Letter Sequence Meeting |
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Results
Other: L-2015-177, Fuel Transition Small Break LOCA Summary Report, ANP-3345NP, Revision 1, L-2015-206, ANP-3428NP, Revision 0, St. Lucie Unit 2 Fuel Transition: Response to SNPB-RAI-1, Attachment 4 to L-2015-206, L-2015-259, ANP-3440NP, Revision 1, Response to NRC Questions SRXB-RAI-1 and Snpb RAI-2 Thru Snpb RAI-20, L-2015-279, RAI Response Clarification for SRXB-RAI-1 and Snpb RAI-2 Thru RAI-20 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel, ML15091A377, ML15197A339, ML15219A184, ML15279A226, ML15356A184, ML15356A185
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MONTHYEARML15002A0912014-12-30030 December 2014 Application for Technical Specification Change and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Request L-2014-366, St. Lucie, Unit 2 - Application for Technical Specification Change and Exemption Request Regarding the Transitioning to Areva Fuel2014-12-30030 December 2014 St. Lucie, Unit 2 - Application for Technical Specification Change and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Request L-2014-366, ANP-3352NP, Revision 0, St. Luice, Unit 2, Fuel Transition License Amendment Request, Technical Report2014-12-31031 December 2014 ANP-3352NP, Revision 0, St. Luice, Unit 2, Fuel Transition License Amendment Request, Technical Report Project stage: Request ML15055A4732015-03-10010 March 2015 Supplemental Information Needed for Acceptance of Requested Licensing Action License Amendment Request and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Acceptance Review ML15072A1232015-03-13013 March 2015 March 19, 2015, Notice of Forthcoming Closed Meeting with Florida Power and Light Company for the License Amendment Request and Exemption Request Regarding the Transitioning to Areva Fuel (TAC Nos. MF5494-95) Project stage: Meeting ML15084A0112015-03-23023 March 2015 Supplemental Information for Technical Specification Change and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Supplement L-2015-091, ANP-3396NP, Revision 0, Fuel Transition Supplemental Information to Support the LAR2015-03-31031 March 2015 ANP-3396NP, Revision 0, Fuel Transition Supplemental Information to Support the LAR Project stage: Request ML15090A2402015-04-0808 April 2015 Acceptance of Requested Licensing Action Regarding License Amendment Request and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Acceptance Review ML15103A3702015-04-15015 April 2015 March 19, 2015, Summary of Closed Meeting with Florida Power and Light Company and Areva Regarding Supplemental Information for the License Amendment and Exemption Requests Regarding the Transitioning to Areva Fuel Project stage: Meeting ML15127A4052015-05-12012 May 2015 RAI Regarding License Amendment Request and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: RAI ML15149A4982015-06-0101 June 2015 June 11, 2015 Notice of Forthcoming Closed Meeting with Florida Power and Light Company for the License Amendment and Exemption Requests Regarding Transitioning to Areva Fuel at St. Lucie Plant, Unit No. 2 Project stage: Meeting L-2015-166, Request for Additional Information Reply for Technical Specification Changes and Exemption Request Regarding the Transitioning to Areva Fuel2015-06-0202 June 2015 Request for Additional Information Reply for Technical Specification Changes and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Request ML15182A1262015-06-11011 June 2015 June 11, 2015, Closed Meeting Slide Re. Florida Power and Light Company for Control Rod Ejection RAI SNPB-RAI-1 at St. Lucie Plant, Unit No. 2 Project stage: Meeting ML15091A4002015-06-15015 June 2015 Request for Withholding Proprietary Information from Public Disclosure for Supplemental Information Supporting the LAR and Exemption Request Re. the Transitioning to Areva Fuel Project stage: Approval ML15181A2902015-06-18018 June 2015 Resubmittal of the Areva Small Break LOCA Summary Report within the Application for Technical Specification Change and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Request L-2015-176, Emergency Response Data Point Library (Dpl) Changes2015-06-18018 June 2015 Emergency Response Data Point Library (Dpl) Changes Project stage: Request ML15166A3682015-06-24024 June 2015 RAI Re. License Amendment Request and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: RAI L-2015-177, Fuel Transition Small Break LOCA Summary Report, ANP-3345NP, Revision 12015-06-30030 June 2015 Fuel Transition Small Break LOCA Summary Report, ANP-3345NP, Revision 1 Project stage: Other ML15188A3402015-07-13013 July 2015 Summary of Closed Meeting with Florida Power and Light Company and Areva Regarding Request for Additional Information for the License Amendment and Exemption Requests Re. the Transitioning to Areva Fuel Project stage: RAI ML15219A1842015-07-30030 July 2015 RAI Response to SNPB-RAI-1 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Other L-2015-206, ANP-3428NP, Revision 0, St. Lucie Unit 2 Fuel Transition: Response to SNPB-RAI-1, Attachment 4 to L-2015-2062015-07-31031 July 2015 ANP-3428NP, Revision 0, St. Lucie Unit 2 Fuel Transition: Response to SNPB-RAI-1, Attachment 4 to L-2015-206 Project stage: Other ML15091A3772015-08-11011 August 2015 Request for Withholding Proprietary Information from Public Disclosure for the License Amendment Request and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Other ML15197A3392015-08-31031 August 2015 Request for Withholding Proprietary Information from Public Disclosure for the License Amendment Request and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Other ML15233A0362015-09-0404 September 2015 Redacted Request for Additional Information Regarding Proposed License Amendment Request and Exemption Request to Allow the Transition to Areva Fuel Project stage: RAI ML15224B3192015-09-21021 September 2015 Request for Withholding Information from Public Disclosure for the St. Lucie Plant, Unit 2 Project stage: Withholding Request Acceptance L-2015-259, ANP-3440NP, Revision 1, Response to NRC Questions SRXB-RAI-1 and Snpb RAI-2 Thru Snpb RAI-202015-10-0202 October 2015 ANP-3440NP, Revision 1, Response to NRC Questions SRXB-RAI-1 and Snpb RAI-2 Thru Snpb RAI-20 Project stage: Other ML15279A2262015-10-0202 October 2015 RAI Response to SRXB-RAI-1 and Snpb RAI-2 Thru RAI-20 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Other L-2015-279, RAI Response Clarification for SRXB-RAI-1 and Snpb RAI-2 Thru RAI-20 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel2015-11-0303 November 2015 RAI Response Clarification for SRXB-RAI-1 and Snpb RAI-2 Thru RAI-20 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Other L-2015-300, ANP-3352NP, Revision 1, Transition License Amendment Request, Technical Report2015-11-30030 November 2015 ANP-3352NP, Revision 1, Transition License Amendment Request, Technical Report Project stage: Request ML15356A1842015-12-0808 December 2015 RAI Response for Snpb RAI-9 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel Project stage: Other ML15356A1852015-12-31031 December 2015 ANP-3456NP, Revision 0, Response to SLU2 NRC Snpb RAI-9, Licensing Report Project stage: Other 2015-05-12
[Table View] |
Text
St. Lucie Unit 2 Fuel Transition Project Control Rod Ejection RAI - SNPB-RAI-1 June 11, 2015
2 NRC Concerns Expressed in the RAI The application of the above methodology [XN-NF-78-44]
to AREVAs CE 16x16 fuel is considered as an expansion of the applicability of this Topical Report.
3 NRC Concerns Expressed in the RAI PIRT for PWR rod ejection accident identifies certain properties of the fuel design under high burnup conditions:
- Fuel thermal conductivity, gap conductance, clad conductivity (including oxide layer), transient cladding-to-coolant heat transfer coefficient, heat capacities of fuel and cladding, and other applicable parameters.
- It is not evident from your submittal on the CR ejection analysis whether a modern fuel performance code is used to compute the fuel and clad properties.
4 NRC Concerns Expressed in the RAI The margin to the centerline temperature (CLT) for 20%
and 65%
rated thermal power (RTP) has been substantially reduced for beginning of cycle (BOC).
5 SNPB-RAI-1 In view of the above, the NRC staff requests that the licensee and AREVA perform a plant-specific analysis of CR Ejection accident for St. Lucie 2 using an alternate methodology that was proposed to the staff during the pre-submittal meeting on November 3, 2014. By performing the alternate analysis using the combination of latest fuel performance methodology and the proposed supplement to the ARCADIA reactor analysis system methodology, the licensee may provide additional information that is necessary for determining the acceptability of the applicability of XN-NF-78-44(NP)(A) to AREVA CE 16x16 fuel design.
6 Proposed Approach for RAI Response Comparison to another approved method
- Part of the basis for the original approval of the XN-NF-78-44 Topical Report was NRC comparison to other approved methods.
Comparison of 16 x 16 results
- Quantitative comparison of 16 x 16 results (St. Lucie Unit 2) to the analysis results for other fuel types provided in ANP-3396P.
- The recently-approved St. Lucie-2 EPU rod ejection Analysis of Record (deposited enthalpy cases), performed by the current fuel vendor, could be modeled with the XN-NF-78-44 method for comparison of results to the currently approved method.
7
Background
The St. Lucie Unit 2 HTP fuel transition control rod ejection accident analysis was performed using the following AREVA approved methodologies for the applicable SRP acceptance criteria:
- XN-NF-78-44(NP)(A), A Generic Analysis of the Control Rod Ejection Transient for Pressurized Water Reactors, 1983.
- EMF-2310(P)(A), Revision 1, SRP Chapter 15 Non-LOCA Methodology for Pressurized Water Reactors, 2004.
8
Background
- XN-NF-78-44(NP)(A), A Generic Analysis of the Control Rod Ejection Transient for Pressurized Water Reactors, 1983.
Used in conjunction with current SRP criteria (more conservative than as approved in topical report)
Peak radial average fuel enthalpy
- 230 cal/g for fuel coolability
- 150 cal/g for HZP conditions PCMI failure criterion - a change in radial average fuel enthalpy greater than the corrosion-dependent limit
- EMF-2310(P)(A), Revision 1, SRP Chapter 15 Non-LOCA Methodology for Pressurized Water Reactors, 2004.
Fuel failure limits from DNB and FCM for core coolability and radiological analysis
9 Applicability to CE 16x16 Fuel (XN-NF-78-44)
Key input parameters are calculated with NRC-approved Neutronics methods:
- Reactivity worth of ejected control rod, power peaking factor, reactivity coefficients, and delayed neutron fraction
- Explicitly models the CE 16x16 reactor and fuel geometry Deposited enthalpy calculation is independent of fuel pin dimensions or array
- Function of ejected rod worth, effective delayed neutron fraction, and Doppler Temperature Coefficient (based on Nordheim-Fuchs model)
10 Applicability to CE 16x16 Fuel (XN-NF-78-44)
The approved methodology has been applied for 14x14, 15x15, and 17x17 fuel.
Application to 16 x 16 followed the same approach as for other fuel types.
Quantitative comparison of 16 x 16 results (St. Lucie Unit
- 2) to the analysis results for other fuel types provided in ANP-3396P.
11 Applicability to CE 16x16 Fuel (XN-NF-78-44)
See FPL Letter L-2015-091 dated March 23, 2015
12 PIRT Parameters for Rod Ejection (EMF-2310 Method)
S-RELAP5 used in the transient analysis of the non-LOCA events, including Rod Ejection, covers the impact of high burnup to explicitly account for the effects of thermal conductivity degradation, as stated in Section 2.7 of ANP-3347P. The parameters include:
- Fuel thermal conductivity
- Heat capacity
- Fuel pellet-to-clad gap coefficient
13 Margin to DNB and FCM (EMF-2310 Method)
S-RELAP5 determines the core average transient response, the hot spot fuel centerline temperature and the thermal-hydraulic boundary conditions for subsequent XCOBRA-IIIC MDNBR calculations.
The S-RELAP5 model explicitly accounts for the St.
Lucie-2 plant and fuel dimensions.
14 Margin to DNB and FCM (EMF-2310 Method)
Key neutronic parameters are conservatively biased
- Doppler reactivity feedback
- moderator reactivity
- ejected CEA worth (maximized to mitigate the event on Doppler feedback prior to reactor scram)
- power peaking factors
- fuel rod exposures
15 Margin to DNB and FCM (EMF-2310 Method)
The S-RELAP5 calculation contains other conservative assumptions
- Conservative reactor protection system setpoints and delays
- minimum Technical Specification RCS flow
- maximum core inlet temperature are used to increase the challenge to MDNBR
- core average pellet-to-cladding gap coefficients are maximized resulting in decreased Doppler feedback and increased core power
- hot spot pellet-to-cladding gap coefficients are minimized resulting in increased fuel centerline temperatures
- Conservative biasing of fuel thermal properties for the average core and hot spot
16 Margin to DNB and FCM (EMF-2310 Method)
Summary:
- In the S-RELAP analyses, key parameters are intentionally biased based on available margin to ensure that cycle-by-cycle variations are bounded.
- Each cycle, the values for these key parameters are checked to ensure that limits are not exceeded (or to re-analyze if necessary)
- For St. Lucie Unit 2, the radiological dose analyses support up to 9.5% fuel failure due to DNB and 0.5% fuel failure from fuel centerline melt.
Since the there are no failures predicted in the AREVA analyses, significant margin is maintained to the fuel failure limits based on DNB and fuel centerline melt.
17 Summary and Recommendations A Supplement to the LAR (ANP-3396P) provides justification of applicability of XN-NF-78-44 to CE 16x16 fuel.
- The recently-approved St. Lucie-2 EPU control rod ejection case could be modeled with XN-NF-78-44, for comparison to the currently approved results, to provide additional justification for applicability of XN-NF-78-44 to CE 16x16 fuel.
The NRC concerns regarding PIRT parameters and margin to DNB and FCM are covered by the EMF-2310 portion of the analysis, which addresses the effects of high burnup.