BSEP 17-0089, Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion

Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion

ML17325B599
Person / Time
Site:	Brunswick
Issue date:	11/01/2017
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17325B636	List: BSEP 17-0089, Updates to Request for License Amendment Regarding Core Flow Operating Range Expansion
References
BSEP 17-0089, CAC MF8363, CAC MF8364
Download: ML17325B599 (5)

Text

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William R. Gideon

~"-)DUKE Vice President

~ ENERGY Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 November 1, 2017 Serial: BSEP 17-0089 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 Updates to Request for License Amendment Regarding Core Flow Opertaing Range Expansion (CAC Nos. MF8363 and MF8364)

References:

1. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, Request for License Amendment Regarding Core Flow Operating Range Expansion, dated September 6, 2016, ADAMS Accession Number ML16257A410

2. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, Response to Request for Supplemental Information for License Amendment Regarding Core Flow Operating Range Expansion, dated November 9, 2016, ADAMS Accession Number ML16330A504 Ladies and Gentlemen:

By letter dated September 6, 2016 (i.e., Reference 1), Duke Energy Progress, LLC (Duke Energy), submitted a license amendment request (LAR) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment would revise the Technical Specifications to support an expansion of the core power-flow operating range (i.e., Maximum Extended Load Line Limit Analysis Plus (MELLLA+)). By letter dated November 9, 2016 (i.e., Reference 2),

Duke Energy provided supplemental information in support of the proposed amendment.

During preparation for an NRC audit of MELLLA+ methodologies, which was conducted

• July 21-24, 2017, General Electric Hitachi (GEH) determined that the original Anticipated Transient Without Scram (ATWS) calculations supporting the BSEP MELLLA+ LAR were performed using some design inputs that were different than current procedures.would dictate.

These design inputs were related to the time steps within the TRACG software and a parameter tolerance associated with the fuel reactivity. Correction of these design inputs has resulted in changes to the Peak Clad Temperature (PCT) values reported in the MELLLA+ Safety Analysis Report (SAR) for the limiting Turbine Trip Without Bypass (TTWBP) event. An editorial correction to the Standby Liquid Control initiation time for this event was also identified. The NRC was verbally informed of these changes during the July 2017 audit. f DD I rJ~tv

U.S. Nuclear Regulatory Commission Page 2 of 3 These design input changes have resulted in updates to selected pages of the MELLLA+ SAR (i.e., Enclosure 5 of Reference 1) and to the Request for Supplemental Information response (i.e., Enclosure 2 of Reference 2). Enclosure 1 of this letter provides updated pages for the BSEP MELLLA+ SAR (i.e., Duke Report DUKE-OB21-1104-000(P)) with mark-ups showing the necessary changes. The affected pages contain proprietary information covered by the affidavit previously included as Enclosure 7 of Duke Energy's LAR (i.e., Reference 1). The changes do

. not affect the non-proprietary version of the pages that were provided in Enclosure 6 of Reference 1. /

Enclosure 2 of this letter provides an updated page for the GEH Document ]

GEH-PGN-MPLUS-143 (i.e., Enclosure 2 of Reference 2). The affected page contains proprietary information covered by the affidavit previously included in Enclosure 3 ofi Reference 2. The changes to the page from GEH Document GEH-PGN-MPLUS-143 do not affect the non-proprietary version of the corresponding page that was provided in En losure 4 of Reference 2.

Enclosure 3 provides a revision to page 3-7 of Duke Energy Document DUKE-OB21-1104-000(P), Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 Maximum Extended Load Line Limit Analysis Plus (M+ SAR), which was provided as Enclosure 5 of Reference 1. The page is being revised to remove proprietary information markings for the discussion of Annulus Pressurization in the table of reactor internals load categories. The Annulus Pressurization summary in the table is no longer being marked as proprietary because the associated discussion in Section 4.1.3.2 does not contain proprietary information. The affidavit provided in Enclosure 7 of Reference 1 remains applicable to the updated page. A non-proprietary version of the revised page is provided in Enclosure 4.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 1, 2017.

Sincerely, wuPJ2 William R. Gideon

U.S. Nuclear Regulatory Commission Page 3 of 3 WRM/wrm

Enclosures:

1. Revised Pages for DUKE-0821-1104-000(P), Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 Maximum Extended Load Line Limit Analysis Plus (M+SAR), July 2016 [Proprietary Information - Withhold from Public Disclosure in Accordance With 10 CFR 2.390]

2. Revised Page for GEH Document GEH-PGN-MPLUS-143, Response to Request for Supplemental Information in Support of Brunswick Steam Electric Plant MELLLA + LAR, dated November 9, 2016 (ADAMS Accession Number ML16330A504) [Proprietary Information -Withhold from Public Disclosure in Accordance With 10 CFR 2.390]

3. Revised Page 3-7 to Duke Energy Document DUKE-0821-1104-000(P), Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 Maximum Extended Load Line Limit Analysis Plus (M+ SAR) [Proprietary Information -Withhold from Public Disclosure in Accordance With 10 CFR 2.390]

4. Revised Page 3-7 to Duke Energy Document DUKE-0821-1104-000(NP), Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 Maximum Extended Load Line Limit Analysis Plus (M+ SAR) cc (with all enclosures):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 84 70 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Andrew.Hon@nrc.gov cc (with Enclosure .4 only):

Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net 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 27699-1645 lee.cox@dhhs.nc.gov

BSEP 17-0089 Enclosure 4 Revised Page 3-7 to Duke Energy Document DUKE-0821-1104-000(NP),

Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2 Maximum Extended Load Line Limit Analysis Plus (M+ SAR)

DUKE-OB21-1l04-001 (NP)

NON-PROPRIETARY INFORMATION 3.3.2 Reactor Internals Structural Evaluation Structural integrity evaluations for MELLLA+ operating domain expans10n are performed consistent with the existing design basis of the components. ((

)) Therefore, no further structural evaluation of the reactor internals is required. An evaluation of the load categories applicable to the reactor internals under normal, upset, emergency, and faulted conditions is presented below:

MELLLA+ Results Load Category for Normal, Upset, Emergency, and Faulted Conditions Dead Weight ((

Seismic RIPDs (including Acoustic and Flow-Induced Loads)

Fuel Assembly Lift Forces Hydrodynamic Containment Dynamic Loads - (LOCA and SRV)

))

Section 4.1.3.2 concludes that the AP loads m the Annulus Pressurization (AP) MELLLA+ operating domain are bounded by the loads in the current licensed operation domain.

((

Jet Reaction Thermal Effects 3-7