ULNRC-06292, Transmittal of 10 CFR50.46 Annual Report ECCS Evaluation Model Revisions

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Transmittal of 10 CFR50.46 Annual Report ECCS Evaluation Model Revisions
ML16091A166
Person / Time
Site: Callaway Ameren icon.png
Issue date: 03/30/2016
From: Wink R
Ameren Missouri, Union Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06292
Download: ML16091A166 (11)
v • d • e


Text

/JI1JeteII Callaway Plant MISSOURI March 30, 2016 ULNRC-06292 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.46 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC Co.

FACILITY OPERATING LICENSE NPF-30 10 CFR 50.46 ANNUAL REPORT ECCS EVALUATION MODEL REVISIONS

References:

1) ULNRC-05260 dated 3-9-06
2) ULNRC-05378 dated 3-7-07
3) ULNRC-05475 dated 3-4-08
4) ULNRC-05 600 dated 3-4-09
5) ULNRC-05683 dated 3-1-10
6) ULNRC-05769 dated 3-1-1 1
7) ULNRC-05840 dated 3-1-12
8) ULNRC-05968 dated 3-6-13
9) ULNRC-06098 dated 3-25-14
10) ULNRC-06203 dated 3-31-15 Ameren Missouri hereby submits the annual report required per 10 CFR 50.46(a)(3) for Callaway Plant. Attachment 1 to this letter describes changes to the Westinghouse ECCS Large Break and Small Break Loss of Coolant Accident (LOCA) Evaluation Models which have been implemented for Callaway during the time period from March 2015 to March 2016. Attachment 2 provides an ECCS Evaluation Model Margin Assessment which accounts for all peak cladding temperature (PCI) changes resulting from the resolution of prior issues as they apply to Callaway. No new PCI penalties are included in these attachments.

References 1 through 10 provided annual 10 CFR 50.46 reports that were issued after the LOCA analysis were revised to reflect the installation of the replacement steam generators in 2005. The PCI values determined in the Large Break and Small Break LOCA analysis of record, when combined with all PCI margin allocations, remain below the 2200°F regulatory limit. However, in March 2014, P0 Box 620  : Fulton, Fy10 65251 AnierenFVlissouri.corn STARS Alliance

ULNRC-06292 March 30, 2016 Page 2 Ameren Missouri was informed by Westinghouse that the absolute magnitude of the Large Break Loss of Coolant Accident (LBLOCA) penalty assessments that have accumulated since the current analysis of record (replacement steam generator analysis approved in Callaway License Amendment 16$)

exceeded 5 0°F. As such, Reference 9 was submitted within the requirements of 10 CFR 50.46(a)(3)(ii), and contains a commitment to reanalyze the Large Break and Small Break Loss of Coolant Accidents using the NRC-approved version of WCAP- 1 6996-P, Realistic LOCA Evaluation Methodology Applied to the Full Spectrum of Break Sizes (FULL SPECTRUM LOCA Methodology), which is still under NRC review. This reanalysis will be completed on a schedule to be determined as part of the 10 CFR 50.46c rulemaking process.

This letter does not contain new commitments. If you have any questions on this report, please contact Mr. Tom Elwood at (314) 225-1905.

Sincerely, Z oger Wink, (7 Manger, Regulatory Affairs JBL Attachments:

1. Changes to the Westinghouse ECCS Evaluation Model and PCT Penalty Assessments
2. ECCS Evaluation Model Margin Assessment for Callaway

ULNRC-062 92 March 30, 2016 Page 3 cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission

$201 NRC Road Steedman, MO 65077 Mr. L. John Klos Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 08H4 Washington, DC 20555-000 1

ULNRC-06292 March 30, 2016 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:

F. M. Diya T. E. Hermiann B. L. Cox R. C. Wink

1. B. Elwood Corporate Communications NSRB Secretary B.D. Richardson J. Cordz Mr. Greg Voss, REP Manager (SEMA)

STARS Regulatory Affairs Mr. John ONeill (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Learine Tippett-Mosby (DNR)

ULNRC-06292 ATTACHMENT ONE CHANGES TO THE WESTINGHOUSE ECCS EVALUATION MODEL AND PCT PENALTY ASSESSMENTS 1

ULNRC-06292 TABLE OF CONTENTS

1. FUEL ROD GAP CONDUCTANCE ERROR
2. RADIATION HEAT TRANSFER MODEL ERROR
3. SBLOCTA PRE-DNB CLADDING SURFACE HEAT TRANSFER COEFFICIENT CALCULATION
4. GENERAL CODE MAINTENANCE 2

ULNRC-062 92

1. FUEL ROD GAP CONDUCTANCE ERROR An error was identified in the fuel rod gap conductance model in the NOTRUMP computer code (reactor coolant system response model). The error is associated with the use of an incorrect temperature in the calculation of the cladding emissivity term. This error corresponds to a Non-Discretionary Change as described in Section 4.1.2 ofWCAP-13451.

Based on a combination of engineering judgment of the phenomena and physics of a small break LOCA, and sensitivity calculations performed with the advanced plant version of NOTRUMP, Westinghouse has concluded that this error has a negligible effect, leading to an estimated Peak Cladding Temperature (PCI) impact of 0°F on small break LOCA analysis results.

2. RADIATION HEAT TRANSFER MODEL ERROR Two errors were discovered in the calculation of the radiation heat transfer coefficient within the fuel rod model of the NOTRUMP computer code (reactor coolant system response model). First, existing logic did not preclude non-physical negative or large (negative or positive) radiation heat transfer coefficients from being calculated. These erroneous calculations occurred when the vapor temperature exceeded the cladding surface temperature or when the predicted temperature difference was less than 1°F. Second, a temperature term incorrectly used degrees Fahrenheit instead of Rankine. These errors represent a closely related group of Non-Discretionary problems in accordance with Section 4.1.2 of WCAP-1345 1.

Based on a combination of engineering judgment of the phenomena and physics of a small break LOCA, and sensitivity calculations performed with the advanced plant version of NOTRUMP, Westinghouse has concluded that this error has a negligible effect, leading to an estimated Peak Cladding Temperature (PCT) impact of 0°F on small break LOCA analysis results.

3. SBLOCTA PRE-DNB CLADDING SURFACE HEAT TRANSFER COEFFICIENT CALCULATION Two errors were discovered in the pre-departure from nucleate boiling (pre-DNB) cladding surface heat transfer coefficient calculation in the SBLOCTA code (cladding heat-up calculations). The first error is a result of inconsistent time units (hours vs. seconds) in the parameters used for the calculation of the Reynolds and Prandtl numbers, and the second error relates to an incorrect diameter used to develop the area term in the cladding surface heat flux calculation. Both of these issues impact the calculation of the pre-DNB convective heat transfer coefficient, representing a closely related group of Non-Discretionary Changes to the Evaluation Model as described in Section 4.1.2 of WCAP- 13451.

These errors have been corrected in the SBLOCTA code. Because this condition occurred prior to DNB, it was judged that these errors had no direct impact on the cladding heat-up related to the core uncover period. A series of validation tests were performed by Westinghouse and confirmed that these errors have a negligible effect on SBLOCA analysis results, leading to an estimated Peak Cladding Temperature (PCI) impact of 0°F.

3

ULNRC-06292

4. GENERAL CODE MAINTENANCE Various changes have been made to enhance the usability of the codes and to help preclude errors in analyses. This includes items such as modifying input variable definitions, units, and defaults; improving the input diagnostic checks; enhancing the code output; optimizing active coding; and eliminating inactive coding. These changes have been evaluated for impact on existing Small Break LOCA analysis results and they represent Discretionary Changes that will be implemented on a forward-fit basis in accordance with Section 4.1.1 of WCAP-1345.

Westinghouse has judged this issue to have an estimated PCT impact of 0°F on existing Small Break LOCA analysis results.

4

ULNRC-06292 ATTACHMENT TWO ECCS EVALUATION MODEL MARGIN ASSESSMENT FOR CALLAWAY 1

ULNRC-06292 LARGE BREAK LOCA A. ANALYSIS Of RECORD (AOR) PCT 193 9°F B. PRIOR ECCS MODEL ASSESSMENTS + 58°F C. CURRENT LOCA MODEL ASSESSMENTS -

+ 0°F March 2016 LICENSiNG BASIS PCT + MARGIN ALLOCATIONS 1997°F ABSOLUTE MAGNITUDE OF MARGIN ALLOCATIONS 58°F SINCE LAST ANALYSIS OF RECORD OR LBLOCA 30-DAY REPORT 2

ULNRC-06292 SMALL BREAK LOCA A. ANALYSIS Of RECORD (AOR) PCT = 1043°F B. PRIOR ECCS MODEL ASSESSMENTS + 0°F C. CURRENT ECC$ MODEL ASSESSMENTS -

+ 0°F March 2016 LICENSING BASIS PCI + MARGIN ALLOCATIONS 1043°F ABSOLUTE MAGNITUDE Of MARGIN ALLOCATIONS 0°F SINCE LAST ANALYSIS Of RECORD OR SBLOCA 30-DAY REPORT 3

/JI1JeteII Callaway Plant MISSOURI March 30, 2016 ULNRC-06292 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.46 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC Co.

FACILITY OPERATING LICENSE NPF-30 10 CFR 50.46 ANNUAL REPORT ECCS EVALUATION MODEL REVISIONS

References:

1) ULNRC-05260 dated 3-9-06
2) ULNRC-05378 dated 3-7-07
3) ULNRC-05475 dated 3-4-08
4) ULNRC-05 600 dated 3-4-09
5) ULNRC-05683 dated 3-1-10
6) ULNRC-05769 dated 3-1-1 1
7) ULNRC-05840 dated 3-1-12
8) ULNRC-05968 dated 3-6-13
9) ULNRC-06098 dated 3-25-14
10) ULNRC-06203 dated 3-31-15 Ameren Missouri hereby submits the annual report required per 10 CFR 50.46(a)(3) for Callaway Plant. Attachment 1 to this letter describes changes to the Westinghouse ECCS Large Break and Small Break Loss of Coolant Accident (LOCA) Evaluation Models which have been implemented for Callaway during the time period from March 2015 to March 2016. Attachment 2 provides an ECCS Evaluation Model Margin Assessment which accounts for all peak cladding temperature (PCI) changes resulting from the resolution of prior issues as they apply to Callaway. No new PCI penalties are included in these attachments.

References 1 through 10 provided annual 10 CFR 50.46 reports that were issued after the LOCA analysis were revised to reflect the installation of the replacement steam generators in 2005. The PCI values determined in the Large Break and Small Break LOCA analysis of record, when combined with all PCI margin allocations, remain below the 2200°F regulatory limit. However, in March 2014, P0 Box 620  : Fulton, Fy10 65251 AnierenFVlissouri.corn STARS Alliance

ULNRC-06292 March 30, 2016 Page 2 Ameren Missouri was informed by Westinghouse that the absolute magnitude of the Large Break Loss of Coolant Accident (LBLOCA) penalty assessments that have accumulated since the current analysis of record (replacement steam generator analysis approved in Callaway License Amendment 16$)

exceeded 5 0°F. As such, Reference 9 was submitted within the requirements of 10 CFR 50.46(a)(3)(ii), and contains a commitment to reanalyze the Large Break and Small Break Loss of Coolant Accidents using the NRC-approved version of WCAP- 1 6996-P, Realistic LOCA Evaluation Methodology Applied to the Full Spectrum of Break Sizes (FULL SPECTRUM LOCA Methodology), which is still under NRC review. This reanalysis will be completed on a schedule to be determined as part of the 10 CFR 50.46c rulemaking process.

This letter does not contain new commitments. If you have any questions on this report, please contact Mr. Tom Elwood at (314) 225-1905.

Sincerely, Z oger Wink, (7 Manger, Regulatory Affairs JBL Attachments:

1. Changes to the Westinghouse ECCS Evaluation Model and PCT Penalty Assessments
2. ECCS Evaluation Model Margin Assessment for Callaway

ULNRC-062 92 March 30, 2016 Page 3 cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission

$201 NRC Road Steedman, MO 65077 Mr. L. John Klos Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 08H4 Washington, DC 20555-000 1

ULNRC-06292 March 30, 2016 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:

F. M. Diya T. E. Hermiann B. L. Cox R. C. Wink

1. B. Elwood Corporate Communications NSRB Secretary B.D. Richardson J. Cordz Mr. Greg Voss, REP Manager (SEMA)

STARS Regulatory Affairs Mr. John ONeill (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Learine Tippett-Mosby (DNR)

ULNRC-06292 ATTACHMENT ONE CHANGES TO THE WESTINGHOUSE ECCS EVALUATION MODEL AND PCT PENALTY ASSESSMENTS 1

ULNRC-06292 TABLE OF CONTENTS

1. FUEL ROD GAP CONDUCTANCE ERROR
2. RADIATION HEAT TRANSFER MODEL ERROR
3. SBLOCTA PRE-DNB CLADDING SURFACE HEAT TRANSFER COEFFICIENT CALCULATION
4. GENERAL CODE MAINTENANCE 2

ULNRC-062 92

1. FUEL ROD GAP CONDUCTANCE ERROR An error was identified in the fuel rod gap conductance model in the NOTRUMP computer code (reactor coolant system response model). The error is associated with the use of an incorrect temperature in the calculation of the cladding emissivity term. This error corresponds to a Non-Discretionary Change as described in Section 4.1.2 ofWCAP-13451.

Based on a combination of engineering judgment of the phenomena and physics of a small break LOCA, and sensitivity calculations performed with the advanced plant version of NOTRUMP, Westinghouse has concluded that this error has a negligible effect, leading to an estimated Peak Cladding Temperature (PCI) impact of 0°F on small break LOCA analysis results.

2. RADIATION HEAT TRANSFER MODEL ERROR Two errors were discovered in the calculation of the radiation heat transfer coefficient within the fuel rod model of the NOTRUMP computer code (reactor coolant system response model). First, existing logic did not preclude non-physical negative or large (negative or positive) radiation heat transfer coefficients from being calculated. These erroneous calculations occurred when the vapor temperature exceeded the cladding surface temperature or when the predicted temperature difference was less than 1°F. Second, a temperature term incorrectly used degrees Fahrenheit instead of Rankine. These errors represent a closely related group of Non-Discretionary problems in accordance with Section 4.1.2 of WCAP-1345 1.

Based on a combination of engineering judgment of the phenomena and physics of a small break LOCA, and sensitivity calculations performed with the advanced plant version of NOTRUMP, Westinghouse has concluded that this error has a negligible effect, leading to an estimated Peak Cladding Temperature (PCT) impact of 0°F on small break LOCA analysis results.

3. SBLOCTA PRE-DNB CLADDING SURFACE HEAT TRANSFER COEFFICIENT CALCULATION Two errors were discovered in the pre-departure from nucleate boiling (pre-DNB) cladding surface heat transfer coefficient calculation in the SBLOCTA code (cladding heat-up calculations). The first error is a result of inconsistent time units (hours vs. seconds) in the parameters used for the calculation of the Reynolds and Prandtl numbers, and the second error relates to an incorrect diameter used to develop the area term in the cladding surface heat flux calculation. Both of these issues impact the calculation of the pre-DNB convective heat transfer coefficient, representing a closely related group of Non-Discretionary Changes to the Evaluation Model as described in Section 4.1.2 of WCAP- 13451.

These errors have been corrected in the SBLOCTA code. Because this condition occurred prior to DNB, it was judged that these errors had no direct impact on the cladding heat-up related to the core uncover period. A series of validation tests were performed by Westinghouse and confirmed that these errors have a negligible effect on SBLOCA analysis results, leading to an estimated Peak Cladding Temperature (PCI) impact of 0°F.

3

ULNRC-06292

4. GENERAL CODE MAINTENANCE Various changes have been made to enhance the usability of the codes and to help preclude errors in analyses. This includes items such as modifying input variable definitions, units, and defaults; improving the input diagnostic checks; enhancing the code output; optimizing active coding; and eliminating inactive coding. These changes have been evaluated for impact on existing Small Break LOCA analysis results and they represent Discretionary Changes that will be implemented on a forward-fit basis in accordance with Section 4.1.1 of WCAP-1345.

Westinghouse has judged this issue to have an estimated PCT impact of 0°F on existing Small Break LOCA analysis results.

4

ULNRC-06292 ATTACHMENT TWO ECCS EVALUATION MODEL MARGIN ASSESSMENT FOR CALLAWAY 1

ULNRC-06292 LARGE BREAK LOCA A. ANALYSIS Of RECORD (AOR) PCT 193 9°F B. PRIOR ECCS MODEL ASSESSMENTS + 58°F C. CURRENT LOCA MODEL ASSESSMENTS -

+ 0°F March 2016 LICENSiNG BASIS PCT + MARGIN ALLOCATIONS 1997°F ABSOLUTE MAGNITUDE OF MARGIN ALLOCATIONS 58°F SINCE LAST ANALYSIS OF RECORD OR LBLOCA 30-DAY REPORT 2

ULNRC-06292 SMALL BREAK LOCA A. ANALYSIS Of RECORD (AOR) PCT = 1043°F B. PRIOR ECCS MODEL ASSESSMENTS + 0°F C. CURRENT ECC$ MODEL ASSESSMENTS -

+ 0°F March 2016 LICENSING BASIS PCI + MARGIN ALLOCATIONS 1043°F ABSOLUTE MAGNITUDE Of MARGIN ALLOCATIONS 0°F SINCE LAST ANALYSIS Of RECORD OR SBLOCA 30-DAY REPORT 3

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