ML22285A130
| ML22285A130 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/12/2022 |
| From: | Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML22285A115 | List: |
| References | |
| ULNRC-06768 | |
| Download: ML22285A130 (10) | |
Text
Attachment 13 to to ULNRC-06768 Page 1 of 10 ATTACHMENT 13 RESPONSE TO INSUFFICIENCY ITEMS FROM FIRST LICENSE AMENDMENT REQUEST 3 to to ULNRC-06768 Page 2 of 10 RESPONSE TO INFORMATION INSUFFICIENCIES Note: References are specific to this attachment and located at the end of this attachment.
During the acceptance review of the previously submitted license amendment request (Reference 1), the NRC staff identified in Reference 2 four items deemed insufficiencies in the original submittal. For unrelated reasons, the license amendment request was subsequently withdrawn which the NRC acknowledged in Reference 3. In Reference 3, the NRC staff stipulated that should Ameren Missouri decide to re-submit the license amendment request, the identified insufficiencies must be addressed. To address this stipulation, the insufficiencies are addressed in this Attachment.
Information Insufficiencies:
- 1. Enclosure 1 of the licensees letter identifies that the results of the control rod ejection event analysis will be available for review by the NRC staff but does not identify a timeline for availability. More detailed information concerning the schedule for providing this analysis appears necessary to support a determination of the NRC staffs review timeline.
Ameren Missouri Response:
The results of the control rod ejection event will be available for review by the NRC staff not later than the date of this LAR submittal.
- 2. In general, the limitations and conditions, established by NRC staff, for each technical report associated with GAIA fuel, and requested by the licensee to be added to its licensing basis, are not dispositioned or addressed.
Ameren Missouri Response:
The following table provides, for each topical report, a cross-reference between the topical report and the disposition of the limitations and conditions identified in the safety evaluation report (SER) for the topical report. The second column provides the location of the limitations and conditions, if any, in the NRC SER. The third column specifies where the disposition of the limitation and condition is addressed within the license amendment request. For limitations and conditions identified as not having been addressed, their relevance is qualified in the table.
Table 7-1 in Attachment 9 to Enclosure 1 of this license amendment request provides a listing of the NRC approved topical reports being added to Callaway's license basis. [Note that while the text in Section 7 in Attachment 9 to Enclosure 1 indicates that this content will be added to the COLR, that text is a hold-over from the original intent of the document to support fuel transition.
This LAR will not add these methods to the COLR nor to the listing of methods in TS 5.6.5.b.
This content will be placed in the FSAR description associated with the Framatome GAIA fuel.]
3 to to ULNRC-06768 Page 3 of 10 Cross-Reference Table for SER Limitations and Conditions Topical Report SER Conditions, Limitations, Reference to Location of Restrictions1 Discussion in LAR or Additional Notes EMF-2103(P)(A), Refer to Section 4 of the SER for EMF- Section 3.7 and Table 3-1 Revision 3, 2103(P)(A), Revision 3 (NRC-IC-16-011) of ANP-3944P, Revision 1, Realistic Large Callaway Realistic Large Break LOCA Break LOCA Analysis Methodology for (ULNRC-06768 Enclosure Pressurized Water 1, Attachment 10)
Reactors EMF-2328(P)(A), A condition imposed on the use of ANF- Section 3.2, 3.5 and 4.1 of Revision 0, RELAP in a previously approved ANP-3943P, Revision 1, PWR Small methodology regarding break size is applied Callaway Small Break Break LOCA to the use of S-RELAP5 in EMF- LOCA Analysis with Evaluation 2328(P)(A) Rev 0. This condition is GAIA. ULNRC-06768 Model, addressed in EMF-2328 Supplement Enclosure 1, Attachment S-RELAP5 1(P)(A), Rev 0. 11. There are no limitations Based specified other than the break size.
EMF-2328(P)(A), EMF-2328 Supplement 1 contains no new See Section 3.5 of ANP-Revision 0, limitations or conditions. 3943P, Revision 1, Supplement 1, Callaway Small Break Revision 0, LOCA Analysis with PWR Small GAIA. ULNRC-06768 Break LOCA Enclosure 1, Attachment 11 Evaluation Model, S-RELAP5 Based 1
This column identifies the existence or absence of any limitations and conditions associated with the specified method. If limitations or conditions do apply, the location of the limitations and condition (in the NRC's SER or other document) is provided. The text of the actual limitation or condition has been omitted for the sake of brevity.
3 to to ULNRC-06768 Page 4 of 10 Topical Report SER Conditions, Limitations, Reference to Location of Restrictions1 Discussion in LAR or Additional Notes EMF-2310(P)(A), Refer to section 5.0 of the SER for EMF- Section 3.9, ANP-3969P, Revision 1, SRP 2310(P)(A), Revision 0 dated 5/19/2004. Revision 2, Callaway Non-Chapter 15 Non- Note that Rev 1 imposed no new limitations. LOCA Summary Report."
LOCA Conditions in section 4.0 for dilution event ULNRC-06768 Enclosure Methodology for analyses are captured in the internal Boron 1, Attachment 12 Section Pressurized Water Dilution Guideline (FS1-0010448) which 3.9 (specifically the Reactors was used for the Callaway analysis, FS1- requirements for 0057494. justification of nodalization, input parameters options selected, and consideration of chosen parameters.)
XN-NF No limitations stated, but section 4.0 Staff Section 3.9, ANP-3969P, 21(P)(A), Position imposes a 2% MDNBR penalty for Revision 2, Callaway Non-Revision 1, mixed cores. LOCA Summary Report."
Application of ULNRC-06768 Enclosure Exxon Nuclear 1, Attachment 12 Section Company PWR 3.9 Thermal Margin Methodology to Mixed Core Configurations EMF Refer to the 2 conditions listed in section Section 5.4 of ANP-3947P, 081(P)(A), 4.0 of the SER Revision 3, and Section 3.9 Revision 1, ANP-3969P, Revision 2, Statistical Callaway Non-LOCA Setpoint/Transient Summary Report."
Methodology for ULNRC-06768 Enclosure Westinghouse 1, Attachment 9 section 5.4 Type Reactors and Attachment 12 Section 3.9 ANP- Refer to section 4.0 of the SER for ANP- Section 3.9 and Table 3-10 10341(P)(A), 10341(P)(A), Revision 0 dated 9/24/2018. (for correlation limits) of Revision 0, The ANP-3969P, Revision 2, ORFEO-GAIA Callaway Non-LOCA and ORFEO- Summary Report."
NMGRID Critical ULNRC-06768 Enclosure Heat Flux 1, Attachment 12 Section Correlations 3.9 3 to to ULNRC-06768 Page 5 of 10 Topical Report SER Conditions, Limitations, Reference to Location of Restrictions1 Discussion in LAR or Additional Notes XN-75-21(P)(A), Refer to Conclusion 2 of section 5.0 of the Section 3.9 and 3.10 of Revision 2, SER for XN-75-21(P)(A), Revision 2, ANP-3969P, Revision 2, XCOBRA-IIIC: XCOBRAIIIC which limits use of the code Callaway Non-LOCA A Computer Code to the snapshot mode and excludes Summary Report."
to Determine the LOCA/ECCS with reverse flow and ULNRC-06768 Enclosure Distribution of recirculation. 1, Attachment 12 Section Coolant During 3.9 and 3.10 Steady State and Transient Core Operation ANP-10311P-A, Refer to section 4.0 of the SER for ANP- Section 5.4 of ANP-3947P, Revision 1, 10311P-A, Revision 1, COBRAFLX" Revision 3, and Sections COBRA-FLX: A (dated 10/18/2017) for the 2 limitations 3.9 and 3.10 of ANP-Core Thermal- related to empirical correlations and 3969P, Revision 2, Hydraulic restrictions on the COBRAFLX fuel rod Callaway Non-LOCA Analysis Code model. Summary Report."
ULNRC-06768 Enclosure 1, Attachment 9 section 5.4 and Attachment 12 Section 3.9 and 3.10 3 to to ULNRC-06768 Page 6 of 10 Topical Report SER Conditions, Limitations, Reference to Location of Restrictions1 Discussion in LAR or Additional Notes XN-NF Refer to Section
7.0 CONCLUSION
S Section 3.9 of ANP-3969P, 06(P)(A), section of SER. Per Attachment 12: "No Revision 2, Callaway Non-Revision 1, restrictions, limitations, and/or conditions LOCA Summary Report."
Supplement 2, 4, are identified in the SER for XN-NF ULNRC-06768 Enclosure and 5, 06(P)(A), Revision 1 Supplement 5 relative 1, Attachment 12, Section Qualification of to DNB propagation." 3.9.
Exxon Nuclear Fuel for Extended For the Callaway VQP Burnup scope, XN-NF-82-06 is only applied for DNB propagation. The Non-LOCA Summary report contains the following statement to address this (section 3.9.1, page 10):
"The quantity of fuel failures includes the effects of DNB propagation as defined in Reference 13, Supplement 5. This method is typically applied conservatively by assuming a single rod failure propagates to the entire assembly. No restrictions, limitations, and/or conditions are identified in the SER for Reference 13, Supplement 5 relative to DNB propagation."
XN-75-32(P)(A) No specific limitations are stated in the SER Section 5.4 of ANP-3947P, Supplements 1, 2, - just a recommendation for continued Revision 3, which is 3, and 4, vendor fuel surveillance program. provided as Attachment 9 Computational of ULNRC-06768 Procedure for Enclosure 1.
Evaluating Fuel Rod Bowing 3 to to ULNRC-06768 Page 7 of 10 Topical Report SER Conditions, Limitations, Reference to Location of Restrictions1 Discussion in LAR or Additional Notes ANP-10297P-A, Refer to the section 3.0 of the SER for Section 3.3 of ANP-3947P, Revision 0, The ANP-10297P-A, Revision 0. (Note that the Revision 3, and Section 3.9 ARCADIA SER for ANP-10297P-A, Revision 0 and 3.10 ANP-3969P, Reactor Analysis included 3 limitations. The SER for Supp 1- Revision 2, Callaway Non-System for PWRs PA rev 1 eliminated the third and included LOCA Summary Report."
Methodology the first 2 and added 4, 5 and 6.) ULNRC-06768 Enclosure 1 Description and Attachment 9 section 3.3 Benchmarking and Attachment 12 sections Results 3.9 and 3.10 ANP-10297P-A, See above. Section 3.3 of ANP-3947P, Revision 0, Revision 3, and Section 3.9 Supplement 1PA, and 3.10 ANP-3969P, Revision 1, The Revision 2, Callaway Non-ARCADIA LOCA Summary Report."
Reactor Analysis ULNRC-06768 Enclosure 1 System for PWRs Attachment 9 section 3.3 Methodology and Attachment 12 sections Description and 3.9 and 3.10 Benchmarking Results ANP-10338P-A, Refer to section 5.0 of the SER for ANP- Section 6.1.1.3 of ANP-Revision 0, 10338P-A, Revision 0 dated 12/20/2-17 3947P, Revision 3, AREA - (NRC-IC-17-051). (ULNRC-06768 Enclosure ARCADIA Rod 1, Attachment 9)
Ejection Limitation 1 is addressed Accident since this analysis is only used for the rod ejection as discussed in section 6.1.1.3 of ULNRC-06768 Enclosure 1, Attachment 9 Limitation 2 refers to the conditions and limitations of the coupled codes that comprise the ARCADIA Rod Ejection Accident.
Limitation 3 is addressed in section 6.1.1.3 of ULNRC-06768 Enclosure 1, Attachment 9.
3 to to ULNRC-06768 Page 8 of 10 Topical Report SER Conditions, Limitations, Reference to Location of Restrictions1 Discussion in LAR or Additional Notes ANP-10323P-A, Refer to section 5.0 of the SER for ANP- Section 6.1.1.3 of ANP-Revision 1, 10323P-A, Revision 1 3947P, Revision 3, GALILEO Fuel Dated 12/20/2017 (ULNRC-06768 Enclosure Rod Thermal-
- The application of GALILEO should 1, Attachment 9)
Mechanical assume fuel failure when the predicted fuel Methodology for temperatures exceed the fuel melting Bullet 1: This is addressed Pressurized Water temperature as calculated by GALILEO due in Section 6.1.1.2 of ANP-Reactors to the lack of properties for molten fuel in 3947P, Revision 3.
GALILEO and other properties such as thermal conductivity and fission gas release. Bullet 2: General requirement. For the
- The ability to make changes to both the Callaway AREA analysis, mean and standard deviation of model GALILEO is used for two parameter uncertainty values without NRC aspects of the analysis.
review and approval is not approved. These are:
Because of the complex interaction between 1. Generation of fuel limits parameters in fuel performance codes, the that are the basis for NRC staff does not approve the ability to comparisons of ARTEMIS make changes to the model parameters results.
without NRC approval. 2. Generation of hgap and porosity tables.
- The peak axial node burnup for the fuel rod is limited to [proprietary] GWd/MTU.
Bullet 3: The peak node
- No methodology has been approved for burnup is shown to be less providing initial data or conditions for than the GALILEO limit in ECCS analysis. the computer output files in the AREA limits analysis (FS1-0056223-2.0).
Bullet 4: This does not apply to the AREA inputs.
BAW-10231P-A, None other than a 62 GWD/MTU limit for Section 2.4.4 of ANP-Revision 1, rod average burn-up. 3947P, Revision 3, COPERNIC (ULNRC-06768 Enclosure Fuel Rod Design 1, Attachment 9) and Computer Code Section 3.9 and 3.10 of ANP-3969P, Revision 2, Callaway Non-LOCA Summary Report,"
(ULNRC-06768 Enclosure 1, Attachment 12).
3 to to ULNRC-06768 Page 9 of 10 Topical Report SER Conditions, Limitations, Reference to Location of Restrictions1 Discussion in LAR or Additional Notes BAW-10227P-A, None explicitly listed. Section 2.4.4 of ANP-Revision 1, 3947P, Revision 3, Evaluation of (ULNRC-06768 Enclosure Advanced 1, Attachment 9).
Cladding and Structural Material (M5) in PWR Reactor Fuel ANP-10342P-A, Refer to Section 4.0 of the SER for ANP- Section 2.4.3.1 of ANP-Revision 0, 10342P-A, Revision 0 (dated 9/24/2019). 3947P, Revision 3, GAIA Fuel (ULNRC-06768 Enclosure Assembly 1, Attachment 9)
Mechanical Design
- 3. The licensee proposes a unique TS structure, which includes parallel sets of TS requirements for TSs 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)); 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor; and 3.2.3, Axial Flux Difference (AFD) (Relaxed Axial Offset Control (RAOC) Methodology, with one set of requirements based on Westinghouse fuel and methods, and the other based on those of Framatome. While the licensee would allow both fuel types to be present in limiting locations for several cycles, only one set of these TS requirements would apply for each cycle. Framatome has performed confirmatory analysis for its fuel, and the two sets of parallel TS operating limits would be similar. However, differences remain, such as with respect to TS required actions and surveillances. The basis for selecting one or the other of the parallel sets of TS requirements as governing for a given cycle is not clear and does not necessarily appear to be associated with which type of fuel has the limiting operating margin. The application does not appear to include sufficient information justifying why the TS requirements for the fuel type considered to govern Core Operating Limits Report development adequately protect the other fuel type, which could be more limiting with respect to operating margin.
Ameren Missouri Response:
The license amendment request presented in this letter, ULNRC-06768, does not include proposed changes to the TS Section 3.2, "Power Distribution Limits," nor does it include the unique TS structure originally proposed. As reflected in this license amendment request, the current TSs continue to reflect the Westinghouse TS LCOs supported by the current Westinghouse methodologies listed in TS 5.6.5, "Core Operating Limits Report (COLR)." A 3 to to ULNRC-06768 Page 10 of 10 summary description of how Westinghouse provides confirmation of core reload analysis and its ability to support the presence of the eight GAIA fuel assemblies has been added at the end of Section 3, "Technical Evaluation," in Enclosure 1.
- 4. Enclosure 1, Attachment 12 (ANP-3969P) identifies that evaluation of the inadvertent loading and operation of a fuel assembly in an improper position event will be provided by the licensee. However, the NRC staff could not locate the analysis or disposition of this event in the licensee's submittal. This information should be provided, and the licensee should clarify the expected schedule to support a determination of the staffs review timeline.
Ameren Missouri Response:
The LAR described in Enclosure 1 of this letter, ULNRC-06768, contains a description of the disposition of this event. Refer to Section 2.2 of Enclosure 1.
References:
- 1. Ameren Missouri letter ULNRC-06729, "Application for Technical Specification Change and Exemption Request Regarding Transition to Framatome Fuel, LDCN 22-0002,"
dated June 2, 2022 (ADAMS Accession No. ML22153A174).
- 2. NRC Letter "Callaway Plant, Unit No. 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action re: Amendment to Allow Use of Framatome GAIA Fuel (EPID L-2022-LLA-0083)," dated July 19, 2022 (ADAMS Accession No. ML22199A177).
- 3. NRC Letter "Callaway Plant, Unit No. 1 - Withdrawal of Requested Licensing Action re:
License Amendment Request for Technical Specification Change and Exemption Request Regarding Transition to Allow Use of Framatome GAIA Fuel, Submitted to NRC for Acceptance Review (EPID L-2022-LLA-0083 and EPID L-2022-LLE-0019),"
dated August 15, 2022 (ADAMS Accession No. ML22220A281).