ML17341A726

Requests Remittance of Fees within 15 Days for 810728 Application Re Request for Extension of Time to Complete Fire Protection Mods

ML17341A726
Person / Time
Site:	Turkey Point
Issue date:	12/04/1981
From:	Miller W NRC OFFICE OF ADMINISTRATION (ADM)
To:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
References
NUDOCS 8112170660
Download: ML17341A726 (57)

Text

Docket Nos. 50-250 and 50-251 Florida Power 8 Light Company ATTN:

Dr. Robert E. Uhrig Vice President P.O.

Box 529100 Miami, Florida 33152 Gentlemen:

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~ I77t By letter dated October 14, 1981, we informed your Company that fees pursuant to 10 CFR 170.22 a<ere due for your application dated July 28, 1981 (L-81-323).

This application requested an extension of time to complete fire protection modifications related to certain valves for Turkey Point Units Hos.

3 and 4 in accordance with 10 CFR 50.48(d).

The $1,600 has not been received by us; therefore, it should be remitted to our office within fifteen days after your receipt of this letter.

Sincerely, p~nal SigneCbg,

~~ p. Miller 1Hlliam 0. Miller, Chief I'icense Fee Management Branch Office of Administration CERTIFIED MAIL RETURN RECEIPT REQUESTED DISTRIBUTION:

PDR LPDR Docket File v

RMDiggs, LFMB MGrotenhuis, ORB-1

CParrish, ORB-1 LFMB Reactor File LFMB Pending Check File LFMB R/F (2 81121 70660 8 1 f 20'DR ADQCK 05000250 F

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8 Q FLORIDA POWER IIc LIGHTCOMPANY November 23, 1981 L-81-492 WITHHOLD ATTACHMENT 3 FROM PUBLIC DISCLOSURE Office of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Mr. Eisenhut:

Re:

Turkey Point Units 3 8 4 Docket Nos.

50-250 8 50-251 Proposed License Amendments Base Load and Radial Burndown In accordance with 10 CFR 50.90, Florida Power 8 Light Company submits herewith three (3) signed originals and forty (40) copies of a request to amend Appendix A of Facility Operating Licenses DPR-31 and DPR-41.

These

,pages wi.ll supersede pages with the same number submitted via L-81-198, dated May 11, 1981.

The remai,nder of that submittal remains applicable.

The proposed. amendment is described below and shown on the accompanying pages bearing the date of this letter in the lower right hand corner.

These amendments are in response to the request of Mr. M. Dunenfdd of your staff for additional information on the Mini-Incore Distribution Surveillance System (MIDS), and additional clarification regarding the basis of the engineering uncertainty factor.

Pa es 3.2-.3, 3.2-3a, 3.2-3b, 3.2-3c and 3.2-4 The specification regarding Augmented Surveillance was revised to include provisions for,use of the MIDS under certain conditions of operation.

Fi ure 3.2-3 E

The, peaking factor nomenclature in the Figure is changed to that now'n use.

~Pa e 6-22 A requirement for reporting Peaking Factor Limits is added.

PEOPLE... SERVING PEOPLE

iS fl

Office of Nuclear Reactor Regulation Page Two Pa es B3.2-. 4, B3.2-8 and B3.2-8a A description. of the measurement of F~ utilizing the MIDS is expanded and clarified.

Please note that our response contains information considered to be proprietary by, the Westinghouse Electric Corporation.

In conformance with 10 CFR 2.790, we are also forwarding an application for withholding information from public disclosure

.(Attachment

1) and an Affidavit (Attachment 2)', setting forth the basis on which the proprietary information contained in Attachment 3 may 'be withheld from public disclosure by the Commission.

Attachment 3 contains a Safety Evaluation supporting the proposed Technical Specification changes'he proposed amendment has been reviewed by the Turkey Point Plant Nuclear Safety Committee and the Florida Power 8 Light Company Nuclear Review Board.

As this submi,ttal supplements, at NRC request, our-;earl,ier Proposed License Amendments (L-81-198) of May ll, 1981, no fee is transmitted.

Very truly yours, Robert E. Uhrig Vice President Advanced Systems 5 Technology REU/JEM/ah Attachments cc:

Mr. J.

P. O'Rei-lly, Director, Region II Harold F. Reis, Esquire

0

. ~C'TTACH>1ENT 1 AM-76-lO AFF'IDAVIT COViYiONWEALTH OF PENNSYLYANIA:

COUNTY.OF, ALLEGHENY:

Before me, the undersigned authority, personally appeared Robert A. Miesemann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation ("Westinghouse" ) ard'hat the aver-ments of. fact set. forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

Robert A. Wiesemann, i~1anager Licensing IPrograms Sworn to and subscribed before me this ~day of O'.W~".1976.

~

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Notary Public GEHEVlEYE X!SH, NOTARY PUSV C b10llROEVliJ.E BOROL'GH hLLLt)11LNf UUVATY UY COtiltniNIQll EMRES JULY 22, 1976

AM-76-10 (1)

I am Manager, Licensing Programs, in the Pressurized Water Reactor Systems Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Hater Reactor Divisions.

(2)

I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse, application for withholding ac-companying this Affidavit.

(3)

I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4)

Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the in-formation sought to be withheld from public disclosure should be withheld.

(i)

The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

3w AM-76-10 (ii).The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public.

Westinghouse has a rational basis for determining the types

~

of information customarily held in confidence by it and, in that connecti'on, utilizes a system to determine when and

. whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it

- falls in one or more of several

types, the release of which might result in. the loss of an existing or potential com-petitive advantage, as follows:

(a)

The in ormation reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.)

where prevention of its use by any of Westinghouse's competitors without license from Westinghouse consti-tutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process,(or c=mponent, structure, tool, method, etc.), the application of which data secures a

competitive economic advantage, e.g.,

by optimization or improved marketability.

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(c)

Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the

design, manufacture, shipment, installation, assurance of'quality, or licensing a similar product.

(d) It reveals cost or price information, production cap-

acities, budget levels, or commercial strategies of Mestinghouse, its customers or suppliers.

(e) It reveals aspects of past,

present, or future West-inghouse or customer funded development plans and pro-grams of potential commercial value to Mestinghouse.

(f) It contains patentable ideas, for which patent pro-

'tection may be desirable.

(g) It is not the property of Mestinghouse, but must be treated as proprietary by Hestinghouse according to agreements with the owner.

There are sound policy reasons behind the Hestinghouse system which include the following:

(a)

The use of such information by Mestinghouse gives Mestinghouse a competitive advantage over its com-petitors.

It is, therefore, withheld from disclosure to protect the Hestinghouse competitive position.

I

AM-76-10 (b) It is information which is marketable in many ways.

The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving'the use of the information.

(c)

Use by our competitor would put Westinghouse at a

competitive disadvantage by reducing his expenditure of resources at our expense.

(d)

Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

If competitors acquire components of proprietary infor-

mation, any one component may be the key to the entire

puzzle, thereby depriving Westinghouse. of a competitive advantage.

(e)

Unrestricted disclosure would jeopardize the position of prom-:.nence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.

(f)

The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

il 0

s

L1 AW-76-10 (iii)

The information is being transmitted to the Commission in confidence

and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Cormission.

(iv)

The information is not available in public sources to the best of our knowledge and belief.

(v)

The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Attachment II to Commonwealth Edison Company letter, Pliml to Purple dated May 4, 1976, concerning reload safety and licensing.

This information is being provided in support of a reload review of Comnonwealth Edison's Zion Station Unit 1, plant for cycle 2

operation.

This information is required per NRC Branch Technical Position CPB 4.3-1 Westinghouse Constant Axial Offset Control (CAOC)" since the applicant proposes cycle 2

CAOC operation for F~ = 2.25.

/

This information enables Westinghouse to:

(a)

Justify the design basis for the fuel (b)

Assist its customers to obtain licenses (c)

Meet warranties Further, this information has substantial commercial value as follows:

(a)

Westinghouse sells the use of the information to its customers for purposes of meeting NRC requirements for licensing documentation.

j

AM-76-10

.{b)

Westinghouse uses the information to perform and justify analyses which are sold to customers.

(c)

Westinghouse uses the information to sell nuclear fuel

'nd related services to its customers.

Public disclosure of this information. is likely to cause sub-stantial harm to the competitive position of Westinghouse in selling nuclear fuel and related services.

, Westinghouse retains a marketing advantage by virtue of the knowledge, experience and competence it has gained through long involvement and considerable investment in all aspects of the nuclear power generation industry.

In particular'Westinghouse has developed a, unique understanding

'of the factors and parameters which are variable in the process of design of nuclear fuel and which do affect the in.service performance of the fuel and its suitability for the purpose for which it was provided.

In all cases that purpose is to generate energy in a safe and efficient manner while enabling the operating nuclear generating station to meet a']1

- regulatory requirements affected by the core loading of nuclear fuel.

Confidence in being able to accomplish this comes from the exercise of judgement based on experience, in the application of empirically derived models based on prior data and in the use f proven analytical models to simulate behavior of the fuel in normal operation and under hypothetical transients.

AM-76-10 Thus, the essence of the competitive advantage in this field lies in an understanding of which analyses should be performed and in the methods and models used to perform these analyses.

A substantial part of this competitive advantage will be lost if the competitors of Hestinghouse are able to use the results of the analyses in the attached document to normalize or verify their own methods or models or if they are able to claim an equiva1ent understanding by demonstrating that they

. can arrive at the same or similar results.

Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design and licensing of a similar product.

This information is a product of Westinghouse design technology.

As. such, it is broadly applicable to the sale and licensing of fuel in pressurized water reactors.

The development of this information is the result of many years of Westinghouse effort and the expenditure of'a considerable sum of money.

While the analyses for this specific application were not unique, in order for competitors of Westinghouse to duplicate this information would require the investment of substantially the same amount of effort and expertise that Westinghouse possesses and which was acquired over a period of more than fifteen years and by the investment

- of millions of dollars.

Over the years, this has included the development of heat transfer codes, nuclear analysis codes, transient analysis

codes, core and system simulation methods and an experimental data base,to support them.

Further the deponent sayeth not.

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ATTACHMENT 2 STATE OF FLORIDA

)

COUNTY OF DADE ss Robert E. Uhri being first duly sworn, deposes and says:

That he is Vice Pres ident the Licensee herein; of Florida Power 5 Light Company, That he has executed the foregoing document; that the statements made in this document are true and correct to the best of hi s knowl edge, information, and belief, and that he is authori zed'o execute the document on behalf of said Licensee.

Attachment 3

(Pages 1

4) of the enclosed material is/ONE exempt from publ ic di sc1 osure i n accordance with Section

2. 790 of the NRC "Rules of Practi ce", Title 10, Code of Federal Regulations

~

Pursuant to section(s) b thi s informati on is exempt from di'scl osure because Attachment 3 contai ns rivi 1 e ed and confidential information.

Robert E ~ Uhrig Subscribed and sworn to before me this 3

day, of'9~!

NOTARY'UBLIC, and for the County of';Dade, State of Flori da.

Notary Pobgc, State of Rorida at Large MY commi ss ion expires:

My commission Expires october 30, 1983 Qno ncU Ivrdyiidi ov ding Agency

reactivity insertion upon ejection greater than 0.3$ Qk/k at rated power.

Inoperable rod worth shall be determined within 4 weeks.

b.

A control'od shall be considered inoperable if a) the rod cannot be moved by CRDM, or b) the rod is misaligned from its bank by more than 15

inches, or (c) the rod drop time is not.met.

c.

If a control rod cannot be moved by the drive mechanism, shutdown margin shall be increased by boron addition to compensate for the withdrawn worth of the inoperable rod.

5.

CONTROL ROD POSITION INDICATION'f either the power range channel deviation alarm or the rod deviation monitor alarm is not operable, rod positions shall be logged once per shift and after a load change greater than 1', of rated power.

If both alarms are inoperable for two hours or more, the nuclear overpower trip shall be reset to 93$ of rated power.

6.

POWER DISTRIBUTION LIMITS a.

Hot channel factors:

(1)

F~ Limit The hot channel factors (defined in Bases) must meet the following limits at all times except during low power physics tests:

Fq (Z)

< (LFqjL/P) x K(Z), for P ) 0.5 Fq (Z)

< (2 x [FgL) x K(Z), for P

< 0.5 FN

< 1.55 L1.0 + 0.2 (1 - P)j Where P is the fraction of rated power. at which the core is operating; K(Z) is the function given in Figure 3.2'-3; Z is the core height location of Fz.

LFAjL and K(Z) are dependent on the steam generator tube plugging 16vel as follows:

Plugging level

[F~jL

< 28$

2. 125 (2)

Augmented Survei 1 lance (MIDS)

Figure Number for K(Z)

3. 2-3 iy [p ],

as.predicted by approved physics calculations, exceeds

[pq]t tIen the power wil.i be limited to a turnon power fraction, PT, equal to the ratio or.[Fn]t divided by [Fq]p, or, for operation at power levels ab6ve PT, augmented surveillance of hot channel. factors shall be implemented, except in.Base Load

3. 2-3 11-.23-81

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operation (Section 3.2.6.a(3))

or Radial Burndown operation (Section 3.2.6.a(4) ).

For operation at power levels between PT and 1.00, the fo'llowing shall apply when not in baseload or radial burndown operation:

1.

The axial power distribution shall be measured by NIDS when the thermal power is in excess of PT such that the limit of

[F]'L/P times Figure 3.2-3 is not exceeded.

F (Z) is the noPmal'ized axial power distribution from thimb'le j at core elevation (Z).

(1) If F (Z) exceeds

[F-(Z)j as defined in the 'bases by 4g, )mmediately reduce thermal power one percent for every percent by which [F -(Z)]s i s exceeded.

(2) If F (Z) exceeds [F.(Z)j by ) 4g immediately reduce thecal'ower below PT.

Corrective action to reduce s,

F (Z).below the limit will permit return to thermal power not to exceed current PL as defined in the bases.

F (Z) shall 'be d'etermined to be within limits by using NIDS tl monitor the thimbles required per specification 6.a.2,3 below at the following frequencies:

(1)

At least once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and (2)

Immediately following and as a minimum at 2, 4 and 8

hours following the events listed below and every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter 1)

Raising the thermal power above PT, or 2)

Movement of.control-bank D more than an.accumulated total of 15 steps in any one direction.

3.

MIDS shall be operable when the thermal power exceeds PT with:

(1)

At least two thimbles available for which 'R-and o as defined in the bases have been determined.

(2)

At least two movable detectors available for mapping F

(Z).

(3)

The continued accuracy and representativeness of the selected thimbles shall be verified by using the most recent flux map as per. Table 4. 1-1 to update the R for each selected thimble.

(3)

Base Load Operation l.

Base Load operation may be used at power levels between PT and PBL or pz and 1.00 (whichever is most 'limiting).

The maximum relative power permitted under Base Load-operation, 3.2-3a 11-23-81

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PBL, is equal to the minimum value of the ratio of

[FQ(Z)jL/[FQ(Z)j where LFQ(Z)g" i s equal to f.FQ(Z)j<

x W(Z) x 1.09, and )FQ(Z)jL is equal to fFQgL X K(Z).

For the purpose of the specification,

$FQ(Z)) <<as shall Map be obtai'ned between the elevati ons bounded by + lOX of the active core height.

The function W(Z) is determined analytically and accounts for the most perturbed power shapes which can occur under the constraints of Section 3.2.6.a(3 )4.

W(Z) corresponding to either + 2X or + 3$

z I may be used to infer PB~.

The uncertainty factor of 9.0$ accounts for manufacturing toTerances, measurement

error, rod bow, and any burnup and power dependent peaking factor increases.

Base Load operation can be utilized only if Section 3. 2.6. a(3) 2 or Section 3. 2.6. a(3')3 is sat i sfi ed.

2.

NOTE:

For entering Base Load operation with power less than PT.

Prior to going to Base Load operation, maintain the following conditions for at least 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

(1)

Relative power must be maintained between PT/1.05 and. PT.

(2) a I within +21, or + 3g AI target band for at least 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.

The corresponding W(Z) is to have been used to determine PBL.

After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have elapsed a full core flux map to determine '[FQ(Z)jM shall be taken unless a vali d Map full core flux map was taken within the time period speci. fied in Section 4.1.

PBL is then to be calculated as per Section

3. 2.6. a(3) 1.

3.

NOTE:

For entering Base Load operation with power greater than PT.

Prior to going to Base Load operation and prior to discontinuing augmented surveillance of hot channel factors, maintain the following conditions for at least 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

(,1)

Relative power must be maintained between PT and the power limited by augmented surveillance of hot channel factors.

(2) a,I within +

2X or + 3g, AI target band.

Corresponding W(Z) to have been used to determine PBL.

After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have elapsed a full core flux map to determine LF (Z)jM shall be taken unless a valid full core flux map Q

Map was taken within the time period specified. in Section 4.1.

PBL is then to be calculated as per Section 3.2.6.a(3,)1.

3. 2-3b 11-23-81

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4.

If the conditions of Section 3.2.6.a(3)2 or of Section 3.2.6.a(3)3 are satisfied, then Base Load operation may be utilized provided the following is maintained..

(1)

Power between PT and PBL or PT and 1.00 (whichever is most 1 imiti ng).

(2) a I withi n +

2g, or + 3$ h I target band.

Correspondi ng W(Z) to have been used to determine PBL.

(3),

Subsequent full core flux maps are taken within the time period specified in Section 4.1.

5.

If any of the requirements of Section 3.2.6.a(3)4 are not maintained, then power shall be reduced to less than or equal to PT, or within 15 minutes augmented surveillance of hot channel factors shall be initiated if the power is above PT.

(4)

Radi al Burndown Operation 1.

Radial Burndown operati.on is restricted to use at powers between PT and PRB or PT and 1.00 (whichever is most limiting).

The max>mum relative power permitted under Radial Burndown operation, Pzz, is equal Q the minimum value of the ratio of [FQ(ZJjL/[FQ(Z)jRB where [FQ(Z)jRB

= [Fxy( )j>

x Fz(Z) x 1.09, and

[FQ(>)jL is equal to [FQjL) x.K(Z) 2.

A full core flux map to determine

[Fxy'(Z')jpa shall be taken within the time period specified in Section 4.1.

For the purpose of the specification,,[Fxy(Z)j ppp shall be obtained between the elevations bounded by + 105 of the active core height.

3.

The function Fz(Z) is determi ned analytical.ly and accounts for the most perturbed axial power shapes which can occur under axi al power di stri buti on control.

The uncer tai nty factor of 9g, accounts for.manu facturi ng to 1 e rane es, measurement

error, rod bow, and any burnup dependent peaking factor increases.

3 ~ 2-3 c 11-23-81

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4.

Radial Burndown operation may be utilized at powers between PT and PRp or PT and 1.00 (whichever is most limiting) provided %hat the.indicated flux difference is withi'n + 5g bI of the target axial offset.

5.

If any of the requirements of Section 3.2.6.a(4)4 are not maintained, then the power shal.l be reduced to less than or equal <<Pq or within 15 minutes augmented surveillance of hot channel factors shall be initiated if the power is above PT.

b.

( 1)

The measurement of total peaking, factor,

$f (Z))~eas shall be increased by,three percent to account for mfnufaAHri ng tolerances and further increased by five percent to account for measurement error..

These uncertainties. only apply if the map is taken for purposes other than determination of, PBL and PRB.

(2)

The measurement of the enthalpy rise hot channel factor f"H.

shall be increased by four percent to account for measurement error.

If either measured hot channel factor exceeds its limit specified under Item 6a, the reactor power shall be reduced so as not to exceed a fraction of the rated value equal to the ratio of the F~

ol FN>H,limit to measured value, whichever is less, and.the high neutron flux trip setpoint shall be reduced by the same ratio.

If subsequent in-core mapping cannot, within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, demonstrate that the hot. channel factors are met, the reactor shall be brought to a hot shutdown condition with return to. power authorized only for the purpose of physics testing.

The reactor may be returned to higher power levels when measurements indicate that hot channel factors are within limits.

c.

The reference equilibrium indicated axial flux di'fference as a

function of power level (called the target flux difference) shall be measured at least once,per effective full power quarter..

If, the axial flux difference has not been measured in the l'ast effective ful.l power month, the target flux difference must be updated, monthly by linear interpolation using the most recent measured value and the value predicted for the end of the cycle life.

d.

Except during physics tests or during excore calibration procedures and as modified by items 6e through 6g.below, the indicated axial flux difference shall be maintained within a +

5g, band about the target flux difference,(this defines the target band on axial flux difference).

e.

If the indicated axial flux di'fference at a power level greater than 90K of the rated power deviates 3:. 2-4 11-23-81

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( or < 28" steam oenerator tube p1uogfna and:[p~)L

= 2.125):

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{12.0 470}

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Amendment Nos.

68 5 60 FIG. 3.2-3 23-81

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6.9.3 SPECIAL REPORTS Special reports shall be submitted covering the activities identified below pursuant to the requirements of the applicable reference speci fication where appropriate.

Twenty copies of the following reports should be sent

.to the Director, Nuclear Reactor Regulation.

a.

In-service inspection, reference 4.2.

b.

Tendon surveil lance, reference 4.4.

c.

Fire protection

systems, reference 3.14.

d.

Peaking Factor Limit Report - The W(Z) function(s) for Base-Load Operation corresponding to a g2X band about the target flux difference and/or a z3g band about the target flux difference, the Load-Follow function FZ(Z) and the augmented surveillance turnon power fraction, PT, shall'e provided to the Director, Nuclear Reactor Regulations, Attention Chief of the Core Performance

Branch, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555 at least 60 days prior to cycle initial criticality.

In Phe event that these values would be submitted at some other time during core life, it will be submitted 60 days prior to the date the values woul'd become effective unless otherwise exempted by the Commission.

6.9.4 UNI UE REPORTING RE UIREMENTS a.

Radioactive Effluent Releases A report of the quantities of radioactive effluents released from the plant, with data summarized on a monthly basis following.the format of U.S.

NRC Regulatory Guide 21.

The report shall be submitted within 60 days after January 1 and after July 1 specifying quantities of radioactive effluents released during the previous 6 months. of operation.

1.

Gaseous Releases (a)

Total radioactivity (,in curies) releases of noble and activation gases.

(b)

Maximum noble gas release r ate during any one-hour period-.

(c)

Total radioactivity (in curies) released by nuclide, based on representative isotopic analyses performed.

(d)

Percent of technical specification limit.

2.

Iodine Releases (a)

Total

( I-133, I-135) radioactivity (in curies) released.

(b)

Total radioactivity (in curies)

released, by nuclide, based on representative isotopic analyses performed.

6-22 11-23-81

4 V

fff a

s W

W I

I, d

W v

Wg f f

WJ I

II I'I E

~ I, 4 w 4, I

'4 I

Il I

I 4

I I

r

.f d "

I r

II

~

4

~ I I Id "I ff

An upper bound. envelope as defined by normalized peaking factor axial dependence of Figure 3.2-3, has been determined to be consistent with the technical specifications on power distribution control as given in Section 3.2.

The results of the loss of coolant accident analyses based on this upper bound envelope indicate a peak clad temperature could theoretically exceed the 2200'F limits.

To ensure the criteria are not violated MIDS will be used to provide a more exact indication of F.

Note that MIDS and a penalty on F are only required above PT to meet the acceptance criteria as justifi'ed in thV analyses.

Below PT, the nuclear analyses of. credible power shapes consistent with these specifications have shown that the limit of LF~]L/P times Figure 3.2-3 is not exceeded provided the limits of Figure. 3.2-3 are applied.

When an F~ measurement is taken, both experimental error and manufacturing tolerance must be allowed for.

Five percent 'is the appropriate allowance for a full core map taken with the movable incore detector flux mapping system and three percent is the appropriate allowance for manufacturing tolerance.

These uncertainties onl.y apply if the map is taken for purposes other than the determination of PBL and PRB.

In the specified limit of F~H, there is an.8 percent allowance for N.

uncertainti~s which.means that normal operation of the core is expected to result in F>H<1.55/1.08.

The logic behind the larger uncertainty in this case is that (a) normal per$ urbations in the radial power shape (e.g.,

rod misalignment) affect F>H, in most cases without necessarily affecting F~,

(b) although the operator has a direct influence on F, through movement of

rods, and can limit it to the desired

value, he has n0 direct control over F>H and(c) an error in the prediction for radial power shape, which may be detected during startup physics tests can be compensated for in F~ by tighter axial control, b t compensation for F~

is less readily available.

When a

measurement of fa is taken, experimen(al error must be allowed for and 4$ is the appropriate a lowance for a full core map taken with,the movable incore detector flux mapping system.

Measurements of the hot channel factors are required as part of start-up physics tests, at least once each full power month of operation, and whenever abnormal power distribution conditions require a reduction of core power to a

level based on measured hot channel factors.

The incore map taken following initial loading provides confirmation of the basic nuclear B3.2-4 11-23-81

Q 1I H

5 (5)(Base Load Case(.s),

150 MWD/T) 5 (5)(Base Load Case(s),

555 EOL W(Z)=(Max 5 (Z)lfARO, 150 MWD/T) 5 (5),(ARO, 555 EOL BOj For Radial Burndown operation the full spectrum of possible shapes consistent with control to a + 5g dI band needs to be considered in determining power capability.

Accordingly, to quantify the effect of the limiting transients which could occur during Radial Burndown operation, the function Fz(Z) is calculated from the following relationship:

Fz(Z)

= t-Fq(Z) jFAC Analysi s/ LFxy(Z)'jARO As discussed

above, the essence of the procedure is to maintain the xenon distribution in the core as close to the equilibrium full power condition as possible.

This can be accomplished without part length rods by using the boron system to position the full length control rods to produce the required i ndi cated flux di fference.

BU) for Operating Transient

events, the core is protected from overpower and a

minimum DNBR of less than 1.30 by an automatic protection system.

Compliance with operating procedures is assumed as a precondition for Operating Transients,

however, operator error and equipment malfunctions are separately assumed to lead to the cause of the transients considered.

Above the power l evel of pT,, addi tional flux shape moni tori ng i s requi red.

In order to assure that the total power peaking factor, Ffi, is maintained at or below the limiting value, the movable incore instrumentation will be utilized'.

Thimbles are selected initially during startup physics tests so that the measurements are representative of the peak core power density.

By limiting the core average axial power distribution, the total power peaking factor F

can be limited since all other components remain relatively fixed.

The remaining part of the total power peaking factor can be derived based on incore measurements, i.e.

an effective radial peaking factor R; can be determined as the ratio of the total peaking factor results from a full core flux map and the axial peaking factor in a selected thimble.

Any reference to part-length rods no longer applies after the part-length rods are removed from the reactor.

REFERENCES FSAR. - Section 14.3.2 B3. 2-8 11-23-81

r J,h k

kh II r,

I c

k I

I 'l Ik k

ih.

h k

Jl hl ll I I

I i

1 1

It.

I I'k lh

~.

k II hl

, ~

II II I

1 k

i k

J 1

k< f kk h

II II J.

Il h

I ti I'l.

I

0 The limiting value of LFj (Z)js is derived as follows:

[F- (Z)j

=

5FqjL l.K(Z)j Where:

a) b)

c) d)

e)

F

~ (Z) is the normalized axial power distribution from thimble j at e/evation Z.

PLis reactor thermal power expressed as a fraction of l.

K (Z) is the reduction in limit as a function of core elevation (Z) as determined from Figure 3.2-3.

LF.(Z)j is the alarm setpoint for NIDS.

.j R, for thimble j,, is determined

.from.n=6 incore flux maps covering tie full configuration of permissible rod patterns at the thermal power excore limit of PT p

X i J where r

VAC.O 5 IF,(z)j (Z) is normalized axial distribution at "el'evation Z from thimble j in map

>, which has a measured peaki qg factor without uncertainties or densification allowance of F~~ias.

f) a< is the standard deviation, expressed as a fraction or, percentage ok Fj, and is derived from n flux maps and the relationship below, or 0.02 I2%), whichever is greater.

.[/

(p,;,-R,)"

3 g)

The factor 1.03 reduction in the Kw/ft limit is the engineering uncertainty factor.

h)

The factors (1 + o;-.) and 1.07 represent the margin between LF. (Z))L limit and the NIDS alarm setpoint IF (Z)]s.

Since

('1 + qj )

bounded by a lower limit of 1.02, there is at least a 9$ reduction of the alarm setpoint.

Operations are permitted in excess of the operational limit < 4g while making power adjustment on a.percent for percent basis.

83.2-8a 11-23-81

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ATTACHMENT 3 0

EKE/llPT FBOL'I OISCNSUBE 10 CQ 2.7C3 lflF62t"MTICi'I WESTINGHOUSE PROPRIETARY CLASS 2 SAFETY EVALUATION Re:

Turkey Point Units 3

8 4

Docket No. 50-250 and 50-251 Radial Burndown and Base Load Operation I

Introduction The present Technical Specifications provide for axial power distribution

controls, which are given in,terms of flux difference limitations and control bank insertion limits.

These controls are designed to minimize the effects of xenon redistribution on the axial power distribution during load-follow maneuvers by limiting the, power to a turnon power

fraction, PT.

This turnon power fraction depends on the analytically predicted maximum [FQP, generated'y, determining FQ(Z) for a series of load follow maneuvers. consistent with axial offset control to a +N band about the target flux. difference.

This safety evaluation supports two alternative methods for determining an increase in the turnon power fraction to a redefined maximum relative power.

The first method, Radial Burndown operation, is based upon utilizing a measured FXY(Z) from a full core flux map in conjunction with the analytically determined FZ(Z).

The Fn(Z} calculated by this method, with the appropriate uncertainties

appliect, s s used to determine a

maximum relative power, PRq.

The second

method, Base Load operation, takes credit for the fact that the severity of the shapes which need to be analyzed is significantly reduced relative to load follow operation.

The Fn(Z) determined by this method also utilizes a full core flux map in the dltermination of,a maximum relative power, PBL.

Uncertainty to Be A plied To Measured Peaki'ng Factors where:

FE Q

FU N

FB FQP,BU 1.05 Flux Map Measurement Uncertainty 1.056 Rod Bow 'Penalty 1.04 Burnup and Power Sensitivity, Uncertainty EKEL".PT FlMl,'l CL~CLGSU."i'"

10 CR 2.769 l(lFG'2iilAIICB 1

11-23-81 The 1.09 uncertainty applied to pFQ(Z)]

and [Fxy(Z)]Meas accounts for Q

Map Map the impact of manufacturing variability on power distribution, the measurement error associated with the flux map inferred'ower distribution, the impact of rod bow on FQ and the sensitivity of FQ to power and bur nup.

The total uncertainty tolerance interval, (95$

probabil.ity and 95$ compliance) was obtained by statistical'.ly combining the individual,uncertainty components as follows:

Total Uncertainty FU 1 + [(FE 1)2 ~

(FU 1)2 ~ (FB-l)2 +

(FQP,BU 1)2]1/2 Q

Q N

'Q 1.03 Engineering Hot Channel Factor

4 4

,h 4 4

F h

, ~ 4 h

4 4

LSV

+

~

IlIWGHOUSE PROPRIETARY CLASS 2

EXEISPT Fllgbi OISOLOSllRE 10 CZ 2.790 IHFCHI",ISATION F

and F

are standard Westinghouse uncertainties which, are multiplicatively E

U applied to FQ measurements in typical technical

~pecifications.

Note that (1.03)(1.05)

= 1.0815.

The value of 1.056 for F

was chosen such that.the convolution (square root of the sum of the squares) of F, F

and F

yields

'E U

B approximately 1.0815.

The justification for convolving these uncertajnties, and information relating to the conservatism of the 1.056 value for F is provided in the rod bow topical report WCAP-8962.

F< 'as obtained from 30 calculations using qualified'0 nodal models developed for Turkey Point Unit 3 (FPL) Cycle,7 and Turkey Point Unit 4 (FLA)

Cycle 6.

Sensitivity of F

for burnup changes of 1000 WWO/WTU and power changes from 90S to 100S w s investigated.

The sensitivity to burnup is needed to account for the effective full power month interval between which full core flux maps are required.

The sensitivity to power accounts for the uncertainty in the full power F as inferred from the F measured at the turn-on power.

The maximum penalty gas calculated to be 0.8$ ]a'c for burnup and

[2.9%] 'or power.

The combined prodIIc) of [3.7S] 'as rounded up to 4$

thereby yielding a value of 1.04 for F

The value of 1.04 was obtained in a sufficiently conservative manner 3o justify the use of this value in subsequent Turkey Point reload cycles.

III.

Evaluation 1.

Radial Burndown 0 eration A multi-case elevation-dependent peaking factor analysis (approved by the NRC in Reference

1) or a several case subset analysis is performed to determine the turnon power fraction PT Before the relative power is permitted to increase the above PT, the maximum relative power permitted under Radial Burndown operation,

PRB, is determined from a full core flux map and the function FZ(Z) as defined below.

c (a c)

F (Z)18 Case or 3 Case subset F (Z)18 Case or 3 Case / Fx>(Z)

Q Q

The above description constitutes a straightforward application of previously developed and approved Westinghouse methodology (Reference 2).

The conservative definition of FZ(Z) coupled with the requi rem~nt of the Radial Burndown Technical Specsfication ensures that I F (Z)]

Q RB conservatively bounds the power distributions that can occur under Radial Bur ndown operation.

2.

Base Load Operation Similarly, as in the case of Radial Burndown operation, the relative power is permitted to increase above Pq if the following conditions are satisfied.

The indicated flux difference must be held to +2 or

+3g, I about the target axial offset and relative power must be between P T and PT/1.05 for 24 -hours.

The maximum relative power EXEl'APT FAOM DISCSSUHE 10 Ci.B 2.700 I/JFO'l/MATfN1 11-23-81

~5 0

4 0

~I L

t'

.WE NGMOUSE PROPRIETARY CLASS 2 ~

EXEI'IPT F'IGll GiSCLOSIIRE 10 Cril 2.790 ll'JFCWHATIQW permitted under Base Load operation, Pq~

is then determined from a full core flux map and the function W(2J as defined below.

Therefore, as a minimum, power swings between PT/1.05 and PBL must be considered in generating the function W(Z).

For gonsyrvatism, power swings between

[PT/1.10 and 1.0 are utilized)<a>>cJ.

Table 1.provides a

description of the several cases used to generate W(Z).

Daily load'ollow is.not permitted; however, to allgw fpr some rod shadowing the 85$

EOL cases are based upon a [0-In 6$g<<

c~ depletion.

The function W(Z) is defined as:

I Base Load Cases 1'

2 Base Load Cases 3 5 4 F

Z F

Z ARO, 150 NWD/MTU ARO, 855 EOL BU Fq(Z)

F<(Z)

The above description constitutes a straightforward application of previously developed and approved (W) methodology (Reference

2) to a tightly constrained operating regime.

The conservative definition of FZ(Z) coupled'ith the restrictiony required by Base Load Technical Specification ensures that.[Fq(Z)jB conservatively bounds the power distributions that can occur under Base Load Operation.

IV.

Conclusion (a.c)

Based on the considerations described

above, (1) the proposed change does not increase the probability or consequences of accidents or malfunctions of equipment important to safety and does not reduce the margin of safety as defined in the basis for any technical specification, therefore, the change does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed

manner, and (3) such activities will be conducted in compliance with the Commission' regulations and the issuance of this amendment will not be inimical to the common defense and securi'ty or to the health and safety of the public.

Reference 1:

Vassallo to Eicheldinger letter 4/76 Reference 2:

WCAP-8385 11-23-81

0 I i I

ll'"

I l

I

't vl I

II It'

/V I.lit fi tii ~

I I

v 1

I,

~ p I

I v

tl lt v

I II It ii t

Il W

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S, I

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II t

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<<< ~~ < ~<4 ll<+AL' z(CP<<QIETQQ<g CLASS 2

qKEUPT HIGill01SCLGSRE 10 CT2 2.760 liN'6'2lilMTtCH TABLE 1 AGES r4>

C (a,c)

Case Descri tion l50 M/D/I~TU, MINB 100-PS-100,

+2 o 3%6X Band 150 l4ND/NTU, CNTR 100-PS-100,

+2 or 3%6X Band 85%

EOL BU, HINB 100-PS-100,

+2 or 3%LX Band.

859 EOL BU, CNTR 100-PS-100,

+2 or 3MI Band (a, c)

)where EOL is reactivity end-of-life of the cycle and PS

= Power Saving

=

P /1.10 T

ATTACHMENT 4 SAFETY EVALUATIG'i Re:

Turkey Point Units 3 8 4 Docket No. 50-250 and 50-251 Radial Burndown and Base Load Operation I.

Introducti on The present Technical Specifications provide ior axial power distribution

controls, which are given in terms of flux difference limitations and control bank insertion limits.

These controls are designed to minimize the effects of xenon redistribution on the axial power distribution during load-follow maneuvers by limiting the power to a turnon power

fraction, PT.

This turnon power fraction depends on the analytically predicted maximum (FgP, generated by determining FQ(Z) for a series of load follow maneuvers consistent with axial offset control to a +N band about the target flux difference.

This safety evaluation supports two alternative methods for determining an increase in the turnon power fraction to a redefined maximum relative power.

The first method, Radial Burndown operation, is oased upon utilizing a measured Fxy(Z) from a full core flux map in conjunction with the analytically determined FZ(Z).

The FG(Z) calculated by this method, with the appropriate uncertainties appliec, is used to determine a

maximum relative power, PRq.

The second rethod, Base Load operation,.

takes credit for the fact Chat the severi ty of the shapes which need to be analyzed is significantly reduced rela-.ive to load follow operation.

The Fq(Z) determined by this method also utilizes a full core flux map in the d8termination of a maximum relative power, PBL.

II.

Uncertainty to Be A plied To measured Peaking Factors

+ [(FE 1)2 P (FU-1)2 + (FB 1)2 ~

(FQP,BU 1)211/2 Q

N Engineering Hot Channel Factor Flux tlap treasure.".ent Uncertainty Total Uncertainty

F"

FE FU N

FB F P,BU where:

1. 03 1.05 1.056.Rod Bow Penalty 1.04 Burnup and Power Sensitivity Uncertainty The 1.09 uncertainty applied to [FQ(Z)Peas and pFxy(Z)g"eas accounts for Q

Hap Nap the impact of manufacturing variability on power distribution, the measurement error associated with the flux map inferred power distribution, the impact of rod bow on FQ and the sensitivity of FQ to power and burnup.

The total uncertainty tolerance interval, (951, probability and 95$ compliance) was obtained by statistically combining the individual uncertainty components as follows:

11-23-81

4 I>

F and F

are standard Westinghouse uncertainties which are multiplicatively E

U applied to FQ measurements in typical technical

~pecitications.

Note that (1.03)(1.05)

= 1.0815.

The value of 1.056 for FQ was chosen such that the convolution (square root of the sum of the squares) of F F

and F

yields Q'

Q approximately 1.0815.

The justification for convolving these uncertaeInties, and information relating to the conservatism of the 1.056 value for F is provided in the rod bow topical report WCAP-8962.

FA 'as obtained from 3D calculations using qualified 3D nodal models developed for Turkey Point Unit 3 (FPL) Cycle 7 and Turkey Point Unit 4 (FLA)

Cycle 6.

Sensitivity of F for burnup changes of 1000 NWD/HTU and power changes from 90', to 1001, was investigated.

The sensitivity to burnup is needed to account for the effective full power month interval between which full core flux maps are required.

The sensitivity to power accounts for the uncertainty in the full power F as inferred from the F~ measured at the turn-on power.

The maximum penalty Aas calculated to be [

ja'c for burnup and-

]4 c for power.

The combined prod~c of L

g 'as rounded up to 4X thereby yielding a value of 1.04 for f The value of 1.04 was obtained in a sufficiently conservative manner 3o justify the use of this value in subsequent Turkey Point reload cycles.

III.

Evaluation 1.

Radial Burndow~n 0 aration A multi:~ase elevation-dependent peaking factor analysis (approved by the NRC in Reference

1) or a several case subset analysis is per formed to determine the turnon power fraction PT Before the relative power is permitted to increase the above PT, the maximum relative power permitted under Radial Burndown operation,

PRB, is determined from a full core flux map and the tunction FZ(Z) as defined below.

(a,c)

The above description constitutes a straightforward application of previously developed and approved Westinghouse methodology (Refer ence 2).

The conservative definition of FZ(Z) coupled with the requirement of the Radial Burndown Technical Specification ensures that t F (Z)j "

R RB conservatively bounds the power distributions that can occur under Radial Burndown operation.

2.

Base Load Operation Similarly, as in the case of Radial Burndown operation, the relative power is permitted to increase above Pl-if the following conditions are satisfied.

The indicated flux di frerence must be held to +2 or

+3/

I about the target axial offset and relative power must be between P T and PT/1.05 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The maximum relative power 11-23-81

0"

~9!.S

~

~

r permitted under Base Load operation, Pqi is then determined from a full core flux map and the function W(2J's defined below.

Therefore, as a minimum, power swings between PT/1.05 and PBL must be considered in generating the function W(Z).

For gonsyrvatism, power swings between P

Table 1 provides a

description of the several cases used to generate W(Z).

Daily load follow is.not permitted; however, to allgw fqr some rod shadowing the 8Q, fOL cases are based upon a f

. j<a~c> depletion.

The function W(Z) is defined as:

Max The above description constitutes a straightforward application of previously developed and approved (W) methodology (Reference

2) to a

tightly constrained operating regime.

The conservative definition of FZ(Z) coupl ed with the restrictions requi red by Base Load Technical Specification ensures that (VAN(2)jB<

conservatively bounds the power distributions that can occur under Base Load Operation.

IV.

Conclusion Based on the considerations described

above, (1) the proposed change does not increas~

the probe"i lity or consequences of accidents or malfunctions of equipment important to safety and does not reduce the margin of safety as defined in the basis for any technical specification, therefore, the change does not involve a significant hazards consider ation, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed

manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Reference I:

Vassallo to Eicheldinger letter 4/76 Reference 2:

WCAP-8385 11-23-81

~'

0 4>

, (

TABKE 3.

[

)

CAS S

'EFXilING BASr LOAD PPEPATZOai'a,c)

(a, c)

gt '

-IO j~

• 1