NL-12-1226, License Amendment Request to Allow Nexus Nuclear Data Methodology in the Preparation of the Core Operating Limits Report

License Amendment Request to Allow Nexus Nuclear Data Methodology in the Preparation of the Core Operating Limits Report

ML12227A884
Person / Time
Site:	Farley
Issue date:	08/14/2012
From:	Ajluni M Southern Co, Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-12-1226
Download: ML12227A884 (14)

Text

Mark J. Ajluni, P.E. Southern Nuclear Nuclear Licensing Director Operating Company, Inc.

40 Inverness Center Pa rkway Post Office Box 1295 Birmingham, Al abama 35201 Tel 205.992.7673 Fax 205.992.7885 SOUTHERN'\'

August 14, 2012 COMPANY Docket Nos.: 50-348 NL-12-1226 50-364 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Allow NEXUS Nuclear Data Methodology in the Preparation of the Core Operating Limits Report Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to Facility Operating License Nos. NPF-2 and NPF-8 for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, respectively . This amendment proposes to revise Technical Specification (TS) 5.6.5, "Core Operating Limits Report (COLR)," to reference and allow use of Westinghouse WCAP-16045-P-A, Addendum i-A, "Qualification of the NEXUS Nuclear Data Methodology," (Reference 1 of Enclosure 1) to determine core operating limits .

The non-proprietary version is WCAP-16045-NP-A, Addendum i-A (Reference 2 of Enclosure 1).

The proposed TS change will allow WCAP-16045-P-A, Addendum i-A as an alternative methodology to WCAP-11596-P-A for determining the refueling boron concentration for Limiting Condition of Operation (LCO) 3.9.1 , "Boron Concentration." WCAP-11596-P-A (Reference 6 of Enclosure 1) was approved as the reference methodology for LCO 3.9.1 as part of the issuance of Amendments 151 (Unit 1) and 143 (Unit 2).

Enclosures 1 through 3 provide the Basis for Proposed Change, Markup of Proposed Technical Specifications, and Clean Type Technical Specifications in support of the amendment request.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92 . Pursuant to 10 CFR 51 .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

I U.S. Nuclear Regulatory Commission NL-12-1226 Page 2 SNC requests approval of the proposed license amendment by June 30, 2013.

The proposed changes would be implemented within 60 days of issuance of the amendment.

This letter contains no NRC commitments . If you have any questions, please contact Jack Stringfellow at (205) 992-7037.

Mr. M. J. Ajluni states he is the Nuclear Licensing Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

dbeforemethis I~ <-j- daYOf~ ,2012.

~~~~~~~

My commission expires: / (- D"2 - 20 13 Respectfully submitted, M. J. Ajluni Nuclear Licensing Director MJAlRMJ/lac

Enclosures:

1 . Basis for Proposed Change

2. Markup of Proposed Technical Specification

3. Clean Typed Pages for Technical Specification cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. A. Lynch, Vice President - Farley Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, I\IRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

M. Farley Nuclear Plant - Units 1 and 2 license Amendment to Allow NEXUS Nuclear Data Methodology in the Preparation of the Core Operating Report Enclosure 1 for Proposed Change

Enclosure 1 Basis for Proposed Change Table of Contents

1. Summary

2. Detailed Description

3. Tect-Inical Evaluation

4. Regulatory Evaluation 4.1 Significant Hazards Consideration 4.2 Regulatory Requirements /

5. Environmental Considerations

6. References E1-2

1. Summary Description Southern Nuclear Operating Company (SNC) proposes to the Joseph M.

Farley Nuclear Plant (FNP) Technical Specification Operating Limits Report (COLR)," to reference and allow use of WCAP-i6045-P-A, Addendum i-A, "Qualification of the Methodology" (Reference 1) to determine core proposed TS change will allow WCAP-16045-P-A, Addendum i-A as an  !:>It,>rn*,,ti\J!O methodology to WCAP-11596-P-A for determining concentration for Limiting Condition of (LCO)

Concentration."

2. Detailed Description Technical Specification Section allowed for use in preparation of the proposed TS change will modify to Addendum i-A, as an alternative methodology to preparation of the COLA. TS Section .,;.v.,.,;.",

methodology for determining LCO in the COLA. WCAP-11 determining COLR value Amendments 151 (Unit 1) and 1 amendment will allow WCAP-1 to be used as the methodology for determining the concentration given in the COLA.

The marked-up proposed change to The clean-copy of the proposed

3. Technical Evaluation LCO 3.9.1 states that the boron concentrations of the Coolant System, the refueling canal, and the refueling cavity shall maintained within the limit specified in the COLR during refueling operations. Section that the analytical methods used to determine the core limits shall be previously reviewed and approved by Nuclear Regulatory Commission (NRC). This section further states that WCAP-11 "Qualification of the Phoenix-P/AI\lC Nuclear Design System for Water .... c"u...Tr,r (Reference 5) is the methodology for determining the minimum boron concentration value for LCO 3.9.1.

PHOENIX-P is the neutron transport traditionally section data as input to the Advanced Nodal (ANC) computer code is a standalone neutron probability techniques, and it is approved for use as a C1'"""I/"I,,,

code and as a cross section generation tool for core uranium-fueled pressurized water (PWRs) simulator code system, which performs calculations supplied by a code such as PARAGON or data methodology was developed as a direct

new PARAGON code to be well qualified as a 1"0 rn 0.-." for the PHOENIX-P lattice code, wherever the in NRC-approved methodologies."

The NEXUS methodology is a re-parameterization of the PARAGON nuclear data output and a new reconstruction approach within the ANC core simulator code to simplify the use of for design use. NEXUS has been implemented in the PARAGON/ANC code system for design use. Specifically, the NEXUS methodology been implemented in the parameterization of PARAGON cross for input to ANC and also in ANC to reconstruct those cross nodal conditions. The NEXUS methodology provides a linkage between PARAGON and ANC, establishing a new code system, while still using PARAGON.

ANC code (Le. Version 9) require cross section data which PARAGON neutron transport code. The NEXUS/ANC system is a of the PARAGON/ANC system in that all nuclear data is based on PARAGON only the methods of representing this data in ANC from version of PARAGON/ANC described in Reference methodology will be used as a substitute to the PHOENIX-P when SNC moves to a of ANC (i.e. ANC Version 9).

Addendum 1-A, "Qualification of the NEXUS 0, verifies the accuracy of NEXUS for cross of this topic report, different assembly types were include the following: both Westinghouse and types; U02 fuel and mixed fuel; (IFBA), wet annular burnable (WABA),

k-infinity results from these k-infinities at corresponding I"A.-.f'lltIAn on-.A.... c'1'r"'1'of'l that the NEXUS cross sections are boron concentrations, and power levels ex[)ecrea core calculations.

methodology has been licensed within the PARAGONIANC system. NRC Evaluation Report for the NEXUS nuclear methodology 4) states:

E1-4

"The NRC staff has reviewed the submitted by Westinghouse and determined that the NEXUS/ANC system is replace the PARAGON/ANC code system wherever in NRC-approved methodologies. The NRC staff, furthermore, that NEXUS/ANC is qualified as a stand-alone so long as its use is limited by the provisions listed in Section 4.0 of evaluation."

The provisions listed in Section 4.0 uranium-fueled PWR applications (i.e. not MOX fuel). is acceptable for use for FNP.

The other methodologies used to determine operating limits rof~1rOr~f' COLR will remain applicable with use of values of these operating limits are controlled by only be developed using NRC approved consistent with all applicable plant Updated Final Safety Analysis !:lor'" The f'"",,~c.n accidents will continue to calculated Assumptions used in Safety analysis

4. Regulatory Evaluation 4.1 The proposed amendment would revise the Plant (FNP), Technical Specification Report (COLR)," to reference and allow use of i6045-P-A, Addendum i-A, "Qualification of the Methodology" (Reference 1) to proposed TS change will allow WCAp*1 alternative methodology to WCAP-11 boron concentration for Limiting Condition of "Boron Concentration" by adding a reference to section lists methods which are used to determine core The proposed addition will allow the use of methodology in preparation of the COLA.

approved by the Nuclear Regulatory February 23, 2007. as a standalone so long as limited by the provisions listed in Section 4.0 of the provided in the February 23, 2007 SNC ",,,,y,oOC' the NRC Safety Evaluation.

As required by 10 CFR 50.91 (a), Southern Nuclear (SNG) has evaluated the proposed to criteria in 10 CFR 50.92 and determined do not involve a significant issue of no significant hazards consideration is

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

Response: No The proposed additional TS reference is not an accident initiator.

The assumed accident initiators are not changed by the introduction of the proposed TS reference. Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant increase in the probability of an accident previously evaluated.

The use of the proposed method will not significantly impact the fission product inventory and transport assumptions in the current licensing basis analyses. Therefore, the radiological consequences of an accident previously evaluated will not increase.

The use of the proposed methods will not increase the consequences of an accident because Limiting Conditions for Operation will continue to restrict operation to within the regions that provide acceptable results, and Reactor Protective System trip setpoints will restrict plant transients so that the consequences of accidents will not exceed the safety analysis acceptance criteria.

Therefore, it is concluded that 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 This change does not alter the physical plant or modes of operation. The plant systems will not be operated outside of design limits, no different equipment will be operated, and system interfaces will not change. Thus, the proposed change does not adversely affect the design function or operation of any structures, systems, and components important to safety.

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

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

Response: No E1-6

All safety limit Conditions of Operability given in the COLR will on NRC approved methodologies. ensure the plant is operating in accordance with the Therefore, it is concluded the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above analysis, SNC concludes that the proposed amendment does not involve a significant hazards consideration, under the standards set forth in 10 "Issuance of Amendment,"

and accordingly, a finding of "no hazards consideration" is justified.

Specification 5.6.5 core operating are and Limits Reports prior reload cycle. to determine the core operating limits shall be those reviewed and approved by NRC. WCAP-11596-P-A, which the methodology for the PHOENIX-P/ANC system, is identified as the approved analytical method for determining the LCO 3.9.1 refueling boron concentration given in the COLA.

WCAP-16045-P-A, Addendum i-A, which describes the methodology for NEXUS/ANC system, and approved by NRC as an acceptable methodology. NEXUS/ANC is a replacement to PHOENIX-P/ANC, SNC is seeking of the NEXUS/ANC system to be used as an acceptable methodology to use in preparation of COLA.

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

has evaluated the proposed change and that the proposed does not involve (i) a significant consideration, (ii) a change in the types or a in the amounts of any that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation the proposed meets the eligibility criterion for exclusion set forth in 10

.22(c)(9). Therefore, pursuant 10 .22(b), no environmental

impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6. References

1. WCAP-16045-P-A, Addendum i-A, "Qualification of the NEXUS Nuclear Data Methodology," August 2007.

2. WCAP-16045-NP-A, Addendum 1 "Qualification of the NEXUS Nuclear Data Methodology," August 2007.

3. Safety Evaluation by the Office of Nuclear Reactor Regulation for WCAP 16045-P, Addendum 1, "Qualification of the NEXUS Nuclear Data Methodology" (TAC No. MC9606) (ADAMS Accession Number ML070320398).

4. WCAP-16045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON," August 2004 (ADAMS Accession Number ML042250345).

5. WCAP-11596-P-A, "Qualification of the Phoenix-P/ANC Nuclear Design System for Pressurized Water Reactor " June 1988.

6. NRC letter from Rinaldi to N. Morey (SNC), "Joseph M. Farley Nuclear Plant, Units 1 and 2 Issuance of Amendments (T AC Nos.

MB1906 and MB1907)," '''''",In<:>r4,2001 (ADAMS Accession Number ML013400451 ).

7. Safety Evaluation by the Office of Nuclear Reactor Regulation for WCAP 16045-P, Revision 0, "Qualification of the Two-Dimensional Code PARAGON" (TAC No. MB8040) (ADAMS Accession Number ML040780402) .

E1-8

Joseph M. Farley Plant - Units 1 and 2 License Amendment Request to Allow NEXUS Nuclear Data Methodology in the Preparation of the Operating Limits Report Enclosure 2 Markup of Proposed Technical Specification

Reporting 5.6.5 (continued) 3a. WCAP-1 Volume 1, Revision and Volumes 2 through 5, Revision 1, "Code Qualification Document for Estimate Analysis," March 1998 (W Proprietary).

WCAP-12610-P-A, "Vantage+ Assembly Reference Core Report," April 1 0!1... Proprietary).

(Methodology for LCO 1 - Heat Flux Hot Channel Factor LCO 3.4.1 Pressure, Temperature and Flow Departure from Nucleate Boiling Limits.)

3c. WCAP-16009-P-A, "Realistic Large Break LOCA Methodology Automated Statistical Treatment of Uncertainty Method (ASTRUM)" Nissley, et January (Proprietary).

WCAP-8745-P-A, for the Overpower d T and Thermal Overtemperature Trip Functions," September 1986 (Westing house Proprietary)

(Methodology for Overpower d T and Thermal Overtemperature d T Trip Functions)

WCAP-1 Revision 1, "RCS Flow Verification Elbow at Westinghouse PWRs. (Westinghouse Proprietary)

(Methodology for minimum RCS flow determination using the elbow tap measurement.)

WCAP-11596-P-A, "Qualification of the Phoenix-P/AI\JC Nuclear Design System for Water Cores," June 1 (Methodology for LCO 3.9.1 Boron Concentration.=':!i~~~~

7. WCAP-11397-P-A Thermal Design Procedure," April 1989 (Methodology for LCO 2.1.1 Safety 1 Pressure, Temperature and Flow Departure Boiling Limits.)

Farley Units 1 and 2 5.6-4 Amendment No. :.t-74 (Unit 1)

Amendment No. (Unit 2)

Joseph M. Farley Nuclear Plant - Units 1 and 2 license Amendment to Allow NEXUS Nuclear Data Methodology in the Preparation of the Core Operating limits Report Enclosure 3 Pages for Specification

Reporting Requirements 5.6 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued) 3a. WCAP-12945-P-A, Volume 1, Revision and Volumes 2 through 5, Revision 1, "Code Qualification Document for LOCA Analysis," March 1998 (Yi Proprietary).

3b. WCAP-1 O-P-A, "Vantage+ Fuel Assembly Reference Core

" April 1995 (Yi Proprietary).

(Methodology for LCO 3.2.1 - Flux Hot Channel Factor and LCO 3.4.1-RCS Pressure, Temperature and Flow Departure from Nucleate Boiling Limits.)

3c. WCAP-16009-P-A, "Realistic Large Break LOCA Evaluation Methodology Using Automated Statistical Treatment of Uncertainty Method (ASTRUM)" M.E. Nissley, et aI., January 2005 (Proprietary).

WCAP-8745-P-A, "Design Bases for the Thermal Overpower and Thermal Overtemperature Trip Functions," September 1986 (Westinghouse Proprietary)

(Methodology for Overpower and Thermal Overtemperature iH Trip Functions)

5. WCAP-14750-P-A Revision 1, "RCS Flow Verification Using Elbow Taps at Westinghouse 3-Loop PWRs. (Westinghouse Proprietary)

(Methodology for minimum flow determination using the elbow tap measurement.)

6a. WCAP-11596-P-A, "Qualification of the Phoenix-P/ANC Nuclear Design System for Pressurized Water Reactor Cores," June 1988 6b. WCAP-16045-P-A, Addendum 1 "Qualification of NEXUS Nuclear Methodology," August 2007.

(Methodology for LCO 3.9.1 Boron Concentration. Methods 6a and 6b are direct replacements for each other; therefore, either may be used.)

7. WCAP-11397-P-A "Revised Thermal DeSign Procedure," April 1989 (Methodology for LCO .1-Reactor Core Safety Limits, 3.4.1 RCS Pressure, Temperature and Flow Departure from Nucleate Boiling Limits.)

Farley Units 1 and 2 Amendment No. (Unit 1)

Amendment No. (Unit 2)