ML21236A286

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License Amendment Request for Revision 1 of DPC-NE-1007-P, Conditional Exemption of the End-of-Cycle (EOC) Moderator Temperature Coefficient (Mtc) Measurement Methodology
ML21236A286
Person / Time
Site: Mcguire, Catawba, McGuire  Duke Energy icon.png
Issue date: 08/30/2021
From: Bortz D
Duke Energy Carolinas
To:
Office of Nuclear Reactor Regulation
Stone Z
References
Download: ML21236A286 (11)


Text

Duke Energy / NRC Pre-submittal Meeting License Amendment Request for Revision 1 of DPC-NE-1007-P, Conditional Exemption of the End-of-Cycle (EOC) Moderator Temperature Coefficient (MTC) Measurement Methodology Presenter:

David Bortz Catawba and McGuire Nuclear Stations August 30, 2021 Duke Energy - Safety Analysis Models Duke / NRC Meeting

Participants

  • Dave Bortz (Safety Analysis Models)
  • Mike Blom (Director Fuel Management and Design)
  • Jeff Abbott (Manager Safety Analysis Models)
  • Art Zaremba (Fleet Licensing Manager)

Duke Energy - Safety Analysis Models Duke / NRC Meeting 2

Outline

  • Overview of DPC-NE-1007-P
  • EOC MTC Measurement
  • Summary of Changes
  • Motivation for Changes
  • Methodology Revisions
  • Schedule Duke Energy - Safety Analysis Models Duke / NRC Meeting 3

Overview of DPC-NE-1007-P

  • Describes the methodology to conditionally exempt the performance of the EOC MTC measurement at CNS and MNS
  • Technical Specification SR 3.1.3.2 requires verification of the MTC within 7 effective full power days of reaching the equivalent of an equilibrium core boron concentration of 300 ppm at RTP conditions
  • Conditional Exemption based on:

- Core performance criteria being satisfied to demonstrate the reactor core is operating as designed

- Calculation of the EOC 300 ppm RTP MTC accounting for uncertainty and differences between predicted and actual core performance

- Verification the calculated MTC is within the SR 3.1.3.2 limit

  • If any single core performance criterion is not met, an EOC MTC measurement is required Duke Energy - Safety Analysis Models Duke / NRC Meeting 4

EOC MTC Measurement

  • Measurement is an infrequent plant evolution
  • Plant systems operated in a mode or condition not typical of steady state operation
  • Difficult to accurately perform
  • Loss in plant availability (decrease in thermal efficiency during the test)
  • Potential for a reactivity event due to a human performance error or unanticipated equipment issue Duke Energy - Safety Analysis Models Duke / NRC Meeting 5

Summary of Changes

  • Remove the incore tilt performance criterion
  • Modify the power distribution performance criterion to prevent a false positive failure
  • Add an alternative method for determining the most-negative MTC safety analysis limit
  • No Technical Specification changes required Duke Energy - Safety Analysis Models Duke / NRC Meeting 6

Motivation for Methodology Changes

  • Prevent the unnecessary performance of an infrequent plant evolution, reactivity transient and loss of plant efficiency
  • Eliminate a condition where an indeterminate instrument issue causes the power distribution performance criteria to be exceeded
  • Increase margin to the safety analysis most-negative MTC limit to accommodate the introduction of advanced fuel designs and fuel management strategies Duke Energy - Safety Analysis Models Duke / NRC Meeting 7

Incore Tilt Methodology Revision

  • Remove the incore tilt criterion based on experience with using the method

- Frequently challenged

- Responsible for all exemption failures

- Negligibly impacts the magnitude of the MTC

- Power distribution reaction rate criterion available to demonstrate core is operating as designed

  • Incore tilts are not uncommon. Can results from:

- differences in loop flows and inlet temperatures

- Asbuilt fuel and burnable absorber fabrication

- Intentional Duke Energy - Safety Analysis Models Duke / NRC Meeting 8

Power Distribution Methodology Revision

  • Modify the performance criteria to remove the single failure criterion
  • Current criteria is +/- 10% assembly average reaction rate error and remains unchanged
  • Any single location with a reaction rate error greater than 10% absolute results in a failure of the criterion
  • New criterion requires multiple failures
  • Eliminates the condition where a measurement due to an indeterminate instrument issue causes a false positive (criteria exceeded)

Duke Energy - Safety Analysis Models Duke / NRC Meeting 9

SA MTC Limit Methodology Revision

  • Add an alternate approach for calculating the EOC most negative MTC Safety Analysis limit
  • Removes unnecessary conservatism in the method
  • Current method is deterministic
  • New method statistically combines parameters used to calculate the limit
  • Methodology revision increases analysis margin to support higher burnup fuel designs and potential two-year fuel management strategies Duke Energy - Safety Analysis Models Duke / NRC Meeting 10

Schedule

  • Expected submittal - September 2021
  • One year review and approval from NRC acceptance Duke Energy - Safety Analysis Models Duke / NRC Meeting 11