L-11-031, Request for Additional Information Response Related to Modification of Technical Specification 2.1.1, Reactor Core SLs
| ML110400136 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/02/2011 |
| From: | Bezilla M FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-11-031, TAC ME4925 | |
| Download: ML110400136 (23) | |
Text
FENOC Perry Nuclear Power Plant 10 Center Road FirstEnergy Nuclear Operating Company Perry, Ohio 44081 Mark B. Bezilla 440-280-5382 Vice President Fax: 440-280-8029 Withhold from Public Disclosure Under 10 CFR 2.390 When Separated from Enclosure 1, This Document can be Decontrolled February 2, 2011 L-11-031 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Request for Additional Information Response Related to Modification of Technical Specification 2.1.1, "Reactor Core SLs" (TAC NO. ME4925)
By letter dated October 21, 2010 (Accession No. ML102980451), the FirstEnergy Nuclear Operating Company (FENOC) submitted to the Nuclear Regulatory Commission (NRC) a license amendment request for the Perry Nuclear Power Plant (PNPP). The proposed amendment would incorporate revised safety limit minimum critical power ratio (SLMCPR) values into the PNPP Technical Specifications.
By letter dated January 6, 2011 (Accession No. ML1 1040168), the NRC staff requested additional information on the proposed amendment to complete its review. The responses to the request for additional information (RAI) are contained in the attachment and three enclosures. For ease of review, the attachment lists the five RAIs and either provides the response or a reference to the enclosure that contains the response.
Several of the RAI responses are contained in Global Nuclear Fuel - Americas, LLC (GNF) report, "LRW-FEN-KLI-1 1-007, Response to NRC RAIs 1 - 4 on Perry Nuclear Power Plant Cycle 14 SLMCPR Submittal." A proprietary version of the report is included as Enclosure 1, and should be.withheld from public disclosure under 10 CFR 2.390. Enclosure 2 contains a non-proprietary version of the report.
A GNF affidavit, which supports the proprietary nature of the report, is included as.
Perry Nuclear Power Plant L-1 1-031 Page 2 of 2 There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager-Fleet Licensing, at (330) 761-6071.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February.
, 2011.
Sincerely, Mark B. Bezillai/
Attachment:
Response To Request For Additional Information
Enclosures:
- 1. GNF "LRW-FEN-KL1-11-007, Response to NRC RAIs 1 - 4 on Perry Nuclear Power Plant Cycle 14 SLMCPR Submittal," GNF Proprietary Information
- 2. GNF "LRW-FEN-KLI-11-007, Response to NRC RAIs 1 - 4 on Perry Nuclear Power Plant Cycle 14 SLMCPR Submittal," GNF Non-Proprietary Information
NRC Region.Ill Administrator (without Enclosure 1)
NRC Project. Manager (without Enclosure 1)
NRC Resident Inspector (without Enclosure 1)
Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison) (without Enclosure 1)
Utility Radiological Safety Board (without Enclosure 1)
L-1 1-031 GNF "LRW-FEN-KL1-11-007, Affidavit" (Four pages follow)
ENCLOSURE 3 LRW-FEN-KL1-11-007 Affidavit
Global Nuclear Fuel - Americas AFFIDAVIT I, Anthony P. Reese, state as follows:
(1) I am Manager, Reload Design and Analysis, Global Nuclear Fuel-- Americas, LLC ("GNF-A"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Enclosure 1 of GNF's letter, LRW-FEN-KL1-11-007, L. Watts (GNF-A) to R. Borland (First Energy Nuclear Operating Company), entitled "GNF Response to NRC Requests for Additional Information (RAIs) 1 -
4 on Perry Nuclear Power Plant Cycle 14 SLMCPR Submittal," dated January 20, 2011.
GNF-A proprietary information in Enclosure 1, which is entitled "Response to NRC RAIs 1 -
4 on Perry Nuclear Power Plant Cycle 14 SLMCPR Submittal," is identified by a dotted underline inside double square brackets. ((This sentence is..an.examp.l..e...)) A "((" marking at the beginning of a table, figure, or paragraph closed with a "))" marking at the end of the table, figure or paragraph is used to indicate that the entire content between the double brackets is proprietary. In each case, the superscript notation {3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3)
In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 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; LRW-FEN-KL1-11-007 Affidavit Page 1 of 3
- c.
Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;
- d.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.
(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. 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 this methodology, along with the testing, development and approval was achieved at a significant cost to GNF-A or its licensor.
The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNF-A asset.
LRW-FEN-KL1-11-007 Affidavit Page 2 of 3
(9)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes, beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process.
In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GNF-A would be lost if the information were disclosed to-,
the public.
Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing 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 2 0 th day of January 2011.
A "o P. Reese Manager, Reload Design and Analysis Global -Nuclear Fuel - Americas, LLC LRW-FEN-KL1-11-007 Affidavit Page 3 of 3
Attachment L-1 1-031 Response To Request For Additional Information Page 1 of 6 By letter dated October 21, 2011 (Accession No. ML102980451), the FirstEnergy Nuclear Operating Company (FENOC) submitted to the Nuclear Regulatory Commission (NRC) a license amendment request for the Perry Nuclear Power Plant (PNPP). The proposed amendment would incorporate revised safety limit minimum critical power ratio values into the PNPP Technical Specifications.
By letter dated January 6, 2011 (Accession No. ML1 1040168), the NRC staff requested additional information to complete its review. Several of the responses to the request for additional information (RAI) are contained in Global Nuclear Fuel - Americas, LLC (GNF) report, "LRW-FEN-KL1-11-007, Response to NRC RAIs 1 -4 on Perry Nuclear Power Plant Cycle 14 SLMCPR Submittal." Enclosure 1 contains a proprietary version of the report and should be withheld from public disclosure under 10 CFR 2.390. contains a non-proprietary version of the report. A GNF affidavit, which supports the proprietary nature of the report, is included as Enclosure 3.
The NRC staff questions are in bold, followed by the FENOC and GNF responses.
When the NRC staff questions and responses refer to items, for example Figures 1,2,,
or 5, or Tables 3, 4, or 5, the reference is to material included in Enclosures B and C of the October 21, 2011 (Accession No. ML102980451) FENOC submittal.
NRC Staff Question 1 Please provide:
(a) The number of fuel assemblies for each fuel type in Figures 1 and 2 for Cycle 14 and Cycle 1.
(b) Core map to show those bundles experienced 0.1 percent boiling transition criterion of limiting cases for single loop operation (SLO) and two-loop operation (TLO).
Response-1.a It was noted that the RAI requested information for Cycle 1. By electronic mail between the NRC and FENOC dated January 7, 2011, the RAI was clarified to request information for Cycle 13 instead of Cycle 1.
The response is contained in proprietary Enclosure 1. The non-proprietary Version of the response is contained in Enclosure 2.
Attachment L-1 1-031 Page 2 of 6 Response - 1.b The response is contained in Enclosure 1, which is proprietary. The non-proprietary version of the response is contained in Enclosure 2.
The response contains the acronym "NRSBT." The proper phrase for the acronym is number of rods subject to boiling transition.
NRC Staff Question 2 Please provide the details of a final core loading pattern as shown in Figure 1 including procedures, guidelines, criteria, and approved methodologies used for this analysis.
Response
The response is contained in Enclosure 1, which is proprietary. The non-proprietary version of the response is contained in Enclosure 2.
NRC Staff Question 3 Please provide:
(a) An approximation of the correlation for MCPR Importance Parameter (MIP) and R-Factor Importance Parameter (RIP) including applicable fuel related coefficients and constants leading to the results of TLO SLMCPR estimate using the MIP/RIP correlation shown in Table 3.
(b) Justification that the approximation is still applicable to GE 14 fuel considering there are no GE14 data points in Figure 5.
(c) An updated Figure 5 including GE14 fuel assembly.
Response - 3.a The response is contained in Enclosure 1, which is proprietary. The non-proprietary version of the response is contained in Enclosure 2.
Response - 3.b and 3.c The response is contained in Enclosure 1, which is proprietary. The non-proprietary version of the response is contained in Enclosure 2.
Attachment L-1 1-031 Page 3 of 6 NRC Staff Question 4.
In Section 2.1 of Enclosures Band C "Major Contributors to SLMCPR Changes,"
it states that "Table 3 presents estimated impacts on the TLO SLMCPR due to methodology deviations, penalties. and/or uncertainties deviations from approved values." Please provide:
(a) Calculation details about how the impact on the SLMCPR from R-factor of less than 0.005 and from core flow rate of 0.003 is generated in Table 3.
(b) Justification that the proposed SLMCPR values for TLO and SLO are conservative related to "methodology deviations, penalties, and/or uncertainties deviations from approved values," or any fuel related Part 21 issues not listed in Table 3.
Response - 4.a The response is contained in Enclosure 1, which is proprietary. The non-proprietary version of the response is contained in Enclosure 2.
Response - 4.b The SLMCPR values listed in the first section of Table 3 of enclosures B and C are estimates of SLMCPR that are based upon the MIP / RIP correlation. These estimates are used only for comparison to the Monte Carlo SLMCPR values that are shown in the second section of Table 3. The Monte Carlo based values of the SLMCPR calculation are ultimately used as the basis of the Technical Specification SLMCPR.
The estimated impacts shown in the first section of Table 3 are applicable to the estimated value of SLMCPR (used for comparison only) and not applicable to the Monte Carlo based calculation of SLMCPR, or the associated Technical Specification.
Tables 4 and 5 identify uncertainties that are incorporated within the Monte Carlo calculation of SLMCPR, and identify three differences from NRC approved values.
Section 2.2 of enclosures B and C contains details regarding these differences.
As described by section 2.4 of enclosures B and C, the limiting bundles in the Cycle 14 SLMCPR calculation do not exhibit any axial power shapes that would be susceptible to SLMCPR penalties, including inlet, cosine, outlet, or double humped. Therefore, there were no axial power shape penalties applied to the calculation of the SLMCPR.
Attachment L-1 1-031 Page 4 of 6 There are no methodology deviations proposed by this change. Applicable uncertainty deviations, penalties, and Part 21 issues have been incorporated into the calculation of the SLMCPR and are conservative relative to NRC approved values.
This response supersedes the response in Enclosures 1 and 2.
NRC Staff Question 5 Please provide an updated version of powerlflow map for, Cycle 14 operation including stability Option III features of scram region and controlled entry region for back up stability protection.
Response
An updated two loop power/flow map and an updated single loop power/flow map for Cycle 14 operation, which includes the stability Option III features of the scram region and the controlled entry region for back up stability protection follow.
Backup Stability Protection Regions - Two Loop Power - Flow Map Nominal Feedwater Temoeratures 100 1
90, Note: Lo~1ine does not change a5 Yvith arapid change in core Row.
M C5ontrolled EntrtI ego-70 Imm ediate rs 60 ManualScramR red c
20-0 5
10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 05 100 105 110 CORE FLOW % Rated 0
5 10 15 20 25 30 35 40 45 50 55 60 65 ý 70 75 80 85 90 96 100 105.
110 115 CORE FLOW (PAlbs1Hr)
Attachment L-1 1-031 Page 5 of 6 Backup Stability Protection Regions - Single Loop Power - Flow Map Nominal Feedwater Temoeratures 1101 105 100 85 80 75 70 655
~50 4.5 40 3,5 30 25 20 15 10 5-0 0
5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 105 110 CORE FLOW % Rated 0
5 10 15 20 25 30 35 40 45 50 55 60 66 70 75 80 85 90 95 100 1oo 110 115 CORE FLOW (Mtisft)
Where:
Line A: Natural circulation.
Line B: Slow speed, minimum flow control valve position.
Line C: Slow speed, maximum flow control valve position.
Line D: Fast speed, minimum flow control valve position.
Point F: 100 percent power, 100 percent flow, 104 million pounds mass/hour.
Point G: Lowest allowable flow at rated power (100 percent power, 81 percent flow).
Line H: 100 percent flow, 104 million pounds mass/hour.
Line I: Maximum allowable core flow, 105 percent, 109.2 million pounds mass/hour.
Attachment L-1 1-031 Page 6 of 6 Area J: Jet pump and reactor recirculation pump cavitation region; fast speed operation is interlocked to delta pressure, reactor dome to pump suction. Jet pump cavitation is limiting.
Area K: Flow control valve cavitation region; fast speed operation is interlocked to feedwater flow.
Area L: Physically unattainable region of operation. This region and natural circulation line may vary slightly through plant life.
L-1 1-031 GNF "LRW-FEN-KL1-1 1-007, Response to NRC RAIs 1 - 4 on Perry Nuclear Power Plant Cycle 14 SLMCPR Submittal" Non-Proprietary Information (Nine pages follow)
ENCLOSURE 2 LRW-FEN-KLI-11-007 Response to NRC RAIs 1 - 4 on Perry Nuclear Power Plant Cycle 14 SLMCPR Submittal Non-Proprietary Information-Class I (Public)
INFORMATION NOTICE This is a non-proprietary version of LRW-FEN-KL1-11-007 Enclosure 1, which has the proprietary information removed. Portions of the document that have been removed are indicated by white space inside open and closed bracket as shown here ((
)).
LRW-FEN-KL1-11-007 Non-Proprietary Information-Class I (Public)
Page 1 of 8 REQUEST FOR ADDITIONAL INFORMATION PERRY NUCLEAR POWER PLANT. UNIT NO. 1 DOCKET NO. 50-440 The Nuclear Regulatory Commission (NRC) staff has reviewed the October 21, 2010 (Agencywide Documents Access and Management System Accession No. ML102980451),
FirstEnergy Nuclear Operating Company submittal regarding changes to the Perry Nuclear Power Plant Cycle 14 Safety Limit Minimum Critical Power Ratios (SLMCPRs). The NRC staff has determined that the following information is needed in order to complete its review:
- 1. Please provide:
(a)
The number of fuel assemblies for each fuel type in Figures 1 and 2 for Cycle 14 and Cycle 1.
(b)
Core map to show those bundles experienced 0.1 percent boiling transition criterion of limiting cases for single loop operation (SLO) and two-loop operation (TLO).
RESPONSE TO ITEM (la): Figures 1 & 2 (of Enclosure B and C) core descriptions are as follows including fuel type identifier from Figures 1 & 2, Bundle Name, number of bundles loaded in each core and the first cycle loaded.
Table RAI-01-1: Figure 1 (Cycle 14) Core Description - Fuel Type, Bundle Name, Number of Bundles, and Cycle Loaded Fuel Bundle Name Number of Cycle Type Bundles Loaded A
GE1 4-P1 OSNAB408-16GZ-120T-1 50-T6-3373 56 14 B
GE14-P1OSNAB411-12G7.0/1G6.0-120T-150-T6-3371 32 14 C
GE14-Pl OSNAB409-15GZ-120T-.1 50-T6-3372 76 14 D
GE14-Pl OSNAB404-16GZ-120T-1 50-T6-3370 20 14 E
GE14-Pl OSNAB407-16GZ-120T-1 50-T6-3374 40 14 F
GE14-P1 OSNAB407-16GZ-1 20T-150-T6-3374 20 14 G
GE 14-P 1OSNAB409-15GZ-1 20T-1 50-T6-3372 8
14 H.
GE14-P1OSNAB404-16GZ-1 20T-1 50-T6-3370 4
14 I
GE1 4-P1 OSNAB413-15GZ-1 20T-1 50-T6-2938 52 12 J
GE14-P1 OSNAB405-16GZ-1 20T-1 50-T6-2939 46 12 K
GE14-P1 OSNAB405-16GZ-1 20T-1 50-T6-2939 86 12 L
GE1 4-P1 OSNAB404-18GZ-1 20T-1 50-T6-3113 56 13 M
GE14-P1OSNAB409-17GZ-120T-150-T6-3114 56 13 N
GE14-P1OSNAB413-14G7.0-120T-150-T6-3115 36
.13 0
GE14-P1OSNAB411-17GZ-120T-150-T6-3116 56 13 P
GEl 4-P1OSNAB409-15GZ-120T-150-T6-3372 4
14 Q
GEl4-P1OSNAB404-18GZ-120T-150-T6-3113 56 13 R
GE14-P1OSNAB413-14G7.0-120T-150-T6-3115 4
13 S
GE14-P1OSNAB411-17GZ-120T-150-T6-3116 16 13 T
GE14-P1OSNAB411-12G7.0/1G6.0-120T-150-T6-3371 24 14
LRW-FEN-KL1-11-007 Non-Proprietary Information-Class I (Public)
Page. 2 of 8 Table RAI-01-2: Figure 2 (Cycle 13) Core Description - Fuel T Number of Bundles. and Cvcle Loaded ype, Bundle Name, Fuel Bundle Name Number of Cycle Type Bundles Loaded A
GE14-P1OSNAB413-16GZ-120T-150-T6-2580 4
10 B
GE14-P1OSNAB413-16GZ-120T-150-T6-2581 3
10 C
GE14-P1OSNAB413-16GZ-120T-150-T6-2810 61 11 D
GE14-P1OSNAB411-18GZ-120T-150-T6-2811 116 11 E
GE14-P1OSNAB413-15GZ-120T-150-T6-2938 92 12 F,
GE14-P1OSNAB405-16GZ-120T-150-T6-2939 48 12 G -
GE14-P 10SNAB405-16GZ-120T-150-T6-2939 144 12 H
GE14-P 1OSNAB404-18GZ-120T-150-T6-3113 56 13 1
GE14-P1OSNAB409-17GZ-1 20T-150-T6-3114 56 13 J
GE14-P1OSNAB413-14G7.0-120T-150-T6-3115 36 13 K
GE14-P1OSNAB411-17GZ-120T-150-T6-3116 56 13 L
GE14-P1OSNAB404-18GZ-120T-150-T6-3113 56 13 M
GE14-P1OSNAB413-14G7.0-120T-150-T6-3115 4
13 N
GE14-P1OSNAB411-17GZ-120T-150-T6-3116 16 13 RESPONSE TO ITEM (1.b): The bundle groupings for the Two-Loop Operation (TLO)
SLMCPR calculations is shown in Table RAI-01 -3, along with the number of bundles in the group, their contribution to percent number of rods in boiling transition (NRSBT) and the group average exposure. The 2-dimensional map of the bundle groupings is shown in Figure RAI-01-1. The bundle grouping for the Single Loop Operation (SLO) SLMCPR calculations is shown in Table RAI-01-4, along with the number of bundles in the group, their contribution to % NRSBT and the group average exposure. The 2-dimensional map of the bundle groupings is shown in Figure RAI-01-2. ((
)). The TLO is ((
)) and the SLO is ((
1))
LRW-FEN-KL1-11-007 Non-Proprietary Information-Class I (Public)
Page 3 of 8 Table RAI-01-3: Bundle group, Number of bundles, type, % contribution to NRSBT, and group exposure for TLO.
I I
.1 1
].
Figure RAI-01-1: Two-dimensional map of the bundle groupings for percent contribution to NRSBT for TLO.
LRW-FEN-KL1-11-007 Non-Proprietary Information-Class I (Public)
Page 4 of 8 Table RAI-01-4: Bundle group, Number of bundles, type, % contribution to NRSBT, and group exposure for SLO.
((:
)).
))
Figure RAI-01-2: Two-dimensional map of the bundle groupings for percent contribution to NRSBT for SLO.
-LRW-FEN-KL1-11-007.
Non-Proprietary Information-Class I (Public)
Page 5 of 8
- 2. Please provide the details of.a final core loading pattern as shown in Figure 1 including procedures, guidelines, criteria, and approved methodologies used for this analysis.
RESPONSE TO ITEM (2): The loading pattern is developed by GNF based on FirstEnergy Nuclear Operating Company (FENOC) input. Among the inputs are:
Cycle Energy Requirements - fuel bundle design (nuclear) and loading patterns Thermal Limit Margins Reactivity Margins - minimum shutdown margin, minimum and maximum hot excess reactivity o
Discharge Exposure Limitations and Other Limits as established by safety analysis Desired Control Rod Patterns - sequences and durations Channel Distortion Minimization Methods used to analyze the core-loading pattern arie in accordance with GESTAR-II.
GESTAR-II is the umbrella for all procedures, guidelines, criteria, and methodologies cited in Enclosures B and C used for this analysis. There is no change in methodologies cited in Enclosures B and C. This is a SLMCPR Technical Specifications change with methodologies cited in Enclosures B and C. SLMCPR is not the primary driver in developing the final core-loading pattern. The energy plan, reactivity, and thermal margins are the primary drivers.
LRW-FEN-KLI-11-007 Non-Proprietary Information-Class I (Public)
Page 6 of 8
- 3. Please provide:
(a)
An approximation of the correlation for MCPR Importance Parameter (MIP) and R-Factor Importance Parameter (RIP) including applicable fuel related coefficients and constants leading to the results of TLO SLMCPR estimate using the MIP/RIP Correlation shown in Table 3.
(b)
Justification that the approximation is still applicable to GE14 fuel considering there are no GE14 data points in Figure 5.
(c)
An updated Figure 5 including GE14 fuel assembly.
RESPONSE TO ITEM (3.a): The correlation provides an estimate to check the reasonableness of the Monte Carlo result. It is not used for any other purpose. The methodology and final SLMCPR is based on the rigorous Monte Carlo analysis. The MIP formulation is provided in NEDC-32601P-A. RIP is similarly formulated, but is in terms of bundle R-Factor rather than MCPR. A description of the correlation used for SLMCPR estimate using the MIPRIP correlation is provided below.
LRW-FEN-KL1-1 1-007 Non-Proprietary Information-Class I (Public)
Page 7 of 8 RESPONSE TO ITEMS (3.b) & (3.c): The 10x10 GE14 and GNF2 data points from several cases are added to Figure 5. As shown by the inclusion of these points, the approximation remains applicable to GE14 fuel.
Also updated are the lattice configurations (e.g. 8x8, 9x9, 10x10) of each fuel product line.
1[
LRW-FEN-KL1-11-007 Non-Proprietary Information-Class I (Public)
Page 8 of 8
- 4. In Section 2.1 of Enclosures B and C "Major Contributors to SLMCPR Changes," it states that "Table 3 presents estimated impacts on the TLO SLMCPR due to methodology deviations, penalties, and/or uncertainties deviations from approved values." Please provide:
(a)
Calculation details about how the impact on the SLMCPR from R-Factor of less than 0.005 and from core flow rate of 0.003 is generated in Table 3.
(b)
Justification that the proposed SLMCPR values for TLO and SLO are conservative related to "methodology deviations, penalties and/or uncertainties deviations from approved values," or any fuel related Part 21 issues not listed in Table 3.
RESPONSE TO ITEM (4.a): The intent of the correlation is to provide an estimate to check the reasonableness of the Monte Carlo result.
It is not used for any other purpose. The methodology and final SLMCPR is based on the rigorous Monte Carlo analysis. The results are conservative because: (1) the uncertainties are increased relative to the methodology cited in Enclosures B and C values, and (2) consequently, the SLMCPR estimate increases as the result of the increased uncertainties.
There are two items in Table 3 that result in the increase of the estimated SLMCPR:
(1) R-factor, and (2) Core Flow Rate. These items are discussed below.
(1) The R-Factor uncertainty increase is discussed in Section 2.2.1 of Enclosures B and C. It accounts for an increase in channel bow due to the phenomena called control blade shadow corrosion-induced channel bow, which is not accounted for in the channel bow uncertainty component of the approved R-Factor uncertainty.
Reference 4 of Enclosures B and C provides the technical justification for this increase.
(2) The core flow rate uncertainty increase, and the associated random effective TIP reading uncertainty increase, is discussed in Section 2.2.2 of Enclosures B and C. The treatment of the core flow uncertainty is based on the assumption that the signal to noise ratio deteriorates as core flow is reduced. It is assumed that the absolute uncertainty remains the same as the flow decreases so that the percentage uncertainty increases inversely proportional to the change in core flow. This is conservative relative to the core flow uncertainty since the variability in the absolute flow is expected to decrease as the flow decreases.
The magnitudes of the estimated impacts were determined by generic Monte Carlo sensitivity studies to the respective uncertainties.
RESPONSE TO ITEM (4.b): This is a SLMCPR Technical Specifications change with no changes in methodologies cited in Enclosures B and C. All factors related to any fuel-related Part 21 issues are included in the SLMCPR Calculation.