ML17352B000

Application for Amends to Licenses DPR-31 & DPR-41,revising TS 6.9.1.7, COLR, Re Implementation of FPL Nuclear Physics Methodology for Calculations of COLR Parameters.Fpl Topical Rept NF-TR-95-01, Nuclear Physics Methodology... Encl

ML17352B000
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	01/17/1995
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17352B002	List: ML17352B000 ML17352B004 ML17352B005
References
L-95-006, L-95-6, NUDOCS 9501270171
Download: ML17352B000 (16)

Text

PRIDRI'ZY ACCELERATED RIDS PROCESSING) 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 9501270171 DOC. DATE: 95/01/17 NOTARIZED: YES DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power- and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 p

50-389 St. Lucie Plant, Unit 2, Florida Powe. & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power & Light Co. R RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to licenses DPR-31,DPR-41,DPR-67 &

NPF-16 to TS re implementation of FPL nuclear physics 0 methodology for calculations of core operating limits rept parameters.

DISTRIBUTION CODE: ADO ID COPIES RECEIVED: LTR ) ENCL / SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 CROTEAU,R 1 1 NORRIS,J 1 1 INTERNAL: ACRS 6 6 CENTEEb 01 1 1 NRR/DRCH/HICB 1 1 NRR/DS SA/S PLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

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N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCU~IENT CONTROL DESK, ROOM PI-37 (EXT. S04-2083 > TO ELI~IINATEYOUR NAME PROD!

DISTRIBUTION LISTS I:OR DOCUMENTS YOU DON"I'L'ED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 17

' ggwlk>995 L-95-006 10 CFR 550.36 10 CFR 550.90 U ~ S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DE C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendments Implementation of FPL Nuclear Physics Methodology for Calculations of Core 0 eratin Limits Re ort Parameters In accordance with Title 10 Code of Federal Regulations 550.90 (10 CFR 550.90), Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-31 and DPR-41 be amended to modify Turkey Point Units,3 and 4 Technical Specification (TS) 6.9.1.7, Core Operating Limits Report (COLR). Enclosed as Attachment 4 of this submittal is FPL's Topical Report NF-TR-95-01 entitled "Nuclear Physics Methodology for Reload Design of Turkey Point & St.

Lucie Nuclear Plants." The proposed revision to the Technical Specifications includes a reference to NF-TR-95-01 as the topical report which demonstrates FPL's proficiency in calculating the COLR parameters. The COLR was added to the Turkey Point Unit's 3 and 4 Technical Specifications by Amendments 156 and 150, respectively. By Amendments 156/150, the parameters of Axial Flux Difference Limits were added to Turkey Point's COLR. By amendment 167/161, the parameters of Control Rod Insertion Limits and Heat Flux Hot Channel Factors were added to Turkey Point's COLR.

A description of the amendments request is provided in Attachment 1.

FPL has determined that the proposed license amendments do not involve a significant hazard pursuant to 10 CFR 550.92. The no significant hazards determination in support of the proposed Technical Specification change is provided in Attachment 2. Attachment 3 provides the proposed Technical Specification changes. Attachment 4 provides NF-TR-95-01 Topical Report which demonstrates FPL's ability to perform certain reload core design calculations.

In accordance with 10 CFR 550.91(b)(1), a copy of these proposed license amendments are being forwarded to the State Designee for the State of Florida.

The proposed amendments have been reviewed by the Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board.

Should there be any questions on this request, please contact us.

Very truly yours, T. F ~ Plunkett Vice President Turkey Point Plant j" 4 w.~

$ Lh .

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<5pi270i7i ADOC p5000250 PDR PDR an FPL Group company, P

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Z,-95-006 Page 2 Attachments TFP/RJT/rt CC: S. DE Ebneter, Regional Administrator, Region II, USNRC T. P. Johnson, Senior Resident Inspector, USNRC, Turkey Point W. A. Passetti, Florida Department of Health and Rehabilitative Services

STATE OF FLORIDA )

) ss.

COUNTY OF DADE )

T. F. Plunkett being first duly sworn, deposes and says:

That he is Vice President Turke Point Nuclear Plant, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.

T. F. Plunkett Subscribed and sworn to before me this

~/day of 1995.

Name of Notary Public (Type or Print)

NOTARY PUBLIC, in and for the Coun o Dade, State of Florida CHERYL A. KELLY IAY COMMISSICN I CC 223781

~f! EXPIRES: Segeebsr Ve 199S Commission expires '7Q 4 StmdtNIlbru NOINy Pubfe Oxkrwrltsra My Commission No.

T. F. Plunkett is personally known to me.

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4 I\ y~ y yl~h)

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ATTACHMENT 1 DESCRIPTION OF AMENDMENTS REQUEST

L-95-006 Page 1 of 5 DESCRIPTION OF AMENDMENTS RE VEST Introduction Generic Letter (GL) 88-16, dated October 4, 1988, was issued to encourage licensees to amend the Technical Specifications related to cycle-specific parameters. The generic letter provided guidance for relocation of certain cycle-dependent core operating limits fzom a licensee's Technical Specifications to the Core Operating Limits Report (COLR) . This would allow changes to the values of the core operating limits without prior NRC approval (i.e., license amendment),

as long as an NRC approved methodology for the parameter limit calculation is followed. In accordance with GL 88-16, FPL submitted and received NRC approval for two proposed license amendments to relocate selected parameters from the Turkey Point Technical Specifications to the COLR. These submittals are as follows:

(a) By letter L-93-092, dated April 23, 1993, FPL proposed revising the Turkey Point Technical Specifications by (a) changing the Axial Flux Distribution (AFD) control methodology in Technical Specification 3/4.2.1 from Constant Axial Offset Control (CAOC) to Relaxed Axial Offset Control (RAOC) and (b) relocating the AFD cycle-specific core opezating limits from the Technical Specifications to the COLR. The NRC approved this submittal by issuing Amendments 156 and 150 to Turkey Point Units 3 and 4 Technical Specifications'b)

By letter L-94-128, dated July 19, 1994, FPL proposed revising the Turkey Point Technical Specifications by relocating (a) TS Figure 3.1-2, Rod Bank Insertion Limits versus Thermal Power curve, and (b) TS Figure 3.2-2, K(Z)

Normalized F()(Z) as a Function of Core Height curve, from the Technical Specifications to the COLR. The NRC approved this submittal by issuing Amendments 167 and 161 to Turkey Point Units 3 and 4 Technical Specifications.

GL 83-11, dated February 8, 1983, was issued to encourage licensees to perform their own safety analyses and describes the current NRC practices regarding licensee qualification for performing safety analyses. The proposed Technical Specification change provides documentation to demonstrate FPL's capabilities to use NRC approved methodology to calculate the COLR parameters.

In accordance with the recommendations of GL 88-16 and 83-11, and the safety evaluations which approved Amendments 156/150 and 167/161 for Turkey Point Units 3 and 4, FPL proposes to revise TS 6.9.1.7 to include a reference to FPL's Topical Report NF-TR-95-01, as the documentation to demonstrate FPL's proficiency in performing certain reload design calculations.

L-95-006 Page 2 of 5 Discussion GL 83-11, entitled "Licensee Qualification For Performing Safety Analyses In Support Of Licensing Actions", describes the current NRC practice regarding licensee qualification for performing safety analyses in support of licensing actions. The generic letter encourages utilities to perform their own safety analyses since doing so significantly improves their understanding of plant behavior. GL 83-11 makes the following statements:

...our review focuses primarily on the competence of the licensee and vendors regarding quality assurance practices, the technical competence of the licensees and vendors with respect to their ability to set up an input deck, execute a code, and properly interpret the results must also be assured. NRR [NRC Office of Nuclear Reactor Regulation] obtains this assurance by reviewing the code verification information submitted by the licensee or vendor. The information we look for includes comparisons performed by the user of the code results to experimental data, plant operational data, or other benchmazked analyses.

each licensee or vendor who intends to use a safety analysis computer code to support licensing actions should demonstrate their proficiency in using the code by submitting code verification performed by them..."

Additional information supporting the NRC's view of the development of licensees analytical capabilities was presented by Larry Phillips (USNRC Reactor Systems Branch) at the March 21-24, 1993, USCEA Fuel Cycle Conference held in Dallas, Texas. At this conference Mr.

Phillips made the following statements as detailed in the meeting transcripts:

"Foz safety evaluations that result in actions that require NRC prior approval, it is necessary foz NRC to conclude that the codes and methods used to reach a safety decision are acceptable before acceptable.

it can be concluded that the proposed action is In order to avoid repetition of reviews and to better segregate and document the methodology part of a safety evaluation, NRC recommends that licensees submit a report of the methodology used for NRC review and approval Foz safety evaluations involving the determination of opezating limits for inclusion in a "Core Operating Limits Report", the plant technical specifications must reference the methodologies used, the NRC review and approval of these methods are required prior to inclusion of the reference in the technical specification."

L-95-006 Page 3 of 5 In order to develop this proficiency, FPL signed a Technology Exchange Agreement with Westinghouse Electric Corporation. The Westinghouse methodology included several important advantages:

o A physics methodology which included extensive written procedures (METCOM) which documented in a step by step fashion core design calculational practices.

o A training progzam which included hands-on experience utilizing METCOM and performing actual calculations on the computer workstations to ensure that the FPL engineers understood the Westinghouse methodology.

o Physics methodology and computer codes previously reviewed and approved by the NRC for all pressurized water reactor applications.

o An agreed upon process under which FPL engineers would perform the reload physics calculations for Turkey Point Unit 3, Cycle 14 independently of Westinghouse and Westinghouse provide Quality Assurance of all calculations.

Training of FPL personnel in the Westinghouse methods involved 5500 manhours of training. FPL individuals weze trained in areas ranging from Loading Pattern Scoping, Cross-Section Development, Loading Pattern Generation, Safety Analysis Models and Analysis, Nuclear Design Models and Analysis, to the development of Core Follow Analysis.

FPL Topical Report NF-TR-95-01 describes the physics methods used by FPL to analyze the coze characteristics for FPL's nuclear units. This report includes a summary description of the Westinghouse computer programs and methodology as applied by FPL to model the Turkey Point and St. Lucie Nuclear Power Station cores. Comparisons between predicted and operating data (i.e , critical boron concentration,

~

moderator temperature coefficients) are provided as a demonstration of FPL's qualifications to use the Westinghouse methodology to perform reload design calculations for the Turkey Point and St. Lucie nuclear units.

FPL's proficiency in executing the nuclear physics methodology for the reload design calculations for Turkey Point Units 3 and 4 using NRC reviewed and approved methods and computer codes is demonstrated by the enclosed NF-TR-95-01 topical report.

L-95-006 Page 4 of 5 Proposed Technica1 Specifications Changes FPL proposes to change the following Technical Specification in support of the proposed amendments:

Technical S ecification 6.9.1.7: revise the Technical Specification requirements for the "CORE OPERATING LIMITS REPORT" to includh a reference to FPL Topical Report NF-TR-95-01, Nuclear Physics Methodology for Reload Design of Turkey Point & St. Lucie Nuclear Plants.

Justification: GL 83-11 makes the following statement:

each licensee or vendor who intends to use a safety analysis computer code to support licensing actions should demonstrate their proficiency in using the code by submitting code verification performed by them..."

As described in Attachment 4, FPL signed a Technology Exchange Agreement with Westinghouse Electric Corporation to develop the ability to perfozm the reload design calculations for FPL nuclear plants (Turkey Point and St. Lucie) . This agreement included the transfer of Westinghouse methods, extensive training of FPL engineers at both FPL and Westinghouse, and access to Westinghouse computer codes and models. The documentation provided in Topical Report NF-TR-95-01 entitled "Nuclear Physics Methodology for Reload Design of Turkey Point & St. Lucie Nuclear Plants," demonstrates FPL's proficiency in performing reload design calculations.

The proposed change adds the reference of the topical report to the Technical Specification requirements for the "CORE OPERATING LIMITS REPORT", to be consistent with the recommendations of GL 88-16 and 83-11. In accordance with GL 88-16, the NRC-approved methodology is specified. The actual COLR report will be required to be submitted to the NRC upon issuance, for each reload cycle, to allow continued trending of cycle-specific parameters.

Summary FPL has determined that in-house capability to design reload cores for Turkey Point would provide the following benefits:

o a better understanding of the zeload design, leading to more comprehensive evaluations of core safety, o improved control over the design, yielding more control of the decision pzocess, and o improved optimization of the design, allowing better fuel utilization and economics.

L-95-006 Page 5 of 5 As described in the enclosed FPL Topical Report NF-TR-95-01, FPL has demonstrated the ability to perform the reload design physics calculations using NRC approved methods and computer codes. No safety-related equipment, safety function, or plant operations will be altered as a result of FPL calculating the reload design parameters in the COLR. Since the applicable Updated Final Safety Analysis Report (UFSAR) limits will be maintained and the Technical Specifications will continue to require operation within the the core operating limits implementation of the calculated using NRC approved methodologies, COLR is administrative in nature as described in GL 88-16. Any changes to the COLR will be made in accordance with the provisions of 10 CFR 550.59. From cycle to cycle, the COLR will be revised such that the appropriate limits for the applicable -cycle will apply.

ATTACHMENT 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION

L-95-006 Page 1 of 3 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Description of Proposed License Amendments Generic Letter (GL) 88-16, dated October 4, 1988, was issued to encourage licensees to amend the Technical Specifications related to cycle-specific parameters. The generic letter provided guidance for relocation of certain cycle-dependent core operating limits from a licensee's Technical Specifications to the Core Operating Limits Report (COLR) . This would allow changes to the values of the core operating limits without prior NRC approval (i.e., license amendment),

as long as an NRC approved methodology for the parameter limit calculation is followed. In accordance with GL 88-16, FPL submitted and received NRC approval for two proposed license amendments to relocate the parameters of Axial Flux Distribution, Rod Bank Insertion Limits and K(Z), from the Turkey Point Technical Specifications to the COLR.

GL 83-11, dated February 8, 1983, was issued to encourage licensees to perform their own safety analyses and describes the current NRC practices regarding licensee qualification for performing safety analyses. This proposed Technical Specification change demonstrates FPL's capabilities to use NRC approved methodology to calculate the COLR parameters.

In accordance with the recommendations of GL 88-16 and 83-11, and the safety evaluations which approved Amendments 156/150 and 167/161 for Turkey Point Units 3 and 4, FPL proposes to revise TS 6.9.1.7 to include a reference to FPL's Topical Repozt NF-TR-95-01, as the documentation to demonstrate FPL's proficiency in performing reload design calculations.

Introduction The Nuclear Regulatory Commission has provided standards for determining whether a significant hazards consideration exists (10 CFR 50.92(c)) . A proposed amendment to an opezating license for a facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; oz (3) involve a significant reduction in a margin of safety. Each standard is discussed below for the proposed license amendments.

Discussion (1) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The addition of the reference to FPL topical report which demonstrates FPL' ability to perform certain reload design

L-95-006 Page 2 of 3 calculations for Turkey Point Units 3 and 4 is administrative in nature and has no impact on the probability or consequences of any Design Bases Event (DBE) occurrences previously evaluated.

The reload design calculations will be performed using methodologies and computer codes approved by the NRC and poses no increase in the probability or consequences of any accident previously evaluated.

The Core Operating Limits Report (COLR) parameters will be evaluated every cycle to ensure proper compliance with the Updated Final Safety Analysis Report (UFSAR). These limits will be evaluated in accordance with 10 CFR 550.59, which ensures that the reload will not involve an increase in the probability of occurrences oz consequences of an accident previously evaluated.

Title 10 CFR 550.59 (2) states that a proposed change involves an unreviewed safety question (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased. Consequently, since any change to the reload core design analysis must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Operation of the facility in accordance with the proposed amendment would not create the possibility of a new oz different kind of accident from any accident previously evaluated.

The addition of the reference to FPL topical report which demonstrates FPL' ability to perform certain reload design calculations for Turkey Point Units 3 and 4 is administrative in nature and has no impact, nor does it contribute in any way to the possibility of a new or different kind of accident from any accident previously evaluated. No new accident scenarios, failure mechanisms or limiting single failure events are introduced as a result of the proposed change.

The generation of the Axial Flux Difference, Rod Bank Insertion limits and K(Z) curve will be performed using NRC-approved methodology and aze submitted to the NRC, as a revision to the COLR, to allow the NRC staff to trend. The Technical Specifications will continue to require operation within the core opezating limits and appropriate actions will be taken if these limits are exceeded.

Title 10 CFR 550.59 permits a licensee to make changes in the facility as described in the safety analysis report without prior Commission approval, provided that the proposed changes does not involve an unreviewed safety question. 10 CFR 550.59 (2) states that a proposed change involves an unreviewed safety question if (ii) a possibility for an accident or malfunction of a different type than any evaluated previously in the safety

L-95-006 Page 3 of 3 analysis report may be created. Consequently, since any change to the reload core design analysis must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then operation of the facility in accordance with the proposed amendments would not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in the margin of safety.

The margin of safety is not affected by FPL performing the reload design calculations for Turkey Point Units 3 and 4. The supporting Technical Specification values are defined by the accident analyses which are performed to conservatively bound the operating conditions defined by the Technical Specifications.

The development of the limits for future reloads will continue to conform to the methodology described in NRC approved documentation. In addition, each future reload will involve a 10 CFR 550.59 review to assure that operation of the units within the cycle specific limits will not involve a reduction in a margin of safety. 10 CFR 550.59 (2) states that a proposed change involves an unreviewed safety question (iii) if the margin of safety as defined in the basis for any technical specification is reduced. Consequently, since any change to the reload core design analysis must be evaluated relative to the more restrictive evaluation criterion of 10 CFR 550.59, then operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.

Summary Based on the above discussion, FPL has determined that the proposed amendments do not (1) involve a significant increase in the probability oz consequences of an accident previously evaluated, (2) create the possibility of a new oz different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore the proposed changes do not involve a significant hazards consideration as defined in 10 CFR 50.92.