Text

Supplement to License Amendment Request for Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, Core Operating Limits Report (Colr), and Revision to Tech Spec 2.1.1.2 Minimum Critical Power
	ML13031A010
Person / Time
Site:	Brunswick
Issue date:	01/22/2013
From:	Annacone M; Duke Energy Corp
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 13-0002, TSC-2011-01
	Download: ML13031A010 (15)
	v • d • e

Letter Enclosures Contain Proprietary Information Duke Withhold in Accordance with 10 CFR 2.390(a)(6)

Michael J. Annacone P

~ukeVice President 6~

EnergyPBrunswick Nuclear Plant Southport, NC 28461 910-457-3698 10 CFR 50.4 January 22, 2013 Serial: BSEP 13-0002 TSC-201 1-01 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325, 50-324 Supplement to License Amendment Request for Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," and Revision to Technical Specification 2.1.1.2 Minimum Critical Power Ratio Safety Limit

References:

1. Letter from Michael J. Annacone to the U.S. Nuclear Regulatory Commission (Serial:

BSEP 12-0031), Request for License Amendments - Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, 'CORE OPERATING LIMITS REPORT (COLR),' and Revision to Technical Specification 2.1.1.2 Minimum Critical Power Ratio Safety Limit, dated March 6, 2012, ADAMS Accession Number ML12076A062

2. Letter from Michael J. Annacone to the U.S. Nuclear Regulatory Commission (Serial:

BSEP 12-0098), Response to Request for Additional Information Regarding License Amendment Request for Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, 'CORE OPERATING LIMITS REPORT (COLR),' and Revision to Technical Specification 2.1.1.2 Minimum Critical Power Ratio Safety Limit, dated August 29, 2012, ADAMS Accession Number ML12251A142 By letter dated March 6, 2012 (i.e., Reference 1), as supplemented by letter dated August 29, 2012 (i.e., Reference 2), Carolina Power & Light Company (CP&L) requested license amendments to revise the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendments: (1) revise TS 5.6.5.b by replacing AREVA Topical Report ANF-524(P)(A), ANF Critical Power Methodology for Boiling Water Reactors with AREVA Topical Report ANP-1 0307PA, Revision 0, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors, June 2011, in the list of analytical methods that have been reviewed and approved by the NRC for determining core operating limits, (2) revise TS 2.1.1, Reactor Core SLs, by incorporating revised Safety Limit Minimum Critical Power Ratio (SLMCPR) values, and (3) revise the license condition in Appendix B, "Additional Conditions," of the operating licenses regarding an alternate method for evaluating SLMCPR values.

On December 18, 2012, a telephone discussion was held between CP&L, AREVA, and the NRC, to discuss the need for a license condition regarding the use of the AREVA channel bow model outside of the range of the channel bow measurement database from which its

U.S. Nuclear Regulatory Commission Page 2 of 5 uncertainty was quantified. Enclosure 1 provides proposed license conditions for BSEP, Units 1 and 2, addressing how channel bow model uncertainty will be modified for fuel channels with fluence gradients outside of the range of the channel bow measurement database. A description of the application and impact of the proposed treatment of the channel bow model uncertainty is provided in AREVA Report No. 51-9196691-000, Supplemental Information for Brunswick SAFLIM3D Submittal: Impact of Assemblies Outside Existing Channel Bow Fast Fluence Gradient Database (Proprietary Version). A copy of AREVA Report No. 51-9196691-000 is provided in Enclosure 2. The report contains information considered proprietary to AREVA; therefore, an affidavit supporting withholding the report from public disclosure is provided in Enclosure 3. A non-proprietary version of the report (i.e., AREVA Report No. 51-9196989-000) is provided in Enclosure 4.

While performing analyses to support preparation of the reports described above, AREVA identified application errors associated with SAFLIM3D analyses which were submitted as part of CP&L's March 6, 2012, license amendment request, as supplemented by CP&L's August 29, 2012, submittal. These application errors do not affect the proposed Safety Limit Minimum Critical Power Ratio values, nor do the application errors affect the generic NRC-approved methodology described in the SAFLIM3D licensing topical report (i.e., ANP-10307PA, Revision 0, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors, June 2011).

The errors slightly impact the percentage of fuel rods in boiling transition and the contribution of total fuel rods predicted to be in boiling transition, as summarized ill the following AREVA reports submitted as part of CP&L's March 6, 2012, license amendment request:

1.

AREVA Report No. 51-9175787-000, Brunswick Unit 2 Cycle 20 SLMCPR Analysis With SAFLIM3D Methodology (Proprietary Version), AREVA NP, February 2012.

2.

AREVA Report No. 51-9177314-000, Brunswick Unit 2 Cycle 20 SLMCPR Analysis With SAFLIM3D Methodology (Nonproprietary Version), AREVA NP, February 2012.

3.

AREVA Report No. 51-9176342-000, Brunswick Unit 2 Cycle 20 SLMCPR Analysis With SAFLIM3D Methodology - Operability Assessment (Proprietary Version), AREVA NP, February 2012.

4.

AREVA Report No. 51-9177316-000, Brunswick Unit 2 Cycle 20 SLMCPR Analysis With SAFLIM3D Methodology - Operability Assessment (Nonproprietary Version), AREVA NP, February 2012.

The errors also slightly impact the percentage of fuel rods in boiling transition and the contribution of total fuel rods predicted to be in boiling transition summarized in the following AREVA reports submitted as part of CP&L's August 29, 2012, supplement to the license amendment request.

1. AREVA Report No. 51-9175814-001, Brunswick Unit 1 Cycle 19 SLMCPR Analysis With SAFLIM3D Methodology (Proprietary Version)" AREVA NP, July 2012.

(Note: This report superseded AREVA Report No. 51-9175814-000, Brunswick Unit I Cycle 19 SLMCPR Analysis With SAFLIM3D Methodology (Proprietary Version), AREVA NP, February 2012, which was submitted in Reference 1)

2. AREVA Report No. 51-9177317-001, Brunswick Unit 1 Cycle 19 SLMCPR Analysis With SAFLIM3D Methodology (Nonproprietary Version), AREVA NP, July 2012.

(Note: This report superseded AREVA Report No. 51-9177317-000, Brunswick Unit 1 Cycle 19 SLMCPR Analysis With SAFLIM3D Methodology (Nonproprietary Version),

AREVA NP, February 2012, which was submitted in Reference 1).

3. AREVA Report No. 51-9176407-001, Brunswick Unit 1 Cycle 19 SLMCPR Analysis With SAFLIM3D Methodology - Operability Assessment (Proprietary Version)" AREVA NP, July 2012.

U.S. Nuclear Regulatory Commission Page 3 of 5 (Note: This report superseded AREVA Report No. 51-9176407-000, Brunswick Unit I Cycle 19 SLMCPR Analysis With SAFLIM3D Methodology - Operability Assessment (Proprietary Version, AREVA NP, February 2012, which was submitted in Reference 1).

4. AREVA Report No. 51-9177315-001, Brunswick Unit I Cycle 19 SLMCPR Analysis With SAFLIM3D Methodology - Operability Assessment (Nonproprietary Version), AREVA NP, July 2012.

(Note: This report superseded AREVA Report No. 51-9177315-000, Brunswick Unit I Cycle 19 SLMCPR Analysis With SAFLIM3D Methodology - Operability Assessment (Nonproprietary Version), AREVA NP, February 2012, which was submitted in Reference 1).

5. AREVA Report No. 51-9186363-000, Brunswick Unit 2 Cycle 21 SLMCPR Analysis With SAFLIM3D Methodology (Proprietary Version), AREVA NP, August 2012.

6. AREVA Report No. 51-9189033-000, Brunswick Unit 2 Cycle 21 SLMCPR Analysis With SAFLIM3D Methodology (Nonproprietary Version), AREVA NP, August 2012.

7. AREVA Report No. 51-9186367-000, Brunswick Unit 2 Cycle 21 SLMCPR Analysis With SAFLIM3D Methodology - Operability Assessment (Proprietary Version), AREVA NP, August 2012.

8. AREVA Report No. 51-9189034-000, Brunswick Unit 2 Cycle 21 SLMCPR Analysis With SAFLIM3D Methodology - Operability Assessment (Nonproprietary Version), AREVA NP, August 2012.

AREVA Document No. 12-9197119-000, Brunswick SAFLIM3D LAR Support - Calculation Error Impact (Proprietary Version), provides a technical assessment of the impact of the application errors. A copy of AREVA Report No. 12-9197119-000 is provided in Enclosure 5. The report contains information considered proprietary to AREVA; therefore, an affidavit supporting withholding the report from public disclosure is provided in Enclosure 6. A non-proprietary version of the report (i.e., AREVA Report No. 12-9197120-000) is provided in Enclosure 7.

CP&L has reviewed this supplement to the Reference 1 license amendment request and determined that the addition of the proposed license conditions provided in Enclosure 1 do not affect the bases for concluding the no significant hazards consideration determination published in the Federal Register (i.e., 77 FR 39524 dated July 3, 2012) remains applicable to BSEP, Units 1 and 2.

This document contains no regulatory commitments.

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

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on January 22, 2013.

Sincerely, Michael J. Annacone

U.S. Nuclear Regulatory Commission Page 4 of 5 WRM/wrm

Enclosures:

1. Proposed License Conditions for BSEP, Units 1 and 2

2. AREVA Report No. 51-9196691-000, Supplemental Information for Brunswick SAFLIM3D Submittal: Impact of Assemblies Outside Existing Channel Bow Fast Fluence Gradient Database (Proprietary Version)

3. AREVA Affidavit Regarding Withholding AREVA Report No. 51-9196691-000 from Public Disclosure

4. AREVA Report No. 51-9196989-000, Supplemental Information for Brunswick SAFLIM3D Submittal: Impact of Assemblies Outside Existing Channel Bow Fast Fluence Gradient Database (Non-Proprietary Version)

5. AREVA Report No. 12-9197119-000, Brunswick SAFLIM3D LAR Support - Calculation Error Impact (Proprietary Version)

6. AREVA Affidavit Regarding Withholding AREVA Report No. 12-9197119-000, from Public Disclosure

7. AREVA Report No. 12-9197120-000, Brunswick SAFLIM3D LAR Support - Calculation Error Impact (Non-Proprietary Version)

U.S. Nuclear Regulatory Commission Page 5 of 5 cc (with Enclosures 1 through 7):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Mr. Christopher Gratton (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 cc (with Enclosures 1, 3, 4, 6, and 7 only):

Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief Radiation Protection Section North Carolina Department of Environment and Natural Resources 1645 Mail Service Center Raleigh, NC 27699-1645

BSEP 13-0002 Proposed License Conditions for BSEP, Units 1 and 2

BSEP 13-0002 Appendix B Additional Conditions Amendment Number XXX (Unit 1)

XXX (Unit 2)

Implementation Additional Conditions Date The fuel channel bow standard deviation component of the channel bow model uncertainty used by ANP-10307PA, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors (i.e.,

TS 5.6.5.b.11) to determine the Safety Limit Minimum Critical Power Ratio shall be increased by the ratio of channel fluence gradient to the nearest channel fluence gradient bound of the channel measurement database, when applied to channels with fluence gradients outside the bounds of the measurement database from which the model uncertainty is determined.

The fuel channel bow standard deviation component of the channel bow model uncertainty used by ANP-10307PA, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors (i.e.,

TS 5.6.5.b.1 1) to determine the Safety Limit Minimum Critical Power Ratio shall be increased by the ratio of channel fluence gradient to the nearest channel fluence gradient bound of the channel measurement database, when applied to channels with fluence gradients outside the bounds of the measurement database from which the model uncertainty is determined.

Upon Implementation of Amendment No.

BSEP 13-0002 AREVA Affidavit Regarding Withholding AREVA Report No. 51-9196691-000 from Public Disclosure

AFFIDAVIT STATE OF WASHINGTON

)

) ss.

COUNTY OF BENTON

1.

My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute thisAffidavit.

2.

I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.

3.

I am familiar with the AREVA NP information contained in the report 51-9196691-000, "Supplemental Information for Brunswick SAFLIM3D Submittal: Impact of Assemblies Outside Existing Channel Bow Fast Fluence Gradient Database (Proprietary Version)," dated January 2013 and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.

4.

This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and riot made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5.

This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made

in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6.

The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:

(a)

The information reveals details of AREVA NP's research and development plans and programs or their results.

(b)

Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c)

The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.

(d)

The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.

(e)

The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.

The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.

7.

In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8.

AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9.

The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this

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day of J

,2013.

AS-I)

"4TAR A Susan K. McCoy NOTARY PUBLIC, STA'T-E OF WASI-I, TON MY COMMISSION EXPIRES: 1/14/2016

BSEP 13-0002 AREVA Affidavit Regarding Withholding AREVA Report No. 12-9197119-000, from Public Disclosure

AFFIDAVIT STATE OF WASHINGTON

)

) ss.

COUNTY OF BENTON

)

1.

My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2.

I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.

3.

I am familiar with the AREVA NP information contained in the Technical Data Record 12-9197119-000, "Brunswick SAFLI M3D LAR Support - Calculation Error Impact (Proprietary Version)," dated January 2013 and referred to herein as "'Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.

4.

This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5.

This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a)(4) 'Trade secrets and commercial or financial information."

6.