ML11123A047

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April 21, 2011, Summary of Public Meeting with Progress Energy on Their Final Pre-Application for Extended Power Uprate
ML11123A047
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 05/12/2011
From: Siva Lingam
Plant Licensing Branch II
To:
Lingam S
References
TAC ME3949
Download: ML11123A047 (8)


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LICENSEE:

Progress Energy, representing Florida Power Corporation FACILITY:

Crystal River Unit 3 Nuclear Generating Plant

SUBJECT:

SUMMARY

OF APRIL 21,2011, EXTENDED POWER UPRATE FINAL PREAPPUCATION MEETING WITH PROGRESS ENERGY (TAC NO. ME3949)

On April 21, 2011, a Category 1 public meeting was held among representatives of Progress Energy, representing Florida Power Corporation (the licensee), the licensee's contractor, AREVA NP, and the Nuclear Regulatory Commission (NRC) staff. This was a final preapplication meeting the purpose of which was to discuss the licensee's plans for an extended power uprate (EPU) and to highlight changes since previous meetings at Crystal River Unit 3 Nuclear Generating Plant. Enclosure 1 contains a list of attendees. The licensee presented slides that may be accessed from NRC's Agencywide Documents Access and Management System through Accession No. ML11123A042.

The highlights of the discussion are noted below:

Boric acid concentration.

Current licensing basis peak cladding temperature (PCT) versus EPU PCT.

Inquiry about fuel.

New battery power monitoring.

Schedule for license amendment approval. contains the meeting discussion, which elaborates on the above items of discussion.

The NRC staff stated that they will be available to discuss or resolve boric acid precipitation issues prior to submitting the EPU application.

No commitments or regulatory decisions were made by the NRC staff during the meeting.

- 2 Members of the public were in attendance and no Public Meeting Feedback forms were received.

Please direct any inquiries to me at 301-415-1564 or by email to siva.lingam@nrc.gov.

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Siva P. Lingam, Project Manager Plant Licensing Branch 2-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosures:

1. List of Attendees
2. Meeting Discussion cc w/encls: Distribution via Listserv

List of Attendees U. S. Nuclear Regulatory Commission (NRC}

Final Preapplication Public Meeting with Progress Energy Regarding Crystal River Unit 3 Extended Power Uprate April 21. 2011 NRC Tom Alexion Kristy Bucholtz (by phone)

Evan Davidson Daniel Doyle Kevin Heller William Jessup Brian Lee Peter Lien Siva P. Lingam Matthew Panicker Ben Parks Farideh Saba Prem Sahay Rich Stattel Travis Tate Leonard Ward Exelon Kevin Borton Florida Public Service Commission Lisa Bennett (by phone)

Mark Laux (by phone)

Pratts Nuclear Publications William Freebairn (by phone)

Progress Energy Jon Franke Bob Muzzi Dave Porter Larry Sexton Lewis Wells Dan Westcott Ted Williams Ken Wilson AREVA Bret Boman Ken Greenwood Scientech Bob Queenan

Meeting Discussion U. S. Nuclear Regulatory Commission Final Preapplication Public Meeting with Progress Energy Regarding Crystal River Unit 3 Extended Power Uprate April 21 J 2011 Progress Energy, representing Florida Power Corporation (the licensee) addressed the final preapplication plans for an extended power uprate (EPU) at Crystal River, Unit 3 Nuclear Generating Plant. The licensee intends to submit the license amendment application for the EPU by the end of Mayor in the early part of June 2011. Major points of discussion of the meeting between the licensee and Nuclear Regulatory Commission (NRC) staff from Nuclear Performance and Code Review Branch (SNPB), Reactor Systems Branch (SRXB), Electrical Engineering Branch (EEEB) and Instrumentation and Controls Branch (EICB) are noted below.

1. Provide an analysis of boric acid precipitation that addresses intermediate and small break loss-of-coolant-accident (LOCA) (break smaller than the double-ended guillotine (DEG) cold leg break sizes). Since reactor coolant system (RCS) pressure can remain above the shutoff head of the low pressure safety injection (LPSI) pump for these breaks, core flush for these breaks is precluded for extended periods of time. What emergency operating procedures (EOP) actions are established to assure intermediate and small breaks can deal with boric acid precipitation? Since cooldown using atmospheric dump valves (ADVs) and/or power-operated relief valves is not an explicit operator EOP action with a specific timing for operation, control of boric acid for intermediate and small breaks is not assured. The EOPs need to be reviewed to identify possible operator actions and explicit timing for control of boric acid for break sizes smaller than the DEG and DEG slot breaks in the RCS piping. The methods for controlling boric acid precipitation for all break sizes needs to be clearly identified and supported by calculations with a model acceptable to the NRC staff.
2. Since activation of LPSI into the hot leg is initiated whenever the borated water storage tank (BWST) or refueling water storage tank drains, this could occur as early as 20 minutes with all emergency core cooling equipment operating. Injection into the hot leg this early could result in the steaming rate from the core sweeping the injection into the steam generators and causing a core heat-up with peak cladding temperatures (PCTs) in excess of the 2200 degrees Fahrenheit (OF) limit. An evaluation of the entrainment of hot leg injection needs to be performed. The earliest time for hot leg injection needs to be determined so that the operators do not initiate hot leg injection too early. An appropriate entrainment correlation needs to be utilized and justified for this application and evaluation.
3. For large break LOCAs there is no timing identified in the EOPs for initiating hot leg injection to assure precipitation is precluded for all break sizes. Once the precipitation timing has been determined, hot leg injection must be initiated within a time period before precipitation, to assure sufficient time is available to the operators to perform the action.

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4. Since there are high concentrate boric acid tanks that could be operational during a LOCA, an evaluation needs to be performed to investigate the impact of discharge of the high concentrate boric acid tanks on timing for precipitation. Injection from these tanks could cause the boric acid to precipitate much earlier and, as such, the need for operator immediate action guidance to terminate injection of these tanks needs to be considered with a specific time identified within which to terminate injection.
5. The models, key assumptions, and limiting conditions employed in performing the boric acid precipitation timing for small and large break LOCA should be indentified in the submittal.

Timing for all operator actions needs to be clearly identified and how they are incorporated into the EOPs.

6. Since the core exit steaming/vapor generation contains boric acid, discuss the potential for crystallization of boric acid in the steam generator tubes and the impact on the loop resistance and mixing volume in the vessel used to determine the boric acid concentration versus time following a LOCA Recent tests at PKL [Primarkreislaufe-Versuchsanlage]

integral test facility constructed at AREVA NP in Germany have shown crystallization of boric acid in the loop piping and steam generators that could increase the resistance to steam flow in the loops and thereby retard the growth of the mixing volume in the vessel following a LOCA

7. When questioned about fuel type, fuel enrichments and thermal-mechanical design of fuel systems, the licensee responded that there is neither a change in fuel type, nor a change in enrichment. However, the licensee is expected to perform the thermal-mechanical-material design analysis for the fuel at the EPU conditions.
8. When inquired about the emergency core cooling water boric acid concentration and volume, the licensee provided the following information:

BWST - 415,000 gallons; 2600 parts per million (ppm) ~ BWST concentration ~ 3000 ppm Two Core flood tanks - 7,000 gallons

9. During the discussion concerning a comparison between the current licensing basis predicted-PCT for the small break LOCA and that predicted for the proposed EPU plant condition, the licensee stated that the current licensing basis value was approximately 1500 OF and the proposed EPU value was roughly 100 OF lower. The NRC staff asked the licensee whether current licensing basis value was based on an explicit analysis or based on an evaluation in accordance with Title 10 of the Code of Federal Regulations 50.46(a)(3) reporting requirements. The licensee clarified that the current licensing basis was based on an evaluation, but that the evaluation was specific to Crystal River Unit 3.
10. When asked whether core flood lines injected into the upper plenum or the downcomer; the licensee stated that the core flood lines inject into the downcomer.

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11. When asked about the new direct current battery for the proposed fast cooldown system be a Class 1 E or a Non-1 E battery, and how it will be tested, the licensee stated that it will be a Class 1 E battery, and it will be tested in accordance with the applicable technical specifications.
12. When asked about transmission grid stability analysis due to the proposed EPU, the licensee answered that a grid stability study has been performed and will be submitted with the EPU application.
13. When asked about any impact on emergency diesel generators (EDG) capacity and capability due to the proposed EPU and any impact on EDG loading or sequence of loading, the licensee answered that there is neither an impact on capacity and capability nor loading or sequence of loading on EDG.
14. Regarding equipment qualification (EO) margins due to EPU, the licensee asked for clarification regarding the meaning of "EO margin." NRC staff clarified the term using an example that NRC regulations required minimum margin between the new temperature and EO peak temperature of record. The licensee made a note of it.
15. The NRC staff questioned the licensee whether the current high energy line break (HELB) analysis would be affected. The licensee stated that they will validate the HELB analysis and address it in EPU application.
16. When asked whether there would be any effect on Class 'I E station battery capacity and capability due to the proposed EPU, or any impact on battery loading or on sequence of loading, the licensee replied, "No."
17. The licensee presented additional details regarding the design of the new ADV fast cooldown safety actuation instrumentation and controls system, also known as the inadequate core cooling mitigation system. This new safety system will be developed on a newly designed platform, which is based on analog technology. Scientech was selected to manufacture the components of this system. The system will actuate on a two-out-of-three logic so there will be three independent sets of redundant instrumentation installed to perform this function. Additional sensors will be installed including an RCS pressure transmitter, new incore detectors, and a new high pressure injection flow transmitter.
18. Because the system is not based upon digital technology, the regulatory requirements associated with software development or software common cause failure will not be applicable. All other regulatory requirements associated with Institute of Electrical and Electronics Engineers (IEEE) standard, IEEE 603, "Standard Criteria for Safety Systems for Nuclear Power Generating Stations," including single-failure criteria, separation criteria, and EO of equipment will need to be addressed during the review.

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19. The NRC staff asked questions regarding how the new system and its components would be powered. In response, the licensee stated that the electronics cabinets that perform the actuation functions would be energized from the safety-related (SR) buses associated with the applicable safety division. The new SR ADV controls will be powered by new safety-related battery banks that will be charged by a nonsafety-related charger via a non safety-related bus. Two battery banks per train will be installed to allow for maintenance and testing without entering a limiting condition for operation.

Schedule At the conclusion of the meeting, NRC Crystal River EPU Project Manager mentioned that it may take approximately two years for NRC staff to approve this EPU due to the addition of new safety-related system and first-of-a-kind review for Babcock and Wilcox reactor. The licensee raised a concern with this schedule during and after the meeting. The NRC Crystal River EPU Project Manager promised to clarify this further in the meeting summary as stated in the following "note".

Note: For a normal EPU, the NRC staff takes one year to complete its review, after the acceptance review is complete. Because of the complexity of the Crystal River EPU, NRC staff anticipates it will require more than one year to complete its review, after accepting the EPU application.

- 2 Members of the public were in attendance and no Public Meeting Feedback forms were received.

Please direct any inquiries to me at 301-415-1564 or by email to siva.lingam@nrc.gov.

IRA!

Siva P. Lingam, Project Manager Plant Licensing Branch 2-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosures:

1. List of Attendees
2. Meeting Discussion cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL2-2 RtF RidsNrrDorlLpl2-2 Resource RidsNrrLACSola Resource RidsAcrsAcnw_MailCTR Resource RidsNrrPMCrystalRiver Resource RidsNrrOd Resource RidsRgn2MailCenter Resource RidsOgcRp Resource RidsNrrDraAadb Resource T. Alexion, NRR K. Bucholtz, NRR S. Bush-Goddard, EDO E. Davidson, NRR D. Doyle, NRR K. Heller, NRR W. Jessup, NRR B. Lee, NRR M. Panicker, NRR P. Lien, RES S. Lingam, NRR B. Parks, NRR P. Sahay, NRR R. Stattel, NRR L. Ward, NRR T. Tate, NRR PACKAGE ACCESSION NO. ML11123A038 MEETING NOTICE ACCESSION NO. ML110740541 MEETING

SUMMARY

ACCESSION NO. ML11123A047 SLIDES PRESENTATION ACCESSION NO ML11123A042 OFFICE LPL2-2/PM LPL2-2/LA LPL2-2/BC LPL2-2/PM NAME SLingam CSoia DBroaddus (CGratton for)

Slingam DATE 05/12/11 05/12/11 05/12/11 05/12/11 OFFICIAL RECORD COpy