RA-16-0042, Response to Request for Additional Information Application to Revise Technical Specifications for Methodology Reports DPC-NF-2010, Revision 3 & DPC-NE-2011-P, Revision 2. Redacted Version Enclosed

Response to Request for Additional Information Application to Revise Technical Specifications for Methodology Reports DPC-NF-2010, Revision 3 & DPC-NE-2011-P, Revision 2. Redacted Version Enclosed

ML16323A102
Person / Time
Site:	Harris, Robinson
Issue date:	11/17/2016
From:	Henderson K Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16323A368	List: RA-16-0042, Response to Request for Additional Information Application to Revise Technical Specifications for Methodology Reports DPC-NF-2010, Revision 3 & DPC-NE-2011-P, Revision 2. Redacted Version Enclosed
References
DPC-NE-2011-P, DPC-NF-2010, RA-16-0042
Download: ML16323A102 (13)

Text

KELVIN HENDERSON Senior Vice President Nuclear Corporate 526 South Church Street, EC-07H Charlotte, NC 28202 980-373-1295 Kelvin.Henderson@duke-energy.com PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENT 3 THIS LETTER IS UNCONTROLLED Serial: RA-16-0042 10 CFR 50.90 November 17, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

SUBJECT:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)

REGARDING APPLICATION TO REVISE TECHNICAL SPECIFICATIONS FOR METHODOLOGY REPORTS DPC-NF-2010, REVISION 3 AND DPC-NE-2011-P, REVISION 2

REFERENCES:

1. Duke Energy letter, Application to Revise Technical Specifications for Methodology Report DPC-NE-1008-P Revision 0, Nuclear Design Methodology Using CASMO-5/SIMULATE-3 for Westinghouse Reactors, dated August 19, 2015 (ADAMS Accession No. ML15236A044)

2. Duke Energy letter, Supplemental Information for License Amendment Request Regarding Methodology Report DPC-NE-1008-P, dated May 4, 2016 (ADAMS Accession No. ML16125A420)

3. NRC letter, Request for Additional Information Regarding Application to Adopt DPC-NF-2010, Revision 3, Nuclear Physics Methodology for Reload Design, and DPC-NE-2011-P, Revision 2, Nuclear Design Methodology Report for Core Operating Limits of Westinghouse Reactors (CAC Nos. MF7693 and MF7694), dated October 26, 2016 (ADAMS Accession No. ML16288A078)

Ladies and Gentlemen:

In Reference 1, Duke Energy Progress, LLC (formerly referred to as 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). In Reference 2, Duke Energy submitted a supplement to the amendment request that superseded Reference 1 in its entirety. In Reference 2, Duke Energy requested, in part, NRC review and approval of DPC-NF-2010, PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENT 3 THIS LETTER IS UNCONTROLLED

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATIACHMENT 3 THIS LETIER IS UNCONTROLLED U.S. Nuclear Regulatory Commission RA-16-0042 Page2 Revision 3, ~Nuclear Physics Methodology for Reload Design,~ and DPC-NE-2011-P, Revision 2, "Nuclear Design Methodology Report for Core Operating Limits of Westinghouse Reactors*

and adoption of these two methodologies into the TS for HNP and RNP. In Reference 3, the NRC requested additional information (RAI) regarding DPC-NF-2010 and DPC-NE-2011-P. provides Duke Energy's response to the Reference 3 RAl's. Attachment 3 contains Information that is proprietary to Duke Energy. In accordance with 10 CFR 2.390, Duke Energy requests that Attachment 3 be withheld from public disclosure. An affidavit Is Included (Attachment 1) attesting to the proprietary nature of Attachment 3. A non-proprietary version of Attachment 3 Is Included in Attachment 2.

This submittal contains no new regulatory commitments. In accordance with 10CFR 50.91, Duke Energy is notifying the states of North Caronna and South Carolina by transmitting a copy of this letter to the designated state officials. 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 November 17, 2016.

Kelvin Henderson Senior Vice President - Nuclear Corporate JBO Attachments: 1. Affidavit of Kelvin Henderson

2. Response to NRC Request for Additional Information (Redacted)

3. Response to NRC Request for Additional Information (Proprietary)

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATIACHMENT 3 THIS LETIER IS UNCONTROLLED

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENT 3 THIS LETTER IS UNCONTROLLED U.S. Nuclear Regulatory Commission RA-16-0042 Page 3 cc: (all with Attachments unless otherwise noted)

C. Haney, Regional Administrator USNRC Region II M. Riches, USNRC Senior Resident Inspector - HNP J. Zeiler, USNRC Senior Resident Inspector - RNP M. C. Barillas, NRR Project Manager - HNP D. J. Galvin, NRR Project Manager - RNP W. L. Cox, III, Section Chief, NC DHSR (Without Attachment 3)

S. E. Jenkins, Manager, Radioactive and Infectious Waste Management Section (SC)

(Without Attachment 3)

A. Wilson, Attorney General (SC) (Without Attachment 3)

A. Gantt, Chief, Bureau of Radiological Health (SC) (Without Attachment 3)

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENT 3 THIS LETTER IS UNCONTROLLED RA-16-0042 Attachment 1 Affidavit of Kelvin Henderson RA-16-0042 Page 1 of 3 AFFIDAVIT of Kelvin Henderson

1. I am Senior Vice President of Nuclear Corporate, Duke Energy Corporation, and as such have the responsibility of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear plant licensing and am authorized to apply for its withholding on behalf of Duke Energy.

2. I am making this affidavit in conformance with the provisions of 10 CFR 2.390 of the regulations of the Nuclear Regulatory Commission (NRC) and in conjunction with Duke Energys application for withholding which accompanies this affidavit.

3. I have knowledge of the criteria used by Duke Energy in designating information as proprietary or confidential. I am familiar with the Duke Energy information contained in Attachment 3 to Duke Energy RAI response letter RA-16-0042 regarding application to revise technical specifications for reports DPC-NF-2010 and DPC-NE-2011-P.

4. Pursuant to the provisions of paragraph (b) (4) of 10 CFR 2.390, the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned by Duke Energy and has been held in confidence by Duke Energy and its consultants.

(ii) The information is of a type that would customarily be held in confidence by Duke Energy. Information is held in confidence if it falls in one or more of the following categories.

(a) The information requested to be withheld reveals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by a vendor or consultant, without a license from Duke Energy, would constitute a competitive economic advantage to that vendor or consultant.

(b) The information requested to be withheld consist of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.),

and the application of the data secures a competitive economic advantage for example by requiring the vendor or consultant to perform test measurements, and process and analyze the measured test data.

(c) Use by a competitor of the information requested to be withheld would reduce the competitors expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation assurance of quality or licensing of a similar product.

(d) The information requested to be withheld reveals cost or price information, production capacities, budget levels or commercial strategies of Duke Energy or its customers or suppliers.

RA-16-0042 Page 2 of 3 (e) The information requested to be withheld reveals aspects of the Duke Energy funded (either wholly or as part of a consortium ) development plans or programs of commercial value to Duke Energy.

(f) The information requested to be withheld consists of patentable ideas.

The information in this submittal is held in confidence for the reasons set forth in paragraphs 4(ii)(a) and 4(ii)(c) above. Rationale for this declaration is the use of this information by Duke Energy provides a competitive advantage to Duke Energy over vendors and consultants, its public disclosure would diminish the informations marketability, and its use by a vendor or consultant would reduce their expenses to duplicate similar information. The information consists of analysis methodology details, analysis results, supporting data, and aspects of development programs, relative to a method of analysis that provides a competitive advantage to Duke Energy.

(iii) The information was transmitted to the NRC in confidence and under the provisions of 10 CFR 2.390, it is to be received in confidence by the NRC.

(iv) The information sought to be protected is not available in public to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld is that which is marked in Attachment 3 to Duke Energy RAI response letter RA-16-0042 regarding application to revise technical specifications for reports DPC-NF-2010 and DPC-NE-2011-P.

This information enables Duke Energy to:

(a) Support license amendment requests for its Harris and Robinson reactors.

(b) Support reload design calculations for Harris and Robinson reactor cores.

(vi) The proprietary information sought to be withheld from public disclosure has substantial commercial value to Duke Energy.

(a) Duke Energy uses this information to reduce vendor and consultant expenses associated with supporting the operation and licensing of nuclear power plants.

(b) Duke Energy can sell the information to nuclear utilities, vendors, and consultants for the purpose of supporting the operation and licensing of nuclear power plants.

(c) The subject information could only be duplicated by competitors at similar expense to that incurred by Duke Energy.

5. Public disclosure of this information is likely to cause harm to Duke Energy because it would allow competitors in the nuclear industry to benefit from the results of a significant development program without requiring a commensurate expense or allowing Duke Energy to recoup a portion of its expenditures or benefit from the sale of the information.

RA-16-0042 Page 3of 3 Kelvin Henderson affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

I declare under penalty of perjlM)' that the foregoing is true and correct.

Executed on November 17, 2016.

RA-16-0042 Attachment 2 Response to NRC Request for Additional Information (Redacted)

Note: Text that is within double brackets (original NRC RAI wording) or brackets with an a,c superscript (Duke Energy response) is proprietary to Duke Energy and has been removed.

RA-16-0042 Page 1 of 5 NRC RAI 1 In DPC-NF-2010 Rev. 3, Duke Energy indicates that the hot zero power (HZP) and hot full power (HFP) isothermal temperature coefficient (ITC) and moderator temperature coefficient (MTC) are used to support startup and operation. The report also states that the ITC may be used to determine the MTC. The MTC is governed by limiting condition for operation (LCO) 3.1.1.3 in the HNP TSs and LCO 3.1.3 in the RNP TSs. Section 10.4.1 of Revision 3 of the DPC-NF-2010 methodology, as proposed in the LAR, added a new means of measuring the ITC. Please clarify how the new method of ITC measurement in Revision 3 differs from the method in Revision 2 of the report.

Duke Energy RAI 1 Response There are two generally industry accepted methods for performing an ITC measurement during startup testing following a refueling outage. The first method is referred to as the slope method, and the second method is referred to as the end-point method. Both methods require the reactor to be stable at hot zero power conditions prior to the start of the test. Stable is implied to mean that primary and secondary system parameters are constant (to the extent possible) such that the initial core reactivity is zero or nearly zero. The slope method is the measurement method used at McGuire and Catawba to measure the ITC. It is also the method described in Revision 2 of DPC-NF-2010. The measurement is started by initiation of a controlled reactor coolant system (RCS) cooldown. During the RCS cooldown, both core reactivity and temperature are measured with the reactivity computer, and a reactivity versus RCS temperature derivative is continuously calculated. This calculation is performed until a specified minimum temperature change has occurred and the standard error of the reactivity versus temperature derivative is converged. This derivative, or slope, is the measured ITC.

Next, a RCS heat-up is initiated and the measurement process is repeated. The slope of the cooldown and heat-up values are averaged to obtain the measured ITC. The end-point method (added in Revision 3 of DPC-NF-2010 to reflect the measurement method currently used at HNP and RNP) is similar to the slope method in that both a cooldown and heat-up of the RCS is performed. This method differs from the slope method in that the ITC is determined using the total reactivity change divided by the temperature change for each portion of the test. The cooldown and heat-up values are similarly averaged to obtain the measured ITC. In both methods, the MTC is calculated by subtracting the predicted Doppler temperature coefficient from the measured ITC.

RA-16-0042 Page 2 of 5 NRC RAI 2 Axial flux difference (AFD), which is a measure of how much power is generated in the top of the core versus the bottom of the core, is a key core power distribution parameter. AFD is controlled in LCO 3.2.1 in the HNP TSs and LCO 3.2.3 in the RNP TSs. One of the primary changes requested in DPC-NE-2011, Revision 2, is a change in the way abnormal xenon distributions are generated in order to define abnormal power shapes and set the AFD operational space provided in the plants TSs. The proposed language clarifies that control rods are only to be inserted at most to the control rod insertion limit. Though this modification appears to make DPC-NE-2011 more consistent to existing approved industry methodologies, the justification provided for the proposed Change 2-3 in the LAR raised several questions about the modifications to the process and whether the AFD limits would be appropriately defined.

a. Please clarify how Duke Energy will ensure that the full AFD operational space is covered by abnormal xenon transients (and thus, abnormal power distributions) over the full range of powers and the length of the cycle. Explain how appropriate coverage of the operating space allowed by the TSs is assured. Describe if there are a variety of xenon transients initiated from a variety of initial conditions.

b. Part of Duke Energys justification for the proposed change in the generation of abnormal xenon distributions is that ((

)) This is illustrated in Figure 1 of the justification of Change 2-3 in the LAR. However, Figure 2 seems to contradict this justification. ((

)) Please explain how a change to the method that is intended to (( )) only ((

)).

c. To justify the operational AFD limits, the analyzed operational space should be slightly wider than the final limits. Please describe how far beyond the limits is the analyzed operational space. Describe if the abnormal xenon distributions include an allowance for the time allowed to be outside of the rod insertion and AFD limits by the TSs.

RA-16-0042 Page 3 of 5 Duke Energy RAI 2.a Response The design xenon transients are selected based on experience to create power distributions that are wider than the operational AFD limits allowed by Technical Specifications. Xenon transients are performed at different times during core life to produce both top and bottom peaked power distributions. [

]a,c Xenon distributions from each xenon transient are evaluated and combined with control rod positions that span the ARO condition to the Technical Specification rod insertion limits to produce the power distributions which are evaluated against thermal limits. Results from the thermal limits calculation are used to establish the Technical Specification AFD limits.

Maneuvering Analysis power distribution calculations are performed for each reload core design.

As previously noted, the design xenon transients were selected to create power distributions that are wider than the Technical Specification AFD limits. For example, the combination of xenon and control rod positions (as constrained by rod insertion limits) used to generate Figure 2 in the technical justification for change 2-3 [

]a,c Duke Energy RAI 2.b Response The power peaking that occurs during transient xenon conditions is based on both the radial and axial xenon concentration. The xenon transient induced from a [

RA-16-0042 Page 4 of 5

]a,c The benefit of the proposed change is realized when Technical Specification AFD limits are established in the range of AFDs where the proposed change provides increased Fq margin. In the example given (Figure 2 for change 2-3), [

]a,c Figure A Fq Dependency on Xenon and Rod Position 2.5 a,c 2.4 Solid lines represent xenon conditions developed 2.3 with control rods initially positioned at 117 SWD.

Dashed lines represent xenon conditions developed 2.2 with control rods initially positioned at 153 SWD.

2.1 2

Fq 1.9 1.8 1.7 225 SWD, Xe Trans. Based on Ctl D at 117 SWD 225 SWD, Xe Trans. Based on Ctl D at 153 SWD 1.6 185 SWD, Xe Trans. Based on Ctl D at 117 SWD 185 SWD, Xe Trans. Based on Ctl D at 153 SWD 1.5 1.4

-35 -30 -25 -20 -15 -10 -5 0 5 10 15 20 25 30 35 Axial Flux Difference (%)

RA-16-0042 Page 5 of 5 Duke Energy RAI 2.c Response The AFD space analyzed in the Maneuvering Analysis is discussed in the response to question 2a. As discussed in this response, design xenon transients are selected to create power distributions that are wider than the operational AFD limits allowed by Technical Specifications.

[

]a,c The xenon distributions generated in the Maneuvering Analysis [

]a,c is also included in the control rod positions considered in the generation of the core power distributions used to establish Technical Specification operating AFD limits. The power distributions generated to establish AFD limits consist of combinations of control rod positions that span the rod insertion limits, and xenon distributions that span the time [

]a,c

[

]a,c