ML20138G323

Application for Amends to Licenses DPR-29 & DPR-30, Permitting Loading of ATRIUM-9B Fuel in Plant Unit 2 Core for Operational Modes 3,4 & 5

ML20138G323
Person / Time
Site:	Quad Cities
Issue date:	04/29/1997
From:	Kraft E COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20138G326	List: ML20138G323 ML20138G332
References
ESK-97-093, ESK-97-93, NUDOCS 9705060263
Download: ML20138G323 (7)

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• Cordou.11. 612 i19' to Tel309 u r22in ESK-97-093 April 29,1997 United States Nuclear Regulatory Commission Washington, D. C. 20555-0001 Attention: Document Control Desk

Subject:

Quad Cities Nuclear Power Station Units I and 2 Emergency Applicatiun for Amendment to Facility Operating Licenses Pursuant to 10CFR50.91 DPR-29 and DPR-30 Operation with ATRIUM-9B Fuelin Modes 3,4 and 5 Docket Nos. 50-254 and 50-265

References:

(a) E. S. Kraft letter to USNRC dated June 10,1996, Proposed Technical Specification Changes for Siemens Power Corporation (SPC) Fuel Transition i as Supplemented by E. S. Kraft letter to USNRC dated February 17,1997. l (b) J. Hosmer letter to USNRC dated July 2,1996, Transmitting topical report, j

" Application of the ANFB Critical Power Correlation to Coresident GE Fuct for Quad Cities Unit 2 Cycle 15, EMF-96-051(P)." ,

I (c) E. S. Krall letter to USNRC dated April 21,1997, Exigent Technical i Specification Change to Revise Minimum Critical Power Ratio Safety Limit for Quad Cities Cycle 15.

(d) "ANFB Critical Power Correlation Uncertainty For Limited Data Sets",

ANF-1125(P), Supplement 1, Appendix D, Siemens Power Corporation -

Nuclear Division, Submitted April 18,1997.

(c) Advanced Nuclear Fuels Methodology for Boiling Water Rt: actors, XN-NF-80-19 (P) (A), Volume 1, Supplement 3, Supplement 3 Appendix F, and Supplement 4, Advanced Nuclear Fuels Corporation, November 1990.

(f) Commonwealth Ediscn Topical Report NFSR-0091, " Benchmark of CASMO/MICROBURN BWR Nuclear Design Methods", Revision 0, ,

Supplements 1 and 2, December 1991, March 1992, and May 1992, respectively; SER letter dated March 22,1993.

(g) Generic Mechanical Design Criteria for BWR Fuel Designs, ANF-89-98(P)(A) Revision 1, and Revision 1 Supplement 1, Advanced Nuclear Fuels Corporation, May 1995.

(h) Advanced Nuclear Fuels Corporation Generic Mechanical Design for Advanced Nuclear Fuels 9X9-IX and 9X9-9X BWR Reload Fucl, ANF-89-014(P)(A), Revision I and Supplements I and 2, Advanced Nuclear /

f] ] -] () ~7 0 Fuels Corporation, October 1991.

9705060263 970429

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ESK-97-093 USNRC Page 2 April 29,1997 Pursuant to 10CFR$0.90, Comed proposes to amend Facility Operating Licenses DPR-29 and DPR-30

- to permit the loading of ATRIUM-9B fuel in the Quad Cities Unit 2 core for Operational Modes 3,4 and 5 (Hot Shutdown, Cold Shutdown, and Refueling respectively). Operation in Modes 3,4 and 5 will support refueling activities such as fuel load, vessel re-assembly, single rod timing and hydrostatic testing while maintaining the Unit 2 reactor in a suberitical condition. The proposed changes rely solely on existing NRC approved codes and methodolegies and entail modifications to Section 5.0, Design Features, and Section 6.9, Reporting Requirements, of the Technical Specifications. The proposed amendment described herein is interim. Upon approval of the Reference (a) and Reference (c) submittals, the interim changes proposed herein will be superseded.

On June 10,1996, Comed submitted to the Staff proposed Technical Specification changes (Reference t (a)) to support the transition to Siemens ATRIUM-9B fuel. The proposed Technical Specification  ;

changes were preparatory in nature by adding Siemens terminology and applicable methodologies. On l July 2,1996, Comed submitted to the Staff the Reference (b) topical report that described the procedure  !

for applying the Siemens ANFB critical power correlation to the coresident GE fuel.

)

During an NRC vendor audit in March 1997, the Staff concluded that Siemens could not support the uncertainty values used in the application of the ANFB critical power correlation to the ATRIUM-9B fuel design. In response to this issue, Siemens submitted a topical report (Reference (d)) to address the specific concerns raised by the NRC. To support Quad Cities Unit 2 return to operation while the Reference (d) topical report is under NRC review, Comed submitted in Reference (c) a resised MCPR Safety Limit for Quad Cities Unit 2 Cycle 15 that is based on an interim doubling of the increase in uncertainties presented in Reference (d). This approach was discussed in a meeting with the NRC, q Comed and Siemens on April 3,1997.

Issues related to the uncertainties in the ANFB correlation for critical power monitoring of the SPC and GE fuel are under review by the NRC and have caused an unanticipated delay in completing the requested approvals of Reference (a) and Reference (b). Resolution of these issues is being aggressively pursued, and upon such resolution, approval to use ATRIUM-9B fuel is expected. However, to support the schedule to return Unit 2 to senice, Comed is requesting a Technical Specification amendment to allow the loading of ATRIUM-9B fuel in the reactor core for Operational Modes 3,4, and 5. The following outlines Comed's proposed license amendment request.

Attachment A prmides the description and evaluation of the proposed changes to Facility Operating Licenses DPR 29 and DPR-30 for Quad Cities Unit I and Unit 2 and the basis for an emergency approval.

Attachment B provides revised Technical Specification pages.

Attachment C prmides the Evaluation of No Significant Sazards Consideration.

Pursuant to 10CFR50.91(a)(5) Comed requests emergency approvd of this amendment to support the return to senice of Quad Cities Unit 2. Approval of this amendmmt on an emergency basis is warranted because the current situation satisfies the Commission's Cefinition of emerpacy: Failure to act in a timely way would result in the prevention of resumption of oxration [10CFR50.91(a)(5)].

Comed's request for an Emergency License amendment has resulted from an unanticipated delay in the resiew and approval of the Reference (a) and (b) submittals. Any dehy in beginning fuel reload is expected to result in a commensurate delay in the return to senice of Quad Cities Unit 2. Currently, fuel load is scheduled to begin on May 2,1997.

ESK-97-093 USNRC Page 3 April 29,1997 The circumstances have resulted from issues raised during NRC vendor inspection activities. Afler learning of the issues in March 1997, Comed reasonably assumed the issues would be resolved sufliciently to allow the Staff to approve References (a) and (b) prior to fuel load. Therefore, this situation could not have been avoided by Quad Cities. Comed believes that the circumstances described l above meet the criteria of 10CFR50.91(a)(5) for review and approval on an emergency basis. Comed j requests that the proposed Technical Specifications be approved by May 2,1997. j 1

The information provided herein has been onsite and offsite reviewed in accordance with Company procedures and policies.  ;

l To the best of my knowledge and belief, the statements contained above are true and correct. In some l respect these statements are not based on my personal knowledge, but obtained information furnished by l

other Comed employees, contractor employees, and consultants. Such information has been resiewed in accordance with company practice, and I believe it to be reliable.

, Comed is notifying the State ofIllinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated state official.

, if you have any questions concerning this letter, please contact Chuck Peterson, Regulatoiy Affairs

Manager, at (309) 654-2241, extension 3609.

Respectfully, l

t i

- A 00 '

E. 8. Kraft, Jr.

Site Vice President Quad Cities Station Subscribed and Sworn to before me on this .29 day of "OFFCIAL SEAL" AAe/d ' 1997- EU NetwyPutsc,StWe ofIgnois

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MrCommheten EWee t11tarmOO Notary Public Attachments: A - Description and Evaluation of the Proposed Changes B - Revised Technical Specification Pages C - Evaluation of No Significant Hazards cc: A. B. Beach, Regional Administrator, Region 111 R. M. Pulsifer, Project Manager, NRR C. G. Miller, Senior Resident inspector, Quad Cities W. D. Leech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center Oflice of Nuclear Facility Safety, IDNS

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, i ATTACllMENT A DESCRIPTION AND EVALUATION OF TIIE PROPOSED CIIANGES Background for the Need for a License Amendment 3 Quad Citics Unit 2, Cycle 15, will utilize the advanced design Siemens Power Corporation (SPC) ATRIUM-9B fuel. The I ATRIUM-9B fuel design is a 9x9 matrix with 72 fuel rods and a water box. The mechardeal design has been analyzed according to SPC's NRC approved generic mechanical design criteria (References (g) and (h)).

Pursuant to 10CFR50.90, Comed proposes to amend Facility Operating Licenses DPR-29 and DPR-30 to permit the loading of ATRIUM-9B fuel in the Quad Citics Unit 2 core for Operational Modes 3,4 and 5 (Hot Shutdown, Cold Shutdown, and Refueling respectively). The proposed changes rely solely on existing NRC approved codes and

methodologies and entail modifications to Section 5.0, Design Features and Section 6.9, Reporting Requirements, of the Technical Specifications. The proposed amendment described herein is interim. Upon approval of the Reference (a) and (c) submittals, the interim changes proposed herein will be superseded. t 4

On June 10,1996, Comed submitted to the Statiproposed Technical Specifications changes (Reference (a)) to suppori the

transition to Siemens ATRIUM-9B fuel. The proposed Technical Specification changes were preparatory in nature in that j they added Siemens terminology and applicable methodologies. On July 2,1996, Comed submitted to the StafT the Reference (b) topical report that described the procedure for applying the Siemens ANFB critical power correlation to the coresident GE fuel. ,,

During an NRC vendor audit in early 1997, the Staff concluded that Siemens could not support the uncertainty values used in the application of the ANFB critical power correlation to the ATRIUM-9B fuel design. In response to this issue, Siemens submitted a topical report (Reference (d)) to address the specific concerns raised by the NRC. In order to support Quad Cities Unit 2 operation while the . Reference (d) topical report is under NRC resiew, Comed submitted in Reference (c) a j 2

resised MCPR Safety Limit for Quad 2 Cycle 15 that is based on an interim doubling of the increased uncertainties  :

presented in Reference (d). This approach was discussed in a meeting with the NRC, Comed and Siemens on April 3, )

i 1997.

Issues related to the analytical basis for the use of ATRIUM-9B fuel are under review by the NRC and have caused an unanticipated delay in , eDicting thqcquested approvals of Reference (a) and Reference (b). Resolution of these issues is 1 i being aggressively pmmed, and upon such resolution, approval to use ATRIUM-9B fuel is expected. However, to support I the Unit 2 return to service on schedule, Comed is requesting a Technical Specification amendment to allow the loading of ATRIUM-9B fuel in the reactor core for Operational Modes 3,4, and 5. The following outlines Comed's proposed license amendment request.

i

Basis for Emernency Amendment Pursuant to 10CFR50.91(a)(5) Comed requests emergency approval of this amendment to support the return to senice of

Quad Cities Unit 2. Approval of this amendment on an emergency basis is warranted because the current situation satisfies

the Commission's definition of emergency

Failure to act in a timely way would result in the prevention of resumption of 2

operation [10CFR50.91(a)(5)]. Comed's request for an Emergency License auendment has resulted from an unanticipated delay in the resiew and approval of the Reference (a) and (b) submittals. Any delay in beginning fuel reload is expected to result in a commensurate delay in the return to senice of Quad Cities Unit 2 operation. Currently, fuel load is scheduled to  !

begin on May 2,1997. I The circumstances have resulted from issues raised during NRC vendor inspection activitics. After learning of the issues in j March 1997, Comed reasonably assumed the issues would be resolved sufliciently to allow the Staff to approve References (a) and (b) prior to fuel load. Therefore, this situation could not have been avoided by Quad Cities. Comed believes that the circumstances described above meet the criteria of 10CFR50.91(a)(5) for review and approval on an emergency basis.

Comed requests that the proposed Technical Specifications be approved by May 2,1997.

8 ATTACIIMENT A DESCRIPTION AND EVALUATION OF TIIE PROPOSED CIIANGES Description of the Proposed Channe Pursuant to 10 CFR 50.90, Comed proposes to amend Appendix A, Technical Specifications (TS) Section 5.3.A, Fuel Assemblics. The purpose of this amendment request is to revise the TS to allow operation of Unit 2 in Operational Modes 3,4 and 5 with Siemens fuel. '

4 The current TS read as follows:

Fuel Assemblics i

j 5.3.A The -cactor core shall contain 724 fuel assemblics. Each assembly consists of a matrix of Zircaloy clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide as fuel material and water rods.

Limited substitutions of zirconium alloy, in accordance with NRC-approved applications of fuel rod

. configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff-approved codes and methods, and shown by tests or analyses to comply with all fuel safety design bases. A limited number oflead test assemblics that have not completed representative testing i may be placed in non-limiting core regions.

l Comed proposes to revisc Section 5.3.A to address the addition of Siemens ATRIUM-9B fuel, and to limit use of the ATRIUM-9B fuel to Operational Modes 3,4 and 5. The description of the water rods is changed, the reference to zirconium alloy is made more specific, and a footnote is added limiting use of the ATRIUM-9B fuel to Operational Modes 3,4 and 5. The revised Section 5.3. A reads as follows:

Fuel Assemblies 5.3.A The reactor core shall contain 724 fuel assemblies'. Each assembly consists of a matrix ofZircaloy cladfuel rods with an initial composition of natural or slightly enriched uranium dioxide as fuel material. The

assemblies may contain water rods or water boxes. Limited substitutions ofZircaloy or Z1RLO, in accordance with NRC-approved applications offuel rod configurations, may be used. Fuel assemblies shall be limited to thosefuel designs that have been analped with applicable NRC staff-approved codes and methods, and shown by tests or analyses to comply with allfuelsafety design bases

• A limited number oflead test assemblies that have not completed representative testing may be placed in non-limiting core regions.

1 Footnote 1 A TIUUAl-9B fuelis only allowedin the reactor core in Operational Afodes 3, 4 and 5, and with no more than one control rod withdrawn.

. Footnote 2 Tne design bases applicable to A TRIUAl-9Bfuel are those which are applicable to Operational Afodes 3, 4 and 5.

Comed also proposes to revisc Section 6.9.A.6, CORE OPERATING LIMITS REPORT, to include various topical reports in the list of references for the Core Operating Limits Report. These topical reports support the operation of ATRIUM-9B j fuel in Operational Modes 3,4 and 5.

Baws for Aparorine the Technical Specification Amendment This section discusses the safety implications of the proposed action.

Design Features (Section 5.3)

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ATTACIIMENT A DESCRIPTION AND EVALUATION OF TIIE PROPOSED CIIANGES ,

l The description of the fuel assembly is resised to reflect that ATRIUM-9B fuel contains a central water box. In addition, the term Zirconium alloy is being resised to "Zircaloy or ZlRLO, " which are the only zirconium alloys allowed by 10 CFR 50.46, Addition of Topical Reports (Section 6.9) included in the revised Technical Specifications sia Reference (a) are the NRC approved Topical Reports describing the i

criteria used by SPC to design BWR fuel assemblies. The ATRIUM-9B mechanical design has been analyzed according to

SPC s NRC approved mechanical design criteria (References (g) and (h)). Comed has performed a review to determine i

which topical reports are required for operation of ATRIUM-9B fuct in Operational Modes 3,4 and 5. These topical reports I are listed below (References (c), (f), (g) and (h)) and have been included in Section 6.9. I Advanced Nuclear Fuels Methodology for Boiling Water Reactors, XN-NF-80-19 (P) (A), Volume 1, .

Supplement 3, Supplement 3 Appendix F, and Supplement 4, Advanced Nuclear Fuels Corporation, November 1990.

Commonwealth Edison Topical Report NFSR-0091, " Benchmark of CASMO/MICROBURN BWR Nuclear

. Design Methods", Revision 0, Supplements I and 2, December 1991, March 1992, and May 1992,

, respectively; SER letter dated March 22,1993.

{ Generic Mechanical Design Criteria for BWR Fuel Designs, ANF-89-98(P)(A) Resision 1, and Resision 1 Supplement 1, Advanced Nuclear Fuels Corporation, May 1995, Advanced Nuclear Fuels Corporation Generic Mechanical Design for Advanced Nuclear Fuels 9X9-IX and

) 9X9-9X BWR Reload Fuel, ANF-89-014(P)(A), Resision 1 and Supplements I and 2, Advanced Nuclear j Fuels Corporation, October 1991. -

b l Core Operation in Modes 3,4 and 5

, Support of fuel load in Operational Modes 3,4 and 5 requires consideration of two factors: Core Shutdown Margin (SDM) i and fuel bundle mechanical integrity.

1 The SDM for Quad Cities Unit 2 Cycle 15 was determined by Comed using the NRC approved methodology identified in l References (c) and (f). The Quad Citics Unit 2 Cycle 15 minimum calculated SDM is 1.88 % AK (based on actual EOC 14 energy). This value occurs at beginning of Cycle 15. The SDM at other Cycle 15 exposures is greater than this value.

j Additionally, at BOC any moderator temperature increase above 68 F will increase SDM.

4 Per Sections 3.3.A/4.3.A of the Quad Cities Technical Specifications, the required SDM for Quad Cities Unit 2 Cycle 15 is 0.38 % AK +R, with the highest worth control rod analytically determined. R accounts for: a) any decrease in SDM over

, the cycle relative to the BOC determined value, and b) the potential SDM loss assuming full B4C settling in all inverted i control blade poison tubes present in the core. Since the SDM is the minimum at BOC 15, and the potential SDM loss assuming full B4C settling in all inverted control blade poison tubes present in the core is 0.05 % AK, the required SDM

from th Technical Specifications is 0.38 % AK + 0.00 % AK + 0.05 % AK = 0.43 % AK. Therefore, the calculated SDM of 1.88 % AK is significantly greater than the required Technical Specification value of 0.43 % AK.

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The fuel equipment handling accidents were considered. Comed has evaluated the bundle drop accident for an ATRIUM-98 fuel assembly and has determined that it is bounded by the results of the fuel handling accident presented in the FSAR.

The NRC has approved the mechanical design of the ATRIUM-9B fuelin References (g) and (h). The SPC mechanical

design calculations performed using NRC approved methods demonstrate that ATRIUM-9B fuel complies with NRC approved acceptance criteria and bounds operation of ATRIUM 9B fuelin Operational Modes 3,4 and 5.

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ATTACHMENT A j DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES 1

Consideration of Higher Pressures

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Comed has considered the potential effects of an unplanned blowdown at pre.,sures corresponding to Operational Modes 3 j and 4. The reactor would remain subcritical and no adverse consequences would result. In addition, the mechanical fuel j design would accommodate both the higher pressure and a potential rapid pressure reduction, and the plant would still be able to be maintained in a safe condition.

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