ML20081J622
| ML20081J622 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek |
| Issue date: | 03/22/1995 |
| From: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-95-0052, WM-95-52, NUDOCS 9503280069 | |
| Download: ML20081J622 (16) | |
Text
4 4-W$LF CREEK
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NUCLEAR OPERATING CORPORATION Neil S. " Buzz" Carns Chairman, Presdent and Chef Executw OMicer March 22, 1995 WM 95-0052 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C.
20555
Subject:
Docket No. 50-482: 10 CFR 50.46 Atuu al Report of ECCS Model Revisions Gentlemen:
This letter describes revisions to the Emergency Core Cooling System (ECCS).
Evaluation Models and the estimated effect on the limiting ECCS analysis for Wolf Creek r,enerating Station (WCGS) in accordance with the criteria and rep. rt. ing requirements of 10 CFR 50.46 (a) (3) (i) and (ii), as clarified in Sectiot 5,1 of WCAP-13541, " Westinghouse Methodology for ' Implementation of 10 CFR r3.46 Reporting." The changes in calculated Peak Cladding Temperatures (PCT) due to the revisions of Westinghouse ECCS Evaluation Models are repe>rt.able per 10 CFR 50.46 guidelines as follows:
1.
For Large Break Loss of Coolant Accident (LOCA), the net PCT effect of the Evaluation Model revisions is O degrees Fahrenheit ("F), for a net PCT of 1955.2*F which remains less than the 10 CFR 50.46 limit of 2200*F.
2.
For Small Break LOCA, the net PCT effect of the Evaluation Model revisions is + 3 8'F, for a net PCT of 157 0. 6*F which remains less than the 10 CFR 50.46 limit of 2200"F.
Attachment I describes the impact of the ECCS Evaluation Model changes.
Attachment II contains the calculated Large Break LOCA and Small Break LOCA PCT margin allocations resulting from the permanent changes to the Evaluation j
Models.
Since the PCT values determined in the Large Break and Small Break i
.LOCA analysis of record, which combined with all PCT margin allocations, remain well below the 22 00*F regulatory limit, no reanalysis will be performed.
I 9503280069 950322 i
PDR ADOCK 05000482 p
\\I P O. Box 411/ Burkngton. KS 66839 / Phe i (316) 364-8831 An Equal Opportunity Employr #F/HC/ VET l
WM 95-0052 Page 2 of 2 If you have any questions concerning this matter, please call me at (316) 364-8831, extension 4100, or Mr. Richard D. Flannigan at extension 4500.
Very truly yours, cs_=
Neil S.
Carns NSC/jra Attachments cc:
L. J.
Callan (NRC), w/a D.
F. Kirsch (NRC), w/a J.
F. Ringwald (NRC), w/a J.
C.
Stone (NRC), w/a 1
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' "Attcchm nt I to WM 95 0052 e
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Paga l'of 11' 4
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ATTACHMENT I l
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CHANGES TO THE WESTINGHOUSE l
EMERGENCY CORE COOLING SYSTEM EVALUATION MODELS 1
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' Attachment I to WM 95-0052 Page 2 of 11 Annual 10 CFR 50.46 Report on Emergency Core Cooling System Evaluation Models Changes
1.0 INTRODUCTION
Wolf Creek Nuclear Operating Corporation (WCNOC) has reviewed the annual 10 CFR 50.46 summary report of Emergency Core Cooling System (ECCS) Evaluation Model changes that were implemented by Westinghouse during 1994.
The report i
includes information concerning changes to and errors discovered. in the Evaluation Models. The review concludes that the cumulative effect of changes to, or errors in the Evaluation Models on the limiting transient Peak Cladding Temperature (PCT) is not significant.
Therefore, reporting of the ECCS Evaluation Model changes could be submitted on an annual basis according to i
the reporting requirements set forth in 10 CFR 50.46 (a) (3) (ii).
Attachment II provides an update of PCT margin rack-up for Wolf Creek Generating Station (WCGS).
The PCT margin rack-up demonstrates that i
compliance with the requirements of 10 CFR 50.46 are maintained considering the combined effects of the ECCS Evaluation Model changes with the plant design changes performed under 10 CFR 50.59.
2.O EVALUATION MODEL CHANGES t
The following sections describe the nature of each change or error and its estimated effect on the calculated PCT for the limiting ECCS analysis.
l 2.1 BOILING HEAT TRANSFER CORRELATION ERRORS
Background
This closely related set of errors deals with how the mixture velocity is defined for use in various boiling heat transfer regime correlations.
'The previous definition for mixture velocity did not properly account for drift and slip effects calculated in NOTRUMP.
This error particularly af f ected i
NOTRUMP calculations of heat transfer coefficient when using the Westinghouse Transition Boiling Correlation and the Dougall-Rohsenow Saturated Film Boiling Correlation.
In addition, a minor typographical error was also corrected in the Westinghouse Transition Boiling Correlation.
This was determined to be a Non-Discretionary Change as described in Section 4.1.2 of WCAP-13451,
" Westinghouse Methodology for Implementation of 10 CFR 50.46 Reporting," and was corrected in accordance with Section 4.1.3 of WCAP-13451.
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95-0052
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Att"chment I to WM
'Page 3 of 11 I
- 1 Affected Evaluation Model j
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.1985.Small Break LOCA Evaluation Model I
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- Estimated Effect j
Representative plant calculations for this issue resulted in an estimated PCT effect of -6' degrees Fahrenheit (*F) for WCGS.
4 2.2 STRAM LINE ISOLATION LOGIC ERRORS Backaround
'This error consists of two portions:
a possible plant specific effect which only applies to analyses which assumed Main Feedwater Isolation (FWI) to occur on a Safety Injection Signal (SIS), and a generic effect applying to all previous analyses.
The possible plant specific effect was the result of incorrect logic which caused the main steam line isolation to occur on the same signal. as FWI..
k Therefore, when the SIS was chosen through user input to be the appropriate signal for FWI, it also caused the steam line isolation to occur on an SIS.
This is inconsistent with the standard conservative assumption of steam line isolation on Loss of Offsite Power coincident with the earlier Reactor. Trip signal.
The generic effect was the result of incorrect logic which always led to the isolation functions occurring at a slightly later time than when' the appropriate signal was generated.
This was determined to be a Non-Discretionary Change as described in Section j
4.1.2 of WCAP-13451 and was corrected in accordance with Section 4.1.3 of i
Affected Evaluation Model 1985 Small Break LOCA Evaluation Model l
Estimated Effect Representative plant calculations for this issue resulted in an estimated PCT effect of +18'F for the generic portion.
The estimated PCT effect of +12 F for the plant specific portion does not apply to WCGS because the standard conservative assumption of steam line isolation on Loss of Offsite Power coincident with the reactor trip signal was assumed in the current licensing basis analysis.
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'Attachm2nt I to WM 95-0052 Paga 4 of 11 2.3 CORE NODE EIRCONIUM OXIDE INITIALIZATION ERROR
-j Backaround NOTRUMP models two regions for each core node analogous to the two (mixture a
and ' vapor) regions in adjoining-fluid nodes.
During the course of a transient, NOTRUMP tracks region specific quantities for each core node, l
Erroneous logic caused incorrect initialization of the region specific, fuel I
cladding zirconium oxide thickness at times prior to the actual creation of the relevant region during the core boil-off transient.
This was determined to be a Non-Discretionary Change as described in Section t
4.1.2 of WCAP-13451 and was corrected in accordance with Section 4.1.3 of l
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Affected Evaluation Model 1985 Small Break LOCA Evaluation Model Estimated Effect Representative plant calculations led to an estimated generic PCT effect of 0*F for this effect.
2.4 CODE STREAM IMPROVEMENT
Background
Revisions were made to the procedures used to interface the various codes that comprise the entire execution stream for performing a Large Break LOCA analysis with the BASH Evaluation Model.
The previous use of the coupled WREFLOOD/ COCO code for calculating containment pressure response, which was then transferred as a boundary condition to the BASH code, has been replaced with direct coupling of the BASH and COCO codes such that the same code used to calculate the Reactor Coolant System conditions during reflood, also supplies the boundary conditions for the containment pressure calculation.
In conjunction with this, the portion of the WREFLOOD code which calculated the refill phase of the transient has been reprogrammed into a separate, but identical code called REFILL, which is also coupled with COCO.
This methodology revision was made only as a process improvement for conducting analyses and involved no changes to the approved physical models, nor basic solution techniques governing the solutions provided by the individual computer codes.
The NRC was advised of the implementation of this methodology on a forward-fit basis via Reference 1.
Affected Evaluation Models I
1981 ECCS Large Break LOCA Evaluation Model with BASH I
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' Attachment I to WM 95-0052 Paga 5 of 11 Estimated Effect Due to small perturbations in the boundary conditions resulting from this revised methodology for interfacing the codes, small differences in predicted results were observed.
The effects were minor, with no observed bias.
Since this methodology is a process improvement which is to be implemented on a forward-fit basis, there are no effects on existing licensing analyses, and any small effects on results will be implicitly accounted for in future
. analyses.
Reference 1 Letter NTD-NRC-94-4143, " Change in Methodology for Execution of BASH Evaluation Model", NJ Liparulo (H) to WT Russell (NRC), May 23, 1994 2.5 BASH:
LOOP / CORE INTERFACE CORRECTIONS
Background
Corrections were made to the logic for interfacing the loop model and BART code model.
One correction prevents the possibility of an occasional inconsistency in how the core timestep was limited by the loop timestep.
Another corrects the fluid density used in the interface calculation when the inlet flowrate is negative.
Affected Evaluation Models 1981 ECCS Large Break LOCA Evaluation Model with BASH Estimated Effect Results from sensitivity studies for the corrections demonstrated negligible perturbations in the trends of the system parameters with a very minor net effect on PCT predictions. relative to results from the previous version.
Since this is an extremely small effect, with no apparent blas, the net effect j
on existing analyses is estimated to be O'F for margin tracking purposes.
The
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change has been implemented on a forward fit basis only and will be incorporated implicitly in any future analyses.
2.6 PELLET POWER RADIAL FLUX DEPRESSION ERROR
Background
A coding error (an incorrect sign) was discovered and corrected in a subroutine that calculates radial distribution power factors in the fuel pellet for the LOCBART code.
Affected Evaluation Models 1981 ECCS Large Break LOCA Evaluation Model with BASH
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'Attcchment 1 to WM 95 0052 -
. Piga 6 of 11 Estimated Effect Sensitivity. studies found the error correction to result in less than a 10.1*F effect on predicted PCT.
The' net effect on existing analyses is therefore 0*F for margin tracking purposes, and will be implicitly included in future recalculations.
2.7 IMPROVEMENTS TO FLOODING RATE SMOOTHING
Background
Part of the approved methodology for performing Large Break LOCA analyses with the BASH Evaluation Model is the requirement that the core inlet flooding rate calculated by the BASH code be linearized in a piece-wise manner.to remove oscillations prior to use in the hot channel fuel rod calculation.
This operation is termed " smoothing," and guidelines are provided to the analysts describing how to linearize the curve by observing inflections in the overall flooding rate.
To facilitate consistency in performing this operation, the logic has been coded into a program named SMUUTH. A new version of the SMUUTH program has been implemented which incorporates improved logic for determining the inflection points gained through experience in utilizing the program for a broad range of plant transients.
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Affected Evaluation Modeln 1981 ECCS Large Break LOCA Evaluation Model with BASH Estimated Effect There are no changes to the approved evaluation model methodology from this revision. The SMUUTH program merely represents a' convenient way of automating the approved methodology and does not explicitly introduce any effects on the results.
This revision is being reported only as a change to the code stream used for standard analynes.
There are no effects on predicted results from using the new program version.
2.8 ACCUMULATOR WATER TEMPERATURE l
Ha.Chground The choice of accumulator water temperature can affect the calculated PCT associated with Large Break LOCA analyses.
Early Westinghouse Evaluation Models had assumed a generic value of 90*F for the accumulator water temperature based on a conservatively low value of containment air temperature at 100% power in fulfillment of the Appendix K requirements associated with the calculation of a low containment back-pressure. These containment initial temperature and pressure assumptions in a plant's Large Break LOCA analysis have been consistently reported to the NRC in the Final Safety Analysis Report. The NRC had previously reviewed and approved this aspect of the Large Ereak LOCA Evaluation Model via plant specific Safety Evaluation Reports.
Using these assumptions, and with the early Westinghouse models, 90*F was conservative with respect to the overall effect on Large Break LOCA PCT.
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' Attachment I to WM 95-0052 Page 7 of 11 Newer evaluation models have demonstrated that a higher containment air temperature, coupled with higher accumulator water temperatures, may result in i
an even more conservative calculation for PCT, even if containment pressure is slightly higher than calculated with the 90*F assumption.
Sensitivity studies
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performed with these newer evaluation models have shown a small sensitivity to l
accumulator water temperature.
The effect on PCT was a 1.3*F change in PCT for a l'F change in accumulator water temperature when the accumulator water temperature varies over a range from 90*F to 12 0*F.
Application of this sensitivity over its applicable range results in a PCT effect which is below the 10 CFR 50.46 threshold for determination of a significant change (i.e.,
< 5 0"F).
It is therefore Westinghouse's position that immediate implementation of this new methodology is not required.
As such, application of the new plant specific methodology and associated change in analysis assumptions can be forward-fit to new Large Break LOCA analyses.
In support of future analyses, Westinghouse has developed a set of criteria for selection of the accumulator water temperature for use in large break LOCA analyses which use either the 1981 Evaluation Model with BART or the 1981 Evaluation Model with BASH.
These criteria will be provided to the plant licensees at the time a new large break LOCA analysis is performed.
Affected Evaluation Models 1981 Large Break LOCA Evaluation Model with BASH Estimated Effect As stated above, the estimated ef fect of a change in the accumulator water temperature methodology over a range f rom 90*F to 120 F is a
- 1. 3 F change in PCT for a 1 F change in accumulator water temperature.
As accumulator water temperatures are expected to vary greatly du-ing plant operation and are difficult to measure directly, the plant specific effect of this new methodology may only be assessed once detailed accumulator water temperature data are available.
As such, it is expected that this data will be provided when implementation of the new methodology occurs at the initiation of future plant specific Large Break LOCA analyses.
Please note that this potential issue has been considered in the current licensing basis Large Break LOCA analysis for WCGS.
For added conservatism, the accumulator water temperature assumed in the analysis is equal to the maximum possible containment internal temperature allowed by WCGS Technical Specifications (i.e.,
12 0 F).
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Attachmsnt I to WM 95-0052 Page 8 of-11 t
2.9 PRESSURE SEARCH CONVERGENCE CRITERIA IN NOTRUNP
Background
The convergence criteria used during the pressure search in NOTRUMP have been found to not be adequately restrictive to ensure a sufficiently accurate value for Fluid Node pressure when conditions approach the boundary between subcooled and saturated in some cases.
The resulting effects on predicted pressure were more pronounced at pressures below those normally seen during standard Evaluation Model calculations.
The previously hardwired convergence criteria values have been made as an user defined input, appropriate values have been determined, and these will be implemented in all future analyses.
This was determined to be a Non-Discretionary Change as described in Section 4.1.2 of WCAP-13451 and was corrected in accordance with Section 4.1.3 of WCAP-13451.
Affected Evaluation Model 1985 Small Break LOCA Evaluation Model (NOTRUMP)
Estimated Effect i
The nature of this error led to an estimated generic PCT effect of 0*F for i
existing analyses.
2.10 FRICTION VALUE INPUT CORRECTIONS
Background
The SPADES code is used to generate input decks for the Small Break LOCA analysis code, NOTRUMP.
An error was found in the code which involved the
-values assigned to some of the friction factor inputs.
The erroneous values had no impact on transient calculations and were corrected in order to maintain the consistency of the SPADES code with the relevant documentation.
The errors were considered to be discretionary changes as described in Section f
4.1.1 of WCAP-13451 and were corrected in accordance with Section 4.1.3 of WCAP-13451.
Affected Evaluation Model 1985 Small Break LOCA Evaluation Model (NOTRUMP) l Estimated Effect Representative plant calculations indicate no effect on PCT analyses.
"Atta.chment I to WM 95-0052 Paga 9 of 11 2.11. AUTOMATIC CONTAINMENT SPRAY ACTUATION DURING SMALL BREAK LOCA 4
Backaround Automatic containment spray actuation during a Small Break LOCA had not previously been addressed in the Westinghouse small Break LOCA evaluation model.
The containment pressure transient is not modeled because the Small I
Break LOCA PCT is not directly sensitive to this effect.
While investigating this issue; however, Westinghouse concluded that containment spray actuation early in the Small Break LOCA transient is. possible for a variety of containment types.
Containment spray actuation could result in draindown of the Refueling Water Storage Tank (RWST) prior to conclusion of the Small Break LOCA transient.
Switching to cold leg recirculation during the transient may reduce or briefly interrupt the modeled ECCS injection flow in some plants and elevate the enthalpy of ECCS injection water.
Furthermore, an alternate single failure scenario could result in earlier draindown for the RWST and subsequent switchover to cold leg recirculation.
i Future Small Break LOCA analyses will explicitly consider these issues.
Affected Evaluation Models 1985 Small Break LOCA Evaluation Model (NOTRUMP)
Estimated Effect The concern with Safety Injection interruption or reduction as a result of switchover from cold leg injection to recirculation does not apply to WCGS.
Regarding the increase in ECCS water enthalpy following switchover to ECCS recirculation, Westinghouse determined that WCGS was not affected by this issue in terms of PCT, through the use of engineering analysis including an i
alternate single failure which would more rapidly drain the RWST.
So there is no PCT effect assessed for this issue for margin tracking purposes.
2.12 SBLOCTA REVISIONS AND AXIAL NODALIZATION ERRORS
Background
10CFR50.46, Appendix K, Section II.3 requires that documentation be in place to verify that sensitivity studies have demonstrated the adequacy. of nodalization schemes used in the analysis models.
A study was recently undertaken with the Westinghouse Small Break LOCA Evaluation Model to examine the sensitivity of predicted results to the nodalization used for the hot rod model.
Specifically, a
series of calculations were performed using increasingly finer axial nodalizations than prescribed for the standard 19 node model.
The results of these calculations indicated that the standard SBLOCTA 19 node model was not conservative with respect to PCT.
The results of that study raised concerns regarding the adequacy of the standard axial nodalization prescribed for use in the SBLOCTA code for licensing basis analyses.
Because of this concern, Westinghouse investigated this as a Potential Issue per 10 CFR 21.
Westinghouse subsequently determined that this issue was not a substantial safety hazard pursuant to 10 CFR 21 because the PCT penalty did not result in a loss of safety function to the extent that there was a major reduction in the degree of protection provided to the health and safety of the public.
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'Atte.chment I to WM 95-0052 P ga'10 of-11 j
As a result of further investigation into the SBLOCTA code, several additional related issues associated with nodalization and the overall solution of the fluid conservation equations were subsequently identified and corrected. As a separate, but related issue, Westinghouse has implemented a revised model for calculating transient fuel rod internal pressure in the SBLOCTA code.
The NRC was informed of these modeling changes, which were summarized in the closout notification (Reference 2).
Affected Evaluation Modeln 1985 Small Break LOCA Evaluation Model (NOTRUMP)
Estimated Effect Westinghouse has completed the generic technical evaluation of the fuel rod axial nodalization methodology.
A revised standard for rod nodalization has been established which insures an adequate solution to the hot channel calculation by specifying a fine nodalization of 0.25 foot nodes for all elevations that are predicted to uncover during the transient.
Since the improved axial nodalization methodology and revised fuel rod internal pressure model can have significant synergistic effects on the predicted peak clad temperature, the SBLOCTA calculation from the limiting Small Break LOCA transient has been rerun with the revised code and methodology in order to obtain an accurate estimation of the net effect of these changes on the analysis record. The revised calculation performed with an axial offset limit of 20 percent resulted in an PCT effect of +26 F.
Reference 2 Letter NTD-NRC-94-4343, " Interim Report of an Evaluation of a Deviation or Failure to Comply Pursuant to 10CFR21.21(a) (2) - Closeout 94-002", NJ Liparulo (H), November 15, 1994 2.13 SAFETY INJECTION IN THE BROKEN LOOP
Background
The referenced topical report (Reference 3) presents a change to the Westinghouse Small Break LOCA methodology dealing with ECCS flows in the broken loop.
It also presents a revised condensation model that will be used on the safety injection jet in future analyses.
This change is being implemented on a forward fit basis prior to formal approval in accordance with Section 4.1.3 of WCAP-13451.
Affected Evaluation Model 1985 Small Break LOCA Evaluation Model (NOTRUMP)
Attachment.I to WM 95-0052 Page 11 of 11 Estimated Effect This change has been shown to typically produce PCT benefits in studies presented in the reference.
Since it is being implemented on a forward fit basis, a net PCT impact of 0 F is being assessed against existing analyses.
Reference 3 WCAP-10054-P, Addendum 2,
" Addendum to the Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code: Safety Injection into the Broken Loop and COSI condensation Model," August, 1994 i
Attcchment II to WM 95-0052 Page 1 of 3 ATTACHMENT II ECCS EVALUATION MODEL PCT MARGIN ASSESSMENTS i
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' Attachment' II to WM 95-0052
>:PIga 2 of 3 Large Break LOCA PCT Margin Rack-Up Summary
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A. ANALYSIS OF RECORD 1 Evaluation Model:
1981 Evaluation Model with BASH' Peaking Factor FQT=2.50, FDH=1.65 SG Tube Plugging:
10 percent 3565MW /17x17 V5H w/IFM, non-IFBA Power Level / Fuel:
t Limiting transient:
Cp=0.4, Min. Safeguards, Reduced Tyg 0
Peak Cladding Temperature (PCT) :
1916 F 0
B. PRIOR PERMANENT ECCS APCT =
-31 F MODEL ASSESSMENTS C.
10 CFR 50.59 EVALUATION 0
1.
RCS Loose Parts APCT = +20,2 F
'0CFR50.46 MODEL ASSESSMENTS D.
1994 1
(Permanent Assessment of PCT Margin) 0
- 1. None APCT =
0F 0
E. TEMPORARY USE OF PCT MARGIN APCT =
0F 0F2 0
- 1. Power Shape Assumption APCT =
F. OTHER MARGIN ALLOCATIONS
- 1. Transition Core (STD/V5H)
APCT =
+50 F3 0
0F4 0
2.
Cold Leg Streaming Temperature APCT =
Gradient 0
NET PCT Result 1955.2 F Notesx
- 1. Based on the reanalysis that was performed to support WCGS Power Rerate l
program.
The results of the reanalysis have been reviewed and approved by the NRC.
- 2. The Power Shape Sensitivity Methodology (PSSM) is used to assure that cycle-specific power distribution will not lead to results more limiting than those of the analysis of record.
Therefore, there is no PCT effect assessed for this issue.
- 3. Transition core penalty applies on a cycle-specific basis for reloads utilizing both V5H (with IFMs) and STD fuel until a full core of V5H is achieved.
0
- 4. A PCT benefit of
<2.5 F was assessed.
For the purposes of tracking PCT, 0
benefit of 0 F has been assigned to this change.
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- Attachmtnt'II to'WM 95-0052 ~
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~ SB LOCA PCT Margin Rack-Up Summary ' ***
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- A. ANALYSIS OF RECORD 1 Evaluation Model:
1985' Evaluation Model with NOTRUMP Peaking Factor:
FQT=2.50, FDH=1.65 SG Tube Plugging:
10 percent Power Level / Fuel:
3565MW /17x17 V5H w/IFM, t
Limiting transient:
3-inch Break 7
Peak Cladding Temperature (PCT):
1510 F 0
0 B.
PRIOR PERMANENT ECCS APCT =
-29 F MODEL ASSESSMENTS C.
10 CFR 50.59 EVALUATION.
0
- 1. RCS Loose Parts APCT = +44.6 F D.
1994 10CFR50.46 MODEL ASSESSMENTS (Permanent Assessment of PCT Margin) i 0
1.
Boiling Heat Transfer Correction Error APCT =
-6 F 0
- 2. Steam Line Isolation Logic Error APCT =
+18 F
- 3. Axial Nodalization, RIP Model Revision APCT =
+26 F' 0
and SBLOCTA Error Correction Analysis 0
E. TEMPORARY USE OF PCT MARGIN APCT =
0F
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F. OTHER MARGIN ALLOCATIONS 1.
Cold Leg Streaming Temperature APCT =
+7 F
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0 Gradient i
NET PCT Result 1570.60F Notes:
i 1.
Based on the reanalysis that was performed to support WCGS Power Rerate program.
The results of the reanalysis have been reviewed and approved by the NRC.
- 2. Based on limiting case reanalysis with an axial offset limit of 20 percent.
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