ML110490572
| ML110490572 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/17/2011 |
| From: | David Helker Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CFL-EXN-HH2-11-005 | |
| Download: ML110490572 (24) | |
Text
Exelkn.
Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 www.exelonCOTP.COM Nuclear PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 February 17, 2011 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Limerick Generating Station, Unit 2 Facility Operating License No. NPF-85 NRC Docket No. 50-353
Subject:
Response to Request for Additional Information Concerning the Safety Limit Minimum Critical Power Ratio Change License Amendment Request
- 1) Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request - Safety Limit Minimum Critical Power Ratio Change," dated December 15, 2010
References:
- 2) Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to M. J.
Pacilio (Exelon Generation Company, LLC), "Limerick Generating Station, Unit 2 - Request for Additional Information Regarding Proposed Technical Specification Safety Limit Minimum Critical Power Ratio Changes (TAC NO.
ME5182)," dated February 4, 2011 In the Reference 1 letter, Exelon Generation Company, LLC (Exelon) requested a proposed change to modify Technical Specification (TS) 2.1 ("Safety Limits"). Specifically, this change incorporates revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the cycle specific analysis performed by Global Nuclear Fuel for Limerick Generating Station (LGS), Unit 2, Cycle 12.
In the Reference 2 letter, the U.S. Nuclear Regulatory Commission staff requested additional information. Attached is our response to this request.
Attachment I transmitted herewith contains Proprietary Information.
When separated from attachments, this document is decontrolled.
Response to Request for Additional Information Concerning the Safety Limit Minimum Critical Power Ratio Change License Amendment Request February 17, 2011 Page 2 (letter from C. F. Lamb (Global Nuclear Fuel) to J. Tusar (Exelon Generation Company, LLC), dated February 16, 2011) contains information proprietary to Global Nuclear Fuel. Global Nuclear Fuel requests that the document be withheld from public disclosure in accordance with 10 CFR 2.390(b)(4). Attachment 2 contains a non-proprietary version of the Global Nuclear Fuel document. An affidavit supporting this request is also contained in.
Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th of February 2011.
Respectfully, David P. Helker Manager, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Proprietary Version of Global Nuclear Fuel Letter
- 2) Non-Proprietary Version of Global Nuclear Fuel Letter and Affidavit cc:
USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS R. R. Janati, Commonwealth of Pennsylvania
ENCLOSURE 3 CFL-EXN-HH2-11-005 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, CFL-EXN-HH2-11-005, C. Lamb (GNF-A) to J. Tusar (Exelon Nuclear), entitled "GNF Response to NRC RAIs for Limerick Generating Station Unit 2 SLMCPR Submittal," dated February 16, 2011.
GNF-A proprietary information in Enclosure 1, which is entitled "Response to NRC RAIs 1 through 8 for Limerick Generating Station Unit 2 SLMCPR Submittal," is identified by a dotted underline inside double square brackets.
((Thli.s
.e.t.e.n.e.i.a.ex.a.p.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 Proiect v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a.
Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;
- b.
Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
- c.
Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A; CFL-EXN-HH2-11-005 Affidavit Page I of 3
- 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.
CFL-EXN-HH2-11-005 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 16 1h day of February 2011.
Anthony P. Reese Manager, Reload Design and Analysis Global Nuclear Fuel - Americas, LLC CFL-EXN-HH2-11-005 Affidavit Page 3 of 3
Proprietary Notice This letter transmits proprietary information in accordance with 10CFR2.390. Upon the removal of Enclosure 1 the balance of the letter may be QF considered non-proprietary.
Global Nuclear Fuel A Jbmf Vedro 0 CFTG sin
&ta Charles F. Lamb Global Nuclear Fuel - Americas, LLC Customer Project Manager Castle Hayne Road, Wilmington, NC 28402 (910) 819-5613, chartesf.lamb@ge.com CFL-EXN-HH2-11-005 February 16, 2011 Mr. Jim Tusar Exelon Nuclear 200 Exelon Way KSA-2N Kennett Square, PA 19348
Subject:
GNF Response to NRC RAIs for Limerick Generating Station Unit 2 SLMCPR Submittal
References:
- 1. "Contract between Exelon and Global Nuclear Fuel for Fuel Fabrication and Related Components and Services for Units 1 and 2 of the Limerick Generating Station,"
September 26, 2003, as amended.
Dear Mr. Tusar:
This letter transmits the Global Nuclear Fuel (GNF) response to the Nuclear Regulatory Commission (NRC) Requests for Additional Information (RAIs). contains the GNF response to RAIs 1 through 8. Please note that Enclosure 1 contains proprietary information of the type that GNF maintains in confidence and withholds from public disclosure. The information has been handled and classified as proprietary to GNF as indicated in the enclosed affidavit. The affidavit contained in Enclosure 3 identifies that the information contained in Enclosure 1 has been handled and classified as proprietary to GNF.
GNF hereby requests that the information in Enclosure 1 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17. Enclosure 2 is a non-proprietary version of Enclosure 1.
GNF requests that any transmittal of this proprietary information to the NRC be accompanied by the enclosed affidavit and proprietary notice. In order to maintain the applicability of the affidavit and to meet the requirements of 10 CFR 2.390, the transmittal to the NRC should:
- 1) Faithfully reproduce the proprietary information,
- 2) Preserve the proprietary annotations, and
- 3) Include the words similar to "GNF Proprietary Information" at the top of first page and each page containing the proprietary information.
Further, 10 CFR 2.390 requires that the proprietary information be incorporated, as far as possible, into separate paper.
Therefore, Enclosure 1 hereto contains the proprietary information, and the non-proprietary and redacted information is provided in Enclosure 2.
Based on past discussions with the NRC, GNF has been encouraged to request its customers to provide a paragraph similar to the following in the customer letters transmitting proprietary information to the NRC in order to clearly indicate the proprietary nature of the information and to document the source of the proprietary information as indicated in the GNF affidavit.
"The enclosed RAI responses contain proprietary information as defined by 10 CFR 2.390.
GNF, as the owner of the proprietary information, has executed the enclosed affidavit, which identify that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.
The proprietary information was provided to Exelon Nuclear in a GNF transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the enclosed RAI responses such that the affidavit remains applicable.
GNF hereby requests that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17. A non-proprietary version of the RAI responses also is provided."
The verified inputs associated with these RAI responses are included eDRF Section 0000-0129-5307.
A signed copy of this letter is included in eDRF Section 0000-0129-5722. If you have any questions, please do not hesitate to contact me.
Sincerely, Charles F. Lamb Customer Project Manager Enclosures
- 1. Response to NRC RAIs 1 through 8 for Limerick Generating Station Unit 2 SLMCPR Submittal - GNF Proprietary Information - Class III (Confidential)
- 2. Response to NRC RAIs 1 through 8 for Limerick Generating Station Unit 2 SLMCPR Submittal - Non-Proprietary Information - Class I (Public)
- 3. Affidavit for Enclosure 1
ATTACHMENT 2 Non-Proprietary Version of Global Nuclear Fuel Letter and Affidavit
ENCLOSURE 2 CFL-EXN-HH2-11-005 Response to NRC RAIs 1 through 8 for Limerick Generating Station Unit 2 SLMCPR Submittal Non-Proprietary Information-Class I (Public)
INFORMATION NOTICE This is a non-proprietary version of CFL-EXN-HH2-11-005 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 ((
I].
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 1 of 14 REQUEST FOR ADDITIONAL INFORMATION LIMERICK GENERATING STATION, UNIT 2 LICENSE AMENDMENT REQUEST REGARDING SAFETY LIMIT MINIMUM CRITICAL POWER RATIO CHANGE DOCKET NO. 50-353 By letter dated December 15, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML103500180), Exelon Generation Company, LLC (Exelon, the licensee) submitted a license amendment request (LAR) proposing to modify Technical Specification (TS) 2.1, "Safety Limits," for Limerick Generating Station (LGS), Unit 2.
The requested change involves revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) calculated as a result of the cycle-specific analysis performed by Global Nuclear Fuel (GNF) to support operation in the upcoming LGS, Unit 2, Cycle 12. The Nuclear Regulatory Commission (NRC) staff has been reviewing the submittal and has determined that additional information is needed to complete its review.
RAI-01: Please provide:
(a) The number of fuel assemblies for each fuel type in Figures 1 and 2 for Cycle 12 and Cycle 11, including Cycle 11 (thrice-burn) through Cycle 12 (fresh fuel), and; (b) A core map to show those bundles experiencing the 0.1% boiling transition for single loop operation (SLO) and two-loop operation (TLO).
RESPONSE TO RAI-01.a: The following tables are provided for clarification:
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 2 of 14 Table RAI-01-1 Figure 1 (Cycle 12) Core Description - Fuel Type, Bundle Name, Number of Bundles, and Cycle Loaded Fuel-Number of Cycle Type Bundle Name Bundles Loaded Irradiated:
F GE14-P1OCNAB389-14GZ-120T-150-T6-3157 56 11 G
GE14-P1OCNAB389-15GZ-120T-150-T6-3158 64 11 H
GE14-P10CNAB391-13GZ-120T-150-T6-3159 88 11 I
GE14-P1OCNAB391-13G8.0-120T-150-T6-3160 32 11 J
GE14-P1OCNAB390-12GZ-120T-150-T6-3161 40 11 K
GE14-P1OCNAB409-16GZ-120T-150-T6-2956 8
10 L
GE14-P10CNAB410-16GZ-120T-150-T6-2950 44 10 M
GE14-P10CNAB409-12GZ-120T-150-T6-2951 16 10 0
GE14-P1OCNAB410-15GZ-120T-150-T6-2952 64 10 P
GE14-P 10CNAB408-14GZ-120T-150-T6-2953 32 10 Q
GE14-P1OCNAB410-13GZ-120T-150-T6-2955 44 10 Fresh:
A GNF2-P10CG2B404-12G6.0-120T2-150-T6-3643 56 12 B
GNF2-P1 0CG2B386-2G8.0/13G7.0-120T2-150-T6-3644 24 12 C
GNF2-P 1 0CG2B389-14GZ-1 20T2-150-T6-3645 48 12 D
GNF2-P 1 0CG2B391-15GZ-1 20T2-150-T6-3646 32 12 E
GNF2-P1 0CG2B392-14GZ-1 20T2-150-T6-3647 16 12 N
GN F2-P1 0CG2B396-6G7.0/6G6.0-120T2-150-T6-3648 32 12 R
GNF2-P1 0CG2B391-14GZ-1 20T2-150-T6-3725 8
12 S
GNF2-P1 0CG2B404-12G6.0-120T2-150-T6-3643 8
12 T
GN F2-P1 0CG2B389-14GZ-1 20T2-150-T6-3645 16 12 U
GNF2-P1 0CG2B391-15GZ-1 20T2-150-T6-3646 8
12 V
GNF2-P1 0CG2B392-14GZ-1 20T2-150-T6-3647 20 12 W
GNF2-P10CG2B391-14GZ-120T2-150-T6-3725 8
12
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 3 of 14 Table RAI-01-2 Figure 2 (Cycle 11) Core Description - Fuel Type, Bundle Name, Number of Bundles, and Cycle Loaded Fuel Bundle Name Number of Cycle Type Bundles Loaded Irradiated:
A GE14-PiOCNAB400-15GZ-120T-150-T6-2832 72 9
B GE 14-P 1OCNAB397-14GZ-120T-150-T6-2833 140 9
H GE 14-P 1OCNAB409-16GZ-120T-150-T6-2956 16 10 I
GE14-P1OCNAB410-16GZ-120T-150-T6-2950 56 10 J
GE14-P1OCNAB409-12GZ-120T-150-T6-2951 16 10 K
GE14-P1OCNAB410-15GZ-120T-150-T6-2952 64 10 L
GE14-P1OCNAB408-14GZ-120T-150-T6-2953 32 10 M
GE 14-P1OCNAB405-14GZ-120T-150-T6-2954 24 10 N
GE14-P1OCNAB410-13GZ-120T-150-T6-2955 64 10 Fresh:
C GE14-P1OCNAB389-14GZ-120T-150-T6-3157 56 11 D
GE14-P1OCNAB389-15GZ-120T-150-T6-3158 64 11 E
GE14-P1OCNAB391-13GZ-120T-150-T6-3159 88 11 F
GE14-P1OCNAB391-13G8.0-120T-150-T6-3160 32 11 G
GE14-P1OCNAB390-12GZ-120T-150-T6-3161 40 11 RESPONSE TO RAI-01.b: The bundle groupings for the Two-Loop Operation (TLO) SLMCPR calculations are 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 at the analysis point. The 2-dimensional map of the bundle groupings is shown in Figure RAI-01-1 for the upper left hand quadrant of the core. 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 for the upper left hand quadrant of the core. ((
)). Both the TLO and SLO are ((
))
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 4 of 14 Table RAI-01-3 Bundle Group, Number of Bundles, Bundle Type, % Contribution to NRSBT, and Group Exposure for TLO Figure RAI-01-1 Two-dimensional map of the bundle groupings for percent contribution to NRSBT for TLO
))
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 5 of 14 Table RAI-01-4 Bundle Group, Number of Bundles, Bundle 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 I]
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 6 of 14 RAI-02: Core design is an iterative process designed to develop an optimal configuration that meets operations requirements. Please provide:
(1) The details of a final core loading pattern as shown in Figure 1, including core design procedures, guidelines, criteria, and approved methodologies used for this Cycle 12 analysis, and (2)
A description of the core design process used for Cycle 12, including the Quality Assurance and Quality Control procedures to assure that the final design meets the SLMCPR limits for the fuel used in the core.
RESPONSE TO RAI-02.1: The loading pattern is developed collaboratively by GNF and Exelon based on Exelon 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
" 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 are in accordance with GESTAR-II.
GESTAR-II is the umbrella for all procedures, guidelines, criteria, and methodologies used for this analysis. There is no change in approved methodologies. This is a SLMCPR Technical Specifications change within approved methodologies. SLMCPR is not the primary driver in developing the fuel cycle core design. The energy plan, reactivity, and thermal margins are the primary drivers.
RESPONSE TO RAI-02.2: Reload core design and analysis activities are performed in accordance with the requirements of 10 CFR 50 Appendix B. Engineering procedures require that the responsible engineer document the core design in a manner that identifies the design inputs and key results, including the SLMCPR limits for the fuel cycle. The cycle design inputs are documented and approved by the customer.
Several project review meetings, which include the customer, are conducted during the cycle design and analysis activities. The design records for each element of the core design, including the determination of the SLMCPR, are verified by a qualified peer and approved by the responsible manager.
The SLMCPR is consistent with the final core design.
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 7 of 14 RAI-03: The NRC staff considers GNF2 a new fuel design with regards to the four restrictions identified in the Safety Evaluation of General Electric (GE) Licensing Topical Reports NEDC-32601P, NEDC-32694, and Amendment 25 to NEDE-24011-P-A.
All of these topical reports are referenced in the application. Given that LGS, Unit 2, Cycle 12 uses a core loading pattern which includes GNF2 fuel, please provide the following:
(1) An evaluation of the four restrictions in NEDC-32601P, NEDC-32694 and Amendment 25 to NEDC-2401 1-P-A, (2) A description that explains under what conditions the methodologies listed in Section 1.0 of the LAR, Attachment 41 are applied to the LGS, Unit 2, Cycle 12
- analysis, (3) The reason why GNF2 has much higher critical power uncertainty than that of GE14 as shown in Table 6 of Attachment 4, and (4) A clarification for the statement "no new GNF fuel designs are being introduced in Limerick [Unit] 2 Cycle 12" in Section 2.5 of the LAR, Attachment 4.
RESPONSE TO RAI-03.1: The four restrictions for GNF2 were determined acceptable by the NRC review of the "GNF2 Advantage Generic Compliance with NEDE024011-P-A (GESTAR II)," NEDC-33270P, Revision 0, FLN-2007-011, March 14, 2007. Specifically, in the NRC audit report (ML081630579) for the said document, Section 3.4.1 page 59 states:
"The NRC staff's SE of NEDC-32694P-A (Reference 69 of NEDE 33207P) provides four actions to follow whenever a new fuel design is introduced.
These four conditions are listed in Section 3.0 of the SE. The analysis and evaluation of the GNF2 fuel design was evaluated in accordance with the limitations and conditions stated in the NRC staffs SE, and is acceptable."
Additionally, the NRC audit report (ML081630579) Section 3.4.2.2.1 page 59 states:
"The NRC staff finds that the calculational methods, evaluations and applicability of the OLMCPR and SLMCPR are in accordance with existing NRC-approved methods and thus valid for use with GNF2 fuel."
1 Attachment 4 to the LAR dated December 15, 2010 is a proprietary document titled, "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR, Limerick 2 Cycle 12." A non-proprietary version of this document can be found as Attachment 5 to the LAR dated December 15, 2010, same title (ADAMS Accession No.ML103500180).
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 8 of 14 RESPONSE TO RAI-03.2: There are 4 references listed in Section 1.0 of Attachment 4. The applicability of each of the four references is discussed. The four references are:
- 1. NEDC-32601P-A, "Methodology and Uncertainties for Safety Limit MCPR Evaluations," August 1999.
- 2. NEDC-32694P-A, "Power Distribution for Safety Limit MCPR Evaluations," August 1999.
- 3. NEDC-32505P-A, "R-Factor Calculation Method for GEl1, GE12 and GE13 Fuel,"
Revision 1, July 1999.
- 4. NEDO-10958-A, "General Electric BWR Thermal Analysis Basis (GETAB): Data, Correlation and Design Application," January 1977. Table 2 identifies the actual methodologies used for the Cycle 11 and Cycle 12 SLMCPR calculations. References A and B are directly applicable to the analysis.
Reference C is the generic R-Factor methodology report that describes the changed methodology that was adopted after part length rods were introduced. The NRC staffs SE for NEDC-32505P-A has a requirement that the applicability of the R-Factor methodology is confirmed when a new fuel type is introduced. The confirmation for GNF2 was determined to be acceptable by the NRC staff review of the "GEXL17 Correlation for GNF2 Fuel," NEDC-33292P, Revision 0, FLN-2007-01 1, March 14, 2007 in the NRC audit report (ML081630579)
Section 3.5.5 page 62.
Reference D is not used for this specific analysis.
RESPONSE TO RAI-03.3: It should be noted that the correlation uncertainty, or standard deviation, for GEXL correlations tends to be in the range of ((
)). There is no definitive explanation for the higher uncertainty with GEXL17. While it is acknowledged that the GEXL17 standard deviation is slightly higher than that associated with GEXL14, the absolute magnitude remains typical and GEXL17 adequately predicts the onset of boiling transition for GNF2.
RESPONSE TO RAI-03.4: GNF's position is that GNF2 is an evolutionary fuel product based on GE14. It is not considered a new fuel design as it maintains the previously established 10x10 array and 2 water rod makeup.
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 9 of 14 RAI-04: Please provide 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 MIPRIP Correlation,"
shown in Table 3.
RESPONSE TO RAI-04: 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.
1]
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 10 of 14 RAI-05: In Section 2.1 "Major Contributors to SLMCPR Changes," it states that "Table 3 presents estimated impacts on the TLO SLMCPR due to methodology deviations, penalties, and/or uncertainty deviations from approved values." Please provide:
(1) Calculation details and justification that the results listed in Table 3 are conservative related to "methodology deviations, penalties, and/or uncertainty deviations from approved values," and (2) Justification that all affected factors, including any fuel related issues under Title 10 of the Code of Federal Regulations (10 CFR) Part 21, are included in Table 3.
RESPONSE TO RAI-05.1: 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 approved methodology values; and (2) consequently, the SLMCPR estimate increases as a result of the increased uncertainties.
There are three items in Table 3 that result in the increase of the estimated SLMCPR:
(1) R-Factor, (2) Core Flow Rate, and (3) LPRM Update. These items are discussed below.
(1) The R-Factor uncertainty increase is discussed in Section 2.2.1 of Attachment 4. 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 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 Attachment 4. 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.
(3) The LRPM update uncertainty increase is discussed in Section 2.2.3 of Attachment
- 4. It is performed to adequately address the LPRM update/calibration interval in the LGS, Unit 2, Technical Specifications.
The NRC approved this change in Amendment No. 156 (October 28, 2008) to Facility Operating License No. NPF-85 for LGS Unit 2.
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 11 of 14 RESPONSE TO RAI-05.2: There are no known 10 CFR Part 21 factors that affect the LGS Unit 2 Cycle 12 SLMCPR calculations.
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 12 of 14 RAI-06: Please Identify how many of the 10x10 (GE14, GNF2) data points shown in new Figure 5 reflect GNF2 data, because new Figure 5 only shows combined data points for GEl4 and GNF2.
RESPONSE TO RAI-06: The 10x10 (GE14, GNF2) points shown in Figure 5 reflect transition cores with a mix of 10x10 fuel products.
Thus, there are not specific GNF2 data points in Figure 5. The table following Figure 5 provides the GE14 and GNF2 batch sizes, and the corresponding ((
)) for the 1Ox10 (GE14, GNF2) points in the figure. The table is in ascending order of the abscissa of Figure 5 for ease of correlation to the figure. Sums of batch sizes and ((
)) may not add to 100% due to rounding and/or the presence of other fuel products in the core.
Batch Fraction (%)
[
GE14 GNF2 31.0 38.5 28.6 71.4 64.4 35.6 31.0 38.5 31.0 38.5 64.4 35.6 28.6 71.4 28.6 71.4 67.4 32.6 64.4 35.6 67.4 32.6 67.4 32.6
))
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 13 of 14 RAI-07: Is the LGS, Unit 2, Cycle 12 operation with GNF2 fuel impacted by the bent spacer wing operating experience (see 10 CMR Part 21 report number 2010-19-00, ADAMS Accession No. ML101370065)? If so, please identify the impacts of such operation on fuel thermal performance and evaluation.
GNF Response to RAI-07: GNF2 bent spacer wing related Part 21 issues are not applicable to Limerick Unit 2 Cycle 12 because the GNF2 fuel in this cycle is not impacted by the Part 21 issue.
CFL-EXN-HH2-11-005 Non-Proprietary Information - Class I (Public)
Page 14 of 14 RAI-08: Please provide an updated version of the power/flow map for Cycle 12 operation including stability Option III features of the scram region and controlled entry region.
GNF Response to RAI-08: The updated power/flow map for Cycle 12 for normal feedwater temperature operation including stability Option III features of the scram region and controlled entry region is shown in Figure RAI-08-1.
Figure RAI-08-2 LGS Unit 2 Cycle 12 BSP Region Boundaries for Normal Feedwater Temperature Operation 110 T*-*
u'alQtba Circd&tio~n' 06'6*.....
'Extended Operating Domain; 1 QQ BSP Scram Region boundary 8SP Controlled Entry Region Bound.ry_
80-1 A2 T7 0......
Al ie 65 0
I-2 0 L-.-..-
a' I
30 20 1 0 0
10 20 30 40 50 60 70 80 90 100 110 120 130 Core Flow(%)