RS-03-174, Notification of Intent to Perform Analyses Using Vendor Safety Analysis Codes

Notification of Intent to Perform Analyses Using Vendor Safety Analysis Codes

ML032681107
Person / Time
Site:	Dresden, Peach Bottom, Oyster Creek, Limerick, Clinton, Quad Cities, LaSalle
Issue date:	09/19/2003
From:	Jury K AmerGen Energy Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-83-011, RS-03-174
Download: ML032681107 (5)

Text

AmerGen.. Exelonsm An Exelon/British EneTgy Company www.exeloncorp.com AmeTGen Energy Company, LLC 200 Exelon Way Exelon Generation Suite 345 4300 Winfield Road Kennett Square, PA 19348 WaTTenville, IL 605SS RS-03-174 September 19, 2003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-1 8 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units I and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Notification of Intent to Perform Analyses Using Vendor Safety Analysis Codes As requested in Generic Letter (GL) 83-11, Supplement 1, "Licensee Qualification for Performing Safety Analyses," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) are notifying the NRC of our intent to perform safety analyses using computer codes supplied by Framatome Advanced Nuclear Products (FANP) based on NRC-approved methods. The specific steady-state analyses are the reactivity anomaly evaluations and cold shutdown margin evaluations. We have implemented the program discussed in GL 83-11, Supplement 1 as discussed in Attachment 1.

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U. S. Nuclear Regulatory Commission September 19, 2003 Page 2 As discussed in the GL, the licensee should send the NRC a notification of its having followed the guidelines at least three months before the date of its intended first licensing application.

The first application of the FANP methods will occur in support of the startup of LaSalle County Station Unit 1 Cycle 11, currently scheduled to begin in January 2004.

Commitments associated with this letter are contained in Attachment 2.

If you have any questions, please contact Mr. Allan R. Haeger at (630) 657-2807.

Respectfully, Keith R. Jury Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC : Summary of Program Controlling Use of Vendor Methodology : Summary of Commitments cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station

Attachment I Summary of Program Controlling Use of Vendor Methodology Eligibility The NRC has approved the Framatome Advanced Nuclear Products (FANP) method CASMO-4/MICROBURN-B2 (Reference 1). Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) intend to use CASMO-4/MICROBURN-B2 to perform reactivity anomaly evaluations and shutdown margin evaluations.

Application Procedures All applicable procedures were reviewed. Procedures related to the steady-state methods were identified. Revisions to these procedures, including the instructions and restrictions on the use of CASMO-4/MICROBURN-B2 related to reactivity anomaly and cold shutdown margin evaluations, will be completed.

Training and Qualification of Licensee Personnel FANP gave formal training to selected Nuclear Fuels employees. Personnel certification guides associated with the revised procedures will be reviewed and revised as appropriate. The qualification of personnel will be maintained on a task-specific basis.

Comparison Calculations We will perform comparison calculations using CASMO-4IMICROBURN-B2. The results will be compared with startup test results (i.e., cold criticals) and measured flux detector data. The results will also be compared with core monitoring system results. The focus of these comparisons is on parameters that most affect reactivity anomaly and cold shutdown margin such as: 1) hot and cold K-effective behavior with cycle bumup; 2) hot power distribution and associated thermal margin behavior; and 3) one-rod-out shutdown margin predictions.

The results of these comparison calculations will be documented in a calculation notebook maintained in accordance with our quality assurance program.

Quality Assurance and Change Control FANP provides quality assurance and change control for CASMO-4/MICROBURN-B2 using a formal software development record. Once received, software is installed and controlled in accordance with our software quality assurance procedures.

Our software quality assurance program requires that any identified errors that affect the use or operation of software products be documented in our corrective action program.

Currently, the software quality assurance program does not explicitly address informing the vendor of identified errors. By agreement with FANP, errors are reported to FANP.

The requirement to inform the vendor will be added to the software quality assurance program.

Evaluations performed with CASMO-4/MICROBURN-B2 - specifically reactivity anomaly and cold shutdown margin - will be conducted under the control of our quality assurance program.

Page 1 of 2

Attachment I Summary of Program Controlling Use of Vendor Methodology Reference

1. Letter from U. S. NRC to J. F. Mallay (Siemens Power Corporation), "Acceptance for Referencing of Licensing Topical Report EMF-2158(P), Revision 0, 'Siemens Power Corporation Methodology for Boiling Water Reactors: Evaluation and Validation of CASMO-4/MICROBURN-B2,"' dated October 18, 1999 Page 2 of 2

Attachment 2 Summary of Commitments The following commitments are made in this document by Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (Amergen). Any other actions discussed in the submittal represent intended or planned actions. They are described for the NRC's information and are not regulatory commitments.

COMMITMENT COMMITED DATE OR OUTAGE Revisions to procedures, including the instructions and restrictions on Prior to startup of the use of CASMO-4/MICROBURN-B2 for tasks related to reactivity LaSalle County Station, anomaly and cold shutdown margin evaluations, will be completed. Unit 1 Cycle 11, currently scheduled for January 2004 Certification Guides associated with the revised procedures will be Prior to startup of reviewed and revised as appropriate. LaSalle County Station, Unit 1 Cycle 11, currently scheduled for January 2004 We will perform comparison calculations using CASMO- Prior to startup of 4/IMI1CROBURN-B2. The results will be compared with startup test LaSalle County Station, results (i.e., cold criticals) and measured flux detector data. The results Unit I Cycle 11, currently will also be compared with core monitoring system results. The focus scheduled for January of these comparisons is on parameters that most affect reactivity 2004 anomaly and cold shutdown margin such as: 1) hot and cold K-effective behavior with cycle burnup; 2) hot power distribution and associated thermal margin behavior; and 3) one-rod-out shutdown margin predictions.

The results of these comparison calculations will be documented in a calculation notebook maintained in accordance with our quality assurance program.

The software quality assurance program will be revised to require that Prior to startup of EGC/AmerGen notify vendors of errors discovered in vendor-supplied LaSalle County Station, computer codes. Unit I Cycle II, currently scheduled for January 2004 Page 1 of 1

Text

AmerGen.. Exelonsm An Exelon/British EneTgy Company www.exeloncorp.com AmeTGen Energy Company, LLC 200 Exelon Way Exelon Generation Suite 345 4300 Winfield Road Kennett Square, PA 19348 WaTTenville, IL 605SS RS-03-174 September 19, 2003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-1 8 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units I and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Notification of Intent to Perform Analyses Using Vendor Safety Analysis Codes As requested in Generic Letter (GL) 83-11, Supplement 1, "Licensee Qualification for Performing Safety Analyses," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) are notifying the NRC of our intent to perform safety analyses using computer codes supplied by Framatome Advanced Nuclear Products (FANP) based on NRC-approved methods. The specific steady-state analyses are the reactivity anomaly evaluations and cold shutdown margin evaluations. We have implemented the program discussed in GL 83-11, Supplement 1 as discussed in Attachment 1.

0oo 1

U. S. Nuclear Regulatory Commission September 19, 2003 Page 2 As discussed in the GL, the licensee should send the NRC a notification of its having followed the guidelines at least three months before the date of its intended first licensing application.

The first application of the FANP methods will occur in support of the startup of LaSalle County Station Unit 1 Cycle 11, currently scheduled to begin in January 2004.

Commitments associated with this letter are contained in Attachment 2.

If you have any questions, please contact Mr. Allan R. Haeger at (630) 657-2807.

Respectfully, Keith R. Jury Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC : Summary of Program Controlling Use of Vendor Methodology : Summary of Commitments cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station

Attachment I Summary of Program Controlling Use of Vendor Methodology Eligibility The NRC has approved the Framatome Advanced Nuclear Products (FANP) method CASMO-4/MICROBURN-B2 (Reference 1). Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) intend to use CASMO-4/MICROBURN-B2 to perform reactivity anomaly evaluations and shutdown margin evaluations.

Application Procedures All applicable procedures were reviewed. Procedures related to the steady-state methods were identified. Revisions to these procedures, including the instructions and restrictions on the use of CASMO-4/MICROBURN-B2 related to reactivity anomaly and cold shutdown margin evaluations, will be completed.

Training and Qualification of Licensee Personnel FANP gave formal training to selected Nuclear Fuels employees. Personnel certification guides associated with the revised procedures will be reviewed and revised as appropriate. The qualification of personnel will be maintained on a task-specific basis.

Comparison Calculations We will perform comparison calculations using CASMO-4IMICROBURN-B2. The results will be compared with startup test results (i.e., cold criticals) and measured flux detector data. The results will also be compared with core monitoring system results. The focus of these comparisons is on parameters that most affect reactivity anomaly and cold shutdown margin such as: 1) hot and cold K-effective behavior with cycle bumup; 2) hot power distribution and associated thermal margin behavior; and 3) one-rod-out shutdown margin predictions.

The results of these comparison calculations will be documented in a calculation notebook maintained in accordance with our quality assurance program.

Quality Assurance and Change Control FANP provides quality assurance and change control for CASMO-4/MICROBURN-B2 using a formal software development record. Once received, software is installed and controlled in accordance with our software quality assurance procedures.

Our software quality assurance program requires that any identified errors that affect the use or operation of software products be documented in our corrective action program.

Currently, the software quality assurance program does not explicitly address informing the vendor of identified errors. By agreement with FANP, errors are reported to FANP.

The requirement to inform the vendor will be added to the software quality assurance program.

Evaluations performed with CASMO-4/MICROBURN-B2 - specifically reactivity anomaly and cold shutdown margin - will be conducted under the control of our quality assurance program.

Page 1 of 2

Attachment I Summary of Program Controlling Use of Vendor Methodology Reference

1. Letter from U. S. NRC to J. F. Mallay (Siemens Power Corporation), "Acceptance for Referencing of Licensing Topical Report EMF-2158(P), Revision 0, 'Siemens Power Corporation Methodology for Boiling Water Reactors: Evaluation and Validation of CASMO-4/MICROBURN-B2,"' dated October 18, 1999 Page 2 of 2

Attachment 2 Summary of Commitments The following commitments are made in this document by Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (Amergen). Any other actions discussed in the submittal represent intended or planned actions. They are described for the NRC's information and are not regulatory commitments.

COMMITMENT COMMITED DATE OR OUTAGE Revisions to procedures, including the instructions and restrictions on Prior to startup of the use of CASMO-4/MICROBURN-B2 for tasks related to reactivity LaSalle County Station, anomaly and cold shutdown margin evaluations, will be completed. Unit 1 Cycle 11, currently scheduled for January 2004 Certification Guides associated with the revised procedures will be Prior to startup of reviewed and revised as appropriate. LaSalle County Station, Unit 1 Cycle 11, currently scheduled for January 2004 We will perform comparison calculations using CASMO- Prior to startup of 4/IMI1CROBURN-B2. The results will be compared with startup test LaSalle County Station, results (i.e., cold criticals) and measured flux detector data. The results Unit I Cycle 11, currently will also be compared with core monitoring system results. The focus scheduled for January of these comparisons is on parameters that most affect reactivity 2004 anomaly and cold shutdown margin such as: 1) hot and cold K-effective behavior with cycle burnup; 2) hot power distribution and associated thermal margin behavior; and 3) one-rod-out shutdown margin predictions.

The results of these comparison calculations will be documented in a calculation notebook maintained in accordance with our quality assurance program.

The software quality assurance program will be revised to require that Prior to startup of EGC/AmerGen notify vendors of errors discovered in vendor-supplied LaSalle County Station, computer codes. Unit I Cycle II, currently scheduled for January 2004 Page 1 of 1