ML20196F893

Safety Evaluation Supporting Amend 182 to License DPR-29

ML20196F893
Person / Time
Site:	Quad Cities
Issue date:	12/03/1998
From:	NRC (Affiliation Not Assigned)
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NUDOCS 9812070152
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1. 1 UNITED STATES

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j NUCLEAR RECULATORY COMMISSICN 2

WASHINGTON, D.C. 2006H001 O

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.182 TO FACILITY OPERATING LICENSE NO. DPR-29 COMMONWEALTH EDISON COMPANY AND MIDAMERICAN ENERGY COMPANY QUAD CITIES NUCLEAR POWER STATION. UNIT 1 DOCKET NO 50-254

1.0 INTRODUCTION

By letter dated August 14,1998 (Reference 1) Commonwealth Edison Company (Comed, the licensee) requested changes to the Technical Specifications (TS) for Quad Cities Nuclear Power Station, Units 1 and 2. Additionalinformation was submitted by letters dated October 13,1998 (Reference 2) and November 23,1998. The proposed changes are due to the transition to Siemens Power Corporation (SPC) ATRIUM-9B fuel. The key items are:

1) incorporation of SPC's new methodologies that would enhance operational flexibility and reduce the likelihood of future plant derates,

2) administrative changes that adopt Improved Technical Specification language where appropriate, and

3) changes to the Quad Cities Minimum Critical Power Ratio (MCPR) Safety Limits.

2.0 EVALUATION The requested TS changes can be categorized into four different topics:

1) Addition of SPC Generic Methodology for Application of Advanced Nuclear Fuel for Boiling Water Reactors (ANFB) Critical Power Correlation to Non-SPC Fuel-EMF-1125(P)(A),

Supplement 1, Appendix C (Reference 3).

2) Addition of SPC Topical for ATRIUM-98 fuel-ANF-1125(P)(A), Supplement 1, Appendix E, (Reference 4).

3) Change to MCPR Safety Limit.

4) Revision to thermal limit descriptions.

Currently Quad Cities, Unit 1, is undergoing a transition from General Electric (GE) to SPC fuel, including the associated methodologies. Due to the transition to SPC fuelit was necessary for SPC to provide a methodology for application of their ANFB critical power correlation to the coresident GE fuel. This topical report has been reviewed and approved by the NRC 9812070152 981203 PDR ADOCK 05000254 P

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(Reference 3) and is applicable to Quad Cities. The approval of this report listed two conditions. By letter dated July 21,1998 (Reference 5) Comed provided the information to address the conditions. This information was reviewed and NRC responded by letter dated August 18,1998 (Reference 6) that the data provided satisfies the SE conditions. Thus, the addition of SPC Generic Methodology for Application of ANFB Critical Power Correlation to Non-SPC Fuel-EMF-1125(P)(A), Supplement 1, Appendix C, is acceptable. The addition of this methodology will ensure that values of cycle-specific parameters are determined such that all applicable limits of the safety analysis are met.

SPC Topical for ATRIUM-98 fuel-ANF-1125(P)(A), Supplement 1, Appendix E, was recently reviewed and approved by NRC (Reference 4) and is applicable to Quad Cities. The restrictions on the additive constant uncertainty from Appendix E are equal to or less restrictive than those used for the analysis of Quad Cities, Unit 1, Cycle 16. Thus, the addition of SPC Topical for ATRIUM-9B fuel-ANF-1125(P)(A), Supplement 1, Appendix E, is acceptable. The addition of this methodology will ensure that values of cycle-specific parameters are determined such that all applicable limits of the safety analysis are met.

The change to MCPR Safety Limit was due to the change to SPC fuel. Using the SPC ANFB critical power correlation methodology and the ATRIUM-9B additive constant uncertainty resulting from the approval of Appendix E (Reference 4), the MCPR Safety Limit for Quad Cities, Unit 1, will be 1.11. This will bound cycle 16 operation. The applicability of the MCPR Safety Limit will be confirmed on a cycle-by-cycle basis. The value of 1.11 is anticipated to bound the actual MCPR Safety Limit for future Quad Cities SPC reloads. Since the MCPR Safety Limit of 1.11 is calculated with an approved methodology and uses the approved additive constant uncertainty from Appendix E, the change to this value will ensure that 99.9%

of the fuel avoids transition boiling and is acceptable.

The change to revise the thermal limit descriptions is to generalize the definitions of the average planar linear heat generation rate (APLHGR) limits to allow either bundle average or average planar exposure based APLHGR iimits, consistent with the loss-of coolant accident (LOCA) analysis of record. This generalization of the definition of APLHGR is consistent with the improved Standard Technical Specifications (NUREG 1433/1434, Revision 1) wording.

Both maximum average planar linear heat-generation rate (MAPLHGRs) (bundle average exposure based and planar average exposure based) are acceptable for Appendix K of 10 CFR Part 50. Thus, this change is acceptable.

3.0 TECHNICAL SPECIFICATION CHANGES Technical Specifications -Table of Contents and TS Section 1-Delete item in Table of Contents for definition of Average Planar Exposure and delete definition of Average Planar Exposure in TS Section 1. This is acceptable because the Average Planar Exposure is no longer used.

Technical Specification 2.1.B - Change the MCPR to 1.11 (from 1.07 and 1.10, respectively).

This change results from the use of ATRIUM 9B fuel and is, therefore, acceptable.

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Technical Specification 3/4.11 The description of the APLHGR Limiting Conditions for Operation (LCO) is changed to not specify that the APLHGR should be a function of average planar exposure. This change is acceptable because the APLHGR is based on the bundle average exposure consistent with the LOCA analysis.

Technical Specification 6.9 - Removal of the cycle 15 specific footnote and the cycle 15 specific methodology. Addition of the topical reports EMF-1125(P)(A), Supplement 1, Appendix C, and ANF-1125(P), Supplement 1, Appendix E, to the list of references. These changes are needed for use of the ATRIUM-98 fuel and addition of these methodologies will ensure that values for cycle-specific parameters are determined such that all applicable limits of the safety analysis are met.

Based on staff evaluation as discussed 2.0 and 3.0 above, the staff concludes that the proposed TS changes are acceptable for Quad Cities. Unit 1.

4.0 DISCUSSION OF EXIGENT CIRCUMSTANCES 10 CFR 50.91(a)(6) provides the necessary requirements for issuing an amendment where the Commission makes a final determination that no significant hazards consideration is involved and that the amendment should be issued. The Commission expects its licensees to: apply for a license amendment in timely fashion; not abuse the provisions by failing to make a timely application for the amendment and thereby explain the exigency and why it could not have I

been avoided.

On November 23,1998, the licensee identified that the license amendment request for Quad Cities, Unit 1, which was originally submitted on August 14,1998, as supplemented by letter dated October 13,1998, and noticed in the Federal Register on November 4,1998, with the 30 day comment period ending at close of business on December 4,1998, may result in the prevention of resumption of operation if the staff failed to act in a timely way. The li::ensee had originally requested that the amendment be approved by December 1,1998, in preparation of reactor startup on December 5,1998. However, due to the completion of outage activities such that the plant would be ready to restart prior to the expiration of the 30 day notice, the licensee promptly requested expedient approval of the amendment to support the revised startup of Quad Cities.

Based on the above circumstances, the staff has determined that (1) the licensee made a timely application for the amendment and properly notified the NRC of changed circumstances warranting expedited processing of the amendment and (2) that the amendment is needed before expiration of the 30 day notice in order to prevent a delay in startup. Therefore, exigent circumstances are present which warrant the processing of this amendment in an expedited manner pursuant to the provisions of 10 CFR 50.91(a)(6).

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4 5.0 FINAL MO SIGNIFICANT HAZARDS CONSIDERATIONS DETERMINATION The Commission's regulations in 10 CFR 50.92 state the Commission may make a final determination that a license amendment involves no significant hazards consideration, if operation of the facility, in accordance with the amendment would not:

_ (1) Involve a significant increase in the probability or consequences of any accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

This amendment has been evaluated against the standards in 10 CFR 50.92. It does not involve a significant hazards consideration because the changes would not:

1.

Involve a significant increase in the probability or consequences of any accident previously evaluated.

The addition of Reference 3 does not significantly increase the probability or consequences of an accident previously evaluated. This change added to the TS a topical report which has been approved by the NRC as a SPC generic methodology for ANFB application to coresident fuel.

This methodology is used to determine the additive constants and the associated uncertainty for this application in calculating a particular fuel cycle's MCPR Safety Limit. The operability of plant systems designed to mitigate any consequences of accidents have not changed.

. Therefore, the proposed addition of this SPC methodology to the list in the TS of analytical methods used to determine operating limits does not significantly increase the probability or consequences of an accident previously evaluated.

The addition of Reference 7 does not significantly increase the probability or consequences of an accident previously evaluated. The basis of Reference 7 was a new statistical analysis using an expanded data base resulting in an approved additive constant uncertainty for

' ATRIUM-9B fuel. This additive constant uncertainty is used as input to the MCPR Safety Limit calculations. These MCPR Safety Limits are applied to ensure the safety limits are not violated during all modes of operation and anticipated operational occurrences. This change does not

- require any physical plant modifications, physically affect any plant components, or entail changes in plant operation. Therefore, no individual precursors of an accident are affected and the operability of plant systems designed to mitigate the probability or the consequences of an

' accident previously evaluated is not affected by this change.

Changing the MCPR Safety Limit at Quad Cities', Unit 1, will not increase the probability or the consequences of an accident previously evaluated. The basis for revising the MCPR Safety

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i Limits for Quad Cities, Unit 1, was due to the revision of the ATRIUM-9B additive constants and the staff approval of the ATRIUM-9B additive constant uncertainty in Reference 7. Cycle specific MCPR Safety Limit calculations will be performed for each reload to verify compliance with the MCPR Safety Limit in the Technical Specifications. Operational limits will be applied that will ensure the MCPR Safety Limit is not violated. The MCPR Safety Limits are being set at the critical power ratio (CPR) value where less than 0.1 percent of the fuel rods in the core are expected to experience boiling transition, therefore, the probability or consequences of an accident will not increase.

The change in the description of APLHGR and deletion of Average Planar Exposure at Quad Cities, Unit 1, will not increase the probability or the consequences of an accident previously

- evaluated. The NRC-approved LOCA methodology applies to either a bundie average or average planar exposure. This new description of APLHGR refers to not exceeding the limits specified in the core operating limits report (COLR), which is consistent with the Improved Technical Specifications, NUREG 1433/1434, Revision 1. No plant equipment or processes are l

affected by this change. Therefore, this change will not increase the probability or the consequences of an accident previously evaluated.

2.

Create the possibility of a new or different kind of accident from any accident previously evaluated.

The addition of Reference 3 is the adding of an NRC-approved methodology for the application of the ANFB critical power correlation to co-resident fuel. It does not introduce any physical changes to the plant, the processes used to operate the plant, or allowable modes of operation.

The MCPR of the co-resident fuel will be calculated using the additive constants determined as described in Reference 3. Therefore, no new precursors of an accident are created and no new or different kinds of accidents are created.

The addition of Reference 7 is the adding of an NRC-approved methodology for the calculation of the additive constant uncertainty for ATRIUM-9B fuel to the MCPR Safety Limit. It does not introduce any physical changes to the plant, the processes used to operate the plant, or allowable modes of operation. Therefore, no new precursors of an accident are created and no new or different kinds of accidents are created.

The changing of the MCPR Safety Limit will not create the possibility of a new or different kind of accident. The revised additive constants for ATRIUM-9B fuel calculated in Reference 7 resulted in a MCPR increase to 1.11. This new limit is expected to bound future reloads of ATRIUM-9B. This change will not change or add any new equipment, change mode of operation or the processes used to operate the plant. Therefore, no new accidents are created that are different from any accident previously waluated.

The revision of the APLHGR description and the ddetion of the Average Planar Exposure definition will not create the possibility of a new or different kind of accident from any previously evaluated. This change provides flexibility and consistency of the APLHGR limits in the COLR.

This change does not introduce any physical changes to the plant, the processes used to 1

1 operate the plant, or allowable modes of plant operation. Therefore, this change does not i

create the possibility of a new or different kind of accident from any accident previously evaluated.

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3.

Involve a significant reduction in a margin of safety.

The margin of safety does not decrease with the addition of Reference 3. This methodology is i

NRC-approved for the application of the ANFB critical power correlation to co-resident fuel, it will continue to ensure that greater than 99.9 percent of the rods in the core avoid boiling i

transition. Operating limits will be established to ensure the MCPR Safety Limit is not violated.

Therefore, there is no significant reduction in the margin of safety.

The margin of safety does not decrease with the addition cf Reference 7. This methodology provides the ATRIUM 9B additive constant uncertainty calculation which is based on a larger i

data base as previous calculations and has been NRC approved.

This methodology ensu' a that greater than 99.9 percent of the rods in the core avoid boiling i

transition. Operating limits will be established to ensure the MCPR Safety Limit is not violated.

j Therefore, there is no significant reduction in the margin of safety.

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Changing of the MCPR Safety Limit will not involve any reduction in the margin of safety. The j

f new MCPR Safety Limits reflect the NRC-approved methodologies of the ANFB critical power 1

correlation and the ATRIUM-9B additive constant uncertainty calculations. This safety limit increase is expected to bound future ATRIUM-9B reloads. This MCPR Safety Limit ensures i

that greater than 99.9 percent of the rods in the core avoid boiling transition. Operating limits j

will be established to ensure the MCPR Safety Limit is not violated. Therefore, there is no significant reduction in the margin of safety.

The revision of the thermallimit APLHGR description and the deletion of the Average Planar Exposure definition will not involve a reduction in the margin.of safety. The methodologies to calculate APLHGR must still meet NRC requirements and the APLHGR is still required to be maintained in the COLR. The surveillance requirements for APLHGR remains unchanged.

Therefore, there is no sigSficant reduction in the margin of safety.

Accordingly, the Commission has determined that this amendment involves no significant hazards consideration.

6.0 STATE CONSULTATION

in accordance with the Commission's regulations, the lilinois State official was notified of the proposed issuance of the amendment. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has made a final no significant hazards finding with respect to this amendment.

Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). This amendment also relates to changes in recordkeeping, reporting or

' administrative procedures or requirements. Accordingly, with respect to these items, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

8.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: M. Chatterton R. Pulsifer Date: December 3,1998 l

4.

9.0 REFERENCES

1.

Letter from R.M. Krich, Comed, to NRC, dated August 14,1998.

2.

Letter from R.M. Krich, Comed, to NRC, dated October 13,1998.

3.

EMF-1125(P)(A), Supplement 1, Appendix C,"ANFB Critical Power Correlation Application for Coresident Fuel," August 1997, and NRC SE, " Acceptance for Referencing of Licensing Topical Report EMF-1125(P), Supplement 1, Appendix C,"ANFB Critical Power Correlation Application for Co-Resident Fuel, " J.E. Lyons to R.A. Copeland, May 9,1997.

4.

ANF-1125(P), Supplement 1, Appendix E,"ANFB Critical Power Correlation Determination of ATRIUM-9B Additive Constant Uncertainties", and NRC SE," Acceptance for Referencing of Licensing Topical Report ANF-1125(P), Supplement 1, Appendix E, Critical Power Correlation Determination of ATRIUM-9B Additive Constant Uncertaintles",

T.H. Essig to H.D. Curet, September 23,1998.

5.

Letter from J.P. Dimmette, Comed, to NRC, dated July 21,1998.

6.

Letter from R.M. Pulsifer, NRC, to O.D. Kingsley, Comed, dated August 18,1998.

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