RS-13-003, Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - Cycle 15

Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - Cycle 15

ML13018A228
Person / Time
Site:	LaSalle
Issue date:	01/17/2013
From:	Gullott D Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML130180301	List: RS-13-003, Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - Cycle 15
References
RS-13-003
Download: ML13018A228 (20)

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4300 Winfield Road Warrenville, IL 60555 Exelon Generation..:

Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 RS-13-003 10 CFR 50.90 January 17, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 LaSalle County Station, Unit 2 Facility Operating License No. NPF-18 NRC Docket No. 50-374

Subject:

Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - LaSalle County Station, Unit 2, Cycle 15

References:

1)

Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - LaSalle County Station, Unit 2, Cycle 15," dated October 11, 2012 2)

Letter from N. J. DiFrancesco (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "LaSalle County Station, Unit 2 - Request for Additional Information Relating to Technical Specification Changes to Safety Limit Minimum Critical Power Ratio for LaSalle County Station, Unit 2 Cycle 15 (TAC No. ME9769)," dated January 7, 2013 In Reference 1, Exelon Generation Company, LLC, (EGC) requested an amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-18 for LaSalle County Station (LSCS), Unit 2. The proposed change revises the value of the LSCS Unit 2 minimum critical power ratio safety limit (MCPR SL) in TS Section 2.1.1, "Reactor Core SLs."

These changes are required to support the upcoming cycle of operation (i.e., Cycle 15) for LSCS, Unit 2. contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

630 657 2000 Office 1

Exelon Generation 4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 RS-13-003 10 CFR 50.90 January 17,2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 LaSalle County Station, Unit 2 Facility Operating License No. NPF-18 NRC Docket No. 50-374

Subject:

Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - LaSalle County Station, Unit 2, Cycle 15

References:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to u. S. Nuclear Regulatory Commission, "Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - LaSalle County Station, Unit 2, Cycle 15," dated October 11, 2012

2) Letter from N; J. DiFrancesco (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "LaSalle County Station, Unit 2 - Request for Additional Information Relating to Technical Specification Changes to Safety Limit Minimum Critical Power Ratio for LaSalle County Station, Unit 2 Cycle 15 (TAC No. ME9769)," dated January 7,2013 In Reference 1, Exelon Generation Company, LLC, (EGC) requested an amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-18 for LaSalle County Station (LSCS), Unit 2. The proposed change revises the value of the LSCS Unit 2 minimum critical power ratio safety limit (MCPR SL) in TS Section 2.1.1, "Reactor Core SLs."

These changes are required to support the upcoming cycle of operation (Le., Cycle 15) for LSCS, Unit 2. contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

1 Exelon Generation 4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 RS-13-003 10 CFR 50.90 January 17,2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 LaSalle County Station, Unit 2 Facility Operating License No. NPF-18 NRC Docket No. 50-374

Subject:

Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - LaSalle County Station, Unit 2, Cycle 15

References:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to u. S. Nuclear Regulatory Commission, "Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - LaSalle County Station, Unit 2, Cycle 15," dated October 11, 2012

2) Letter from N; J. DiFrancesco (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "LaSalle County Station, Unit 2 - Request for Additional Information Relating to Technical Specification Changes to Safety Limit Minimum Critical Power Ratio for LaSalle County Station, Unit 2 Cycle 15 (TAC No. ME9769)," dated January 7,2013 In Reference 1, Exelon Generation Company, LLC, (EGC) requested an amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-18 for LaSalle County Station (LSCS), Unit 2. The proposed change revises the value of the LSCS Unit 2 minimum critical power ratio safety limit (MCPR SL) in TS Section 2.1.1, "Reactor Core SLs."

These changes are required to support the upcoming cycle of operation (Le., Cycle 15) for LSCS, Unit 2. contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

January 17, 2013 U. S. Nuclear Regulatory Commission Page 2 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 In Reference 2, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC is providing the attached information in response to the request. Specifically, the responses to RAI-01 through RAI-06 are provided in Attachment 1, with supplemental responses to RAI-04 and RAI-06 provided in Attachment 4.

The information in Attachment 1 contains proprietary information as defined by 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." Global Nuclear Fuel (GNF), as the owner of the proprietary information, has executed the enclosed affidavit (Attachment 3), which identifies that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to Exeion Nuclear in a GNF transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the attached RAI responses such that the affidavit remains applicable. GNF hereby requests that the attached proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 10 CFR 9.17.

A Non-Proprietary version of the information contained in Attachment 1 is provided in. The affidavit is provided in Attachment 3.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachments are being provided to the designated State of Illinois official.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815. contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

January 17, 2013 U. S. Nuclear Regulatory Commission Page 2 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 In Reference 2, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC is providing the attached information in response to the request. Specifically, the responses to RAI-01 through RAI-06 are provided in Attachment 1, with supplemental responses to RAI-04 and RAI-06 provided in Attachment 4.

The information in Attachment 1 contains proprietary information as defined by 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." Global Nuclear Fuel (GNF), as the owner of the proprietary information, has executed the enclosed affidavit (Attachment 3), which identifies that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to Exelon Nuclear in a GNF transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the attached RAI responses such that the affidavit remains applicable. GNF hereby requests that the attached proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 10 CFR 9.17.

A Non-Proprietary version of the information contained in Attachment 1 is provided in. The affidavit is provided in Attachment 3.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachments are being provided to the designated State of Illinois official.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815. contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

January 17, 2013 U. S. Nuclear Regulatory Commission Page 2 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 In Reference 2, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed license amendment request. EGC is providing the attached information in response to the request. Specifically, the responses to RAI-01 through RAI-06 are provided in Attachment 1, with supplemental responses to RAI-04 and RAI-06 provided in Attachment 4.

The information in Attachment 1 contains proprietary information as defined by 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." Global Nuclear Fuel (GNF), as the owner of the proprietary information, has executed the enclosed affidavit (Attachment 3), which identifies that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to Exelon Nuclear in a GNF transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the attached RAI responses such that the affidavit remains applicable. GNF hereby requests that the attached proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 10 CFR 9.17.

A Non-Proprietary version of the information contained in Attachment 1 is provided in. The affidavit is provided in Attachment 3.

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachments are being provided to the designated State of Illinois official.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815. contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

January 17, 2013 U. S. Nuclear Regulatory Commission Page 3 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th day of January 2013.

Respectfully, David M. Gullott Manager - Licensing Exelon Generation Company, LLC Attachments:

1) Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit -

LaSalle County Station, Unit 2, Cycle 15 (PROPRIETARY) 2)

Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit -

LaSalle County Station, Unit 2, Cycle 15 (NON-PROPRIETARY)

3) Global Nuclear Fuel Affidavit Supporting Proprietary Nature of Information in Attachment 1 4)

Exelon Generation Company, LLC, Supplemental Responses to RAI-04 and RAI-06 cc:

Illinois Emergency Management Agency - Division of Nuclear Safety contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

January 17, 2013 U. S. Nuclear Regulatory Commission Page 3 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th day of January 2013.

Respectfully, David M. Gullott Manager - Licensing Exelon Generation Company, LLC Attachments:

1) Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit-LaSalle County Station, Unit 2, Cycle 15 (PROPRIETARY)

2) Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit-LaSalle County Station, Unit 2, Cycle 15 (NON-PROPRIETARY)

3) Global Nuclear Fuel Affidavit Supporting Proprietary Nature of Information in Attachment 1

4) Exelon Generation Company, LLC, Supplemental Responses to RAI-04 and RAI-06 cc:

Illinois Emergency Management Agency - Division of Nuclear Safety contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

January 17, 2013 U. S. Nuclear Regulatory Commission Page 3 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th day of January 2013.

Respectfully, David M. Gullott Manager - Licensing Exelon Generation Company, LLC Attachments:

1) Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit-LaSalle County Station, Unit 2, Cycle 15 (PROPRIETARY)

2) Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit-LaSalle County Station, Unit 2, Cycle 15 (NON-PROPRIETARY)

3) Global Nuclear Fuel Affidavit Supporting Proprietary Nature of Information in Attachment 1

4) Exelon Generation Company, LLC, Supplemental Responses to RAI-04 and RAI-06 cc:

Illinois Emergency Management Agency - Division of Nuclear Safety contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit -

LaSalle County Station, Unit 2, Cycle 15 (NON-PROPRIETARY) 9 pages follow Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit -

LaSalle County Station, Unit 2, Cycle 15 (NON-PROPRIETARY) 9 pages follow Response to Request for Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit -

LaSalle County Station, Unit 2, Cycle 15 (NON-PROPRIETARY) 9 pages follow

ENCLOSURE2 CFL-EXN-HA2-13-003-R1 Response to NRC RAls for LaSalle Unit 2 Cycle 15 SLMCPR Submittal Non-Proprietary Information - Class I (Public)

INFORMATION NOTICE This is a non-proprietary version of CFL-EXN-HA2-13-003 Enclosure 1, which has the proprietary information removed. Portions of the document that have been removed are indicated by white space inside an open and closed bracket as shown here ((

1].

ENCLOSURE 2 CFL -EXN-HA2-13-003-R 1 Response to NRC RAls for LaSalle Unit 2 Cycle 15 SLMCPR Submittal Non-Proprietary Information - Class I (Public)

INFORMATION NOTICE This is a non-proprietary version of CFL-EXN-HA2-13-003 Enclosure 1, which has the proprietary information removed. Portions of the document that have been removed are indicated by white space inside an open and closed bracket as shown here ((

)).

ENCLOSURE 2 CFL -EXN-HA2-13-003-R 1 Response to NRC RAls for LaSalle Unit 2 Cycle 15 SLMCPR Submittal Non-Proprietary Information - Class I (Public)

INFORMATION NOTICE This is a non-proprietary version of CFL-EXN-HA2-13-003 Enclosure 1, which has the proprietary information removed. Portions of the document that have been removed are indicated by white space inside an open and closed bracket as shown here ((

)).

Non-Proprietary Information - Class I (Public) to CF L-EXN-HA2-13-003-R 1

RAI-01

In the license amendment request, Attachment 6 Tables, Request for Additional Information (RAI)-01-1, RAI-01-2 and RAI-01-3 provide a core map to show those bundles that experienced the 0.1 boiling transition criterion of limiting cases for single-loop operation (SLO) and two-loop operation (TLO). Please provide: (1) clarification of why the bundle group and bundle type stated in the Figure 1, Attachment 5, is different from those listed in Tables RAI-01-1 and RAI-01-2; (2) a description how the data listed in Tables RAI-01-1 and RAI-01-2 are applied to the final values of the SLMCPR; and (3) the reason why Bundle Group 15 plays such a small role to contribute to 0.1 boiling transition criterion.

GNF Response to RAI-01-1 Per the "GNF Response to RAI-01 Applied to LaSalle 2" in Attachment 6, LL

)) The bundle groups in Tables RAI-01-1 and RAI-01-2 of Attachment 6 use this bundle grouping process rather than the bundle type (IAT) grouping that is used in Figure 1 of Attachment 5.

GNF Response to RAI-01-2 Tables RAI-01-1 and RAI-01-2 show the bundle groups used in GNF's SLMCPR calculation process. The NRSBT is the only direct driver of the SLMCPR from these tables.

Per the "GNF Response to RAI-01 Applied to LaSalle 2" in Attachment 6, bundles with a non-zero value for % Contribution to NRSBT have rods in boiling transition at the SLMCPR point, and thus contribute to the final SLMCPR.

GNF Response to RAI-01-3 At the point in the cycle at which the SLMCPR is limiting, this ATRIUM10 bundle group is relatively high in exposure (--35 GWd/ST, see Table RAI-01-1 in Attachment 6) and thus much less reactive than the low exposure, high power GNF2 bundles around it at this point.

Therefore, this bundle group is less likely to have rods in boiling transition, and has a very low contribution to the final SLMCPR value.

1 of 8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R 1

RAI-01

In the license amendment request, Attachment 6 Tables, Request for Additional Information (RAI)-01-1, RAI-01-2 and RAI-01-3 provide a core map to show those bundles that experienced the 0.1 boiling transition criterion of limiting cases for single-loop operation (SLO) and two-loop operation (TLO). Please provide: (1) clarification of why the bundle group and bundle type stated in the Figure 1, Attachment 5, is different from those listed in Tables RAI-01-1 and RAI-01-2; (2) a description how the data listed in Tables RAI-01-1 and RAI-01-2 are applied to the final values of the SLMCPR; and (3) the reason why Bundle Group 15 plays such a small role to contribute to 0.1 boiling transition criterion.

GNF Response to RAI-01-1 Per the "GNF Response to RAI-01 Applied to LaSalle 2" in Attachment 6, ((

)) The bundle groups in Tables RAI-01-1 and RAI-01-2 of Attachment 6 use this bundle grouping process rather than the bundle type (IAT) grouping that is used in Figure 1 of Attachment 5.

GNF Response to RAI-01-2 Tables RAI-01-1 and RAI-01-2 show the bundle groups used in GNF's SLMCPR calculation process. The NRSBT is the only direct driver of the SLMCPR from these tables.

Per the "GNF Response to RAI-01 Applied to LaSalle 2" in Attachment 6, bundles with a non-zero value for % Contribution to NRSBT have rods in boiling transition at the SLMCPR point, and thus contribute to the final SLMCPR.

GNF Response to RAI-01-3 At the point in the cycle at which the SLMCPR is limiting, this ATRIUM10 bundle group is relatively high in exposure (-35 GWd/ST, see Table RAI-01-1 in Attachment 6) and thus much less reactive than the low exposure, high power GNF2 bundles around it at this point. Therefore, this bundle group is less likely to have rods in boiling transition, and has a very low contribution to the final SLMCPR value.

1 of 8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R 1

RAI-01

In the license amendment request, Attachment 6 Tables, Request for Additional Information (RAI)-01-1, RAI-01-2 and RAI-01-3 provide a core map to show those bundles that experienced the 0.1 boiling transition criterion of limiting cases for single-loop operation (SLO) and two-loop operation (TLO). Please provide: (1) clarification of why the bundle group and bundle type stated in the Figure 1, Attachment 5, is different from those listed in Tables RAI-01-1 and RAI-01-2; (2) a description how the data listed in Tables RAI-01-1 and RAI-01-2 are applied to the final values of the SLMCPR; and (3) the reason why Bundle Group 15 plays such a small role to contribute to 0.1 boiling transition criterion.

GNF Response to RAI-01-1 Per the "GNF Response to RAI-01 Applied to LaSalle 2" in Attachment 6, ((

)) The bundle groups in Tables RAI-01-1 and RAI-01-2 of Attachment 6 use this bundle grouping process rather than the bundle type (IAT) grouping that is used in Figure 1 of Attachment 5.

GNF Response to RAI-01-2 Tables RAI-01-1 and RAI-01-2 show the bundle groups used in GNF's SLMCPR calculation process. The NRSBT is the only direct driver of the SLMCPR from these tables.

Per the "GNF Response to RAI-01 Applied to LaSalle 2" in Attachment 6, bundles with a non-zero value for % Contribution to NRSBT have rods in boiling transition at the SLMCPR point, and thus contribute to the final SLMCPR.

GNF Response to RAI-01-3 At the point in the cycle at which the SLMCPR is limiting, this ATRIUM10 bundle group is relatively high in exposure (-35 GWd/ST, see Table RAI-01-1 in Attachment 6) and thus much less reactive than the low exposure, high power GNF2 bundles around it at this point. Therefore, this bundle group is less likely to have rods in boiling transition, and has a very low contribution to the final SLMCPR value.

1 of 8

Non-Proprietary Information - Class I (Public) to C FL-EXN-HA2-13-003-R 1

RAI-02

Core design is an iterative process designed to develop an optimal configuration that meets operational requirements. Please provide the details of a plant-specific final core loading pattern as shown in Figure 1; including core design procedures, guidelines, criteria, and approved methodologies used for the Cycle 15 analysis with respect to a mixed core application. Also, please provide the rationale that the current LSCS, Unit 2, Cycle 15, core will have an increase of 0.03 and 0.05 SLMCPR value for two recirculation loop operation and SLO, respectively.

GNF Response to RAI-02 Methods used to analyze the core-loading pattern, shown in Figure 1, are in accordance with GESTAR-II. GESTAR-II is the umbrella for all procedures, guidelines, criteria, and methodologies used for this analysis. There is no change in approved methodologies.

This is a SLMCPR Technical Specifications change within approved methodologies.

SLMCPR is not the primary driver in developing the fuel cycle core design. The energy plan, reactivity, and thermal margins are the primary drivers.

In the development of a mixed core, as in the development of a core containing all GNF fuel, the loading pattern is developed collaboratively by GNF and Exelon based on Exelon input. Among the inputs are:

Cycle Energy Requirements - fuel bundle design (nuclear) and loading patterns Thermal Limit Margins Reactivity Margins - minimum shutdown margin, minimum and maximum hot excess reactivity Discharge Exposure Limitations and Other Limits as established by safety analysis Desired Control Rod Patterns - sequences and durations Channel Distortion Minimization The rationale behind the SLMCPR change, apart from the change in the core design, is that GNF's approved SLMCPR calculation methodology was used rather than the previous fuel vendor's methodology.

2 of 8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1

RAI-02

Core design is an iterative process designed to develop an optimal configuration that meets operational requirements. Please provide the details of a plant-specific final core loading pattern as shown in Figure 1; including core design procedures, guidelines, criteria, and approved methodologies used for the Cycle 15 analysis with respect to a mixed core application. Also, please provide the rationale that the current LSCS, Unit 2, Cycle 15, core will have an increase of 0.03 and 0.05 SLMCPR value for two recirculation loop operation and SLO, respectively.

GNF Response to RAI-02 Methods used to analyze the core-loading pattern, shown in Figure 1, are in accordance with GESTAR-II. GESTAR-II is the umbrella for all procedures, guidelines, criteria, and methodologies used for this analysis. There is no change in approved methodologies.

This is a SLMCPR Technical Specifications change within approved methodologies.

SLMCPR is not the primary driver in developing the fuel cycle core design. The energy plan, reactivity, and thermal margins are the primary drivers.

In the development of a mixed core, as in the development of a core containing all GNF fuel, the loading pattern is developed collaboratively by GNF and Exelon based on Exelon input. Among the inputs are:

Cycle Energy Requirements - fuel bundle design (nuclear) and loading patterns Thermal Limit Margins Reactivity Margins - minimum shutdown margin, minimum and maximum hot excess reactivity Discharge Exposure Limitations and Other Limits as established by safety analysis Desired Control Rod Patterns - sequences and durations Channel Distortion Minimization The rationale behind the SLMCPR change, apart from the change in the core design, is that GNF's approved SLMCPR calculation methodology was used rather than the previous fuel vendor's methodology.

20f8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1

RAI-02

Core design is an iterative process designed to develop an optimal configuration that meets operational requirements. Please provide the details of a plant-specific final core loading pattern as shown in Figure 1; including core design procedures, guidelines, criteria, and approved methodologies used for the Cycle 15 analysis with respect to a mixed core application. Also, please provide the rationale that the current LSCS, Unit 2, Cycle 15, core will have an increase of 0.03 and 0.05 SLMCPR value for two recirculation loop operation and SLO, respectively.

GNF Response to RAI-02 Methods used to analyze the core-loading pattern, shown in Figure 1, are in accordance with GESTAR-II. GESTAR-II is the umbrella for all procedures, guidelines, criteria, and methodologies used for this analysis. There is no change in approved methodologies.

This is a SLMCPR Technical Specifications change within approved methodologies.

SLMCPR is not the primary driver in developing the fuel cycle core design. The energy plan, reactivity, and thermal margins are the primary drivers.

In the development of a mixed core, as in the development of a core containing all GNF fuel, the loading pattern is developed collaboratively by GNF and Exelon based on Exelon input. Among the inputs are:

Cycle Energy Requirements - fuel bundle design (nuclear) and loading patterns Thermal Limit Margins Reactivity Margins - minimum shutdown margin, minimum and maximum hot excess reactivity Discharge Exposure Limitations and Other Limits as established by safety analysis Desired Control Rod Patterns - sequences and durations Channel Distortion Minimization The rationale behind the SLMCPR change, apart from the change in the core design, is that GNF's approved SLMCPR calculation methodology was used rather than the previous fuel vendor's methodology.

20f8

Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-RI

RAI-03

Global Nuclear Fuel (GNF2) fuel deviates from traditional 10x10 design through the introduction of a new part length rod configuration, the use of higher linear power, and the use of mixing vanes. The NRC staff considers this to be a new fuel design with regards to the four restrictions identified in the safety evaluation of General Electric Licensing Topical Reports NEDC-32601 P, NEDC-32694, and Amendment 25 to NEDE-24011-P-A. Given that LSCS2, Cycle 15, uses a core loading pattern which includes GNF2 fuel and ATRIUM-10, please provide an evaluation of the applicability of the four restrictions stated in NEDC-32601P, NEDC-32694, and Amendment 25 to NEDE-24011-P-A to ATRIUM-10 fuel since the NRC audit report was only evaluated for GNF-2 notATRIUM-10 fuel.

GNF Response to RAI-03 The four restrictions applied specifically to the mixed core were addressed during the transition from ATRIUM-10 to GNF2 fuel.

These limitations were addressed for ATRIUM-10 as follows:

1)

The TGBLA fuel rod power calculational uncertainty for ATRIUM-10 was verified through extensive comparisons of TGBLA06 and MCNP. Comparisons included lattice k°° values and lattice pin power peaking at numerous exposure, temperature, and control conditions. The comparisons included comparisons to TGBLA06 accuracy for GNF 10x10 fuel designs to demonstrate that TGBLA accuracy had not been degraded for ATRIUM-10 fuel in comparison to the accuracy of our analyses for standard GNF fuel product offerings. This analysis justified the use of the standard TGBLA modeling uncertainties for ATRIUM-10 fuel. GNF then received justification from the customer that standard GNF manufacturing uncertainties were bounding compared to the uncertainties associated with the manufacture of ATRIUM-10 fuel. This information, when combined with uncertainties inherent in GNF methodologies, confirmed that the standard rod power calculational uncertainty defined in NEDC-32601 P-A is applicable to ATRIUM-10 fuel.

2)

The item I rod power calculation uncertainties were used to reevaluate and confirm the R-factor uncertainty for ATRIUM-10. The above uncertainty, combined with uncertainties inherent in GNF methodologies, demonstrated that the R-Factor uncertainty contained in NEDC-32601 P-A is still applicable to ATRIUM-10 fuel.

3)

The applicability of the MIP criterion was previously reevaluated through the inclusion of plants containing ATRIUM-10 fuel in the data contained in Figure 5 of Attachment 5. The following points in the table supplied in the LAR Attachment 6 supplemental response to LS1 RAI-05 contain 3 of 8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1

RAI-03

Global Nuclear Fuel (GNF2) fuel deviates from traditional 1 Ox1 0 design through the introduction of a new part length rod configuration, the use of higher linear power, and the use of mixing vanes. The NRC staff considers this to be a new fuel design with regards to the four restrictions identified in the safety evaluation of General Electric Licensing Topical Reports NEDC-32601P, NEDC-32694, and Amendment 25 to NEDE-24011-P-A. Given that LSCS2, Cycle 15, uses a core loading pattern which includes GNF2 fuel and ATRIUM-10, please provide an evaluation of the applicability of the four restrictions stated in NEDC-32601 P, NEDC-32694, and Amendment 25 to NEDE-24011-P-A to ATRIUM-10 fuel since the NRC audit report was only evaluated for GNF-2 not A TRIUM-1 0 fuel.

GNF Response to RAI*03 The four restrictions applied specifically to the mixed core were addressed during the transition from ATRIUM-10 to GNF2 fuel.

These limitations were addressed for ATRIUM-10 as follows:

1) The TGBLA fuel rod power calculational uncertainty for ATRIUM-10 was verified through extensive comparisons of TGBLA06 and MCNP. Comparisons included lattice koo values and lattice pin power peaking at numerous exposure, temperature, and control conditions. The comparisons included comparisons to TGBLA06 accuracy for GNF 1 Ox1 0 fuel designs to demonstrate that TGBLA accuracy had not been degraded for ATRIUM-10 fuel in comparison to the accuracy of our analyses for standard GNF fuel product offerings. This analysis justified the use of the standard TGBLA modeling uncertainties for ATRIUM-10 fuel. GNF then received justification from the customer that standard GNF manufacturing uncertainties were bounding compared to the uncertainties associated with the manufacture of ATRIUM-10 fuel. This information, when combined with uncertainties inherent in GNF methodologies, confirmed that the standard rod power calculational uncertainty defined in NEDC-32601 P-A is applicable to ATRIUM-10 fuel.

2) The item 1 rod power calculation uncertainties were used to reevaluate and confirm the R-factor uncertainty for ATRIUM-10. The above uncertainty, combined with uncertainties inherent in GNF methodologies, demonstrated that the R-Factor uncertainty contained in NEDC-32601 P-A is still applicable to ATRIUM-10 fuel.

3) The applicability of the MIP criterion was previously reevaluated through the inclusion of plants containing ATRIUM-10 fuel in the data contained in Figure 5 of Attachment S. The following points in the table supp!ied in the LAR Attachment 6 supplemental response to LS1 RAI-OS contain 30f8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1

RAI-03

Global Nuclear Fuel (GNF2) fuel deviates from traditional 1 Ox1 0 design through the introduction of a new part length rod configuration, the use of higher linear power, and the use of mixing vanes. The NRC staff considers this to be a new fuel design with regards to the four restrictions identified in the safety evaluation of General Electric Licensing Topical Reports NEDC-32601P, NEDC-32694, and Amendment 25 to NEDE-24011-P-A. Given that LSCS2, Cycle 15, uses a core loading pattern which includes GNF2 fuel and ATRIUM-10, please provide an evaluation of the applicability of the four restrictions stated in NEDC-32601 P, NEDC-32694, and Amendment 25 to NEDE-24011-P-A to ATRIUM-10 fuel since the NRC audit report was only evaluated for GNF-2 not A TRIUM-1 0 fuel.

GNF Response to RAI*03 The four restrictions applied specifically to the mixed core were addressed during the transition from ATRIUM-10 to GNF2 fuel.

These limitations were addressed for ATRIUM-10 as follows:

1) The TGBLA fuel rod power calculational uncertainty for ATRIUM-10 was verified through extensive comparisons of TGBLA06 and MCNP. Comparisons included lattice koo values and lattice pin power peaking at numerous exposure, temperature, and control conditions. The comparisons included comparisons to TGBLA06 accuracy for GNF 1 Ox1 0 fuel designs to demonstrate that TGBLA accuracy had not been degraded for ATRIUM-10 fuel in comparison to the accuracy of our analyses for standard GNF fuel product offerings. This analysis justified the use of the standard TGBLA modeling uncertainties for ATRIUM-10 fuel. GNF then received justification from the customer that standard GNF manufacturing uncertainties were bounding compared to the uncertainties associated with the manufacture of ATRIUM-10 fuel. This information, when combined with uncertainties inherent in GNF methodologies, confirmed that the standard rod power calculational uncertainty defined in NEDC-32601 P-A is applicable to ATRIUM-10 fuel.

2) The item 1 rod power calculation uncertainties were used to reevaluate and confirm the R-factor uncertainty for ATRIUM-10. The above uncertainty, combined with uncertainties inherent in GNF methodologies, demonstrated that the R-Factor uncertainty contained in NEDC-32601 P-A is still applicable to ATRIUM-10 fuel.

3) The applicability of the MIP criterion was previously reevaluated through the inclusion of plants containing ATRIUM-10 fuel in the data contained in Figure 5 of Attachment S. The following points in the table supp!ied in the LAR Attachment 6 supplemental response to LS1 RAI-OS contain 30f8

Non-Proprietary Information - Class I (Public) to CF L-EXN-HA2-13-003-R 1 ATRIUM-10 fuel: the 1st, 4th, and 5th points. This can be seen from the table as the combined GE14 and GNF2 batch fractions for these points do not add up to 100%; the remaining fuel for these points is ATRIUM-10 fuel.

As can be seen by locating these points on the plot in Figure 5 of Attachment 5, every point is above the MIP correlation, demonstrating the continued generic conservatism of this correlation.

Additionally, Section 2.6 of of the licensing amendment request demonstrates that if the limiting SLMCPR case for LaSalle 2 Cycle 15 were plotted on Figure 5, this point, too, would lie above the MIP correlation line, further demonstrating the conservatism of this correlation for this specific application.

4)

The bundle power uncertainty associated with the core monitoring system was verified by Exelon as applied to ATRIUM-10.

4of8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1 ATRIUM-10 fuel: the 1st, 4th, and 5th points. This can be seen from the table as the combined GE14 and GNF2 batch fractions for these points do not add up to 100%; the remaining fuel for these points is ATRIUM-10 fuel.

As can be seen by locating these points on the plot in Figure 5 of Attachment 5, every point is above the MIP correlation, demonstrating the continued generic conservatism of this correlation.

Additionally, Section 2.6 of of the licensing amendment request demonstrates that if the limiting SLMCPR case for LaSalle 2 Cycle 15 were plotted on Figure 5, this point, too, would lie above the MIP correlation line, further demonstrating the conservatism of this correlation for this specific application.

4) The bundle power uncertainty associated with the core monitoring system was verified by Exelon as applied to ATRIUM-10.

40f8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1 ATRIUM-10 fuel: the 1st, 4th, and 5th points. This can be seen from the table as the combined GE14 and GNF2 batch fractions for these points do not add up to 100%; the remaining fuel for these points is ATRIUM-10 fuel.

As can be seen by locating these points on the plot in Figure 5 of Attachment 5, every point is above the MIP correlation, demonstrating the continued generic conservatism of this correlation.

Additionally, Section 2.6 of of the licensing amendment request demonstrates that if the limiting SLMCPR case for LaSalle 2 Cycle 15 were plotted on Figure 5, this point, too, would lie above the MIP correlation line, further demonstrating the conservatism of this correlation for this specific application.

4) The bundle power uncertainty associated with the core monitoring system was verified by Exelon as applied to ATRIUM-10.

40f8

Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-RI

RAI-04

The LSCS, Unit 2, Cycle 15, is a mixed core with once and twice burned ATRIUM 10 fuel. Please provide: (1) a confirmation that NEDC-33106P, Revision 4, August 2012, was reviewed and approved by the NRC staff; (2) a detailed description of the difference between GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 2, June 2004, and GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 4, August 2012; (3) an analysis on the impact of the SLMCPR value due to the differences identified in Item (2), if any, and (4) the description for the basis and method used to generate nominal uncertainty value for ATRIUMIO and ATRIUMIO-XM given in Table 6.

GNF Response to RAI-04-1 Exelon will provide a response to this RAI.

GNF Response to RAI-04-2 The GEXL97 correlation for ATRIUM10 fuel was developed prior to the filing of the Part 21 report in 2007 by AREVA regarding a defect in the additive constants of the SPCB critical power correlation. In the subsequent years, GNF received revised critical power data for ATRIUM10 fuel from AREVA, and issued a revision to GEXL97 accordingly.

The correlation coefficients and the R-factor additive constants, however, remained unchanged when the correlation was revisited with the revised critical power data from AREVA. The two correlation revisions described in NEDC-33106P-A Revision 2 and 4 are therefore the same with the exception of:

1) Pressure Application Range.

The revised data from AREVA supported an expansion of the pressure range from ((

)).

2) R-factor Application Range Lower Bound.

The revised data from AREVA supported a change for the R-factor range lower bound value from ((

)).

3) ((

))

5 of 8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R 1

RAI-04

The LSCS, Unit 2, Cycle 15, is a mixed core with once and twice burned ATRIUM 10 fuel. Please provide: (1) a confirmation that NEDC-33106P, Revision 4, August 2012, was reviewed and approved by the NRC staff; (2) a detailed description of the difference between GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 2, June 2004, and GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 4, August 2012; (3) an analysis on the impact of the SLMCPR value due to the differences identified in Item (2), if any; and (4) the description for the basis and method used to generate nominal uncertainty value for ATRIUM10 and ATRIUM10-XM given in Table 6.

GNF Response to RAI-04-1 Exelon will provide a response to this RAJ.

GNF Response to RAI-04-2 The GEXL97 correlation for ATRIUM10 fuel was developed prior to the filing of the Part 21 report in 2007 by AREVA regarding a defect in the additive constants of the SPCB critical power correlation. In the subsequent years, GNF received revised critical power data for ATRIUM10 fuel from AREVA, and issued a revision to GEXL97 accordingly.

The correlation coefficients and the R-factor additive constants, however, remained unchanged when the correlation was revisited with the revised critical power data from AREVA. The two correlation revisions described in NEDC-33106P-A Revision 2 and 4 are therefore the same with the exception of:

1) Pressure Application Range.

The revised data from AREVA supported an expansion of the pressure range from ((

)).

2) R-factor Application Range Lower Bound.

The revised data from AREVA supported a change for the R-factor range lower bound value from ((

n*

3) ((

))

50fB Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R 1

RAI-04

The LSCS, Unit 2, Cycle 15, is a mixed core with once and twice burned ATRIUM 10 fuel. Please provide: (1) a confirmation that NEDC-33106P, Revision 4, August 2012, was reviewed and approved by the NRC staff; (2) a detailed description of the difference between GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 2, June 2004, and GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 4, August 2012; (3) an analysis on the impact of the SLMCPR value due to the differences identified in Item (2), if any; and (4) the description for the basis and method used to generate nominal uncertainty value for ATRIUM10 and ATRIUM10-XM given in Table 6.

GNF Response to RAI-04-1 Exelon will provide a response to this RAJ.

GNF Response to RAI-04-2 The GEXL97 correlation for ATRIUM10 fuel was developed prior to the filing of the Part 21 report in 2007 by AREVA regarding a defect in the additive constants of the SPCB critical power correlation. In the subsequent years, GNF received revised critical power data for ATRIUM10 fuel from AREVA, and issued a revision to GEXL97 accordingly.

The correlation coefficients and the R-factor additive constants, however, remained unchanged when the correlation was revisited with the revised critical power data from AREVA. The two correlation revisions described in NEDC-33106P-A Revision 2 and 4 are therefore the same with the exception of:

1) Pressure Application Range.

The revised data from AREVA supported an expansion of the pressure range from ((

)).

2) R-factor Application Range Lower Bound.

The revised data from AREVA supported a change for the R-factor range lower bound value from ((

n*

3) ((

))

50fB

Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1

4) Correlation Uncertainty. The correlation uncertainty was revised from

((

)).

GNF Response to RAI-04-3 Per the response to RAI-04-2, the correlation coefficients and R-factor additive constants remain the same between each version of the correlation. Therefore the two versions of GEXL97 will predict essentially the same critical power for any given ATRIUMIO fuel in Cycle 15. The only difference between the two correlations that will affect the SLMCPR is therefore the correlation uncertainty revision. As the ATRIUM-10 fuel has only a minor ((

)) contribution to the limiting SLMCPR, the effect of the change in correlation on the final SLMCPR is expected to be relatively small.

GNF Response to RAI-04-4 Revision 4 of the GEXL97 correlation used the same basis and method to generate the nominal uncertainty for the correlation as was used for Revision 2 of the correlation.

The description for the basis and method used to generate the nominal uncertainty value is found in Section 5 of the approved LTR NEDC 33106P-A Revision 2.

6of8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R 1

4) Correlation Uncertainty. The correlation uncertainty was revised from

((

n*

GNF Response to RAI-04-3 Per the response to RAI-04-2, the correlation coefficients and R-factor additive constants remain the same between each version of the correlation. Therefore the two versions of GEXL97 will predict essentially the same critical power for any given ATRIUM10 fuel in Cycle 15. The only difference between the two correlations that will affect the SLMCPR is therefore the correlation uncertainty revision. As the ATRIUM-10 fuel has only a minor ((

J] contribution to the limiting SLMCPR, the effect of the change in correlation on the final SLMCPR is expected to be relatively small.

GNF Response to RAI-04-4 Revision 4 of the GEXL97 correlation used the same basis and method to generate the nominal uncertainty for the correlation as was used for Revision 2 of the correlation.

The description for the basis and method used to generate the nominal uncertainty value is found in Section 5 of the approved LTR NEDC 33106P-A Revision 2.

6 of 8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R 1

4) Correlation Uncertainty. The correlation uncertainty was revised from

((

n*

GNF Response to RAI-04-3 Per the response to RAI-04-2, the correlation coefficients and R-factor additive constants remain the same between each version of the correlation. Therefore the two versions of GEXL97 will predict essentially the same critical power for any given ATRIUM10 fuel in Cycle 15. The only difference between the two correlations that will affect the SLMCPR is therefore the correlation uncertainty revision. As the ATRIUM-10 fuel has only a minor ((

J] contribution to the limiting SLMCPR, the effect of the change in correlation on the final SLMCPR is expected to be relatively small.

GNF Response to RAI-04-4 Revision 4 of the GEXL97 correlation used the same basis and method to generate the nominal uncertainty for the correlation as was used for Revision 2 of the correlation.

The description for the basis and method used to generate the nominal uncertainty value is found in Section 5 of the approved LTR NEDC 33106P-A Revision 2.

6 of 8

Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1

RAI-05

Please describe the effect, if any, of a bent spacer wing on GNF2 fuel for LSCS, Unit 2, Cycle 15, operation. If there is an effect, please provide the details of the effect on thermal performance due to GNF2 bent spacer wing.

GNF Response to RAI-05 GNF2 bent spacer wing related Part 21 issues are not applicable to LaSalle Unit 2 Cycle 15 because the GNF2 fuel in this cycle is not impacted by the Part 21 issue, as indicated in Section 2.13 of Attachment 5 of the LAR. Therefore this issue has no effect on the GNF2 fuel in LaSalle Unit 2 Cycle 15.

7 of 8 Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1

RAI-05

Please describe the effect, if any, of a bent spacer wing on GNF2 fuel for LSCS, Unit 2, Cycle 15, operation. If there is an effect, please provide the details of the effect on thermal performance due to GNF2 bent spacer wing.

GNF Response to RAI-05 GNF2 bent spacer wing related Part 21 issues are not applicable to LaSalle Unit 2 Cycle 15 because the GNF2 fuel in this cycle is not impacted by the Part 21 issue, as indicated in Section 2.13 of Attachment 5 of the LAR. Therefore this issue has no effect on the GNF2 fuel in LaSalle Unit 2 Cycle 15.

70fB Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1

RAI-05

Please describe the effect, if any, of a bent spacer wing on GNF2 fuel for LSCS, Unit 2, Cycle 15, operation. If there is an effect, please provide the details of the effect on thermal performance due to GNF2 bent spacer wing.

GNF Response to RAI-05 GNF2 bent spacer wing related Part 21 issues are not applicable to LaSalle Unit 2 Cycle 15 because the GNF2 fuel in this cycle is not impacted by the Part 21 issue, as indicated in Section 2.13 of Attachment 5 of the LAR. Therefore this issue has no effect on the GNF2 fuel in LaSalle Unit 2 Cycle 15.

70fB

Non-Proprietary Information - Class I (Public) to CFL-EXN-HA2-13-003-R1 RAI-06 provides an updated version of power/flow map for Cycle 15 operation, including stability Option Ill features of scram region and controlled entry region for backup stability protection based on the Boiling Water Rector Owners Group position stated in NEDO-31960A for SLO and TLO. Please provide: (1) the decay ratio boundary for Region 2; (2) an explanation why Region 2 covers a very small area in the power/flow map; and (3) any operator actions needed for Region 2.

GNF Response to RAI-06 The stability regions have no impact on the SLMCPR. Exelon will provide an additional response to this RAI.

8 of 8 Non-Proprietary Information - Class I (Public) to CFL -EXN-HA2-13-003-R 1 RAI-06 provides an updated version of power/flow map for Cycle 15 operation, including stability Option 11/ features of scram region and controlled entry region for backup stability protection based on the Boiling Water Rector Owners Group position stated in NEDO-31960A for SLO and TLO. Please provide: (1) the decay ratio boundary for Region 2; (2) an explanation why Region 2 covers a very small area in the powerlflow map; and (3) any operator actions needed for Region 2.

GNF Response to RAI-06 The stability regions have no impact on the SLMCPR. Exelon will provide an additional response to this RAI.

80f8 Non-Proprietary Information - Class I (Public) to CFL -EXN-HA2-13-003-R 1 RAI-06 provides an updated version of power/flow map for Cycle 15 operation, including stability Option 11/ features of scram region and controlled entry region for backup stability protection based on the Boiling Water Rector Owners Group position stated in NEDO-31960A for SLO and TLO. Please provide: (1) the decay ratio boundary for Region 2; (2) an explanation why Region 2 covers a very small area in the powerlflow map; and (3) any operator actions needed for Region 2.

GNF Response to RAI-06 The stability regions have no impact on the SLMCPR. Exelon will provide an additional response to this RAI.

80f8 Global Nuclear Fuel Affidavit Supporting Proprietary Nature of Information in Attachment 1 3 pages follow Global Nuclear Fuel Affidavit Supporting Proprietary Nature of Information in Attachment 1 3 pages follow Global Nuclear Fuel Affidavit Supporting Proprietary Nature of Information in Attachment 1 3 pages follow

Global Nuclear Fuel - Americas AFFIDAVIT

, Lukas Trosman, state as follows:

(1)

I am Engineering Manager, Reload Design and Analysis, Global Nuclear Fuel -

Americas, LLC (GNF-A), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2)

The information sought to be withheld is contained in Enclosure 1 of GNF's letter, CFL-EXN-HA2-13-003-RI, C. Lamb (GNF-A) to J. Fisher (Exelon), entitled "GNF Response to NRC RAIs for LaSalle Unit 2 Cycle 15 SLMCPR Submittal," January 16, 2013.

GNF-A proprietary information in Enclosure 1, which is entitled "Response to NRC RAIs for LaSalle Unit 2 Cycle 15 SLMCPR Submittal," is identified by a dotted underline inside double square brackets. ((`is_seltence_zsean exarnple__'e))

Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation tai refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3)

In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4).

The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Re ul g atory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4)

Some examples of categories of information which fit into the definition of proprietary information are:

a.

Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies; b.

Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; c.

Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A; d.

Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

CFL-EXN-HA2-13-003-RI Affidavit Page 1 of 3 Global Nuclear Fuel-Americas AFFIDAVIT I, Lukas Trosman, state as follows:

(1) I am Engineering Manager, Reload Design and Analysis, Global Nuclear Fuel -

Americas, LLC (GNF-A), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GNF's letter, CFL-EXN-HA2-13-003-Rl, C. Lamb (GNF-A) to J. Fisher (Exelon), entitled "GNF Response to NRC RAls for LaSalle Unit 2 Cycle 15 SLMCPR Submittal," January 16, 2013. GNF-A proprietary information in Enclosure 1, which is entitled "Response to NRC RAIs for LaSalle Unit 2 Cycle 15 SLMCPR Submittal," is identified b~ a dotted underline inside double square brackets.

((Ihi§.~.~nJ~n£xj~.!m.~~~.p.lx,~.!.))

Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation {3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF -A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a.

Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b.

Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c.

Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;

d.

Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

CFL-EXN-HA2-13-003-Rl Affidavit Page 1 of 3 Global Nuclear Fuel-Americas AFFIDAVIT I, Lukas Trosman, state as follows:

(1) I am Engineering Manager, Reload Design and Analysis, Global Nuclear Fuel -

Americas, LLC (GNF-A), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GNF's letter, CFL-EXN-HA2-13-003-Rl, C. Lamb (GNF-A) to J. Fisher (Exelon), entitled "GNF Response to NRC RAls for LaSalle Unit 2 Cycle 15 SLMCPR Submittal," January 16, 2013. GNF-A proprietary information in Enclosure 1, which is entitled "Response to NRC RAIs for LaSalle Unit 2 Cycle 15 SLMCPR Submittal," is identified b~ a dotted underline inside double square brackets.

((Ihi§.~.~nJ~n£xj~.!m.~~~.p.lx,~.!.))

Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation {3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF -A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a.

Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b.

Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c.

Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;

d.

Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

CFL-EXN-HA2-13-003-Rl Affidavit Page 1 of 3

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5)

To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6)

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

Access to such documents within GNF-A is limited on a "need to know" basis.

(7)

The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.

Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8)

The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.

The development of this methodology, along with the testing, development and approval was achieved at a significant cost to GNF-A.

The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNF-A asset.

(9)

Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities.

The information is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation CFL-EXN-HA2-13-003-R1 Affidavit Page 2 of 3 The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. The infonnation sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietmy treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF -A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.

The development of this methodology, along with the testing, development and approval was achieved at a significant cost to GNF -A.

The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNF-A asset.

(9) Public disclosure of the infonnation sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF-Ns 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 detennine and apply the appropriate evaluation CFL-EXN-HA2-13-003-Rl Affidavit Page 2 of 3 The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. The infonnation sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietmy treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF -A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.

The development of this methodology, along with the testing, development and approval was achieved at a significant cost to GNF -A.

The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNF-A asset.

(9) Public disclosure of the infonnation sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF-Ns 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 detennine and apply the appropriate evaluation CFL-EXN-HA2-13-003-Rl Affidavit Page 2 of 3

process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GNF-A would be lost if the information were disclosed to the public.

Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

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

Executed on this 16th day of January 2013.

as Trosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel-Americas, LLC CFL-EXN-HA2-13-003-R1 Affidavit Page 3 of 3 process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this infonnation to GNF-A would be lost if the infonnation 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 COlTect to the best of my knowledge, information, and belief.

Executed on this 16th day of January 2013.

CFL-EXN-HA2-13-003-RI as Trosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel-Americas, LLC Affidavit Page 3 of 3 process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this infonnation to GNF-A would be lost if the infonnation 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 COlTect to the best of my knowledge, information, and belief.

Executed on this 16th day of January 2013.

CFL-EXN-HA2-13-003-RI as Trosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel-Americas, LLC Affidavit Page 3 of 3 Exelon Generation Company, LLC, Supplemental Responses to RAI-04 and RAI-06 2 pages follow Exelon Generation Company, LLC, Supplemental Responses to RAI-04 and RAI-06 2 pages follow Exelon Generation Company, LLC, Supplemental Responses to RAI-04 and RAI-06 2 pages follow

RAI-04

The LSCS, Unit 2, Cycle 15, is a mixed core with once and twice burned ATRIUM 10 fuel.

Please provide: (1) a confirmation that NEDC-33106P, Revision 4, August 2012, was reviewed and approved by the NRC staff; (2) a detailed description of the difference between GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 2, June 2004 and GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 4, August 2012; (3) an analysis on the impact of the SLMCPR value due to the differences identified in Item (2), if any; and (4) the description for the basis and method used to generate nominal uncertainty value for ATRIUM10 and ATRIUM10-XM given in Table 6.

EGC Response to RAI-04-1:

The same GEXL97 correlation that is proposed to be applied at LaSalle County Station (LSCS) was reviewed by the NRC and approved for use at Columbia Generating Station (Reference 1).

The proposed calculations will apply the same methodology in total at LSCS with the same terms, conditions, and limitations documented in the NRC SE for the methodology at Columbia.

The use of NEDC-33106P, Revision 4, has been evaluated by EGC under 10 CFR 50.59 for use at LSCS and concluded prior NRC review and approval specific to LSCS is not required.

RAI-06: provides an updated version of power/flow map for Cycle 15 operation, including stability Option III features of scram region and controlled entry region for backup stability protection based on the Boiling Water Reactor Owners Group position stated in NEDO-31960A for SLO and TLO. Please provide: (1) decay ratio boundary for Region 2; (2) an explanation why Region 2 covers a very small area in the power/flow map; and (3) any operator actions needed for Region 2.

EGC Response to RAI-06-1:

The backup stability protection (BSP) Region 2 boundary represents the more conservative of either a) a constant decay ratio of 0.8 or b) a boundary defined by the original Interim Corrective Action (ICA) region endpoints. The process/procedure applied to determine the BSP regions is described in the Reference 2 document. For LSCS Unit 2 Cycle 15, the BSP Region 2 boundary is based on the original ICA region endpoints. However, the BSP regions depicted on the power/flow map in Attachment 9 are based on a previous cycle and bound the LSCS Unit 2 Cycle 15 results. These bounding BSP regions will be maintained on the power/flow map for Unit 2 Cycle 15 operation.

EGC Response to RAI-06-2:

The BSP Region 1 and Region 2 boundaries depicted on the LSCS power/flow map are based on reduced feedwater temperature conditions (e.g., final feedwater temperature reduction - FFWTR). BSP regions are also determined for normal feedwater temperature operation - these regions are generally smaller than the reduced feedwater temperature

RAI-04

The LSCS, Unit 2, Cycle 15, is a mixed core with once and twice burned ATRIUM 10 fuel.

Please provide: (1) a confirmation that NEDC-33106P, Revision 4, August 2012, was reviewed and approved by the NRC staff; (2) a detailed description of the difference between GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 2, June 2004 and GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 4, August 2012; (3) an analysis on the impact of the SLMCPR value due to the differences identified in Item (2), if any; and (4) the description for the basis and method used to generate nominal uncertainty value for ATRIUM10 and ATRIUM10-XM given in Table 6.

EGC Response to RAI-04-1:

The same GEXL97 correlation that is proposed to be applied at LaSalle County Station (LSCS) was reviewed by the NRC and approved for use at Columbia Generating Station (Reference 1).

The proposed calculations will apply the same methodology in total at LSCS with the same terms, conditions, and limitations documented in the NRC SE for the methodology at Columbia.

The use of NEDC-33106P, Revision 4, has been evaluated by EGC under 10 CFR 50.59 for use at LSCS and concluded prior NRC review and approval specific to LSCS is not required.

RAI-06: provides an updated version of powerlflow map for Cycle 15 operation, including stability Option III features of scram region and controlled entry region for backup stability protection based on the Boiling Water Reactor Owners Group position stated in NEDO-31960A for SLO and TLO. Please provide: (1) decay ratio boundary for Region 2; (2) an explanation why Region 2 covers a very small area in the power/flow map; and (3) any operator actions needed for Region 2.

EGC Response to RAI-06-1:

The backup stability protection (BSP) Region 2 boundary represents the more conservative of either a) a constant decay ratio of 0.8 or b) a boundary defined by the original Interim Corrective Action (lCA) region endpoints. The process/procedure applied to determine the BSP regions is described in the Reference 2 document. For LSCS Unit 2 Cycle 15, the BSP Region 2 boundary is based on the originallCA region endpoints. However, the BSP regions depicted on the powerlflow map in Attachment 9 are based on a previous cycle and bound the LSCS Unit 2 Cycle 15 results. These bounding BSP regions will be maintained on the power/flow map for Unit 2 Cycle 15 operation.

EGC Response to RAI-06-2:

The BSP Region 1 and Region 2 boundaries depicted on the LSCS power/flow map are based on reduced feedwater temperature conditions (e.g., final feedwater temperature reduction - FFWTR). BSP regions are also determined for normal feedwater temperature operation - these regions are generally smaller than the reduced feedwater temperature

RAI-04

The LSCS, Unit 2, Cycle 15, is a mixed core with once and twice burned ATRIUM 10 fuel.

Please provide: (1) a confirmation that NEDC-33106P, Revision 4, August 2012, was reviewed and approved by the NRC staff; (2) a detailed description of the difference between GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 2, June 2004 and GEXL97 Correlation for ATRIUM-10 Fuel, NEDC-33106P-A, Revision 4, August 2012; (3) an analysis on the impact of the SLMCPR value due to the differences identified in Item (2), if any; and (4) the description for the basis and method used to generate nominal uncertainty value for ATRIUM10 and ATRIUM10-XM given in Table 6.

EGC Response to RAI-04-1:

The same GEXL97 correlation that is proposed to be applied at LaSalle County Station (LSCS) was reviewed by the NRC and approved for use at Columbia Generating Station (Reference 1).

The proposed calculations will apply the same methodology in total at LSCS with the same terms, conditions, and limitations documented in the NRC SE for the methodology at Columbia.

The use of NEDC-33106P, Revision 4, has been evaluated by EGC under 10 CFR 50.59 for use at LSCS and concluded prior NRC review and approval specific to LSCS is not required.

RAI-06: provides an updated version of powerlflow map for Cycle 15 operation, including stability Option III features of scram region and controlled entry region for backup stability protection based on the Boiling Water Reactor Owners Group position stated in NEDO-31960A for SLO and TLO. Please provide: (1) decay ratio boundary for Region 2; (2) an explanation why Region 2 covers a very small area in the power/flow map; and (3) any operator actions needed for Region 2.

EGC Response to RAI-06-1:

The backup stability protection (BSP) Region 2 boundary represents the more conservative of either a) a constant decay ratio of 0.8 or b) a boundary defined by the original Interim Corrective Action (lCA) region endpoints. The process/procedure applied to determine the BSP regions is described in the Reference 2 document. For LSCS Unit 2 Cycle 15, the BSP Region 2 boundary is based on the originallCA region endpoints. However, the BSP regions depicted on the powerlflow map in Attachment 9 are based on a previous cycle and bound the LSCS Unit 2 Cycle 15 results. These bounding BSP regions will be maintained on the power/flow map for Unit 2 Cycle 15 operation.

EGC Response to RAI-06-2:

The BSP Region 1 and Region 2 boundaries depicted on the LSCS power/flow map are based on reduced feedwater temperature conditions (e.g., final feedwater temperature reduction - FFWTR). BSP regions are also determined for normal feedwater temperature operation - these regions are generally smaller than the reduced feedwater temperature regions. To simplify station procedures, LSCS has chosen to conservatively implement only the reduced feedwater temperature regions which bound normal temperature operation. At reduced feedwater temperature conditions, the BSP calculations result in less separation between the Region 1 and Region 2 boundaries than at the normal feedwater temperature.

EGG Response to RAI-06-3:

LSCS conservatively treats BSP Region 2 as an immediate exit region. In accordance with station procedures, entry into this region requires immediate action by the operators to exit the region utilizing control rod insertion (to reduce power) or a slight flow increase as appropriate.

References:

1)

Letter from C. F. Lyon (U. S. Nuclear Regulatory Commission) to J. V. Parrish (Energy Northwest), "Columbia Generating Station - Issuance of Amendment Re:

Core Operating Limits Report and Scram Time Testing (TAC. No. MD9247)," dated May 5, 2009 2)

GENE Letter OG 02-0119-260, "Backup Stability Protection (BSP) for Inoperable Option III Solution," dated July 17, 2002 regions. To simplify station procedures, LSCS has chosen to conservatively implement only the reduced feedwater temperature regions which bound normal temperature operation. At reduced feedwater temperature conditions, the BSP calculations result in less separation between the Region 1 and Region 2 boundaries than at the normal feedwater temperature.

EGC Response to RAI-06-3:

LSCS conservatively treats BSP Region 2 as an immediate exit region. In accordance with station procedures, entry into this region requires immediate action by the operators to exit the region utilizing control rod insertion (to reduce power) or a slight flow increase as appropriate.

References:

1)

Letter from C. F. Lyon (U. S. Nuclear Regulatory Commission) to J. V. Parrish (Energy Northwest), "Columbia Generating Station - Issuance of Amendment Re:

Core Operating Limits Report and Scram Time Testing (TAC. No. MD9247)," dated May 5,2009

2)

GENE Letter OG 02-0119-260, "Backup Stability Protection (BSP) for Inoperable Option III Solution," dated July 17, 2002 regions. To simplify station procedures, LSCS has chosen to conservatively implement only the reduced feedwater temperature regions which bound normal temperature operation. At reduced feedwater temperature conditions, the BSP calculations result in less separation between the Region 1 and Region 2 boundaries than at the normal feedwater temperature.

EGC Response to RAI-06-3:

LSCS conservatively treats BSP Region 2 as an immediate exit region. In accordance with station procedures, entry into this region requires immediate action by the operators to exit the region utilizing control rod insertion (to reduce power) or a slight flow increase as appropriate.

References:

1)

Letter from C. F. Lyon (U. S. Nuclear Regulatory Commission) to J. V. Parrish (Energy Northwest), "Columbia Generating Station - Issuance of Amendment Re:

Core Operating Limits Report and Scram Time Testing (TAC. No. MD9247)," dated May 5,2009

2)

GENE Letter OG 02-0119-260, "Backup Stability Protection (BSP) for Inoperable Option III Solution," dated July 17, 2002