RS-16-016, Supplement to Request for License Amendment Regarding Transition to Areva Fuel

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Supplement to Request for License Amendment Regarding Transition to Areva Fuel
ML16020A232
Person / Time
Site: Dresden, Quad Cities  Constellation icon.png
Issue date: 01/20/2016
From: Simpson P
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-16-016
Download: ML16020A232 (3)


Text

,. 300 W 1 .~ C1 Ro~r*

W 11 er vli*e _ GO'i.i'i Exelon Generation 1)30 6Sl 2000 c*11c 10 CFR 50.90 RS-16-016 January 20, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPA-25 NRG Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPA-29 and DPR-30 NRG Docket Nos. 50-254 and 50-265

Subject:

Supplement to Request for License Amendment Regarding Transition to AREVA Fuel

Reference:

Letter from Patrick A. Simpson (Exelon Generation Company, LLC) to U. S.

NRG, "Request for License Amendment Regarding Transition to AREVA Fuel,"

dated February 6, 2015 In the referenced letter, Exelon Generation Company, LLC (EGG) requested an amendment to Renewed Facility Operating License Nos. DPR-19 and DPA-25 for Dresden Nuclear Power Station (DNPS) Units 2 and 3, and Renewed Facility Operating License Nos. DPA-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS) Units 1 and 2. The proposed change supports the transition from Westinghouse SVEA-96 Optima2 (Optima2) fuel to AREVA ATRIUM 10XM fuel at DNPS and QCNPS. Specifically, EGG proposes to revise Technical Specification (TS) 5.6.5, "Core Operating Limits Report (COLA),* paragraph b, to delete no longer used methodologies and to add the AREVA analysis methodologies to the list of approved methods to be used in determining the core operating limits in the COLA. Also, in support of the planned transition to AREVA ATRIUM 10XM fuel, EGG proposes to revise DNPS and QCNPS TS 3.2.3, "Linear Heat Generation Rate (LHGR)," and TS 3.7.7, "The Main Turbine Bypass System."

Subsequent to submittal of the referenced letter, AREVA, Inc. identified two issues associated with the MICROBURN-82 computer code. One issue is associated with the potential hydraulic non-convergence in MICROBURN-82 at low flow conditions and the second issue is associated with the behavior of the MICROBURN-82 void quality correlation for low flow conditions. Both

January 20, 2016 U.S. Nuclear Regulatory Commission Page2 of these issues have been documented and evaluated in the AREVA corrective action program.

These corrective action program evaluations were performed to determine the impact of these errors on the analyses submitted in support of the DNPS and QCNPS referenced license amendment request.

Based on these evaluations, AREVA has concluded that the operating limits provided in the referenced letter continue to be supported. It was noted however, that some non-limiting analyses were adversely affected by the error corrections and some limiting analysis results actually improved as a result of the error corrections.

Since both issues are only a concern at low flow conditions, the potentially affected analyses include the following:

  • Stability Option Ill Delta Over Initial MCPR Versus Oscillation Magnitude (DIVOM) calculations
  • MICROBURN-B2/STAIF calculations for Backup Stability Protection (BSP)
  • Oscillation Power Range Monitor (OPRM) Setpoint Analyses
  • Flow Runup Analyses including both flow-dependent Linear Heat Generation Rate adjustment factors (LHGRFAC1) and flow-dependent MCPR operating limits (MCPR1)
  • Transients, infrequent events, or design basis accidents where MICROBURN-B2 is used to set the initial core conditions for low flows AREVA has determined that based on their evaluation of all the analyses supporting the referenced amendment request for DNPS and QCNPS, only one report, ANP-3361 (P), "Reload Safety Analysis Report," contains information that would change with the correction of the MICROBURN-B2 errors. This report (Attachment 12 to the referenced letter) provides the results of a reload safety analysis for a representative cycle design. AREVA prepared this report using a representative transition core in support of the DNPS and QCNPS transition to ATRIUM 10XM fuel to demonstrate the applicability of the AREVA methodologies at both stations (i.e., DNPS and QCNPS). The identified errors in the MICROBURN-B2 code will be corrected prior to the cycle specific licensing calculations performed for the first reload of ATRIUM 10XM fuel in DNPS and QCNPS.

In summary, AREVA has completed evaluations of the impact of the MICROBURN-B2 errors on the proposed transition to ATRIUM 10XM fuel at DNPS and QCNPS. It was determined that the operating limits for a representative transition core provided in the referenced letter continue to be supported.

In accordance with 10 CFR 50.91(b), EGC is notifying the State of Illinois of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 to the referenced letter. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant

January 20, 2016 U.S. Nuclear Regulatory Commission Page 3 hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this letter. Should you have any questions related to this letter, please contact Mr. Timothy A Byam at (630) 657-2818.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 20th day of January 2016.

Patrick R. Simpson Manager - Licensing cc: Regional Administrator- NRC Region Ill NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector- Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

,. 300 W 1 .~ C1 Ro~r*

W 11 er vli*e _ GO'i.i'i Exelon Generation 1)30 6Sl 2000 c*11c 10 CFR 50.90 RS-16-016 January 20, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPA-25 NRG Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPA-29 and DPR-30 NRG Docket Nos. 50-254 and 50-265

Subject:

Supplement to Request for License Amendment Regarding Transition to AREVA Fuel

Reference:

Letter from Patrick A. Simpson (Exelon Generation Company, LLC) to U. S.

NRG, "Request for License Amendment Regarding Transition to AREVA Fuel,"

dated February 6, 2015 In the referenced letter, Exelon Generation Company, LLC (EGG) requested an amendment to Renewed Facility Operating License Nos. DPR-19 and DPA-25 for Dresden Nuclear Power Station (DNPS) Units 2 and 3, and Renewed Facility Operating License Nos. DPA-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS) Units 1 and 2. The proposed change supports the transition from Westinghouse SVEA-96 Optima2 (Optima2) fuel to AREVA ATRIUM 10XM fuel at DNPS and QCNPS. Specifically, EGG proposes to revise Technical Specification (TS) 5.6.5, "Core Operating Limits Report (COLA),* paragraph b, to delete no longer used methodologies and to add the AREVA analysis methodologies to the list of approved methods to be used in determining the core operating limits in the COLA. Also, in support of the planned transition to AREVA ATRIUM 10XM fuel, EGG proposes to revise DNPS and QCNPS TS 3.2.3, "Linear Heat Generation Rate (LHGR)," and TS 3.7.7, "The Main Turbine Bypass System."

Subsequent to submittal of the referenced letter, AREVA, Inc. identified two issues associated with the MICROBURN-82 computer code. One issue is associated with the potential hydraulic non-convergence in MICROBURN-82 at low flow conditions and the second issue is associated with the behavior of the MICROBURN-82 void quality correlation for low flow conditions. Both

January 20, 2016 U.S. Nuclear Regulatory Commission Page2 of these issues have been documented and evaluated in the AREVA corrective action program.

These corrective action program evaluations were performed to determine the impact of these errors on the analyses submitted in support of the DNPS and QCNPS referenced license amendment request.

Based on these evaluations, AREVA has concluded that the operating limits provided in the referenced letter continue to be supported. It was noted however, that some non-limiting analyses were adversely affected by the error corrections and some limiting analysis results actually improved as a result of the error corrections.

Since both issues are only a concern at low flow conditions, the potentially affected analyses include the following:

  • Stability Option Ill Delta Over Initial MCPR Versus Oscillation Magnitude (DIVOM) calculations
  • MICROBURN-B2/STAIF calculations for Backup Stability Protection (BSP)
  • Oscillation Power Range Monitor (OPRM) Setpoint Analyses
  • Flow Runup Analyses including both flow-dependent Linear Heat Generation Rate adjustment factors (LHGRFAC1) and flow-dependent MCPR operating limits (MCPR1)
  • Transients, infrequent events, or design basis accidents where MICROBURN-B2 is used to set the initial core conditions for low flows AREVA has determined that based on their evaluation of all the analyses supporting the referenced amendment request for DNPS and QCNPS, only one report, ANP-3361 (P), "Reload Safety Analysis Report," contains information that would change with the correction of the MICROBURN-B2 errors. This report (Attachment 12 to the referenced letter) provides the results of a reload safety analysis for a representative cycle design. AREVA prepared this report using a representative transition core in support of the DNPS and QCNPS transition to ATRIUM 10XM fuel to demonstrate the applicability of the AREVA methodologies at both stations (i.e., DNPS and QCNPS). The identified errors in the MICROBURN-B2 code will be corrected prior to the cycle specific licensing calculations performed for the first reload of ATRIUM 10XM fuel in DNPS and QCNPS.

In summary, AREVA has completed evaluations of the impact of the MICROBURN-B2 errors on the proposed transition to ATRIUM 10XM fuel at DNPS and QCNPS. It was determined that the operating limits for a representative transition core provided in the referenced letter continue to be supported.

In accordance with 10 CFR 50.91(b), EGC is notifying the State of Illinois of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 to the referenced letter. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant

January 20, 2016 U.S. Nuclear Regulatory Commission Page 3 hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this letter. Should you have any questions related to this letter, please contact Mr. Timothy A Byam at (630) 657-2818.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 20th day of January 2016.

Patrick R. Simpson Manager - Licensing cc: Regional Administrator- NRC Region Ill NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector- Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety