ML20236M035
| ML20236M035 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/31/1987 |
| From: | Scnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20236M039 | List: |
| References | |
| RTR-REGGD-01.099, RTR-REGGD-1.099 ULNRC-1565, NUDOCS 8708100451 | |
| Download: ML20236M035 (10) | |
Text
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Union Etsome PE 1901 Gratiot Street. St. LOum Donald F. Schnell Vice President July 31, 1987 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
ULNRC-1565 DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/4.4.9 Pressure / Temperature Limits
References:
- 1) ULNRC-1469 dated, 3/18/87
- 2) ULNRC-1244, dated 1/21/86 Union Electric Company is transmitting an application for amendment to Facility Operating License No. NPF-30 for Callaway Plant.
This amendment application requests that the plant heatup and cooldown curves and the maximum allowable PORV setpoint curve for cold overpressure protection, as found in Technical Specification Figures 3.4-2, 3.4-3 and 3.4-4, be modified.
Additionally, the reactor vessel surveillance capsule removal schedule as given by Technical Specification Table 4.4-5 would be revised.
It thould be noted that the surveillance capsule report submitted by Reference 1 will be revised and resubmitted to the NRC.
The revision concerns the heatup and cooldown curves contained therein.
An error was found in the calculations for (RT using The attached hdr)ves determining the reference nil-ductility temperature Regulatory Guide 1.99 Rev. 2 methodology.
are the corrected heatup and cooldown curves which will be in Revision 1 of the surveillance capsule report.
Following is a discussion of the requested amendments.
1)
Figure 3.4-2 is the heatup limitation curve.
This curve is being revised to reflect the RT calculated The S$ vised curve N
from the surveillance capsule data.
will be valid to 9 effective full power years (EFPY).
The curve is based on Regulatory Guide 1.99, Rev.
2, and bounds the plant conditions which will be observed by the change to Westinghouse Vantage 5 fuel and the Callaway Plant uprated power level.
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Mailing Address: P.O. Box 149, St. Louis, MO 63166
2)
Figure 3.4-3 is the cooldown limitation curve.
This curve is also being revised to reflect the RT calculated for 9EFPY in the surveillance capsNSI report.
This curve is also based on Regulatory Guide 1.99, Rev. 2 and bounds the plant conditions which will be observed by the change to Westinghouse Vantage 5 fuel and the Callaway plant uprating.
3)
Table 4.4-5 is the surveillance capsule withdrawal cchedule. It is being modified to reflect the newly plunned withdrawal schedule.
This schedule modi.?ication calls for the withdrawal of the second capsu.'e at SEFPY instead of 6EFPY.
This is being done due to Lhe representative fluence seen by the capsule at 5 EFPY which is the fluence observed by the vessel at 1/4 thickness at end of plant life.
This will allow 1/4T Vessel location at an accurate prediction of RTNDT end of plant life conditions 4)
Callaway Technical Specification 3/4.4.9 also requires review of Figure 3.4-4 to determine if revision is needed.
Figure 3.4-4 is the maximum allowable PORV setpoint curve for cold overpressure protection.
The review performed found that this curve required modification due to the changes made in the heatup and cooldown limitation curves.
5)
Technical Specification Bases 3/4.4.9, page B3/4 4-7, is being revised to reflect the change in the service life period and the revision level of Regulatory Guide 1.99 that was used in formulating the new curves.
Attachments 1, 2,
and 3 provide the Safety Evaluation, the Significant Hazard Evaluation and the Proposed Technical Specification Changes associated with the amendment request discussed under items 1, 2, 3 and 4 above.
Reference 2 submitted the RT values for Callaway and committed to provide an update wh$$$ver changes in core loadings, surveillance measurement or other information indicate a significant change in projected values.
A review of RT was performed which found that the presented value remains bbbnding.
l It should be noted that the change to OFA fuel and currently to Vantage 5 fuel have lowered the fluence seen by the vessel over core life such that, even after uprating effects are included, the value of RT is more conservative than when originally submitted.
Bas $$ on this, no change to RT s requ red.
PTS The Callaway Plant On-Site Review Committee and Nuclear Safety Review Board have reviewed and approved this amendment request.
f
a s Enclosed is a check for the $150.00 application fee (Attachment 4) as required by 10CFR170.21.
Very truly yours, i
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Donald F.
Schnell i
DFS/ tar
Attachment:
1.
Safety Evaluation 2.
Significant Hazard Evaluation 4
3.
Proposed Technical Specification Changes 4.
Application Fee i
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1 STATE OF MISSOURI )
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Donald F.
Schnell, of lawful age, being first duly sworn l
upon oath says that he is Vice President-Nuclear and an officer of i
Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By sid#./
Donald F.
Schnell Vice President Nuclear SUBSCRIDED and sworn to before me this 3/4f day of pf
,1987
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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 Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman. Missouri 65077 Tom Alexion (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Ron Kucera, Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 I
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., Page 1 of 3 ULNRC-1565 Safety Evaluation This Technical Specification change is being made to incorporate information gained from surveillance capsule U which was removed during Callaway Refuel 1.
These curves also' incorporate the effects of a low leakage fuel and plant uprated conditions.
The modification of curves found in Figures 3.4-2, 3.4-3, and 3.4-4 are to incorporate the new RT Table 4.4-5 is being modified to incorporate the new recommWRIe.d withdraw schedule, and the i
Bases are being revised to reflect the change in the Service Life Period and the revision level of Regulatory Guide 1.99.
Westinghouse derived adjoint importance functions have been used to assess the effects that past, present, and projected fuel cycles have on the fast neutron exposure of the Callaway reactor vessel.
Plant specific evaluations for fuel cycles using "out-in" fuel management (Cycle 1) have demonstrated that the maximum fast (E >
1.0 MeV) neutron flux incident on the reactor vessel at an azimuthal angle of 25 degrees was 31 percent less than i
predictions based on design basis core power distributions.
Evaluations for the projected Vantage-5 low leakage core loading Strategy (Cycle 5) predicted that the react ^r vessel maximum fast (E > 1.0 MeV) neutron flux was further reduced, by approximately 33 percent, relative to that existing prior to the implementation of low leakage.
Implementation of a more severe low leakage core loading pattern would act to reduce the fluence projections at key locations.
On the other hand, relaxation of the current low leakage core loading patterns or a return to "out-in" fuel management would increase those fluence projections.
Confirmation of assumed fluence level will be made prior to exceeding SEFPY, currently expected to be at the 3rd refueling when capsule Y is withdrawn.
Design fluence levels for subsequent fuel cycles will,be compared to the Westinghouse derived adjoint importance functions to l
confirm projected fluence values used in the attached curves remain valid.
Excellent agreement was demonstrated between measured data from the first withdrawn surveillance capsule (Capsule U) and values calculated using the adjoint importance functions with the measurement exceeding the calculation by approximately 6 percent.
Differences of this magnitude are within the uncertainty of the measured result.
The Westinghouse neutron transport methodology, both forward and adjoint, using the SAILOR cross-section library has been benchmarked against the CRNL PCA facility, the VENUS PWR engineering mockup and the Westinghouse power reactor surveillance capsule data base.
The benchmarking studies show that the use of the SAILOR cross-sections and design basis core power distributions produces neutron fluxes that tend to be
., Page 2 of 3 j
ULNRC-1565
(
conservative, with calculations exceeding measurements by 10 to 25 percent.
When plant specific core power distributions are used with the adjoint importance functions, the benchmarking studies show that neutron fluence predictions are distributed with +/-15 percent of measured values at surveillance capsule locations.
Callaway Heatup/Cooldown Curves i
Pressure-temperature limit curves for heatup and cooldown were generated using the neutron fluences for two cases.
The first I
case was a Design Basis Calculation, performed as part of the Radiation Surveillance Program for Capsule U.
The second case, which was a plant specific analysis for the 3565 MWT uprated condition. was for Cycle 3 and beyond.
(Cycles 3 and 4 are transition to a full Vantage 5 core.
Cycle 5 is a full Vantage 5 core, and projections beyond Cycle 5 assume a Cycle 5 average flux).
The methods of Regulatory Guide 1.99 Proposed Revision 2
(" Radiation Damage to Reactor Vessel Materials"), see attached, were used to generate the heatup and cooldown curves for both cases.
ASME Code Section III Appendix G safety factors and assumptions were incorporated in both cases.
Since the material chemistry of the vessel is unaltered, the only difference between the two cases is caused by the different fluences.
The heatup and cooldown curves generated for case 2 (uprated condition, realistic loading pattern) showed lower RT values than case 1 at the one-quarter thickness and three-quN95er thickness locations.
Since the uprated plant specific case is the more realistic of the two cases and since Appendix G safety
' factors and conservative assumptions are applied, it is i
recommended that the heatup and cooldown curves for the 3565 MWT uprated case will be used for the Technical Specification.
PORV Setpoints The Maximum Allowable PORV Setpoint Curve for the Cold Overpressure Mitigation System (COMS) is generated using the Heatup/Cooldown curves.
Thus, anytime the H/C curves are revised, the PORV Setpoint Curve and the COMS setpoints must be reevaluated and revised if necessary.
In the case of Callaway, the H/C curves were revised such that a revision to the PORV Setpoint Curve was necessary.
This provides justification for the new curves to be submitted by Union Electric as a Technical Specification change for Callaway.
The withdraw schedule is being modified to reflect capsule Y withdrawal prior to or at 5 EFPY because the fluence seen by the capsule at this time will be representative of the fluence seen by the vessel at the 1/4 thickness location at the end of plant life (32 EFPY).
Also fluence level verification will be performed when the capsule is withdrawal.
d,
Page 3 of 3 ULNRC-1565 None of the above mentioned modifications will have an adverse effect on the consequences or probability of any accident.
These modifications will not effect the probability or consequences of an equipment malfunction, Finally, since the Technical Specifications are modified in accordance with these changes, the margin of safety is not reduced.
ULNRC-1565 Significant Hazard Evaluation This Technical Specification change is being requested to I
incorporate information gained from surveillance capsule U which l
was removed during first refueling.
These curves also incorporate the effects of a low leakage fuel and plant uprated conditions.
The modifications of the plant heatup and cocidown limitation curves (Figures 3.4-2, 3.4-3, and 3.4-4) are to incorporate the RT Table 4.4-5 is being modified to incorporate the negDJe. commended withdraw schedule.
The changes being made are jointly considered in this evaluation for significant hazards.
This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The revision being made is to merely ensure that the acceptable range of operation is clearly defined using conservative and validated data obtained from the analysis of surveillance capsule U which was withdrawn at refuel 1.
This change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
This is based on the fact that the method and manner of plant operation are unchanged.
This change does not involve a significant reduction in a margin of safety.
This is based on the fact that the change only revises the heatup and cooldown limitation curves and surveillance program table to reflect operational parameters based on surveillance capsule data as applied to Vantage 5 fuel and uprated conditions.
The recalculated limit curves have the same degree of conservatism as the original curves, since they are based on the most limiting values of the nil-ductility reference temperature which includes the radiation induced shift (ARTNDT) as determined by the surveillance capsule analysis.
Based on the above discussions, the amendment request does not involve a significant increase in the probability or consequences of an accident previously evaluated; nor create the possibility of a new or different kind of accident from any accident previously evaluated; nor involve a reduction in the required margin of safety.
Based on the foregoing, the requested amendment does not present a significant hszard.
(1)
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