ML18299A049

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Accident Analyses Methodology Transition LAR Public Meeting
ML18299A049
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 10/30/2018
From:
Westinghouse
To:
Office of Nuclear Reactor Regulation
Singal B, NRR/DORL/LPL4-1, 415-3016
References
EPID L-2017-LLA-0211
Download: ML18299A049 (14)


Text

Accident Analyses Methodology Transition LAR Public Meeting October 30, 2018 1

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

Opening Remarks

Purpose:

- Timely Resolution of RAI documented within ADAMS Accession No. ML18270A094 Agenda:

- Introduction

- License Amendment Request (LAR) Description

- Submittal Timeline

- Thermal Conductivity Degradation Methodology Changes

- LAR Completion

- Conclusion 2

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

Introduction Wolf Creek and Westinghouse are focused and committed to complete the Transition program Recent requests for additional information puts the LAR schedule at significant risk Discussion today is to agree upon approach for timely implementation of the transition to Westinghouse methods

- Providing potential options for consideration

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

License Amendment Request (LAR) Description

The transition to Westinghouse core design and safety analyses methodologies is being performed to utilize current methodologies and provide more consistent alignment with the Westinghouse fleet of plants

Wolf Creek safety analyses methodologies and analyses of record are roughly 20 years old and this transition will bring Wolf Creek up to the latest industry best practices as well as closing all open issues

Furthermore, Wolf Creek was facing depleted core design and safety analysis engineering experience and capability within Nuclear Engineering in addition to the ongoing difficulties associated with hiring, retaining, and training personnel to update and maintain the safety analysis Transition to updated methodologies is paramount for Wolf Creek long term successful operation

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

Submittal Timeline

August 2016 - Transition pre-submittal meeting with the NRC

January 2017 - Transition LAR re-submitted to the NRC for review

May 2017 - Transition LAR accepted for review

June - December 2017 - Multiple RAIs received

January 2018 - P-A version of PAD5 Topical Report issued

April 2018 - NRC audit to facilitate RAI response

September 2018 - Draft RAIs related to TCDs received

October 2018 - Final TCD RAIs received

May 2019 - Target NRC approval of the Transition program Collaboration amongst NRC, WCNOC, and Westinghouse is needed to support desired approval timeline

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

Thermal Conductivity Degradation Methodology Changes

NRC requested additional information on two safety analysis events (Rod Ejection and Steamline break) regarding appropriately including the effects of thermal conductivity degradation (TCD)

While the transition LAR referenced the TCD safety evaluation (LTR-NRC-12-18), the NRC has requested additional information to comply with GDC27 and GDC28

To support the RAI response for a timely approval of the transition LAR, WCNOC recommends a descriptive evaluation and quantitative examples to address thermal conductivity degradation

- Originally submitted transition analyses supported by LTR-NRC-12-18 conclusions will form the licensing basis

- Results will demonstrate that the acceptance criteria for the Rod Ejection and Steamline break events are met when accounting for TCD Rationale behind proposed RAI response requires a proprietary discussion

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

7 Closed Portion

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

8 Westinghouse Non-Proprietary Class 3

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

This slide is left intentionally blank

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

9 Westinghouse Non-Proprietary Class 3

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

Technical Interfaces for PAD5 Implementation a,c

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

10 Westinghouse Non-Proprietary Class 3

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

Thermal Conductivity Degradation Methodology Changes Explicitly accounting for TCD in the licensing basis within the RAI referenced analyses requires the following:

- Rod Ejection and Steamline break analyses provide part of the basis for fuel centerline melt Technical Specification (TS) Safety Limit (SL) 2.1.1.2 Explicitly accounting for TCD in the Westinghouse methodology can only be accomplished with PAD5 Use of PAD5 in the re-analyses of the events described in the RAIs may incur relaxation of the current TS SL 2.1.1.2 value If this is the case, all other not-LOCA analyses that support the basis of TS SL 2.1.1.2 would also require re-analysis WCAP-17642-P-A provides a basis for crediting a relaxed fuel centerline temperature limit

- Due to the timing of the question and consistent with the Westinghouse-NRC January 2018 (LTR-NRC-18-7) discussion, a full Not-LOCA PAD5 transition cannot be completed within the current license amendment review timeframe

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

11 Westinghouse Non-Proprietary Class 3

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

Explicitly accounting for TCD in the licensing basis within the RAI referenced analyses requires the following (cont.):

- Performance of limited TS SL 2.1.1.2 analyses with PAD5 is not a viable option Per Westinghouse NRC letter LTR-NRC-16-57, PAD5 implementation [

]a,c Thermal Conductivity Degradation Methodology Changes

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

12 Westinghouse Non-Proprietary Class 3

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

LAR Completion With these considerations, the following is recommended to complete the Transition LAR on the desired schedule

- Descriptive evaluation and quantitative examples to address thermal conductivity degradation Evaluation and example analysis results will demonstrate that the acceptance criteria for the Rod Ejection and Steamline break events are met when accounting for TCD

- Supports a transition implementation date coincident with the Fall 2019 Refuel Expect to meet the 2 year review goal

- As discussed during the RAI clarification call, when addressing the rod ejection analysis, the current calorie per gram limit will be retained

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

13 Westinghouse Non-Proprietary Class 3

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

LAR Completion Alternatively, the following allows for implementation of TS SL 2.1.1.2 limit change as part of the Transition LAR but outside of the desired schedule

- Results of the Rod Ejection and Steamline break events will be provided in the RAI responses

- All analyses that support the fuel melt TS limit will be revised to explicitly account for TCD

- Full Not-LOCA PAD5 implementation will be introduced into the licensing basis via 50.59

Due to reload schedule requirements associated with cycle-specific planning and consistent with Turkey Point (ML18086A154, March 2018), implementation of PAD5 Not-LOCA will occur upon completion of required analysis effort on a forward fit basis by no later than the next reload campaign following approval of the Transition program LAR

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)

14 Westinghouse Non-Proprietary Class 3

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

Conclusion The transition to Westinghouse core design and safety analyses methodologies is being performed to utilize current methodologies and provide more consistent alignment with the Westinghouse fleet of plants TS SL 2.1.1.2 introduces complexities in responding to the TCD RAIs Concurrence on RAI response approach is required to ensure timely method transition approval WCNOC is committed to transitioning to Westinghouse methods

      • This record was final approved on 10/25/2018 6:03:10 PM. (This statement was added by the PRIME system upon its validation)