ML13197A095
| ML13197A095 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/11/2013 |
| From: | Arizona Public Service Co |
| To: | Division of Operating Reactor Licensing |
| Rankin J K | |
| References | |
| TAC MF1932, TAC MF1933, TAC MF1934 | |
| Download: ML13197A095 (23) | |
Text
Implementation of STAR Program and Replacement of the 2/3 Cycle MTC Measurement Pre-Submittal Presentation to the NRC Date: 07/11/2013
Purpose Present and discuss with the NRC planned licensing changes
-Implementation of the Startup Testing Activity Reduction (STAR) Program at PVNGS
-Replacement of the 2/3 Cycle Moderator Temperature Coefficient (MTC) Measurement 2
Topics STAR Replacement of the 2/3 Cycle MTC Measurement Licensing Approach Conclusion and Discussion 3
STAR Objectives
-Alternate method to validate core design
-Minimize the time the plant is in an abnormal configuration 4
STAR Overview -Approved by NRC in WCAP
-16011-P-A Participating plants only Successfully implemented at 8 CE units
-Incorporated into Improved Standard TS NUREG-1432, Rev 4 TSTF 486 5 STAR Overview -Adds Credits Pre
-Operational Checks New Beginning of Cycle (BOC) Hot Zero Power (HZP) MTC surveillance methodology Applicability Requirements
-Replaces BOC HZP Isothermal Temperature Coefficient (ITC) Measurement CEA Worth Measurement 6
STAR Current Methodology
-CEA worth measurement Require operation outside the normal TS LCOs Presents operational challenges
-Unit 3 LER 2012
-001 -Unit 1 LER 2011
-005 -Measure ITC at HZP with use of reactivity computer 7 STAR Proposed Methodology
-Replacement of CEA Worth Measurements Use applicability requirements Replacement will reduce the occurrence of problems associated with testing and minimize time in abnormal operating configuration 8
STAR Proposed Methodology (cont.)
-Alternate MTC verification Adjust predicted HZP MTC based on measured Critical Boron Increase availability of the control channels Align PVNGS with Improved Standard TS 9
STAR Applicability Requirements
-Found in Table 3
-4 of WCAP
-16011-P-A -Compliance evaluated on a reload cycle
-specific basis
-STAR only applied to cycles when compliance verified -Maintain the effectiveness of the STAR Program in problem identification 10 STAR Applicability Requirements (cont.)
-Core design methods have a defined set of uncertainties based on a benchmark of predictions to actual plant measurements
-Core, fuel, CEA design are similar to that of a benchmarked core
-Cycle specific predictions independently verified by Comparison of 2 independent neutronics codes 11 STAR Applicability Requirements (cont.)
-Implementation of CEA Lifetime Program Limit CEA life within operation experience base
-Pre-operational checks verify core and CEA loading are consistent with design
-CEA Coupling checks performed during reactor restack Many favorable PVNGS unique design feature 12 STAR Benefits -Minimize the time the plant is in an abnormal operating configuration
-Increase the availability of the control channels
-Operationally focused improvement 13 STAR WCAP 16011
-P-A approach
-Compare STAR Program to Generic Program Generic Program based on ANSI/ANS 19.6.1
-1997Property "ANSI code" (as page type) with input value "ANSI/ANS 19.6.1</br></br>-1997" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. Identify set of core problems
-Design Predictions
-As-Built Core
-Test Performance 14 STAR WCAP 16011
-P-A approach (cont.)
-Concluded STAR Program is as effective in detecting the Problems as the Generic Program
-STAR is an NRC approved and implemented alternative to current testing methodology.
-Compared Design differences between PVNGS and original participating plants Differences in current PVNGS startup program and Generic Program Operating Experience since original STAR
-NRC and INPO
-PVNGS -Implementing plants 16 STAR Results of Evaluations
-Contained in plant specific justification
-CASMO/SIMULATE as applied at PVNGS is acceptable for STAR
-The PVNGS STAR Program is as effective as the approved STAR Program and is an acceptable alternative to the current PVNGS startup testing program.
17 Replacement of 2/3 Cycle MTC Measurement Objective
-To replace the 2/3 cycle MTC measurement with alternate verification Overview -Approved for all CE plants in CE NPSD
-911-A and Amendment 1
-A (TSTF 406)
-No measurement at 2/3 cycle if 40 EFPD measurement is within acceptance criteria
-Already implemented at many PWRs 18 Replacement of 2/3 Cycle MTC Measurement Current Topical only applicable for ROCS & ANC PVNGS will demonstrate applicability of SIMULATE Conclusions
-SIMULATE is acceptable for use
-Replacement of the 2/3 cycle MTC measurement is acceptable at PVNGS including STAR Cycles 19 Licensing Approach Submit one LAR
-Replacement of 2/3 cycle MTC Measurement 20 Licensing Approach Technical Specification 3.1.4 MTC
-SR 3.1.4.1 (HZP verification)
Add note allowing use of alternate BOC HZP MTC surveillance method (TSTF 486)
-SR 3.1.4.2 (At power verifications)
Add note allowing replacement of 2/3 cycle at power MTC Measurement (CE
-NPSD-911 & TSTF 406) 21 Licensing Approach Proposed Schedule
-Submit November 2013
-Requesting NRC Approval in November 2014
-First use in Spring of 2015 22 Conclusion and Discussion Acceptable to implement the STAR Program at PVNGS Acceptable to replace the 2/3 cycle at power MTC measurement Submit both under a single LAR November 2013 Requesting NRC approval November 2014 23