ML13311A053

License Amendment Request to Relocate the Pressure & Temperature Limit Curves to the Pressure and Temperature Limits Report - Supplemental Information in Response to NRC Request for Additional Information

ML13311A053
Person / Time
Site:	Nine Mile Point
Issue date:	11/04/2013
From:	Swift P Constellation Energy Nuclear Group, EDF Group, Nine Mile Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML13311A044	List: ML13311A053 ML13311A054 ML13311A055
References
TAC MF0345
Download: ML13311A053 (8)

Text

This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 6. 1 CENG.

a joint venture of sConstelWaion. - eDF EnerWgy0 NINE MILE POINT NUCLEAR STATION November 4, 2013 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 Docket No. 50-4 10 Nine Mile Point Nuclear Station License Amendment Request to Relocate the Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report - Supplemental Information in Response to NRC Request for Additional Information (TAC No. MF0345)

REFERENCE:

(a) Letter from K. Langdon (NMPNS) to Document Control Desk (NRC), dated November 21, 2012, License Amendment Request Pursuant to 10 CFR 50.90:

Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report (b) Letter from C. Costanzo (NMPNS) to Document Control Desk (NRC), dated July 31, 2013, Nine Mile Point Nuclear Station License Amendment Request to Relocate the Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report - Supplemental Information in Response to NRC Request for Additional Information Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information requested by the NRC in support of a previously submitted license amendment request (LAR) to Nine Mile Point Unit 2 (NMP2) Renewed Facility Operating License NPF-69. The initial request, dated November 21, 2012 (Reference a), proposed to modify Technical Specification (TS) Section 3.4.11, "RCS Pressure and Temperature (P/T) Limits," by replacing the existing reactor vessel heatup and cooldown rate limits and the pressure and temperature (P/T) limit curves with references to the Pressure and Temperature Limits Nine Mile Point Nuclear Station P.O. Box 63, Lycoming, NY 13093 This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 6.

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Document Control Desk November 4, 2013 Page 2 Report (PTLR). Other associated TS changes would also be incorporated. Supplemental information was submitted on July 31, 2013 (Reference b).

The supplemental information, provided in Attachment 1 to this letter, responds to the requests for additional information (RAls) that were provided in an email from the NRC to NMPNS on September 13, 2013, Revised Draft Follow-UP RAIs, MF0345, LAR Re: Revising and Relocating PT Limit Curves to PTLR. Subsequent teleconferences with the NRC reviewer and staff on September 16, 2013 and September 18, 2013 provided additional clarification of the RAIs, SRXB - RAI 4 and SRXB - RAI 5.

As agreed to during the course of the teleconferences, a revision of the draft NMP2 PTLR is provided as to this letter. Referenced in the NMP2 PTLR is the fluence extrapolation performed by MP Machinery and Testing, LLC, MPM-913991, to project fluence to 32 Effective Full Power Years (EFPY).

The fluence extrapolation report, MPM-913991, is provided as Attachment 3.

Additional RAIs were provided in an email from the NRC to NMPNS on September 27, 2013, Revised Additional RAIs, MF0345, LAR Re: Revising and Relocating PT Limit Curves to PTLR. The supplemental information to respond to the September 27, 2013 RAI, EVIB-RAI 6, was prepared by General Electric Hitachi Nuclear Energy Americas LLC (GEH). The response to EVIB-RAI 6 response is provided in Attachment 4 (non-proprietary) and Attachment 6 (proprietary). The affidavit from GEH detailing the reasons for the request to withhold the proprietary information is provided in Attachment 5. is considered to contain proprietary information exempt from disclosure pursuant to 10 CFR 2.390. Therefore, on behalf of GEH, NMPNS hereby makes application to withhold this attachment from public disclosure in accordance with 10 CFR 2.390(b)(1).

The approval of the proposed license amendment was initially requested by November 22, 2013 (Reference a). The initial request was based on conservative projections for when NMP2 would reach the 22 EFPY limit of the current PT curves in the NMP2 TS. Updates to EFPY calculations to account for actual EPU power and fluence project the existing PT curves will remain valid through the end of the NMP2 refueling outage in the spring of 2014, with margin. Therefore, to support continued plant operation, approval of the proposed license amendment is requested by May 31, 2014, with implementation within 60 days.

This supplemental information does not affect the No Significant Hazards Determination analysis provided by NMPNS in Reference (a). Pursuant to 10 CFR 50.91 (b)(1), NMPNS has provided a copy of this supplemental information, without the proprietary Attachment 6, to the appropriate state representative. This letter contains no new regulatory commitments.

Should you have any questions regarding the information in this submittal, please contact Everett (Chip)

Perkins, Director Licensing, at (315) 349-5219.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 4, 2013.

Sincerely, Paul M. Swift Manager, Engineering Services

Document Control Desk November 4, 2013 Page 3 CRC/KJK Attachments: 1. Response to NRC Request for Additional Information, SRXB - RAI 4 and SRXB -

RAI 5

2. Nine Mile Point Unit 2 Pressure and Temperature Limits Report (PTLR) - Revision 0 (Draft B)

3. Fluence Extrapolation in Support of NMP2 P-T Curve Update, MPM-913991, September 30, 2013

4. Response to NRC Request for Additional Information, EVIB - RAI 6 (Non-Proprietary)

5. Affidavit from GE-Hitachi Nuclear Energy Americas LLC (GEH) Justifying Withholding Proprietary Information Contained in Attachment 5

6. Response to NRC Request for Additional Information, EVIB - RAI 6 (Proprietary) cc: Regional Administrator, NRC Project Manager, NRC Resident Inspector, NRC A. L. Peterson, NYSERDA (without Attachment 6)

ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION SRXB - RAI 4 and SRXB - RAI 5 Nine Mile Point Nuclear Station, LLC November 4, 2013

ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION SRXB - RAI 4 and SRXB - RAI 5 By letter dated November 21, 2012, Nine Mile Point Nuclear Station, LLC (NMPNS) proposed to modify Nine Mile Point Unit 2 (NMP2) Technical Specification (TS) Section 3.4.11, "RCS Pressure and Temperature (P/T) Limits," by replacing the existing reactor vessel heatup and cooldown rate limits and the pressure and temperature (P/T) limit curves with references to the Pressure and Temperature Limits Report (PTLR). Other associated TS changes would also be incorporated. This attachment provides supplemental information in response to the NRC request for additional information that was provided in an email from the NRC to NMPNS on September 13, 2013; specifically, SRXB - RAI 4 and SRXB -

RAI 5. Each individual NRC question is repeated (in italics), followed by the NMPNS response.

SRXB- RAI 4 Section 1 of the enclosure to the NMPNS2 letter dated November 21, 2012 (ML123380336), states that

"[rielocationof the P-T [Pressure-Temperature]limit curves to the PTLR [pressure-temperaturelimits report] is consistent with the guidance provided in NRC approved General Electric Hitachi Nuclear Engineering (GEH) Licensing Topical Report, [NEDO-33178-A], Revision 1, "General Electric Methodology for Development of Reactor Pressure Vessel Pressure-TemperatureCurves... " (NEDO-33178-A: ML092370487)

Regardingreactor vessel neutron fluence, NEDO-33178-A, Section 4.2.1.2, "Fluence," states that "It is assumed that such fluence methods would be utilized to develop the necessary and appropriateinputs

[emphasis added]for use in the P-T curve development methodology outlined in this report."

In regards to the fluence methodology in use for NMPNS2 for P-T curve development, the enclosure to the November 21, 2012, request letter states, "NMP2 maintains an NRC approved RG [Regulatory Guide] 1.190fluence monitoringprogram... and reviews actualfluence on a routine basis. The fluence projections have been confirmed to be conservative using the NMP2 fluence methods. " Further clarificationis provided in a letter dated July 31, 2013 (ML13214A396), in which Attachment 1, response to SRXB - RAI 1, explains that fluence calculations were performed as described in GEH Licensing Topical Report NEDO-32983-A, Revision 2, "General ElectricMethodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations" (ML072480121). The response states, "The P/T limit curves were developed based on the more conservative GEHfluence rate.

In consideration of information contained in both the request letter and its supplement, it appears that, while the basisfor the proposedPT limits is a GEHfluence calculation, the licensee intends to adjust the applicabilityof the PT limits by performing ongoingfluence monitoring using calculationsin accordance with the current NMPNS plant-specific methods furnished by MPM Technologies, Inc. This approach appearssomewhat different than that delineated in NEDO-33178-A. It would appear that NEDO-33178-A establishes an approachwhereby a PTLR is developed with a specific applicabilityperiod,setforth in effective full power years (EFPY) of exposure. However, the method proposed by NMPNS2 appears not to constrainthe PTLR to such an applicabilityperiod,but ratherto the applicabilityoffluence values.

Pleaseprovide additionalinformation relatedto the above approach:

1. Confirm the accuracy of the information outlined above. If different, please provide additional information to clarify the proposedapproach.

2. Provide a clear reference to the fluence method on which the PT limits are based It is necessary to reference a single, NRC-approvedfluence methodology that forms the basisfor the PT limits, 1 of4

ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION SRXB - RAI 4 and SRXB - RAI 5 in order to satisfy the condition/limitationfor approval of NEDO-33178-A. As discussed in Section 4.2.1.2 of the LTR, this must be the fluence method usedfor input to the PTLR.

3. Provide information to establish the applicabilityof the draft PT limits.

4. Revise the draft PTLR as necessary to clearly delineate saidapplicability.

5. Explain in greater detail how the fluence monitoring program will be used in relation to the PTLR. For example:

a. Explain whether the applicabilityof the PTLR could be adjusted beyond 32 EFPY

b. Explain what would happen in the event that a non-limitingfluence value, such as that for a nozzle location, is shown by the fluence monitoring program to be non-conservative, while the limitingfluence value remains boundedby the GEH calculation.

6. Explain what aspects of this approach differ from that delineated in NEDO-33178-A. As necessary, revise the proposed citation in TS 5.6 to reflect use ofplant-specific methodology (i.e.,

potential use of plant-specific fluence monitoring program to extend applicability of PTLR) consistent with GL 88-16, "Removal of Cycle-Specific Parameter Operating Limits from Technical Specifications" (note that GL 96-03 and TSTF-419-A are based on GL 88-16).

Response to SRXB-RAI 4

1. The PTLR and the SRXB- RAI I response (Reference b) state the fluence methods remain the NMP2 plant specific methods described in references 6.2 and 6.3 of the PTLR. References 6.2 and 6.3 of the PTLR refer to the approved MPM method for calculating fluence. The derivation of the PT limit curves used the NMP2 plant specific RG 1.190 fluence calculation results from the end of cycle 10.

The PT limits were defined using conservative extrapolation methods to account for EPU conditions and to provide margin to account for typical variations in neutron flux related to future variation in core and fuel design. Additional information is provided in the PTLR reference 6.4 (MPM-913991) documenting the NMP2 plant specific RG 1.190 fluence and the current best estimate projections based on these methods. The PT curves in the PTLR are valid for 32 EFPY.

2. The fluence methods used for the PT limit curves remain the PTLR reference 6.2 (MPM-402781, Revision 1) and 6.3 (NRC approval of the License Amendment for the NMPI PT Limit Curves and Tables (TAC No. MB6687)). The PTLR reference 6.4 (MPM-913991) reflects the NMP2 RG 1.190 plant specific method fluence extrapolation basis for the NMP2 PT limit curves in the PTLR provided in Attachment 2. The single NRC approved methodology used for the PT limit curves is the MPM method.

3. The PTLR reference 6.4 (MPM-913991) is included as Attachment 3 to provide the specific fluence projections that are the basis for the proposed PTLR limit curve applicability.

4. The PTLR is revised to reflect the NMP2 plant specific EFPY applicability. The revised PTLR is included as Attachment 2.

5. The PTLR curves are based on a bounding fluence for each location. While the EFPY applicability is a simple way of approximating the applicability of the PT limits, the controlling parameter is the fluence used to define the PT limits. Maintenance of the RG 1.190 fluence requires periodic update of the analysis to reflect actual operation.

a. It is not the intent to extend the applicability beyond that stated in the PTLR without revision to the PTLR applicability. The PTLR is revised to state the report is applicable up to 32 EFPY. As 2 of 4

ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION SRXB - RAI 4 and SRXB - RAI 5 required by the proposed NMP2 TS section 5.6.7, the revised PTLR shall be provided to the NRC upon issuance.

b. For example, the location of high power bundles near the periphery is impacted by core design factors such as cycle energy requirements and batch fraction. These core design aspects can significantly increase or decrease the peak azimuthal and axial neutron flux impacting the reactor vessel locations. In addition, changes in fuel design such as the length of the natural uranium blanket of the fuel can significantly change the neutron flux associated with an approximate EFPY for upper core locations such as the Low Pressure Coolant Injection (LPCI) Nozzle (N6) or Water Level Instrumentation Nozzle (N12) locations. Therefore, EFPY alone is potentially a non-conservative measure of the PT limit curve applicability. If the NMP2 RG 1.190 fluence monitoring predicts the PTLR applicability for either EFPY or the actual fluence used to define the Adjusted Reference Temperature (ART) for any location will become non-conservative, then a change to the PTLR would be implemented.

Additionally, if a fuel type, core design change, or an operating strategy change, such as spectral shift, results in high neutron flux at a currently non limiting location, such as the N12 location, then the associated ART for that location would be adjusted to reflect the revised projected fluence. If the revised RGI 1.190 projected fluence shows the PT limits assumptions are non-conservative, then a calculation will be performed to determine if the N12 would become limiting. If the location becomes limiting over any portion of the limit curve, then revision to the PT limit curves would be implemented.

6. This approach is fully consistent with NEDO-33178-A, approved in PTLR reference 6.5 (NRC Safety Evaluation for NEDC-33178P), which states that the input for fluence will be based on an approved RG 1.190 fluence method. All BWR RG 1.190 fluence methods recognize that core and fuel design and operating characteristics can significantly shift the neutron flux potentially impacting the fluence /

EFPY relationship. The NMP2 RG 1.190 plant specific methods discuss these factors and include provisions to monitor the fluence predictions to ensure the PT limits remain conservative.

A change to the proposed TS 5.6.7 is not required to comply with the format approved in TS Task Force (TSTF) Traveler, TSTF-419-A and subsequent NRC clarification provided to the TSTF as described in the original submittal (Reference a).

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ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION SRXB - RAI 4 and SRXB - RAI 5 SRXB- RAI 5 NEDC-33178P-A requires the licensee to identify the "reportused to calculate the neutronfluence. " The licensee primarilyreferences MPM-402 781 and NEDC-32983P-A; however, the NRC determined that additionaldocuments describe the fluence methods:

" MPM-402781, "Benchmarking ofNine Mile Point Unit 1 and Unit 2 Transport Calculations,"

September 2003.

• Letter NMP1L 1749, "Requestfor Additional Information (RAI) - Amendment Application Re:

Pressure-TemperatureLimit Curves, " includingAttachment 1, "Response to Requestfor Additional Information, " andAttachment 2, MPM-703 782, "Response to NRC Request for Additional Information: Nine Mile Point Unit I P-T Limit Curves. "

• "Safety Evaluation by the Office of Nuclear ReactorRegulation Related to Amendment No. 183 to Facility OperatingLicense No. DPR-63, "insofar as it establishes that the methods described in MPM-402 781, as supplemented, are acceptableto support P-T limits at NMPNS Unit 1for up to 28 EFPYs.

• "Safety Evaluation by the Office of Nuclear ReactorRegulation Related to Amendment No. 240 to Facility OperatingLicense No. NPF-69, "insofar as it establishes that the methods described in MPM-402781, as supplemented, are acceptable to support P-Tlimits at NMPNS Unit 2for up to 22 EFPYs.

• "Nine Mile PointNuclear Station License Amendment Request to Relocate the Pressureand Temperature Limit Curves to the Pressureand Temperature Limits Report - Supplemental Information In Response to NRC Requestfor Additional Information," includingAttachment 1, "Response to NRC Request for Additional Information SRXB - RAI 1, SRXB - RAI 2, and SRXB -

RAI 3, " insofar as it describes additionalassumptions and conservatisms appliedto reactor vesselfluence, and provides references to additionalreports to update the NMPNS Unit 2fluence methods.

Please confirm whether the licensee-referenced methodology is complete, or provide supplemental information to provide a succinct description of the fluence methodology in use. If the methodology is complete, provide informationjustifying such a conclusion in light of the information provided above.

Response to SRXB - RAI 5 The NMP2 PTLR (Attachment 2) has been updated to clarify the fluence methodology used. The PTLR reference 6.10 is added to include the NRC issuance of amendments for both NMP1 and NMP2 approving the implementation of the reactor pressure vessel integrated surveillance program (TAC NOS MC1758 and MC1759). The NRC SER for both Nine Mile Point Unit 1 and NMP2 specifically acknowledge the use of the NRC approved plant specific methodology is in accordance with the recommendations of RG 1.190.

The PTLR reference 6.2 (MPM-402781 Rev 1) includes the complete description of the methods.

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