NL-13-0628, Follow-Up on the Response to Request for Additional Information Concerning the Allowance for Nexus Methodology in the Preparation of the Core Operating Limits Report

Follow-Up on the Response to Request for Additional Information Concerning the Allowance for Nexus Methodology in the Preparation of the Core Operating Limits Report

ML13112A154
Person / Time
Site:	Farley
Issue date:	04/19/2013
From:	Pierce C Southern Nuclear Operating Co, Southern Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-13-0628
Download: ML13112A154 (9)

Text

Charles R. Pierce Southern Nuclear Reg ul atory Affairs Director Operating Company. Inc.

40 Inverness Center Parkway Post Office Box 1295 Bi rmingham, Alabama 35201 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN ' \

COMPANY April 19, 2013 Docket Nos.: 50-348 NL-13-0628 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Follow-Up on the Response to Request for Additional Information Concerning The Allowance for NEXUS Methodology in the Preparation of the Core Operating Limits Report

References:

1. SNC letter NL-12-1226 to the NRC , Joseph M. Farley Nuclear Plant Units 1 and 2 License Amendment Request to Allow NEXUS Nuclear Oata Methodology in the Preparation of the Core Operating Limits Report, dated August 14, 2012 (ML12227A884)

2. t\IRC letter to SNC, Joseph M. Farley Nuclear Plant, Units 1 And 2 Request For Additional Information Concerning The Allowance For NEXUS Methodology In The Preparation of the Core Operating Limits Report (Tac Nos. ME9244 and ME9245), dated January 30,2013 (ML13025A298)

3. SNC letter NL-13-0264 to the NRC, Joseph M. Farley Nuclear Plant Response to Request for Additional Information Concerning the Allowance for NEXUS Methodology in the Preparation of the Core Operating Limits Report, dated February 28, 2013 (ML13063A291)

Ladies and Gentlemen :

By letter dated August 14, 2012, Southern Nuclear Operating Company (SNC),

submitted a license amendment request for the Joseph M. Farley Nuclear Plant (FNP) (Reference 1). The proposed amendments would revise Technical Specification (TS) 5.6.5, "Core Operating Limits Report (COLR)," to reference and allow use of Westinghouse WCAP-16045-P-A, Addendum 1-A, "Qualification of the NEXUS l\Juclear Data Methodology," to determine core operating limits.

The U.S. Nuclear Regulatory Commission staff (NRC) issued a Request for Additional Information (RAI) by letter dated January 30, 2013 (Reference 2).

SNC responded to the RAI questions by letter dated February 28, 2013 (Reference 3) .

U.S. Nuclear Regulatory Commission NL-13-0628 Page 2 An NRC public meeting was held on March 7, 2013 to discuss the SNC response to the RAI questions. During this public meeting, it was mutually agreed that SNC would revise the proposed TS revision to further clarify their intention of the analytical methods used to determine core operating limits by adding WCAP 16045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON,"

to TS 5.6.5. contains the revised markup of the proposed TS per the public meeting. Enclosure 2 contains the revised clean typed TS. Please note that SNC's intention in the original submittal (Reference 1) was always to use the PARAGON method (WCAP-16045-P-A) with the NEXUS methodology. Adding WCAP-16045-P-A represents an editorial modification from what was proposed in the original submittal (Reference 1). As such, the "Significant Hazards Consideration" in the original submittal remains applicable.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. C. R. Pierce states he is Regulatory Affairs 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.

Respectfully submitted, C. R. Pierce Regulatory Affairs Director CPRlRMJ/md Sworn to and subscribed before me this /9-dl day of_.:....:#+,t?---'I-_",---'-i_*_ _ _, 2013.

/1JO.v.LL Notary Public

&a i/ Ii. f/;vb My commission expires: Iu J t /~ ~ 0 If

Regulatory Commission cc:

Kuczynski, Chairman, G. Bost, Executive Vice Nuclear Officer A. Lynch, Vice President - Farley L. Ivey, Vice President - Regulatory Affairs J. Adams, Vice President - Operations CFA04.054

Joseph M. Farley Nuclear Plant Follow-Up on the Response to Request for Additional Information Concerning The Allowance for NEXUS Methodology in the Preparation of the Core Operating Limits Report Enclosure 1 Technical Specifications Marked-up Pages

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

WCAP-1 Volume 1, Revision 2, and Volumes 2 through 5, Revision 1, "Code Qualification Document for LOCA

" March 1998 Proprietary).

3b. WCAP-12610-P-A, "Vantage+ Fuel Assembly Reference Report," April 1 0!Y... Proprietary).

(Methodology for LCO 3.2.1 - Flux Hot Factor and 1 Pressure, Temperature and Flow Departure from Nucleate Boiling Limits.)

WCAP-16009-P-A, "Realistic LOCA Evaluation Methodology Using Automated Treatment Uncertainty Method (ASTRUM)" M.E. et aI., January (Proprietary).

4. WCAP-8745-P-A, for the Overpower and Thermal Overtemperature 8 T Trip Functions," September 1986 (Westinghouse Proprietary)

(Methodology for Overpower and Thermal Overtemperature Functions)

WCAP-1 Revision 1, "RCS Flow Verification Taps at 3-Loop PWRs. (Westinghouse Proprietary)

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

1 "Qualification of Phoenix-P/ANC Design ..... ""T""rY\ for Pressurized Water Reactor Cores," June 1988 (Methodology for LCO 1 - Boron Concentration.)

7. WCAP-11397-P-A Thermal Procedure," April 1 Core Safety Limits, 1 Flow Departure Nucleate Boiling Limits.)

---

----------.--------------------------NOTE ------------------------------------

Commencing Unit 1 26 and Unit 2 Cycle methods 6b and 6c shall be used in lieu of method 6a.

6b. "Qualification the Two-Dimensional Code " August 2004 (continued) 6c. WCAP-16045-P-A, Addendum i-A, "Qualification of the NEXUS mendment No. (Unit 1)

~__N_u_c_le_ar_D_a_t_a______~~'_'A_u~g~u_st_2_0_07 ______________________~mendmentNo. (Unit 2)

M. Farley Nuclear Follow-Up on to Request for Information The Allowance for NEXUS Methodology in the Preparation of the Core Operating Limits Report Enclosure 2 Technical Specifications Clean Typed Pages

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

3b. WCAP-12610-P-A, "Vantage+ Fuel Assembly Reference Core Report," April 1995 (W Proprietary).

(Methodology for LCO 3.2.1 - Heat 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).

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

(Methodology for Overpower ~ T and Thermal Overtemperature ~T 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 RCS 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 Commencing Unit 1 Cycle 26 and Unit 2 Cycle 24, methods 6b and 6c shall be used in lieu of method 6a.

6b. WCAP-16045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON," August 2004 6c. WCAP-16045-P-A, Addendum 1-A, "Qualification of the NEXUS Nuclear Data Methodology," August 2007 (Methodology for LCO 3.9.1 - Boron Concentration.)

(continued)

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

Amendment No. (Unit 2)

Reporting Requirements 5.6

7. WCAP-11397 -P-A "Revised Thermal n urr,,,,,,,... " April 1989 (Methodology LCO 1.1 Safety Limits, LCO 3.4.1 Pressure, Temperature and Flow Departure from Nucleate Boiling Limits.)

c. The core operating limits shall determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic Emergency Core Cooling Systems lim nuclear limits such as SDM, transient analysis limits, and accident analysis limits) the safety analysis are met.

d. The COLR. including midcycle revisions or shall provided upon issuance for reload to the NRC.

a. coolant temperature including heatup and cooldown rates, shall be established and documented in the for LCO

b. The analytical methods used to determine pressure and limits be previously reviewed and approved by NRC, specifically described in NRC letters March 31, 1 April 3, 1998.

c. The shall be provided to the NRC upon issuance for each reactor fluence period and for revision or supplement thereto.

5.6.7 If an individual emergency diesel generator (EDG) experiences four or more valid failures in the these shall be within 30 on EDG failures include a description of the underlying causes, per the Diesel Generator Reliability Monitoring Farley U 1 and 2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Reporting uirements When a report is B or F of LCO Monitoring (PAM) II a report shall be submitted within following 14 days. the preplanned alternate method monitoring, the cause of and the plans and schedule restoring the instrumentation of the Function to OPERABLE status.

Deleted 10 A report shall be submitted within 180 into 4 following completion of an in accordance with the Specification The report shall include:

a. The scope of on each SG,

b. Active degradation found,

c. Nondestructive techniques utilized for each degradation mechanism, Location, orientation (if and measured sizes (if available) of service induced indications,

e. Number of inspection outage for degradation mechanism,

f. Total number and to and results of condition including the results of tube pulls and in-situ testing.

11 The NRC shall be notified if the AAC source is out of service for greater than 10 days.

Units 1 and 2 Amendment No. (Unit 1)

Amendment No. (Unit 2)