L-15-266, Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 16

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Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 16
ML15252A228
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 09/09/2015
From: Harkness E
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15252A227 List:
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L-15-266
Download: ML15252A228 (35)
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FENOC Perry Nuclear Power Plant PO Box 97 10 Center Road FirstEnergy Nuclear Operating Company Perry> Oh'° 44081 Ernest J. Harkness 440-280-5382 Vice President Fax 440-280-8029 WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 WHEN SEPARATED FROM ENCLOSURE A, THIS DOCUMENT CAN BE DECONTROLLED September 9, 2015 L-15-266 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 16 Enclosed is Revision 24 of the Core Operating Limits Report for the Perry Nuclear Power Plant (PNPP). This mid-cycle revision is submitted to the Nuclear Regulatory Commission (NRC) in accordance with PNPP Technical Specification 5.6.5, "Core Operating Limits Report (COLR)." A summary of the revision is provided on page 28 of the COLR.

Enclosure A contains proprietary information and should be withheld from public disclosure under 10 CFR 2.390. Enclosure B provides the nonproprietary version of this report. Enclosure C provides the Global Nuclear Fuel - Americas, LLC proprietary information affidavit.

There are no regulatory commitments contained in this submittal. If there are any questions or additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.

Sincerely, /

°MJ^

Ernest J. Harkness

Perry Nuclear Power Plant L-15-266 Page 2 of 2

Enclosures:

A. Core Operating Limits Report for the Perry Nuclear Power Plant Unit 1 Cycle 16 (Reload 15), Revision 24 [PROPRIETARY]

B. Core Operating Limits Report for the Perry Nuclear Power Plant Unit 1 Cycle 16 (Reload 15), Revision 24 [NONPROPRIETARY]

C. Affidavit, Global Nuclear Fuel - Americas, LLC cc: NRC Region III Administrator NRC Resident Inspector NRC Project Manager

ENCLOSURE B L-15-266 NONPROPRIETARY Core Operating Limits Report for the Perry Nuclear Power Plant Unit 1 Cycle 16 (Reload 15), Revision 24

[28 Pages Follow]

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category.

Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 1 of 28 CORE OPERATING LIMITS REPORT FOR THE PERRY NUCLEAR POWER PLANT UNIT 1 CYCLE 16 (RELOAD 15)

Functional Location (J11)

Plant Data Book Effective Date: 8-11-15 Preparer: Pat Curran / 7-16-15 Date Approver: Paul Bordlev / 8-7-15 Date Proprietary Information Notice The Cycle 16 Core Operating Limits Report contains proprietary information of the type that Global Nuclear Fuel - Americas, LLC (GNF) maintains in confidence and withholds from public disclosure. The GNF proprietary information is identified by a dotted underline inside double square brackets. [LT.h is .sentence, is. an example.))

Procedure Number.

PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page:

24 2 Of 28 TABLE OF CONTENTS

1.0 INTRODUCTION

3

2.0 REFERENCES

4 3.0 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (T.S. 3.2.1) 6 4.0 MINIMUM CRITICAL POWER RATIO (T.S. 3.2.2) 9 5.0 LINEAR HEAT GENERATION RATE (T.S. 3.2.3) 18 6.0 REACTOR PROTECTION SYSTEM INSTRUMENTATION (T.S. 3.3.1.1) 23 7.0 OSCILLATION POWER RANGE MONITOR (OPRM)

INSTRUMENTATION (T.S. 3.3.1.3) 23 8.0 SCOPE OF REVISION 23

Procedure Number:

PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 3 of 28

1.0 INTRODUCTION

This Core Operating Limits Report (COLR) for the Perry Nuclear Power Plant (PNPP) Unit 1 Cycle 16 is prepared in accordance with the requirements of PNPP Technical Specification Administrative Control 5.6.5.

The core operating limits presented herein were determined using NRC-approved methods (Obligation 1 and Obligation 2). The core operating limits for the Global Nuclear Fuel (GNF) fuel in PNPP Unit 1 for Cycle 16 are documented in Obligations 3, 4, 5, 14, 16, and 17 and summarized herein for the following PNPP Unit 1 Technical Specifications:

1. Average Planar Linear Heat Generation Rate (APLHGR) Limits for each fuel/lattice type, including the power and flow dependent MAPFAC multipliers with the single loop MAPLHGR reduction factor. (Technical Specification 3.2.1)
2. Minimum Critical Power Ratio Operating Limit including the power and flow dependent MCPR curves for Two Loop Operation and Single Loop Operation. (Technical Specification 3.2.2)

Additional power dependent MCPR curves for Two Loop Operation and Single Loop Operation are provided for operation with one pressure regulator out of service.

3. Linear Heat Generation Rate (LHGR) Limits for each fuel/lattice type, including the power and flow dependent LHGRFAC curves with the single loop LHGRFAC reduction factor. (Technical Specification 3.2.3)
4. The simulated thermal power time constant. (Technical Specification 3.3.1.1, SR 3.3.1.1.14)
5. Oscillation Power Range Monitor (OPRM) Instrumentation.

(Technical Specification 3.3.1.3)

Calculation FM-075, Support for the Core Operating Limits Report, details the development of the various graphs contained within this COLR.

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 4 of 28

2.0 REFERENCES

2.1 Discretionary None 2.2 Obligations

1. General Electric Standard Application for Reactor Fuel, NEDE-24011-P-A-20, December 2013; and the US Supplement, NEDE-24011-P-A-20-US, December 2013
2. Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications, Licensing Topical Report, NEDO-32465-A, August 1996
3. Supplemental Reload Licensing Report for Perry 1 Reload 15 Cycle 16, GNF Document 000N9539-SRLR, Rev 0, November 2014
4. Fuel Bundle Information Report for Perry 1 Reload 15 Cycle 16, GNF Document 000N9540-FBIR, Rev 0, November 2014
5. Calculation FM-012, Revision 4, Addendum 3 OPRM Device Settings and Setpoints
6. Technical Specification 2.1.1.2, Safety Limit MCPR, Amendment No. 165.
7. Technical Specification 3.2.1, Average Planar Linear Heat Generation Rate, Amendment No. 112
8. Technical Specification 3.2.2, Minimum Critical Power Ratio, Amendment No. 112
9. Technical Specification 3.2.3, Linear Heat Generation Rate, Amendment No. 112
10. Technical Specification 3.3.1.1, Reactor Protection System Instrumentation (SR 3.3.1.1.14), Amendment No. 115

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision- Page 24 5 of 28

11. Technical Specification 3.3.1.3, OPRM Instrumentation (SR 3.3.1.3.3), Amendment 138
12. Technical Specification 5.6.5, Core Operating Limits Report, Amendment No. 136
13. Neutron Monitoring System Design Specification, 22A3739, Revision 6
14. Calculation FM-075, Support For Core Operating Limits Report, Revision 2
15. FTI-B0012, Single Loop Operation
16. Tables D-2 (UO2) and D-4 (U,GdO2) of GE14 Compliance with Amendment 22 of NEDE-24011-P-A, (GESTAR II), NEDC-32868P, Revision 5, May 2013, MFN 13-028, May 24, 2013.
17. Tables B-1 (UO2) and B-2 (U,GdO2) of GNF2 Advantage Generic Compliance with NEDE-24011-P-A, (GESTAR II), NEDC-33270P, Revision 5, May 2013, MFN 13-029, May 24, 2013.
18. Condition Report 2015-06018 - Use of GNF Provided Proprietary Information Commitments addressed in this document:

None

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 6 of 28 3.0 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (T.S. 3.2.1)

All AVERAGE PLANAR LINEAR HEAT GENERATION RATES (APLHGRs) shall not exceed the result obtained from multiplying the applicable MAPLHGR limit, Figure 3.2.1-1a GE14 Fuel Type or Figure 3.2.1-1b GNF2 Fuel Type, by the smaller of either the flow dependent MAPLHGR factor (MAPFACf) or the power dependent MAPLHGR factor (MAPFACp).

MAPLHGR Limits and MAPFACf and MAPFACp are defined in Obligation 3.

For Two Loop Operation, MAPFACf and MAPFACp are set equal to 1.0.

For Single Loop Operation, MAPFACf and MAPFACp are set equal to 0.8.

The Single Loop Operation limits take effect when reset for single loop operation per LCO 3.4.1,MRecirculation Loops Operating". This is consistent with note "(b)" to Table 3.3.1.1-1 of the Technical Specifications.

Use FTI-B0012 Single Loop Operation to implement the revised MAPLHGR Limits.

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 7 of 28 Figure 3.2.1-1a MAPLHGR versus Average Planar Exposure Fuel Type GE14 16 12 N

PERMISSI BLE

\

10 REGION <

OPERATl ON xt N

o 5 8 N

to O

O 6 UJ iGE14 ECCS MAPLHGR Limit MAPLHGR = 12.82 for Exposures <= 19 13 MAPtHGR = 12.82 + (-0.12526) * (Exposure -19.13) for 19.13 < Exposures <= 57.61 MAPUHGR = 8.00 -s- (-0.50934) 4 (Exposure - 57.61) for 57.61 < Exposures <= 63.50 10 15 20 25 30 35 40 45 50 55 60 '65 70 Average Planar Exposure (GWD/ST)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page-24 8 of 28

( Figure 3,2.1-1b MAPLHGR Versus Average Pianar Exposure Fuel Type GNF2 16 s

\

12 PERMISSI BLE \

REGION iJH OPERAT1 ON \

ID I

_J OL

< \

CO 8 .6

-TGNE2 ECCS MAPLHGR UM!T l MAPLHGR -13 78 for Exposures <~ 17.15 MAPLHGR = 13.78 + (rQ. 15838) * (Exposure -17.15}

for 17.15 < Exposures <= 60.78 MAPLHGR = 6.87 + (-0.50368) * (Exposure - 60.78) for 60.78 < Exposures, <= 63.50 ' "

1.0 15 20 25 30 35 40 45 50 55 60 65 70 Average Planar Exposure (GWD/ST)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 9 of 28 4.0 MINIMUM CRITICAL POWER RATIO (T.S. 3.2.2)

The MINIMUM CRITICAL POWER RATIO (MCPR) shall be equal to or greater than the higher of the flow dependent MCPR (MCPRf) and power dependent MCPR (MCPRp) limits at the indicated core flow and THERMAL POWER.

The MCPR Safety Limit for Cycle 16 for Two Loop Operation is 1.10 and the MCPR Safety Limit for Single Loop Operation is 1.13 <TECHNICAL SPECIFICATIONS 2.1.1.2> (Obligations 3 and 6). The change in Safety Limit from Two Loop Operations to Single Loop Operations is accomplished by increasing the Cycle 16 MCPRf and MCPRp limits by 0.03. 3DMONICORE PANACEA Version 11 uses this approach to calculate Single Loop Operation Limits.

The Single Loop Operation limits take effect when reset for single loop operation per LCO 3.4.1,"Recirculation Loops Operating". This is consistent with note "(b)" to Table 3.3.1.1-1 of the Technical Specifications.

Use FTI-B0012 Single Loop Operation to implement the revised MCPR Limits.

The Stability Analysis based Two Loop Operating Limit MCPR is 1.46 with a Single Loop Operating Limit of 1.49. The Transient Analysis based Two Loop Operating Limit MCPR is 1.37 (GNF2 Fuel Type) and 1.34 (GE14 Fuel Type) and with a Single Loop Operating Limit of 1.40 (GNF2 Fuel Type) and 1.37 (GE14 Fuel Type). The off-rated multipliers for power and flow (MCPRp and MCPRf) are applicable to the Transient based OL-MCPR.

The Stability Analysis does not rely on off-rated multipliers. As such, greater than 38%RTP, MCPRp will be based upon multiplying the Transient Based OL-MCPR times Kp. MCPRf will be maximum of the MCPRf and the Stability Based OL-MPCR. Using this approach, at rated full power conditions the Stability Based OL-MCPR will be limiting. As power and/or flow is decreased from rated conditions, the Transient Based MCPRp and MCPRf OL-MCPR will become more limiting.

For Cycle 16 no change to MCPR limits is required for planned reduction of feedwater temperature to as low as 325.5°F. Final feedwater temperature may be reduced to 255.5°F after all control rods are withdrawn at the end of cycle if the OPRMs are OPERABLE.

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 10 of 28 Planned reduction of rated feedwater temperature from nominal rated feedwater temperature is not permitted during plant operation with the reactor recirculation system in Single Loop Operation.

The 3DMONICORE Computer software should automatically shift between 2 LOOP ON and ONE LOOP ON modes of operation on transfer to Single Loop Operations. As such the Safety Limit change should occur automatically. The guidance in FTI-B0012 can be used to verify proper functioning of the 3DMONICORE System. If the 3DMONICORE System is not functioning properly, FTI-B0012 will implement administrative limits until such time as 3DMONICORE is properly calculating MCPR values.

The MCPRf and MCPRp Limits are based on whether the plant is operating in Two Loop or Single Loop Operations and whether Two Pressure Regulators or One Pressure Regulator is in service. Select MCPRf /

MCPRp Limit Curves based on plant conditions:

MCPRf Figure 3.2.2-1, MCPRf- Two Loop Operations - Fuel Type GE14/GNF2 Figure 3.2.2-2, MCPRf- Single Loop Operations - Fuel Type GE14/GNF2 MCPRp Figure 3.2.2-3a, MCPRp- Two Loop Operations - Fuel Type: GNF2 Figure 3.2.2-3b, MCPRp- Two Loop Operations - Fuel Type: GE14 Figure 3.2.2-4a, MCPRp- Single Loop Operations - Fuel Type: GNF2 Figure 3.2.2-4b, MCPRp- Single Loop Operations - Fuel Type: GE14 Figure 3.2.2-5a, MCPRp- Two Loop Operations / Pressure Regulator Out of Service - Fuel Type: GNF2 Figure 3.2.2-5b, MCPRp- Two Loop Operations / Pressure Regulator Out of Service - Fuel Type: GE14 Figure 3.2.2-6a, MCPRp- Single Loop Operations / Pressure Regulator Out of Service - Fuel Type: GNF2 Figure 3.2.2-6b, MCPRp- Single Loop Operations / Pressure Regulator Out of Service - Fuel Type: GEM Figure 3.2.2-7 Maximum Fraction Limiting Critical Power Ratio Limit (MFLCPR) With One Pressure Regulator Out Of Service

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 11 of 28 The 3DMONICORE Software will not automatically shift to the Pressure Regulator Out of Service Thermal Limits. The 3DMONICORE databank will be manually changed using a software change request. Until such time as 3DMONICORE databank is updated for the Pressure Regulator Out of Service Thermal Limits, an MFLCPR Administrative Limit will be issued to Operations. Figure 3.2.2-7 can be used as a guide in establishing the MFLCPR Administrative Limit. The graph is the ratio of MCPRp to MCPRp - Pressure Regulator Out Of Service.

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001

Title:

Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page:

24 12 of 28 Figure 3.2.2-1 Flow Dependent MCPR (MCPRf) - Ttyo Loop Operation Fuel Type GE14/GNF2 1.8 1.7 o

Q.

o PERMISSIBLE REGION OF o

o OPERATION

_J o

o 1A MCPRf= MAX [1.46, 1.65-0.©#714fF

\ - 1.46 1<<2 40 80 400 120 CORE FLOW {% RATED)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page.

24 13 of 28 Figure 3-2,2-2 Flow Dependent MCPR{MCPRf} - Single Loop Operation Fuel Type GET4 /GNF2 1.8 PERMISSIBLE REGION OF OPERATION

\

1.68-0.W714 {F-3S}]

OLMCPR =

1,4 f.2 60 100 120 CORE FLOW l% RATED)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 14 of 28 Figure 3.2.2-3a Power Dependent MCPR Limit (MCPRP) - Two Loop Operation Fuel Type: GNF2 2.5 2.4 MCPRp = 2.44 - 0.01620 {P - 23.8}

For 23.8% '<= P < 38%; Core Flow >

2.3 MCPRp = 2.41 - 0.02042 {P - 23.8)

For 23.8% <= P < 38%; Core Flow <=

2.2 MCPRp = 2.1591 - 0.01336 (P - 38) 2.1 For 38% <= P <= §0.0%; Core Flow <= 105%

IB O

2.0 Q)

Q.

o Q. 1.9 O

O PERMISSIBli REGION OF OPERATION b

1.7 Q_

1.6 MCPRp = 1.7673 - §.00550 {P - 50}

For 50.0% < P <= 6.7%; Core Flow <= 105%

1.5 MCPRp = 1.5988 - 0.006S7 {P - 66:70}

For 66.7% < P <= 100%; Core Flow <=105%

1.4 1.3 1.2 20 40 60 CORE THERMAL POWER {% RATED}

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 15 of 28 Figure 3.2^2-3b Power Dependent MCPR Limit (MCPRP) - Two Loop Operation Fuel Type: GE14 2.5 2.4 MCPRp = 2.44 - 0.01620 {P - 23.8}

For 23.8% <= P < 38%; Core Flow > 56%

MCPRp - 2.41 - 0.02042 (P - 23.8}

For 23.8% <=P<38%; Core Flow <=

2.2 MCPRp = 2.1118 - 0.01307 lP -38}

2.t -___>>;

For 38% <= P <= 50.0%; Core Flow<= 105%

2.0 . .-

a.

O Q. 1.9 O

O PERMISSIBLE REGION OF 1.8 OPERATION 1.7 Q_

O MCPRp = 1.7286 - 0.00538 {P - 50}

For 50.0% <P<=66J%; Core Flow <= 105%

1-5 MCPRp = 1.5638 - 0.00672 (P: 66.70}

For 66.7% < P<= 100%; Core Flow<= 105%

1.3

~lQLMCPR = 1.34 1.2 4-20 40 60 80 100 CORE THERMAL POWER {% RATED)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 16 of 28 Figure 3^2.

Power Dependant MCPR Limit (MCPRP) - Single Loop Operation Fuel Type: GNF2 MCPRp = 2.47 - 0.01620 fP - 23.8)

For 23.8% <=P<38%; Core Flow >

MCPRp = 2.44 - 0.02042 (P - 23.8)

For 23.8% <= P < 38%; Core Flow <=

MCPRp = 2.1891 - 0.01336 lP - 38.0)

For 38% <= P <= 50.0%; Core Flow <= 1 ©5%

PERMISSIBLE REGION OF OPERATION a.

u p = 1.7973 - 0.&S55S (P ^ 50) 1.6 Pot 50.0% < P <= m.7%; Core Fldw<=r 105%

MCPRp = 1.S288 - 0.00687 {P , 66.70) 1,5 For 66.7%

  • P <= 100%; Core;FI6w <= 105%

iA 1.3 1.2

20. 40 60 1G0 CORE THERMAL POWER {% RATED)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision. Page 24 17 of 28 Figure 3.2.24b Power Dependent MCPR Limit {MCPRP) - Single Loop Operation Fuel Type: GE14 2.5 2A MCPRp = 2.47 - Q.01620 (P - 23.8}

For 23.8% <=P<38%: Core Flow >

2.3 MCPRp = 2.44 - 0J2O42 (P - 23.8}

For 23.8% <= P < 38%; Core Flow <=

2.2 MCPRp = 2.1418 - 0.01307 fP - 38.0)

For 38% <= P <= 50.0%; Core Flow <=

PERRHISSIBLE REGION OF c

OPERATION o

MCPRp = 1.7586 - O.0053S (P -

For 50.0% < P <=6.7%; Core Flow<= 105%

MCPRp = 1.5938 - 0.00672 (P - 66.70}

1.5 For 66.7% < P <= 100%; Core Flow <= 1C

^

20 too CORE THERMAL POWER (% RATED)

Procedure Number.

PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 18 of 28 Figure 3.Z2-5a PowerDependent MCPR Limit (MCPRP) - Two Loop Operation Pressure Regulator Out Of Service / Fuel Type: GNF2 2.5 2.4 MCPRp = 2.44 - O.S1620 {P - 23.8}

For 23.8% <= P < 38%; Core Flow >

2.3 MCPRp = 2.41 - 0.02042 lP - 23.8)

For 23.8% <= P < 38%; Core Flow <= 50%

2.2 MCPRp = 2.1591 - 0J1138 (P - 38}

O For 38% <= P <= 80%; Core Flow <=

O c

JO PERMISSIBLE Is REGION OF

<5 OPERATION o.

O a.

o o

1.7 Q

1.5 MCPRp - 1.5070 - 0.OO685 lP - 80)

For 8S% < P <= 100%; Core Flow <= 105%

1.4 1.3 -

OLMCPR 1.2 20 40 60 100, CORE THERMAL POWER {% RATED}

Procedure Number.

PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category s Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page:

24 19 Of 28 Figure 3,2.2-5b Power Dependent MCPR Limit (NICPRp) - Two Loop Operation Pressure Regulator Out Of Service / Fuel Type: GE14 MCPRp = 2.44 - 0.01620 lP - 23.8J For 23.8% <= P < 38%; Core Flow >

MCPRp = 2.41 - 0.02642 fP - 23.8)

For 23.8% <= P < 38%: Core Flow <=

MCPRp = 2.1118 - 0.01113 (P - 38}

= p <= 80%; Core Flow <= 105%

PERMISSIBLE REGION OF OPERATION 1.5 1,4 MCPRp = 1.4740 - 0.00670 (P - 81 For 80% < P <= 100%; Core Flow <=

1.3 OLMCPR = 1.34 1.2 40 60 100 CORE THERMAL POWER {% RATED}

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 20 of 28 Figure 3.2.2-6a Power Dependent MCFR Limit (MCPRP) - Single Loop Operation Pressure Regulator Out Of Service / Fuel Type: GNF2 MCPRp = 2.47 - 0.91S20 lP - 23.8)

For 23.8% <= P < 38%; Core Flow > 58%

MCPRp = 2.44 - S.02042 lP - 23.8)

For 23.8% <= P < 38%; Core Flow<=

MCPRp = 2.1891 - 0.01138 lP - 38)

For 38% <= P <= 80%; Core Flow <= 185%

PERMISSIBLE REGION OF OPERATION MCPRp = 1.5370 - 0.00685 {P - 80)

For 80% < P <= 100%; Core Flow <= 105%

40 60 CORE THERMAL POWER {% RATED)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 21 of 28 Figure 3.2.2-6b Power Dependent MCPR Limit lMCPRP) - Single Loop Operation Pressure Regulator Out Of Service / Fuel Type: GE14 MCPRp = 2.47 - 0.01620 <P - 23.8}

For 23.8% <- P < 38%; Core Flow >

MCPRp = 2.44 - 0.02042 {P - 23.8)

For 23.8% <= P < 38%; Core Flow <=

MCPRp = 2.1418 - 0J1113 {P - 38)

For 38% <= P <= 80%; Core Flow <= 105%

PERMISSIBLE REGION OF OPERATION MCPRp = 1. 0.00670 (P - 80)

For 80% <P<= Core Flow <=

OLMCPR = 1.37 1,2 20 40, 60 100 CORE THERMAL POWER {% RATED)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision. Page 24 22 of 28 Figure 3.2.2-7 Maximum Fraction Limiting Criticai Power Ratio Limit {MFLCPR}

With One Pressure Regulator Out Of Service Fuel Type GE14/GNF2 1.000 PERMISSIBLE REGION OF OPERATION 6,850 20 25 30 35 40 45 50 55 60 65 70 75 95 100 CORE THERMAL POWER {% RATED}

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision. Page 24 23 of 28 5.0 LINEAR HEAT GENERATION RATE (T.S. 3.2.3)

All LINEAR HEAT GENERATION RATES (LHGRs) shall not exceed the result obtained from multiplying the applicable LHGR limit, Figure 3.2.3-1 a GE14 Fuel Type or Figure 3.2.3-1 b GNF2 Fuel Type, by the smaller of either the flow dependent LHGR factor (LHGRFACf), Figure 3.2.3-2, or the power dependent LHGR factor (LHGRFACp) Figure 3.2.3-3.

LHGR Limits and LHGRFACf and LHGRFACp are defined in Obligations 3, 4, 16, and 17.

For Two Loop Operation, LHGRFACf and LHGRFACp shall not exceed 1.0.

For Single Loop Operation, LHGRFACf and LHGRFACp shall not exceed 0.8.

The Single Loop Operation limits take effect when reset for single loop operation per LCO 3.4.1,"Recirculation Loops Operating". This is consistent with note "(b)" to Table 3.3.1.1-1 of the Technical Specifications.

Use FTI-B0012 Single Loop Operation to implement the revised MAPLHGR Limits.

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 24 of 28 Figure 3.2.3-1a CONTAINS PROPRIETARY INFORMATION AND IS WITHHELD FROM PUBLIC DISCLOSURE

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 25 of 28 Figure 3.2.3-1 b CONTAINS PROPRIETARY INFORMATION AND IS WITHHELD FROM PUBLIC DISCLOSURE

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Titie- Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page:

24 26 of 28 Figure 3.2.3-2 Flow Dependent LHGR Factor (LHGRFACf)

Fuel Type GEM/GNF2 Clamped at 0.30 During SLO of

= 0.544 0.00310 (F - 30} => 30% and < 40% flow

= §.575 0.02020 {F - 40} => 40% and < 50% flow

= 0.777 0.00850 \F - 50} => 50% and < 60% flow

= 0.862 0;00680 (F - 60)'-> 60% and < 80% flow

= 0.998 0.00667 (F - 80} => 80% and < 80.3% flow

= 1.0 => 80.3% and <= 107% flow 0.5 20 100 120 CORE FLOW (% RATED)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 27 of 28 Figure 3.2.3-3 Power Dependent LHGR Factor lLHGRFACP)

Fuel Type GE14/GNF2 iA 1.0 0.604

  • 0.00507 (P - 23.8) =>23.8% and <38% power 0.676 + 0.00408 (P- 38) +/->3S% and <50% power 0.725
  • 0.00550 (P- 50] =>50% and <100% power 38%<= P<=106%; Core Flow <=105%

23.8%<=P<3S%; Core Clamped at

©.80 During SLO LHGRFACp= 0.57+400211 (P-23.8) 23.8%<=P<38%; Core Flow >m 0.5 40 80 100 CORE THERMAL POWER {% RATED)

Procedure Number PERRY NUCLEAR POWER PLANT PDB-F0001 Title Use Category Core Operating Limits Report for the Perry Nuclear NONPROPRIETARY Power Plant Unit 1 Cycle 16 (Reload 15) Revision Page 24 28 of 28 6.0 REACTOR PROTECTION SYSTEM INSTRUMENTATION (T.S. 3.3.1.1)

The simulated thermal power time constant shall be 6 +/-0.6 seconds (Obligation 13).

7.0 OSCILLATION POWER RANGE MONITOR (OPRM) INSTRUMENTATION (T.S. 3.3.1.3)

These are the Cycle 16 OPRM setpoints for operable OPRMs.

Current Settings:

1. Confirmation Count Setpoint (NP = N2): 12
2. Amplitude. Setpoint (Sp): 1.10 (Obligation 5) 8.0 SCOPE OF REVISION Rev. 24 1. Revision 24 updated the MCPRp Curves (Figures 3.2.2-3a and -3b,

-4a and -4b, -5a and -5b, and -6a and -6b) based on Revision 2 of Calculation FM-075 and the Mid Cycle 16 OL-MCPR Improvement Project.

2. Revision 2 of Calculation FM-075 changed MCPRp from being the result of Kp times Stability Based OL-MCPR to being the result of Kp times the Transient Based OL-MCPR.
3. The Transient Based OL-MCPR was split into a limit for GNF2 and GE14 fuel types, which resulted in generating separate MCPRp curves for both GNF2 and GE14 fuel types.

ENCLOSURE C L-15-266 Affidavit, Global Nuclear Fuel -Americas, LLC

[3 Pages Follow]

Global Nuclear Fuel - Americas AFFIDAVIT I, Lukas Trosman, state as follows:

(1) I am Engineering Manager, Reload Design and Analysis, Global Nuclear Fuel -

Americas, LLC (GNF-A), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GNF's letter, JMT-FEN-KL1-15-049, Jeanne M. Thome to Robert Borland (FirstEnergy Nuclear Operating Company), entitled "Perry Nuclear Power Plant Unit 1 Cycle 16 Core Operating Limits Report," April 28, 2015. GNF proprietary information in Enclosure 1, which is entitled "Perry Nuclear Power Plant Unit 1 Cycle 16 Core Operating Limits Report," is identified by a ((dotted_ underline .inside .double.square brackets^.*)). A "((" marking at the beginning of a table, figure, or paragraph closed with a "))" marking at the end of the table, figure or paragraph is used to indicate that the entire content between the double brackets is proprietary. In each case, the superscript notation {3* refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group

v. FDA, 704F2dl280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;
b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; JMT-FEN-KL1 049 Enclosure 1 Affidavit Page 1 of 3
c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;
d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.

The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost to GNF-A or its licensor.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF-A's JMT-FEN-KL1 049 Enclosure 1 Affidavit Page 2 of 3

comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

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

Executed on this 28th day of April 2015.

Lukas Trosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel - Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 Lukas.Trosman@gnf.com JMT-FEN-KL1 049 Enclosure 1 Affidavit Page 3 of 3

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