ML20236X443
| ML20236X443 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, Allens Creek  |
| Issue date: | 08/05/1998 |
| From: | Polich T NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9808100022 | |
| Download: ML20236X443 (40) | |
Text
..
p UNITED STATES j
NUCLEAR REGULATORY COMMISSION g
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WASHINGTON, D.C. enmaa annt August 5, 1998 l
LICENSEE: TEXAS UTILITIES ELECTRIC COMPANY FACILITY: COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2
SUBJECT:
SUMMARY
OF MEETING WITH TEXAS UTILITIES ELECTRIC COMPANY (TUE)
REGARDING USE OF THE CALDON LEADING EDGE FLOW METER FOR APPENDIX K EXEMPTION AND POWER UPRATE LICENSE AMENDMENT ON JULY 14,1998
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On July 14,.1998, members of the NRC staff met with representatives of TUE to discuss the licensing submittals required for proposing an exemption to Appendix K and a power uprate license amendment. Attachment 1 is the list of meeting attendees.
The NRC staff provided an introduction to the meeting and stated that in a letter from Caldon dated December 23,1997, Caldon announced that TUE had agreed that Comanche Peak Steam Electric Station (CPSES) Unit 2 would be the lead plant for the Caldon Engineering Report-80P OER-80P), " Improving Thermal Power Accuracy and Plant Safety While Increasing Operating l
Power level Using the LEFM System" Revision 0, dated March 1997, which is the topical report l
for the Caldon leading edge flow meter (LEFM). In a letter dated January 30,1998, TUE l
confirmed that CPSES Unit 2 would be the lead plant to request a license amendment for a power uprate using Caldon Topical Report ER-80P and anticipated a submittal to the staff in July 1998; Several phone conversations were held with TUE to discuss their proposed approach for the emergency core cooling system (ECCS) analyses and the power uprate license amendment prior to this meeting.
TUE presented their overview of the Caldon topical report, analyses supporting the license amendment, proposed license amendment request, basis for Appendix K exemption request, and the proposed schedule for submittal of these items. Attachment 2 is a copy of the material l
presented by TUE.
l The staff questioned the bases for the safety analyses that used 104.5 percent of the rated g
l thermal power and asked if there was documentation available for the 104.5 percent number.
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l The TUE stated that the bases was for futura power uprates. Documentation of this will need to j.
be provided in the power uprate submittal.
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The staff asked which specific design transient would be raised to address increased primary to secondary delta pressure. TUE explained it was the secondary depressurization that would be affected.
The staff cautioned TUE to carefully review any initial conditions or contingencies that may have been imposed during the approval of the NRC's Safety Evaluation Report.
Docket Nos. 50-445 and 50-446 Adiu b 9008100022 990005 PDR ADOCK 05000445 P
2 The staff asked how the LEFM spool pieces are calibrated and tM%. Caldon answering for TUE stated that each spool piece was calibrated and tested indept...aently at Alden Laboratory before installation and is tested as part of the initialinstallation. Caldon also stated that sound velocity is used for temperature measurement and the instrument is pressure compensated.
The staff also questioned whether there was a need to add surveillance requirements for the LEFM on-line accuracy verification. The licensee stated that this was not necessary since the current daily calorimetric requirement would not change and proposed technical specification would allow for operathn at a reduced power using the current venturiif the LEFM was not operable. Also the ar.alyses would be performed to bound both the LEFM at the new higher 100 percent power level and the venturi at the current 100 percent power level.
The schedule of submittals was discussed indicating the Topical Report ER-80P would be placed on the CPSES docket within the next two weeks followed by the submittal of the exemption request from the 10 CFR Part 50 Appendix K requirement to perform safety analyses at 102 percent of licensed thermal power. The licensee also stated that a licensee amendment request would be submitted in December 1998, to increase the rated thermal power for CPSES Unit 2 and corresponding technical specification changes associated with the increase in rated thermal power. The licensee requested the license amendment be processed by April 1999, to coincide with the startup after the CPSES Unit 2 outage. The staff asked if the license amendment request could be made earlier to allow the staff more review time for the additional ECCS analyses. The licensee stated that the analyses could not be accomplished before December; however, the topical report and exemption request would be submitted within a few weeks.
The staff stated that although parts of the review would be started prior to the power uprate amendment request (topical report review and exemption request) the actual power uprate portion would require a significant staff effort. The licensee acknowledged the fact that the power uprate license amendment request may not be approved prior to the end of the CPSES Unit 2 outage.
The staff and the licensee acknowledged the benefit of the meeting and an understanding of the
- schedule for the licensee's submittals and staff's review effort to approve such submittals.
Timothy J. P ich, Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation l
Attachments: 1. Meeting Attendees
- 2. Licensee Presentation cc w/atts: See next page
f-2 The staff asked how the LEFM spool pieces are calibrated and tested. Caldon answering for TUE stated that each spool piece was calibrated and tested independently at Alden Laboratory before installation and is tested as part of the initialinstallation. Caldon also stated that sound velocity is used for temperature measurement and the instrument is pressure compensated.
The staff also questioned whether there was a need to add surveillance requirements for the LEFM on-line accuracy verification. The licensee stated that this was not necessary since the current daily calorimetric requirement would not change and proposed technical specification would allow for operation at a reduced power using the current venturi if the LEFM was not operable. Also the analyses would be performed to bound both the LEFM at the new higher 100 percent power level and the venturi at the current 100 percent power level.
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The schedule of submittals was discussed indicating the Topical Report ER-80P would be placed on the CPSES docket within the next two weeks followed by the submittal of the exemption request from the 10 CFR Part 50 Appendix K requirement to perform safety analyses at 102 percent of licensed thermal power. The licensee also stated that a licensee amendment request l
would be submitted in December 1998, to increase the rated thermal power for CPSES Unit 2 and corresponding technical specification changes associated with the increase in rated thermal power. The licensee requested the license amendment be processed by April 1999, to coincide with the startui., after the C?SES Unit 2 outage. The staff asked if the license amendment request could be made eanier to allow the staff more review time for the additional ECCS l
analyses. The licensee stated that the analyses could not be accomplished before December; l
however, the topical report and exemption request would be submitted within a few weeks.
The staff stated that although parts of the review would be started prior to the power uprate amendment request (topical report review and exemption request) the actual power uprate portion would require a significant staff effort. The licensee acknowledged the fact that the i
power uprate license amendment request may not be approved prior to the end of the CPSES i
Unit 2 outage.
]
The staff and the licensee acknowledged the benefit of the meeting and an understanding of the schedule for the licensee's submittals and staffs review effort to approve such submittals.
ORIGINAL SIGNED BY:
Timothy J. Polich, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/IV Office r/ Nuclear Reactor Regulation Attachments: 1. Meeting Attendees
- 2. Licensee Presentation cc w/atts: See next page DISTRIBUTION: See next page Document Name: CP71498.MTS
- See previous concurrence OFC PM/PD4-1 LA/PD4-1 BC/SRXB*
BC/HICB*
D/PD4-1N NAME TPolichk Chaw TCollins JWermiel JHannon DATE 7 / 5(98
$ /k 198 07/27/98 07/29/98 7/3 //98 COPY YES/NO YES/NO YES/NO YES/NO YES/NO Syd OFFICIAL RECORD COPY rid 96 i
Jrg-N Meeting Held on:, July 14.1998 DISTRIBUTION:
- +
.4-HARD COPY Docket File -
PUBLIC PD4-1 r/f OGC ACRS TGwynn, RIV E-MAIL SCollins/FMiraglia (SJC1/FJM) i BBoger (BAB2) l EAdensam (EGA1) l CHawes (CMH2)
. TMartin (SLM3) i
' TPolich (TJP1)
JHannon (JNH)
TCollins (TEC)
JMauck (JLM2)
CDoutt (CKD)
JDonoghue (JED1) l EWeiss (EWW)
FOrr (FRO)
RCaruso (RXC)
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TU Electric Company Comanche Peak, Units 1 and 2 cc:
Senior Resident inspector Honorable Dale McPherson U.S. Nuclear Reguta'ory Commission County Judge P. O. Box 2159 P. O. Box 851 Glen Rose, TX 76403-2159 Glen Rose, TX 76043 Regional Administrator, Region IV Office of the Govemor U.S. Nuclear Regulatory Commission ATTN: John Howard, Director 611 Ryan Plaza Drive, Suite 400 Environmental and Natural Arlington, TX 76011 Resources Policy P. O. Box 12428 Mrs. Juanita Ellis, President Austin, TX 78711 Citizens Association for Sound Energy 1426 South Polk Arthu-C. Tate, Director Dallas, TX 75224 Division of Compliance & Inspection Bureau of Radiation Control Mr. Roger D. Walker Texas Department of Health TU Electric 1100 West 49th Street Regulatory Affairs Manager Austin, TX 78756-3189 P. O. Box 1002 Glen Rose, TX 76043 Mr. C. Lance Terry TU Electric George L. Edgar, Esq.
Group Vice President Nuclear Morgan, Lewis & Bockius Attn: Regulatory Affairs Depp iment 1800 M Street, N.W.
P. O. Box 1002 Washington, DC 20036-5869 Glen Rose, TX 76045 t
Jim Calloway l
Public Utility Commission of Texas i
Elec ric Industry Analysis P. O. Box 13326 Austin, TX 78711-3326 l
l 4
TEXAS UTILITIES ELECTRIC-NRR MEETING REGARDING COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 EXEMPTION FROM APPENDIX K AND POWER UPRATE AMENDMENT HELD ON JULY 14.1998 MEETING ATTENDEES Name Organization Phone T. Collins NCR/NRR/SRXB 301-415-2895 J. Mauck NRC/NRR/HlCB 301-415-3248 C. Doutt NRC/NRR/HICB 301-415-2847 J.Hannon NRC/NRR/PD4-1 301-415-1038 T. Polich NRC/NRR/PD4-1 301-415-1038 J.Donoghue NCR/NRR/SRXB 301-415-1131 E. Weiss NCR/NRR/SRXB 301-415-3264 F. Orr NCR/NRR/SRXB 301-415-1815 R. Caruso NCR/NRR/SRXB 301-415-1813 J. Kelley TUE 254-897-5202 R. Walker TUE 254-897-8233 D. Buschbaum TUE 254-897-5851 M. Killgore TUE 254-897-0703 J. Seawright TUE 254-897-0140 J. Boatwright TUE 214-812-8232 W. Choe TUE 214-812-4371 C. Hastings Caldon 412-341-9920 E. Hauser Caldon 412-341 9920 H. Estrada Caldon 410-849-3324 H. Fontecilla Arizona Public Service 703-527-2217 R. Givankar Commonwealth Edison 630-663-7430 N. Chapman Florida Power and Light 301-417-3771 C. Contard Niagra Mohawk 315-349-4093 D. Vincent Northem States Power 612-388-1121 x4107 R. Drake Tennessee Valley Authority 423-751-4578 M. Philips Winston and Strawn 202-371 5729 i
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l ATTACHMENT 1 l
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MEETING REGARDING POWER UPRATE NRC STAFF AND TEXAS UTILITIES JULY 14,1998 I
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ATTACHMENT 2
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1 AGENDA 1)
Introduction l
2)
Overview of the Topical Report supporting use of reduced LEFM uncertainty to obtain a 1% RTP uprate i
3)
Analyses supporting the License Amendment change to the DEFINITION of RATED THERMAL POWER Description of Plant Hardware Changes Description of Operating Procedure Changes Impact on Supporting Safety Analyses 4)
Proposed License Amendment Request 5)
Basis for Appendix K Exemption Request l
6)
Schedule l
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2 TU REPRESENTATIVES and OTHER KEY PLAYERS James J. Kelley, Jr. Vice President of Nuclear Engineering & Support Roger Walker, Manager of Regulatory Affairs e
Mickey Killgore, Reactor Engineering Manager Whee Choe, Safety Analysis Manager James Boatwright, Consulting Safety Analysis w
Engineer Jimmy Seawright, Licensing Engineer Herb Estrada, Caldon, Inc.
e Malcolm H. Philips, Jr., Winston and Strawn w
Calvin R. Hastings, President & CEO, Caldon, Inc.
Ernest Hauser, Caldon, Inc.
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OTHER SUPPORTING UTILITIES
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TVA Arizona Public Service Comed FP&L Virginia Power Niagara Mohawk Northern States Power l
PSE&G I
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PECO Entergy 1
Southern California Edison
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STAFF ACTIONS NEEDED BY TU Approval of Caldon's Topical Report Approval of License Amendment (Increase in Rated Power Level)
Approval of Corresponding Tech Spec Amendment (Increase in Rated Power Level)
Granting of Exemption to Appendix K (Accident Analysis at 101% Licensed Power Level Instead of 102 %)
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11 PROPOSED APPLICATION OF CALDON LEFMV TOPICAL REPORT TO COMANCHE PEAK STEAM ELECTRIC STATION l
Use increased accuracy in power measurement to support thermal uprate of CPSES Use LEFM-based power calorimetric l
measurement as baseline for daily comparisons with neutron flux and N-16 power indications Use LEFM input to plant computer for real-time plant calorimetric calculation Justification of increased accuracy associated with calorimetric measurement l
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r 12 PLANT OPERATING PARAMETERS AT THE UPRATED CONDITION i
Increase RTP from 3411 MWt to 3445 MWt
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No change in Tavg vs. % RTP program At the new 100% RTP, Thot < 0.3 F hotter; Tcold < 0.3 F cooler Approximately 1 F increase in FW temperature Approximately 1% increase in FW and steam flows 1
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13 PHYSICAL PLANT CHANGES No hardware changes anticipated except for LEFMV electronics l
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New high pressure turbine design specified for 1% uprate condition l
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. OPERATING PROCEDURES No substantive changes to Normal, Abnormal, or Emergency Operating Procedures other than definition of RATED THERMAL POWER If the LEFMV is unavailable for calorimetric measurement, reduce power under administrative controls to maintain consistency between calorimetric uncertainty and operating power level Similar to current practices with other l
equipment (preferred and alternate indications) s
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15 SUPPORTING SAFETY ANALYSES l
Current RTP Defined as 3411 MWt 102% RTP Accident Analyses evaluated for core power of 2 3479 MWt New RTP to be Defined as 3445 MWt 101% RTP Accident Analyses to be evaluated for core power of 2 3479 MWt l
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16 SAFETY ANALYSES l
Four General Types of Safety Analyses:
I Those that use 104.5% of 3411 MWt l
1 Those that use 102% of 3411 MWt Those that use statistical combination of uncertainties Those that use nominal power levels 1
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r 17 SAFETY ANALYSES THAT USE 104.5% OF 3411 MWt l
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No Changes Required 1
LOCA Mass & Energy Releases l
Radiological Source Terms l
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r 18 SAFETY ANALYSES THAT USE 102% OF 3411 MWt
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No Changes Required 1
Appendix K' LOCA LBLOCA & SBLOCA Evaluation Models as Listed in Current COLR TS Most Chapter 15 non-LOCA transients Using methodologies Listed in Current COLR TS Steamline Break Mass and Energy Releases 1
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l As amended through proposed exemption
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19 SAFETY ANALYSES THAT USE STATISTICAL COMBINATION OF UNCERTAINTIES Any Chapter 15 non-LOCA Analyses where statistical DNBR methods are used Using methodologies listed in current COLR TS Currently, only Dropped Rod Event Must be re-evaluated to consider both 3445 MWt i1% & 3411 MWt i 2%
4 Uncertainty Analyses (plant specific)
RCS flow calorimetric measurement Power calorimetric measurement High neutron flux reactor trip setpoint 1
Overpower N-16 reactor trip setpoint Overtemperature N-16 reactor trip setpoint I
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20 ANALYSES THAT USE NOMINAL POWER NSSS Control System Setpoints Automatic Rod Control Pressurizer Pressure and Level Control Steam Generator Water Level Control Steam Dump Control NSSS Fluid Systems l
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Chemical and Volume Control System i
Safety injection System Residual Heat Removal System l
Containment Spray System k
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21 ANALYSES THAT USE NOMINAL POWER (cont.)
NSSS Support Systems
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Service Water System Component Cooling Water NSSS and BOP Interface System Requirements Auxiliary Feedwater System Main Steam Safety and Relief Valves i
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22 ANALYSES THAT USE NOMINAL POWER (cont.)
Secondary Plant (BOP) Systems Main Steam System Main Feedwater System Heater Drains System Condensate System Evaluated for:
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Design Basis Compliance l
Impact on Stress and Fatigue Analyses l
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23 ANALYSES THAT USE NOMINAL POWER (cont.)
NSSS Component Stress and Fatigue Evaluated for conditions more severe than simple 1% RTP increase 4.5% RTP increase 10% SG Tube Plugging i2 F Tavg change
~30 F change in feedwater temp
~12 psi steam pressure decrease One Design Transient to be revised to address increased primary to secondary AP All NSSS Components (Reactor Vessel, internals, pressurizer, etc.) to be evaluated 1
No significant effects expected l
1 Nuclear Fuel Assemblies to be evaluated by vendor on cycle-specific basis l
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x 24 SAFETY ANALYSES General Information FSAR Chapter 15 Analyses to be performed with NRC-approved methodologies, as listed in the COLR Technical Specification For Non-Chapter 15 Analyses, standard engineering practices are used, unless an NRC-approved methodology is required Level of detail in submittal expected to be same as current FSAR l
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r 25 PROPOSED LICENSE AMENDMENT REQUEST Revised Definition of RATED THERMAL POWER Revised Setpoint and Allowable Values for:
High Neutron Flux Reactor Trip Overpower N-16 Reactor Trip Overtemperature N-16 Reactor Trip Initial Request for Unit 2 Only I
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SUMMARY
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License Amendment Request to be similar to previous power uprates 1
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The use of the LEFM accuracy does not affect the scope of Safety Analyses that must be considered All other aspects of the evaluations supporting the uprate are similar to other recent submittals I
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r 27 10 CFR 50.12 EXEMPTION Appendix K requires analysis at 102% of licensed power level to accommodate uncertainties TU Seeks Exemption to this Appendix K provision to conform to Licensing Amendment Request --
Req.uired Findings for Exemption IAW @ 50.12 Authorized by Law No Undue Risk to Public Health and Safety Consistent with Common Defense and Security Special Circumstances Exist (Discussed in Following Pages) l
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28 APPLICABLE 10 CFR 50.12 SPECIAL CIRCUMSTANCES l
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The Requirement is not necessary to achieve j
underlying purpose of Appendix K.
Benefit to Public Health and Safety l
Material Change in Circumstances l
New technology l
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NOT NECESSARY TO ACHIEVE UNDERLYING PURPOSE l
Purpose:
102% Analysis Margin Required for Uncertainty Basis is Provide in Staff Documents: For Example, 2% stated in Reg Guide 1.49 for "possible instrument errors in determining the power level" and in Section 15.2.1 of the Standard Review Plan "to account for a 2% power measurement uncertainty" Better Technology increases Instrument Accuracy 102% Analysis Margin Requirement Not Necessary to Achieve Underlying Purpose of Appendix K i
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30 PUBLIC BENEFIT Improves Accuracy of Power Level Determination Increased Electrical Generation Improves Safety r
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31 MATERIAL CIRCUMSTANCES LEFMV Technology Not Available When Appendix K Adopted Imoroved Calorimetric Accuracy Digital Signal Processing Benefits in Public Interest l
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l CONCLUSION l
When the technical case accepted by NRC staff, an l
exemption to 10 CFR 50 Appendix K is warranted l
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33 SCHEDULE: STAFF ACTIONS NEEDED BY TU Approval of Caldon's Topical Report i
Submittal within two weeks Granting of Exemption to Appendix K (Accident Analysis at 101% Licensed Pwoer Level Instead of 102 %)
Submittal within two weeks Approval of License Amendment (Increase in Rated Power Level)
Submittal December,1998 Approval by April,1999 1
Approval of Corresponding Tech Spec Amendment (Increase in Rated Power Level)
Submittal December,1998 Approval by April,1999 l
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