RS-07-157, Request for Technical Specification Change for Minimum Power Ratio Safety Limit

Request for Technical Specification Change for Minimum Power Ratio Safety Limit

ML073250364
Person / Time
Site:	Quad Cities
Issue date:	11/20/2007
From:	Simpson P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAW-07-2355, RS-07-157 NF-BEX-07-209, Rev 0
Download: ML073250364 (60)

Text

RS-07-157 November 20, 2007 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001

Subject:

Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit,"

Exelon Generation Company, LLC (EGC) requests an amendment to Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS),

Unit 1 and Unit 2, respectively. The proposed change revises the values of the safety limit minimum critical power ratio (SLMCPR) in Technical Specification (TS) Section 2.1.1, "Reactor Core SLs." Specifically, the proposed change would delete the QCNPS Unit 2 fuel-specific SLMCPR requirements for Global Nuclear Fuel (GNF) GE14 fuel and consolidate the Unit 1 and Unit 2 SLMCPR requirements into a bounding dual-unit requirement. This change is needed to support the next cycle of Unit 2 operation.

vvwuv eXeloncorp com Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 This request is subdivided as follows. provides an evaluation supporting the proposed change.

Exellon contains an affidavit and non-proprietary version of Attachment 3.

Nuclear 10 CFR 50.90 contains the marked-up TS page, with the proposed change indicated. provides a description of the SLMCPR evaluation for QCNPS Unit 2 Cycle 20, as well as a summary of the Westinghouse establishment of a critical power ratio correlation for GNF GE14 fuel.

November 20, 2007 U. S. Nuclear Regulatory Commission Page 2 The proposed change has been reviewed by the QCNPS Plant Operations Review Committee and approved by the EGC Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program and EGC procedures.

EGC requests approval of the proposed change by March 3, 2008, to support startup following the next refueling outage for Unit 2 (i.e., 02R 19), which is scheduled to start in March 2008.

Once approved, the amendment will be implemented prior to startup from Q2R19. This implementation period will provide adequate time for the affected station documents to be revised using the appropriate change control mechanisms.

In accordance with 10 CFR 50.91(b), EGC is notifying the State of Illinois of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official. contains information proprietary to Westinghouse Electric Company, LLC; it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit, provided in Attachment 4, sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390, "Public inspections, exemptions, requests for withholding."

Accordingly, it is requested that the information be withheld from public disclosure in accordance with 10 CFR 2.390. A non-proprietary version of the information contained in Attachment 3 is also provided in Attachment 4.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. John L. Schrage at (630) 657-2821.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 20th day of November 2007.

Patrick R. Simpson Manager - Licensing Attachments: : : : :

Evaluation of Proposed Change Markup of Proposed Technical Specifications Page Quad Cities Unit 2 Cycle 20 SLMCPR (PROPRIETARY)

Westinghouse Application for Withholding, Affidavit, and Non-Proprietary Version of Attachment 3

ATTACHMENT 1 Evaluation of Proposed Change 1.0 DESCRIPTION

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria

7.0 REFERENCES

1.0 DESCRIPTION ATTACHMENT 1 Evaluation of Proposed Change In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit,"

Exelon Generation Company, LLC (EGC) requests an amendment to Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS),

Unit 1 and Unit 2, respectively. The proposed change revises Technical Specification (TS)

Section 2.1.1, "Reactor Core SLs." Specifically, the proposed change would delete the QCNPS Unit 2 fuel-specific SLMCPR requirements for Global Nuclear Fuel (GNF) GEl4 fuel and consolidate the Unit 1 and Unit 2 SLMCPR requirements into a bounding dual-unit requirement.

The proposed TS will then require that, for both Unit 1 and Unit 2, SLMCPR shall be _> 1.11 for two recirculation loop operation, or _> 1.13 for single recirculation loop operation, irrespective of fuel type (i.e., either GE14 fuel or Westinghouse SVEA-96 Optimal fuel). This change is needed to support the next cycle of Unit 2 operation. The proposed change is described below.

2.0 PROPOSED CHANGE

TS Section 2.1.1.2 specifies the value for the SLMCPR. The current TS states :

For Unit 1, MCPR shall be _> 1.11 for two recirculation loop operation or _> 1.13 for single recirculation loop operation.

For Unit 2, MCPR for GNF fuel shall be > 1.09 for two recirculation loop operation, or

> 1.10 for single recirculation loop operation. MCPR for Westinghouse fuel shall be

> 1.11 for two recirculation loop operation, or _> 1.13 for single recirculation loop operation.

The proposed change will revise TS Section 2.1.1.2 to read as follows.

For two recirculation loop operation, MCPR shall be _> 1.11, or for single recirculation loop operation, MCPR shall be > 1.13.

The consolidation of the Unit 1 and Unit 2 SLMCPR requirements into a bounding dual-unit requirement is administrative, and does not change the current SLMCPR TS value for either Unit 1 or the SVEA-96 Optimal fuel SLMCPR value for Unit 2. provides the marked-up TS page indicating the proposed change.

3.0 BACKGROUND The fuel cladding integrity SLMCPR is established to assure that at least 99.9% of the fuel rods in the core do not experience boiling transition during an anticipated operational occurrence (AOO). To determine the explicit value for the cycle specific safety limit, a full core statistical analysis is performed. The core model incorporates the uncertainty in the measurement of core operating parameters, critical power ratio (CPR) calculation uncertainties, and the statistical uncertainty associated with the fuel vendor's correlation. The model also calculates the number of rods that might experience boiling transition as a function of the nominal MCPR.

4.0 TECHNICAL ANALYSIS

Unit 2 Cvcle 20 Core_ Loading Pattern ATTACHMENT 1 Evaluation of Proposed Change Prior to QCNPS Unit 2 fuel cycle 19 (i.e., Q2C19, the current fuel cycle), the NRC-approved GNF methodology (References 1 and 2) was used to determine the appropriate SLMCPR values for GNF GE14 fuel assemblies. EGC loaded Westinghouse SVEA-96 Optima2 fuel assemblies in QCNPS Unit 2 for 02C1 9, with the result being a mixed core containing both GE14 and SVEA-96 Optima2 fuel assemblies. Unlike the GNF methodology, the NRC-approved Westinghouse methodology (Reference 3) generates a unique SLMCPR value for each fuel product line present in the core. However, based on a previously approved, and similar amendment for QCNPS Unit 1 Cycle 20 (Reference 4), as well as previous discussions with the NRC related to the Westinghouse methodology, EGC will apply the more conservative SVEA-96 Optima2 fuel SLMCPR to all fuel types in Q2C20, rather than utilizing the previously calculated SLMCPR for the GE14 fuel.

In Reference 5, the NRC issued a license amendment for QCNPS that, in part, revised TS Section 5.6.5, "Core Operating Limits Report (COLR)," to allow Westinghouse methodologies, which have been generically approved by the NRC, to be used for core reload evaluations. The methodology used for SLMCPR evaluations is described in Reference 3, which was approved for use at QCNPS as part of the Reference 5 amendment. provides a description of the SLMCPR evaluation for QCNPS Unit 2 Cycle 20, as well as a summary of the Westinghouse establishment of a CPR correlation for GNF GE14 fuel.

In addition, the following information is provided to support the proposed change, since this information was requested in support of a previously approved amendment for QCNPS Unit 2 (Reference 6).

The QCNPS Unit 2 Cycle 20 core loading pattern was developed via a design collaboration between EGC and Westinghouse. Both Westinghouse and EGC used NRC-approved lattice physics codes and three-dimensional simulator codes to perform bundle and core design calculations, respectively. The Westinghouse core reload design group performed design calculations using the PHOENIX lattice physics code and the POLCA7 three-dimensional simulator code, while the EGC Nuclear Fuels (NF) department core reload design group used the CASM04 lattice physics code and MICROBURN-B2 three-dimensional simulator code.

The core loading pattern was developed, reviewed, and approved in accordance with the EGC core reload design process and procedures. Consistent with this, NF worked with QCNPS to develop and document the design goals, constraints, and requirements for the reload cycle.

Westinghouse design and manufacturing requirements were also incorporated. The Unit 2 Cycle 20 design criteria were approved by QCNPS and NF management prior to the development and finalization of the core loading pattern.

Using the approved design criteria, Westinghouse and NF core reload design engineers performed iterations on proposed SVEA-96 Optima2 bundle designs and core loading patterns.

Designs were modeled and evaluated in both the Westinghouse POLCA7 core model and the NF MICROBURN-B2 core model. Engineers in both organizations reviewed proposed designs and collectively revised these designs until the design criteria were met. Based on a

ATTACHMENT 1 Evaluation of Proposed Change comparison of the results from both core models to the design criteria, the core design was determined to ensure that cycle energy requirements, operating thermal margin goals, licensing requirements, and other design criteria were satisfied. In addition, the final bundle designs were reviewed to ensure that they comply with the Westinghouse SVEA-96 Optima2 fuel manufacturing criteria.

For QCNPS Unit 2 Cycle 20, EGC will load Westinghouse SVEA-96 Optima2 fuel assemblies for the second consecutive operating cycle, with the result being a mixed core containing both GE14 and SVEA-96 Optima2 fuel assemblies. Therefore, the Westinghouse NRC-approved methodology described in Reference 3 was used to determine the SLMCPR values for Cycle 20. Since QCNPS Unit 2 Cycle 20 will be a mixed core, the Westinghouse methodology was used to determine appropriate SLMCPRs for application to the GE14 fuel, and separate SLMCPRs for application to the SVEA-96 Optima2 fuel. However, based on previous discussions with the NRC related to the Westinghouse methodology, EGC will apply the more conservative SVEA-96 Optima2 fuel SLMCPR to both fuel types in QCNPS Unit 2 Cycle 20, rather than establishing a unique SLMCPR for the GE14 fuel. This conservative approach was also applied to the SLMCPR requirement for QCNPS Unit 1 Cycle 20 (Reference 4). For QCNPS Unit 2 Cycle 20, this approach adds additional conservatism since the GE14 fuel assemblies will be in the third cycle of irradiation and thus will operate at sufficiently low assembly powers, such that the GE14 Critical Power Ratio limits will not be challenged.

The prediction of the cycle energy capability for a given core design is dependent on the hot reactivity bias (i.e., hot target eigenvalue) that is assumed for the design cycle. This reactivity bias is also dependent on the three-dimensional core simulator code used to perform the design. Since the QCNPS Unit 2 Cycle 20 core design was developed in collaboration between Westinghouse and NF using both the POLCA7 and MICROBURN-B2 core models, separate reactivity biases were established for use with each model. For POLCA7, Westinghouse used historical plant, bundle, and cycle operational data provided by NF to develop POLCA7 core models of recent QCNPS cycles. Then, Westinghouse and NF reviewed the results of this POLCA7 benchmark and determined appropriate POLCA7 reactivity biases (i.e., hot and cold target eigenvalues) for use with the Unit 2 Cycle 20 core design. In a similar manner, MICROBURN-B2 eigenvalue trends from recent QCNPS cycles were reviewed to determine appropriate MICROBURN-B2 hot and cold target eigenvalues.

USAG14 Correlation Consistent with the Westinghouse methodology described in Reference 3, the treatment of the SLMCPR in mixed cores containing non-Westinghouse fuel utilizes the SLMCPRs that were established in previous QCNPS cycles for the non-Westinghouse fuel. The USAG14 correlation is the Westinghouse CPR correlation for GE14 fuel that was used in the reload design and licensing analyses for QCNPS Unit 1 Cycle 20 (Reference 4) and QCNPS Unit 2 Cycle 19 (Reference 6).

As described in Reference 7, the USAG14 correlation sufficiently addresses the GNF Part 21 issue (i.e., Reference 8) with respect to critical power determination. The correlation was generated based on GEXL14 CPR data that already reflected the GNF corrections to the GEXL14 CPR correlation that were made in response to the GNF Part 21 issue. Therefore, CPRs calculated with the USAG14 correlation match the values from the Part 21-corrected GEXL14 correlation.

The USAG14 correlation was developed using the NRC-approved methodology described in Reference 3. The USAG14 correlation, including a detailed description of the methodology used to develop the correlation, was submitted to the NRC in response to a request for additional information (i.e., response to NRC Request 8 in Attachment 2 of Reference 9) in support of an amendment request to allow the transition to SVEA-96 Optima2 fuel at QCNPS and Dresden Nuclear Power Station (DNPS). The NRC approved that amendment for QCNPS and DNPS in Reference 5.

In Attachment 7 of Reference 10, EGC submitted information to the NRC to address the measures taken to ensure compliance with the limitations and conditions discussed in the NRC's safety evaluation for Reference 3. Attachment 7 of Reference 10 also included a description of the methodology used to derive the conservative adder to the operating limit minimum critical power ratio (OLMCPR), as required by Condition/Limitation 7 of the NRC safety evaluation for Reference 3. In Reference 4, the NRC concluded that Limitation 7 of the SER that approved the Reference 3 methodology had been satisfied for Q1 C20.

Adiustment Factor As described in Section 4 of Attachment 3, an adjustment factor is applied when using the USAG14 correlation. The adjustment factor applying to the USAG14 correlation is conservative.

The adjustment factor is specifically applied to establish the GE14 fuel OLMCPR that satisfies the 95/95 statistical criterion. A description of the process in generating USAG14 was previously provided to the NRC in response to NRC Request 8 in Attachment 2 of Reference 9.

Core Flow Uncertainty ATTACHMENT 1 Evaluation of Proposed Change The total core flow uncertainty values for dual-loop and single-loop operations that were applied for the Unit 2 Cycle 20 SLMCPR calculation are the same as those used in SLMCPR calculations for recent QCNPS cycles. These uncertainties are consistent with values provided in General Electric (GE) Nuclear Energy topical report NEDC-32601 P-A (Reference 11), in which GE updated their methodology and the inputs to be used in SLMCPR evaluations.

Reference 11 concluded that these core flow uncertainty values, which had also been previously approved for General Electric BWR Thermal Analysis Basis (GETAB) analyses, continued to be applicable and conservative. In Reference 1, the NRC approved NEDC-32601 P.

The total core flow uncertainty values are based on system performance. There is no impact on the total core flow uncertainty values as a result of the mixed core, since the GE14 and SVEA-96 Optima2 fuel are hydraulically compatible.

5.0 REGULATORY ANALYSIS 5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests an amendment to Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS) Unit 1 and Unit 2, respectively. The proposed change revises the values of the safety limit minimum critical power ratio (SLMCPR) in Technical Specification (TS) Section 2.1.1, "Reactor Core SLs." Specifically, the proposed change would delete the QCNPS Unit 2 fuel-specific SLMCPR requirements for Global Nuclear Fuel (GNF) GE14 fuel and consolidate the Unit 1 and Unit 2 SLMCPR requirements into a bounding dual-unit requirement. This change is needed to support the next cycle of Unit 2 operation.

According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(2)

Create the possibility of a new or different kind of accident from any accident previously evaluated ; or ATTACHMENT 1 Evaluation of Proposed Change Involve a significant increase in the probability or consequences of an accident previously evaluated ; or Involve a significant reduction in a margin of safety.

EGC has evaluated the proposed changes to the TS for QCNPS, Unit 1 and Unit 2, using the criteria in 10 CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

1.

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

Response: No The probability of an evaluated accident is derived from the probabilities of the individual precursors to that accident. The consequences of an evaluated accident are determined by the operability of plant systems designed to mitigate those consequences. Limits have been established consistent with NRC-approved methods to ensure that fuel performance during normal, transient, and accident conditions is acceptable. The proposed change to delete the QCNPS Unit 2 fuel-specific SLMCPR requirements for Global Nuclear Fuel (GNF) GE14 fuel conservatively establishes the SLMCPR for QCNPS, Unit 2, Cycle 20 at the SLMCPR value for the co-resident Westinghouse SVEA-96 Optima2 fuel, such that the fuel is protected during normal operation and during plant transients or anticipated operational occurrences (AOOs).

ATTACHMENT 1 Evaluation of Proposed Change The proposed change to delete the GE14 SLMCPR and establish the requirement at the SLMCPR value for the co-resident Westinghouse SVEA-96 Optimal fuel does not increase the probability of an evaluated accident. The change does not require any physical plant modifications, physically affect any plant components, or entail changes in plant operation. Therefore, no individual precursors of an accident are affected.

The proposed change to delete the GE14 SLMCPR and establish the requirement at the SLMCPR value for the co-resident Westinghouse SVEA-96 Optimal fuel revises the QCNPS Unit 2 SLMCPR requirement to protect the fuel during normal operation as well as during plant transients or AOOs. Operational limits will be established based on the proposed SLMCPR to ensure that the SLMCPR is not violated. This will ensure that the fuel design safety criterion (i.e., that at least 99.9% of the fuel rods do not experience transition boiling during normal operation and AOOs) is met. Since the proposed change does not affect operability of plant systems designed to mitigate any consequences of accidents, the consequences of an accident previously evaluated will not increase.

The proposed consolidation of the Unit 1 and Unit 2 SLMCPR requirements into a bounding dual-unit requirement is administrative. As such, the proposed consolidation does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Therefore, the proposed changes do 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 Creation of the possibility of a new or different kind of accident requires creating one or more new accident precursors. New accident precursors may be created by modifications of plant configuration, including changes in allowable modes of operation. The proposed changes do not involve any plant configuration modifications or changes to allowable modes of operation. The proposed change to delete the GE14 SLMCPR and establish the requirement at the SLMCPR value for the co-resident Westinghouse SVEA-96 Optimal fuel assures that safety criteria are maintained for QCNPS, Unit 2, Cycle 20. The proposed consolidation of the Unit 1 and Unit 2 SLMCPR requirements into a bounding dual-unit requirement is administrative.

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

3.

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

Response : No ATTACHMENT 1 Evaluation of Proposed Change The SLMCPR provides a margin of safety by ensuring that at least 99.9% of the fuel rods do not experience transition boiling during normal operation and AOOs if the SLIVICPR limit is not violated. The proposed change will ensure the current level of fuel protection is maintained by continuing to ensure that at least 99.9%

of the fuel rods do not experience transition boiling during normal operation and AOOs if the SLMCPR limit is not violated. The proposed SLMCPR values were developed using NRC-approved methods. Additionally, operational limits will be established based on the proposed SLMCPR to ensure that the SLMCPR is not violated. This will ensure that the fuel design safety criterion (i.e., that no more than 0.1 %

of the rods are expected to be in boiling transition if the MCPR limit is not violated) is met.

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

Based upon the above, EGC concludes that the proposed amendment presents 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 10 CFR 50.36, "Technical specifications," paragraph (c)(1), requires that power reactor facility TS include safety limits for process variables that protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity. The fuel cladding integrity SLMCPR is established to assure that at least 99.9% of the fuel rods in the core do not experience boiling transition during normal operation and AOOs. Thus, SLMCPR is required to be contained in TS.

10 CFR 50, Appendix A, General Design Criterion (GDC) 10 requires that the reactor core and associated coolant, control, and protection systems be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of AOOs. To ensure compliance with GDC 10, EGC has performed the plant-specific SLMCPR analyses using NRC-approved methodologies as prescribed in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants,"

Section 4.4. The SLMCPR ensures that sufficient conservatism exists in the operating limit MCPR such that, in the event of an AOO, there is a reasonable expectation that at least 99.9% of the fuel rods in the core will avoid boiling transition for the power distribution within the core including all uncertainties.

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

ATTACHMENT 1 Evaluation of Proposed Change EGC has determined that the proposed amendment 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, "Standards for Protection Against Radiation." 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, "Criterion for categorical exclusion ; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review,"

paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1.

Letter from F. Akstulewicz (NRC) to G. A. Watford (GE), "Acceptance for Referencing of Licensing Topical Reports NEDC-32601 P, 'Methodology and Uncertainties for Safety Limit MCPR Evaluations ;' NEDC-32694P, 'Power Distribution Uncertainties for Safety Limit MCPR Evaluation ;' and Amendment 25 to NEDE-24011-P-A on Cycle Specific Safety Limit MCPR (TAC Nos. M97490, M99069, and M97491)," dated March 11, 1999

2.

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

3. CENPD-300-P-A, "Reference Safety Report for Boiling Water Reactor Reload Fuel,"

dated July 1996

4. Letter from J. F. Williams to C. M. Crane (Exelon Generation Company, LLC), "Quad Cities Nuclear Power Station, Unit 1 - Issuance of Amendment Re : Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit (TAC No. MD4008)," dated May 2, 2007

5. Letter from M. Banerjee (NRC) to C. M. Crane (Exelon Generation Company, LLC),

"Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments Re: Transition to Westinghouse Fuel and Minimum Critical Power Ratio Safety Limits (TAC. Nos. MC7323, MC7324, MC7325 and MC7326)," dated April 4, 2006

6. Letter from M. Banerjee (NRC) to C. M. Crane (Exelon Generation Company, LLC),

"Quad Cities Nuclear Power Station, Unit 2 - Issuance of Amendment Re : Minimum Critical Power Ration Safety Limit (TAC No. MC9243)," dated March 31, 2006

7. Letter from P. R. Simpson (Exelon Generation Company, LLC) to NRC, "Additional Information Supporting Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit," dated February 13, 2006 Page 9

ATTACHMENT 1 Evaluation of Proposed Change

8.

Letter from J. S. Post (GE Energy) to NRC, "Part 21 60 Day Interim Report Notification :

Critical Power Determination for GE14 and GE12 Fuel With Zircaloy Spacers," dated June 24, 2005

9. Letter from P. R. Simpson (Exelon Generating Company, LLC) to NRC, "Additional Information Supporting Request for License Amendment Regarding Transition to Westinghouse Fuel," dated January 26, 2006 10. Letter from P. R. Simpson (Exelon Generation Company, LLC) to NRC, "Request for License Amendment Regarding Transition to Westinghouse Fuel," dated June 15, 2005 11. NEDC-32601 P-A, "Methodology and Uncertainties for Safety Limit MCPR Evaluations,"

dated August 1999

ATTACHMENT 2 Quad Cities Nuclear Power Station, Unit 1 and Unit 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 REVISED TECHNICAL SPECI FICATIONS PAGE 2.0-1

For two recirculation loop operation, MCPR shall be _> 1.11, or for single recirculation loop operation, MCPR shall be > 1.13.

Insert 2.2 SL Violations 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.

.1.2 With the reactor steam dome pressure >_ 785 psig and core flow >_ 10% rated core flow :

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 _< 1345 psig.

With any SL violation, the following actions shall be completed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> :

2.2.1 Restore compliance with all SLs ;

and 2.2.2 Insert all insertable control rods Quad Cities 1 and 2 2.0-1 SLs 2.0

ATTACHMENT 4 Westinghouse Application for Withholding, Affidavit, Quad Cities Unit 2 Cycle 20 SLMCPR (NON-PROPRIETARY)

Westinghouse U.S. Nuclear Regulatory Commission Directtel: (412) 374-4643 Document Control Desk Directfax: (412) 374-5139 Washington, DC 20555-0001 e-mail : greshaja@westinghouse.com

Subject:

NF-BEX-07-209 P-Attachment, "Quad Cities Unit 2 Cycle 20 SLMCPR" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-07-2355 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-07-2355 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

. A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures cc : M. Banerjee/NRR F. M. Akstulewicz/NRR G. S. Shukla/NRR Westinghouse Electric Company Nuclear Services P.O

. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA Ourrei: CAW-07-2355 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE November 7, 2007

COMMONWEALTH OF PENNSYLVANIA :

COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief Sworn to and subscribed before me this day 1 2007 Notary Public ALL';( L!'r V i^" "!

.~

..~~

".~!;n fc

! ~ c.:y~!fThf vi l,aiul7,is AFFIDAVIT ss CAW-07-2355 J. A. Gresham, Manager Regulatory Compliance and Plant Licensing

I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.

(3)

I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4)

Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

2 CAW-07-2355 (ii)

The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows :

(a)

The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b)

It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(e)

Its use 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 a similar product.

3 CAW-07-2355 (d)

It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e)

It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following :

(a)

The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b)

It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c)

Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d)

Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e)

Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv)

The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

4 CAW-07-2355 (v)

The proprietary information sought to be withheld in this submittal is that which is appropriately marked in NF-BEX-07-209 P-Attachment "Quad Cities Unit 2 Cycle 20 SLMCPR" (Proprietary), for review and approval, being transmitted by Exelon Nuclear letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse for "Quad Cities Unit 2 Cycle 20 SLMCPR" for review and approval.

This information is part of that which will enable Westinghouse to :

(a)

Support Exelon's use of Westinghouse Fuel at Quad Cities and Dresden.

(b)

Assist customer to obtain license change.

Further this information has substantial commercial value as follows:

(a)

Westinghouse can use this information to further enhance their licensing position with their competitors.

(b)

The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar analyses and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (t) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Westinghouse Non-Proprietary Class 3 Quad Cities Unit 2 Cycle 20 SLMCPR Westinghouse Electric Company Nuclear Fuel 4350 Northern Pike Monroeville, PA 15146 CQ 2007 Westinghouse Electric Company LLC, All Rights Reserved NF-BEX-07-209 Rev. 0 NP-Attachment Page 1 of 39

1.0 Introduction Westinghouse Non-Proprietary Class 3 This document contains a description of the Safety Limit Minimum Critical Power Ratio (SLMCPR) evaluation for Quad Cities Nuclear Power Station Unit 2 (QCNPS2) Cycle 20, as well as identification of the Critical Power Ratio (CPR) correlation for Global Nuclear Fuel (GNF) GE14 legacy fuel, and the "conservative Adder" required by SER restriction 7 of Reference 3.

Cycle 20 is the second cycle in which reload quantities of SVEA-96 Optimal fuel is being installed in QCNPS2. Dual recirculation loop operation (DLO) and single recirculation loop operation (SLO) SLMCPRs of 1.09 and 1.10, respectively, were established for the GE14 fuel by GNF for QCNPS2 Cycle 18, [

I a,c DLO and SLO recirculation loop SLMCPRs of 1.11 and 1.13, respectively, have been calculated for the Westinghouse SVEA-96 Optimal assemblies in QCNPS2 Cycle 20.

As discussed in References 10 through 12 and 15, these values of 1.11 and 1.13 were also established for the QCNPS2 Cycle 19 SVEA-96 Optimal reload fuel, and the QCNPS2 Technical Specification was modified accordingly.

Therefore, application of the Westinghouse methodology in Reference 3 does not require modification of the QCNPS2 Technical Specification to support DLO and SLO SLMCPRs of 1.09 and 1.10, respectively, for the GE14 fuel in Cycle 20 and 1.11 and 1.13, respectively, for the SVEA-96 Optimal fuel in Cycle 20.

For all Quad Cities and Dresden SLMCPR evaluations performed by Westinghouse to date, the Westinghouse methodology described in Reference 3 has produced SVEA-96 Optimal DLO and SLO SLMCPRs that are greater than or equal to the GE14 SLMCPRs calculated by GNF for the previous cycles. Exelon Generation Company, LLC, (EGC) elected to conservatively apply the higher SLMCPR values that were established for the SVEA-96 Optimal fuel to all the assemblies in the core including the SVEA-96 Optimal and the GE 14 fuel assemblies.

This conservative approach was applied to Dresden Nuclear Power Station Unit 3 (DNPS3)

Cycle 20 (Reference 13), Quad Cities Nuclear Power Station Unit 1 (QCNPS 1) Cycle 20 (Reference 14), and Dresden Nuclear Power Station Unit 2 (DNPS2) Cycle 21 (Reference 16).

As discussed below, this approach is considered to be unnecessarily conservative for QCNPS2 Cycle 20, since this is the second cycle in which SVEA-96 Optimal is being loaded. The GE14 fuel in its third cycle of irradiation will operate at sufficiently low assembly powers in QCNPS2 Cycle 20, such that the GE14 Critical Power Ratio (CPR) limits will not be challenged. Therefore, continued application of the GE14 DLO and SLO SLMCPRs of 1.09 and 1.10, respectively, is conservative and acceptable for QCNPS2 Cycle 20.

The GNF NRC-approved methodology (References 1 and 2) was used previously to determine the appropriate SLMCPR values for the QCNPS2 Cycle 18, which is dominated by GNF GE14 fuel assemblies. Consistent with the GNF methodology, a single set of Cycle 18 SLMCPRs is applied to all fuel assemblies in the core.

For QCNPS2 Cycle 20, EGC will load Westinghouse SVEA-96 Optimal reload fuel for the second consecutive cycle. SVEA-96 Optirna2 reload fuel was also loaded in QCNPS2 Cycle 19. Therefore, the Westinghouse NRC-approved methodology described in Reference 3, and NF-BEX-07-209 Rev. 0 NP-Attachment Page 2 of 39

further clarified in the response to Request for Additional Information (RAI) D13 of Reference 4, was used to determine the SLMCPRs for Cycle 20.

Further clarification of the Westinghouse SLMCPR methodology was also provided to the NRC in support of the transition to SVEA-96 Optimal fuel in the Quad Cities and Dresden Units as follows :

The response to NRC Request 19 in Reference 9 which supported the Licensing Amendment Request for transition to SVEA-96 Optimal fuel in the Dresden and Quad Cities plants provided in Reference 8, The technical information supporting the Quad Cities 2 Technical Specification SLMCPR changes transmitted by Reference 10 as supplemented by the clarifying information in Reference 11.

The same SLMCPR methodology described in these references was followed to establish appropriate GE14 and SVEA-96 Optimal SLMCPRs for QCNPS2 Cycle 20. Unlike the GNF methodology, I a,c The EGC proposed license amendment to use the Westinghouse methodology for core reload evaluations at the Dresden and Quad Cities units was submitted to the NRC in Reference 8.

This submittal was approved by the NRC and supported QCNPS2 Cycle 19, DNPS3 Cycle 20, QCNPS I Cycle 20, and DNPS2 Cycle 21, all of which are cores containing a reload of SVEA-96 Optimal fuel. This submittal also supports QCNPS2 Cycle 20.

Condition 7 in the NRC safety evaluation for Reference 3 requires that a conservative factor to be applied to the GE14 Operating Limit Minimum Critical Power Ratio (OLMCPR) be identified in licensee applications. The value of this factor for QCNPS2, Cycle 20, is I a,c which was also used for the QCNPS 2 Cycle 19, DNPS3 Cycle 20, QCNPSI Cycle 20, and DNPS2, Cycle 21 licensing analyses.

2.0 GE14 SLMCPR for QCNPS2 Cycle 20 Consistent with the Westinghouse methodology described in Reference 3, the treatment of the SLMCPR in mixed cores containing non-Westinghouse fuel [

a'c The Cycle 18 SLMCPR was determined by GNF based on plant-and cycle-specific analyses using GNPs NRC-approved methodology and uncertainties (References I and 2) as supplemented with QCNPS2-specific uncertainties. The GNF evaluation used the GEXL14 correlation for GE14 fuel. The GNF evaluation confirmed that the DLO and SLO SLMCPRs of 1.09 and 1.10, respectively, were appropriate for Cycle 18.

NF-BEX-07-209 Rev. 0 NP-Attachment Page 3 of 39

a,c For example, the conservative adder discussed in Section 4.0 is intended to assure that the GE14 OLMCPRs are conservative with a probability of at least 0.95 with 95% confidence.

Furthermore, the Reference Core depletion discussed in Section 3.0 predicts that the CPRs of the GE14 assemblies will be greater than or equal to 3.0 throughout Cycle 20.

Therefore, application of the larger SVEA-96 Optimal SLMCPRs to the GE14 assemblies is considered to be somewhat over conservative for QCNPS2 Cycle 20 since this is the second cycle in which SVEA-96 Optimal fuel was loaded, and the GE 14 fuel is in its third cycle of irradiation.

3.0 SVEA-96 Optimal SLMCPR for Cycle 20 In establishing the SLMCPR for Westinghouse SVEA-96 Optimal fuel assemblies, it is assumed that I a,c The SVEA-96 Optimal SLMCPR for QCNPS2 Cycle 20 is based on a Reference Core design (SVEA-96 Optimal bundle designs, core loading pattern and state point depletion strategy) that represents realistic current plans for the Cycle 20 loading and operation. The Reference Core loading pattern for QCNPS2 Cycle 20 is shown in Figure 1. The Reference Core design was generated via collaboration between EGC and Westinghouse based on EGC's cycle assumptions and design goals.

The Reference Core was designed to meet the cycle energy requirements, to satisfy all licensing requirements, to provide adequate thermal margins and operational flexibility, and to meet other design and manufacturing criteria established by EGC and Westinghouse.

In general, the calculated SLMCPR is dominated by the flatness of the assembly CPR distribution across the core, and the flatness of the relative pin CPR distribution based on the pin-by-pin power/R-factor distribution in each bundle.

Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher SLMCPR.

NF-BEX-07-209 Rev. 0 NP-Attachment Page 4 of 39

calculations were performed at SLMCPR become I a,c The calculation of the SLMCPR as a function of cycle exposure captures the interplay between the relative fuel assembly CPR and bundle relative pin-by-pin CPR distributions established from the power/R-factor distributions and allows a determination of the maximum (limiting)

SLMCPR for the entire cycle. This limiting SLMCPR is applied throughout the entire cycle.

The SVEA-96 Optimal SLMCPR for QCNPS2 Cycle 20 was determined as a function of cycle exposure based on radial assembly power distributions with about the same "flatness" as the cycle exposure-dependent radial power distributions from Accordingly, the SVEA-96 Optimal SLMCPR for DLO was calculated at 100% power and 100% flow at 14 cycle exposures throughout the cycle to assure that the limiting SLMCPR was identified. In addition, the DLO SLMCPRs were calculated at 100% power at the minimum allowed core flow at rated power (95.3% flow), and the maximum licensed core flow at rated power of 108% flow to confirm that a limiting SLMCPR had been established. Figure 3 shows a current QCNPS2 power-flow map which is applicable to Cycle 20. Consistent with Figure 3, a flow window 95.3% to 108 % of rated core flow was analyzed.

SLO SVEA-96 Optimal SLMCPR calculations were also performed.

These SLMCPR I a>c The SLO calculations used the same procedure as the dual loop cases, except that the SLO cases applied a larger uncertainty for the core flow.

The SLMCPR results for Cycle 20 are plotted in Figure 4. As shown in Figure 4, the DLO

]a'c Since the uncertainties at each DLO point are the same, this behavior is due to the interplay between the assembly relative CPRs and the relative fuel rod CPRs. In general, as the fraction of assembly or fuel rod CPRs in the vicinity of the minimum assembly or fuel rod CPR increases, the number of rods with a potential for experiencing dryout increases. Therefore, a larger SLMCPR is required to assure that less than 0.1 % of the rods are in dryout.

While control rod patterns at individual state points required to maintain margins to thermal limits may perturb the trend, experience has shown that the assembly CPR distributions tend to NF-BEX-07-209 Rev. 0 NP Attachment Page 5 of 39

I a,e Consequently, the peak SLMCPR tends to occur when the assembly CPR and rod CPR distributions combine to place the maximum number of fuel rod CPRs close to the minimum CPR.

This behavior is shown for the QCNPS2 Cycle 20 SLMCPR by the relative assembly CPR and relative fuel rod histograms shown in Figures 5 through 17 and 18 through 28, respectively. In Figures 5 through 17, assembly types UC20 and UD20 refer to the SVEA-96 Optimal assembly types loaded in Cycle 20. Assembly type [

I a,c Inspection of the DLO histograms in Figures 5 through 15 and the relative fuel rod CPR histograms for the QCNPS2 Cycle 20 feed fuel UC20 and UD20 assembly types shown in Figures 18 through 28 lead to the following observations, which explain the SLMCPR behavior in Figure 4:

a,c NF-BEX-07-209 Rev. 0 NP-Attachment Page 6 of 39

of Therefore, the DLO SLMCPR results at rated conditions in Figure 4 can be explained in terms The SLO results calculated at a,c The continued adequacy of a DLO SLMCPR of [

I a,c The relative fuel rod CPRs in the SLMCPR calculations are I a,c NF-BEX-07-209 Rev. 0 NP-Attachment Page 7 of 39 I a,c In addition to the strong dependence on assembly CPR and relative fuel rod CPR distributions, the SLMCPR is strongly dependent on the distribution of assembly and relative fuel pin CPRs about their mean values leading to an overall distribution of fuel rod CPRs relative to their mean values. The wider these distributions, the higher the SLMCPR must be to prevent 0.1%

of the fuel rods from experiencing boiling transition.

The distributions of fuel rod CPRs relative to their mean values are determined by the uncertainties relative to the mean CPRs.

Accordingly, the uncertainties used in establishing the SVEA-9S Optima2 SLMCPR for Cycle 20 are shown in Table 2.

5.0 References 4.0 Westinghouse CPR Correlation for GE14 Fuel The Westinghouse CPR correlation for GE14 fuel used in the QCNPS2 Cycle 20 reload design and licensing analyses is the same as that used for QCNPS2 Cycle 19, and described in the Response to NRC Request 8 in Reference 9.

Further clarification of the correlation was provided in the response to NRC Request 2 in Reference i 1 as well as in Reference 12. This correlation is also used in the reload analysis supporting DNPS3 Cycle 20 and QCNPS1, Cycle 20 operation as discussed in References 13 and 14.

1 a,c a'c The determination of this value was also based on EGC's plans to continue to monitor the CPR performance of GE14 fuel using the GNF GEXL14 correlation within the POWERPLEX-III online core monitoring system rather than the USAG14 correlation.

This approach is consistent with Westinghouse's NRC-approved methodology per Reference 3.

1.

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-24011-P-A on Cycle Specific Safety Limit MCPR, " (TAC Nos. M97490, M99069, and M97491), March 11, 1999.

2.

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

3. Licensing Topical Report, Reference Safety Reportfor Boiling Water Reactor Reload Fuel, CENPD-300-P-A, July 1996.

4. CENPD-389-P-A, 10x10 SVEA Fuel Critical Power Experiments and CPR Correlations: SVEA-96+,

August 1999.

5. Quad Cities Technical Specifications, Section 2.1.1.2 6. WCAP-16081-P-A, IOx10 SVEA Fuel Critical Power Experiments and CPR Correlation: SVEA-96 Optimal, March 2005.

7.

Letter, Jason S. Post (GE) to NRC, Part 2160 Day Interim Report Notification : Critical Power Determination for GE] 4 and GE12 Fuel With Zircaloy Spacers, MFN 05-058 Rev 1, June 24, 2005, and GE Energy - Nuclear, 10 CFR Part 21 Communication, 60-Day Interim Report Notification and Transfer of Information, Critical Power Determination for GE14 and GEl2 Fuel With Zircaloy Spacers, SC05-04 Rev 1, June 24, 2005.

8.

Letter, Patrick R. Simpson (Exelon Generation Company, LLC) to NRC, Request for License Amendment Regarding Transition to Westinghouse Fuel, dated June 15, 2005.

9.

RS-06-009, Additional Information Supporting Requestfor License Amendment Regarding Transition to Westinghouse Fuel, January 26, 2006.

NF-BEX-07-209 Rev. 0 NP-Attachment Page 8 of 39

10. Letter from Patrick R. Simpson, Exelon Nuclear, to U.S. NRC, "Requestfor Technical Specifications Change for Minimum Critical Power Ratio Safety Limit ", QCNPS, Unit 2, December 15, 2005.

11. RS-06-024, "Additional Information Supporting Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit ", QCNPS, Unit 2, February 13, 2006.

12. RS-06-038, "Additional Information Supporting Request for Licensing Amendment Request Regarding Transition to Westinghouse Fuel and Request for Technical Specifications Change far Minimum Critical Power Ratio Safety Limit ", March 3, 2006.

13. Letter from NRC (John Honcharik) to EXELON GENERATION COMPANY, LLC, dated November 7, 2006, Dresden Nuclear Power Station, Unit 3-Issuance of Amendment RE: Minimum Critical Power Ratio Safety Limit (TAC No. MD2706).

14. Letter from NRC (Joseph Williams) to EXELON GENERATION COMPANY, LLC, dated May 3, 2007, Quad Cities Nuclear Power Station, Unit I-Issuance ofAmendment RE: Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No. MD4008).

15. Letter from NRC (Maitri Banerjee) to EXELON GENERATION COMPANY, LLC, dated March 31, 2006, Quad Cities Nuclear Power Station, Unit 2-Issuance of Amendment RE: Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No. MC9243).

16. Letter from Patrick R. Simpson (EXELON GENERATION COMPANY, LLC) to NRC, RS-07-97, Dresden Nuclear Power Station, Unit 2, Renewed Facility Operating License No. DPR-19, Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit, July 10,2007.

NF-DEX-07-209 Rev. 0 NP-Attachment Page 9 of 39

Table 1 Comparison of Cycle 19 and 20 Cores NF-BEX-07-209 Rev. 0 NP-Attachment Page 10 of 35 Description Quad Cities 2 Cycle 19 Quad Cities 2 Cycle 20 Number of Bundles in Core 724 724 Limiting Cycle Exposure Point Near EOC Near EOC Cycle Exposure at Limiting Point, EFPH 12,219 EFPH 14,723 EFPH Reload Fuel Type SVEA-96 O tima2 SVEA-96 O tima2 Reload Batch Average Weight % Enrichment 3.91 w/o 4.00 w/o Reload Batch Fraction %

31.5%

35.9%

Batch Fraction of SVEA-96 O tima2 Fuel 31.5%

67.4%

Batch Fraction of GNF GE 14 Fuel 68.5%

32.6%

Core Average Weight % Enrichment 3.99 w/o 3.97 w/o Calculated Safety Limit MCPR (DLO) a,c a,c Calculated Safety Limit MCPR (SLO)

C a,c 1

a,c i

Table 2 - Uncertainties used in Quad Cities 2 Cycle 20 SVEA-96 Optima2 SLMCPR Determination NF-BEX-07-209 Rev. 0 NP-Attachment Page F 1 of 35

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 8

6 4

2 1

3 5

7 9 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 12 12 12 11 12 11 12 11 12 12 12 12 11 12 11 12 11 12 12 12 12 12 12 12 12 11 11 40 40 11 12 12 11 12 12 r111 2 11 25 25 25 26 25 12 12 12 11 11 40 25 15 40 15 40 40 15 40 15 25 40 11 11 12 12 12 12 12 12 12 12 11 12 12 12 11 11 30 12 30 25 12 15 25 30 30 25 40 E15 25 30 15 30 25 15 30 15 25140 15130 30115 40115 15 40 15 30 40 15 30 15 153001630 t5 0

40 15 30 15 15 40 15 30 30 15 40 15 25 40 15 30 25 15 30 15 25 30 15 30 30 25 40 15 12 15 25 30 30 12 30 25 12 12 11 11 42 12 11 12 12 12 12 12 12 12 12 12 i 12 12 12 12 12 12 12 11 11 11 11 11 11 12 11 11 11 11 40 40140 40 11 12 12 25 25 25 15115 25 25 40 25 15 40 15 40140 15 40 25 25 30 15 40 15115 40 15 15 40 15 40 15 30130 15 40 30 15 40 15 30 15115 30 15 15 30 15 30 15 30 1 30 15 30 30 15 30 15 30 15 15 30 15 15 30 15130 16 30 30 15 30 30 15 30 15 30 15 1 15 30 15 15 30 15 30 15 30130 15 30 30 15 30 15 30 15 1 15 30 15 l5 30 15 30 15 30130 15 30 12 12 12 11 12 16 25 40 30 25 25 15 40 15130 15 30 15 30 15 30 15 15 30 30 15 15 30 15 30 30 15 30 15 16 3011.5 30 11 11 25 12 E

15 30 30 15 12 12 12 12 12! 12 12 12 12 12 Figure l - Quad Cities 2 Cycle 20 - Reference Loading Pattern 12 12 12 12 11 12 12 11 11 12 12 12 25 30 12 30 12 30125 16112 12 15140 25 30 11 30 15 30 25 11 30 15 25 40 25 25 30 15 15 40 15 40 30 15 40 15 15 40 15 40 40 15 15 30 12 12 12 11 12 12 12 12 11 12 12 12 12 12 25 11 11 12 25 40 11 12 11 12 NF-BEX-07-209 Rev. 0 NP-Attachment Page 12 of 39 Fuel T Bundle Name 9 Assern ID Ran Cycle First Loaded 11 GE14-P10DNAB418-16GZ 2646 80 JLJ669.1LJ748 18 12 GE14-PlODNA8389-18GZ-2650 158 JLJ269-JLJ276 18 JLJ761JLJ912 30 pt2-3.89-16GZ&00-2G6.00 152 4BAOOi-OBA152 19 40 pt2-3_94-13GZ7.00-2G&00 76 OBA153-OBA228 19 15 Opt2J.99-15GZ8.00-3G6.00 196 OBB001-OBB196 20 25 Opt2-4.05-12GZ7.00-2G6.00 64 OBB197-OBB260 20 15130 15130 15 30"30 15 0115 30 15 30 15 30 15 40115 40 11 12 30 15 30 15 30 15115 30 '15 30 15 30 15 30 15 40 15 25 40 11 12 15 30 15 30 15 30130 15 30 15 30 15 30 15 40 15 40 25 11 11 12 30 15 30 15 30 15115 30 15 3 115 30 15 40 15 30 15 25 11 12 12 16 30 15 30 75 30130 15 30 15 30 15 30 15 40 25 25 12 11 12 12 30 15 30 15 30 15115 30 15 30 15 30 15 30 15 25 40 12 11 12 15 30 '15 30 15 30130 15 30 15 30 15 30 15 30 25 11 12 12 30 U54 15 30 a

15 1 15 30 15 40 15 30 15 40 25 30 11 11 12 15 40 15 30 30 15 40 15 40 15 30 25 15 12 12 12 12 25 25 30 15 40 15 15 40 15 30 25 25 25 30 12 30 12 12 40 25 15 40 15 40 1 40 15 40 15 25 40 11 11 12 12 12 12 12 25 25 25 15115 25 25 25 12 12 12 11 12 12 11 71 11 11 40 40 1 40 40 11 1'1 1'1 11 12 12 12 12 12 12 11 11 11111 11 11 12 12 12

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 8

6 4

2 1

3 5

7 9

11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 21 20 20 21 21 20 21 20 21 20 21 21 20 21 20 20 21 21 20 21 21 21 21 21 20 20 21 21 21) 20 20 21 21 21 40 21 20 40 40 20 40 27Z) 71 30 11 40 11 20 20 40 20 21 12 21 20 21 21 21 21 21 21 20 20 21 40 40 21 40 21 21 21 20 21 21 21 21 20 21 11 12 40 40 11 11 40 40 12 11 30 30 11 11 30 30 11 30 12 40 11 40 11 20 21 21 21 20 21 12 40 12 30 12 30 11 30 11 30 12 30 12 30 12 30 12 30 12 21 21 20 20 21 20 21 11 40 40 40 20 11 30 30 12 30 12 12 30 11 30 1 30 11 12 30 21 20 21 21 21 i 21 21 21 20 21 20 20 20 1 20 20 20 U12 21 20 2012 d 20 20 40 40 40140 40 40 11 40 11 30 111 11 30 11 40 12 30 11 30130 11 30 11 30 12 30 12112 30 it 30 12 30 72 12/ 12 12 30 12 30 12 30 12 1 12 30 11 30 12 30 11 30 30 11 30 12 12 12 30 12112 30 12 12 12 E30 12 72 1 72 12 30 12 30 12 30 12112 30 11 30 12 30 12 30 1 30 12 30 011 2 _30 _20 20 30 30 2 30 2020 30 12 12 30 12 30 12 40 121 21 20 21 20 21 20 21 20 21 21 21 21 20 40 40 21 20 11 40 11 40 30 12 40 11 12 30 11 30 30 12 30 11 12 30 12 30 30 12 30 11 12 12 12 30 E

30 72 12 12 12 30 12 30 30 12 30 11 777 12 12 12 30 12 12 1 12 12 30 30 11 12 30 2 3 12 0 30 11 12 30 30 11 11 30 40 11 11 40 21 20 21 20 20 21 21 Figure 2 Quad Cities 2 Cycle 19 - Reference Loading Pattern NF-DEX-07-209 Rev. 0 NP-Attachment Page 13 of 39 Fuel T Bundle Name 9 Assem ID Ran Cycle First loaded 20 GE14-P10DNA8409-15GZ-2507 112 JLA573-JLA668 17 21 GE14-P10DNA8406-166Z-2508 144 JLA689-JLAS40 17 11 GE14-P10DNA8418-16GZ-2646 80 JLJ669-JLJ748 18 12 GE14-P10DNAB369-18GZ-26M 160 JLJ269-JLJ276 18 JLJ761JLJ912 30 Opt2-3.88-16GZ&00-2G6.00 152 QBA001-QBA152 19 40 Opt2-3.94-13GZT00-2G6.00 76 OBA153-OBA228 19 43 45 47 49 51 53 55 57 59 20 21 21 21 20 21 21 12 21 20 21 20 40 11 20 21 21 21 12 40 40 20 21 21 21 30 20 40 11 21 20 21 11 30 12 40 12 21 20 30 11 30 11 40 20 20 21 12 30 11 40 11 21 21 20 21 30 12 30 12 40 40 21 21 20 12 30 12 30 11 40 21 20 21 30 12 30 11 30 40 20 20 21 12 12 30 11 20 21 12112 12 30 11140 20 20 21 30 12 30 11 30 40 20 20 21 12 30 12 30 1140 21 20 21 30112 0

0 12 30 11 40 11 21 21120 2 30 11 30 11 40 20 20 21 11 30 12 40 12 21 20 30 20 40 11 21 20 21 12 40 40 20 21 21 21 40 11 20 21 21 21 12 21 20 21 20 21 20 21 21 20 21 21 30 11 30 12 30 12 30130 12 30 12 30 12 30 12 30 12112 30 12 30 72 12 12 30 12 72 / 12 12 30 12 30 12 12 12 30 12112 30 12 30 11 30 12 30 11 30130 11 30 11 30 12 30 12 30 12112 30 12 30 11 30 12 30 12 12 1 12 12 30 12 30 11 30 12 30 12 12 30 12 40 11 40 12 30 11 30 30 11 30 12 40 11 40 11 30 11 / 11 30 11 21 20 21 40 40 40 40 40 40 40 20 20 21 21 21 2d 20 1 20 20 21 2d 21 20 20 20120 20 21 20 21 20 21 21 21 ! 21 21 21

0 V

m 0

Q.

0 d

L m

V ORTP :

Original Rated Thermal Power (100"

. Pewr - 2511 NW... }

10 20 30 40 50 60 Care Flaw {%)

70 80 90 Figure 3 - QCNPS Power Flow Map (Nominal Feedwater Temperature)

NF-BEX-07-209 Rev. 0 NP-Attachment Page 14 of 39 100". EPO Power

- 2951 HK 100r Cora Flow

- 96.0 Hlb/hr ha 43.6 P / 23.0 :. F 8".

54.2 "-- P / 15.5 i F C :

100.0 ""- P /

95.3 F

1): 100.0 t P / 100.0 i F E :

100_0 6 P / 106.0 ° F F".

27.0 i P / 108.0 " F G:

18.8 P / 36.6 < F 11 :

84.9 'i P / 88.5 3 F

Figure 4 Quad Cities 2 Cycle 20 SLMCPR Results for SVEA-9S Optima2 Fuel NF-BEX-07-209 Rev. 0 NP-Attachment Page 1 5 of 39

Figure 5 -Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 16 of 39

Figure 6-Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 1 7 of 39

Figure 7 - Assembly Histograms NF-BEX-07-209 Rev, 0 NP-Attachment Page 18 of 39

Figure 8-Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment

Figure 9 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 20 of 39

Figure 10 -Assembly Histograms NFBEX-09-209 Rev. 0 NP-Attachment Page 21 of 39

Figure 11 -Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 22 of 39

Figure 12-Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 23 of 39

Figure 93 -Assembly Histograms NF-DEX-07-209 Rev. 0 NP-Attachment Page 24 of 39

Figure 14 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 25 of 39

Figure 15-Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 26 of 39

Figure 96-Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment

NF-BEX-07-209 Rev. 0 NP-Attachment Page 28 of 39 Figure 17--Assembly Histograms

Figure 18 - Assembly Histograms NF-BEX-07-204 Rev. 0 NP-Attachment

Figure 19 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 30 of 39

Figure 20 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment

Figure 21 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment

Figure 22 - Assembly Histograms NF-BEX-07-204 Rev. 0 NP-Attachment

Figure 23 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment

Figure 24 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment

Figure 25 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 36 of 39

Figure 26 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment

Figure 27 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment

Figure 28 - Assembly Histograms NF-BEX-07-209 Rev. 0 NP-Attachment Page 39 of 39