RA-15-0058, Response to Second NRC Request for Additional Information (RAI) Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-2005-P, Revision 5

Response to Second NRC Request for Additional Information (RAI) Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-2005-P, Revision 5

ML15356A315
Person / Time
Site:	Harris, Robinson
Issue date:	12/21/2015
From:	Kapopoulos E Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DPC-NE-2005-P, Rev. 5, RA-15-0058, TAC MF5872, TAC MF5873
Download: ML15356A315 (5)

Text

(_~ DUKE Ernest J. Kapopoulos, Jr.

526 South Church Street ENERGY Charlotte, NC 28202 Mailing Address:

Mail Code ECOlH I P.O. Box 1006 Charlotte, NC 28201-1006 704-382-8162 Serial: RA-15-0058 10 CFR 50.90 December 21, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 I RENEWED LICENSE NO. NPF-63 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23

SUBJECT:

RESPONSE TO SECOND NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING APPLICATION TO REVISE TECHNICAL SPECIFICATIONS FOR METHODOLOGY REPORT DPC-NE-2005-P, REVISION 5

REFERENCES:

1. Duke Energy letter, Application to Revise Technical Specifications for Methodology Report DPC-NE-2005-P, Revision 5, 'Thermal-Hydraulic Statistical Core Design Methodology, dated March 5, 2015 (ADAMS Accession No. ML15075A211)

2. NRC letter, Duke Energy Progress, Inc., for H. B. Robinson Steam Electric Plant, Unit No. 2, and Shearon Harris Nuclear Power Plant, Unit 1 - Request for Additional Information Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-2005-P, Revision 5, "Thermal-Hydraulic Statistical Core Design Methodology (TAC Nos. MF5872 And MF5873), dated August 10, 2015 (ADAMS Accession No. ML15215A651)

3. Duke Energy letter, Response to NRG Request for Additional Information (RA/)

Regarding Application to Revise Technical Specifications for Methodology Report DPC-NE-2005-P, Revision 5, dated September 9, 2015 (ADAMS Accession No. ML15253A680 and ML15253A683)

4. Email from Martha Barillas (USNRC) to Arthur Zaremba, "DRAFT - Harris-Robinson SCD Methodology- 2nd Round RAI v2.docx," dated November 25, 2015.

Ladies and Gentlemen:

In Reference 1, Duke Energy Progress, Inc., referred to henceforth as "Duke Energy,"

submitted a request for an amendment to the Technical Specifications (TS) for Shearon Harris Nuclear Power Plant, Unit 1 (HNP) and H.B. Robinson Steam Electric Plant, Unit No. 2 (RNP).

Specifically, Duke Energy requested NRC review and approval of DPC-NE-2005-P, Thermal-Hydraulic Statistical Core Design Methodology," Revision 5, and adoption of the methodology into the TS for HNP and RNP. In Reference 2, the NRC requested additional information (RAI)

U.S. Nuclear Regulatory Commission RA-15-0058 Page2 regarding this submittal and Reference 3 provided Duke Energy's response to that RAI. In Reference 4, the NRG has provided a second RAI for the subject submittal. Attachment 1 provides Duke Energy's response to the NRG RAI requested in Reference 4.

This submittal contains no new regulatory commitments. In accordance with 1o CFR 50.91, Duke Energy is transmitting a copy of this letter to the designated state officials of North Carolina and South Carolina. Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Manager- Nuclear Fleet Licensing, at 980-373-2062.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 21, 2015.

Sincerely,

~LA--

Ernest J. Kapopoulos, Jr.

Vice President - Operations Support JBD Attachments: 1. Response to NRG Request for Additional Information cc: (all with Attachments unless otherwise noted)

L. D. Wert, Regional Administrator USNRC Region II (Acting)

J. D. Austin, USNRC Senior Resident Inspector - HNP K. M. Ellis, USN RC Senior Resident Inspector - RNP M. C. Barillas, NRR Project Manager - HNP & RNP D. J. Galvin, NRR W. L. Cox, Ill, Section Chief, NC DHSR S. E. Jenkins, Manager, Radioactive and Infectious Waste Management Section (SC)

Attorney General (SC)

A. Gantt, Chief, Bureau of Radiological Health (SC)

RA-15-0058 Attachment 1 Response to NRC Request for Additional Information

NRC Request for Additional Information:

In a letter dated March 5, 2015 1, Duke Energy (Duke), the licensee for Shearon Harris Nuclear Power Plant, Unit 1, (Harris) and H.B. Robinson Steam Electric Plant, Unit 2, (Robinson) requested NRC review and approval of DPC-NE-2005-P, "Thermal-Hydraulic Statistical Core Design Methodology," Revision 5, for application to Robinson and Harris, respectively. In its submittal, Duke requested the adoption of DPC-NE-2005-P, Rev. 5, into the Harris and Robinson technical specifications (TS) Core Operating Limits Report (COLR) reference lists, located in TS 5.6.5.b and TS 6.9.1.6.2, respectively. Duke supplemented the original submittal in a September 9, 2015 letter2 in response to an August 10, 2015 3 NRC letter requesting additional information. The NRC staff determined additional information is needed to complete its review:

SNPB-RAI-6: In its response to SNPB-RAI-4, Duke provided additional detail on the axial power peaking uncertainty, Fz, and axial peak location uncertainty, z, used in the Statistical Core Design (SCD) analysis for Harris and Robinson. These factors are intended to capture uncertainty in the performance of the nuclear design calculations and the uncertainty due to the axial nodalization of the nuclear design codes. The RAI response indicated that values provided in the original submittal were intended to bound the performance and nodalization, respectively, of the CASM0-5/SIMULATE-3 code system documented in DPC-NE-1008-P, "Nuclear Design Methodology Using CASM0-5/SIMULATE-3 for Westinghouse Reactors."

At this time DPC-NE-1008-P has not been reviewed or approved by the NRC and is not in use at either Robinson or Harris. Since the neutronics code system currently in use at both Harris and Robinson has been approved with uncertainties on FQ and FAH and not Fz, explain how the uncertainty of the existing code system currently in use will be verified to be bounded by the uncertainties assumed in the Harris and Robinson SCD analysis, inclusive of the proposed Fz uncertainty being introduced, to assure General Design Criteria 10 requirements are met.

Duke Energy Response to SNPB-RAI-6:

The Duke licensed Statistical Core Design (SCD) DNB methodology to assure General Design Criteria 10 requirements are met for any cycle requires that all uncertainties are bounded for the application of the Statistical Design Limit (SDL). The NRC approved neutronics code used to verify licensing criteria for the cycle provides the nuclear uncertainty factors that must be bounded for the SDL to be applicable. For Duke SCD analyses, both a radial peaking uncertainty, FAH, and an axial peaking uncertainty, Fz, are needed as DNB is a function of both the integrated radial and axial power distribution profiles. The current licensed neutronics code for the cycle design does not include a specific calculation of an Fz uncertainty, therefore the total peaking uncertainty, FQ, will be conservatively assumed to represent the axial uncertainty component. If the FQ uncertainty value for neutronics code used in the cycle design exceeds the 4.5% Fz value currently assumed in the Harris and Robinson appendices, the larger uncertainty will be analyzed as per the requirements of Table 7 of DPC-NE-2005-P.

For example, analysis with the existing licensed code system currently in use for Robinson would require the assumption of a Fz uncertainty of 5% since only FAH and FQ uncertainties are calculated. Analysis that 1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML15075A211.

2 ADAMS Accession No. ML15253A680 (non-proprietary) and ML15253A683 (proprietary) 3 ADAMS Accession No. ML15215A651

propagates the higher uncertainty for Fz would result in a calculated SDL increase of 0.009 for the limiting statepoint. This would require an additional penalty for cycle DNB analyses with the existing neutronic licensed code system currently in use that also employs the Duke SCD method as per Table 7.

This is only an example provided to illustrate the concept. If an uncertainty is determined in future cycles higher than the value currently assumed in the Harris I Robinson appendices, a specific calculation would be performed to determine the effect on the SDL.