ML033370919

Constellation Energy Group, License Amendment Request: Revised Safety Limit Minimum Critical Power Ratio in Technical Specification 2.1.1.2

ML033370919
Person / Time
Site:	Nine Mile Point
Issue date:	11/20/2003
From:	Katz P Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP2L 2104, TS 2.1.1.2
Download: ML033370919 (24)

Text

P.O. Box 63 Lycoming, New York 13093 Constellation Energy Group Nine Mile Point Nuclear Station November 20, 2003 NMP2L 2104 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Nine Mile Point Unit 2 DocketNo. 50-410 Facility Operating License No. NPF-69 License Amendment Request: Revised Safety Limit Minimum Critical Power Ratio in Technical Specification 2.1.1.2 Gentlemen:

Pursuant to 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC (NMPNS) hereby requests an amendment to Nine Mile Point Unit 2 (NMP2) Operating License NPF-69. The proposed change revises the Safety Limit Minimum Critical Power Ratio (SLMCPR) values in Technical Specification (TS) 2.1.1.2 to reflect the results of cycle-specific calculations performed for the upcoming NMP2 Operating Cycle (OC-10), using NRC-approved methodology for determining SLMCPR values. The current SLMCPR values in TS 2.1.1.2 were approved by the NRC in a safety evaluation dated March 13, 2002, for Operating Cycle 9 (OC-9) and do not provide the appropriate level of conservatism for OC-10.

NMPNS plans to use a mixed core consisting of predominantly GE 1I fuel with new GE14 fuel during OC-10 whereas OC-9 uses a full core of GE] I fuel. The proposed revision to TS 2.1.1.2 takes into account the mixed core containing GE14 fuel. NMPNS requests approval of this license amendment request by March 1, 2004, with implementation prior to startup from the next refueling outage (RFO9). The loading of GE14 fuel will occur during RFO9, which is currently scheduled to begin in March 2004. This letter contains no new commitments, as reflected in.

Detailed information supporting the changes to the SLMCPR values is included as Attachment 4 and was provided by the NMP2 fuel vendor, Global Nuclear Fuel (GNF). Attachment 4 is considered by GNF to contain proprietary information exempt from disclosure pursuant to 10 CFR 2.790. Therefore, on behalf of GNF, NMPNS hereby makes application to withhold this document from public disclosure in accordance with 10 CFR 2.790(b)(1). An affidavit executed by GNF detailing the reasons for the request to withhold the proprietary information is included 1AD

Page 2 NMP2L 2104 as Attachment 5. A non-proprietary version of the information in Attachment 4 is included as.

Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this license amendment request and the associated analyses regarding no significant hazards consideration to the appropriate state representative.

Very truly yours, Pete E. Katz Vice President Nine Mile Point PEK/IAA/bjh STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Peter E. Katz, being duly sworn, state that I am Vice President Nine Mile Point, and that I am duly authorized to execute and file this request on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in ac ordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the State of New York and County of Oswego, this Oeyday of B y-

, 2003.

WITNESS my Hand and Notarial Seal:

Notary Public

>j4-4

)

JQ My Commission Expires:

Date If /zo 103 SANDRA A. OSWALD Notary Public, State of New York No. o0os6032276 Qualified In Oswego Calw Commission Expires

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Page 3 NMP2L 2104 Attachments:

1. Evaluation of Proposed Technical Specification Changes

2. Proposed Technical Specification Changes (Mark-up)

3. List of Regulatory Commitments

4. Attachment to Global Nuclear Fuel Letter No. EWG-N-03-02 1, dated October 3, 2003, titled "Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10" (Proprietary)

5. Affidavit by Global Nuclear Fuel for Withholding Proprietary Information

6. Attachment to Global Nuclear Fuel Letter No. EWG-N-03-021, dated October 3, 2003, titled "Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10" (Non-Proprietary) cc:

Mr. H. J. Miller, NRC Regional Administrator, Region I Mr. G. K. Hunegs, NRC Senior Resident Inspector Mr. P. S. Tam, Senior Project Manager, NRR (2 copies)

Mr. J. P. Spath, NYSERDA

ATTACHMENT 1 EVALUATION OF PROPOSED TECHNICAL SPECIFICATION CHANGES

Subject:

License Amendment Request: Revised Safety Limit Minimum Critical Power Ratio in Technical Specification 2.1.1.2

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS

1.0 DESCRIPTION

Section 2.1.1.2 of the Nine Mile Point Unit 2 (NMP2) Technical Specifications (TS) contains Safety Limit Minimum Critical Power Ratio (SLMCPR) values of 1.06 and 1.07 for two recirculation loop operation and single recirculation loop operation, respectively. Cycle-specific calculations performed by the NMP2 fuel vendor, Global Nuclear Fuel (GNF), for the upcoming NMP2 Operating Cycle (OC-10) have resulted in higher SLMCPR values of 1.07 and 1.09 for two recirculation loop operation and single recirculation loop operation, respectively. The cycle specific calculations considered, besides other factors, the planned use of a mixed core containing predominantly GEl1 fuel with some new GE14 fuel during OC-10 whereas the current Operating Cycle (OC-9) uses a full core of GE 1I fuel. The proposed change incorporates the new SLMCPR values in TS 2.1.1.2 in order to maintain the appropriate conservative margin relative to the conditions required for fuel cladding integrity.

Nine Mile Point Nuclear Station, LLC (NMPNS) requests approval of this license amendment request by March 1, 2004. This will support plans to load GE14 fuel into the core during the next refueling outage (RFO9), which is currently scheduled to begin in March 2004.

2.0 PROPOSED CHANGE

TS 2.1.1.2 currently requires that with the reactor steam dome pressure greater than or equal to 785 psig and core flow greater than or equal to 10 percent rated core flow, the minimum critical power ratio (MCPR) shall be greater than or equal to 1.06 for two recirculation loop operation, or greater than or equal to 1.07 for single recirculation loop operation. The proposed change revises these SLMCPR values to 1.07 and 1.09, respectively.

3.0 BACKGROUND

The proposed change revises the SLMCPR values in NMP2 TS 2.1.1.2 to reflect the results of a plant-specific evaluation performed by GNF for OC-10. This SLMCPR evaluation was performed using NRC approved methodology, as described in Amendment 25 to NEDE-2401 1-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR II)," (Reference 1) and other NRC approved vendor documents, which are referenced in Attachments 4 and 6. The analysis methodology incorporates plant and cycle-specific parameters that include: 1) the expected reference loading pattern; 2) conservative variations of projected control blade patterns;

3) the actual bundle parameters; 4) the full cycle exposure range; and 5) reduced power distribution uncertainties associated with the process computer system. Table I of Attachments 4 and 6 provides a summary of the relevant input parameters and results of the SLMCPR value determinations for both OC-10 and OC-9 cores, including identification of differences in the two core and bundle designs and the impact of these differences on the calculated SLMCPR values.

As indicated in Table 1 of Attachments 4 and 6, the NRC approved (Reference 2) reduced power distribution uncertainties have been applied in the OC-10 analyses. These uncertainties were also included in the previous NRC approved SLMCPR evaluation for OC-9 (Reference 3) and, therefore, do not constitute a change for OC-10.

Page 1 of5

4.0 TECHNICAL ANALYSIS

The fuel cladding is one of the principal barriers to the release of radioactive materials to the environment. The SLMCPR is applied to ensure that fuel cladding integrity is not lost due to overheating during normal plant operation and anticipated transients. The SLMCPR is set such that no mechanistic fuel damage is calculated to occur if the limit is not violated. Since the parameters that result in fuel damage are not directly observable during reactor operation, the thermal and hydraulic conditions resulting in a departure from nucleate boiling have been used to mark the beginning of the region where fuel damage could occur. Although it is recognized that a departure from nucleate boiling would not necessarily result in damage to BWR fuel rods, the critical power at which boiling transition is calculated to occur has been adopted as a convenient limit. However, the uncertainties in monitoring the core operating state and in the procedures used to calculate the critical power result in an uncertainty in the value of the critical power.

Therefore, the SLMCPR is defined as the critical power ratio in the limiting fuel assembly for which more than 99.9 percent of the fuel rods in the core are expected to avoid boiling transition considering the power distribution within the core and all uncertainties.

The GNF evaluation for the OC-IO mixed core design has concluded that the calculated SLMCPR values of 1.07 for two recirculation loop operation and 1.09 for single recirculation loop operation are appropriate when the approved methodology and the reduced uncertainties given in General Electric Topical Reports NEDC-32601P-A and NEDC-32694P-A are used. The limiting SLMCPR values for both two loop and single loop operation occur at the end of cycle (EOC). The calculated values, rounded to two digits, are shown in Table 2 of Attachments 4 and 6, and include a penalty for top-peaked power shape in GE14 fuel bundles. Factors contributing to the increase in the SLMCPR values from their current TS values are discussed in Attachments 4 and 6.

NRC generic questions pertaining to how GE14 applications satisfy the conditions of the NRC's safety evaluation (Reference 2) regarding NEDC-32601P-A and NEDC-32694P-A have been addressed in Reference 4. Other generically applicable questions relating to applications of the GEXL14 correlation and the applicable range for the R-factor methodology are addressed in Reference 5. The NMP2 specific core loading information for OC-10 and OC-9 is provided in Figures 1 and 2, respectively, of Attachments 4 and 6. The MCPR Importance Parameter (MIP) and R Factor Importance Parameter (RIP) values for NMP2 OC-9 and OC-I0 are provided in Table 1 of Attachment 4.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration The proposed change revises the Safety Limit Minimum Critical Power Ratio (SLMCPR) values stated in Nine Mile Point Unit 2 (NMP2) Technical Specification (TS) 2.1.1.2.

This revision reflects the results of cycle-specific calculations performed by the fuel vendor, Global Nuclear Fuel, for the next NMP2 Operating Cycle (OC-IO), using NRC-Page 2 of 5

approved methodology for determining SLMCPR values. The revision will maintain the appropriate conservative margin in TS 2.1.1.2 for OC-10.

Nine Mile Point Nuclear Station, LLC (NMPNS) has evaluated whether or not a significant hazards consideration is involved with the proposed change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below.

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The revision to the Safety Limit Minimum Critical Power Ratio (SLMCPR) values stated in TS 2.1.1.2 has been performed for OC-10 using NRC-approved methods and uncertainties. The analysis methodology incorporates appropriate cycle-specific parameters and reduced power distribution uncertainties in determining the revised SLMCPR values. The analyses do not change the method of operating the plant and have no effect on the probability of an accident initiating event or transient.

The SLMCPR ensures that no mechanistic fuel damage occurs in the core if the limit is not violated. The revised SLMCPR values maintain the appropriate conservative margin to transition boiling and the probability of fuel damage is not increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The revised SLMCPR values for the OC-10 core reload have been calculated in accordance with NRC approved methods and uncertainties. The changes do not involve any new method for operating the facility and do not involve any facility modifications. No new initiating events or transients result from these changes.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Page 3 of 5

The proposed change does not reduce a margin of safety as defined in the TS bases. The increased cycle-specific SLMCPR values are calculated using NRC-approved methods and uncertainties, which are in accordance with the current fuel design and licensing criteria. These increased values are high enough to ensure that greater than 99.9 percent of all fuel rods in the core are expected to avoid transition boiling if the limits are not violated, thereby maintaining the fuel cladding integrity during normal plant operation and anticipated transients.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, NMPNS concludes that the proposed amendment involves no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria The proposed Operating Cycle 10 SLMCPR values will continue to ensure that 99.9 percent of the fuel rods in the core do not experience boiling transition during any condition of normal operation, including the effects of anticipated operational occurrences. Therefore, the requirements of GDC 10, "Reactor Design," regarding acceptable fuel design limits will continue to be met.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed revision to the SLMCPR values stated in TS 2.1.1.2 would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page 4 of 5

7.0 REFERENCES

1. Amendment 25 to NEDE-2401 1-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR II)," dated December 13, 1996

2. Letter, Frank Akstulewicz (NRC) to Glen A. Watford (GE), "Acceptance for Referencing of Licensing Topical Reports NEDC-32601P, Methodology and Uncertainties for Safety Limit MCPR Evaluations; NEDC-32694P, Power Distribution Uncertainties for Safety Limit MCPR Evaluation; and Amendment 25 to NEDE-2401 1-P-A on Cycle Specific Safety Limit MCPR," (TAC Nos. M97490, M99069 and M97491), dated March 11, 1999

3. Amendment 105 to NMP2 Facility Operating License No. NPF-69, dated March 13, 2002

4. Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of 1 OXI 0 Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies," FLN-2001-016, September 24, 2001

5. Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Final Presentation Material for GEXL Presentation - February 11, 2002," FLN-2002-004, February 12, 2002 Page 5 of 5

ATTACHMENT 2 Proposed Technical Snecification Chanees (Mark-up)

The current version of Technical Specifications page 2.0-1 has been marked-up by hand to reflect the proposed change.

SLs 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 psig or core' flow < 10% rated core flow:.

THERMAL POWER shall be *25% RTP.

2.1.1.2 With the reactor steam dome pressure 2 785 psig and core flow > 10% rated core flow:

..MCPR shall be dfor two recirclation loop operation

.or Žf for single recirculation loop operation.

2.1.1.3 Reactor vessel water level shall be greater than the top of active irradiated fuel.

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be

• 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within

.2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

2.2.1

-Restore compliance with all SLs; and 2.2.2 Insert all insertable control rods.

NMP2 2.0-1 Amendment 94, t0

ATTACHMENT 3 List of Reiulatory Commitments The following table identifies those actions committed to by Nine Mile Point Nuclear Station, LLC (NMPNS) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT DUE DATE None N/A

ATTACHMENT 5 Affidavit by Global Nuclear Fuel for Withholding Proprietary Information

Affidavit Affidavit 1, Margaret E. Harding, state as follows:

(1) I am Manager, Fuel Engineering Services, Global Nuclear Fuel -Americas, L.L.C. ("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 the attachment, "Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10," October 2, 2003. GNF proprietary information is indicated by enclosing it in double brackets. In each case, the superscript notation

13) 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 2.790(a)(4) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information," and some portions 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 Proiect v. Nuclear Regulatory Commission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (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;

c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, of potential commercial value to GNF-A;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

Affidavit 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 the 10 CFR 2.790 (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. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. 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.

(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. Access to such documents within GNF-A is limited on a "need to know" basis.

(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, on the order of several million dollars, 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 fuel design and licensing methodology is part of GNF-A's 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 or its licensor.

Affidavit 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 affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed at Wilmington, North Carolina, this 3rd day of

October, 2003.

Margaret E. HardF A

n Global Nuclear Fuel - Amen s, ILIC

ATTACHMENT 6 Attachment to Global Nuclear Fuel Letter No. EWG-N-03-021, dated October 3, 2003, titled "Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10" (Non-Proprietary)

Attachment Additional Information Regarding the 2 October 2003 Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10 References

[1]

Letter, Frank Akstulewicz (NRC) to Glen A. Watford (GE), "Acceptance for Referencing of Licensing Topical Reports NEDC-32601P, Methodology and Uncertainties for Safely Limit MCPR Evaluations; NEDC-32694P, Power Distribution Uncertainties for Safety Limit MCPR Evaluation; and Amendment 25 to NEDE-2401 1-P-A on Cycle Specific Safety Limit MCPR,"

(TAC Nos. M97490, M99069 and M97491), March 11, 1999.

[2]

Letter, Thomas H. Essig (NRC) to Glen A. Watford (GE), "Acceptance for Referencing of Licensing Topical Report NEDC-32505P, Revision 1, R-Factor Calculation Methodfor GEl),

GE12 and GEJ3 Fuel," (TAC Nos. M99070 and M95081), January 11, 1999.

[3]

General Electric BWR Thermal Analysis Basis (GETAB): Data, Correlation and Design Application, NEDO-10958-A, January 1977.

[4]

Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of IOx1O Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies", FLN-2001-016, September 24, 2001.

[5]

Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Confirmation of the Applicability of the GEXL14 Correlation and Associated R-Factor Methodology for Calculating SLMCPR Values in Cores Containing GE14 Fuel", FLN-2001-017, October 1, 2001

[6]

Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), 'Tinal Presentation Material for GEXL Presentation

- February 11, 2002", FLN-2002-004, February 12, 2002.

Comparison of Nine Mile Point Unit 2 Cycle 10 SLMCPR Value Table 1 summarizes the relevant input parameters and results of the safety limit MCPR (SLMCPR) determination for the Nine Mile Point Unit 2 Cycle 10 and Cycle 9 cores. The SLMCPR evaluations were performed using NRC approved methods and uncertainties 1[J In comparing the Nine Mile Point Unit 2 Cycle 10 and Cycle 9 SLMCPR values it is important to note the impact of the differences in the core and bundle designs. These differences are summarized in Table 1.

In general, the calculated safety limit is dominated by two key parameters: (1) flatness of the core bundle-by-bundle MCPR distributions and (2) flatness of the bundle pin-by-pin power/R-factor distributions. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR.

page 1 of 7 DRF #0000-0017-0870

Attachment Additional Information Regarding the 2 October 2003 Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10 1[~~~~~~~~~~~~~~~~~~~1 The uncontrolled bundle pin-by-pin power distributions were compared between the Nine Mile Point Unit 2 Cycle 10 bundles and the Cycle 9 bundles. Pin-by-pin power distributions are characterized in terms of R-factors using the NRC approved methodology

1. For the Nine Mile Point Unit 2 Cycle 10 limiting case analyzed at EOC, ((

)) the Nine Mile Point Unit 2 Cycle 10 bundles are more peaked than the bundles used for the Cycle 9 SLMCPR analysis.

As indicated in Table 1, the NRC-approved [I1 reduced power distribution uncertainties have been applied for the Nine Mile Point Unit 2 Cycle 10 analyses. These reduced power distribution uncertainties were also included in the previous SLMCPR calculation for Nine Mile Point Unit 2 Cycle 9 and do not constitute a change for the new operating cycle.

The revised power distribution model and reduced uncertainties associated with 3D Monicore have been justified, reviewed and approved by the NRC (reference NEDC-32601P-A and NEDC-32694P-A). The conservatism that remains even when applying the revised model and reduced uncertainties to calculate a lower SLMCPR was documented as part of the NRC review and approval. It was noted on page A-24 of NEDC-32601P-A ((

1))

These calculations use the GEXL14 correlation for GE14 fuel. The SLMCPR penalty associated with a top-peaked power shaped in GE14 bundles has been incorporated directly into the calculated value by applying the higher GEXL14 uncertainty and bias indicated on sheet 35 of the presentation materials attached to Reference [6].

The details of the evaluation are provided in Table 2.

A SLMCPR penalty of 0.016 is included in the value at EOC; becoming the limiting SLMCPR for this cycle. Top-peaked power shapes were present only at EOC. The potential impact of a bias on the calculated SLMCPR due to a double-humped axial power shape was considered. For this plant and cycle, no double-humped power shapes were present. The DLO and SLO SLMCPR values calculated for Cycle 10 of Nine Mile Point Unit 2 are shown in Table 1. Other quantities that have been shown to have some impact on the determination of the SLMCPR are also shown in Table 1.

Summary page 2 of 7 DRF #0000-0017-0870

Attachment Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10 2 October 2003

((

)) have been used to compare quantities that impact the calculated SLMCPR value.

Based on these comparisons, the conclusion is reached that the Nine Mile Point Unit 2 Cycle 10 core/cycle has a more peaked core MCPR distribution ((

)) than what was used to perform the Cycle 9 SLMCPR evaluation; and the Nine Mile Point Unit 2 Cycle 10 core/cycle has a more peaked in-bundle power distributions ((

)) than what was used to perform the Cycle 9 SLMCPR evaluation.

Both of these characteristics help to mitigate [I

)) so that a net increase of 0.01 from Cycle 9 is realized. The potential impact of a bias on the calculated SLMCPR due to a double-humped axial power shape was considered. For this plant and cycle, no double-humped power shapes were present.

The calculated 1.07 Monte Carlo SLMCPR for Nine Mile Point Unit 2 Cycle 10 is consistent with what one would expect ((

)) the 1.07 SLMCPR value is appropriate when the approved methodology and the reduced uncertainties given in NEDC-32601P-A and NEDC-32694P-A are used.

Based on all of the facts, observations and arguments presented above, it is concluded that the calculated SLMCPR value of 1.07 for the Nine Mile Point Unit 2 Cycle 10 core is appropriate.

For single loop operations (SLO) the calculated safety limit MCPR for the limiting case is 1.09 as determined by specific calculations for Nine Mile Point Unit 2 Cycle 10. The limiting value for SLO occurs at EOC.

page 3 of 7 DRF #0000-0017-0870

Attachment Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10 2 October 2003 Supporting Information The following information is provided in response to NRC questions on similar submittals regarding changes in Technical Specification values of SLMCPR. NRC questions pertaining to how GE14 applications satisfy the conditions of the NRC SER Ill have been addressed in Reference [4]. Other generically applicable questions related to application of the GEXL14 correlation and the applicable range for the R-factor methodology are addressed in Reference [5]. Only those items that require a plant/cycle specific response are presented below since all the others are contained in the references that have already been provided to the NRC.

The core loading information for Nine Mile Point Unit 2 Cycle 10 is provided in Figure 1. For comparison the core loading information for Nine Mile Point Unit 2 Cycle 9 is provided in Figure 2.

The impact of the fuel loading pattern differences on the calculated SLMCPR is correlated to the values of((

1))

The SLO value at EOC includes a penalty for top-peaked power shape and remains at 1.09 when rounded to two-digits as seen in Table 2. It is typical to see an SLO value that is 0.01 to 0.02 higher than the DLO value.

Prepared by:

.4. Butrovich Globnical Program Manager Gobal Nuclear Fuel - Americas Verified by:

Technical Program Manager Global Nuclear Fuel - Americas page 4 of 7 DRF #0000-0017-0870

Attachment Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10 2 October 2003 Table 1 Comparison of the Nine Mile Point Unit 2 Cycle 10 and Cycle 9 SLMCPR QUANTITY, DESCRIPTIONNine Mile Point Nine Mile Point Unit 2 Unit 2 Cycle 9 Cycle 10 Number of Bundles in Core 764 764 Limiting Cycle Exposure Point PHE EOC Cycle Exposure at Limiting Point 10,000 14,000

[MWd/ST_

(EOC-1325)

Reload Fuel Type GEI I GE14 Latest Reload Batch Fraction [%]

37.2 37.2 Latest Reload Average Batch Weight %

4.06 4.04 Enrichment Batch Fraction for GE14 [%I 0.0 37.2 Batch Fraction for GEII [%

100.0 62.8 Core Average Weight % Enrichment 4.09 4.05 Core MCPR (for limiting rod pattern) 1.27 1.A0

[r X

1 Power distribution methodology Revised Revised NEDC-32601P-A NEDC-32601P-A Power distribution uncertainty Reduced Reduced NEDC-32694P-A NEDC-32694P-A Non-power distribution uncertainty Revised Revised NEDC-32601P-A NEDC-32601P-A Calculated Safety Limit MCPR (DLO) 1.06 1.07 Calculated Safety Limit MCPR (SLO) 1.07 1.09 Table 2 Net Adjustment to SLMCPR to Account for Top-Peaked Power Shapes Dual Loop Ops.

I Single Loop Ops.

l BOc PHE EOC BOC EOC I

Calculated M/C SLMCPR 1.0699 1.0541 1.0552 1.0855 1.0707 Penalty for top-peaked power shape 0.000 0.000 0.0163 0.000 0.0156 Credit for Reduced Uncertainties 0.000 0.000 0.000 0.000 0.000 Was power shape outlet peaked?

N N

Y N

Y Adjusted SLMCPR without rounding 1.0699 l 1.0541 1.0715 1.0855 1.0863 SLMCPR for Tech Spec Submittal DLO 1.07 SLO 1.09 page 5 of 7 DRF #0000-0017-0870

Attachment Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10 2 October 2003 Figure 1 Reference Core Loading Pattern - Cycle 10

~~~.

60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 08 06 04 02 13112112113113113113113113113113112112113 131121121151121131121 9 9 112112112115112112113 121121214115115114 i1511511-511511511511411511511411211 10 1 12 114 1181181191181181181121121181181181 19118118114 112110 131131161 18119114117151191141181181141191151171141191181 6113113 1312 13 9

1~7 14l 17l 16l 9114118l 16l16l 18l14l19l116l17l1411717 113 1~

12112116117117115 119116119115119114119119114119115119116119115117117116112112 1217 114 118117115118116118114118116118115115118116118114118116118115117118116I 7112 13 12 15 18 19 14 19 16 19 14 19 18 13 15 19 19 15 13 18 19 14 19 16 19 14 19 18 15 12 13 12 12 15 18 15 17 15 18 14 19 14 16 18 15 16 16 15 18 16 14 19 14 18 15 17 16 18 15 12 12 13 15 15 19 17 16 19 14 19 14 17 18 14118 19 19 18 14118 17 14 19114119 16 17 19 15 15 13 13 12 14 18 15 19 15 18 18 16 18 12 18112 16 16 12 18 12 18 16 18118 15 19 16 18114 12 13 13 12 15 18 19 14 19 16 12 18 14 18 15118 14 14 18 15 18 14 18 12116 19 14 19 18 15 12 13 13 12 15 18 18 14 18 15 151812181419 11418 121815151814181518151213 13 15 15 13 18 16 19 16 19 16 19 16 1419 12 12 19114 16 19 16 191619 16 18 13 15 14 13 13 14 15 13 18 16 19 16 19 16 19 16 14 19 12 12 19 14 16 19 16 19 16 19 16 18 13 15 15 13 13 12 15 18 15 18 14 18 15 15 18 12 18 14 19 19 14 18 12 18 15 15 18 14 18 15 18 15 12 13 13 12 15 18 19 14 19 16 12 18 14 18 15 18 14 14 18 15 18 14 18 12 16 19 14 19 18 15 12 13 13 12 14 18 16 19 15 18 18 16 18 12 18 12 16 16 12 18 12 18 16 18118 15 19116118 14 12 13 13 15 15 19 17 16 19 14 19 14 17 18 14 18 19 19 18 14 18 17 14 19 14 19 16 17 19 15 15 13 12 12 15 18 16 17 15 18 14 19 14 16 18 15116116115 18 16 14 19 14118 15 17116118115112 13 12 15 18 19 14 19 16 19 14119118112115119119115113118 19 14 19 16 19 14119118151213 121 7 114118117115118116t18114118116118115115118116118114118116118115117118115I 7 112 121121161171171 151191161191151191141191191141191151191161191151171 17116112112 11 112113112117117 14 17 16 19 14 18 16 16 18 14 19116117114117 17 12 13 12113 131131 161 1811911411711511911411811811411911511711411911811611313 10 112114 1181181191181181181 12112181181181191181181141121 10 12112112114115116114115115115115115115114115115114112 1212 131121121-511211-21121_ 9 1 9 12 113r12 11-5 11-212113

.13112112113113 1131131-3113113113112112113 01 03 05 07 09 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 IAT Bundle Name No.

Cycle Loaded IAT Bundle Name 7

9 10 11 12 13 GE11-P9CUB349-10GZ1-120M-146-T GE11-P9CUB375-12GZ-120T-146-T GE11-P9CUB413-12GZ-120T-146-T GE 1-P9CUB414-13GZ-120T-146-T GE 1-P9CUB407-14GZ-120T-146-T.2382 GE1 1-P9CUB407-14GZ-120T-146-T-2383 4

4 4

1 110 73 5

6 7

7 8

8 14 15 16 17 18 19 GE 1-P9CUB404-12GZ-120T-146-T-2501 GE 1-P9CUB407-14GZ-1 20T-146-T-2502 GE 1-P9CUB407-14GZ-120T-146-T-2503 GE14-P1 OCNAB406-15GZ-120T-150-T-2674 GE14-P1OCNAB404-15GZ-120T-150-T-2675 GE14-P1 OCNAB403-17GZ-120T-1 50-T.2676 No.

Cycle Loaded 96 9

108 9

80 9

40 10 140 10 104 10 page 6 of 7 DRF #0000-0017-0870

Attachment Additional Information Regarding the Cycle Specific SLMCPR for Nine Mile Point Unit 2 Cycle 10 2 October 2003 Figure 2 Reference Core Loading Pattern - Cycle 9 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 08 06 04 02 iol iou ii jolot 10110111111111101101111101 I

I I

I I

I I

I I

I I

iolioliolioiolii~lillioioiOil~ii~lioliollOlOl T

io 11 1i3l12l12l12l13 12 15 15 12 13 12 12112113 1111 10 10111112114114115114115115113113115115114 15114114112111110 l

l l

l l

10ii i211515131161131151131161161131151131161131' 15 12111 10 li 10l ltl 15 l3l1511311*5112114 13113114112115113115 1e315115 10 10 gql 121515 121161121161121141101141141101 14112116112116112115 1151 12111111

.~~~~~~~~~~~~~~~~~~~

t10 11r12 FSII415 -141 nII 12116121121214110110114112111112116113114112115115112l 11 110 10 10 12 14 15 13 16113115112 14 14 11 12116 1611211114114 12 1511311613 15 14121010 11 10 12 14 13 15 3

15 10 13 16 12 13 13 12 16 13 10 15 12 16 13 15 13 14 12 10 11l 10 11 12 15 16 13 16 12 14 10 14 14 12 16 16 16 16 12 14 14 10 14 12 16 13 16 15 12 11 10 11 10 12 14 13 15 13 11 14 13 14 11 14 11 13 13 11 14 1114 13 14 11 13 15 13 14 12 10 11 10 11 12 15 15 12 14 12 11 16 13 14 13 15 12 12 15 13 14 13 16 11 12 14 12 15 15 12 11 10 10 11 12 15 13 14 10 14 12 13 16 10 15 12 16 16 12 15 10 16 13 12 14 10 14 13115 12 11 10 10 10 15 12 16 13 14 10 16 13 16 13 13 16 11 1116 13 13 16 13 16 10 14 13 16 12 15 10 10 10 10 15 12 16 13 14 10 16 13 16 13 13 16 11 11 16 13 13 16 13 1 10 14 13 16 12 15 10 10 10 1112 15 13 14 10 14 12 13 16 10 15 12 16 16 12 15 10 16 13 12 14 10 14 13 15 12 1110 10 1112 15 15 12 14 12 1116 13 14 13 15 12 12 15 13 14 13 16 11 12 14 12 15 15 12 11 10 11 10112.14.13 15 13111 1413 1411141113 13 11 14 1114 13 14 11 1315 13 14 121011 10 11 12 15 16 13 16 12 14 10 14 14 12 16 16 16 16 12 14 14 10 14 12 16 13 16 15 12 11 10 1110 12 14 13 15 13 16 12 15 10 13 16 12 13 13 12 16 13 10 15 1 16 13 15 13 14112 10 11 10 10 1211415 131613112 14 141112 1 6 12 11 141412 15 13 16 13 15T 1

1010 10111 112115115112114113116112111 1121141011011411211111211611:1!41211511512l11 110 11111112115115112116112116112114110114114110114112161121161121151151 12111111 11 10 10110115115113115.1315112114113113114112115113115 1:15 15 10 10 IW 101 11 112115151.131161131 13M16116113115113116113 1!5111121 11 I10 10111112114114115114115115113113115115114115114114112111110 10hii iI13 12Ila 12 13 12 15I15 12(13] 1212 12f1: 11 1110 1CI0101101o1¶o1ioltliolioi illiollolioliolio 10!lioliljioIIo~lo~liliiliohlo~loi 1111011 01 03 05 07 09 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 IAT Bundle Name 10 GE11.P9CUB413-12GZ-120T-146-T 11 GE11-P9CUB414-13GZ-120T-146-T 12 GE1-P9CUB407-14GZ-120T-146-T-2382 13 GE11-P9CUB407-14GZ-120T-146-T-2383 No.

Cycle Loaded 136 7

96 7

132 8

116 8

IAT Bundle Name 14 GE11-P9CUB404-12GZ-120T-146-T-2501 15 GE11-P9CUB407-14GZ-120T.146-T-2502 16 GE11-P9CUB407-14GZ-120T-146-T-2503 No.

Cycde Loaded 96 9

108 9

80 9

page 7 of 7 DRF #0000-0017-0870