southern nuclear 3535 colonnade parkway birmingham, al 35243 · correspondence with respect to the...

& Southern Nuclear Cheryl A. Gayheart Regulatory Affairs Director

3535 Colonnade Parkway Birmingham, AL 35243 205 9925316 tel 205 992 7601 fax [email protected]

Attachments 1 and 3 contain Proprietary Information. When separated from the Enclosure, this transmittal Document, the Enclosure, and the remaining Attachments are decontrolled.

July 13, 2020

Docket Nos.: 50-348 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 Supplement to License Amendment

10 CFR 50.90

NL-20-0828

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 FNP's authorized core power from 2775 megawatts thermal (MWt) to 2821 MWt (ML 19308A761).

During NRC review, it was noted that there was some inconsistency within the License Amendment Request package related to proprietary markings. The enclosure to this letter provides a supplement to address this inconsistency.

Attachments 1 and 3 provide proprietary versions of the Engineering Reports errata. Attachments 2 and 4 provide non-proprietary versions of the Engineering Reports errata. Attachment 5 provides the Cameron Technologies US, LLC (Cameron), CAW-20-05, for Withholding Proprietary Information from Public Disclosure. The affidavit sets forth the basis upon which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information that is proprietary to Cameron be withheld from public disclosure.

Correspondence with respect to the application for withholding or the supporting Cameron affidavit should reference CAW-20-05 and should be addressed to Joanna Phillips, Nuclear Sales Manager, Cameron Technologies US LLC, 1000 Mcclaren Woods Drive, Coraopolis, Pennsylvania 15108.

U.S. Nuclear Regulatory Commission NL-20-0828 Page2

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 reviewed and are unaffected by this supplement.

In accordance with 1 O CFR 50.91, SNC is notifying the state of Alabama of this license amendment supplement 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 July 13, 2020.

C. A. Gayhe Regulatory Affairs Director Southern Nuclear Operating Company

CAG/was/scm

Enclosure: Supplement to LAR for MUR-PU

•

cc: NRC Regional Administrator, Region II 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 Supplement to License Amendment

Request for Measurement Uncertainty Recapture Power Uprate

ENCLOSURE

Supplement to LAR for MUR-PU

Supplement to LAR for MUR-PU (NL-20-0828) Page 1 of 43

This Enclosure contains five attachments. The first four attachments provide errata pages for proprietary and non-proprietary attachments contained in the original Joseph M. Farley Nuclear Plant license amendment request for the measurement uncertainty recapture power uprate. The final attachment provides an application for withholding proprietary information from public disclosure.

Attachment: (1) Engineering Report: ER-1180P Rev. 1 and Rev. 1 Errata*, "BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER

DETERMINATION AT FARLEY UNIT 1 USING THE LEFM ✓ + SYSTEM"

(2) Engineering Report: ER-11 B0NP Rev. 1 and Rev. 1 Errata*, "BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT

FARLEY UNIT 1 USING THE LEFM ✓ + SYSTEM"

(3) Engineering Report: ER-1181P Rev. 1 and Rev. 1 Errata*, "BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT


(4) Engineering Report: ER-1181NP Rev. 1 and Rev. 1 Errata*, "BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT


(5) CAW 20-05, APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE


Attachment 2

Engineering Report: ER-1180NP Rev. 1 and Rev. 1 Errata*, "BOUNDING

UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT FARLEY

UNIT 1 USING THE LEFM ✓+SYSTEM"

Supplement to LAR for MUR-PU (NL-20-0828) Page 8 of43

@CAMERON .llileasurernentSVst~rns

Caldon® Ultrasonics

Engineering Report: ER-1 t80NP Rev. 1 and Rev.

1 Errata*

*This report supersedes the initial release of ER-4180NP Rev. 1

BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL. POWER DETERMINATIO.N AT FARLEY UNIT 1 USING THE LEFM✓+ SYSTEM

Prepared by: Jonathan Lent Reviewed by: RyEln Harmas o Reviewed for Proprietary Content by: Joanna Philli~I

June 2020

ER-1180NP Rev. 1 andRev. LErtata Prepared by: JJL

Schlumberger-Private

Reviewed by: RSH i \\

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Rev 1 Errata

Page 9 of43 Measurement Systems

1. Page 4 Footnote 1 and 2, proprietary markings should be removed, as follows:

Rev 1:

]

]

· Rev. 1 and Rev. 1 Errata:

1 The LEFM ✓ + is composed of the average flow of two independent LEFM3 subsystems. There are four acoustic paths in an LEFM✓ summing to eight paths in the LEFM✓ +. 2 Maintenance Mode refers to the state when any LEFM ✓ + meter has only one of its two LEFM✓ subsystems fully operational, resulting in that meter's computing flow from just the remaining fully operational LEFM ✓ subsystem.

2. Page 5, Section 2.0, first bulleted entry under item 3, proprietary markings should be removed as follows:

Rev 1: o Thermal power uncertainty using a Fully Functional LEFM ✓ + system is [ ]

Rev 1 and Rev 1 Errata:

o Thermal power uncertainty using a Fully Functional LEFM ✓ + system is ± 0.32%

ER-1180NP Rev. 1 and Rev. 1 Errata Prepared by: JJL


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,~·CAMERON Page 10 of43

Measurement Systems

1.0 INTRODUCTION The LEFM✓ and LEFM✓ +1 are advanced ultrasonic systems that accurately determine the volume flow and temperature of feedwater in nuclear power plants. Using a feedwater pressure signal input to the LEFM ✓ and LEFM ✓ +: mass flow can be determined and, along with the temperature· output are used along with plant data to compute reactor core thermal power. The technology underlying the LEFM ✓ ultrasonic instruments and the factors affecting their performance are described in a topical report, Reference 1, and a supplement to this topical report, Reference 2.

The LEFM✓ +, which is made of two LEFM✓ subsystems, is described in another supplement to the topical report, Reference 3. The exact amount of the uprate allowable under a revision to 1 0CFR50 Appendix K depends not only ort the accuracy of the LEFM ✓ + instrument, but also on the uncertainties in other inputs to the thermal power calculation.

It is the purpose of this document to provide an analysis of the uncertainty contribution of the LEFM ✓ + System [ ] to the overall mass flow and thermal power uncertainty of Farley Unit 1 (Appendix B).

The uncertainties in mass flow and feedwater temperature are also used in the calculation of the overall thermal power uncertainty (Appendix B). [

] A detailed discussion of the methodology for combining these terms is described in Reference 3.

This analysis is a bounding analysis for Farley Unit 1. [

]

1 The LEFM✓ + is composed of the average flow of two independent LEFM3 subsystems. There are four acoustic paths in an LEFM ✓ summing to eight paths in the LEFM ✓ +. 2 Maintenance Mode refers to the state when any LEFM ✓ + meter has only one of its two LEFM ✓ subsystems fully operational, resulting in that meter's computing flow from just the remaining fully operational LEFM✓ subsystem.

Trade Secret & Confidential Commercial Information

. Trade Secret & Confidential Commercial Information





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Measurement Systems

2.0 SUMMARY For Farley Unit 1, Revision 1 results are as follows:

1. The mass flow uncertainty approach is documented in Reference 3. The uncertainty in the LEFM✓ +'s mass flow offeedwater is as follows:

o Fully Functional LEFM ✓ + system mass flow uncertainty is [ ]

o Maintenance Mode LEFM ✓ + system mass flow uncertainty is [ ]

[

]

2. The uncertainty in the LEFM ✓ + feedwater temperature is as follows:

o Fully Functional LEFM ✓ + system temperature uncertainty is [ ]

o Maintenance Mode LEFM ✓ + system the uncertainty is [ ]

3. The total thermal power uncertainty approach is documented in Reference 3 and Appendix B of this document. The total uncertainty in the determination of thermal power uses the



LEFM ✓ + system parameters and plant specific parameters, i.e., heat gain/losses, etc. and is as follows:


o Thermal power uncertainty using a Maintenance Mode LEFM ✓ + system is [

]

Trade ] Secret &

Confidential Commercial Information




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Attachment 4

Engineering Report: ER-1181NP Rev. 1 and Rev. 1 Errata*, "BOUNDING

UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT FARLEY

UNIT 2 USING THE LEFM ✓+SYSTEM"

\


{€CAMERON Measurement Systems

Caldon® Ultrasonics

Engineering Report: ER-1181NP Rev. 1 and Rev.

1 Errata*

*This report supersedes the initial release of ER-1181 NP R~v. 1

BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT FARLEY UNIT 2 USING THE LEFM✓+ SYSTEM

Prepared by: Jonathan Lent Reviewed by: Ryan Hannas Reviewed for Proprietary Content by: Joanna Philli~

June2020



Reviewed by: RSH .~~

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Measurement Systems

© 2019 Cameron International Corporation ("Cameron") All information contained in this publication is confidential and proprietary property of Cameron. Any reproduction or use of these instructions, drawings, or photographs without the express written permission of an officer of Cameron is forbidden. ·

ER-1181.NP Rev, 1

All Rights Reserved. Printed in the United States of America.

Engineering Report No. ER-1181NP Rev. 1 May 2019

Prepared by: JJL


Reviewed by: .~l1

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Rev 1 Errata

Page 20 of43 Measurement Systems

1. Page 4 Footnote 1 and 2, proprietary markings should be removed, as follows:

Rev 1:

]

]

Rev. 1 and Rev. 1 Errata:

1 The LEFM ✓ + is composed of the average flow of two independent LEFM3 subsystems. There are four acoustic paths in an LEFM ✓ summing to eight paths in the LEFM ✓ +. 2 Maintenance Mode refers to the state when any LEFM ✓ + meter has only one of its two LEFM✓ subsystems fully operational, resulting in that meter's computing flow from just the remaining fully operational LEFM ✓ subsystem.

2. Page 5, Section 2.0, first bulleted entry under item 3, proprietary markings should be removed as follows:

Rev 1: o Thermal power uncertainty using a Fully Functional LEFM ✓ + system is [ ]

Rev 1 and Rev 1 Errata:


3. Proprietary statement should be removed from the following pages: Table of Contents, pages 4, 5, 7, 8, Appendix A Table of Contents, Appendix A.4 and A.5 Cover sheets:



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Measurement Systems

Engineering Report: ER-1181NP Rev.1

BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT FARLEY UNIT 2 USING THE LEFM✓+ SYSTEM

Table of Contents

1.0 INTRODUCTION 2.0 SUMMARY 3.0 APPROACH 4.0 OVERVIEW 5.0 REFERENCES 6.0 APPENDICES

A Information Supporting Uncertainty in LEFM✓+ Flow and Tem.perature Measurements A.1 LEFM✓+ Inputs A.2 LEFM✓ + Uncertainty Items/Calculations A.3 LEFM ✓+Meter Factor Calculation and Accuracy Assessment AA [ ] A.5 [ ]

B Total Thermal Power and Mass Flow Uncertainties using the LEFM✓+ System

ER-1181NP Rev. 1 and Rev I Eirnta Prepared by: JJL


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Measurement Systems

1.0 INTRODUCTION The LEFM ✓ and LEFM ✓ +1 are advanced ultrasonic systems that accurately determine the volume flow and temperature offeedwater in nuclear power plants. Using a feedwater pressure signal input to the LEFM ✓ and LEFM ✓ +: mass flow can be determined and, along with the temperature output are used along with plant data to compute reactor core thermal power. The technology underlying the LEFM ✓ ultrasonic instruments and the factors affecting their performance are described in a topical report, Reference 1, and a supplement to this topical report, Reference 2.

The LEFM ✓ +, which is made of two LEFM ✓ subsystems, is described in another supplement to the topical report, Reference 3. The exact amount of the uprate allowable under a revision to 1 0CFR50 Appendix K depends not only on the accuracy of the LEFM ✓ + instrument, but also on the uncertainties in other inputs to the thermal power calculation.

It is the purpose of this document to provide an analysis of the uncertainty contribution of the LEFM ✓ + System [ ] to the overall mass flow and thermal power uncertainty of Farley Unit 2 (Appendix B).

The uncertainties in mass flow and feec;lwater temperature are also used in the calculation of the overall thermal power uncertainty (Appendix B). '[

] A detailed discussion of the methodology for combining these terms is described in Reference 3.

This analysis is a bounding analysis for Farley Unit 2. [

]

1 The LEFM ✓ + is composed of the average flow of two independent LEFM3 subsystems. There are four acoustic paths in an LEFM ✓ summing to eight paths in the LEFM ✓ +. 2 Maintenance Mode refers to the state when any LEFM ✓ + meter has only one of its two LEFM ✓ subsystems fully operational, resulting in that meter's computing flow from just the remaining fully operational LEFM ✓ subsystem.







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Measurement Systems

2.0 SUMMARY

For Farley Unit 2, Revision 1 results are as follows:

1. The mass flow uncertainty approach is documented in Reference 3. The uncertainty in the LEFM ✓ +' s mass flow of feedwater is as follows:

o Fully Functional LEFM ✓ + system mass flow uncertainty is [ ]

o Maintenance Mode LEFM ✓ + system mass flow uncertainty is [ ]

[

2. The uncertainty in the LEFM ✓ + feedwater temperature is as follows:

o Fully Functional LEFM ✓ + system temperature uncertainty is [ ]

o Maintenance Mode LEFM ✓ + system the uncertainty is [ ]

3. The total thermal power uncertainty approach is documented in Reference 3 and Appendix B of this document. The total uncertainty in the determination of thermal power uses the LEFM ✓ + system parameters and plant specific parameters, i.e., heat gain/losses, etc. and is as follows:

o Thermal power uncertainty using a Fully Functional LEFM✓ + system is± 0.34%

o Thermal power uncertainty using a Maintenance Mode LEFM ✓ + system is [




ER-1181NP Rev. 1 and Rev.I Errata Prepared by: JJL


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3.0 APPROACH

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Measurement Systems

All errors and biases are calculated and combined according to the procedures defined in Reference 4 in order to determine the 95oi confidence and probability value. The approach to determine the uncertainty, consistent with determining set points, is to combine the random and bias terms by the means of the RSS approach provided that all the terms are independent, zerocentered and normally distributed.

Reference 4 defines the contributions of individual error elements through the use of sensitivity coefficients defined as follows:

A calculated variable Pis determined by algorithm f, from measured variables X, Y, and Z.

P =f(X, Y, Z)

The error, or uncertainty in P, dP, is given by:

dP = IJf I dX + §LI dY + IJ I dZ iJX yz of XZ tJZ XY

As noted above, P is the determined variable--in this case, reactor power or mass flow-- which is calculated via measured variables X, Y, and Z using an algorithm f (X, Y, Z). The uncertainty or error in P, dP, is determined on a per unit basis as follows:

where the terms in brackets are referred to as the sensitivity coefficients.

If the errors or biases in individual elements (dX/x. dYIY. and dilz in the above equation) are all caused by a common (systematic) boundary condition ( for example ambient temperature) the total error dPlP is found by summing the three terms in the above equation. If, as is more often the

case, the errors in X, Y, and Z ~e independent of each other, then Reference 4 recommends and probability theory requires that the total uncertainty be determined by the root sum square as follows (for 95°/o confidence and probability):

dP = p

Obviously, if some errors in individual elements are caused by a combination of boundary conditions, some independent and some related (i.e., systematic) then a combination of the two procedures is appropriate.

ER-:-1181NP Rev. 1 Prepared by: JJL


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Measurement Systems

4.0 OVERVIEW The analyses that support the calculation of LEFM ✓ + uncertainties are contained in the appendices to this document. The function of each appendix is outlined below.

Appendix A.1, LEFM✓ + Inputs

This appendix tabulates dimensional and other inputs to the LEFM ✓ +. The spreadsheet calculates other key dimensions and factors from these inputs (e.g., the face-to-face distance between pairs of transducer assemblies), which is used by the LEFM ✓ + for the computation of mass flow and temperature.

Appendix A.2, LEFM✓ + Uncertainty Items Calculations

This appendix calculates the uncertainties in mass flow and temperature as computed by the LEFM ✓ + using the methodology described in Appendix E of Reference 1 and Appendix A of Reference 33, with uncertainties in the elements of these measurements bounded as described in both references4• The spreadsheet calculations draw on the data of Appendix A. l for dimensional information. It draws from Appendix A.4 [

]. These uncertainties are an important factor in establishing the overall uncertainty of the LEFM✓+.

This appendix utilizes the results of the calibration testing for the plant spool piece(s) for the uncertainty in the profile factor ( calibration coefficient). The engineering reports for the spool piece calibration tests are referenced in Appendix A.3 to this report.

3 Reference 3 (ER l 57P-A) develops the uncertainties for the LEFM ✓ + system. Because this system uses two measurement planes, the structure of its uncertainties differs somewhat that of an LEFM3. 4 Reference 3 (ER 157P-A) revised some of the time measurement uncertainty bounds. The revised bounds are a conservative projection of actual performance of the LEFM hardware. ER 80P used bounds that were based on a conservative projection of theoretical performance.


ER-1181NP Rev. I and Rev.1 Errata Prepared by: JJL


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Measurement Systems

Appendix A.3, Meter Factor (Calibration) Uncertainties

Included with Revision 1 only- NIA for Revision 0 As noted above, the calibration test report for the spool piece(s) establishes the overall uncertainty in the meter factor of the LEFM ✓ +. [

]

[

].

Appendix A.4, [

This appendix calculates the [ ]

Appendix A.5, [

This appendix calculates the [ ]

Appendix B, Total Thermal Power Uncertainty due to the LEFM ✓ +

The total thermal power uncertainty due to the LEFM ✓ + is calculated in this appendix, using the results of Appendix A.2, A.4 and A.5. Plant supplied steam conditions (which enter into the computation of errors due to feedwater temperature) are used for this computation. This appendix also computes the :fraction of the uncertainty in feedwater temperature that is systematically related to the mass flow uncertainty.

Trade Secret& Confidential Commercial Information


Trade Secret& Confidential Commercial Information

ER-1181NP Rev. 1 and Rev.I Errata Prepared by: JJL


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5.0 REFERENCES

Page 27 of43

Measurement Systems

1) Cameron Topical Report ER-80P, "Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM Check System", Rev. 0

2) Cameron Engineering Report ER-160P, "Supplement to Topical Report ER 80P: Basis for a Power Uprate with the LEFM System", May 2000

3) Cameron Engineering Report ER-157(P-A), "Supplement to Cameron Topical Report ER-80P: Basis for Power Uprates with an LEFM Check or an LEFM CheckPlus", dated May 2008, Revision 8 and Revision 8 Errata

4) ASME PTC 19.1-1985, Measurement Uncertainty

ER-1181NP Rev. 1 Prepared by: JJL


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Appendix A.1, LEFM ✓ + Inputs

Appendix.A

Page 28 of43

Measurement Systems

Appendix A.2, LEFM ✓ + Uncertainty Items/Calculations Appendix A.3, Meter Factor

Calculation and Accuracy Assessment Appendix A.4, [ Trade

Secret & Confidential Commercial Information

] Appendix A.5, [

ER-1181NP Rev. 1 and Rev.1 Errata Prepared by: JJL



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Appendix A.I

LEFM ✓ + Inputs

Page 29 of43

No attachment to follow, as Appendix is Proprietary in its Entirety


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Appendix A.2

LEJ;i'M✓ + Uncertainty lt~ms/Calcula(ions


Schlumberger,Private

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Appendix A.3

LEFM ✓ + Meter Factor Calculation and Accuracy Assessment

Reference Caldon Engineering Reports

ER-1183 Rev 0, "Meter Factor Calculation and Accuracy Assessment for Farley Unit 2", June 2019


Page 31 of43

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AppendixA.4


ER-1181NP Rev. 1 and Rev.I Errata


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I Confidential Commercial Information

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Appendix A.S-


ER-1181NP Rev. 1 and Rev.I Errata


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I Secret & Confidential Commercial Information

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Supplement to LAR for MUR-PU {NL-20-0828) Page 34 of43

Appendix'B

Total Thermal Power and Mass Flow Uncertainty using the LEFM✓+ System

No attachment to follow, 3s Appen<Jix is Propriet3ry in it$ Entirety


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Valves & Measurement $ales [email protected]

Service ms-services@c-a~m.coiTI

.••••~ .... - ..... - ... •-- ,...f&,;. •••--

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