ML18198A118

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Transmittal of Proposed License Amendment Request (LAR) Addition of Analytical Methodology to COLR Small Break Loss of Coolant Accident (SBLOCA)
ML18198A118
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 07/12/2018
From: Mark D. Sartain
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18198A133 List:
References
18-233
Download: ML18198A118 (22)
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Text

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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390 July 12, 2018 10 CFR 50.90 ATTN: Document Control Desk Serial No.18-233 U.S. Nuclear Regulatory Commission NRA/DEA RO Washington, DC 20555-0001 Docket Nos. 50-338/339 License Nos. NFP-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION - UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST CLAR)

ADDITION OF ANALYTICAL METHODOLOGY TO COLR SMALL BREAK LOSS OF COOLANT ACCIDENT (SBLOCA)

Pursuant to 10 CFR 50.90,* Virginia Electric and Power Company (Dominion Energy Virginia) is submitting a request for an amendment to revise the Technical Specifications (TS) for North Anna Power Station (NAPS) Units 1 and 2. The proposed amendment requests the addition of Framatome Topical Report EMF-2328(P)(A),

Revision 0,. "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based," as supplemented by the North Anna-specific application report ANP-3467P, Revision 0, "North Anna Fuel-Vendor Independent Small Break LOCA Analysis Licensing Report,"

to the list of methodologies approved for reference in the Core Operating Limits Report (COLR) in TS 5.6.5.b. This amendment also removes one obsolete COLR reference in TS 5.6.5.b that supported use of the Advanced Mark-BW (AMBW) fuel product. The AMBW fuel product is not planned to be used in future North Anna cores.

Supporting information provided in the attachments to this letter is summarized below:

- Attachment 1 provides an evaluation of the proposed TS changes.

- Attachment 2 provides marked-up TS pages.

- Attachment 3 provides proposed TS changes pages.

- Attachment 4 provides a reanalysis of the NAPS Updated Final Safety Analysis Report (UFSAR) Chapter 15 SBLOCA (Proprietary).

- Attachment 5 provides a reanalysis of the North Anna Power Station UFSAR Chapter 15 SBLOCA (Non-proprietary).

-

  • Attachment 6 contains the Affidavit of Framatome Inc. for withholding proprietary information from public disclosure.

Since Attachment 4 contains information proprietary to Framatome, it is supported by an affidavit *signed by the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and /

addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390.) /) ()

. ~~i Attachment 4 contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation from Attachment 4, this letter is decontrolled.

Serial No.18-233 LAR - SBLOCA Methodology Addition to COLR References Page 2 of 3 Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. A redacted, non-proprietary version is provided in Attachment 5 as noted above ..

Dominion Energy Virginia has evaluated the proposed amendment and determined that it does not involve a significant hazards consideration as defiried in 10 CFR 50.92. The basis for this determination is included in Attachment 1. Dominion Energy Virginia has also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

The proposed TS change has been reviewed and approved by the NAPS Facility Safety Review Committee.

Dominion Energy Virginia requests approval of the proposed amendment by December 31, 2019, with a 90 day implementation period.

If there are any questions or if additional information is needed, please contact Ms.

Diane Aitken at (804 )-273-2694.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support COMMONWEAL TH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering and Fleet Support of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this ~ a y of ~ , 2018.

My Commission Expires: S-3 / - :/2 VICKI L. HULL

//;di. ;(JI~ 'ttif NOTARY PUBLIC REG. # 140542 COMMONWEALTH OF VIRGINIA

  • MY COMMISSlON EXPIRES 9131/2022

Serial No.18-233 LAR - SBLOCA Methodology Addition to COLR References Page 3 of 3 Commitments made in this letter: None Attachments:

1. Discussion of Technical Specifications Change
2. Marked-up Technical Specification Pages
3. Proposed Technical Specification Pages
4. ANP-3467P, Revision 0, North Anna Fuel-Vendor Independent Small Break LOCA Analysis Licensing Report (Proprietary)
5. ANP-3467NP, Revision 0, North Anna Fuel-Vendor Independent Small Break LOCA Analysis Licensing Report (Non-Proprietary)
6. Affidavit of Framatome Inc.

Serial No.18-233 LAR - SBLOCA Methodology Addition to COLR References cc: U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 NRG Senior Resident Inspector North Anna Power Station Mr. James R. Hall NRG Senior Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B 1-A 11555 Rockville Pike Rockville, Maryland 20852-2738 Ms. K. R. Cotton NRG Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Marcus Harris Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Blvd.

Glen Allen, Virginia 23060 State Health Commissioner Virginia Department of Health James Madison Building - y!h Floor 109 Governor Street Room 730 Richmond, Virginia 23219

Serial No.18-233 LAR - SBLOCA Methodology Addition to COLR References Attachment 1, Page 1 of 8 Attachment 1 Discussion of Technical Specification Change Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

Serial No.18-233 Docket Nos. 50-338/339 Attachment 1, Page 2 of 8 DISCUSSION OF TECHNICAL SPECIFICATIONS CHANGE 1.0

SUMMARY

DESCRIPTION Virginia Electric and Power Company (Dominion Energy Virginia) proposes this license amendment request (LAR) to Facility Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. The proposed Technical Specification (TS) change adds Framatome Topical Report EMF-2328(P)(A), "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based," (Reference 1) as supplemented by the North Anna-specific application report ANP-3467P to the list of methodologies approved for reference in the Core Operating Limits Report (COLR) in Technical Specification 5.6.5.b. Framatome Topical Report EMF-2328(P)(A), as supplemented by the North Anna-specific application report, replaces two existing COLR references for the current Westinghouse Small Break (SB) LOCA Evaluation Model (EM). The added reference identifies the analytical methods used to determine core operating limits for the SBLOCA event described in the North Anna Power Station UFSAR Section 15.3.1.

This LAR also proposes to remove the TS 5.6.5.b reference to BAW-10168P-A (SBLOCA EM) used to analyze the Advanced Mark-BW fuel product since the SBLOCA EM documented in BAW-10168P-A is no longer used to determine core operating limits.

The proposed LAR has been reviewed, and it has been determined that no significant hazards consideration exists as defined in 10 CFR 50.92. In addition, it has been determined that the change qualifies for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9); therefore, no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed TS change.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The design requirements of the existing plant Systems, Structures, and Components (SSCs) are used as inputs to the SBLOCA analysis, with appropriate technical conservatisms applied pursuant to 10 CFR 50 Appendix K. Therefore, the SBLOCA analysis does not directly impact the existing design or configuration of any plant SSCs.

2.2 Current Technical Specification Requirements TS 5.6.5.a directs that core operating limits shall be established prior to each reload cycle. TS 5.6.5.b contains references to the approved analytical methods that are used to determine the core operating limits. The current method listed for SBLOCA is the Westinghouse NOTRUMP EM identified as methodologies 3 and 4 of TS 5.6.5.b.

Serial No.18-233 Docket Nos. 50-338/339 Attachment 1, Page 3 of 8 2.3 Reason for the Proposed Change The reason for the proposed change to the methodologies of TS 5.6.5.b is to add the Framatome Fuel-Vendor Independent SBLOCA (FVI-SBLOCA) analysis for North Anna Units 1 and 2 (Attachment 4) as the methodology used to demonstrate compliance with the requirements of 10 CFR 50.46 and 10 CFR 50 Appendix K.

The current North Anna SBLOCA analysis that uses the Westinghouse NOTRUMP EM (References 3 and 4) shows low margin to the Emergency Core Cooling System (ECCS) performance criteria of 10 CFR 50.46(b)(1-3) and could be challenging for the proposed 10 CFR 50.46(c) rule (Reference 5). The Framatome SBLOCA EM using S-RELAP5 provides additional margin to the current and proposed 10 CFR 50.46 ECCS performance criteria. Supplement 1 of Framatome Topical Report EMF-2328(P)(A),

"PWR Small Break LOCA Evaluation Model, S-RELAP5 Based," includes a sample problem for a Westinghouse 3-loop Nuclear Steam Supply System (NSSS). The North Anna analysis compares well, with respect to transient behavior and analytical results, to the sample analysis that was reviewed and approved by the NRC as part of the submittal package. The improvement in results with the S-RELAP5 methodology relative to the NOTRUMP methodology is consistent with previous evaluations for North Anna as documented in the 2014 Annual Report of ECCS Model Changes (Reference 10).

Dominion Energy Virginia has developed a process to evaluate other fuel design and cladding material properties with respect to the applicability of the FVI-SBLOCA analyses. When validated by this process, the impact of fuel product changes on the SBLOCA analysis is assessed and evaluated for reportability under 10 CFR 50.46.

Dominion Energy Virginia procedures for 10 CFR 50.46 reporting are consistent with NRC Regulatory Issue Summary 2016-04 (Reference 6). Specifically, a fuel product change would be evaluated as a change to the ECCS EM and evaluated for reportability under 10 CFR 50.46.

2.4 Description of Proposed Change TS 5.6.5.b is revised to delete two COLR references for the Westinghouse SBLOCA EM and include a new reference for the Framatome FVI-SBLOCA EM. The proposed reference supports core operating limits, TS 5.6.5.a.7 "Heat Flux Hot Channel Factor" and TS 5.6.5.a.8 "Nuclear Enthalpy Rise Hot Channel Factor."

The following methodologies will be deleted from TS 5.6.5.b:

3. WCAP-10054-P-A, "Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code."
4. WCAP-10079-P-A, "NOTRUMP, A Nodal Transient Small Break and General Network Code."

Serial No.18-233 Docket Nos. 50-338/339 Attachment 1, Page 4 of 8 The following methodology will be added to TS 5.6.5.b:

3. EMF-2328(P)(A), "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based," as supplemented by ANP-3467P, "North Anna Fuel-Vendor Independent Small Break LOCA Analysis." .

The Framatome SBLOCA EM that was used for the Advanced Mark-BW fuel product, currently listed as methodology 15 of TS 5.6.5.b, will be deleted because it is no longer used to determine core operating limits:

15. BAW-10168P-A, "RSG LOCA - BWNT Loss-of-Coolant Accident Evaluation Model for Recirculating Steam Generator Plants," Volume II only (SBLOCA models).

TS 5.6.5.b methodologies 5 through14, 16 and 17 are renumbered as 4 through 15-.

The mark-up of TS 5.6.5.b, reflecting the proposed changes, is provided in Attachment

2. A clean copy of the proposed changes is provided in Attachment 3.

3.0 TECHNICAL EVALUATION

provides a description of the North Anna SBLOCA analysis, which is common to Units 1 and 2. This analysis was performed in accordance with the NRG-approved S-RELAP5 methodology in Framatome Topical Report EMF-2328(P)(A) and Supplement 1(P)(A) (References 1 and 2), which incorporates the appropriate conservatisms prescribed by 10 CFR 50 Appendix K. The application of this Topical Report to North Anna includes one deviation that is discussed in Section 3.2.3 of .

In addition to employing the methodology of EMF-2328(P)(A), there are four notable changes between the existing Westinghouse SBLOCA analysis documented in the UFSAR (Section 15.3.1 and Table 15.3-1) and the Framatome FVI-SBLOCA analysis (as described in Attachment 4):

  • North Anna Units 1 and 2 currently use the Westinghouse 17x17 RFA-2 fuel design with Optimized ZIRLO TM cladding, which was modeled in the current Westinghouse SBLOCA analysis. The Framatome FVI-SBLOCA analysis was performed using representative fuel design and material characteristics.
  • The current North Anna NOTRUMP analysis used an Fa (Heat Flux Hot Channel Factor) of 2.32. The Framatome FVI-SBLOCA analysis was performed using an Fa of 2.5.
  • The current North Anna NOTRUMP analysis employed a K(z) envelope that was used as a multiplier on Fa. The Framatome FVI-SBLOCA analysis assumed a constant K value of 1.0.

Serial No.18-233 Docket Nos. 50-338/339 Attachment 1, Page 5 of 8

  • In the current SBLOCA analysis, the HHSI minimum flow rates assumed operator action to close the pump mini-recirculation valves in a certain time to increase flow to the Reactor Coolant System (RCS) cold legs. The Framatome FVI-SBLOCA analysis includes HHSI minimum flow rates that assume these valves remain open throughout the event. The North Anna Emergency Operating Procedures will continue to include a step to close the valves during a LOCA to maximize HHSI pump flow to the RCS cold legs. However, after implementation of the new SBLOCA analysis, this action will no longer be credited.

The results presented in Attachments 4 and 5 satisfy the acceptance criteria specified by 10 CFR 50.46. The calculated peak clad temperature is less than the 2200°F limit.

The maximum transient local metal water reaction is less than the embrittlement limit of 17%. An assessment of the maximum total oxidation (pre-transient plus transient) was performed and remained below 17% throughout the life of the fuel. The total core wide zirconium water reaction is less than the 1% limit. To summarize, all analytical results satisfy the ECCS performance acceptance criterion of 10 CFR 50.46(b)(1-3).

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements and Criteria The Small Break Loss of Coolant Accident (SBLOCA) analysis satisfies all requirements of 10 CFR 50.46(b)(1-3) and 10 CFR 50 Appendix K, when considered in conjunction with the established North Anna Units 1 and 2 pre-transient oxidation limits. The proposed change meets the current regulatory requirements and does not affect conformance with the General Design Criterion as described in the North Anna Units 1 and 2 UFSAR.

4.2 Precedent Framatome's Supplement 1 to EMF-2328(P)(A) was approved by the NRC in September 2015 (Reference 2). Dominion Energy Nuclear Connecticut, Inc. submitted a LAR for Millstone Power Station Unit 2 to incorporate an updated SBLOCA analysis using the EMF-2328(P)(A) Supplement 1 methodology into plant TS 6.9.1.8.b (References 7 and 8). The associated license amendment was issued by the NRG in September 2016 (Reference 9).

4.3 No Significant Hazards Consideration Determination Analysis The proposed change to Technical Specification (TS) 5.6.5.b adds Framatome Topical Report EMF-2328(P)(A) and its North Anna-specific application report ANP-3467P to the list of approved methodologies for use in determining core operating limits.

Serial No.18-233 Docket Nos. 50-338/339 Attachment 1, Page 6 of 8 Dominion Energy Virginia has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to TS 5.6.5.b permits the use of an NRG-approved methodology for analysis of the Small Break Loss of Coolant Accident (SBLOCA) to determine if North Anna Power Station (NAPS) Units 1 and 2 continue to meet the applicable design and safety analysis acceptance criteria. The proposed change to the list of NRG-approved methodologies in TS 5.6.5.b has no direct impact upon plant operation or configuration. The list of methodologies in TS 5.6.5.b does not impact either the initiation of an accident or the mitigation of its consequences.

The results of the revised SBLOCA transient analysis and existing pre-transient oxidation limits demonstrate that NAPS Units 1 and 2 continue to satisfy the 10 CFR 50.46(b)(1-3) Emergency Core Cooling System performance acceptance criteria using an NRG-approved evaluation model.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change will not create the possibility of a new or different accident due to credible new failure mechanisms, malfunctions, or accident initiators not previously considered. There is no change to the parameters within which the plant is normally operated, and thus, the possibility of a new or different type of accident is not created.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Serial No.18-233 Docket Nos. 50-338/339 Attachment 1, Page 7 of 8 No design basis or safety limits are exceeded or altered by this change.

Approved methodologies have been used to ensure that the plant continues to meet applicable design criteria and safety analysis acceptance criteria.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Dominion Energy Virginia concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion Implementation of the proposed license amendment is safe and will have no effect on plant operation. The proposed change will make no physical modifications to equipment or how equipment is operated or maintained.

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Dominion Energy Virginia has reviewed the proposed license amendment for environmental considerations in accordance with 10 CFR 51.22. As the proposed license amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents

  • that may be released onsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure, the categorical exclusion criteria of 10 CFR 51.22(c)(9) are met. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Framatome Topical Report EMF-2328(P)(A) Revision 0, "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based," March 2001. (Accession No. ML011410383)
2. Framatome Topical Report EMF-2328(P)(A) Revision 0, Supplement 1(P)(A)

Revision 0, "PWR Small Break LOCA Evaluation Model, S-RELAPS Based,"

September 2015. (Accession No. ML12065A390)

Serial No.18-233 Docket Nos. 50-338/339 Attachment 1, Page 8 of 8

3. WCAP-10054-P-A, "Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code."
4. WCAP-10079-P-A, "NOTRUMP, A Nodal Transient Small Break and General Network Code."
5. Staff Requirements Memorandum SECY-16-0033, "Draft Final Rule -

Performance-Based Emergency Core Cooling System Requirements and Related Fuel Cladding Acceptance Criteria (RIN 3150-AH42)," released date April 4, 2016. (Accession No. ML 1523A947)

6. NRC Regulatory Issue Summary 2016-04, "Clarification of 10 CFR 50.46 Reporting Requirements and Recent Issues with Related Guidance not Approved for Use," April 19, 2016. (Accession No. ML15324A296)
7. Correspondence, Dominion (Mark D. Sartain) to U.S. N.R.C. (Document Control Desk), Serial No.15-411, "Dominion Nuclear Connecticut, Inc., Millstone Power Station Unit 2, Proposed License Amendment Request, Small Break Loss of Coolant Accident Reanalysis," September 1, 2015. (Accession No. ML15253A205)
8. Correspondence, Dominion (Mark D. Sartain) to U.S. N.R.C. (Document Control Desk), Serial No.16-070, "Dominion Nuclear Connecticut, Inc., Millstone Power Station Unit 2, Response to Request for Additional Information for Proposed License Amendment Request Regarding Small Break Loss of Coolant Accident Reanalysis (CAC NO. MF6700)," March 24, 2016. (Accession No. ML16096A388)
9. Correspondence, U.S. N.R.C. (Richard V. Guzman) to Dominion (David A.

Heacock), "Millstone Power Station, Unit No. 2 - Issuance of Amendment Re:

Small Break Loss of Coolant Accident Reanalysis (CAC NO. MF6700),"

September 30, 2016. (Accession No. ML16249A001)

10. Correspondence, Dominion (Mark D. Sartain) to U.S. N.R.C. (Document Control Desk), Serial No.15-299, "Dominion Nuclear Connecticut, Inc., Virginia Electric and Power Company, Millstone Power Station Units 2 and 3, North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2, 2014 Annual Report of Emergency Core Cooling System (ECCS) Model Changes Pursuant to the Requirements of 10 CFR 50.46," June 30, 2015. (Accession No. ML15188A346)

Serial No.18-233 LAR - SBLOCA Methodology Addition to COLR References Attachment 2 Marked-up Technical Specification Pages Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

3. EMF-2328(P)(A), "PWR Small Break LOCA Evaluation Model S-RELAP5 Based," as supplemented by ANP-3467P, "North Anna Fuel- Reporting Requirements 5 6 Vendor Independent Small Break LOCA Analysis."
  • 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)
b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
1. VEP-FRD-42-A, "Reload Nuclear Design Methodology."
2. Plant-specific adaptation of WCAP-16009-P-A, "Re~listic Large Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM)," as approved by NRC Safety Evaluation Report dated February 29, 2012.

WCAP-10054-P-A, "Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code."

4. WCAP-10079-P-A, "NOTRUMP, A Nodal Trar,sier,t Small Break aRd ~

Ger,eral --Network Co<:le."

~-5-. WCAP-12610, "VANTAGE+ FUEL ASSEMBLY-REFERENCE CORE REPORT. 11

~-6-:-- VEP-NE-2-A, 11 Statistical DNBR Evaluation Methodology. 11

@}-7-7-..- VEP-NE-1-A, VEPCO Rel axed Power Di stri buti on Control 11 Methodology and Associated FQ Surveillance Technical Specifications. 11

~-&;- WCAP-8745-P-A, Design Bases for Thermal Overpower Delta-T ~

11 and Thermal Overtemperature Delta-T Trip Function. 11

@}-7-9-.- WCAP-14483-A, Generi c Methodology for Expanded Core 11

~

Operating Limits Report."

~r&;- BAW-10227P-A, Evaluation of Advanced Cladding and 11 Structural Material (MS) in PWR Reactor Fuel. 11

~ t t - : - BAW-10199P-A, 11 The BWU Critical Heat FlL!X Correlations."

~ 1-2-. BAW-10170P-A, 11 Stati sti cal Core Design for Mixing Vane Cores. 11 (continued)_

North Anna Units 1 and 2 5.6-3 Amendments 267/248

l Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

b. (continued)

~ - H . EMF-2103 (P) (A), "Realistic Large Break LOCA Methodology for Pressurized Water Reactors."

~ l - 4 . EMF-96-029 (P)(A), "Reactor Analysis System for PWRs."

15. SAW 10168P A, "RSG LOCA
  • BWNT Loss*of*Coolant Aeeident Evalu-atioA Model for Recirculating Steam Generator Plants,"

Volume II only (SBLOCA modets).

DOM-NAF-2-A, "Reactor Core Thermal-Hydraulics Using the VIPRE-D Computer Code," including Appendix A, "Qualification of th~ F-ANP BWU CHF Correlations in the Dominion VIPRE-D Computer Code/' Appendix C, "Qualification 'k_

of the Westinghouse WRB-2M CHF Correlation in the Dominion VIPRE-D Computer Code," and Appendix D, "Qualification of the ABB-NV and WLOP CHF Correlations in the Dominion VIPRE-D Computer Code."

t

~ ti'-: WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO" (Westinghouse Proprietary).

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 PAM Report When a report is required by Condition B of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the cause of the .inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

North Anna Units i" and 2 5.6-4. Amendments 'i.71/z53

Serial No.18-233 LAR - SBLOCA Methodology Addition to COLR References Attachment 3 Proposed Technical Specification Pages Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
1. VEP-FRD-42-A, "Reload Nuclear Design Methodology."
2. Plant-specific adaptation of WCAP-16009-P-A, "Realistic Large Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM)," as approved by NRC Safety Evaluation Report dated February 29, 2012.
3. EMF-2328(P)(A), "PWR Small Break LOCA Evaluation Model S-RELAP5 Based," as supplemented by ANP-3467P, "North Anna Fuel-Vendor Independent Small Break LOCA Analysis."
4. WCAP-12610, "VANTAGE+ FUEL ASSEMBLY-REFERENCE CORE REPORT."
5. VEP-NE-2-A, "Statistical DNBR Evaluation Methodology."
6. VEP-NE-1-A, "VEPCO Relaxed Power Distribution Control Methodology and Associated FQ Surveillance Technical Specifications."
7. WCAP-~745-P-A, "Design Bases for Thermal Overpower Delta-T and Thermal Overtemperature Delta-T Trip Function."
8. WCAP-14483-A, "Generic Methodology for Expanded Core Operating Limits Report."
9. BAW-10227P-A, "Evaluation of Advanced Cladding and Structural Material. (M5) in PWR Reactor Fuel."
10. BAW-10199P-A, "The BWU Critical Heat Flux Correlations."
11. BAW-10170P-A, "Statistical Core Design for Mixing Vane Cores."

(continued)

North Anna Units 1 and 2 5.6-3 Amendments

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

b. (continued)
12. EMF-2103 (P)(A), "Realistic Large Break LOCA Methodology for Pressurized Water Reactors."
13. EMF-96-029 (P)(A), "Reactor Analysis System for PWRs."
14. DOM-NAF-2-A, "Reactor Core Thermal-Hydraulics Using the VIPRE-D Computer Code," including Appendix A, "Qualification of the F-ANP BWU CHF Correlations in the Dominion VIPRE-D Computer Code," Appendix C, "Qualification of the Westinghouse WRB-2M CHF Correlation in the Dominion VIPRE-D Computer Code," and Appendix D, "Qualification of the ABB-NV and WLOP CHF Correlations in the Dominion VIPRE-D Computer Code."
15. WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO" (Westinghouse Proprietary).
c. The core operating limits shall be determined such that-all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 PAM Report When a report is required by Condition B of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

North Anna Units 1 and 2 5.6-4 Amendments

Serial No.18-233 LAR - SBLOCA Methodology Addition to COLR References Attachment 6 Affidavit of Framatome Inc.

Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

Attachment 6 AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is Philip A Opsal. I am Manager, Product Licensing, for Framatome Inc., (formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.
2. I am familiar with the criteria applied by Framatome Inc., to determine whether certain Framatome Inc. information is proprietary. I am familiar with the policies established by Framatome Inc. to ensure the proper application of these criteria.
3. I am familiar with the Framatome Inc. information contained in the following document: Framatome (formally AREVA Inc.) Document 103-3467-000, North Anna Fuel-vendor Independent Small Break LOCA Analysis, ANP-3467P Rev. 0, referred to. herein as "Document."

Information contained in this Document has been classified by Framatome Inc. as proprietary in accordance with the policies established by Framatome Inc. 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 Framatome Inc. 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
  • \,. .:.:?\,}f: f:L~ \,)~~~tm~1 L.,i*w~~,.<*;*tA~ ~: ft:::.,~r ~ L 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 Framatome Inc. to determine whether information should be classified* as proprietary:

(a) The information reveals details of Framatome lnc.'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 Framatome Inc.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome Inc. in product optimization or marketability.

(e) The information is vital to a competitive advantage held by Framatome Inc.,

would be helpful to competitors to Framatome Inc., and would likely cause substantial harm to the competitive position of Framatome Inc.

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

7. In accordance with Framatome lnc.'s policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome Inc. only as required and under suitable agreement providing for nondisclosure and limited use of the information.
8. Framatome lnc.'s 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 ~q day of tv'\O....j I 2018, Heidi Hamilton Elder NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 12/31/2022 Reg. # 7777873 HEIDI HAMILTON ELDER NOTARY PUBLIC REGISTRATION.# 7777873 COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES DECEMBER 31, 2022

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