note. However, upon further review, it was determined that the licensing documentation issued at that ti me presented a different section of the ASME code as discussed below.

In December 2002, Westinghouse issued Addendum 1 to WCAP-10125, Extended Burnup Evaluation of Westinghouse Fuel, to the NRC for review and approval. The purpose of the submittal was to update certain fuel licensing criteria that are applied to Westinghouse fuel. The update promoted convergence with the practices of all other Westinghouse business segments and consisten cy with current industry guidelines. In this Addendum, it was specifically noted that the Fuel Claddi ng Transient Stress parameter criterion was being changed from "the transient stress will be less than the

[ ]a,c" to "Cladding stresses will be consistent with ASME Code Section III requirements." In this addendum it is specifically stat ed that the maximum cladding stress will be evaluated using ASME Pressure Vessel Code,Section III, ENCLOSURE 1 Non-Proprietary Responses to Requ ests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel Page 2 of 2 Article NG-3000, 1998. In the Safety Evaluation issued by the NRC dated April 14, 2003 (see Reference A), it states the following.

"SRP Section 4.2 indicates that stress lim its are acceptable if they are obtained using methods based on the ASME Code,Section III criteria.Section III describes various stress state criteria and limits, and is widely accepted in the nuclear industry. The Westinghouse proposal for a fuel rod cladding stress limit based on the ASME Code,Section III is co nsistent with the SRP Section 4.2 recommendations. Based on the use of the acceptable ASME Code,Section III methods, the staff approves the Westinghouse proposal to revise the fuel cladding stress limit."

A review of the Westinghouse calculation note which documents the fuel cladding stresses indicates that the approach used is consistent with both the ASME Section VIII, Division 2, Appendix 4 and ASME Code, Secti on III criteria. Based on the above, the appropriate reference for the response to EMCB RAI-1 should have been ASME Code,Section III, Article NG-3000, 1998. The Westinghouse calculation note will be revised to reference ASME Code Section III, Article NG-3000, consistent with the US NRC approved licensing ba sis documentation.

Reference A: WCAP-10125-P-A, Addendum 1-A, Revision 0, Addendum 1 to WCAP-10125-P-A Revisions to Design Criteria , Approved May 2003.