L-MT-11-066, Correction of 10 CFR 50.46 Analysis Error Applicable to Monticello Extended Power Uprate (TAC MD9990) and Monticello Maximum Extended Load Line Limit Analysis Plus (TAC ME3145) License Amendment Requests

Correction of 10 CFR 50.46 Analysis Error Applicable to Monticello Extended Power Uprate (TAC MD9990) and Monticello Maximum Extended Load Line Limit Analysis Plus (TAC ME3145) License Amendment Requests

ML11321A332
Person / Time
Site:	Monticello
Issue date:	11/11/2011
From:	O'Connor T Xcel Energy, Northern States Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-11-066, TAC MD9990, TAC ME3145
Download: ML11321A332 (19)

Text

ENCLOSURES 1 AND 2 CONTAINS PROPRIETARY INFORMATION -

WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10CFR 2.390 XcelEnergy Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 November 11,2011 L-MT-1 1-066 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22 Correction of 10 CFR 50.46 Analysis Error Applicable to Monticello Extended Power Uprate (TAC MD9990) and Monticello Maximum Extended Load Line Limit Analysis Plus (TAC ME3145) License Amendment Requests

References:

1) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),

"License Amendment Request: Extended Power Uprate (TAC MD9990)," L-MT-08-052, dated November 5, 2008. (ADAMS Accession No. ML083230111)

2) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),

"License Amendment Request: Maximum Extended Load Line Limit Analysis Plus," L-MT-10-003, dated January 21, 2010. (ADAMS Accession No. ML100280558)

3) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),

"10 CFR 50.46 Thirty Day Report," L-MT-1 1-039, dated July 7, 2011.

(ADAMS Accession No. ML111890240)

4) Email from P Tam (NRC) to Fields, John S and Eckholt, Gene F (NSPM), "

Subject:

Monticello - Draft RAI re. ECCS analysis for the EPU application (TAC MD9990)," dated September 12, 2011.

(ADAMS Accession No. ML112570095)

5) Letter from T J O'Connor (NSPM), to Document Control Desk (NRC),

"Monticello Extended Power Uprate: Updates to Docketed Information (TAC MD9990)," L-MT-10-072, dated December 21, 2010. (ADAMS Accession No. MLI103570026)

Document Control Desk Page 2 Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, requested in Reference 1 an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS) to increase the maximum authorized power level from 1775 megawatts thermal (MWt) to 2004 MWt. This is called an extended power uprate (EPU).

Pursuant to 10 CFR 50.90, NSPM requested in Reference 2 an amendment to the MNGP Renewed OL and TS to allow operation within the Maximum Extended Load Line Limit Analysis Plus (MELLLA+) operating domain.

Pursuant to 10 CFR 50.46(a)(3)(ii), NSPM provided in Reference 3 a 30-day report of changes or errors identified in the Emergency Core Cooling System (ECCS) evaluation models or their application for MNGP. The 30-day report was provided due to the receipt of several recent General Electric/Hitachi (GEH) Nuclear Energy 10 CFR 50.46 notifications of analysis errors that resulted in a cumulative increase in Peak Cladding Temperature (PCT) exceeding 50'F.

In Reference 4 the NRC identified that the same errors that NSPM reported in Reference 3 would also affect the analyses that the NRC was currently reviewing for the EPU license amendment request (LAR) (Reference 1). The NRC further requested that NSPM provide a revised ECCS evaluation that accounts for EPU operation and corrects the errors identified in Reference 3.

The purpose of this letter is to provide corrected pages to both the EPU and MELLLA+

LARs with respect to the 10 CFR 50.46 errors identified by GEH Nuclear Energy.

Reference 3 was initiated in accordance with 10CFR 50.46 to document four errors discovered in evaluations of PCT. Two of the errors (error notifications 2003-01 and 2006-01) were already included in the analysis of PCT under EPU and MELLLA+

conditions provided in References 1 and 2 as they predate the submission of these safety analysis reports (SARs). The two remaining errors (error notifications 2011-02 and 2011-03) resulted in further analysis of PCT for EPU and MELLLA+ conditions.

GEH has completed the reanalysis and has provided the enclosed corrected pages to the EPU and MELLLA+ SARs. contains the corrected pages for NEDC-33322P, "Safety Analysis Report for Monticello Constant Pressure Power Uprate," a proprietary version of the EPU SAR. contains the corrected pages for NEDC-33435P, "Safety Analysis Report for Monticello Maximum Extended Load Line Limit Analysis Plus," a proprietary version of the MELLLA+ SAR.

Document Control Desk Page 3 contains affidavits executed to support withholding Enclosures 1 and 2 from public disclosure. Enclosures 1 and 2 contain information that is proprietary to General Electric - Hitachi (GEH), the owner of the information. The affidavits provided set forth the basis for which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). Accordingly, it is respectfully requested that the information which is proprietary to GEH be withheld from public disclosure in accordance with 10 CFR 2.390.

Correspondence with respect to the copyright or proprietary aspects of GEH information or the supporting GEH affidavits in Enclosure 3 should be addressed to Edward Schrull, Vice President, Regulatory Affairs, Services Licensing, GE Hitachi Nuclear Energy Americas LLC, 3901 Castle Hayne Road, Wilmington, North Carolina 28401. contains the corrected pages for NEDO-33322, "Safety Analysis Report for Monticello Constant Pressure Power Uprate," a non-proprietary version of the EPU SAR. contains the corrected pages for NEDO-33435, "Safety Analysis Report for Monticello Maximum Extended Load Line Limit Analysis Plus," a non-proprietary version of the MELLLA+ SAR.

The corrected pages provided herein do not change the conclusions of the No Significant Hazards Consideration and the Environmental Consideration evaluations provided in Reference 1 as revised by Reference 5 for EPU. Further, the corrected pages provided herein do not change the conclusions of the No Significant Hazards Consideration and the Environmental Consideration evaluations provided in Reference 2 for MELLLA+.

In accordance with 10 CFR 50.91(b), a copy of this application supplement, without enclosures, is being provided to the designated Minnesota Official.

Document Control Desk Page 4 Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct.

Executed o : November 2011 Ti yyJ. nonnor SifVice-P ident Monticello clear Generating Plant Northern States Power Company-Minnesota Enclosures (5) cc: Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC Minnesota Department of Commerce

ENCLOSURE3 AFFIDAVITS FOR WITHHOLDING PROPRIETARY DOCUMENTS 6 pages follow

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Edward D. Schrull, state as follows:

(1) I am the Vice President, Regulatory Affairs, Services Licensing, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GEH letter GE-MNGP-AEP-3109 RI, "NEDC-33322P Revision 3 and NEDO-33322 Revision 3 Corrected Pages and NEDC-33435P Revision 1 and NEDO-33435 Revision 1 Corrected Pages," dated October 25, 2011. The GEH proprietary information in Enclosure 1, which is entitled "NEDC-33322P Revision 3 Corrected Page," is identified by a dotted underline inside double square brackets. ((Ihis sentence is. an....exampl.3e.. 3 )). In each case, the superscript notation (3'refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of trade secret, Within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d 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 GEH's competitors without license from GEH constitutes a competitive economic advantage over GEH and/or 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 GEH customer-funded development plans and programs, that may include potential products to GEH.

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

Affidavit for GE-MINGP-AEP-3109 RI Enclosure I Affidavit Page I of 3

GE-Hitachi Nuclear Energy Americas LLC (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 GEH, 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 GEH, 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 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 GEH. Access to such documents within GEH 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 GEH 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 detailed results and conclusions regarding supporting evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability of the Constant Pressure Power Uprate (CPPU) analysis for a GEH Boiling Water Reactor (BWR). The analysis utilized analytical models and methods, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of CPPUs for a GEH BWR. 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 GEH asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH'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.

Affidavit for GE-MNGP-AEP-3109 R1 Enclosure 1 Affidavit Page 2 of 3

GE-Hitachi Nuclear Energy Americas LLC The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. 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. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH 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 GEH 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 25th day of October 2011.

Edward D. Schrull Vice President, Regulatory Affairs Services Licensing GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.

Wilmington, NC 28401 edward.schrull@ge.com Affidavit for GE-MNGP-AEP-3109 RI Enclosure I Affidavit Page 3 of 3

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Edward D. Schrull, state as follows:

(1) I am the Vice President, Regulatory Affairs, Services Licensing, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 4 of GEH letter GE-MNGP-AEP-3109 RI, "NEDC-33322P Revision 3 and NEDO-33322 Revision 3 Corrected Pages and NEDC-33435P Revision I and NEDO-33435 Revision I Corrected Pages," dated October 25, 2011. The GEH proprietary information in Enclosure 4, which is entitled "NEDC-33435P Revision I Corrected Pages," is identified by a dotted underline inside double square brackets. ((Ihis sentence isan..example. 3)). In each case, the superscript notation 1 refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).

(4) 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 GEH's competitors without license from GEH constitutes a competitive economic advantage over GEH and/or 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 GEH customer-funded development plans and programs, that may include potential products to GEH.

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

Affidavit for GE-MNGP-AEP-3109 RI Enclosure 4 Affidavit Page I of 3

GE-Hitachi Nuclear Energy Americas LLC (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 GEH, 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 GEH, 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 GEH. Access to such documents within GEH 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 GEH 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 detailed results and conclusions regarding supporting evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability of the Maximum Extended Load Line Limit Analysis Plus analysis for a GEH Boiling Water Reactor (BWR).

The analysis utilized analytical models and methods, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of Maximum Extended Load Line Limit Analysis Plus for a GEH BWR. 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 GEH asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH'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.

Affidavit for GE-MNGP-AEP-3109 RI Enclosure 4 Affidavit Page 2 of 3

GE-Hitachi Nuclear Energy Americas LLC The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. 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. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH 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 GEH 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 25th day of October 2011.

Edward D. Schrull Vice President, Regulatory Affairs Services Licensing GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.

Wilmington, NC 28401 edward.schrull@ge.com Affidavit for GE-MNGP-AEP-3109 RI Enclosure 4 Affidavit Page 3 of 3

ENCLOSURE4 CORRECTED PAGE FOR NEDO-33322, REVISION 3, SAFETY ANALYSIS REPORT FOR MONTICELLO CONSTANT PRESSURE POWER UPRATE 1 page follows

NEDO-33322, Revision 3 - Corrected Page failure is the limiting single failure. ((

)) For both EPU and CLTP, the GE14 Licensing Basis PCT is 2140'F and is based on the operating conditions at CLTP power and MELLLA core flow. The results of these analyses are provided in Table 2.8-5.

The results provided in Table 2.8-5 have subsequently been re-analyzed to incorporate resolutions to 10 CFR 50.46 error notifications 2011-02 and 2011-03. ((

)) The updated results are in compliance with 10 CFR 50.46 acceptance criteria.

In addition to the large break LOCA analysis, the small break LOCA response was reviewed in order to assure adequate ADS capacity. The increased decay heat associated with EPU results in a longer ADS blowdown and a higher PCT for the small break LOCA. Plant specific analyses demonstrate that there is sufficient ADS capacity at EPU conditions with all ADS valves available. With two ADS valves available, a LHGR multiplier is applied to ensure that the small break is not limiting. Also, the plant performance improvement of three SRVs OOS remains valid with EPU.

For SLO, a multiplier is applied to the Two-Loop MAPLHGR Operation limits. The operating I conditions for SLO are not changed with EPU; therefore, the current SLO analysis remains acceptable for EPU.

ARTS limits are unaffected by EPU. Also, the effect of ICF on PCT is negligible with EPU.

Thus the ARTS limits, as well as the ICF domain, remain valid with EPU.

Conclusion NSPM has evaluated the LOCA events and the ECCS. The evaluation concludes that operation of the plant at the proposed power level is acceptable In addition, NSPM will perform cycle specific reload analyses to confirm that the peak cladding temperature, total oxidation of the cladding, total hydrogen generation, and changes in core geometry and long-term cooling will remain within acceptable limits. Based on this, the evaluation concludes that the plant will continue to meet the requirements of the current licensing basis and 10 CFR 50.46 following implementation of the proposed EPU, and is, therefore, acceptable.

2-296

ENCLOSURE5 CORRECTED PAGES FOR NEDO-33435, REVISION 1, SAFETY ANALYSIS REPORT FOR MONTICELLO MAXIMUM EXTENDED LOAD LINE LIMIT ANALYSIS PLUS 4 pages follow

NEDO-33435 REVISION 1 - CORRECTED PAGE NON-PROPRIETARY INFORMATION PowerlFlow 2 Nominal PCT (°F) 1 Appendix K PCT (IF) 1 1st Peak 2nd Peak 1st Peak 2nd Peak

((

(1) PCT results shown are for GE14 fuel.

(2) Power level shown is percent of CLTP. Flow level shown is percent of rated core flow.

(3) ((

(4) [

Updated Results of 10 CFR 50.46 Error Resolution through 2011-03 Resolution of 10 CFR 50.46 error corrections 2011-02 and 2011-03 subsequent to this analysis indicates that ((

)) The Licensing Basis PCT result is in compliance with 10 CFR 50.46 acceptance criteria.

4.3.3 Small Break Peak Clad Temperature

((I M+LTR SER Limitation and Condition 12.13 requires that the MELLLA+ plant-specific SAR include calculations for the limiting small break at rated power/rated core flow and rated power/MIELLLA+ boundary, if the small break PCT at rated power/rated core flow is within

(( )) of the limiting Appendix K PCT. For Monticello, the small break PCT at rated power/rated core flow is (( )) than the Appendix K PCT. Therefore, no small break PCT calculations are performed for MELLLA+ flow.

M+LTR SER Limitation and Condition 12.14 requires that for plants that will implement MELLLA+, a sufficient number of small break sizes shall be analyzed at the rated EPU power level to ensure that the peak PCT break size is identified. ((

))

As required by M+LTR SER Limitation and Condition 12.11 and Methods LTR SER Limitation and Condition 9.7, for MELLLA+ applications, the small and large break ECCS-LOCA analyses shall include top-peaked and mid-peaked power shape in establishing the MAPLHGR and determining the PCT. This limitation is applicable to both the licensing bases PCT and the upper bound PCT. The plant-specific applications shall report the limiting small and large break 4-11

NEDO-33435 REVISION 1 - CORRECTED PAGE NON-PROPRIETARY INFORMATION licensing basis and upper bound PCTs. ((

The factors influencing the selection of the limiting single failure for Monticello are

)) The trends discussed in the M+LTR regarding the first and second clad temperature peaks are applicable to Monticello. ((

))

M+LTR SER Limitation and Condition 12.12 and Methods LTR SER Limitation and Condition 9.8 also requires that the ECCS-LOCA evaluation be performed for all statepoints in the upper boundary of the expanded operating domains. ((

Resolution of 10 CFR 50.46 error corrections 2011-02 and 2011-03 subsequent to this analysis indicates that the results are still in compliance with 10 CFR 50.46 acceptance criteria.

4.3.4 Local Cladding Oxidation

)) Sections 4.3.1 and 4.3.2 that determine the effect to the PCT. ((

)) and no further evaluation of this topic is required.

((I )) for Monticello Sections 4.3.1 and 4.3.2 show acceptable PCT results that meet the 2200'F limit. ((

)) and no further evaluation of this topic is required.

Resolution of 10 CFR 50.46 error corrections 2011-02 and 2011-03 subsequent to this analysis indicates that ((

)) The result is in compliance with 10 CFR 50.46 acceptance criteria.

4.3.5 Core Wide Metal Water Reaction

[1

)) Sections 4.3.1 and 4.3.2 that determine the effect on the PCT. ((

4-12

NEDO-33435 REVISION 1 - CORRECTED PAGE NON-PROPRIETARY INFORMATION

)) and no further evaluation of this topic is required.

)) for Monticello Sections 4.3.1 and 4.3.2 show acceptable PCT results that meet the 2200'F limit. ((

)) and no further evaluation of this topic is required.

Resolution of 10 CFR 50.46 error corrections 2011-02 and 2011-03 subsequent to this analysis indicates that ((

)) The result is in compliance with 10 CFR 50.46 acceptance criteria.

4.3.6 Coolable Geometry

)) Monticello's compliance with the coolable geometry acceptance criteria was generically demonstrated as a GE BWR ((

4.3.7 Long Term Cooling I((

)) Monticello's compliance with the long term cooling acceptance criteria was generically demonstrated as a GE BWR ((

((I 4-13

NEDO-33435 REVISION I - CORRECTED PAGE NON-PROPRIETARY INFORMATION 4.3.8 Flow Mismatch Limits limits have been placed on recirculation drive flow mismatch over a range of core flow. For most plants, the limits on flow mismatch are more relaxed at lower core flow rates. The drive flow mismatch affects the core flow coastdown following the break. The effect of the drive flow mismatch on the LOCA evaluation is similar to a small change in the initial core flow. ((

Me )) the discussion and trends in the M+LTR are applicable to Monticello. [

4-13A

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