NL-20-0636, Third Response to Request for Additional Information Related to License Amendment Request for Measurement Uncertainty Recapture Power Uprate

Third Response to Request for Additional Information Related to License Amendment Request for Measurement Uncertainty Recapture Power Uprate

ML20150A295
Person / Time
Site:	Farley
Issue date:	05/29/2020
From:	Gayheart C Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-20-0636
Download: ML20150A295 (5)

Text

3535 Colonnade Parkway Cheryl A. Gayheart Birmingham, AL 35243 Regulatory Affairs Director 205 992 5316 tel 205 992 7601 fax cagayhea@southernco.com May 29, 2020 10 CFR 50.90 Docket Nos.: 50-348 NL-20-0636 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Third Response to Request for Additional Information Related to License Amendment Request for Measurement Uncertainty Recapture Power Uprate Ladies and Gentlemen:

By letter dated October 30, 2019, Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) to the Joseph M. Farley Nuclear Plant (FNP) Unit 1 Renewed Facility Operating License (NPF-2), and the Unit 2 Renewed Facility Operating License (NPF-8) to allow for a measurement uncertainty recapture power uprate (MUR-PU). This MUR-PU LAR would increase FNPs authorized core power from 2775 megawatts thermal (MWt) to 2821 MWt (ML19308A761).

By email dated March 23, 2020 (ML20084G527), the U.S. Nuclear Regulatory Commission (NRC) staff notified SNC that additional information is needed for the staff to complete their review. By letter dated April 22, 2020 (ML20113E970), SNC responded to the Request for Additional Information.

By email dated April 29, 2020 (ML20121A147), the NRC staff notified SNC that additional information is needed regarding RAI EMIB No. 1 as discussed during a clarification call on April 28, 2020. By letter dated May 8, 2020 (ML20129J876), SNC responded to the Request for Additional Information.

By email dated May 21, 2020 (ML20149K439), the NRC staff notified SNC that additional information is needed for the staff to complete their review as discussed during a clarification call on May 21, 2020.

The enclosure to this letter provides the SNC response to the third NRC request for additional information (RAI).

This letter contains no NRC commitments.

The conclusions of the No Significant Hazards Consideration Determination Analysis and Environmental Consideration contained in the original License Amendment Request have been

U. S. Nuclear Regulatory Commission NL-20-0636 Page 2 reviewed and are unaffected by this RAI response or associated change to the Technical Specifications mark-up discussed in the response.

In accordance with 10 CFR 50.91, SNC is notifying the state of Alabama of this license amendment RAI response by transmitting a copy of this letter to the designated state official.

If you have any questions, please contact Jamie Coleman at 205.992.6611.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 29, 2020.

C. A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Company CAG/was/scm

Enclosure:

SNC Third Response to Request for Additional Information (RAI) cc: NRC Regional Administrator NRC NRR Project Manager - Farley 1&2 NRC Senior Resident Inspector - Farley 1 & 2 Alabama - State Health Officer for the Department of Public Health SNC Document Control R-Type: CFA04.054

Joseph M. Farley Nuclear Plant - Units 1 and 2 Third Response to Request for Additional Information Related to License Amendment Request for Measurement Uncertainty Recapture Power Uprate ENCLOSURE SNC Third Response to Request for Additional Information (RAI)

SNC Third Response to Request for Additional Information (RAI)

NL-20-0636 SFNB RAI No. 2 Generic Letter (GL) 96-03, Relocation of the Pressure Temperature Limit Curves and Low Temperature Overpressure Protection System Limits, in part, describes the requirements related to the contents of the technical specifications (TSs) when referencing a pressure temperature limits report (PTLR), or similar document. GL 96-03 states:

Relocation of the curves and setpoints to a licensee-controlled document requires three separate licensee actions. The licensee must (1) have a methodology approved by the NRC to reference in its TS; (2) develop a report such as a PTLR or a similar document to contain the figures, values, parameters, and any explanation necessary; and (3) modify the applicable sections of the TS accordingly.

The guidance provided in GL 96-03 identifies six provisions that licensees must address to relocate pressure-temperature limits to an administratively controlled document. The first of these is that the methodology shall describe how the neutron fluence is calculated. While WCAP-14040-A, Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves, (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML050120209) addresses this requirement by describing neutron transport calculations in Chapter 2, alternative methods are described in WCAP-18124-NP-A, Fluence Determination with RAPTOR-M3G and FERRET (ADAMS Accession No. ML18204A010). While the use of WCAP-18124-NP-A is generally acceptable as described in the associated NRC staff safety evaluation, its use may preclude adherence to Chapter 2 of WCAP-14040-A.

TS 5.6.6.b is stated below, with the proposed changes in bold.

The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in WCAP-14040-A, Revision 4, Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves, May 2004 and WCAP-18124-NP-A, Revision 0, Fluence Determination with RAPTOR-M3G and FERRET, July 2018.

For Farley Nuclear Plant, Units 1 and 2, the NRC staff understands that the approved methodology used to determine pressure-temperature limits would continue to be WCAP-14040-A. However, in cases where WCAP-18124-NP-A is used, the transport methods described in Chapter 2 of WCAP-14010-A may not be used.

Please modify the proposed TS revision to clarify that WCAP-18124-NP-A may be used as an alternative to Chapter 2 of WCAP-14040-A. As presently proposed, the revision suggests that both methodologies would be used.

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SNC Third Response to Request for Additional Information (RAI)

NL-20-0636 SNC Response:

As discussed during the clarification call, the methodology discussed in WCAP-18124 is an acceptable fluence determination alternative to the methodology discussed in Section 2.2 of WCAP-14040-A. To clarify this relationship, the following revised text is proposed (added text in blue):

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in WCAP-14040-A, Revision 4, Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves, May 2004. WCAP-18124-NP-A, Revision 0, Fluence Determination with RAPTOR-M3G and FERRET, July 2018, may be used as an alternative to Section 2.2 of WCAP-14040-A.

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