ML15224B119
| ML15224B119 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/27/1987 |
| From: | Pastis H Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC-61957, TAC-61958, TAC-61959, NUDOCS 8705010186 | |
| Download: ML15224B119 (22) | |
Text
Docket Nos.:
50-269, 50-270 2 gy and 50-287 APR LICENSEE:
Duke Power Company FACILITY:
Oconee Nuclear Station, Units 1, 2 and 3
SUBJECT:
SUMMARY
OF MEETING WITH DUKE POWER COMPANY ON REFORMATING THE OCONEE 2 CYCLE 9 RELOAD TECHNICAL SPECIFICATIONS (TACS 61957/61958/61959)
Introduction On July 17, 1986, the NRC staff met with representatives of Duke Power Company (the Licensee) in the Phillips Building, Bethesda, Maryland to discuss Duke Power Company's proposed amendment to the Technical Specifications to delete the rod index curves and power imbalance envelope from the Technical Specifi cations and put them into a core operations limits report. The licensee would then be able to revise the report without prior NRC review and approval.
This concept would set a precedent for the industry. The list of participants is included as Enclosure 1. A description of the affected Technical Specifications is to be included as Enclosure 2 and the licensee's agenda and viewgraphs has been incorporated as Enclosure 3.
Summary In the meeting, both the technical and legal aspects of the proposed amendment to the Technical Specifications was discussed. The licensee had proposed this concept in a submitted dated June 30, 1986.
The staff discussed its concerns with the licensee. Legally, either a TS change is required or if no NRC prior approval is needed, then it may be performed under the auspices of 10 CFR 50.59. The licensee stated that they will go back to their headquarters and rethink the issue.
On November 14, 1986, the NRC staff sent a letter to Duke Power Company stating that the difficulties associated with the concept of removing the cycle specific parameters from the TS to eliminate the necessity of TS amendments with each cycle reload and instead submitting a core operating limits report with each cycle to the NRC staff for its information. A copy of the letter is attached as Enclosure 4.
Helen N. Pastis, Project Manager Project Directorate 11-3 Division of Reactor Projects-I/Il
Enclosures:
As stated cc: See next page PD#I -
DRP-I/II PD#
RP-I/II HPas mac BJYo n lood 04/
/87 04/4 87 8705010186 870427 PDR ADOCK 05000269 P
PDR I
Mr. H. B. Tucker Oconee Nuclear Station Duke Power Company Units Nos. 1, 2 and 3 cc:
Mr. A. V. Carr, Esq.
Duke Power Company Duke Power Company P. 0. Box 33189 Post Office Box 33189 422 South Church Street 422 South Church Street Charlotte, North Carolina 28242 Charlotte, North Carolina 28242 J. Michael McGarry, III, Esq.
Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W.
Washington, D.C. 20036 Mr. Robert B. Borsum Babcock & W-ilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 Manager, LIS NUS Corporation 2536 Countryside Boulevard Clearwater, Florida 33515 Senior Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, South Carolina 29678 Regional Administrator U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 3100 Atlanta, Georqia 30303 Mr. Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 Office of Intergovernmental Relations 116 West Jones Street Raleigh, North Carolina 27603 Honorable James M. Phinney County Supervisor of Oconee County Walhalla, South Carolina 29621 Attendance List Tor Meeting with Duke Power Company Concerning meormating Oconee Technical Specifications July 17, 1986 Name Position/Organization Helen N. Pastis NRC/NRR John F. Stolz NRC/NRR Conrad McCracken NRC/NRR Daniel Fieno NRC/NRR Cecil Thomas NRC/NRR Norm Lauben NRC/NRR George Papanic, Jr.
Yankee Atomic Electric Co.
Robert L. Perch NRC/NRR Marvin Dunenfeld NRR/RSB(A)
William H. Regan NRR/FOB(B)
Tony Cappucci NRR/FOB(B)
Eve Fotopoulos Serch Licensing Bechtel Bob Jansen Westinghouse Joe Randazzo GPU - TMI-1 G. L. Plumlee, III NRR/FOB M. H. Philips Duke Power J. M. McGarry Duke Power M. B. Fartile NRC/NRR/DPLA R. L. Gill Duke Licensing Paul Guill Duke Licensing Dick Clark Duke/Nuclear Design Bill Reckley Duke/Nuclear Safety Jerry N. Wilson NRC/NRR David L. Stucker Westinghouse -
NFD Joseph Scinto NRC/OGC Victor Benaroya NRR/PWR-A/FOB Jim Clifford NRR/PPAS/TOSB CONCEPT OF THE CORE OPERAT 'CS LIMITS PEPORT CONTPOL ROD GROUP AND POWER DISTRIBUTION LIMITS This specification applies to power distribution and operation of control rods during power operation. The TS assures an acceptable core power distribution during power operation, sets a limit on potential reactivity insertion from a hypothetical control rod ejection and assures core subcriticality after a reactor trip.
- 1. ROD INDEX CURVES (ROD POSITION LIMITS).
OBJECTIVE OF THE TS:
The rod position limits assure that an acceptable power distribution is maintained and that the potential effects of rod misalignment on associated accidents are minimized. The rod position limits are based on the most limiting of the following three criteria:
ECCS power peaking, shutdown marnin, and potential ejected rod worth.
Therefore, compliance with the -ECCS power peaking criterion is ensured by the* rod position limits. The minimum available rod worth, consistent with the rod position limits, provides for achieving hot shutdown by reactor trip at any time, assuming the highest worth control rod that is withdraw;n remains in the full out position.
The rod position limits also ensure that inserted rod groups will not contain single rod worths areater than C.C5%,IK/K at rated power and these values have been shown to be safe by safety analysis of hypothatical rod ejection accident.
LCO:
If the control rod position limits are exceeded, corrective measures shall be taken immediately to achieve an acceptable control rod position. An acceptable control rod position shall then be attained within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
The minimum shutdown margin shall be maintained at all times.
DUKE OBJECTIVE:
Remove the rod index curves and place them in the core operations limits report.
- 2.
POWER IMBALANCE ENVELOPE OBJECTIVE OF THE TS:
The power imbalance envelope is based on LOCA analyses which have defined the naximum linear heat rate so the maximum clad temperature will not exceed the Fnal Acceptance Criteria. Corrective measures must be taken immediately should the quadrant tilt, rod position, or imbalance are outside their specified boundary!.
LCO:
Reactor power imbalance shall be monitored or a frequency not to exceed two hours du rg rower operation above 4O rated power.
If the ipbalance is not within the envelope defined by the figures, corrective measures shall be taken to achieve an acceptable imbalance.
If it is not achieved in 2.hours, reactor power shall be reduced until the imbalance limits are met.
DUKE OJECTIVE:
Remove the power imbalence curves from the TS and plac them in the core operations limit-report.
AGENDA I INTRODUCTION II TECHNICAL CONSIDERATIONS III LICENSING CONSIDERATIONS IV CONCLUSIONS V NRC FEEDBACK VI ADJOURN
PURPOSE:
TO DISCUSS AND RESOLVE NRC CONCERNS IN REGARD TO THE RELOCATION OF THE CYCLE DEPENDENT ROD POSITION AND OPERATIONAL IMBALANCE CURVES.
OBJECTIVE:
TO OBTAIN NRC ACCEPTANCE OF THE PROPOSED AIENT CONCEPT AND TO liMPLEI1ff PROPOSED TECHNICAL SPECIFICATION AfENDME~T PRIOR TO THE START OF OCONEE 2 CYCLE 9 (OCTOBER 8, 1986)
CHIONOLOGY:
FEBRUARY 22, 1985 DUKE LETTER NOVEMBER 19, 1985 DUKE LETTER FEBRUARY 14, 1986 DUKE LETTER JUNE 30, 1986 DUKE LETTER
Reload Design Historical Summary Date Item 1968 Duke Management expresses desire to achieve reload design capability 1969-1971 Stoller Fuel Management Training 1971-1975 Oconee Core Calculations Using Stoller Codes 1974-1976 Oconee Core Calculations Using LEAHS Code System 1976 EPRI-ARMP Code System Initially Released 1976 Begin Nuclear Calculations at University Computing Company 1977 Kickoff meeting with Licensing and Nuclear Fuels to scope Reload Design Topical Report 1977-1979 Oconee Reload Design Methodology Report developed 23 APR 79 Reload Design Methodology Report NFS-1001 submitted to NRC 06 FEB 80 Presentation to NRC on Duke Reload Design Methodology 1980-1981 NFS-1001 Supplements and Revisions 29 JUL 81 NRC SER Received for Reload Design Methodology Report NFS-1001 14 DEC 81 B&W Technology Agreement Signed
Reload Design Historical Summary (Continued)
Date Item APR 82 0-3 C-7 Reload Report submitted JUL 82 0-3 C-7 Reload Report Rev. 1 submitted SEP 82 SER issued for 0-3 C-7 Reload Report & Technical Specifications OCT 82 0-3.C-7 Startup JAN 83 McGuire Reload Design Topical Meeting kickoff JAN 83 Duke-Westinghouse meeting on Fuel Mechanical Analysis JUL 84 Submitted to NRC McGuire/Catawba Nuclear Physics Methodology, DPC-NF-2010 NOV 84 -
DEC 84 NRC Questions and Answers on DPC-NF-2010 MAR 85 Received SER on DPC-NF-2010 APR 85 Submit to NRC Oconee Reload Design Methodology II, DPC-NE-1002.
MAY 85 -
JUN 85 NRC Questions and Answers on DPC-NE-1002 SEP 85 SER issued for DPC-NE-1002 NOV 85 Oconee 1 Cycle 10 Reload Report submitted using methods of DPC-NE-1002.
APR 86 NRC approves Oconee 1 Cycle 10 Technical Specifications MAY 86 Oconee 1 Cycle 10 Startup
Maneuvering Analysis FFCD T-H LOCA Mechanical Analysis Pin/Assembly DNBR Limits kw/ft Limits Centerline fuel melt Maneuvering Analysis
- 1. Depletion
- 2. Design Power Maneuvers 100-50-100 100-100-100
- 3. Rod and APSR Scans (Nominal, Min,,Max Xenon)
- 5. Develop RPS and Operating P-I limits
- 6. Develop Rod Index and APSR limits.
- 7. Error adjusted P-I, RI, APSR, tilt limits Non 50.59 50.59 Reload Report and Core Operating Technical Specifications Limit Report Core Operating Limit Report
III LICENSING CONSIDERATIONS 0
BENEFITS OF §50.59 REVIEWS o OVERVIEW OF PROPOSED TECHNICAL SPECIFICATION AMENDMENT 0
NSHC EVALUATION RESULTS o §50.36 REQUIREMENTS o SIMILARITIES TO OTHER.SPECIFICATIONS/ISSUES 0
CONSISTENT WITH TSIP EFFORTS
BENEFITS 0
550.59 REVIEW OF CORE RELOADS IS A DESIRABLE FEATURE WHICH HAS BEEN RECOGNIZED BY BOTH THE NRC AND INDUSTRY.
o PERFORMING §50.59 REVIEW FOR CORE RELOADS WILL RESULT IN CONSERVING NRC AND LICENSEE RESOURCES.
o §50.59 REVIEW WILL ASSURE THAT THERE ARE NO UNREVIEWED SAFETY QUESTIONS INVOLVED.
o REMOVAL OF CURVES FROM TECHNICAL SPECIFICATION TO A "REPORT" IS A METHOD WHICH WILL MINIMIZE IMPACT TO LICENSEE AND NRC.
OVERVIEW o
TW BASIC APPRDACHES TO ACHIEVING PART 50.59 REVIEWS FOR CORE RELOADS
- GENERIC CURVES
- COLR o
CORE SAFETY LIMITS AND RPS SETPOINTS REMAIN IN TECHNICAL SPECIFICATIONS o
JROD POSITION AND OPERATIONAL IMBALANCE CURVES ARE RELOCATED TO AN ADMINISTRATIVE CONTROLLED DOCUMENT.
o SPECIFICATIONS REGARDING CONTROL RODS AND POWER DISTRIBUTION REMAIN IN TECHNICAL SPECIFICATIONS.
o ACTION STATEIENT WHEN LIMITS ARE EXCEEDED REMAIN IN TECHNICAL SPECIFICATIONS.
o DEVELOPMENT OF LIMITS ARE BY NRC APPRDVED METHODS.
o CURVES ARE PROVIDED FOR STAFF EXAMINATION AND, IF NECESSARY, CONSULTATION PRIOR TO UTILIZATION.
NSHC RESULTS o PROPOSED AMENDMENT EVALUATED WITHIN THE CONTEXT OF THE STANDARDS SPECIFICED IN §50,92(c)
-FIRST STANDARD:
RELOCATION OF CURVES HAS NO IMPACT ON THE PROBABILITY OR CONSEQUENCES OF PREVIOUSLY EVALUATED ACCIDENT.
-SECOND STANDARD:
RELOCATION OF CURVES DOES NOT CREATE A NEW OR DIFFERENT ACCIDENT FROM ANY PREVIOUSLY EVALUATED ACCIDENT.
-THIRD STANDARD:
RELOCATION OF CURVES DOES NOT RESULT IN A REDUCTION IN A MARGIN OF SAFETY o BASIS INVOLVED IN EVALUATION
-STILL REQUIRE OPERATION WITHIN LIMITS
-ACTION STATEMENT REMAINS UNCHANGED
-DEVELOPMENT OF LIMITS ARE IN ACCORDANCE WITH NRC APPROVED METHODS
-AMPLE TIME IS PROVIDED FOR NRC REVIEW PRIOR TO IMPLEMENTATION.
§50.36 REQUIREMENTS o §50.36(c)(2) SAYS, IN PART, THE FOLLOWING:
"LIMITING CONDITIONS FOR OPERATION ARE THE LOWEST FUNCTIONAL CAPABILITY OR PERFORMANCE LEVELS OF EQUIPMENT REQUIRED FOR SAFE OPERATION OF THE FACILITY.
WHEN A LIMITING CONDITION FOR OPERATION OF A NUCLEAR REACTOR IS NOT MET, THE LICENSEE SHALL SHUT DOWN THE REACTOR OR FOLLOW ANY REMEDIAL ACTION PERMITTED BY THE TECHNICAL SPECIFICATION UNTIL THE CONDITION CAN BE MET."
o ACTION STATEMENTS REMAIN UNCHANGED BY PROPOSED TECHNICAL SPECIFICATION.
o PROPOSED AMENDMENT COMPLYS WITH REGULATORY REQUIREMENTS.
TSIP EFFORTS o PROPOSED AMENDMENT IS CONSISTENT WITH TSIP, o PROPOSED AMENDMENT WILL SIMPLIFY TECHNICAL SPECIFICATIONS AND.AMENDMENT PROCESS FOR CORE RELOADS WITHOUT IMPACTING
- SAFETY, o DUKE CONCURS WITH PRELIMINARY RESULTS THAT RODPOSITION AND POWER DISTRIBUTION SPECIFICATIONS NEED TO REMAIN IN TECHNICAL SPECIFICATIONS.
o PROPOSED AMENDMENT STILL MAINTAINS THE ROD POSITION AND POWER DISTRIBUTION SPECIFICATIONS WITHIN THE TECHNICAL SPECIFICATIONS.
SIMILARITIES REACTOR VESSEL SURVEILLANCE PROGRAM INSERVICE INSPECTION/INSERVICE TESTING PROGRAMS
- SECURITY PLANS 8MERGENCY PLANS
- ENVIRONiN.TAL QUALIFICATION PROGRAM POST-ACCIDENT SAMPLING PROGRAM STARTUP PHYSICS TEST PROGRAM
IV CONCLUSIONS o PROPOSED AM9ENDMENT:
- COMPLYS WITH REGULATORY REQUIREMENTS
- DOES NOT INVOLVE A SIGNIFICANT HAZARD CONSIDERATION
- DOES NOT IMPACT THE OPERATION OR SAFETY OF THE PLANT
- CONSISTENT WITH CURRENT NRC/INDUSTRY EFFORTS TO SIMPLIFY TECHNICAL SPECIFICATIONS o NRC REVIEW OF RELOAD TECHNICAL SPECIFICATION REVISIONS CONSISTS OF:
- REVIEW OF INPUTS/ASSUMPTIONS
- VERIFICATION OF 'ETHODOLOGY USED
- COMPARISON OF DATA/INFORMATION TO PREVIOUS RELOADS o METHODS USED IN THE DEVELOPMENT OF THE REQUIRED LIMITS AND IN THE PREPARATION OF THE CURVES SHALL CONFORM TO THOSE DESCRIBED IN NRC APPROVED DOCUMENTATION o BASED ON THE DISCUSSIONS, DUKE CONTENDS THAT THERE ARE NO VALID REASONS WHY THE PROPOSED AMN'DNENT SHOULD NOT BE APPROVED
00G UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 November 14, 1986 Dockets Nos. 50-269, 50-270 and 50-287 Mr. Hal B. Tucker Vice President - Nuclear Production Duke Power Company P. 0. Box 33189 422 South Church Street Charlotte, North Carolina 28242
Dear Mr. Tucker:
SUBJECT:
PROPOSED REMOVAL OF CERTAIN CYCLE-DEPENDENT CORE OPERATING LIMITS FROM THE TECHNICAL SPECIFICATIONS Re:
Oconee Nuclear Station, Units 1, 2 and 3 By letter dated June 30, 1986, you proposed a change to your Technical Specifications (TS) that would remove the cycle specific parameters from your TS to eliminate the necessity of TS amendments with each cycle reload.
You also stated that you would submit Core Operating Limits Reports with each cycle to the NRC staff for our information.
The staff has reviewed your proposed TS changes and finds that they cannot be approved under present NRC regulations because the process variables (i.e.,
moderator temperature coefficient, etc.) remaining in the TS are not sufficient to ensure that LOCA and rod ejection accident analyses assumptions, as well as core safety limits, are met, if controls on the rod insertion and/or power peaking limit curves are removed. However, the staff would be willing to consider alternative approachesfor controlling such process variables if you wish to propose them. One such approach would be to specify an approved method of calculating the numeric values of the process variables in the TS that would allow you to make changes to the values of the process variables without prior approval (i.e., license amendment) so long as the approved method is followed. The staff believes that these specific findings apply'to other similar cycle-dependent core operating limits (COLs) as well.
The staff must consider the following when reviewing, licensee requests to remove cycle-dependent COLs from TS:
- 1.
If the staff requires the review of any safety limit or curve change before its implementation, such a revision requires a license amendment.
- 2.
10 CFR 50.36 requires that safety limits and/or Limiting Conditions for Operations (LCOs) be placed on the process variables which are required for safe operation of the plant.
- 3. The staff's proposed policy for improving TS, delineated in SECY-86-10, "Recommendations for. Improving TS", states that a
-2 process variable which is an initial condition of a Design Basis Accident (DBA), or a structure, system or component that is part of the primary success path of a safety sequence analysis and functions or actuates to mitioate a DBA, must be controlled by LCO's in the TS.
This policy allows such process variables to be controlled by specifying them numerically in the TS or by specifyina the method of calculating their numerical values if the staff finds that the method provides adequate assurance that the correct limits will be followed in operating the plant.
If you have any questions, please do not hesitate to contact your Project Manager.
- incerelY, o F. Stolz, Director PW Project Directorat #6
'vision of PWP Licensing-B cc:
See next page
MEETING
SUMMARY
DISTRIBUTION Docket File APR 2 7 1987 NRC Participants NRC PDR H. Pastis L PDR J. Stolz NSIC C. McCracken PRC System D. Fieno PD#II-3 Rdg C. Thomas Project Manager H. Pastis N. Lauben M. Duncan R. Perch OGC-Bethesda M. Dunenfeld ACRS (10)
W. Regan T. Cappucci G. Plumlee, III M. Fartile J. Wilson OTHERS J. Sci.nto V. Benaroya J. Clifford bcc:
Licensee & Service List