ML111600180

License Amendment Request - Safety Limit Minimum Critical Power Ratio Change

ML111600180
Person / Time
Site:	Peach Bottom
Issue date:	06/08/2011
From:	Jesse M Exelon Nuclear, Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML111600188	List: ML111600180
References
GNF-0000-0127-1959-R0-NP
Download: ML111600180 (43)

Text

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PROPRIETARY INFORMATION WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 June 8,2011 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278

Subject:

License Amendment Request - Safety Limit Minimum Critical Power Ratio Change In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (Exelon) requests a proposed change to modify Technical Specification (TS) 2.1.1 (Reactor Core SLs).

Specifically, this change incorporates revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the cycle specific analysis performed by Global Nuclear Fuel for Peach Bottom Atomic Power Station (PBAPS), Unit 3, Cycle 19.

The proposed changes have been reviewed by the Peach Bottom Atomic Power Station Plant Operations Review Committee, and approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program.

In order to support the upcoming refueling outage at PBAPS, Unit 3, Exelon requests approval of the proposed amendment by September 8, 2011. Once approved, this amendment shall be implemented within 30 days of issuance. Additionally, there are no commitments contained within this letter. contains the evaluation of the proposed changes. Attachments 2 and 3 provide the marked up TS page and the retyped TS page, respectively. (letter from C. F. Lamb (Global Nuclear Fuel) to J. Tusar (Exelon Generation Company, LLC), dated May 11, 2011) specifies the new SLMCPRs for PBAPS, Unit 3, Cycle 19. 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. Attachment 5 contains a non-proprietary version of the Global Nuclear Fuel document.

An affidavit supporting this request is also contained in Attachment 5. Attachment 6 contains the power/flow map for Cycles 18 and 19. transmitted herewith contains Proprietary Information.

When separated from Attachment 4, this document is decontrolled.

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 June 8,2011 u.s. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278

Subject:

License Amendment Request - Safety Limit Minimum Critical Power Ratio Change In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (Exelon) requests a proposed change to modify Technical Specification (TS) 2.1.1 ("Reactor Core SLs").

Specifically, this change incorporates revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the cycle specific analysis performed by Global Nuclear Fuel for Peach Bottom Atomic Power Station (PBAPS), Unit 3, Cycle 19.

The proposed changes have been reviewed by the Peach Bottom Atomic Power Station Plant Operations Review Committee, and approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program.

In order to support the upcoming refueling outage at PBAPS, Unit 3, Exelon requests approval of the proposed amendment by September 8, 2011. Once approved, this amendment shall be implemented within 30 days of issuance. Additionally, there are no commitments contained within this letter. contains the evaluation of the proposed changes. Attachments 2 and 3 provide the marked up TS page and the retyped TS page, respectively. (letter from C. F. Lamb (Global Nuclear Fuel) to J. Tusar (Exelon Generation Company, LLC), dated May 11, 2011) specifies the new SLMCPRs for PBAPS, Unit 3, Cycle 19. 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. Attachment 5 contains a non-proprietary version of the Global Nuclear Fuel document.

An affidavit supporting this request is also contained in Attachment 5. Attachment 6 contains the power/flow map for Cycles 18 and 19. transmitted herewith contains Proprietary Information.

When separated from Attachment 4, this document is decontrolled.

U.S. Nuclear Regulatory Commission License Amendment Request Safety Limit Minimum Critical Power Ratio Change June 8, 2011 Page 2 In accordance with 10 CFR 50.91, Exelon is notifying the State of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

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 8 th day of June 2011.

Respectfully, Zi fl A/ttJ /r Michael D. Jes Director, Licenig..&

4 egulatory Affairs Exelon Generation Company, LLC Attachments:

1)

Evaluation of Proposed Changes 2)

Markup of Technical Specifications Page 3)

Retyped Technical Specifications Page 4)

Proprietary Version of Global Nuclear Fuel Letter 5)

Non-Proprietary Version of Global Nuclear Fuel Letter 6)

Power/Flow Map for Cycles 18 and 19 cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland U.S. Nuclear Regulatory Commission License Amendment Request Safety Limit Minimum Critical Power Ratio Change June 8,2011 Page 2 In accordance with 10 CFR 50.91, Exelon is notifying the State of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

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 8th day of June 2011.

Respectfully, Michael D. Jes Director, Licen.

egutatory Affairs Exelon Generation Company, LLC Attachments:

1)

Evaluation of Proposed Changes 2)

Markup of Technical Specifications Page 3)

Retyped Technical Specifications Page 4)

Proprietary Version of Global Nuclear Fuel Letter 5)

Non-Proprietary Version of Global Nuclear Fuel Letter 6)

Power/Flow Map for Cycles 18 and 19 cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland

991Ida 0N OSUO3fl 6uijeiod Ai!I!31?1 POMOUGH C 4!Ufl uo!w1s JOMOd 3iwojy W0j409 LPBGd se6ueq pesodojd 40 U0!jtflIBA3 I jUOWLlOV Evaluation of Proposed Changes Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License No. DPR-56

AT1ACHMENT 1 EVALUATION OF PROPOSED CHANGES CONTENTS

SUBJECT:

Safety Limit Minimum Critical Power Ratio Change 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

4.2 Precedents

4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES CONTENTS

SUBJECT:

Safety Limit Minimum Critical Power Ratio Change 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

4.2 Precedents

4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Evaluation of Proposed Changes License Amendment Request Safety Limit Minimum Critical Power Ratio Page 1 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Facility Operating License No. DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Unit 3.

The proposed change modifies Technical Specification (TS) 2.1.1 (Reactor Core SLs).

Specifically, this change incorporates revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the cycle specific analysis performed by Global Nuclear Fuel for PBAPS, Unit 3, Cycle 19.

2.0 DETAILED DESCRIPTION The proposed change involves revising the SLMCPRs contained in TS 2.1.1 for two recirculation loop operation and single recirculation loop operation. The SLMCPR value for two recirculation loop operation is being changed from 1.07 to 1.09. The SLMCPR value for single recirculation loop operation is being changed from 1.09 to 1.12.

Marked up TS page 2.0-1 showing the requested changes is provided in Attachment 2.

30 TECHNICAL EVALUATION The proposed TS change will revise the SLMCPRs contained in TS 2.1.1 for two recirculation loop operation and single recirculation loop operation to reflect the changes in the cycle specific analysis performed by Global Nuclear Fuel for PBAPS, Unit 3, Cycle 19.

The new SLMCPRs are calculated using NRC-approved methodology described in NEDE 24011-P-A, General Electric Standard Application for Reactor Fuel, Revision 18. A listing of the associated NRC-approved methodologies for calculating the SLMCPRs is provided in Section 1.0 (Methodology) of Attachment 4.

The SLMCPR analysis establishes SLMCPR values that will ensure that during normal operation and during abnormal operational transients, at least 99.9% of all fuel rods in the core do not experience transition boiling if the limit is not violated. The SLMCPRs are calculated to include cycle specific parameters and, in general, are dominated by two key parameters: 1) flatness of the core bundle-by-bundle MCPR distribution, and 2) flatness of the bundle pin-by-pin power/R Factor distribution. Information to support the cycle specific SLMCPRs is included in Attachment

4. That attachment summarizes the methodology, inputs, and results for the change in the SLMCPRs. The PBAPS, Unit 3, Cycle 19 core will consist of GE14 and GNF2 fuel types. contains the power/flow map for Cycles 18 and 19.

No plant hardware or operational changes are required with this proposed change.

Evaluation of Proposed Changes License Amendment Request Safety Limit Minimum Critical Power Ratio Page 1 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Facility Operating License No. DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Unit 3.

The proposed change modifies Technical Specification (TS) 2.1.1 ("Reactor Core SLslI).

Specifically, this change incorporates revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the cycle specific analysis performed by Global Nuclear Fuel for PBAPS, Unit 3, Cycle 19.

2.0 DETAILED DESCRIPTION The proposed change involves revising the SLMCPRs contained in TS 2.1.1 for two recirculation loop operation and single recirculation loop operation. The SLMCPR value for two recirculation loop operation is being changed from;;::: 1.07 to ;;::: 1.09. The SLMCPR value for single recirculation loop operation is being changed from;;::: 1.09 to 2:: 1.12.

Marked up TS page 2.0-1 showing the requested changes is provided in Attachment 2.

3.0 TECHNICAL EVALUATION

The proposed TS change will revise the SLMCPRs contained in TS 2.1.1 for two recirculation loop operation and single recirculation loop operation to reflect the changes in the cycle specific analysis performed by Global Nuclear Fuel for PBAPS, Unit 3, Cycle 19.

The new SLMCPRs are calculated using NRC-approved methodology described in NEDE-24011-P-A, IIGeneral Electric Standard Application for Reactor Fuel, II Revision 18. A listing of the associated NRC-approved methodologies for calculating the SLMCPRs is provided in Section 1.0 (IIMethodologyll) of Attachment 4.

The SLMCPR analysis establishes SLMCPR values that will ensure that during normal operation and during abnormal operational transients, at least 99.9%

of all fuel rods in the core do not experience transition boiling if the limit is not violated. The SLMCPRs are calculated to include cycle specific parameters and, in general, are dominated by two key parameters: 1) flatness of the core bundle-by-bundle MCPR distribution, and 2) flatness of the bundle pin-by-pin power/R-Factor distribution. Information to support the cycle specific SLMCPRs is included in Attachment

4. That attachment summarizes the methodology, inputs, and results for the change in the SLMCPRs. The PBAPS, Unit 3, Cycle 19 core will consist of GE14 and GNF2 fuel types. contains the power/flow map for Cycles 18 and 19.

No plant hardware or operational changes are required with this proposed change.

Evaluation of Proposed Changes License Amendment Request Safety Limit Minimum Critical Power Ratio Page 2

4.0 REGULATORY EVALUATION

4.1 Aorlicable ReuIatory Recjuirements/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 SLMCPR analysis establishes SLMCPR values that will ensure that during normal operation and during abnormal operational transients, at least 99.9% of all fuel rods in the core do not experience transition boiling if the limit is not violated. Thus, the SLMCPR is required to be contained in TS.

4.2 Precedents

The NRC has approved similar SLMCPR changes for a number of plants:

1)

Letter from J. Hughey (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), Peach Bottom Atomic Power Station, Unit 2 Issuance of Amendment RE: Safety Limit Minimum Critical Power Ratio Value Change (TAC NO.

ME3994), dated September 28, 2010 2)

Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), Limerick Generating Station, Unit 2 Issuance of Amendment RE: Safety Limit Minimum Critical Power Ratio Changes (TAC NO.

ME51 82), dated April 5, 2011 4.3 No Significant Hazards Consideration Exelon Generation Company, LLC (Exelon) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1.

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

Response: No.

The derivation of the cycle specific Safety Limit Minimum Critical Power Ratios (SLMCPRs) for incorporation into the Technical Specifications (TS), and their use to determine cycle specific thermal limits, has been performed using the methodology discussed in NEDE-2401 1-P-A, General Electric Standard Application for Reactor Fuel, Revision 18.

The basis of the SLMCPR calculation is to ensure that during normal operation and during abnormal operational transients, at least 99.9% of all fuel rods in the core do not experience transition boiling if the limit is not violated. The new SLMCPRs preserve the existing margin to transition boiling.

Evaluation of Proposed Changes License Amendment Request Safety Limit Minimum Critical Power Ratio Page 2

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, "Technical specifications, II 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 SLMCPR analysis establishes SLMCPR values that will ensure that during normal operation and during abnormal operational transients, at least 99.9%

of all fuel rods in the core do not experience transition boiling if the limit is not violated. Thus, the SLMCPR is required to be contained in TS.

4.2 Precedents

The NRC has approved similar SLMCPR changes for a number of plants:

1)

Letter from J. Hughey (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Unit 2 - Issuance of Amendment RE: Safety Limit Minimum Critical Power Ratio Value Change (TAC NO.

ME3994)," dated September 28,2010 2)

Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Limerick Generating Station, Unit 2 - Issuance of Amendment RE: Safety Limit Minimum Critical Power Ratio Changes (TAC NO.

ME5182)," dated April 5, 2011 4.3 No Significant Hazards Consideration Exelon Generation Company, LLC (Exelon) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No.

The derivation of the cycle specific Safety Limit Minimum Critical Power Ratios (SLMCPRs) for incorporation into the Technical Specifications (TS), and their use to determine cycle specific thermal limits, has been performed using the methodology discussed in NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel, II Revision 18.

The basis of the SLMCPR calculation is to ensure that during normal operation and during abnormal operational transients, at least 99.90/0 of all fuel rods in the core do not experience transition boiling if the limit is not violated. The new SLMCPRs preserve the existing margin to transition boiling.

Evaluation of Proposed Changes License Amendment Request Safety Limit Minimum Critical Power Ratio Page 3 The MCPR safety limit is reevaluated for each reload using NRC-approved methodologies The analyses for Peach Bottom Atomic Power Station (PBAPS), Unit 3, Cycle 19 have concluded that a two recirculation loop MCPR safety limit of 1.09, based on the application of Global Nuclear Fuels NRC-approved MCPR safety limit methodology, will ensure that this acceptance criterion is met. For single recirculation loop operation, a MCPR safety limit of 1.12 also ensures that this acceptance criterion is met. The MCPR operating limits are presented and controlled in accordance with the PBAPS, Unit 3 Core Operating Limits Report (COLR).

The requested TS changes do not involve any plant modifications or operational changes that could affect system reliability or performance or that could affect the probability of operator error. The requested changes do not affect any postulated accident precursors, do not affect any accident mitigating systems, and do not introduce any new accident initiation mechanisms. Therefore, the proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No.

The SLMCPR is a TS numerical value, calculated to ensure that during normal operation and during abnormal operational transients, at least 99.9% of all fuel rods in the core do not experience transition boiling if the limit is not violated. The new SLMCPRs are calculated using NRC-approved methodology discussed in NEDE-2401 1-P-A, General Electric Standard Application for Reactor Fuel, Revision 18. The proposed changes do not involve any new modes of operation, any changes to setpoints, or any plant modifications. The proposed revised MCPR safety limits have been shown to be acceptable for Cycle 19 operation. The core operating limits will continue to be developed using NRC-approved methods. The proposed MCPR safety limits or methods for establishing the core operating limits do not result in the creation of any new precursors to an accident. Therefore, this change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

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

Response: No.

There is no significant reduction in the margin of safety previously approved by the NRC as a result of the proposed change to the SLMCPRs. The new SLMCPRs are calculated using methodology discussed in NEDE-2401 1-P-A, General Electric Standard Application for Reactor Fuel, Revision 18. The SLMCPRs ensure that during normal operation and during abnormal operational transients, at least 99.9% of all fuel rods in the core do not experience transition boiling if the limit is not violated, thereby preserving the fuel cladding integrity. Therefore, the proposed TS changes do not involve a significant reduction in the margin of safety previously approved by the NRC.

Evaluation of Proposed Changes License Amendment Request Safety Limit Minimum Critical Power Ratio Page 3 The MCPR safety limit is reevaluated for each reload using NRC~approved methodologies. The analyses for Peach Bottom Atomic Power Station (PBAPS), Unit 3, Cycle 19 have concluded that a two recirculation loop MCPR safety limit of ~ 1.09, based on the application of Global Nuclear Fuel's NRC~approved MCPR safety limit methodology, will ensure that this acceptance criterion is met. For single recirculation loop operation, a MCPR safety limit of ~ 1.12 also ensures that this acceptance criterion is met. The MCPR operating limits are presented and controlled in accordance with the PBAPS, Unit 3 Core Operating Limits Report (COLR).

The requested TS changes do not involve any plant modifications or operational changes that could affect system reliability or performance or that could affect the probability of operator error. The requested changes do not affect any postulated accident precursors, do not affect any accident mitigating systems, and do not introduce any new accident initiation mechanisms. Therefore, the proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No.

The SLMCPR is a TS numerical value, calculated to ensure that during normal operation and during abnormal operational transients, at least 99.9%

of all fuel rods in the core do not experience transition boiling if the limit is not violated. The new SLMCPRs are calculated using NRC~approved methodology discussed in NEDE~24011 ~P~A, "General Electric Standard Application for Reactor Fuel," Revision 18. The proposed changes do not involve any new modes of operation, any changes to setpoints, or any plant modifications. The proposed revised MCPR safety limits have been shown to be acceptable for Cycle 19 operation. The core operating limits will continue to be developed using NRC~approved methods. The proposed MCPR safety limits or methods for establishing the core operating limits do not result in the creation of any new precursors to an accident. Therefore, this change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

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

Response: No.

There is no significant reduction in the margin of safety previously approved by the NRC as a result of the proposed change to the SLMCPRs. The new SLMCPRs are calculated using methodology discussed in NEDE~24011 ~P~A, "General Electric Standard Application for Reactor Fuel," Revision 18. The SLMCPRs ensure that during normal operation and during abnormal operational transients, at least 99.90/0 of all fuel rods in the core do not experience transition boiling if the limit is not violated, thereby preserving the fuel cladding integrity. Therefore, the proposed TS changes do not involve a significant reduction in the margin of safety previously approved by the NRC.

Evaluation of Proposed Changes License Amendment Request Safety Limit Minimum Critical Power Ratio Page 4 Based on the above, Exelon Generation Company, LLC, concludes that the proposed amendment does not involve a 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.

4.4 Conclusions 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 Commissions 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.

5.0 ENVIRONMENTAL CONSIDERATION

A review 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, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1) NEDE-24011-P-A, General Electric Standard Application for Reactor Fuel, Revision 18.

Evaluation of Proposed Changes License Amendment Request Safety Limit Minimum Critical Power Ratio Page 4 Based on the above, Exelon Generation Company, LLC, concludes that the proposed amendment does not involve a 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.

4.4 Conclusions 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.

5.0 ENVIRONMENTAL CONSIDERATION

A review 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, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1) NEDE-24011-P-A, IIGeneral Electric Standard Application for Reactor Fuel, II Revision 18.

(c4!un) i.-o obed SI pesiAeu e

6 td SUO!4tO!iOed5 IED!uLlDeI o dnNn 1N3IIiH3VLLV ATIACHMENT2 Markup of Technical Specifications Page Revised TS Page 2.0-1 (Unit 3)

) [s 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 2.1.1.1 With the reactor steam dome pressure

< 185 psig or core flow 10% rated core flow:

THERMAL POWER shall be 25%

RTP.

2.1,1.2 With the reactor steam dome pressure 785 psig and core flow 10% rated core flow:

for siecircuationioopoperation.

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

2.1,2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within 2

hours:

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

(continued)

PBAPS UNIT 3

2.0-1 Amendment No.

262 L

2.0

.0 TY LIMITS (SLs) 2.1 SLs

2. 1. 1

.1.1.1 With the reactor steam dome pressure < 785 psig or core flow < 10% rated core flow:

THERMAL POWER shall be 25% RTP.

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

2.1. 1.2 With fl ow the reactor steam dome pressure

~ 785 psig and core

~ 10% rated~core flow: c s

1 e

~

. 7 0 r two ~'ecl rcu1at ion 100popera t ion for sing e recirculation loop operation.

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

~ 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

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

PBAPS UNIT 3 2.0-1 Amendment No. 262

ATTACHMENT 3 Retyped Technical Specifications Page Revised TS Page 2O-1 (Unit 3)

AITACHMENT3 Retyped Technical Specifications Page Revised TS Page 2.0-1 (Unit 3)

S Ls 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure

< 785 psig or core flow 10% rated core flow:

THERMAL POWER shall be 25%

RTP.

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

MCPR shall be 1.09 for two recirculation loop operation or 1.12 for single recirculation loop operation.

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

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within 2

hours:

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

(continued)

PBAPS UNIT 3

2.0-1 Amendment No.

SLs 2.0 2.0 SAFETY LIMITS (SLs)

2. 1 SLs 2.1.1 2.1.1.1 With the reactor steam dome pressure < 785 psig or core flow < 10% rated core flow:

THERMAL POWER shall be

~ 25% RTP.

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

MCPR shall be 2 1.09 for two recirculation loop operation or 2 1.12 for single recirculation loop operation.

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

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

~ 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

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

(continued)

PBAPS UNIT 3 2.0 1 Amendment No.

ATTACHMENT 5 Non-Proprietary Version of Global Nuclear Fuel Letter ATTACHMENT 5 Non-Proprietary Version of Global Nuclear Fuel Letter ATTACHMENT 5 Non-Proprietary Version of Global Nuclear Fuel Letter

Global Nuclear Fuel - Americas LLC AFFIDAVIT I, Russell K. Stachowski, state as follows:

(1) 1 am the t.hiet Consulting Engineer, Nuckar Physics of Global Nudear I ud 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 tbr its withholding.

(2)

The information sought to be withheld is contained in GNF-A proprietary report, GNF 0000-0127-i 959-R0-P (

1 NF 4ddztzoncil In/ormation Regarding the Requested ( hanges to the Technical Specification SLMCPR, Peach Bottom Unit 3 Cycle 19, Revision 0, Class III (GNF-A Proprietary Information), May 2011. GNF-A text proprietary information in GNF 0000-0127-1959-R0-P is identified by a dark red dotted underline inside double square brackets.

nqmpI fl Figures and large equation objects containing GNF-A proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation refers to Paragraph (3) of this affidavit that provides the basis for the proprietary determination.

(3)

In making this application for withholding of proprietary inftrmation 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 qualifies under the narrower definition of trade secret, within the meanings assigned to those tcrms for purposes of FOIA Exemption 4 in respectively Critical Mass Energy Project v. Nuclear Regulatory Commission 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4)

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that 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-As competitors without license from GNF-A constitutes a competitive economic advantage over GNF-A andJor other companies.

b.

Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the

design, manufacture,

shipment, installation, assurance of quality, or licensing of a similar product.

c.

Information that reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, -that may include potential products of GNF-A.

GNF-0000-0127-1959-RO-P Affidavit Page 1 of 3 Global Nuclear Fuel-Americas LLC AFFIDAVIT

(, Russell E. Stachowski, state as follows:

(I)

[am the Chief Consulting Engineer, Nuclear Physics, of 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 infonnation sought to be withheld is contained in GNF-A proprietary report, GNF-OOOO-0127-1959-RO-P, GiVF Additional Information Regarding the Requested Changes to the Technical Specification SLA;fCPR, Peach Bottom Unit 3 Cycle 19, Revision 0, Class III (GNF-A Proprietary Information), lYfay 2011. GNF-A text proprietary information in GNF-0000-0127-1959-RO-P is identified by a dark red dotted underline inside double square brackets. ((Ihi;;..~_t;.Q_~t;nc.;_ttj~_.ml_5!X~mpJ.t;...:J:)) Figures and large equation objects containing GNF-A proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation PI refers to Paragraph (3) of this affidavit that provides the basis for the proprietary determination.

(3)

In making this application tor 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 qualities under the narrower definition of trade secret, within the meanings assigned to those terms tor purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4)

The information sought to be withheld is considered to be proprietary tor the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that tit 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 GNF-A and/or other compames.

b.

Intormation that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the

design, manufacture,

shipment, installation, assurance ofquality, or licensing of a similar product.

c.

Information that reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, -that may include potential products of GNF-A.

GNF-0000-0 127-1959-R0-P Aftidavit Page I of 3 Global Nuclear Fuel-Americas LLC AFFIDAVIT

(, Russell E. Stachowski, state as follows:

(I)

[am the Chief Consulting Engineer, Nuclear Physics, of 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 infonnation sought to be withheld is contained in GNF-A proprietary report, GNF-OOOO-0127-1959-RO-P, GiVF Additional Information Regarding the Requested Changes to the Technical Specification SLA;fCPR, Peach Bottom Unit 3 Cycle 19, Revision 0, Class III (GNF-A Proprietary Information), lYfay 2011. GNF-A text proprietary information in GNF-0000-0127-1959-RO-P is identified by a dark red dotted underline inside double square brackets. ((Ihi;;..~_t;.Q_~t;nc.;_ttj~_.ml_5!X~mpJ.t;...:J:)) Figures and large equation objects containing GNF-A proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation PI refers to Paragraph (3) of this affidavit that provides the basis for the proprietary determination.

(3)

In making this application tor 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 qualities under the narrower definition of trade secret, within the meanings assigned to those terms tor purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4)

The information sought to be withheld is considered to be proprietary tor the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that tit 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 GNF-A and/or other compames.

b.

Intormation that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the

design, manufacture,

shipment, installation, assurance ofquality, or licensing of a similar product.

c.

Information that reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, -that may include potential products of GNF-A.

GNF-0000-0 127-1959-R0-P Aftidavit Page I of 3

d.

Information that discloses trade secret and/or potentially patentable subject matter lbr which it may be desirable to obtain patent protection.

(5) 10 addrcss 10 CFR 2 390(bX4) the information sought to be withheld is being submitted to the 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 knowlcdge and belief, consistently becn hdd in confidence by (jNF-A, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transinittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in the following paragraphs (6) and (7).

(6)

Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited to 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 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 and/or confidentiality agreements.

(8)

The information identified in paragraph (2) above is classified as proprietary because it contains details of GNF-As fuel design and licensing methodology for the Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GNF-A. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GNF-A asset.

(9)

Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-As competitive position and foreclose or reduce the availability of protit making opportunities. The fuel design and licensing methodology is part of GNF-As 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.

(INF-0000-0127-1959-RO-P Affidavit Page 2 of 3 d.

Infom1ation that discloses trade secret and/or potentially patentable subject matter tor which it may be desirable to obtain patent protection.

(5)

To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to the 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, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or contidentiality agreements that provide tor maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in the following paragraphs (6) and (7).

(6)

Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GNF*A. Access to such documents within GNF~A is limited to 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 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 and/or confidentiality agreements.

(8)

The infonllation identified in paragraph (2) above is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology for the Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GNF-A. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GNF-A asset.

(9)

Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

GNF-OOOO-O 127-1959-RO-P Affidavit Page 2 of 3 d.

Infom1ation that discloses trade secret and/or potentially patentable subject matter tor which it may be desirable to obtain patent protection.

(5)

To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to the 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, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or contidentiality agreements that provide tor maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in the following paragraphs (6) and (7).

(6)

Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GNF*A. Access to such documents within GNF~A is limited to 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 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 and/or confidentiality agreements.

(8)

The infonllation identified in paragraph (2) above is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology for the Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GNF-A. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GNF-A asset.

(9)

Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

GNF-OOOO-O 127-1959-RO-P Affidavit Page 2 of 3

[he research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GNFA. The precise value ot the expertise to devise in evaluation process and ipply th orru inalytiLal tmthodology is diltiuIt to quantify, but it clearly is substantial. GNF-As 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 on this 9th day of May 2011.

Russell E. Stachowski Global Nuclear Fuel

- Americas LLC GNF-0000-O I 27-I 959-RO-P Affidavit Page 3 of 3 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. 1Vlaking 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.

[ declare under penalty of perjury that the foregoing aflldavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 9th day of Nlay 2011.

-~~~-

Russell E. Stachowski Global Nuclear Fuel - Americas LLC GNF-OOOO-O 127-1959-RO-P Affidavit Page 3 of 3 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. 1Vlaking 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.

[ declare under penalty of perjury that the foregoing aflldavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 9th day of Nlay 2011.

-~~~-

Russell E. Stachowski Global Nuclear Fuel - Americas LLC GNF-OOOO-O 127-1959-RO-P Affidavit Page 3 of 3

NON-PROPRIETARY INFORMATION Class 1 (Public)

GNF Attachment 5/3/2011 GNF-0000-0 127-1 959-R0-NP eDRFSection: 0000-0127-i 959-R0 GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Peach Bottom Unit 3 Cycle 19 Copyright 2011 Global Nuclear Fuel-Americas, LLC All Rights Reserved Peach Bottom Unit 3 Cycle 19

{Verified Information}

Page 1 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 5/3/2011 GNF-OOOO-OI27-1959-RO-NP eDRFSection: 0000-OI27-1959-RO GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Peach Bottom Unit 3 Cycle 19 Copyright 2011 Global Nuclear Fuel-Americas, LLC All Rights Reserved Peach Bottom Unit 3 Cycle 19

{Verified Information}

Page 1 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 5/3/2011 GNF-OOOO-OI27-1959-RO-NP eDRFSection: 0000-OI27-1959-RO GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Peach Bottom Unit 3 Cycle 19 Copyright 2011 Global Nuclear Fuel-Americas, LLC All Rights Reserved Peach Bottom Unit 3 Cycle 19

{Verified Information}

Page 1 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Information Notice This document is the GNF non-proprietary version of the GNF proprietary report.

From the GNF proprietary version the information denoted as GNF proprietary (enclosed in double brackets) was deleted to generate this version.

Important Notice Regarding Contents of this Report Please Read Carefully The only undertakings of Global Nuclear Fuel-Americas, LLC (GNF-A) with respect to information in this document are contained in contracts between GNF-A and its customers, and nothing contained in this document shall be construed as changing those contracts. The use of this information by anyone other than those participating entities and for any purposes other than those for which it is intended is not authorized; and with respect to any unauthorized use, GNF-A makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.

Information Notice

{Verified Information}

Page 2 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Information Notice This document is the GNF non-proprietary version of the GNF proprietary report.

From the GNF proprietary version, the information denoted as GNF proprietary (enclosed in double brackets) was deleted to generate this version.

Important Notice Regarding Contents ofthis Report Please Read Carefully The only undertakings of Global Nuclear Fuel-Americas, LLC (GNF-A) with respect to information in this document are contained in contracts between GNF-A and its customers, and nothing contained in this document shall be construed as changing those contracts. The use of this information by anyone other than those participating entities and for any purposes other than those for which it is intended is not authorized; and with respect to any unauthorized use, GNF-A makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness ofthe information contained in this document.

Information Notice

{Verified Information}

Page 2 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Information Notice This document is the GNF non-proprietary version of the GNF proprietary report.

From the GNF proprietary version, the information denoted as GNF proprietary (enclosed in double brackets) was deleted to generate this version.

Important Notice Regarding Contents ofthis Report Please Read Carefully The only undertakings of Global Nuclear Fuel-Americas, LLC (GNF-A) with respect to information in this document are contained in contracts between GNF-A and its customers, and nothing contained in this document shall be construed as changing those contracts. The use of this information by anyone other than those participating entities and for any purposes other than those for which it is intended is not authorized; and with respect to any unauthorized use, GNF-A makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness ofthe information contained in this document.

Information Notice

{Verified Information}

Page 2 of25

NON-PROPRIETARY IN FORMATION Class I (Public)

GNF Attachment Table of Contents 1.0 METHODOLOGY 4

2.0 DISCUSSION 4

2.1.

MAJOR CONTRIBUTORS TO SLMCPR CHANGE 4

2.2.

DEVIATIONS IN NRC-APPRovED UNCERTAiNTIES 5

2.2.].

R-Factor 5

2.2.2.

Core Flow Rate and Random Effctive TIP Reading 5

2.2.3.

LPRM Update Interval and Calculated Bundle Power 6

2.3.

DEPARFURE FROM NRC-APPRovED METHoDoLoGY 7

2.4.

FUEL AXIAL POWER SHAPE PENALTY 7

2.5.

METHoDoLoGY REsTRIcTIoNS 8

2.6.

MINIMUM CORE FLOW CoNDITION 9

2.7.

LIMITING CoNTRoL ROD PATTERNS 9

2.8.

CORE MONITORING SYSTEM 9

2.9.

POwER]FLOw MAP 9

2.10.

CORE LOADING DIAGRAM 9

2.11.

FIGURE REFERENCES 9

2.12.

ADDITIONAL SLMCPR LICENSING CONDITIONS 10 2.13.

SUMMARY

10

3.0 REFERENCES

11 List of Figures FIGURE 1. CURRENT CYCLE CORE LOADING DIAGRAM 12 FIGURE 2. PREVIOUS CYCLE CORE LOADING DIAGRAM 13 FIGURE 3. FIGURE 4.1 FROM NEDC-32601P-A 14 FIGURE 4. FIGURE 111.5-1 FROM NEDC-32601P-A 15 FIGURE 5. RELATIONSHIP BETWEEN MIP AND CPRMARGIN 16 List of Tables TABLE 1. DESCRIPTION OF CoRE 17 TABLE 2. SLMCPR CALCULATION METHODOLOGIES 18 TABLE 3. MONTE CARLO CALCULATED SLMCPR VS. ESTIMATE 19 TABLE 4. NON-POWER DISTRIBUTION UNCERTAINTIES 21 TABLE 5. POWER D1STRIBUTI0N UNCERTAINTIES 23 TABLE 6. CRITICAL POWER UNCERTAINTIES 25 Table of Contents

{Verified Information}

Page 3 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table of Contents 1.0 METHODOLOGY 4

2.0 DISCUSSION 4

2.1.

MAJOR CONTRIBUTORS TO SLMCPR CHANGE 4

2.2.

DEVIATIONS IN NRC-ApPROVED UNCERTAINTIES 5

2.2.1.

R-Factor 5

2.2.2.

Core Flow Rate and Random Effective TIP Reading 5

2.2.3.

LPRM Update Interval and Calculated Bundle Power 6

2.3.

DEPARTURE FROM NRC-ApPROVED METHODOLOGY 7

2.4.

FUEL AXIAL POWER SHAPE PENALTy 7

2.5.

METHODOLOGY RESTRICTIONS 8

2.6.

MINIMUM CORE FLOW CONDITION 9

2.7.

LIMITING CONTROL ROD PATTERNS 9

2.8.

CORE MONITORING SYSTEM 9

2.9.

PowER/FLOW MAP 9

2. 10.

CORE LOADING DIAGRAM 9

2. 11.

FIGURE REFERENCES 9

2.12.

ADDITIONAL SLMCPR LICENSING CONDITIONS 10 2.13.

SUMMARy 10

3.0 REFERENCES

...........................................................*..................................................................................11 List of Figures FIGURE 1. CURRENT CYCLE CORE LOADING DIAGRAM 12 FIGURE 2. PREVIOUS CYCLE CORE LOADING DIAGRAM 13 FIGURE 3. FIGURE 4.1 FROMNEDC-32601P-A 14 FIGURE 4. FIGURE III.5-1 FROM NEDC-32601P-A 15 FIGURE 5. RELATIONSHIP BETWEEN MIP AND CPR MARGIN 16 List of Tables TABLE 1. DESCRIPTION OF CORE 17 TABLE 2. SLMCPR CALCULATION METHODOLOGIES 18 TABLE 3. MONTE CARLO CALCULATED SLMCPR VS. ESTIMATE 19 TABLE 4. NON-POWER DISTRIBUTION UNCERTAINTIES 21 TABLE 5. POWER DISTRIBUTION UNCERTAINTIES 23 TABLE 6. CRITICAL POWER UNCERTAINTIES 25 Table of Contents

{Verified Information}

Page 3 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table of Contents 1.0 METHODOLOGY 4

2.0 DISCUSSION 4

2.1.

MAJOR CONTRIBUTORS TO SLMCPR CHANGE 4

2.2.

DEVIATIONS IN NRC-ApPROVED UNCERTAINTIES 5

2.2.1.

R-Factor 5

2.2.2.

Core Flow Rate and Random Effective TIP Reading 5

2.2.3.

LPRM Update Interval and Calculated Bundle Power 6

2.3.

DEPARTURE FROM NRC-ApPROVED METHODOLOGY 7

2.4.

FUEL AXIAL POWER SHAPE PENALTy 7

2.5.

METHODOLOGY RESTRICTIONS 8

2.6.

MINIMUM CORE FLOW CONDITION 9

2.7.

LIMITING CONTROL ROD PATTERNS 9

2.8.

CORE MONITORING SYSTEM 9

2.9.

PowER/FLOW MAP 9

2. 10.

CORE LOADING DIAGRAM 9

2. 11.

FIGURE REFERENCES 9

2.12.

ADDITIONAL SLMCPR LICENSING CONDITIONS 10 2.13.

SUMMARy 10

3.0 REFERENCES

...........................................................*..................................................................................11 List of Figures FIGURE 1. CURRENT CYCLE CORE LOADING DIAGRAM 12 FIGURE 2. PREVIOUS CYCLE CORE LOADING DIAGRAM 13 FIGURE 3. FIGURE 4.1 FROMNEDC-32601P-A 14 FIGURE 4. FIGURE III.5-1 FROM NEDC-32601P-A 15 FIGURE 5. RELATIONSHIP BETWEEN MIP AND CPR MARGIN 16 List of Tables TABLE 1. DESCRIPTION OF CORE 17 TABLE 2. SLMCPR CALCULATION METHODOLOGIES 18 TABLE 3. MONTE CARLO CALCULATED SLMCPR VS. ESTIMATE 19 TABLE 4. NON-POWER DISTRIBUTION UNCERTAINTIES 21 TABLE 5. POWER DISTRIBUTION UNCERTAINTIES 23 TABLE 6. CRITICAL POWER UNCERTAINTIES 25 Table of Contents

{Verified Information}

Page 3 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 1.0 Methodology GNF performs Safety Limit Minimum Critical Power Ratio (SLMCPR) calculation in accordance to NEDE-2401 1-P-A General Electric Standard Application for Reactor Fuel (Revision 18) using the following NRC-approved methodologies and uncertainties:

NEDC-32601P-A Methodology and Uncertainties for Safety Limit MCPR Evaluations (August 1999).

NEDC-32694P-A Power Distribution Uncertainties for Safety Limit MCPR Evaluations (August 1 999).

NEDC-32505P-A R-Factor Calculation Method for GEl 1, GE12 and GE13 Fuel (Revision 1, July 1999).

Table 2 identifies the actual methodologies used for the Peach Bottom Unit 3 Cycle 18 and the Cycle 19 SLMCPR calculations.

2.0 Discussion In this discussion, the TLO nomenclature is used for two recirculation loops in operation, and the SLO nomenclature is used for one recirculation loop in operation.

2.1.

Major Contributors to SLMCPR Change In general, the calculated safety limit is dominated by two key parameters: (1) flatness of the core bundle-by-bundle MCPR distribution, and (2) flatness of the bundle pin-by-pin power/R Factor distribution. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR. MIP (MCPR Importance Parameter) measures the core bundle-by-bundle MCPR distribution and RIP (R-Factor Importance Parameter) measures the bundle pin-by-pin power/R-Factor distribution.

The impact of the fuel loading pattern on the calculated TLO SLMCPR using rated core power and rated core flow conditions has been correlated to the parameter MIPRIP, which combines the MIP and RIP values.

Table 3 presents the MIP and RIP parameters for the previous cycle and the current cycle along with the TLO SLMCPR estimate using the MIPRIP correlation. If the minimum core flow case is applicable, the TLO SLMCPR estimate is also provided for that case although the MIPRIP correlation is only applicable to the rated core flow case.

This is done only to provide some reasonable assessment basis of the minimum core flow case trend. In addition, Table 3 presents estimated impacts on the TLO SLMCPR due to methodology deviations, penalties, andlor uncertainty deviations from approved values. Based on the MIPRIP correlation and any impacts due to deviations from approved values, a final estimated TLO SLMCPR is determined. Table 3 also provides the actual calculated Monte Carlo SLMCPRs.

Given the bias and uncertainty in the MIPRIP correlation ((

]j and the inherent variation in the Methodology

{Verified Information}

Page 4 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 1.0 Methodology GNF perfonns Safety Limit Minimum Critical Power Ratio (SLMCPR) calculation in accordance to NEDE-24011-P-A "General Electric Standard Application for Reactor Fuel" (Revision 18) using the following NRC-approved methodologies and uncertainties:

NEDC-32601P-A "Methodology and Uncertainties for Safety Limit MCPR Evaluations" (August 1999).

NEDC-32694P-A "Power Distribution Uncertainties for Safety Limit MCPR Evaluations" (August 1999).

NEDC-32505P-A "R-Factor Calculation Method for GEl I, GEI2 and GEI3 Fuel" (Revision I, July 1999).

Table 2 identifies the actual methodologies used for the Peach Bottom Unit 3 Cycle 18 and the Cycle 19 SLMCPR calculations.

2.0 Discussion In this discussion, the TLO nomenclature is used for two recirculation loops in operation, and the SLO nomenclature is used for one recirculation loop in operation.

2.1.

Major Contributors to SLMCPR Change In general, the calculated safety limit is dominated by two key parameters: (I) flatness of the core bundle-by-bundle MCPR distribution, and (2) flatness of the bundle pin-by-pin power/R-Factor distribution. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR. MIP (MCPR Importance Parameter) measures the core bundle-by-bundle MCPR distribution and RIP (R-Factor Importance Parameter) measures the bundle pin-by-pin power/R-Factor distribution.

The impact of the fuel loading pattern on the calculated TLO SLMCPR using rated core power and rated core flow conditions has been correlated to the parameter MIPRIP, which combines the MIP and RIP values.

Table 3 presents the MIP and RIP parameters for the previous cycle and the current cycle along with the TLO SLMCPR estimate using the MIPRIP correlation. If the minimum core flow case is applicable, the TLO SLMCPR estimate is also provided for that case although the MIPRIP correlation is only applicable to the rated core flow case.

This is done only to provide some reasonable assessment basis of the minimum core flow case trend. In addition, Table 3 presents estimated impacts on the TLO SLMCPR due to methodology deviations, penalties, and/or uncertainty deviations from approved values. Based on the MIPRIP correlation and any impacts due to deviations from approved values, a final estimated TLO SLMCPR is detennined. Table 3 also provides the actual calculated Monte Carlo SLMCPRs. Given the bias and uncertainty in the MIPRIP correlation ((

)) and the inherent variation in the Methodology

{Verified Infonnation}

Page 40f25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 1.0 Methodology GNF perfonns Safety Limit Minimum Critical Power Ratio (SLMCPR) calculation in accordance to NEDE-24011-P-A "General Electric Standard Application for Reactor Fuel" (Revision 18) using the following NRC-approved methodologies and uncertainties:

NEDC-32601P-A "Methodology and Uncertainties for Safety Limit MCPR Evaluations" (August 1999).

NEDC-32694P-A "Power Distribution Uncertainties for Safety Limit MCPR Evaluations" (August 1999).

NEDC-32505P-A "R-Factor Calculation Method for GEl I, GEI2 and GEI3 Fuel" (Revision I, July 1999).

Table 2 identifies the actual methodologies used for the Peach Bottom Unit 3 Cycle 18 and the Cycle 19 SLMCPR calculations.

2.0 Discussion In this discussion, the TLO nomenclature is used for two recirculation loops in operation, and the SLO nomenclature is used for one recirculation loop in operation.

2.1.

Major Contributors to SLMCPR Change In general, the calculated safety limit is dominated by two key parameters: (I) flatness of the core bundle-by-bundle MCPR distribution, and (2) flatness of the bundle pin-by-pin power/R-Factor distribution. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR. MIP (MCPR Importance Parameter) measures the core bundle-by-bundle MCPR distribution and RIP (R-Factor Importance Parameter) measures the bundle pin-by-pin power/R-Factor distribution.

The impact of the fuel loading pattern on the calculated TLO SLMCPR using rated core power and rated core flow conditions has been correlated to the parameter MIPRIP, which combines the MIP and RIP values.

Table 3 presents the MIP and RIP parameters for the previous cycle and the current cycle along with the TLO SLMCPR estimate using the MIPRIP correlation. If the minimum core flow case is applicable, the TLO SLMCPR estimate is also provided for that case although the MIPRIP correlation is only applicable to the rated core flow case.

This is done only to provide some reasonable assessment basis of the minimum core flow case trend. In addition, Table 3 presents estimated impacts on the TLO SLMCPR due to methodology deviations, penalties, and/or uncertainty deviations from approved values. Based on the MIPRIP correlation and any impacts due to deviations from approved values, a final estimated TLO SLMCPR is detennined. Table 3 also provides the actual calculated Monte Carlo SLMCPRs. Given the bias and uncertainty in the MIPRIP correlation ((

)) and the inherent variation in the Methodology

{Verified Infonnation}

Page 40f25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Monte Carlo results ((

)), the change in the Peach Bottom Unit 3 Cycle 19 calculated Monte Carlo TLO SLMCPR using rated core power and rated core flow conditions is consistent with the corresponding estimated TLO SLMCPR value.

The intent of the final estimated TLO SLMCPR 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 items in Table 3 that result in the increase of the estimated SLMCPR are discussed in Section 2.2.

2.2.

Deviations in NRC-Approved Uncertainties Tables 4 and 5 provide a list of NRC-approved uncertainties along with values actually used. A discussion of deviations from these NRC-approved values follows; all of which are conservative relative to NRC-approved values.

Also, estimated impact on the SLMCPR is provided in Table 3 for each deviation.

2.2.1. R-Factor At this time, GNF has generically increased the GEXL R-Factor uncertainty from ((

j] to account for an increase in channel bow due to the emerging unforeseen 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. The step a RPEAK in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, is affected by this deviation. Reference 4 technically justifies that a GEXL R Factor uncertainty of ((

j] accounts for a channel bow uncertainty of up to {[

1].

Peach Bottom Unit 3 has experienced control blade shadow corrosion-induced channel bow to the extent that an increase in the NRC-approved R-Factor uncertainty ((

fi is deemed prudent to address its impact.

Accounting for the control blade shadow corrosion-induced channel bow, the Peach Bottom Unit 3 Cycle 19 analysis shows an expected channel bow uncertainty of ((

j], which is bounded by a GEXL R-Factor uncertainty of ((

]J.

Thus the use of a GEXL R-Factor uncertainty of [{

jj adequately accounts for the expected control blade shadow corrosion-induced channel bow for Peach Bottom Unit 3 Cycle 19.

2.2.2. Core Flow Rate and Random Effective TIP Reading In Reference 5 GNF committed to the expansion of the state points used in the determination of the SLMCPR.

Consistent with the Reference 5 commitments, GNF performs analyses at the rated core power and minimum licensed core flow point in addition to analyses at the rated core power and rated core flow point. The approved SLMCPR methodology is applied at each state point that is analyzed.

Discussion

{Verified Information}

Page 5 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Monte Carlo results ((

)), the change in the Peach Bottom Unit 3 Cycle 19 calculated Monte Carlo TLO SLMCPR using rated core power and rated core flow conditions is consistent with the corresponding estimated TLO SLMCPR value.

The intent of the final estimated TLO SLMCPR 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 items in Table 3 that result in the increase of the estimated SLMCPR are discussed in Section 2.2.

2.2.

Deviations in NRC-Approved Uncertainties Tables 4 and 5 provide a list of NRC-approved uncertainties along with values actually used. A discussion of deviations from these NRC-approved values follows; all of which are conservative relative to NRC-approved values.

Also, estimated impact on the SLMCPR is provided in Table 3 for each deviation.

2.2.1. R-Factor At this time, GNF has generically increased the GEXL R-Factor uncertainty from ((

)) to account for an increase in channel bow due to the emerging unforeseen phenomena called control blade shadow corrosion-induced channel bow, which is not accounted for in the channel bow uncertainty component ofthe approved R-Factor uncertainty. The step "0 RPEAK" in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, is affected by this deviation. Reference 4 technically justifies that a GEXL R-Factor uncertainty of ((

)) accounts for a channel bow uncertainty ofup to ((

)).

Peach Bottom Unit 3 has experienced control blade shadow corrosion-induced channel bow to the extent that an increase in the NRC-approved R-Factor uncertainty ((

)) is deemed prudent to address its impact.

Accounting for the control blade shadow corrosion-induced channel bow, the Peach Bottom Unit 3 Cycle 19 analysis shows an expected channel bow uncertainty of ((

)), which is bounded by a GEXL R-Factor uncertainty of ((

)).

Thus the use of a GEXL R-Factor uncertainty of ((

)) adequately accounts for the expected control blade shadow corrosion-induced channel bow for Peach Bottom Unit 3 Cycle 19.

2.2.2. Core Flow Rate and Random Effective TIP Reading In Reference 5 GNF committed to the expansion of the state points used in the determination of the SLMCPR.

Consistent with the Reference 5 commitments, GNF performs analyses at the rated core power and minimum licensed core flow point in addition to analyses at the rated core power and rated core flow point. The approved SLMCPR methodology is applied at each state point that is analyzed.

Discussion

{Verified Information}

Page 5 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Monte Carlo results ((

)), the change in the Peach Bottom Unit 3 Cycle 19 calculated Monte Carlo TLO SLMCPR using rated core power and rated core flow conditions is consistent with the corresponding estimated TLO SLMCPR value.

The intent of the final estimated TLO SLMCPR 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 items in Table 3 that result in the increase of the estimated SLMCPR are discussed in Section 2.2.

2.2.

Deviations in NRC-Approved Uncertainties Tables 4 and 5 provide a list of NRC-approved uncertainties along with values actually used. A discussion of deviations from these NRC-approved values follows; all of which are conservative relative to NRC-approved values.

Also, estimated impact on the SLMCPR is provided in Table 3 for each deviation.

2.2.1. R-Factor At this time, GNF has generically increased the GEXL R-Factor uncertainty from ((

)) to account for an increase in channel bow due to the emerging unforeseen phenomena called control blade shadow corrosion-induced channel bow, which is not accounted for in the channel bow uncertainty component ofthe approved R-Factor uncertainty. The step "0 RPEAK" in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, is affected by this deviation. Reference 4 technically justifies that a GEXL R-Factor uncertainty of ((

)) accounts for a channel bow uncertainty ofup to ((

)).

Peach Bottom Unit 3 has experienced control blade shadow corrosion-induced channel bow to the extent that an increase in the NRC-approved R-Factor uncertainty ((

)) is deemed prudent to address its impact.

Accounting for the control blade shadow corrosion-induced channel bow, the Peach Bottom Unit 3 Cycle 19 analysis shows an expected channel bow uncertainty of ((

)), which is bounded by a GEXL R-Factor uncertainty of ((

)).

Thus the use of a GEXL R-Factor uncertainty of ((

)) adequately accounts for the expected control blade shadow corrosion-induced channel bow for Peach Bottom Unit 3 Cycle 19.

2.2.2. Core Flow Rate and Random Effective TIP Reading In Reference 5 GNF committed to the expansion of the state points used in the determination of the SLMCPR.

Consistent with the Reference 5 commitments, GNF performs analyses at the rated core power and minimum licensed core flow point in addition to analyses at the rated core power and rated core flow point. The approved SLMCPR methodology is applied at each state point that is analyzed.

Discussion

{Verified Information}

Page 5 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment For the TLO calculations performed at 82.8% core flow, the approved uncertainty values for the corc flow itc (2 5%) and thc random cflcctive TIP rciding (1 2%) arc conscrvatively adjusted by dividing them by 82.8/100. The steps a CORE FLOW and a TIP (INSTRUMENT) in Figure 4.1 from NEDC-3260i P-A, which has been provided for convenience in Figure 3 of this attachment, are affected by this deviation, respectively.

Historically, these values have been construed to be somewhat dependent on the core flow conditions as demonstrated by the fact that higher values have always been used when performing SLO calculations.

it is for this reason that GNF determined that it is appropriate to consider an increase in these two uncertainties when the core flow is reduced.

The amount of increase is determined in a conservative way. For both parameters it is assumed that the absolute uncertainty remains the same as the how is decreased 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 somewhat as the flow decreases.

For the random effective TIP uncertainty, there is no reason to believe that the percentage uncertainty should increase as the core flow decreases for TLO.

Nevertheless, this uncertainty is also increased as is done in the more extreme case for SLO primarily to preserve the historical precedent established by the SLO evaluation. Note that the TLO condition is different than the SLO condition because for TLO there is no expected tilting of the core radial power shape.

The treatment of the core flow and random effective TIP reading uncertainties is based on the assumption that the signal to noise ratio deteriorates as core flow is reduced. GNF believes this is conservative and may in the future provide justification that the original uncertainties (non flow dependent) are adequately bounding.

The core flow and random TIP reading uncertainties used in the SLO minimum core flow SLMCPR analysis remain the same as in the rated core flow SLO SLMCPR analysis because these uncertainties (which are substantially larger than used in the TLO analysis) already account for the effects of operating at reduced core flow.

2.2.3.

LPRM Update Interval and Calculated Bundle Power To address the LPRM update/calibration interval in the Peach Bottom Unit 3 Technical Specifications, GNF has increased the LPRM update uncertainty in the SLMCPR analysis for Peach Bottom Unit 3 Cycle 19. The approved uncertainty values for the contribution to bundle power uncertainty due to LPRM update ((

1] and the resulting total uncertainty in calculated bundle power ((

j] are conservatively increased, as shown in Table 5. The steps a TIP (INSTRUMENT) and a BUNDLE (MODEL) in Figure 4.1 from NEDC 3260 1P-A, which has been provided for convenience in Figure 3 of this attachment, are affected by this deviation.

Discussion

{Verified Information}

Page 6 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment For the TLO calculations performed at 82.8% core flow, the approved uncertainty values for the core flow rate (2.5%) and the random effective TIP reading (1.2%) are conservatively adjusted by dividing them by 82.8/100. The steps "cr CORE FLOW" and "cr TIP (INSTRUMENT)" in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, are affected by this deviation, respectively.

Historically, these values have been construed to be somewhat dependent on the core flow conditions as demonstrated by the fact that higher values have always been used when performing SLO calculations. It is for this reason that GNF determined that it is appropriate to consider an increase in these two uncertainties when the core flow is reduced. The amount of increase is determined in a conservative way. For both parameters it is assumed that the absolute uncertainty remains the same as the flow is decreased 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 somewhat as the flow decreases. For the random effective TIP uncertainty, there is no reason to believe that the percentage uncertainty should increase as the core flow decreases for TLO.

Nevertheless, this uncertainty is also increased as is done in the more extreme case for SLO primarily to preserve the historical precedent established by the SLO evaluation. Note that the TLO condition is different than the SLO condition because for TLO there is no expected tilting ofthe core radial power shape.

The treatment of the core flow and random effective TIP reading uncertainties is based on the assumption that the signal to noise ratio deteriorates as core flow is reduced. GNF believes this is conservative and may in the future provide justification that the original uncertainties (non-flow dependent) are adequately bounding.

The core flow and random TIP reading uncertainties used in the SLO minimum core flow SLMCPR analysis remain the same as in the rated core flow SLO SLMCPR analysis because these uncertainties (which are substantially larger than used in the TLO analysis) already account for the effects of operating at reduced core flow.

2.2.3.

LPRM Update Interval and Calculated Bundle Power To address the LPRM update/calibration interval in the Peach Bottom Unit 3 Technical Specifications, GNF has increased the LPRM update uncertainty in the SLMCPR analysis for Peach Bottom Unit 3 Cycle 19. The approved uncertainty values for the contribution to bundle power uncertainty due to LPRM update ((

)) and the resulting total uncertainty in calculated bundle power ((

)) are conservatively increased, as shown in Table 5. The steps "cr TIP (INSTRUMENT)" and "cr BUNDLE (MODEL)" in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, are affected by this deviation.

((

Discussion

{Verified Information}

Page 6 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment For the TLO calculations performed at 82.8% core flow, the approved uncertainty values for the core flow rate (2.5%) and the random effective TIP reading (1.2%) are conservatively adjusted by dividing them by 82.8/100. The steps "cr CORE FLOW" and "cr TIP (INSTRUMENT)" in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, are affected by this deviation, respectively.

Historically, these values have been construed to be somewhat dependent on the core flow conditions as demonstrated by the fact that higher values have always been used when performing SLO calculations. It is for this reason that GNF determined that it is appropriate to consider an increase in these two uncertainties when the core flow is reduced. The amount of increase is determined in a conservative way. For both parameters it is assumed that the absolute uncertainty remains the same as the flow is decreased 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 somewhat as the flow decreases. For the random effective TIP uncertainty, there is no reason to believe that the percentage uncertainty should increase as the core flow decreases for TLO.

Nevertheless, this uncertainty is also increased as is done in the more extreme case for SLO primarily to preserve the historical precedent established by the SLO evaluation. Note that the TLO condition is different than the SLO condition because for TLO there is no expected tilting ofthe core radial power shape.

The treatment of the core flow and random effective TIP reading uncertainties is based on the assumption that the signal to noise ratio deteriorates as core flow is reduced. GNF believes this is conservative and may in the future provide justification that the original uncertainties (non-flow dependent) are adequately bounding.

The core flow and random TIP reading uncertainties used in the SLO minimum core flow SLMCPR analysis remain the same as in the rated core flow SLO SLMCPR analysis because these uncertainties (which are substantially larger than used in the TLO analysis) already account for the effects of operating at reduced core flow.

2.2.3.

LPRM Update Interval and Calculated Bundle Power To address the LPRM update/calibration interval in the Peach Bottom Unit 3 Technical Specifications, GNF has increased the LPRM update uncertainty in the SLMCPR analysis for Peach Bottom Unit 3 Cycle 19. The approved uncertainty values for the contribution to bundle power uncertainty due to LPRM update ((

)) and the resulting total uncertainty in calculated bundle power ((

)) are conservatively increased, as shown in Table 5. The steps "cr TIP (INSTRUMENT)" and "cr BUNDLE (MODEL)" in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, are affected by this deviation.

((

Discussion

{Verified Information}

Page 6 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment

]J The total bundle power uncertainty is a function of the LPRM update uncertainty as detailed in Section 3.3 of NEDC 32694P-A.

2.3.

Departure from NRC-Approved Methodology No departures from NRC-approved methodologies were used in the Peach Bottom Unit 3 Cycle 19 SLMCPR calculations.

2.4.

Fuel Axial Power Shape Penalty At this time, GNF has determined that higher uncertainties and non-conservative biases in the GEXL correlations for the various types of axial power shapes (i.e., inlet, cosine, outlet and double hump) could potentially exist relative to the NRC-approved methodology values, see References 3, 6, 7 and 8. The following table identifies, by marking with an X, this potential for each GNF product line currently being offered:

((

1]

Axial bundle power shapes corresponding to the limiting SLMCPR control blade patterns are determined using the PANACEA 3D core simulator. These axial power shapes are classified in accordance to the following table:

11 Discussion

{Verified Information}

Page 7 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment

)) The total bundle power uncertainty is a function of the LPRM update uncertainty as detailed in Section 3.3 of NEDC-32694P-A.

2.3.

Departure from NRC-Approved Methodology No departures from NRC-approved methodologies were used in the Peach Bottom Unit 3 Cycle 19 SLMCPR calculations.

2.4.

Fuel Axial Power Shape Penalty At this time, GNF has determined that higher uncertainties and non-conservative biases in the GEXL correlations for the various types of axial power shapes (i.e., inlet, cosine, outlet and double hump) could potentially exist relative to the NRC-approved methodology values, see References 3, 6, 7 and 8. The following table identifies, by marking with an "X", this potential for each GNF product line currently being offered:

((

))

Axial bundle power shapes corresponding to the limiting SLMCPR control blade patterns are determined using the PANACEA 3D core simulator. These axial power shapes are classified in accordance to the following table:

((

))

Discussion

{Verified Information}

Page 70f25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment

)) The total bundle power uncertainty is a function of the LPRM update uncertainty as detailed in Section 3.3 of NEDC-32694P-A.

2.3.

Departure from NRC-Approved Methodology No departures from NRC-approved methodologies were used in the Peach Bottom Unit 3 Cycle 19 SLMCPR calculations.

2.4.

Fuel Axial Power Shape Penalty At this time, GNF has determined that higher uncertainties and non-conservative biases in the GEXL correlations for the various types of axial power shapes (i.e., inlet, cosine, outlet and double hump) could potentially exist relative to the NRC-approved methodology values, see References 3, 6, 7 and 8. The following table identifies, by marking with an "X", this potential for each GNF product line currently being offered:

((

))

Axial bundle power shapes corresponding to the limiting SLMCPR control blade patterns are determined using the PANACEA 3D core simulator. These axial power shapes are classified in accordance to the following table:

((

))

Discussion

{Verified Information}

Page 70f25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment if the limiting bundles in the SLMCPR calculation exhibit an axial power shape identified by this table, GNF penalizes the GEXL critical power uncertainties to conservatively account for the impact of the axial power shape. Table 6 provides a list of the GEXL critical power uncertainties determined in accordance to the NRC-approved methodology contained in NEDE-2401 1-P-A along with values actually used.

For the limiting bundles, the fuel axial power shapes in the SLMCPR analysis were examined to dctcrmmL th picsene of axial power shapes idcntifled in the above table These power shapes were not found; therefore, no power shape penalties were applied to the calculated Peach Bottom Unit 3 Cycle 19 SLMCPR values.

25.

Methodology Restrictions The four restrictions identified on Page 3 of the NRCs Safety Evaluation relating to the General Electric Licensing Topical Reports NEDC-32601P, NEDC-32694P, and Amendment 25 to NEDE-2401 1-P-A (March 11, 1999) are addressed in References 1, 2, 3, and 9.

GNF2 fuel is introduced in Peach Bottom Unit 3 Cycle 19. The four restrictions for GNF2 were determined acceptable by the NRC review of GNF2 Advantage Generic Compliance with NEDE-2401 1-P-A (GESTAR II), NEDC-33270P, Revision 0, FLN-2007-01 1, March 14, 2007.

Specifically, in the NRC audit report ML081630579 for the said document, Section 3.4.1 page 59 states:

The NRC staffs SE of NEDC-32694P-A (Reference 19 of NEDC-33270P) 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.

GNFs 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 lOxlO array and 2 water rod makeup, as stated by the NRC audit report MLO8 1630579, Section 3.4.2.2.1 Page 59:

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.

As such, no new GNF fuel designs are being introduced in Peach Bottom Unit 3 Cycle 19; therefore, the NEDC-32505P-A statement...if new fuel is introduced, GENE must confirm that the revised R-Factor method is still valid based on new test data is not applicable.

Discussion

{Verified Information}

Page 8 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment If the limiting bundles in the SLMCPR calculation exhibit an axial power shape identified by this table, GNF penalizes the GEXL critical power uncertainties to conservatively account for the impact ofthe axial power shape. Table 6 provides a list of the GEXL critical power uncertainties determined in accordance to the NRC-approved methodology contained in NEDE-24011-P-A along with values actually used.

For the limiting bundles, the fuel axial power shapes in the SLMCPR analysis were examined to determine the presence of axial power shapes identified in the above table. These power shapes were not found; therefore, no power shape penalties were applied to the calculated Peach Bottom Unit 3 Cycle 19 SLMCPR values.

2.5.

Methodology Restrictions The four restrictions identified on Page 3 of the NRC's Safety Evaluation relating to the General Electric Licensing Topical Reports NEDC-32601P, NEDC-32694P, and Amendment 25 to NEDE-24011-P-A (March 11, 1999) are addressed in References 1,2, 3, and 9.

GNF2 fuel is introduced in Peach Bottom Unit 3 Cycle 19. The four restrictions for GNF2 were determined acceptable by the NRC review of "GNF2 Advantage Generic Compliance with NEDE-24011-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 staffs SE of NEDC-32694P-A (Reference 19 of NEDC-33270P) 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."

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 1Ox10 array and 2 water rod makeup, as stated by the NRC audit report ML081630579, Section 3.4.2.2.1 Page 59:

"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" As such, no new GNF fuel designs are being introduced in Peach Bottom Unit 3 Cycle 19; therefore, the NEDC-32505P-A statement "...ifnew fuel is introduced, GENE must confirm that the revised R-Factor method is still valid based on new test data" is not applicable.

Discussion

{Verified Information}

Page 8 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment If the limiting bundles in the SLMCPR calculation exhibit an axial power shape identified by this table, GNF penalizes the GEXL critical power uncertainties to conservatively account for the impact ofthe axial power shape. Table 6 provides a list of the GEXL critical power uncertainties determined in accordance to the NRC-approved methodology contained in NEDE-24011-P-A along with values actually used.

For the limiting bundles, the fuel axial power shapes in the SLMCPR analysis were examined to determine the presence of axial power shapes identified in the above table. These power shapes were not found; therefore, no power shape penalties were applied to the calculated Peach Bottom Unit 3 Cycle 19 SLMCPR values.

2.5.

Methodology Restrictions The four restrictions identified on Page 3 of the NRC's Safety Evaluation relating to the General Electric Licensing Topical Reports NEDC-32601P, NEDC-32694P, and Amendment 25 to NEDE-24011-P-A (March 11, 1999) are addressed in References 1,2, 3, and 9.

GNF2 fuel is introduced in Peach Bottom Unit 3 Cycle 19. The four restrictions for GNF2 were determined acceptable by the NRC review of "GNF2 Advantage Generic Compliance with NEDE-24011-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 staffs SE of NEDC-32694P-A (Reference 19 of NEDC-33270P) 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."

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 1Ox10 array and 2 water rod makeup, as stated by the NRC audit report ML081630579, Section 3.4.2.2.1 Page 59:

"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" As such, no new GNF fuel designs are being introduced in Peach Bottom Unit 3 Cycle 19; therefore, the NEDC-32505P-A statement "...ifnew fuel is introduced, GENE must confirm that the revised R-Factor method is still valid based on new test data" is not applicable.

Discussion

{Verified Information}

Page 8 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 2.6.

Minimum Core Flow Condition For Peach Bottom Unit 3 Cycle 19, the minimum core flow SLMCPR calculation performed at 82.8% core flow and rated core power condition was limiting as compared to the rated core flow and rated core power condition. At low core flows, the search spaces for the limiting rod pattern and the nominal rod pattern are essentially the same.

Additionally, the condition that MIP jj establishes a reasonably bounding limiting rod pattern. Hence, the rod pattern used to calculate the SLMCPR at 100% rated power/82.8% rated flow reasonably assures that at least 99.9% of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of Peach Bottom Unit 3 Cycle 19.

Consequently, the SLMCPR value calculated from the 82.8% core flow and rated core power condition limiting MCPR distribution reasonably bounds this mode of operation for Peach Bottom Unit 3 Cycle 19.

2.7.

Limiting Control Rod Patterns The limiting control rod patterns used to calculate the SLMCPR reasonably assures that at least 99.9% of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of Peach Bottom Unit 3 Cycle 19.

28.

Core Monitoring System For Peach Bottom Unit 3 Cycle 19, the 3DMonicore system will be used as the core monitoring system.

2.9.

Power/Flow Map The utility has provided the current and previous cycle power/flow map in a separate attachment.

2.10. Core Loading Diagram Figures 1 and 2 provide the core-loading diagram for the current and previous cycle respectively, which are the Reference Loading Pattern as defined by NEDE-240 11-P-A.

Table 1 provides a description of the core.

2.11. Figure References Figure 3 is Figure 4.1 from NEDC-32601P-A. Figure 4 is Figure 111.5-1 from NEDC-32601P-A.

Figure 5 is based on Figure 111.5-2 from NEDC-32601P-A, and has been updated with GE14 and GNF2 data.

Discussion

{Verified Information}

Page 9 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 2.6.

Minimum Core Flow Condition For Peach Bottom Unit 3 Cycle 19, the minimum core flow SLMCPR calculation performed at 82.80/0 core flow and rated core power condition was limiting as compared to the rated core flow and rated core power condition. At low core flows, the search spaces for the limiting rod pattern and the nominal rod pattern are essentially the same.

Additionally, the condition that MIP

((

)) establishes a reasonably bounding limiting rod pattern. Hence, the rod pattern used to calculate the SLMCPR at 100% rated power/82.8% rated flow reasonably assures that at least 99.90/0 of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of Peach Bottom Unit 3 Cycle 19.

Consequently, the SLMCPR value calculated from the 82.80/0 core flow and rated core power condition limiting MCPR distribution reasonably bounds this mode of operation for Peach Bottom Unit 3 Cycle 19.

2.7.

Limiting Control Rod Patterns The limiting control rod patterns used to calculate the SLMCPR reasonably assures that at least 99.9% of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of Peach Bottom Unit 3 Cycle 19.

2.8.

Core Monitoring System For Peach Bottom Unit 3 Cycle 19, the 3DMonicore system will be used as the core monitoring system.

2.9.

Power/Flow Map The utility has provided the current and previous cycle power/flow map in a separate attachment.

2.10. Core Loading Diagram Figures 1 and 2 provide the core-loading diagram for the current and previous cycle respectively, which are the Reference Loading Pattern as defined by NEDE-24011-P-A. Table 1 provides a description of the core.

2.11. Figure References Figure 3 is Figure 4.1 from NEDC-32601P-A. Figure 4 is Figure III.5-1 from NEDC-32601P-A.

Figure 5 is based on Figure III.5-2 from NEDC-32601P-A, and has been updated with GE14 and GNF2 data.

Discussion

{Verified Information}

Page 9 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 2.6.

Minimum Core Flow Condition For Peach Bottom Unit 3 Cycle 19, the minimum core flow SLMCPR calculation performed at 82.80/0 core flow and rated core power condition was limiting as compared to the rated core flow and rated core power condition. At low core flows, the search spaces for the limiting rod pattern and the nominal rod pattern are essentially the same.

Additionally, the condition that MIP

((

)) establishes a reasonably bounding limiting rod pattern. Hence, the rod pattern used to calculate the SLMCPR at 100% rated power/82.8% rated flow reasonably assures that at least 99.90/0 of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of Peach Bottom Unit 3 Cycle 19.

Consequently, the SLMCPR value calculated from the 82.80/0 core flow and rated core power condition limiting MCPR distribution reasonably bounds this mode of operation for Peach Bottom Unit 3 Cycle 19.

2.7.

Limiting Control Rod Patterns The limiting control rod patterns used to calculate the SLMCPR reasonably assures that at least 99.9% of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of Peach Bottom Unit 3 Cycle 19.

2.8.

Core Monitoring System For Peach Bottom Unit 3 Cycle 19, the 3DMonicore system will be used as the core monitoring system.

2.9.

Power/Flow Map The utility has provided the current and previous cycle power/flow map in a separate attachment.

2.10. Core Loading Diagram Figures 1 and 2 provide the core-loading diagram for the current and previous cycle respectively, which are the Reference Loading Pattern as defined by NEDE-24011-P-A. Table 1 provides a description of the core.

2.11. Figure References Figure 3 is Figure 4.1 from NEDC-32601P-A. Figure 4 is Figure III.5-1 from NEDC-32601P-A.

Figure 5 is based on Figure III.5-2 from NEDC-32601P-A, and has been updated with GE14 and GNF2 data.

Discussion

{Verified Information}

Page 9 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 2.12. Additional SLMCPR Licensing Conditions For Peach Bottom Unit 3 Cycle 19, no additional SLMCPR licensing conditions are included in the analysis.

2.13. Summary The requested changes to the Technical Specification SLMCPR values are 1.09 for 110 and 1.12 for SLO for Peach Bottom Unit 3 Cycle 19.

Discussion

{Verified Information)

Page 10 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 2.12. Additional SLMCPR Licensing Conditions For Peach Bottom Unit 3 Cycle 19, no additional SLMCPR licensing conditions are included in the analysis.

2.13. Summary The requested changes to the Technical Specification SLMCPR values are 1.09 for TLO and 1.12 for SLO for Peach Bottom Unit 3 Cycle 19.

Discussion

{Verified Information}

Page 10 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 2.12. Additional SLMCPR Licensing Conditions For Peach Bottom Unit 3 Cycle 19, no additional SLMCPR licensing conditions are included in the analysis.

2.13. Summary The requested changes to the Technical Specification SLMCPR values are 1.09 for TLO and 1.12 for SLO for Peach Bottom Unit 3 Cycle 19.

Discussion

{Verified Information}

Page 10 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 3.0 References I.

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

2.

Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), Confirmation of the Applicability of the GEXL14 Correlation and Associated R-Factor Methodology for Calculating SLMCPR Values in Cores Containing GEI4 Fuel, FLN-200l-017, October 1, 2001.

3.

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

4.

Letter, John F. Schardt (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Mel B. Fields (NRC), Shadow Corrosion Effects on SLMCPR Channel Bow Uncertainty, FLN-2004-030, November 10, 2004.

5.

Letter, Jason S. Post (GENE) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Chief, Information Management Branch, et al. (NRC), Part 21 Final Report: Non-Conservative SLMCPR, MFN 04-108, September 29, 2004.

6.

Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Alan Wang (NRC), NRC Technology Update

Proprietary Slides July 31 August 1, 2002, FLN-2002-015, October31, 2002.

7.

Letter, Jens G. Munthe Andersen (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Alan Wang (NRC), GEXL Correlation for 1OX1O Fuel, FLN-2003-005, May 31, 2003.

8.

Letter, Andrew A. Lingenfelter (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with cc to MC Honcharik (NRC), Removal of Penalty Being Applied to GE14 Critical Power Correlation for Outlet Peaked Axial Power Shapes, FLN-2007-031, September 18, 2007.

9.

Letter, Andrew A. Lingenfelter (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with cc to SS Philpott (NRC), Amendment 33 to NEDE-2401 1-P, General Electric Standard Application for Reactor Fuel (GESTAR II) and GNF2 Advantage Generic Compliance with NEDE-2401 1-P-A (GESTAR II), NEDC-33270P, Revision 3, March 2010., MFN 10-045, March 5, 2010.

References

{Verified Information}

Page 11 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 3.0 References 1.

Letter, Glen A.Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of 10xl0 Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies",

FLN-2001-016, September 24,2001.

2.

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

3.

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

4.

Letter, John F. Schardt (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Mel B. Fields (NRC), "Shadow Corrosion Effects on SLMCPR Channel Bow Uncertainty", FLN-2004-030, November 10,2004.

5.

Letter, Jason S. Post (GENE) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Chief, Information Management Branch, et al. (NRC), "Part 21 Final Report: Non-Conservative SLMCPR", MFN 04-108, September 29,2004.

6.

Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Alan Wang (NRC), "NRC Technology Update Proprietary Slides - July 31 August 1, 2002", FLN-2002-015, October 31, 2002.

7.

Letter, Jens G. Munthe Andersen (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Alan Wang (NRC), "GEXL Correlation for 10XI0 Fuel", FLN-2003-005, May 31,2003.

8.

Letter, Andrew A. Lingenfelter (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with cc to MC Honcharik (NRC), "Removal of Penalty Being Applied to GE14 Critical Power Correlation for Outlet Peaked Axial Power Shapes",

FLN-2007-031, September 18,2007.

9.

Letter, Andrew A. Lingenfelter (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with cc to SS Philpott (NRC), "Amendment 33 to NEDE-24011-P, General Electric Standard Application for Reactor Fuel (GESTAR II) and GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II), NEDC-33270P, Revision 3, March 2010.", MFN 10-045, March 5,2010.

References

{Verified Information}

Page 11 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 3.0 References 1.

Letter, Glen A.Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of 10xl0 Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies",

FLN-2001-016, September 24,2001.

2.

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

3.

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

4.

Letter, John F. Schardt (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Mel B. Fields (NRC), "Shadow Corrosion Effects on SLMCPR Channel Bow Uncertainty", FLN-2004-030, November 10,2004.

5.

Letter, Jason S. Post (GENE) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Chief, Information Management Branch, et al. (NRC), "Part 21 Final Report: Non-Conservative SLMCPR", MFN 04-108, September 29,2004.

6.

Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Alan Wang (NRC), "NRC Technology Update Proprietary Slides - July 31 August 1, 2002", FLN-2002-015, October 31, 2002.

7.

Letter, Jens G. Munthe Andersen (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Alan Wang (NRC), "GEXL Correlation for 10XI0 Fuel", FLN-2003-005, May 31,2003.

8.

Letter, Andrew A. Lingenfelter (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with cc to MC Honcharik (NRC), "Removal of Penalty Being Applied to GE14 Critical Power Correlation for Outlet Peaked Axial Power Shapes",

FLN-2007-031, September 18,2007.

9.

Letter, Andrew A. Lingenfelter (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with cc to SS Philpott (NRC), "Amendment 33 to NEDE-24011-P, General Electric Standard Application for Reactor Fuel (GESTAR II) and GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II), NEDC-33270P, Revision 3, March 2010.", MFN 10-045, March 5,2010.

References

{Verified Information}

Page 11 of25

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(Ji C)

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 60 58 56 54 52 50 42

,10 38 313 34 32 30 28 26 24 22 20 18 16 14 12 10 8

G 4-

'2 A = G514-PI0DNAB416-15GZ-IOOT-150-T6-2008 B

= GE14-PIODNAB40.s-15GZ-IOGT-150-T6-3213 GNF2-PIODG2B400-13GZ-IOOT2-150-T6-2850-LUA D

GE14-PIODNAB414-14GZ-I00T-150-T6-3200 E = GE14-PIODNAB403-15GZ-IOOT-150-T6-3003 f

= GE14-PIODNAB417-15GZ-100T-150-T6-3199 GE14-PIODNAB408-15GZ-I00T-150-T6-3213 GE14-PIODNAB42D-13GZ-I00T-150-T6-3198 I

= GNF2-P10DG2B395-14GZ-IOOT:-150-T6-3981

,J = GE14-PlODNAE414-14GZ-IOOT-150-T6-3002 K = GE14-PIODNAB416-15GZ-I00T-150-T6-2908 L = GE14-PIGDNAB409-15GZ-IOOT-150-T6-2913

'1 = GNF2-PI0DG2B390-4GB. 0/%;7. 0/2G£. 0-1001'2-150-T6-3992 N = GE14-PIGDNAB403-15i3Z-100T-15G-T£-3Q03 o = GE14-PIGDNAB403-15GZ-IOOT-150-T6-3G03 p = GE14-PIODNAB418-12GZ-100T-150-T6-3D05 Q = GE!.4-PI0DNAB412-14GZ-IO')T-150-T6-3004 R

'?NF2-P10DG23399-13G'Z-lOO'T2-1 SG-T6-3Sf~+3 S

GNF2-PIGDG2B404-13GZ-I00T2-150-T6-3094 T = GNF2-PIODG:3390-4G8.0/8G7~O!2G6.0-100T2-150-T6-3992 u = ';NF2-PIODG2B404-13GZ-IOOT2-150-T6-3994 Figure 1. Current Cycle Core Loading Diagram Figure 1. Current Cycle Core Loading Diagram

{Verified Information}

Page 12 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 60 58 56 54 52 50 42

,10 38 313 34 32 30 28 26 24 22 20 18 16 14 12 10 8

G 4-

'2 A = G514-PI0DNAB416-15GZ-IOOT-150-T6-2008 B

= GE14-PIODNAB40.s-15GZ-IOGT-150-T6-3213 GNF2-PIODG2B400-13GZ-IOOT2-150-T6-2850-LUA D

GE14-PIODNAB414-14GZ-I00T-150-T6-3200 E = GE14-PIODNAB403-15GZ-IOOT-150-T6-3003 f

= GE14-PIODNAB417-15GZ-100T-150-T6-3199 GE14-PIODNAB408-15GZ-I00T-150-T6-3213 GE14-PIODNAB42D-13GZ-I00T-150-T6-3198 I

= GNF2-P10DG2B395-14GZ-IOOT:-150-T6-3981

,J = GE14-PlODNAE414-14GZ-IOOT-150-T6-3002 K = GE14-PIODNAB416-15GZ-I00T-150-T6-2908 L = GE14-PIGDNAB409-15GZ-IOOT-150-T6-2913

'1 = GNF2-PI0DG2B390-4GB. 0/%;7. 0/2G£. 0-1001'2-150-T6-3992 N = GE14-PIGDNAB403-15i3Z-100T-15G-T£-3Q03 o = GE14-PIGDNAB403-15GZ-IOOT-150-T6-3G03 p = GE14-PIODNAB418-12GZ-100T-150-T6-3D05 Q = GE!.4-PI0DNAB412-14GZ-IO')T-150-T6-3004 R

'?NF2-P10DG23399-13G'Z-lOO'T2-1 SG-T6-3Sf~+3 S

GNF2-PIGDG2B404-13GZ-I00T2-150-T6-3094 T = GNF2-PIODG:3390-4G8.0/8G7~O!2G6.0-100T2-150-T6-3992 u = ';NF2-PIODG2B404-13GZ-IOOT2-150-T6-3994 Figure 1. Current Cycle Core Loading Diagram Figure 1. Current Cycle Core Loading Diagram

{Verified Information}

Page 12 of25

NONPROPR1ETARY INFORMATION Class I (Public)

GNF Attachment 60 Jj jFJ 58 jfjfj jJ Tj jf 56 I1i Ii1 IiI UiIIii IIi1IiI Ji1 52 50 48 46 44 JjJQj jjj jjj 42 40 38 36 IIlIlL11IlIILJII!f 34 32 30 28 26 24 F1iII E1i1 kti LJiLI FiL1 I:LIIU 1JLL aui iai LJIU 22 20 18 16 14 12 iiiiiiiiiiLIIILi 10 8

6 4

III 2

1 3

5 7

9 11 13 15 17 19 21 23 25 27 29 31 33 3 37 39 41 43 45 47 49 51 53 55 57 59 Figure 2. Previous Cycle Core Loading Diagram Figure 2. Previous Cycle Core Loading Diagram Page 13 of 25 Fuel Type A=GE14-P1ODNAB4I6-15GZ-100T-150-T6-2908 Cvc1e 13)

B=GE14-P1ODNAB408-15GZ-I0OT-50-T6-3213 Cvcle 18)

C=GE14-PIODNAB415-I4GZ-100T-150-Tó-2848 (yc1e 16)

GE14-Pl0DNAB414-l5GZ-100T-l5O-T6-2849 (Cycle 16)

E=GNF2-Pl0DG2B4O0-i3GZ-lOOT2-150T&2350-LUA (Cycle 16)

F=GE14-PIODNAB414-I4GZ-100T-150-T6-3200 (Cycle 12)

G=GE14-P1ODNAB4O3--15GZ-IOOT-150-T6-3003 Cycle 18)

H=GE14-PIODNAB4I7-15GZ-100T-150-T6-3W9 (Cycle 1$)

I=GEI4-PIODNAB4OS-I5GZ-IOOT-150-16-3213 (Cycle 13)

T=GE14-P10DNAB420-13GZ-i00T-I50T&3198 K=GEI4-PIODNAB4I4-I4GZ-iOOT-i50-T6-3002 L=GEI4-PIODNAB4I6-15GZ-100T-150-T6-2908 M=GE13-PIODNAB4O9-I5GZ-IOOT-150-T6-2913 N=GEi4-P10DN.303-15GZ-lO0T-15OT6-3O03 O=GE14-P10DNA33-15GZ-iO0T-i5O-T6-3OO3 P=GEI4-PIODNAB4IS-I2GZ-lOOT-150--T6-3005 Q=E14-P10D![AB-l2-l4cZ4O0T-1S0-T6-3O04 (Cycle 18)

(Cycle 17)

(Cycle I))

(Cycle 17)

(Cycle 17)

(Cycle 13 (Cycle 17)

(Cycle 17)

{Verified Information}

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 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 1719 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 Fuel Type A=GE14-PIODNAB416-15GZ-lOOT-15D-T6-290S (Cycle 18)

J=GE14-PIODNAB420-13GZ-IOOT-150-T6-3198 B=GE14-PlODNAB408-15GZ-100T-150-T6-3213 (Cycle 18)

K=GEl4-PlODNAB414-14GZ-lOOT-150'-To-3002 C=GEI4-PlODNAB415-14GZ-IOOT-150-T6-2848 (Cycle 16)

L=GE14-PlODNAB416-15GZ-lOOT-150-T6-2908 D=GEI4-PIODNAB414-15GZ-lOOT-150-T6-2S49 (Cycle 16)

!vl=GEl4-PlODNAB409-15GZ-100T~150-T6-2913 E=GNF2-PlODG2B400-13GZ-lOOTI-150-T6-2850-LUA (Cycle 16)

N=GE14-PlODNAB403-15GZ-lOOT-150-Ta-3003 F=GE14-PlODNAB414-14GZ-lOOT..150-T6-3200 (Cycle IS)

O=GEl4-PI0DNAB403-15GZ-lOOT-150..T6-3003 G=GE14-PIODNAB403-15GZ-lOOT-150-T6-3003 (Cycle IS)

P=GEl4-PIODN.:\\B418-12GZ-IOOT-150-T6-3005 H=GE14-PlODNAB417-15GZ-IOOT-15U-To-3199 (Cycle 18)

Q=GEI4-PlODNAB412-14GZ-lOOT-150-Ta-3004 I=GE14-PlODN.A.B408-15GZ-lOOT-150-T6-3213 (Cycle 18)

Figure 2. Previous Cycle Core Loading Diagram (Cycle 18)

(Cycle 17)

(Cycle 17)

(Cycle 17)

(Cycle 17)

(Cyde 13)

(Cyde 17)

(Cycle 17)

Figure 2. Previous Cycle Core Loading Diagram

{Verified Information}

Page 13 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment 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 1719 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 Fuel Type A=GE14-PIODNAB416-15GZ-lOOT-15D-T6-290S (Cycle 18)

J=GE14-PIODNAB420-13GZ-IOOT-150-T6-3198 B=GE14-PlODNAB408-15GZ-100T-150-T6-3213 (Cycle 18)

K=GEl4-PlODNAB414-14GZ-lOOT-150'-To-3002 C=GEI4-PlODNAB415-14GZ-IOOT-150-T6-2848 (Cycle 16)

L=GE14-PlODNAB416-15GZ-lOOT-150-T6-2908 D=GEI4-PIODNAB414-15GZ-lOOT-150-T6-2S49 (Cycle 16)

!vl=GEl4-PlODNAB409-15GZ-100T~150-T6-2913 E=GNF2-PlODG2B400-13GZ-lOOTI-150-T6-2850-LUA (Cycle 16)

N=GE14-PlODNAB403-15GZ-lOOT-150-Ta-3003 F=GE14-PlODNAB414-14GZ-lOOT..150-T6-3200 (Cycle IS)

O=GEl4-PI0DNAB403-15GZ-lOOT-150..T6-3003 G=GE14-PIODNAB403-15GZ-lOOT-150-T6-3003 (Cycle IS)

P=GEl4-PIODN.:\\B418-12GZ-IOOT-150-T6-3005 H=GE14-PlODNAB417-15GZ-IOOT-15U-To-3199 (Cycle 18)

Q=GEI4-PlODNAB412-14GZ-lOOT-150-Ta-3004 I=GE14-PlODN.A.B408-15GZ-lOOT-150-T6-3213 (Cycle 18)

Figure 2. Previous Cycle Core Loading Diagram (Cycle 18)

(Cycle 17)

(Cycle 17)

(Cycle 17)

(Cycle 17)

(Cyde 13)

(Cyde 17)

(Cycle 17)

Figure 2. Previous Cycle Core Loading Diagram

{Verified Information}

Page 13 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment

((

ii Figure 3. Figure 4.1 from NEDC-32601P-A Figure 3. Figure 4.1 from NEDC-3260 1 P-A Page 14 of 25

{Verified Information}

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment

((

Figure 3. Figure 4.1 from NEDC-32601P-A Figure 3. Figure 4.1 from NEDC-32601P-A

{Verified Information}

))

Page 14 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment

((

Figure 3. Figure 4.1 from NEDC-32601P-A Figure 3. Figure 4.1 from NEDC-32601P-A

{Verified Information}

))

Page 14 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment ii Figure 4. Figure 111.5-1 from NEDC-32601P-A Figure 4. Figure 111.5-1 from NEDC-32601P-A Page 15 of 25

{Verified Information}

NON-PROPRIETARY INFORMATION Class 1(Public)

GNF Attachment

((

Figure 4. Figure 111.5-1 from NEDC-32601P-A Figure 4. Figure 111.5-1 from NEDC-32601P-A

{Verified Information}

))

Page 15 of25 NON-PROPRIETARY INFORMATION Class 1(Public)

GNF Attachment

((

Figure 4. Figure 111.5-1 from NEDC-32601P-A Figure 4. Figure 111.5-1 from NEDC-32601P-A

{Verified Information}

))

Page 15 of25

NON-PROPRiETARY INFORMATION Class I (Public)

GNF Attachment 11 Figure 5. Relationship Between MIP and CPR Margin Figure 5. Relationship Between MIP and CPR Margin Page 16 of 25

{Verified Information}

NON-PROPRIETARY rNFORMATION Class I (Public)

GNF Attachment

((

Figure 5. Relationship Between MIP and CPR Margin Figure 5. Relationship Between MIP and CPR Margin

{Verified Information}

))

Page 16 of25 NON-PROPRIETARY rNFORMATION Class I (Public)

GNF Attachment

((

Figure 5. Relationship Between MIP and CPR Margin Figure 5. Relationship Between MIP and CPR Margin

{Verified Information}

))

Page 16 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 1. Description of Core Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case Number of Bundles in the 764 764 Core Limiting Cycle Exposure Point (i.e.

EOC EOC EOC EOC BOC/MOC/EOC)

Cycle Exposure at Limiting Point 13200 13200 12425 12425 (MWdISTU)

%Rated Core Flow 82.8 100 82.8 100 Reload Fuel Type GE14 GNF2 Latest Reload Batch 35 6 Fraction, %

35.1 Latest Reload Average Batch Weight%

4.12 3.95 Enrichment Core Fuel Fraction:

GE14 0.995 0.647 GNF2 0.005 0.353 Core Average Weight %

4 13 Enrichment Table 1. Description of Core

{Verified Information}

Page 17 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 1. Description of Core Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case Number ofBundles in the 764 764 Core Limiting Cycle Exposure Point (i.e.

EOC EOC EOC EOC BOC/MOC/EOC)

Cycle Exposure at Limiting Point 13200 13200 12425 12425 (MWd/STU)

% Rated Core Flow 82.8 100 82.8 100 Reload Fuel Type GE14 GNF2 Latest Reload Batch 35.6 35.1 Fraction, %

Latest Reload Average Batch Weight %

4.12 3.95 Enrichment Core Fuel Fraction:

0.995 0.647 GE14 GNF2 0.005 0.353 Core Average Weight %

4.13 4.06 Enrichment Table 1. Description of Core

{Verified Information}

Page 17 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 1. Description of Core Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case Number ofBundles in the 764 764 Core Limiting Cycle Exposure Point (i.e.

EOC EOC EOC EOC BOC/MOC/EOC)

Cycle Exposure at Limiting Point 13200 13200 12425 12425 (MWd/STU)

% Rated Core Flow 82.8 100 82.8 100 Reload Fuel Type GE14 GNF2 Latest Reload Batch 35.6 35.1 Fraction, %

Latest Reload Average Batch Weight %

4.12 3.95 Enrichment Core Fuel Fraction:

0.995 0.647 GE14 GNF2 0.005 0.353 Core Average Weight %

4.13 4.06 Enrichment Table 1. Description of Core

{Verified Information}

Page 17 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 2.

SLMCPR Calculation Methodologies Previous Cycle I

Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow I

Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case j

Case Limiting Case Case Non-power Distribution NEDC-3260 1 P-A NEDC-32601 P-A Uncertainty Power Distribution NEDC-3260 1 P-A NEDC-32601 P-A Methodology Power Distribution NEDC-32694P-A NEDC-32694P-A Uncertainty Core Monitoring System 3DMonicore 3DMonicore R-Factor Calculation NEDC-32505P-A NEDC-32505P-A Methodology Table 2. SLMCPR Calculation Methodologies

{Verified Information}

Page 18 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 2. SLMCPR Calculation Methodologies Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case Non-power Distribution NEDC-3260IP-A NEDC-32601P-A Uncertainty Power Distribution NEDC-32601P-A NEDC-32601P-A Methodology Power Distribution NEDC-32694P-A NEDC-32694P-A Uncertainty Core Monitoring System 3DMonicore 3DMonicore R-Factor Calculation NEDC-32505P-A NEDC-32505P-A Methodology Table 2. SLMCPR Calculation Methodologies

{Verified Information}

Page 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 2. SLMCPR Calculation Methodologies Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case Non-power Distribution NEDC-3260IP-A NEDC-32601P-A Uncertainty Power Distribution NEDC-32601P-A NEDC-32601P-A Methodology Power Distribution NEDC-32694P-A NEDC-32694P-A Uncertainty Core Monitoring System 3DMonicore 3DMonicore R-Factor Calculation NEDC-32505P-A NEDC-32505P-A Methodology Table 2. SLMCPR Calculation Methodologies

{Verified Information}

Page 18 25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case

((

Table 3. Monte Carlo Calculated SLMCPR vs. Estimate

{Verified Information}

Page 19 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case

((

Table 3. Monte Carlo Calculated SLMCPR vs. Estimate

{Verified Information}

Page 19 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case

((

Table 3. Monte Carlo Calculated SLMCPR vs. Estimate

{Verified Information}

Page 19 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case Ii Table 3. Monte Carlo Calculated SLMCPR vs. Estimate

{Verified Information}

Page 20 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case

))

Table 3. Monte Carlo Calculated SLMCPR vs. Estimate

{Verified Information}

Page 20 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case

))

Table 3. Monte Carlo Calculated SLMCPR vs. Estimate

{Verified Information}

Page 20 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 4. Non-Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/- a (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case GETAB Feedwater Flow 1.76 N/A N/A N/A N/A Measurement Feedwater Temperature 0.76 N/A N/A N/A N/A Measurement Reactor Pressure 0.50 N/A N/A N/A N/A Measurement Core Inlet Temperature 0.20 N/A N/A N/A N/A Measurement Total Core Flow 6.0 SLO/2.5 TLO N/A N/A N/A N/A Measurement Channel Flow Area 3.0 N/A N/A N/A N/A Variation Friction Factor 10.0 N/A N/A N/A N/A Multiplier Channel Friction 5.0 N/A N/A N/A N/A Factor Multiplier Table 4. Non-Power Distribution Uncertainties

{Verified Information}

Page 21 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 4. Non-Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/-O'(%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case GETAB Feedwater Flow 1.76 N/A N/A N/A Measurement Feedwater Temperature 0.76 N/A N/A N/A N/A Measurement Reactor Pressure 0.50 N/A N/A N/A N/A Measurement Core Inlet Temperature 0.20 N/A N/A N/A N/A Measurement Total Core Flow 6.0 SLO/2.5 TLO N/A N/A N/A N/A Measurement Channel Flow Area 3.0 N/A N/A N/A N/A Variation Friction Factor 10.0 N/A N/A N/A Multiplier Channel Friction 5.0 N/A N/A N/A N/A Factor Multiplier Table 4. Non-Power Distribution Uncertainties

{Verified Information}

Page 21 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 4. Non-Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/-O'(%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case GETAB Feedwater Flow 1.76 N/A N/A N/A Measurement Feedwater Temperature 0.76 N/A N/A N/A N/A Measurement Reactor Pressure 0.50 N/A N/A N/A N/A Measurement Core Inlet Temperature 0.20 N/A N/A N/A N/A Measurement Total Core Flow 6.0 SLO/2.5 TLO N/A N/A N/A N/A Measurement Channel Flow Area 3.0 N/A N/A N/A N/A Variation Friction Factor 10.0 N/A N/A N/A Multiplier Channel Friction 5.0 N/A N/A N/A N/A Factor Multiplier Table 4. Non-Power Distribution Uncertainties

{Verified Information}

Page 21

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 4. Non-Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Approved) Value Minimum Core Rated Core Flow.

Minimum Core Rated Core Flow

+/- a (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case NEDC-32601P-A Feedwater Flow

((

Ii

((

ii

((

11 El U

((

U Measurement Feedwater Temperature

((

))

((

jj

((

jJ

((

ii

((

j]

Measurement Reactor Pressure

((

1]

II U

((

U

((

U

((

U Measurement Core Inlet Temperature 0.2 0.2 0.2 0.2 0.2 Measurement Total Core Flow 6.0 SLO/2.5 TLO 6.0 SLO/3.02 TLO 6.0 SLO/2.5 TLO 6.0 SLO/3.02 TLO 6.0 SLO/2.5 TLO Measurement Channel Flow Area

((

U

((

U

((

11

((

U

((

U Variation Friction Factor

{[

11

[{

11

((

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Multiplier Channel Friction 5.0 5.0 5.0 5,0 5.0 Factor Multiplier Table 4. Non-Power Distribution Uncertainties

{Verified Information}

Page 22 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 4. Non-Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Approved) Value Minimum Core Rated Core Flow*

Minimum Core Rated Core Flow

+/- 0' (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case NEDC-32601P-A Feedwater Flow

((

))

((

))

((

))

((

))

((

))

Measurement Feedwater Temperature

((

))

((

))

((

))

((

))

((

))

Measurement Reactor Pressure

((

))

((

))

((

))

((

))

((

))

Measurement Core Inlet Temperature 0.2 0.2 0.2 0.2 0.2 Measurement Total Core Flow 6.0 SLO/2.5 TLO 6.0 SLO/3.02 TLO 6.0 SLO/2.5 TLO 6.0 SLO/3.02 TLO 6.0 SLO/2.5 TLO Measurement Channel Flow Area

((

))

((

))

((

))

((

))

((

))

Variation Friction Factor

((

))

((

))

((

))

((

))

((

))

Multiplier Channel Friction 5.0 5.0 5.0 5.0 5.0 Factor Multiplier Table 4. Non-Power Distribution Uncertainties

{Verified Information}

Page of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 4. Non-Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Approved) Value Minimum Core Rated Core Flow*

Minimum Core Rated Core Flow

+/- 0' (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case NEDC-32601P-A Feedwater Flow

((

))

((

))

((

))

((

))

((

))

Measurement Feedwater Temperature

((

))

((

))

((

))

((

))

((

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Measurement Reactor Pressure

((

))

((

))

((

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((

))

((

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Measurement Core Inlet Temperature 0.2 0.2 0.2 0.2 0.2 Measurement Total Core Flow 6.0 SLO/2.5 TLO 6.0 SLO/3.02 TLO 6.0 SLO/2.5 TLO 6.0 SLO/3.02 TLO 6.0 SLO/2.5 TLO Measurement Channel Flow Area

((

))

((

))

((

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((

))

((

))

Variation Friction Factor

((

))

((

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((

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((

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((

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Multiplier Channel Friction 5.0 5.0 5.0 5.0 5.0 Factor Multiplier Table 4. Non-Power Distribution Uncertainties

{Verified Information}

Page of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 5. Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Description Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/- a (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case GETAB/NEDC-32601P-A GEXL R-Factor

((

jj N/A N/A N/A N/A Random Effective 2.85 SLO/l.2 TLO N/A N/A N/A N/A TIP Reading Systematic Effective 8.6 N/A N/A N/A N/A TIP Reading NEDC-32694P-A, 3DMONICORE GEXL RFactor

((

))

((

j]

((

jj

((

ii

((

Random Effective 2.85 SLO/l.2 TLO 2.85 SLO/l.45 TLO 2,85 SLO/l.2 TLO 2.85 SLO/l.45 TLO 2.85 SLO/1.2 TLO TIP Reading TIP Integral

((

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11

((

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Four Bundle Power Distribution

((

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((

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Uncertainty Due to LPRM Update Table 5. Power Distribution Uncertainties

{Verified Information}

Page 23 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 5. Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Description Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/- (j (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case GETAB/NEDC-32601P-A GEXL R-Factor

((

))

N/A N/A N/A N/A Random Effective 2.85 SLOIl.2 TLO N/A N/A N/A N/A TIP Reading Systematic Effective 8.6 N/A N/A N/A N/A TIP Reading NEDC-32694P-A, 3DMONICORE GEXL R-Factor

((

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((

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((

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((

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((

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Random Effective 2.85 SLO/I.2 TLO 2.85 SLOIl.45 TLO 2.85 SLOIl.2 TLO 2.85 SLO/I.45 TLO 2.85 SLO/I.2 TIP Reading TIP Integral

((

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((

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((

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Four Bundle Power Distribution

((

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((

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((

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Surrounding TIP Location Contribution to Bundle Power

((

))

((

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((

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Uncertainty Due to LPRMUpdate Table 5. Power Distribution Uncertainties

{Verified Information}

Page 23 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 5. Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Description Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/- (j (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case GETAB/NEDC-32601P-A GEXL R-Factor

((

))

N/A N/A N/A N/A Random Effective 2.85 SLOIl.2 TLO N/A N/A N/A N/A TIP Reading Systematic Effective 8.6 N/A N/A N/A N/A TIP Reading NEDC-32694P-A, 3DMONICORE GEXL R-Factor

((

))

((

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((

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((

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Random Effective 2.85 SLO/I.2 TLO 2.85 SLOIl.45 TLO 2.85 SLOIl.2 TLO 2.85 SLO/I.45 TLO 2.85 SLO/I.2 TIP Reading TIP Integral

((

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((

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((

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Uncertainty Due to LPRMUpdate Table 5. Power Distribution Uncertainties

{Verified Information}

Page 23

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 5. Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Description Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/-

(%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case Contribution to Bundle PowerDue to

((

jj ii 1]

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Failed TIP Contribution to Bundle Power Due to

[{

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{Verified Information}

Page 24 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 5. Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Description Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/- cr (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case Contribution to Bundle Power Due to

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Failed TIP Contribution to Bundle Power Due to

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Power Uncertainty ofTIP Signal Nodal

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Uncertainty Table 5. Power Distribution Uncertainties

{Verified Information}

Page 24 of25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 5. Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Description Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow

+/- cr (%)

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case Contribution to Bundle Power Due to

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Failed TIP Contribution to Bundle Power Due to

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Uncertainty Table 5. Power Distribution Uncertainties

{Verified Information}

Page 24 of25

NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 6. Critical Power Uncertainties ii Previous Cycle Previous Cycle Current Cycle Current Cycle Nominal Value Description

+

10/

Minimum Core Rated Core Flow Minimum Core Rated Core Flow G

Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case

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Table 6. Critical Power Uncertainties

{Verified Information}

Page 25 of 25 NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 6. Critical Power Uncertainties Nominal Value Previous Cycle Previous Cycle Current Cycle Current Cycle Description

+/- (J (%)

Minimum Core Rated Core Flow Minimum Core Rated Core Flow Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case

((

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Table 6. Critical Power Uncertainties

{Verified Information}

Page NON-PROPRIETARY INFORMATION Class I (Public)

GNF Attachment Table 6. Critical Power Uncertainties Nominal Value Previous Cycle Previous Cycle Current Cycle Current Cycle Description

+/- (J (%)

Minimum Core Rated Core Flow Minimum Core Rated Core Flow Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case

((

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Table 6. Critical Power Uncertainties

{Verified Information}

Page

6 [ puI3 I-sokj io de MOId/JOMOd 9 1N]VH3YLLV ATTACHMENT 6 Power/Flow Map for Cycles 18 and 19 ATTACHMENT 6 Power/Flow Map for Cycles 18 and 19

. PBAPS POWER FLOW OPERATION MAP I 30 kT A

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