ML19232A085
| ML19232A085 | |
| Person / Time | |
|---|---|
| Site: | 99901376 |
| Issue date: | 08/29/2019 |
| From: | Dennis Morey Division of Licensing Projects |
| To: | Michelle Catts GE-Hitachi Nuclear Energy Americas |
| Joseph Golla, NRR/DLP/PLPB, 415-1002 | |
| References | |
| EPID L-2018-TOP-0038 | |
| Download: ML19232A085 (12) | |
Text
August 29, 2019 Ms. Michelle P. Catts Senior Vice President, Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC P.O. Box 780 M/C A-10 Wilmington, NC 28401
SUBJECT:
FINAL SAFETY EVALUATION FOR GLOBAL NUCLEAR FUEL -
AMERICAS, LLC, PROPOSED AMENDMENT 47 TO NEDE-24011-P-A-27, GENERAL ELECTRIC STANDARD APPLICATION FOR REACTOR FUEL (GESTARII) SUPPORTING IMPLEMENTATION OF TSTF-564 (EPID NO. L-2018-TOP-0038)
Dear Ms. Catts:
By letter dated September 12, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18256A013), Global Nuclear Fuel - Americas, LLC (GNF) submitted Proposed Amendment 47 to NEDE-24011-P-A-27, General Electric Standard Application for Reactor Fuel (GESTARII) Supporting Implementation of TSTF-564, to the U.S.
Nuclear Regulatory Commission (NRC) staff for review.
By letter dated July 25, 2019, an NRC draft safety evaluation (SE) (ADAMS Accession No. ML19184A109) regarding our approval of Proposed Amendment 47 to NEDE-24011-P-A-27, was provided for your review and comment. By letter dated August 15, 2019 (ADAMS Accession No. ML19228A187), you provided your comments on the draft SE.
The comments have been resolved and the proprietary information identified by you has been removed from the SE.
The NRC staff has found that Proposed Amendment 47 to NEDE-24011-P-A-27 is acceptable for referencing in licensing applications for nuclear power plants to the extent specified and under the limitations delineated in the Topical Report (TR) and in the enclosed final SE. The final SE defines the basis for our acceptance of the TR.
Our acceptance applies only to material provided in the subject TR. We do not intend to repeat our review of the acceptable material described in the TR. When the TR appears as a reference in licensing applications, our review will ensure that the material presented applies to the specific plant involved. License amendment requests that deviate from this TR will be subject to a plant-specific review in accordance with applicable review standards.
M. Catts In accordance with the guidance provided on the NRC website, we request that GNF publish the approved Amendment 47 to NEDE-24011-P-A-27, within three months of receipt of this letter.
The approved version shall incorporate this letter and the enclosed final SE after the title page.
The approved versions shall include a "-A" (designating approved) following the TR identification symbol.
If future changes to the NRCs regulatory requirements affect the acceptability of this TR, GNF will be expected to revise the TR appropriately or justify its continued applicability for subsequent referencing. Licensees referencing this TR would be expected to justify its continued applicability or evaluate their plant using the revised TR.
Sincerely,
/RA/
Dennis C. Morey, Chief Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 99901376
Enclosure:
Final SE
ML19232A085 *concurrence via e-mail NRR-106 OFFICE NRR/DLP/PLPB/PM NRR/DLP/PLPB/LA* NRR/DSS/SNPB/BC NRR/DLP/PLPB/BC NAME JGolla DHarrison RLukes* DMorey DATE 8/26/2019 8/22/2019 8/29/2019 8/29/2019 Global Nuclear Fuel - Americas Project No. 712 Docket No. 99901376 cc:
Ms. Michelle P. Catts Senior Vice President, Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC P.O. Box 780 M/C A-10 Wilmington, NC 28401 Michelle.Catts@ge.com Mr. Kent E. Halac Senior Project Manager, Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC P.O. Box 780, M/C A-70 Wilmington, NC 28401-0780 Kent.Halac@ge.com Dr. Brian R. Moore General Manager, Core & Fuel Engineering Global Nuclear Fuel-Americas, LLC P.O. Box 780, M/C A-75 Wilmington, NC 28401-0780 Brian.Moore@ge.com
OFFICE OF NUCLEAR REACTOR REGULATION FINAL SAFETY EVALUATION FOR AMENDMENT 47 TO GLOBAL NUCLEAR FUEL - AMERICAS TOPICAL REPORT NEDE-24011-P-A-27 GENERAL ELECTRIC STANDARD APPLICATION FOR REACTOR FUEL (GESTAR II) TO SUPPORT IMPLEMENTATION OF TSTF-564 (EPID: L-2018-TOP-0038)
1.0 INTRODUCTION AND BACKGROUND
By letter dated September 12, 2018, Global Nuclear Fuel - Americas, LLC (GNF) submitted proposed Amendment 47 to Topical Report (TR) NEDE-24011-P-A-27, General Electric Standard Application for Reactor Fuel (GESTAR II) To Support Implementation of TSTF-564, to the U.S. Nuclear Regulatory Commission (NRC) staff for review (Ref. 1).
In Amendment 47, GNF requests to amend GESTAR II to provide the process and methodology elements to implement TSTF-564. TSTF-564 modifies the definition of the Technical Specification Safety Limit Minimum Critical Power Ratio such that it is no longer cycle-specific.
The original request for TSTF-564 was subsequently modified in response to NRC requests for additional information (RAIs). These revisions are consistent with process and methodology elements that have been documented by plant license amendment requests in past years.
Traveler TSTF-564, Revision 2, proposed changes to the standard technical specifications for boiling water reactor (BWR) designs. These changes will be incorporated into future revisions of NUREG-1433 and NUREG-1434. Associated changes were also made to the technical specifications (TS) bases. The proposed changes revise the basis, calculational method, and the value of the TS safety limit (SL) 2.1.1.2, which protects against boiling transition (BT) on the fuel rods in the core. The current basis ensures that 99.9 percent of the fuel rods in the core are not susceptible to BT. The revised basis will ensure that there is a 95 percent probability at a 95 percent confidence level that no fuel rods will be susceptible to BT using an SL based on critical power ratio (CPR) data statistics. Technical Specification 5.6.3, Core Operating Limits Report
[(COLR)], is also modified.
GNF requested that the NRC review and approve proposed Amendment 47 to GESTAR II and is applied to all BWR plants for which GNF provides reload fuel and licensing.
2.0 REGULATORY EVALUATION
The TS SL value and method of calculation for the minimum CPR (MCPR) limit, SL 2.1.1.2, is revised for BWR plants using Global Nuclear Fuel. The revised calculation method is based on CPR data statistics ensuring 95 percent probability at a 95 percent confidence level that no fuel rods will be susceptible to BT instead of the previous basis that ensures 99.9 percent of the fuel rods in the core are not susceptible to BT.
Enclosure
Traveler TSTF-564, Revision 2, proposed a method for determining a revised, cycle-independent MCPR SL for any BWR fuel applicable to all BWR designs. The original MCPR SL, referred to in Traveler TSTF-564, Revision 2, as the MCPR99.9% SL, ensures that 99.9 percent of the fuel in the core is not susceptible to boiling transition. The revised MCPR SL, referred to in Traveler TSTF-564, Revision 2, as the MCPR95/95 SL, ensures there is a 95 percent probability at a 95 percent confidence level that no fuel rods will be susceptible to transition boiling.
Applicable General Design Criterion 10, Reactor design, of Title 10 of the Code of Federal Regulations Part 50 Appendix A, General Design Criteria of Nuclear Power Plants, states:
The reactor core and associated coolant control and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.
The limit placed on the MCPR acts as a specified acceptable fuel design limit to prevent BT, which has the potential to result in fuel rod cladding failure.
An applicable guidance Section 4.4, Thermal and Hydraulic Design, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:
LWR Edition (SRP) provides acceptance criteria for establishing fuel design limits such as:
A. For departure from nucleate boiling [(DNB)] ratio (DNBR), CHFR [critical heat flux ratio] or CPR correlations, there should be a 95-percent probability at the 95-percent confidence level that the hot rod in the core does not experience a DNB or boiling transition condition during normal operation or AOOs [anticipated operational occurrences].
B. The limiting (minimum) value of DNBR, CHFR, or CPR correlations is to be established such that at least 99.9 percent of the fuel rods in the core will not experience a DNB or boiling transition during normal operation or AOOs.
3.0 TECHNICAL EVALUATION
3.1 Introduction In Amendment 47, GNF requests to amend GESTAR II to provide the process and methodology elements to implement TSTF-564. TSTF-564 modifies the definition of the TS MCPR such that it is no longer cycle-specific. The NRC staff approved the TSTF-564, Revision 2, in Reference 1. Traveler TSTF-564, Revision 2, is applicable to BWR nuclear power plants. The proposed change revises Revision 4 of the STS, Volumes 1 and 2 of NUREG-1433, Standard Technical Specifications, General Electric Plants BWR/4, and NUREG-1434, Standard Technical Specifications, General Electric Plants BWR/6. Volume 1 of these NUREGs can be accessed in the Agencywide Documents Access and Management System (ADAMS) under Accession Nos. ML12104A192 and ML12104A195, respectively. Volume 2 of these NUREGs can be accessed in ADAMS under Accession Nos. ML12104A193 and ML12104A196, respectively. In accordance with the staffs approval of TSTF-564, GNF submitted an application (Ref. 1) in which GNF lists changes to GESTAR Sections 1 and 4 (Ref. 2) that provide the process and methodology elements to implement TSTF-564. This SE lists the changes to GESTAR II per the approval of TSTF-564.
3.2 GESTAR II Revisions for Amendment 47 3.2.1 GESTAR II Section 1.1.5 Safety Limit Minimum Critical Power Ratio For plants that have adopted TSTF-564, the TS Safety Limit MCPR is cycle independent as described in Reference 4 as approved by the staff. TSTF-564 uses the term SLMCPR95/95 to define the cycle independent SL that will be applied in TS 2.1.1.2. The cycle-specific SLMCPR is termed MCPR99% and shall be included in the cycle-specific COLR. The methodology for calculating the cycle-specific SLMCPR is included in Sections 1.2.5 and 4.3.1.1 of Reference 2.
The proposed cycle-independent TS safety limit (MCPR95/95) values for fuel product lines GE14, GNF2, and GNF3 are included in Table 1 of TSTF-564.
Table 1 Proposed MCPR95/95 Values by Vendor and Fuel Bundle Type.
Vendor Fuel Type Proposed MCPR95/95 Global Nuclear Fuel GE14 1.06 Global Nuclear Fuel GNF2 1.07 Global Nuclear Fuel GNF3 1.07 Westinghouse Optima2 1.06 The methodology for developing SLMCPR95/95 is described in Section 3.1 of TSTF-564.
For plants that have NOT adopted TSTF-564, the TS SLMCPR shall be a cycle-specific SLMCPR, as described in GESTAR Sections 1.2.5 and 4.3.1.1.
3.2.2 GESTAR Section 1.1.7 Critical Power Correlation The addition to this section of GESTAR II is regarding the double-hump (DH) power shape that may exist in cycle core designs. The critical power (CP) correlations (CPCs) developed using the process in Section 1.1.7 have been shown to be non-conservative, and therefore, specific analyses are used to estimate a bounding effect on the basis and uncertainty.
3.2.3 GESTAR II Section 1.2.5 Safety Limit Minimum Critical Power Ratio Section 1.2.5 of GESTAR II (Ref. 2) provides information on cycle-specific SLMCPR calculations. Amendment 47 adds item number viii to this section regarding analyses that are performed at maximum extended load line analysis (MELLLA) and maximum extended load line analysis plus (MELLLA+) core power low consistent with the licensed domain boundary.
- 1. Non-MELLLA+ Plants with Minimum Core Flow 99%: Rated Core Power / Rated Core Flow
- 2. Non-MELLLA+ Plants with Minimum Core Flow <99%: Rated Core Power / Rated Core Flow, and Rated Core Power / Minimum Core Flow
- 3. MELLLA+ Plants: Rated Core Power / Rated Core Flow, Rated Core Power / Increased Core Flow, Rated Core Power / Minimum Core Flow, and Off-Rated Core Power at Minimum Core Flow on MELLLA+ boundary Also, this section is amended to include bias and uncertainty when a DH power shape is identified during the determination of cycle-specific SLMCPR.
3.2.4 GESTAR II Section 1.2.7 Critical Power Correlation Section 1.2.7 of GESTAR II (Ref. 2) establishes criteria for currently approved CPCs and for any new correlation that must be established if significant new data exists for any new fuel designs.
An additional subsection (D) is added to this GESTAR II Section 1.2.7 to describe a methodology if a DH axial shape exists. Because there is insufficient data for DH shape, an improved statistical approach similar to the one in Section 1.1.7 of GESTAR II is developed and the documentation is provided in subsection D of Section 1.2.7 of GESTAR II.
3.2.5 GESTAR II Section 4.3.1 Critical Power Section 4 of GESTAR II (Ref. 2) describes various thermal-hydraulic design aspects of the reactor core and the reactor coolant system based upon the objective of no fuel damage during AOOs or during normal operation. Section 4.3.1 of GESTAR II provides information on the fuel cladding integrity SL statistical model; the MCPR operating limit calculational procedure for AOO pressurization events, AOO slow events, rod withdrawal error calculation; MCPR uncertainty considerations; low flow and low power effects on MCPR; and end-of-cycle coastdown considerations. GNF has modified the introduction to Section 4.3.1 by adding the same text as in Section 1.1.5 of GESTAR II (See Section 3.2.1 of this SE).
3.2.6 GESTAR II Sections 4.3.1.1.2, 4.3.1.1.3, and 4.3.1.1.4 Boiling Water Reactor Statistical Analysis Section 4.3.1.1.2 is modified to include a statement that uncertainties in MCPR are confirmed during the cycle specific analysis process by the plants. The plants may elect to use larger uncertainties during this process.
Section 4.3.1.1.2 modification also includes a directive for plants licensed for operation in the MELLLA+ extended operating domain (Ref. 5), that the required core power and core flow state points and associated uncertainties are defined in Reference 5. Additional margin for such plants with MELLLA+ operation may also be required per the SE for Reference 6.
A new subsection 4.3.1.1.3 has been introduced in GESTAR II as Methodology Restrictions.
This section reiterates four restrictions that were listed in the SE for TRs, NEDC-32601-P, NEDC-32694P, and Amendment 25 to GESTAR II. These four restrictions were addressed for GE14 in FLN-2001-1016, for GNF2 in section 3.6 of its GESTAR II compliance report and for GNF3 in Section 3.6 of its GESTAR II compliance report. The four restrictions from NEDC-32601P TR SE are listed below:
- 1. The TGBLA fuel rod power calculational uncertainty should be verified when applied to fuel designs not included in the benchmark comparisons of Table 3.1 of NEDC-32601-P, since changes in fuel design can have a significant effect on calculation accuracy.
- 2. The effect of the correlation of rod power calculation uncertainties should be reevaluated to insure the accuracy of R-Factor uncertainty when the methodology is applied to a new fuel lattice.
- 3. In view of the importance of MIP criterion and its potential sensitivity to changes in fuel bundle designs, core loading, and operating strategies, the MIP criterion should be reviewed periodically as part of the procedural review process to ensure that the specific value recommended in NEDC-32601-P is applicable to future designs and operating strategies.
- 4. The 3D-MONICORE bundle power calculational uncertainty should be verified when applied to fuel and core designs not included in the benchmark comparisons in Tables 3.1 and 3.2 of NEDC-32694P.
A new subsection 4.3.1.1.4 is added to GESTAR II for deviations from NEDC-32601P (Ref. 7) for the following items:
- 1. R-Factor The GEXL R-Factor uncertainty was increased from 1.6 percent to 2.0 percent to account for an increase in channel bow due to the phenomenon called control blade shadow corrosion induced channel bow.
- 2. Core Flow Rate and Random Effective TIP Reading Per Section 1.1.5 of GESTAR II, analyses are performed at core power/flow points consistent with the domain boundary and Section 1.2.5 presents general guidance for the core power and flow state points to be analyzed. At each state point, the analysis is performed using an approved SLMCPR methodology. For the Two Loop Operation calculations performed at less than 99 percent core flow, the approved uncertainty values for the core flow rate (2.5%) and the random effective Traversing In-Core Probe reading (1.2%) are conservatively adjusted by dividing them by the percent core flow/100. For example:
Core Flow Rate Uncertainty at 90% Core Flow = 100%*2.5%/90% = 2.78%
For Single Loop Operation (SLO), the minimum core flow SLMCPR analysis remains the same as in the rated flow SLO SLMCPR analysis since these uncertainties already account for the effects of operating at reduced core flow.
- 3. Flow Area Uncertainty Flow area uncertainty calculations for GE14, GNF2, and GNF3 are performed using the process described in Section 2.7 of Reference 7. This recalculation determined that the flow area uncertainty for GE14, GNF2, and GNF3 is larger than the Reference 7 value of 2.0 percent. If the flow area uncertainty using methodology of Reference 7 is greater than 2 percent, then it shall be documented in the GESTAR II Compliance Report for that product and used in the cycle specific SLMCPR calculations.
3.2.7 Summary In summary, Amendment 47 that supports the implementation of TSTF-564 has been reviewed by the NRC staff which determined that the changes to GESTAR II are in accordance with the approved TSTF-564.
4.0 LIMITATION AND CONDITION Amendment 47 to GESTAR II shall be applied to all BWR plants for which GNF provides reload fuel and licensing.
5.0 CONCLUSION
The staff reviewed the documents related to the proposed GESTAR II Amendment 47 which describes implementation of TSTF-564 which modifies the definition of TS SLMCPR. TSTF-564 revises the TS SL value and method of calculation for the MCPR limit, TS 2.1.1.2 for BWR plants. The staff has reviewed the documents pertaining to TSTF-564 and its implementation in Amendment 47 to GESTAR II. The staff determined that Amendment 47 to GESTAR II has complied with the approved TSTF-564 and therefore is acceptable for adoption by licensees subject to the condition specified in Section 4.1.
6.0 REFERENCES
- 1. Letter, M180100 from Brian Moore (GNF- A) to US NRC, Proposed Amendment 47 to NEDE-24011-P-A-27, General Electric Standard Application for Reactor Fuel (GESTAR II) Supporting Implementation of TSTF-564, September 12, 2018, ADAMS Accession No. ML18256A012
- 2. NEDE-24011-P-A-27, General Electric Standard Application for Reactor Fuel (GESTAR II), Global Nuclear Fuel, August 2018.
- 3. Technical Specification Task Force (TSTF) TSTF-18-12, Attachment 1 TSTF Comments on TSTF-564 Draft Safety Evaluation, Attachment 2, TSTF Markup Safety Evaluations, Enclosure TSTF-564 Revision 2, Boiling Water Reactor Owners Group, October 24, 2018.
- 4. USNRC Letter to Technical Specifications Task Force, Final Safety Evaluations of Technical Specifications Task Force Traveler TSTF-564, Revision 2, Safety Limit MCPR, Using the Consolidated Line Item Improvement Process, USNRC, November 16, 2018, ADAMS Package Accession No. ML18299A048.
- 5. NEDC-32006P-A, Revision 3 General electric Boiling Water Reactor, Maximum Extended Load Line Limit Analysis Plus, General Electric, June 2003.
- 6. NEDC-33173P-A Revision 4, Licensing Topical Report Applicability of GE Methods to Expanding Operating Domains, General Electric, June 2009.
- 7. NEDC-32601P-A, Methodology and Uncertainties for Safety Limit MCPR Evaluations, General Electric, August 1999.
Attachment:
Resolution of Comments Principal Contributor: Mathew M. Panicker NRR/DSS/SNPB Date: August 29, 2019
Comment Summary for Draft Safety Evaluation for Proposed Amendment 47 to NEDE-24011-P-A-27, General Electric Standard Application for Reactor Fuel (GESTAR II)
Supporting Implementation of TSTF-564 Note: Page numbers in this table reflect the page numbers in Enclosure 1 of the Global Nuclear Fuel response to the NRC Draft Safety Evaluation (SE) of Proposed Amendment 47.
Location Comment NRC Disposition Section 1.0 Page 2: Comment accepted.
Introduction and Line 17 refers to the incorrect revision of Background GESTAR. This change is in relation to Revision 27 of GESTAR.
Section 3.2.3 Page 5: Comment accepted.
GESTAR II Lines 1 through 14 describe a change that is Section 1.2.2 already found in Revision 27 of GESTAR. Note: The GNF Thermal Recommend removal of this section of the SE. response to the Draft Mechanical SE indicates with brackets the identification of information on page 5, lines 7 through 13 as being proprietary.
Since this comment is accepted by the NRC, that information has been deleted from the SE and at this point is therefore moot.
Further, the SE contains no other information identified by GNF as proprietary.
Section 6.0 Page 8: Comment accepted.
References Lines 8 and 9 for Reference 2 should be revised to Revision 27 of GESTAR published in August 2018.
Attachment