ML14079A412

Declaration of Mr. William A. Cross in Support of Florida Power & Light Company'S Answer Opposing Sace Motion to Stay Restart. Attachment 1

ML14079A412
Person / Time
Site:	Saint Lucie
Issue date:	03/20/2014
From:	Cross W Florida Power & Light Co
To:	NRC/OCM
SECY RAS
Shared Package
ML14079A409	List: ML14079A410 ML14079A411 ML14079A412 ML14079A413
References
50-389-LA, License Amendment, RAS 25705
Download: ML14079A412 (15)

Text

ATTACHMENT 1 March 20, 2014 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of )

)

Florida Power & Light Company ) Docket No. 50-389

)

(St. Lucie Plant, Unit 2) )

DECLARATION OF MR. WILLIAM A. CROSS IN SUPPORT OF FPLS ANSWER OPPOSING SACE MOTION TO STAY RESTART Mr. William A. Cross states as follows under penalty of perjury:

I. INTRODUCTION A. Declarants Background

1. I am the Nuclear Regulatory Programs Manager for Florida Power and Light Com-pany (FPL).

My educational background and qualifications include receiving a Bachelor of Sci-ence in Engineering (Nuclear Engineering) in 1974 from the University of Florida and holding a Nuclear Regulatory Commission (NRC) Senior Reactor Operator License for Crystal River Unit 3. Upon graduation from the University of Florida in 1974 I began my professional career with Florida Power Corporation as a Nuclear Licensing Engineer. From 1974 until 1975, I was employed by Tennessee Valley Authority as a Power Supply Planning Engineer. In 1975 I joined Florida Power Corporation at Crystal River Unit 3 as a Nuclear Plant Engineer. I continued my ca-reer advancement at Crystal River Unit 3 in positions with increasing responsibility

and authority including Technical Specifications Engineer, Reactor Engineer, Oper-ations Engineer and Nuclear Licensing Manager, until 1982. While employed by Florida Power Corporation I received a Senior Reactor Operator License from the NRC. In 1982 I commenced work as a nuclear industry consultant specializing in nuclear licensing and regulatory compliance services with Southern Technical Ser-vices, Inc. a Florida corporation, which continued through 2002. From 2002 through 2008 I rendered small business consulting services as Crosservices, Incor-porated, a Florida Corporation. In 2008 I joined Florida Power & Light Company as Nuclear Projects Engineering Design Basis Supervisor directing a team responsible for ensuring the technical and regulatory quality of the 10 C.F.R. § 50.59 reviews, as required, supporting engineering products including design changes, license amendments, exemptions and responses to NRC requests for additional information.

As Design Basis Supervisor, I completed and maintain engineering qualifications for Section 50.59 Screening, Evaluation and Verification. In 2010 I joined Nuclear Licensing as Fleet Project Licensing Manager with responsibility for governance and oversight of Nuclear Projects and Nuclear Engineering activities needed to achieve timely and successful licensing actions for transition to NFPA 805, imple-mentation of Cyber Security Programs and resolution of GSI-191.

2. As Nuclear Regulatory Programs Manager, I am responsible for leadership of a team in the development of licensing actions for the nuclear fleet to meet regulatory requirements, improve operating margins, extend allowed completion times, im-prove outage effectiveness, avoid unwarranted plant shutdowns and prevent unnec-essary regulatory actions. Based on my design engineering qualifications, I con-2

ducted a review of the 10 C.F.R. § 50.59 Evaluation for the St. Lucie Unit 2 re-placement steam generators for technical and regulatory quality.

B. SACEs Motion to Stay Restart of St. Lucie Unit 2

3. I have reviewed and am familiar with Southern Alliance for Clean Energys (SACE) motion to stay the restart of the St. Lucie Unit 2 reactor, which was filed with the Secretary on March 10, 2014. 1 I have also reviewed and am familiar with the Declaration provided by Mr. Arnold Gundersen in support of SACEs motion for stay. 2 II. REPLACEMENT OF ST. LUCIE UNIT 2 STEAM GENERATORS PROPERLY PURSUANT TO 10 C.F.R. § 50.59

4. SACE erroneously asserts that FPL made changes to the St. Lucie steam generators pursuant to 10 C.F.R. § 50.59 that exceed the design basis for the reactor with-out requesting a formal license amendment, and that these design changes create new, unanalyzed safety issues for the reactor coolant pressure boundary. SACE Motion at 3-4; Gundersen Decl. at ¶¶ 59-63. In fact, the replacement of the St.

Lucie steam generators was properly implemented pursuant to Section 50.59, which is the common industry practice, after a thorough screening and evaluation. In ac-cordance with Section 50.59, FPL prepared an evaluation that demonstrated the re-placement steam generators satisfied the existing Updated Final Safety Analysis Report (UFSAR) acceptance criteria and Technical Specification Limits. In addi-1 Southern Alliance for Clean Energys Motion to Stay Restart of St. Lucie Unit 2 Pending Conclusion of Hearing Regarding De Facto Amendment of Operating License and Request for Expedited Consideration (Mar. 10, 2014)

(SACE Motion).

2 Declaration of Arnold Gundersen (Mar. 9, 2014), Attachment 1 to Southern Alliance for Clean Energys Hearing Request Regarding De Facto Amendment of St. Lucie Unit 2 Operating License (Mar. 10, 2014) (Gundersen Decl.).

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tion, the Section 50.59 evaluation found that none of the criteria warranting a li-cense amendment, as specified in 10 C.F.R. § 50.59(c)(2), applied to the replace-ment steam generators for St. Lucie Unit 2. No changes to St. Lucie Unit 2 Tech-nical Specifications were required, nor were any changes to the Emergency Operat-ing Procedures required as a result of the replacement of the steam generators. Af-fected sections of the UFSAR were updated, but the new steam generators were bounded by the original calculations for the original steam generators.

5. The 10 C.F.R. § 50.59 evaluation of the St. Lucie Unit 2 replacement steam gen-erators was reviewed by the NRC Staff as part of a three-month inspection, which included the St. Lucie Unit 2 steam generator replacement inspection. St. Lucie Nu-clear Plant - NRC Integrated Inspection Report 05000335/2007005, 05000389/2007005 (Feb. 1, 2008) (ADAMS Accession No. ML080350408), En-closure at 28. The inspectors reviewed the change screening and/or evaluation for all [plant change modifications] reviewed to verify that the modifications were properly evaluated in accordance with 10 CFR 50.59. Id. No findings of signifi-cance were identified. Id. at 33. See also Letter from Gordon L. Johnston, Site Vice President, St. Lucie Plant, to NRC, L-2008-148 (June 26, 2008), at 8 (AD-AMS Accession No. ML081840111) (summarizing the results of the Section 50.59 evaluation).

6. FPLs replacement of the St. Lucie Unit 2 steam generators in accordance with 10 C.F.R. § 50.59 did not modify the operating license or afford FPL any greater oper-ating authority.

4

III. EXTENDED POWER UPRATE LICENSE AMENDMENT FOR ST. LUCIE UNIT 2 WITH REPLACEMENT STEAM GENERATORS

7. On February 25, 2011, FPL requested a license amendment to permit an extended power uprate (EPU) at St. Lucie Unit 2. Letter from Richard L. Anderson, Site Vice President, St. Lucie Plant, to NRC, L-2011-021 (Feb. 25, 2011) (ADAMS Ac-cession No. ML110730116). On September 1, 2011, the Commission published a notice of the license amendment request and of an opportunity to request a hearing.

76 Fed. Reg. 54,503 (Sept. 1, 2011). No hearing requests or petitions to intervene were filed.

8. In reviewing the EPU request, both the NRC Staff and the Advisory Committee on Reactor Safeguards (ACRS) evaluated the steam generator tube wear in the St.

Lucie Unit 2 steam generators in light of the unique tube-to-tube wear observed at SONGS Unit 3. Certain of the requests for additional information (RAIs) from the NRC Staff addressed St. Lucie tube wear issues and the potential for tube-to-tube wear experienced by San Onofre Nuclear Generating Station (SONGS) Unit

3. On June 22, 2012, the ACRS Subcommittee on Power Uprates reviewed the St.

Lucie Unit 2 EPU license amendment request and the associated NRC safety evalu-ation. On July 11 - 13, 2012, the ACRS full committee reviewed the St. Lucie Unit 2 EPU license amendment request. In the letter to the NRC Executive Director for Operations recommending approval of the St. Lucie Unit 2 EPU license amendment, the ACRS commented on pertinent differences between the types and extent of steam generator wear observed at the two plants and concluded that

[t]hese considerations and the licensees action plan adequately address concerns about [steam generator] tube integrity. Letter from J. Sam Armijo, Chairman, 5

ACRS, to R.W. Borchardt, NRC Executive Director of Operations (Jul. 23, 2012),

at 4 (ADAMS Accession No. ML12198A202), Exhibit A hereto. The Commission issued the requested license amendment on September 24, 2012. Letter from Tracy J. Orf, Project Manager, Plant Licensing Branch 11-2, to Mano Nazar, Executive Vice President and Chief Nuclear Officer, Florida Power and Light Company (Sept.

24, 2012) (ADAMS Accession No. ML12235A463). The NRC Staffs Safety Evaluation Report supporting the license amendment specifically found that the li-censee demonstrated that tube integrity will continue to be maintained and will con-tinue to meet the performance criteria in NEI 97-06 and the requirements of 10 C.F.R. § 50.55a following implementation of the proposed EPU. NRC staff also found the proposed EPU acceptable with respect to steam generator tube in-service inspection. Id., Enclosure 2 at 39.

IV. ST. LUCIE UNIT STEAM GENERATOR REPLACEMENT AND EPU HAVE BEEN PROPERLY IMPLEMENTED PURSUANT TO NRC REGULATIONS AND PROCEDURES

9. Particularly in view of the detailed safety evaluation conducted by the NRC Staff and the ACRS prior to granting the St. Lucie Unit 2 EPU license amendment, SACEs claim that the NRC Staff has repeatedly amended FPLs operating license to allow significant alterations to the original and renewed design basis of the reac-tor and without affording the public an opportunity for hearing (SACE Motion at 6-7) is unfounded. The St. Lucie Unit 2 steam generators were replaced appropri-ately pursuant to 10 C.F.R. § 50.59; this was confirmed by an NRC review during an inspection of steam generator replacement with no adverse findings. The EPU of St. Lucie Unit 2 with the replacement steam generators was accomplished pursu-6

ant to a license amendment, during which the tube wear at St. Lucie Unit 2 was considered and evaluated in light of the unique tube-to-tube wear at SONGS Unit 3.

FPL and AREVA, as well as the NRC Staff and the ACRS, were satisfied that the design, fabrication and operations of the replacement steam generators in St. Lucie Unit 2 were sufficiently different from SONGS Unit 3 to be less likely susceptible to tube-to-tube wear. Results of inspections of St. Lucie Unit 2 steam generators and operational assessments prepared in support of each restart after such inspec-tions have confirmed the consensus technical view. Mr. Gundersens speculation does not address the considerable record in the EPU license amendment proceeding.

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

Executed in Accord with 10 C.F.R. § 2.304(d)

William A. Cross Nuclear Regulatory Programs Manager 700 Universe Blvd Juno Beach, FL 33408 Phone: (561) 561-2970 E-mail: William.Cross@fpl.com 7

Exhibit A 8

UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 July 23, 2012 Mr. R.W. Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

FINAL SAFETY EVALUATION REPORT ASSOCIATED WITH THE FLORIDA POWER AND LIGHT ST. LUCIE, UNIT 2, LICENSE AMENDMENT REQUEST FOR AN EXTENDED POWER UPRATE

Dear Mr. Borchardt:

During the 596th meeting of the Advisory Committee on Reactor Safeguards, July 11-13, 2012, we completed our review of the license amendment request (LAR) for the extended power uprate (EPU) of St. Lucie, Unit 2, (St. Lucie 2) and the associated draft Safety Evaluation (SE).

Our Subcommittee on Power Uprates reviewed this matter in a meeting on June 22, 2012.

During these reviews, we met with representatives of the staff, Florida Power and Light Company (FPL or the licensee), and their consultants. We did not review the St. Lucie 2 spent fuel pool analysis, which is still under review by the staff. We had the benefit of the documents referenced.

CONCLUSIONS AND RECOMMENDATION

1. The FPL LAR for an EPU of St. Lucie 2 should be approved subject to the conditions imposed in the staffs draft Safety Evaluation.

2. Fuel thermal conductivity degradation (TCD) phenomena at St. Lucie 2 are addressed by the license condition that FPL maintain more restrictive operational/design radial power fall-off (RFO) curve limits.

3. The licensees action plan addresses our concerns related to further wear of the tubes in the replacement steam generators (SGs).

BACKGROUND The two unit St. Lucie Nuclear Power Plant is located on Hutchinson Island, near Ft. Pierce, Florida in St. Lucie County. Unit 2 is a 2x4 loop pressurized water reactor, designed by Combustion Engineering and licensed in 1983 to operate at 2560 MWt. In 1985, the unit was approved for a 5% stretch uprate to the currently licensed thermal power (CLTP) of 2700 MWt.

In this LAR, FPL requested approval of a power uprate of 10% above the CLTP and a 1.7%

measurement uncertainty recapture (MUR) to allow a maximum core power level of 3020 MWt.

FPL plans to implement this EPU in the fall of 2012.

There are no changes in the reactor coolant system, reactor vessel internals, and fuel type due to the EPU. The two St. Lucie 2 SGs were replaced in 2007 with AREVA Model 86/19TI SGs.

The reactor vessel closure head was replaced in 2007.

The EPU will change some core design parameters including fuel enrichment and radial peaking factor, but the maximum linear heat rate will remain the same. The core average coolant temperature will increase from 573.3°F to 578.5°F. The reactor vessel head temperature will increase from about 595°F to 604°F. Design steam mass flow rates in each of the SGs will increase by approximately 13%.

Safety-related changes include control room air conditioning, charging pump control circuits, neutron absorption materials in spent fuel pool storage racks, nuclear steam supply system setpoints, environmental qualification of electrical equipment, component cooling water supports, and the SG low-level trip setpoints. Installation of a Leading Edge Flow Measurement system reduces flow measurement uncertainty and allows a 1.7% increase in power. Some of these changes have already been implemented, and the remaining changes will be completed during the fall 2012 outage.

DISCUSSION We reviewed the staffs evaluation of the EPU effects on station blackout, component material degradation, risk, and electrical power systems. In addition, we considered the licensee's power ascension test program. Issues of special interest that arose during our review are discussed in this letter.

Fuel Thermal Conductivity Degradation (TCD)

NRC Information Notice 2009-23, Nuclear Fuel Thermal Conductivity Degradation, describes an issue concerning the ability of legacy thermal-mechanical fuel modeling codes to accurately predict the exposure-dependent fuel TCD.

The NRC-approved FATES3B fuel rod performance model used by FPL for predicting fuel centerline temperature at high burnup does not model TCD. In response to staff concerns, FPL proposed a license condition that will impose more restrictive operational/design radial power fall-off (RFO) curve limits for St. Lucie 2. The new RFO curve limits were derived by comparing FATES3B fuel temperature predictions to results from Halden fuel tests. FATES3B predictions compared well to Halden data up to intermediate levels of rod average burnup (about 35 GWd/MTU). The predictions underestimate fuel centerline temperatures at higher burnups.

New RFO curve limits were determined by imposing in the analysis a penalty that increases from 0-200°F over the burnup range from 35-50 GWd/MTU and remains constant for higher burnups. The staff compared FPL FATES3B fuel temperature predictions that incorporate this RFO curve penalty to Halden data and performed independent FRAPCON-3.4 calculations.

Based on these comparisons, the staff concluded that this was acceptable for addressing TCD phenomena at St. Lucie 2. The more restrictive RFO curve limits will be verified as part of the Reload Safety Analysis Checklist process.

Steam Generator Performance Each replacement SG contains 8999 thermally-treated Alloy 690 tubes with broached stainless steel horizontal supports and an anti-vibration bar (AVB) system. The steam generator supplier, AREVA, performed design calculations with their codes to ensure that accumulated SG tube wear was acceptable for 110% CLTP and EPU conditions.

After their first 18 month cycle of operation at the CLTP level, an inspection revealed a number of tube-to-AVB wear indications (3700 indications on 1231 tubes in SG A and 2157 indications on 815 tubes in SG B). Approximately 90% of these wear indicators were less than 15% of the tube wall thickness. Although none of the tube wear reached the 40% wear limit that would require plugging, FPL conservatively plugged the 14 tubes with greater than 25% wear (e.g., 8 tubes in SG A and 6 tubes in SG B). After their second 18 month cycle of operation, inspections found an additional 2164 indications on tubes in SG A and 804 additional indications on tubes in SG B (bringing the total number of affected tubes to 1862 for SG A and to 1125 for SG B). The measured average wear rates reduced from 7.9 to 4.0 %/EFPY for SG A and from 7.7 to 1.6%/EFPY for SG B, but one tube in SG A reached the 40% wear limit for plugging. In addition, the licensee plugged any tubes with measured wear exceeding approximately 30% (a total of 16 additional tubes in SG A and 5 additional tubes in SG B).

The licensee completed a root cause evaluation that considered factors such as SG design, manufacturing processes, materials and associated tolerances, and potential operational effects. They concluded that the root cause was that the U-tubes were not effectively supported during SG manufacture, which caused the tubes to sag into the AVBs and led to slight AVB deformation that closed the tube-to-AVB gap at specific locations. This exacerbated tube wear in those locations. Supporting information for this root cause evaluation included updated AREVA analyses with revised gap distributions that predict wear similar to observed values after the first and second inspections.

The licensees analyses indicate that the increased steam flow rates associated with the EPU will have a negligible effect on the observed tube wear rates. Results from a third full 100%

bobbin coil inspection (scheduled for this fall) will provide additional information. In addition, a full 100% bobbin coil inspection will be conducted after EPU conditions are implemented.

The licensee performed an operational assessment for the next two cycles which included a cycle under EPU conditions. This assessment was based on wear rate data from the first two inspections. The analysis applied a factor of 1.24 to the wear rates to account for the increase in wear rate due to the change in flow conditions for the EPU. The factor of 1.24 is based on an analysis with the tube and support in contact in accordance with the root cause evaluation. The assessment does not credit any additional attenuation of the wear rates that may occur during the current cycle of operation. Assessment results indicate acceptable margin against tube structural integrity requirements, indicating a probability of loss of margin of 0.02 versus an allowable value of 0.05.

The tube wear observed at St Lucie 2 is primarily at AVB supports. This is different than the form of degradation reported to have occurred at San Onofre. There are a number of design differences between the SGs installed at San Onofre and those at St Lucie 2. We reviewed the FPL evaluation of these differences and concluded that the forms of degradation reported to have occurred at San Onofre are less likely to occur at St Lucie 2. This will be verified by the inspection following the first EPU cycle.

These considerations and the licensees action plan adequately address concerns about SG tube integrity.

CLOSING COMMENT In summary, the EPU license amendment request for St. Lucie 2 should be approved with the license conditions identified in the SER.

Sincerely,

/RA/

J. Sam Armijo Chairman REFERENCES

1. License Amendment Request for Extended Power Uprate, St. Lucie, Unit 2, Docket No.

50-389, Renewed License No. NPF-16, February 25, 2011, (ML110730116).

2. Draft NRC Safety Evaluation on St. Lucie 2 EPU, updated July 2012 (ML12145A032).

3. NRC Review Standard 001 (RS-001), Review Standard for Extended Power Uprate, Revision 0, December 2003 (ML033640024).

4. CENPD-132, Supplement 4-P-A, Calculative Methods for the C-E Nuclear Power Large Break LOCA Evaluation Model, April 2001 (ML011030417).

5. NRC Information Notice 2009-23, Nuclear Fuel Thermal Conductivity Degradation,"

October 8, 2009 (ML091550527).

6. CENPD-139-P-A, Fuel Evaluation Model, July 1974, (ML120960147).

7. CEN-161(B)-P-A, Improvements to Fuel Evaluation Model, August 1989, (ML120960155).

8. CEN-161(B)-P, Supplement 1-P-A, Improvements to Fuel Evaluation Model, January 1992, (ML120960175).

9. CENPD-275-P, Revision 1-P-A, C-E Methodology for Core Designs Containing Gadolinia-Urania Burnable Absorbers, May 1988.

10. CEN-372-P-A, Fuel Rod Maximum Allowable Gas Pressure, May 1990.

11. CENPD-275-P, Revision 1-P, Supplement 1-P-A C-E Methodology for PWR Core Designs Containing Gadolinia-Urania Burnable Absorbers, April 1999.

12. Letter from B. T. Moroney (NRC) to J. A. Stall (FP&L), St. Lucie Plant, Unit 2 - Issuance of Amendment Regarding Change in Reload Methodology and Increase in Steam Generator Tube Plugging Limit (TAC No. MC1566), January 31, 2005 (ML050120363).

13. CENPD-404-P-A, Revision 0, Implementation of ZIRLOTM Cladding Material in CE Nuclear Power Fuel Assembly Designs, November 2001 (ML013270123 and 013270127).

14. CEN-386-P-A, Verification of the Acceptability of a 1-Pin Burnup Limit of 60 MWD/kgU for Combustion Engineering 16x16 PWR Fuel, ABB Combustion Engineering, Inc.,

August 1992.

15. CENPD-384-P, Report on the Continued Applicability of 60 MWD/kgU for ABB Combustion Engineering PWR Fuel, ABB Combustion Engineering, Inc., September 1995.

10. CEN-372-P-A, Fuel Rod Maximum Allowable Gas Pressure, May 1990.

11. CENPD-275-P, Revision 1-P, Supplement 1-P-A C-E Methodology for PWR Core Designs Containing Gadolinia-Urania Burnable Absorbers, April 1999.

12. Letter from B. T. Moroney (NRC) to J. A. Stall (FP&L), St. Lucie Plant, Unit 2 -

Issuance of Amendment Regarding Change in Reload Methodology and Increase in Steam Generator Tube Plugging Limit (TAC No. MC1566), January 31, 2005 (ML050120363).

13. CENPD-404-P-A, Revision 0, Implementation of ZIRLOTM Cladding Material in CE Nuclear Power Fuel Assembly Designs, November 2001 (ML013270123 and 013270127).

14. CEN-386-P-A, Verification of the Acceptability of a 1-Pin Burnup Limit of 60 MWD/kgU for Combustion Engineering 16x16 PWR Fuel, ABB Combustion Engineering, Inc., August 1992.

15. CENPD-384-P, Report on the Continued Applicability of 60 MWD/kgU for ABB Combustion Engineering PWR Fuel, ABB Combustion Engineering, Inc., September 1995.

Accession No: ML12198A202 Publicly Available Y Sensitive N Viewing Rights: NRC Users or ACRS Only or See Restricted distribution OFFICE ACRS SUNSI Review ACRS ACRS ACRS NAME WWang WWang CSantos EMHackett EMH for JSA DATE 07/23/12 07/23/12 07/23/12 07/23/12 07/23/12 OFFICIAL RECORD COPY

Letter to R.W. Borchardt, EDO, from J. Sam Armijo, ACRS Chairman, dated July 23, 2012

SUBJECT:

FINAL SAFETY EVALUATION REPORT ASSOCIATED WITH THE FLORIDA POWER AND LIGHT ST. LUCIE, UNIT 2, LICENSE AMENDMENT REQUEST FOR AN EXTENDED POWER UPRATE ML#12198A202 Distribution:

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