BSEP 15-0090, Response to Request for Additional Information Regarding License Amendment Request to Adopt Topical Report ANP-10298P-A, Revision 1

Response to Request for Additional Information Regarding License Amendment Request to Adopt Topical Report ANP-10298P-A, Revision 1

ML15329A377
Person / Time
Site:	Brunswick
Issue date:	11/05/2015
From:	William Gideon Duke Energy Carolinas, Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 15-0090, TAC MF5851, TAC MF5852
Download: ML15329A377 (4)

Text

DUKE William R.Gideon

~ J ENERGYD EVice °~ President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3898 November 5, 2015 Serial: BSEP 15-0090 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SubjeCt: Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Response to Request for Additional Information Regarding License Amendment Request to Adopt Topical Report ANP-1 0298P-A, Revision 1

References:

1. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission, Re quest for License Amendments - Adoption of Topical Report ANP-10298P-A, Revision 1, dated February 19, 2015, ADAMS Accession Number ML15075A021.

2. NRC E-mail Capture, Brunswick Steam Electric Plant, Units I and 2 - Request for Additional In formation Related to License Amendment Request - Adoption of Topical Report ANP-10298P-A, Revision I (TAC Nos. MF585I and MF5852), dated September 22, 2015, ADAMS Accession Number ML15266A530 Ladies and Gentlemen:

By letter dated February 19, 2015 (i.e., Reference 1), Duke Energy Progress, Inc., submitted a license amendment request (LAR) to revise the Technical Specification (TS) 5.5.6.b for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, by replacing AREVA Topical Report ANP-1 0298P-A, ACE/A TRIUM IOXM Critical Power Correlation, Revision 0, March 2010, with AREVA Topical Report ANP-1 0298P-A, ACE/A TRIUM 10 XM CriticalPower Correlation, Revision 1, March 2014, in the list of analytical methods that have been revised and approved by the NRC for determining core operating limits. On September 22, 2015, by electronic mail (i.e., Reference 2), the NRC provided a request for additional information (RAI) regarding the LAR. Duke Energy's response to the RAI is provided in the enclosure of this letter.

No new regulatory commitments are contained in this letter.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

U.S. Nuclear Regulatory Commission Page 2 of 3 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 5, 2015.

Sincerely, William R. Gideon WRM/wrm

Enclosure:

Response to Request for Additional Information cc (with enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: NRC Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWEN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, Ill, Section Chief (Electronic Copy Only)

Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1 645 lee.cox@dhhs.nc.gov

U-BSEP 15-0090 Enclosure 1 Page 1 of 2 Response to Request for Additional information By letter dated February 19, 2015 (i.e., Reference 1Ito this enclosure), Duke Energy Progress, Inc., submitted a license amendment request (LAR) to revise the Technical Specification (TS) 5.5.6.b for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, by replacing AREVA Topical Report ANP-1 0298P-A, ACE_/A TRIUM IOXM CriticalPower Correlation, Revision 0,'

March 2010, with AREVA Topical Report ANP-10298P-A, ACE/ATRIUM 10 XM Critical Power Correlation,Revision 1, March 2014, in the list of analytical methods that have been revised and approved by the NRC for determining core operating limits.

On September 22, 2015, by electronic mail (i.e., Reference 2 to this enclosure), the NRC provided a request for additional information (RAI) regarding the LAR. Duke Energy's response to the RAI is provided below.

NRC Request for Additional Information:

In the submitted LAR, the licensee is requesting approval of the use of the NRC-approved CPR correlation (ARE VA Topical Report ANP-1 0298P-A, ACE/ATRIUM 10OXM Critical Power:

Correlation, Revision 1, March 2014) in the upcoming core design safety analysis. However, the supporting plant-specific analysis with the CPR, Revision I correlation was not included. Please provide analyses of the limiting anticipated operational occurrences (such as FWCF, LRNBP, PREDS, TTNBP, etc. at 2923 MWth) including determination of limiting ACPR using the CPR, Revision 1 correlation together with a comparison to the ACPR Revision 0 results for the same transients.

Response

AREVA has performed analyses of CPR limiting Brunswick Anticipated Operational Occurrences using both Revision 0 and Revision 1 of the ACE/ATRIUM I10XM critical power correlation. The analyses were performed for the Brunswick Unit 1 Cycle 21 core consisting entirely of ATRIUM I10XM fuel. The scope of the analysis included evaluating the Critical Power Ratio (CPR) limiting fast transient events (i.e., Load Reject No Bypass (LRNBP) and Turbine Trip No Bypass (TTNBP)) at the end of full power (EOFP) cycle exposure and rated power (i.e.,

2,923 MWth), which have been shown to be clearly limiting in past Brunswick licensing analyses. The CPR limiting control rod withdrawal error (CRWE) case at rated power was also analyzed with Revision 0 and Revision I of the correlation. The resulting ACPRs and the difference between the two forms of the correlation from these analyses are provided in the following table.

BSEP 15-0090 Enclosure 1 Page 2 of 2 Comparison of ACPRs between Revision 0 and Revision 1 of the ACEIATRIUM 10OXM Critical Power Correlation Event ACPR, ACE Revision 0 ACPR, ACE Revision 1 Delta Load Reject No Bypass 0.297 0.288 -0.009 (LRNBP) at 100% Rated Power Turbine Trip No Bypass 0.302 0.290 -0.012 (TTNBP) at 100% Rated Power Control Rod Withdrawal 0.271 0.262 -0.009 Error (CRWE) at 100%

Rated Power

References:

1. Letter from William R. Gideon (Duke Energy) to U.S. Nuclear Regulatory Commission, Request for License Amendments - Adoption of Topical Report ANP-10298P-A, Revision 1, dated February 19, 2015, ADAMS Accession Number ML15075A021.

2. NRC E-mail Capture, Brunswick Steam Electric Plant, Units I and 2 - Request for Additional In formation Related to License Amendment Request - Adoption of Topical Report ANP-10298P-A, Revision 1 (TAC Nos. MF5851 and MF5852), dated September 22, 2015, ADAMS Accession Number ML15266A530.