ML20214V867

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Forwards Response to NRC 870429 Request Re Conditions for Acceptance of WCAP-10444 & Cycle 3 Amend Application. Submittal of Related Info Discussed
ML20214V867
Person / Time
Site: Callaway 
Issue date: 06/05/1987
From: Schnell D
UNION ELECTRIC CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
ULNRC-1525, NUDOCS 8706120341
Download: ML20214V867 (6)


Text

-Umon Etscraic a

1901 Gratiot Street. St. Louis Donald F. Schnell Vce President June 5, 1987 U.

S. Nuclear Regulator y Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

ULNRC-1525 DOCKET NUMBER 50-483 CALLAWAY PLANT VANTAGE 5 LICENSING SUBMITTAL

References:

1. ULNRC-1470 dated 3-31-87
2. ULNRC-1491 dated 4-15-87.

3.

Letter from C. H. Berlinger-NRC/RSB to E.

P. Rahe-Westinghouse dated 6-18-86 Reference 1 transmitted the Reload License Amendment Application for Callaway Plant using Westinghouse 17 x 17 VANTAGE 5 fuel assemblies.

Reference 2 amended this application with revised LOCA analysis results.

On April 29, 1987 Union Electric and Westinghouse personnel met with members of the NRC Staff to discuss the Callaway Cycle 3 Amendment Application.

The attachment responds to the Staff's request regarding the conditions for acceptance of topical report WCAP-10444, as specified in Section 6.0 of the Staff's SER on this topical.

In addition, Reference 3 provided the Staff's approval of the reduction in the fuel assembly burnup limit for the calculation of maximum rod bow penalty.

This reference was also requested by the Staff at the April 29 meeting.

If there are any questions on the above or on the attachment, please contact us.

Very truly yours, r

Donald F.

Schnell GGY/ tar Attachment 8706120341 870605 PDR ADOCK 05000403 0l P

PDR 9

Mailing Address: P.O. Box 149 St. Louis, MO 63166

cc:

Gerald Charnoff, Esq.=

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C.

20037 Dr.

J. O. Cermak CFA, Inc.

4 Professional Drive (Suite 110)

Gaithersburg, MD 20879 W.

L.

Forney Division of Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RRS1 Steedman, Missouri 65077 Tom Alexion (2)

Office of Muclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Morfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102

ULNRC-1525 The NRC Staff reviewed the topical report WCAP-10444 and in their SER (Section 6.0) concluded that the topical was acceptable for reference to the Westinghouse VANTAGE 5 fuel design subject to certain conditions.

Listed below are these conditions and our comments addressing the inclusion of these conditions in the VANTAGE 5 Licensing Submittal (ULNRC-1470).

1.

The statistical convolution method described in WCAP-10125 for the evaluation of initial fuel rod to nozzle growth gap has not been approved.

This method should not be used in VANTAGE 5.

COMMENT With regard to the Fuel Rod Performance discussion in Section 3.0 of the Safety Evaluation in the VANTAGE 5 Licensing Submittal, the worst case fabrication tolerances were used to determine the initial fuel rod to nozzle growth gap for fuel rod irradiation growth.

This is in compliance with the above condition.

2.

For each plant application, it must be demonstrated that the LOCA/ seismic loads _ considered in WCAP-9401 bound the plant in question; otherwise additional analysis will be required to demonstrate the fuel assembly structural integrity.

COMMENT The LOCA/ seismic loads considered in WCAP-9401 bound the Callaway Plant.

This is addressed on Page 11 of the Safety Evaluation in the VANTAGE 5 Licensing Submittal.

3.

An irradiation demonstration program should be performed to provide early confirmation performance data for the VANTAGE 5 design.

COMMENT A summary of the VANTAGE 5 demonstration programs is given on Pages 2 and 3 of the Safety Evaluation in the VANTAGE 5 Licensing Submittal.

Individual VANTAGE 5 design features such as axial blankets and IFBA coatings were also part of the VANTAGE 5 demonstration programs, but are not mentioned in the Licensing Submittal.

4.

For those plants using the ITDP, the restrictions enumerated in Section 4.1 of this report must be addressed and information regarding measurement uncertainties must be provided.

ULNRC-1525 COMMENT Westinghouse has addressed the restrictions enumerated in SER Section 4.1 and the information regarding measurement uncertainties was provided to the NRC in ULRNC-1227.

This is stated in Section 2.0 on Page 4 of the Safety Evaluation in the VANTAGE 5 Licensing Submittal.

l 5.

The WRB-2 correlation with a DNBR limit of 1.17 is acceptable for application to 17x17 VANTAGE 5 fuel.

Additional data and analysis are required when applied to 14x14 or 15x15 fuel with an appropriate DNBR limit.

The applicability range of WRB-2 is specified in Section 4.2.

COMMENT This condition is not applicable to 17x17 VANTAGE 5 fuel.

However, Page 16 of the Safety Evaluation in the VANTAGE 5 Licensing Submittal refers to WCAP-10444 in which Appendix A contains the supporting 17x17 VANTAGE 5 fuel DNB test data for the WRB-2 correlation.

l 6.

For 14x14 and 15x15 VANTAGE 5 fuel designs, separate l

analyses will be required to determine a transitional j

mixed core penalty.

The mixed core penalty and plant-l specific safety margin to compensate for the penalty should be addressed in the plant Technical l

Specification Bases.

COMMENT This conditicn is not applicable to 17x17 VANTAGE 5 fuel.

However, Page 17 of the Safety Evaluation in the VANTAGE 5 Licensing Submittal states the 17x17 VANTAGE 5 transition core penalty and DNB safety margins.

The Bases for Technical Specification 2.1.1, Reactor Core Safety Limits, also addresses these parameters.

7.

Plant-specific analysis should be performed to show that the DNBR limit will not be violated with the higher value of FAH*

COMMENT The plant-specific DNB analysis is addressed on Pages 16 and 17 of the Safety Evaluation in the i

VANTAGE 5 Licensing Submittal.

8.

The plant-specific safety analysis for the steam system i

I piping failure event should be performed with the l

assumption of loss of offsite power if that is the most conservative case.

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(

ULNRC-1525 COMMENT This event was evaluated for Callaway Plant and there was no change in the results from the OFA analysis (i.e. OFA Licensing Submittal is bounding).

See ULNRC-1207, as referenced on Page 15.1-1 of Attachment 5, Appendix A of the VANTAGE 5 Licensing Submittal, which contains the OFA steamline break analysis.

9.

With regard to the RCS pump shaft seizure accident, the fuel failure criterion should be the 95/95 DNBR limit.

The mechanistic method mentioned in WCAP-10444 is not acceptable.

COMMENT The mechanistic method was not used with regard to the RCS pump shaft seizure accident addressed in Section 15.3.3, Page 15.3-7 of Attachment 5, Appendix A of the VANTAGE 5 Licensing Submittal.

Any rods which violated the 95/95 DNBR limit were assumed to fail.

Results of this evaluation were within current FSAR limits.

10.

If a positive MTC is intended for VANTAGE 5, the same positive MTC consistent with the plant Technical Specifications should be used in the plant-specific safety analysis.

COMMENT The current licensing basis does not have a positive MTC.

However, a positive MTC (conservative analysis) was incorporated in the plant safety analysis discussed in Section 6.1.2, Page 24, of the Safety Evaluation in the VANTAGE 5 Licensing Submittal.

It was found that for each of the non-LOCA accidents reanalyzed that the appropriate safety criteria were met.

11.

The LOCA analysis performed for the reference plant with higher F of 2.55 has shown that the PCT limit of g

2200*F is viotated during transitional mixed core configurations.

Plant-specific LOCA analysis must be done to show that with the appropriate value of F, the 2200 F criterion can be met during use of transitkonal mixed cores.

COMMENT The plant-specific LOCA analysis performed with an F of 2.50 is discussed in Section 6.2, Pages 27-30 of the Safety Evaluation in the VANTAGE 5 Licensing Submittal.

12.

Our SER on Westinghouse's extended burnup topical report WCAP-10125 is not yet complete; the approval of the VANTAGE 5 design for operation to extended burnup levels is contingent on NRC approval of WCAP-10125.

However, VANTAGE 5 fuel may be used to those burnups to which Westinghouse fuel is presently operating.

Our

m ULNRC-1525 review of the Westinghouse extended burnup topical report has not identified any safety issues with operation to the burnup value given in the extended burnup report.

COMMENT WCAP-10125 has been approved.

The extended burnup methodology contained in this topical has been applied and is discussed in Section 3.0 of the Safety Evaluation in the VANTAGE 5 Licensing Submittal.

13.

Recently, a vibration problem has been reported in a French reactor having 14-foot fuel assemblies; vibration below the fuel assemblies in the lower l

portion of the reactor vessel is damaging the movable incore instrumentation probe thimbles.

The Staff is currently evaluating the implications of this problem to other cores having 14 foot long fuel bundle assemblies.

Any limitations to the 14 foot core design resulting from the Staff evaluation must be addressed in plant-specific evaluations.

COMMENT Callaway Plant has 12 foot long fuel assembly bundles and, therefore, the above condition is not applicable.

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