ML090500398

Response to Request for Additional Information on License Amendment for Measurement Uncertainty Recapture Power Uprate

ML090500398
Person / Time
Site:	Calvert Cliffs
Issue date:	02/17/2009
From:	Spina J Calvert Cliffs, Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML090500398 (5)

Text

- .-.--.-- -vs James A. Spina Calvert Cliffs Nuclear Power Plant, Inc.

Vice President 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.495.3500 Fax 0Constellation Energy" Nuclear Generation Group February 17, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Response to Request for Additional Information - License Amendment for Measurement Uncertainty Recapture Power Uprate - Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2

REFERENCES:

(a) Letter from Mr. D. R. Bauder (CCNPP) to Document Control Desk (NRC), dated August 29, 2008, License Amendment Request: Appendix K Measurement Uncertainty Recapture - Power Uprate Request (b) Letter from Mr. D. V. Pickett (NRC) to Mr. J. A. Spina (CCNPP), dated October 3, 2008, Request for Additional Information Re: License Amendment for Measurement Uncertainty Recapture Power Uprate -

Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (c) Letter from Mr. M. D. Flaherty (CCNPP) to Document Control Desk (NRC) dated December 29, 2008, Response to Request for Additional Information - License Amendment for Measurement Uncertainty Recapture Power Uprate In Reference (a), Calvert Cliffs Nuclear Power Plant, Inc. submitted a license amendment request to the Nuclear Regulatory Commission (NRC) for a measurement uncertainty recapture power uprate for Calvert Cliffs Nuclear Power Plant, Units 1 and 2. In Reference (b) the NRC requested additional information to be submitted to support their review of the submittal. Reference (c) contains Calvert Cliffs responses. Following receipt of our responses, a phone call between NRC staff and Calvert Cliffs staff was conducted to clarify our response to RAI 2 (Reference c). Attachment (1) contains the clarifying information requested during the phone call with the NRC staff.

Y1 00 ý-Ia

Document Control Desk February 17, 2009 Page 2 Should you have any questions regarding this matter, please contact Mr. Jay S. Gaines at (410) 495-5219.

Very p

STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT I, James A. Spina, being duly sworn, state that I am Vice President - Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP), and that I am duly authorized to execute and file this License Amendment Request on behalf of CCNPP. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other C(ENPP employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it e iable.

Subscribed and sworn before me, a Notary kEullic in and for the State of Maryland and County of

,_ 6,, __,this/7 daycof /--,_zge,-q ,2009.

WITNES"ST myinand-and Notarial Seal: 0a'-1C1'd'a

// Notary P..efic My Commission Expires:

Date JAS/KLG/bjd

Attachment:

(1) Response to Request for Additional Information - Measurement Uncertainty Recapture Power Uprate cc: D. V. Pickett, NRC Resident Inspector, NRC S, J. Collins, NRC S. Gray, DNR

ATTACHMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION -

MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Calvert Cliffs Nuclear Power Plant, Inc.

February 17,2009

ATTACHMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION - MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE

RAI 1

Recalculate the Reactor Vessel fluence values provided in Section IV 5 of Attachment 2 of Calvert Cliffs Measurement Uncertainty RecaptureEvaluation LAR ofAugust 29,2008 in accordance with the guidance of Regulatory Guide 1.99.

CCNPP Response:

The below values were calculated in accordance with guidance of Regulatory Guide 1.99:

Unit 1 Fluence Unit 1 Fluence Unit 2 Fluence Unit 2 Fluence Current 1.4% Power UpaeCurrent 1.4%

UrtPower Uprate Uprate Vessel Clad 5.09E+19 5.11E+19 5.74E+19 5.79E+19 Interface 1/4 T Location 3.04E+19 3.05E+19 3.42E+19 3.45E+19 3/4 T Location 1.08E+19 1.08E+19 1.22E+19 1.23E+19 Note that this information may be different than the data used for reactor vessel surveillance capsule withdrawals and is subject to evaluation and re-calculation as necessary whenever new information is obtained (i.e., data obtained from future surveillance capsule withdrawals).

RAI 2

State whether Calvert Cliffs is in compliance with Regulatory Guide 1.190 in regards to the determinationof reactorvessel neutonfluence values used in this submittal.

CCNPP Response:

The determination of reactor vessel neutron fluence values was performed using methodologies that are consistent with the overall intent, although not the specific details, of Regulatory Guide 1.190 (Reference 1).

For Calvert Cliffs Unit 1, the current dosimetry, neutron fluence, and radiation embrittlement results were documented in Babcock & Wilcox (B&W) Report BAW-2160 (Reference 3) and submitted to the Nuclear Regulatory Commission (NRC) via the correspondence of Reference 4. For Calvert Cliffs Unit 2, the current dosimetry, neutron fluence, and radiation embrittlement results were documented in B&W Report BAW-2199 (Reference 5) and submitted to the NRC via the correspondence of Reference 6.

The surveillance capsule withdrawal schedules were determined via American Society for Testing and Materials (ASTM) E185 (Reference 7), while the neutron fast and total fluxes, neutron fast and total fluences, and the displacement per atom values of the surveillance specimens and the corresponding values for the reactor vessel were determined in accordance with the guidelines in ASTM E482 (Reference 8) and Regulatory Guide 1.99 (Reference 2). The DOT4 discrete ordinates transport code was used in R-theta (midplane) and R-Z coordinates using a P3 expansion of the cross-section transfer matrix and flux moments, an S8 r-theta quadrature, and a multi-group energy structure above 0.1 eV. The methodology employs absolute fluence calculations with documented and verified plant-specific data, local fission isotopics, and temperature-dependent water densities.

Note that Regulatory Guide 1.190 was issued seven years after Calvert Cliffs last surveillance capsule analysis. Calvert Cliffs Nuclear Power Plant Units 1 and 2 surveillance capsules will be extracted in 2010

ATTACHMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION - MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE and 2011, respectively; after which updated fluence analyses will be performed that conform to appropriate regulatory guidance.

References

1. Regulatory Guide 1.190, March 2001, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence

2. Regulatory Guide 1.99 Revision 2, May 1988, Radiation Embrittlement of Reactor Vessel Materials

3. B&W Report BAW-2160, June 1993, Analysis of Capsule 970 BG&E CCNPP Unit No. 1

4. Letter from Mr. R. E. Denton (BG&E) to Document Control Desk (NRC), June 22, 1993, Analysis of the Calvert Cliffs Unit No. 1 Reactor Vessel Surveillance Capsule Withdrawn from the 970 Location

5. B&W Report BAW-2199, February 1994, Analysis of Capsule 970 BG&E CCNPP Unit No. 2

6. Letter from Mr. R. E. Denton (BGE) to Document Control Desk (NRC), March 18, 1994, Analysis of the Calvert Cliffs Unit No. 2 Reactor Vessel Surveillance Capsule Withdrawn from the 97' Location

7. ASTM E185-82, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels, E 706

8. ASTM E482-89, Standard Guide for Application of Neutron Transport Methods for Reactor Vessel Surveillance, E 706 2