ML20248B419
| ML20248B419 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/03/1989 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19297H484 | List: |
| References | |
| CON-NRC-89-0052, CON-NRC-89-52 TAC-69074, NUDOCS 8904100402 | |
| Download: ML20248B419 (26) | |
Text
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B. Riiph Sylvb L {
Semor Vice President
.l Edison 6400 North Dixie Highway
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April 3,1989 NFC-89-0052 l
U. S. IAlclear Regulatory Commission l Attn: Document Control Deck l Washington, D. C. 20555
References:
' 1) Fermi 2 -
NRC Docket No. 50-341 NPC License No. IFF-43
- 2) " General Electric Standard Application for Reactor Fuel," NEDE-240ll-P-A and US (Revision 9)
- 3) Detroit Edison Letter to NBC, NBC-88-0177,
, " Proposed Technical Specification (License Amendment) Change - Minimum Critical Power Ratio ~ (3/4.2.3) and Main Turbine Bypass System (3/4.7.9)", dated January 27, 1988 -
- 4) Detroit Edison Letter to IBC, IEC-87-0132,
" Proposed Technical Specification Changes to Include Single Loop Operation (SLO)",
dated August 4,1988
- 5) Detroit Edison Letter to IGC, NRC-88-0280,
" Technical Specification Changes for Single Loop Operation (TAC No. 69074)", dated November 16, 1988
Subject:
Proposed Operating License / Technical Specifications Change (License Araendment) - Cycle 2 Reload Submittal Pursuant with 10CFR50.91 and 50.92, Detroit Edison hereby sroposes to amend Operating License NPF-43 for the Fermi 2 plant by Incorporating the enclosed changes into the Plant Operating License and Technical Specifications. The proposed requests changes to the Technical
' Specifications related to the Reload 1, Cycle 2 plant operations.
Attachnent 1 provides the Summary, Description of Changes, Significant Hazards and Environmental Impact Considerations. Attactment 2 provides a summary listing of the proposed Technical Specification and o@%7 Mi"pg AP '/37 l- 8904100402 890403 ' q g j f(-
f a USNBC-April 3, 1989 NBC-89-0052 Page 2 Bases changes for the first reload. Attachment 3 is a copy of the marked up Operating License, Technical Specification and Bases pages.
Enclosure 1 provides the GE Nuclear Energy (GE) developed Supplemental Reload Licensing Submittal for the Fermi 2 Nuclear Power Plant (23A5949) Reload 1, Cycle 2 which provides a description of the core and sunmarizes the results of the transient analyses.
Enclosure 2 provides Supplement 1 (23A5949AA) to the above Supplemental Reload Licensing Submittal which contains fuel bundle descriptions and the Maximum Average Planar Linear Heat Generation Rates for the new fuel to be loaded into the core for the upcoming cycle. This information is considered by GE to be proprietary information and an affidavit from GE to that effect is also enclosed.
Pursuant to 10CFR2.790 it is requested that the information contained in Enclosure 2 be withheld from public disclosure.
Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and has determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review Organization has approved and the Nuclear Safety Review Group has reviewed the proposed Technical Specifications and concurs with I the enclosed determinations. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.
If you have any questions in this matter, please contact Mr. Glen Ohlemacher at (313) 586-4275.
Sincerely,
[
Enclosure cci A. B. Davis R. C. Knop W. G. Rogers ,
J. F. Stang )
Supervisor, Advanced Planning and Review Section, l Michigan Publice Service Commission ;
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' USNRC ,.
April 3,.1989 NRC-89-0052-Page 3 l
I, B.~ RALPH SYLVIA,: do hereby affirm that the foregoing statements are based on facts and cit:cumstances which are true and accurate to the best of my knowledge and belief.
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B. NALPTSYLV)(
Senior Vice President on this dbMN ~ day w O4 hN , 1989, before me personally appeared B. Ralph Sylvia, being first duly sworn and says
- that he executed the foregoing as his free act and deed.
Y b Y )4- d.- -
Notary Public
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KAREN M. REED Notary Public, Menroe County, Mic!t My Consisticn Expires May 14, 1933 l- -
i_____________._____ _ '
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GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Janice Charnley, being duly sworn, depose and state as follows:
- 1. I am Manager, Fuel Licensing, General Electric Company, 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 "23A5949AA,Rev O, Supplement 1 Supplemental Reload Licensing Submittal for Fermi Power Plant Unit 2 Reload 1, Cycle 2", March 1989.
- i. 3. In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757. This definition provides:
l "A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it.... A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring information.... Some factors to be considered in determining I
whether given information is one's_ trade secret are: (1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures '!
taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expanded by him in developing the information; (6) the ease or difficulty with the which the information could be properly acquired or duplicated by others."
- 4. Some examples of categories of information which fit into the definition l of proprietary information are: )
- a. Information that discloses a process, method or apparatus where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; J
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- b. Information consisting of supporting data and analyses, i including test data, relative to a process, method or j apparatus, the application of which provide a competitive !
economic advantage, e.g., by optimization or improved marketability;
- c. Information which if used by a competitor, would reduce his !
I expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product;
- d. Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers;
- e. Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial value to General Electric:
- f. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection;
- g. Information which General Electric must treat as proprietary according to agreements with other parties.
- 5. Initial approval of proprietary treatment of a document is typically made by the Subsection manager of the originating component, the person who is most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within the Gompany is limited on a "need to know" basis and such documents are clearly identified as proprietary.
- 6. The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project Manager, Principal Scientist or other equivalent authority, by the Subsection Manager of the cognizant Marketing function (or delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees then only with appropriate protection by applicable regulatory provisions or proprietary agreements.
- 7. The document mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.
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- 8. The document mentioned in paragraph 2 above is classified as proprietary l because it contains details concerning current General Electric fuel ,
designs which were developed at considerable expense to General Electric '
which are not available to other parties.
- 9. The information to he best of my knowledge and belief ha consistently l
been held in confidence by the General Electric Company, no public '
disclosure has been made, and it is not available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions of proprietary agreements which provide for maintenance of the information in confidence.
- 10. Public disclosure of the information sought to be withheld is ,
1 likely to cause substantial harm to the competitive position of the General Electric Company and deprive or reduce the availability of profit making opportunities because it would provide other parties, including competitors, with valuable information regarding l current General Electric fuel designs which were obtained at considerable cost to the General Electric Company. The man-power, computer and manufacturing resources expended by General Electric to develop the current fuel designs are valued at approximately $8 million. In addition, the development of individual bundle and lattice designs require over 120 man-hours and approximately
$20,000 in computer resources.
STATE OF CALIFORNIA COUNTY OF SANTA CLARA
) ss:
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Janice Charnley, being duly sworn, deposes and says:
That she has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.
Executed at San Jose, California, this @ day of h eb , 19 $ .
,, f .j?s u s _ z , A'W shitfe Charnley peneralElectricCompany ,/ Subscribed and sworn before me this y of beck 1981 Sy W < u _ _ . . - _
~ ~ iFN O NOTARY PUBLIC, STATE OF Q FORNTf LYDIA M SIMPSON 9 NOTARY PUBUC - CAllFORNIA SANTA CLARA COUNTY My comm. expires DEC 26, 1989
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l! 1 ATTACHMENT 1 l l l-
SUMMARY
, DESCRIPTION OF l CHANGES, SIGNIFICANT HAZARDS AND ENVIRONMENTAL IMPACT CONSIDERATIONS 1 l i l
3 h l 1 Page 1 of 19 ) Attachment 1 l NRC-89-0052 l
SUMMARY
l 1 This proposed amendment is requested to reflect the characteristics of the new fuel to be loaded into the core for Cycle 2 operation. i The reload analyses were performed by GE Nuclear Energy (GE) using , their advanced computer modeling methods. These methods are known I as GEMINI, and have been approved for use in lieu of the older l GENESIS methods. Additionally, an improved GE thermal correlation l GEXL-PLUS was applied to Fermi-2 for the first time. The GEXL { correlation was used for the initial core. Both of these correlations have received NRC approval. Results of equipment performance identified during the Startup Test Program were j factored into the analyses. Additionally, the Bases of the j Technical Specifications are updated to be consistent with the ! reload analyses and generalized to reflect a more extensive j reference to the GE reload licensing topical report; General l Electric Standard Application for Reactor Fuel - GESTAR II: NEDE- ! 24011-P-A and US Supplement (Reference 2, hereafter referred to as j GESTAR). ] 1 The reload fuel is of the GE8X8EB extended burnup fuel design. j I This fuel design, as described in Table 1 (Acceptable Fuel Types and Operating Conditions) in the Safety Evaluation Report (SER) for Amendment 8 of GESTAR, has been reviewod and approved by the j NRC for generic applications and extended turnup operations. l The impact of the new fuel types upon the Emergency Core Cooling j System (ECCS) analysis were evaluated widh the SAFE /REFLOOD LOCA j analysis methodology. Application of this method is described in i GESTAR and has received NRC review and approval. Results from analysis of the postulated plant desion basis LOCA with this new fuel type, demonstrate that Fermi 2 craforms with the ECCS and Peak Cladding Temperature (PCT) acceptance criteria of 10CFR50.46 and 10CFR50 Appendix K. Control Cell Core (CCC) loading and operating strategy will be employed for the second cycle. An additional Minimum Critical Power Ratio (MCPR) operating limit was developed for the A2 sequence CCC operational mode. The CCC operational mode include A2 sequence rods, Al sequence shallow rods (inserted less than or equal to notch position 36) , all peripheral rods, and rods inserted l to position 46. The Rod Withdrawal Error (RWE) Analysis was performed for the CCC operational mode. This condition is expected to exist throughout Cycle 2. The CCC operating MCPR limit is i applicable only following the completion of a proposed Surveillance Requirement 4.2.3.2 which verifies that the Control Cell Core i conditions are satisfied. Fermi-2 is a group notch plant converting from the Group Notch l l
l Page 2 of 19 Attachment 1 NRC-89-0052 Withdrawal Sequence (GNWS) operational mode to the Banked Position Withdrawal Sequence (BPWS) operational mode for protection against exceeding the design basis accident design limits for the control rod drop accident (CRDA). The results show that the peak enthalpy in the CRDA would be much less than the 280 cal /gm design limit even with a maximum incremental rod worth corresponding to 95% probability at the 95% confidence level. The rod worth minimizer (RWM) will be programmed to enforce the BPWS operation mode. The RWM will provide the withdrawal sequence monitoring function that enforces adherence to established startup, shutdown and low power level control rod sequences. The BPWS sequences are designed to limit incremental control rod worth. No hardware modifications are involved in this change. The reload analyses considered the effects of several modes of operation and initial conditions which were either continued from the first cycle or were adjusted to incorporate startup test results and other plant operational considerations. The operational domain considers the 100% power / flow region and extended load line region with 100% power and reduced flow. Both the CCC and non-CCC operational modes were evaluated. In addition, the inoperability of the main turbine bypass system and/or moisture separator reheater system out of service were analyzed. Analyses for the extended load line region were continued for Cycle 2 from Cycle 1. Operation in the entire extended region is currently restrained by Average Power Range Monitor (APRM) rod block, rod block monitor (RBM) and scram setpoint Technical Specification requirements. Detroit Edison will submit the necessary Technical Specification changes to fully utilize the extended region at a later date. 1 In Reference 3 (NRC-87-0177), Detroit Edison applied for Technical Specification provisions for operation greater than 25 percent of rated thermal power with an inoperable moisture separator reheater. This submittal included provisions for the continued operation with both the moisture separator reheater system and the main turbine bypass system inoperable. The Reference 3 proposal is presently under NRC review and its application will be extended to Cycle 2. In Reference 4 (NRC-87-0132), Detroit Edison applied for the Technical Specification changes necessary for single loop operation in Cycle 1. This change request is currently scheduled for revision by Detroit Edison following resolution of BWR thermal-hydraulic stability questions (discussed in Reference 5, NRC 0280). When revised, the Reference 4 proposal will include the necessary provisions which apply to Cycle 2. Detroit Edison has adopted GE SIL-380 recommendations and they have
Page 3 of 19 Attachment 1 NRC-89-0052 ) been included in the Fermi 2 operating procedures. The regions of restricted operation defined in Attachment 1 to the NRC Bulletin No. 88-07 Supplement 1, are applicable to Fermi 2 Reload 1 and have been implemented in Fermi 2 operating procedures. l Consistent with Cycle 1, the transient analyses were performed with j a rated core thermal power of 3293 MWT. The most significant change that impacted the transient analyses was the new GE8X8EB extended burnup fuel bundles which have a larger negative void coefficient than present Cycle 1 fuel bundles. The Technical Specification changes are proposed to reflect the initial conditions applied to the reload transient analyses. Various fuel and core operating limits are established to bound normal and transient operations to ensure core conditions are maintained within the scope of the accident analyses. Analysis with NRC approved methods (described within GESTAR) demonstrates that adequate safety margins are maintained. The Technical Specification changes specifically related to Cycle 2 reload fuel operating limits and analyses are as follows: A. Pages 2-1, B 2-1, B 2-2, B 2-3, B 2-4, B 3/4 2-2, B 3/4 2-4, and B 3/4 2-5. Increase the Safety Limit Minimum Critical Power Ratio (MCPR) from 1.06 to 1.07 to account for the additional uncertainties in the Traversing Incore Probe (TIP) readings and R-factors that normally occur in the second and , subsequent cycles. The R-factor is a parameter in the critical power correlation which characterizes the local peaking pattern with respect to the most limiting rod and is further described in GESTAR. This factor accounts for the details of flow and enthalpy distribution in the bundle. The bases for the Safety Limit MCPR appear in GESTAR. GESTAR is referenced in the Technical Specification Bases in place of the redundant information currently in the Bases. B. Pages 3/4 2-1, 3/4 2-4, 3/4 2-4a, and B 3/4 2-1. The MAPLHGR limit Technical Specifications are revised to include two new fuel bundle types, BC318D and BC318E. C. Page 3/4 2-6. The change to GEMINI methods requires that - Specification 3.2.3 be changed to reflect changes in the I calculation of Tau g. D. Page 3/4 2-10 and B 3/4 2-3. Higher LHGR limit is added for , the new GE8X8EB fuel bundles. ) l E. Page 5-5. This change will allow the use of fuel designs which have received generic NRC approval. l 1 l
l i l l Page 4 of 19 Attachment 1 , NRC-89-0052 ! F. Page 1-2 and 3/4 2-9. A new K, curve for the change to the GEXL-PLUS correlation and generalization of the definition of ! Critical Power Ratio. l G. Pages 3/4 2-6 through 2-8B. New exposure dependent operating MCPR 13mits are included to reflect Cycle 2 core design. H. ?agea 3/4 2-6 through 2-8B. Additional MCPR operating limit t ic included for control cell core (CCC) operational mode. l I. Operating License Page 3 and Page 1-5. Change in licensed rated thermal power from 3292 MWT to 3293 MWT to reflect the actual analyzed design power. - J. Pages 3/4 1-16, B 3/4 1-3 and B 3/4 1-4. Replacement of the ! GNWS method with the BPWS method. Verify that the BPWS is correctly loaded into the RWM program and associated reference changes in the Bases Section. pl MRIPTION OF TECHNICAL SPECIFICATION CHANGES GESTAR presents generic information relative to the various GE fuel designs and analyses of the General Electric Boiling Water Reactors (GE BWRs) for which GE provides fuel. GESTAR consists of a description of the fuel design and fuel mechanical, nuclear and , thermal hydraulic analyses bases. A United States Supplement to GESTAR provides the plant specific information and safety analysis methodology used to determine reactor limits. GESTAR provides core and fuel related information that is independent of a plant , specific application. In Table S-1 (Applicable Reactors) of the l US Supplement, Fermi 2 was identified as applicable for the i information provided in GESTAR. The generic information contained j in this document is supplemented by plant and cycle-specific information and analytical results presented in the Supplemental Reload Licensing Submittal included herein as Enclosure 1. It includes a listing of the fuel to be loaded in the core, reference core loading pattern and safety analysis results. Together GESTAR and the Supplemental Reload Licensing Submittal completely describe the reactor fuel, core design and safety analyses. A. Safety Limit MCPR for Reload Cores Operating limits are specified to maintain adequate margin to the onset of transition boiling (from nucleate to film boiling). The critical power ratio (CPR) is defined as the ratio of the critical power (bundle power at which some point within the fuel assembly experiences onset of transition boiling) to the operating bundle power. The critical power
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, e Page 5 of'19 Attachment 1
.NRC-89-0052
~is determined for the mass flux, inlet temperature, and pressure which exists at the specified reactor condition.
Thermal margin is expressed in terms of.the minimum critical power ratio (MCPR),'which corresponds to the smallest CPR of 'l' those found in the core. The MCPR safety limit and ' normal MCPR operating limits are derived from this basis. The plant-specific Minimum Critical Power Ratio (MCPR) operating limit is established to ensure that the fuel cladding integrity. Safety Limit . is not exceeded for any moderate frequency transient. Since the parameters which result in fuel damage are not directly observable during reactor operation, the thermal and hydraulic conditions resulting in a departure from nucleate boiling have been used to mark the beginning of the region where fuel damage could occur. Therefore the fuel cladding integrity Safety Limit is defined as the CPR in the limiting fuel assembly for which more'than 99.9% of the fuel rods in the core are expected to avoid boiling transition considering the power distribution within the core and all uncertainties. The Safety Limit MCPR is determined using a statistical model that combines all of the uncertainties in the operating parameters and in the procedures used to calculate critical power. The probability of the occurrence of boiling transition is determined using the NRC approved critical power correlation GEXL-PLUS. The Safety Limit MCPR has been increased from 1.06 to 1.07 to account for the increased uncertainties in the Traversing-Incore Probe (TIP) readings and R-factors.that normally occur in the second and subsequent cycles. The R-factor accounts for the details ' of flow and enthalpy distribution in the bundle. B. Maximum averaae olanar linear heat aeneration rate (MAPLHGR) for the GE8X8EB fuel bundles The average planar linear heat generation rate (APLHGR) is applicable to a specific planar height and is equal to the sum of the LHGRs for all of the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in l the fuel bundle. The MAPLHGR is the most limiting value of i APLHGR for a given bundle type such that thermal limits are not exceeded. 10CFR50.46 establishes acceptance criteria for ) I the fuel and Emergency Core Cooling Systems (ECCS). MAPLHGR limits are established to ensure that the acceptance criteria are met. J For this cycle, the natural uranium bundles are completely removed and two new 3.18 percent enriched GE8X8EB extended l ___________m _m.___ _ . . - . _ _
1 Page 6 of 19 Attachment 1 NRC-89-0052 1 burnup bundle types are introduced. For the initial fuel bundle designs (8CR183 and 8CR233) the MAPLHGR limit depends only on bundle type and burnup. The reload fuel bundle designs (BC318D and BC318E) have MAPLHGR limits that vary axially depending upon the specific combination of enriched uranium and gadolinia that comprises a fuel bundle cross section at a particular axial node. Each particular combination of enriched uranium and gadolinia, for these fuel bundle types, is called a lattice type. These particular fuel bundle types have MAPLHGR limits that vary by lattice type (axially) as well as with fuel burnup. Only the most limiting MAPLHGR values are shown in the Technical Specification figures for multiple lattice fuel. When hand calculations are required, these Technical Specification MAPLHGR figure values for the bundle type are used as the limit for all lattices in that bundle. The APLHGRs for each fuel type are monitored against the corresponding fuel lattice MAPLHGR (developed from the NRC approved fuel lattices described in GESTAR) . The fuel lattice MAPLHGR limits are proprietary. In order not to breach the proprietary nature of the fuel designs, GE and the NRC have agreed that only the limiting enriched fuel lattice MAPLHGR curve is necessary within the Technical Specifications for fuel with multiple lattices (further discussion is contained in GESTAR). Supplement 1 to the Supplemental Reload Licensing Submittal (Enclosure 2) will be available to the control room operator to supply information on the axial location of each lattice and the composite MAPLHGR, as a function of exposure for each fuel bundle, in accordance with the NRC's Safety Evaluation Report (SER) for Amendment 19 of GESTAR. This proposal adds two limiting lattice MAPLHGR curves for the two new GE8X8EB extended burnup bundle types and deletes the MAPLHGR curve for the natural uranium bundle type. The Limiting Conditions of Operation, Action and Surveillance Requirements are also modified to reflect the fact that the fuel lattice dependent MAPLHGR limits are located outside the Technical Specifications and the limiting curve for each ! bundle type is included for hand calculations purposes. C. The chance in Tau, coefficients associated with the chance from GENESIS methods to NRC approved GEMINI methods The Bases have been revised to reference the GEMINI methods. This change is an administrative change in which references
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.g',. g.' 1 Page 7 of'19 [
Attachment 1 NRC-89-0052 in the Technical. Specification Bases are updated to reference-the methods' used to . evaluate Fermi 2 Reload 1 and Option B. scram time conformance requirements. The methods-themselves
' have been reviewed and approved by the NRC, and have been used to analyze other reloads previously approved by the NRC.
equation The change to GEMINI be modified. methods requirescorrespond The coefficients'which that the Tau, to-the mean and standard deviation values are updated in Specification 3.2.3 in the equation for Tau, to reflect the new NRC approved GEMINI methods. Because this change involves only the calculational methodology, there are no changes or modifications made to the Fermi 2 facility and no changes to any existing Limiting a' Conditions for Operation (other than modifying' Tau coefficients), surveillance Requirements, or margins of safety. ! D. LHGRs for the GE8X8EB extended burnun fuel desians The linear heat generation rate (LHGR) is the heat generation per unit length of fuel rod. It is.the integral of the heat flux over the heat transfer area associated with the unit length. . The new GE8X8EB extended burnup fuel bundles have an NRC approved higher LHGR limit than. the initial core. Therefore, the linear heat generation rate specification is revised to allow for this fuel type. The design and analysis of this fuel _is described within GESTAR and'its' application has been approved on a generic basis by the NRC. E. Use'of new NRC accroved fuel desions Technical Specification 5.3.1, Fuel Assemblies, currently provides specific fuel design information. The reload fuel is'of the GE8X8EB extended burnup fuel design. This ' fuel design, as described in-Table 1 (Acceptable Fuel Types and Operating Conditions) in the Safety Evaluation Report (SER) for Amendment 8 of GESTAR, has been reviewed and approved by the NRC .for generic applications and extended burnup operations. The change allows the use of this reload fuel and those fuel designs which have received generic NRC approval. The specific use of any generically approved fuel design at Fermi 2 would require NRC review and approval at that time. This proposed change is therefore strictly administrative and is made to preclude the need for future changes to the Technical Specification. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ i
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Page 8 of 19 Attachment 1 N.RC-89-0052 F. New ]5, curve for the chance to the GEXL-PLUS correlation and generalization of the definition of Critical Power Ratio The Bases have been revised to reference the generically approved critical power correlation. For Cycle 2 this approved correlation is the GEXL-PLUS correlation. This change is an administrative change in which references are updated to reference the methods used to evaluate Fermi 2 Reload 1, Cycle 2. The GEXL-PLUS correlation has been reviewed and approved by the NRC, and has been used to analyze other reloads previously approved by the NRC. The definition of Critical Power Ratio is also generalized to allow for the use of GEXL-PLUS and future NRC approved correlations. This is strictly an administrative change, any calculations or analysis based upon future NRC approved correlations will receive NRC review at the time of their application. A low flow correction is applied to the MCPR operating limit for the NRC approved GEXL-PLUS correlation. These adjustments were found acceptable and approved by the NRC. Because this change involves only the calculational methodology, there are no changes or modifications made to the Fermi 2 facility and no changes to any existing Limiting Conditions for Operation (other than modifying the Kf curve), Surveillance Requirements, or margins of safety. G. Exposure denendent operatina MCPR limits The severity of the transient analyses is worst at the end of the cycle primarily because the end-of-cycle all-rods-out scram curve gives the worst possible scram response. It follows that less restrictive MCPR limits can be obtained by analyzing the transients at other interim points in the cycle and administering the resulting MCPR limits on an exposure dependent basis. After the cycle reactivity peaks, the scram reactivity l function monotonically deteriorates with exposure. Repeating l the transient analyses at selected midcycle exposure points I takes credit for the larger scram reactivity available at that j exposure point. The MCPR limit determined for these midcycle exposure points are administered over the applicable exposure intervals. These applicable exposure intervals for the MCPR limit is between the exposure point of the analysis performed ' to the next lower exposure point. For Cycle 2 there are three I l l I
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Page 9 of 19 Attachment 1 NRC-89-0052 l exposure intervals: Beginning of Cycle (BOC) to 12,700 MWD /ST (core average exposure), 12,700 MUD /ST to 13,700 MWD /ST, and 13,700 MWD /ST to End of Cycle (EOC). H. MCPR Operatina Limit for use in Control Cell Core Operational Mode An additional MCPR operating limit was developed for the A2 sequence CCC operational mode. The CCC operational mode include A2 sequence rods, Al sequence shallow rods (inserted less than or equal to notch position 36), all peripheral rods, and rods inserted to position 46. The Rod Withdrawal Error (RWE) Analysis was performed for the CCC operational mode. This condition is expected to exist throughout Cycle 2. This additional MCPR operating limit was calculated using NRC approved methods and satisfies NRC approved criteria which are similar to the methods and criteria used to establish the non-CCC operational mode MCPR limit for Cycle 2 and Cycle 1. The CCC operating MCPR limit is applicable only following completion of the proposed Surveillance Requirement 4.2.3.2 which verifies that the Control Cell Core conditions are satisfied. Normal control rod operability checks, coupling checks, scram time testing, and friction testing of non-CCC control rods does not require the utilization of the more restrictive non-CCC operational mode MCPR limits. For operability and coupling checks, control rods are intentionally inserted and withdrawn by one or two notch increments. The reactivity change associated with this small amount of rod movement is below analytical concerns. For friction and scram time testing of non-CCC control rods, the withdrawal of the inserted non-CCC rod is not of concern because the immediate withdrawal of the rod just inserted can only return the core to the previous operating state. The only rods which may be inadvertently withdrawn are CCC control rods. The inadvertent withdrawal of any of these rods was analyzed with the RWE analysis. This RWE analysis is based upon limiting control rod patterns chosen from all possible rod patterns, not just ] CCC control rod patterns. Therefore, the use of the more 1 restrictive non-CCC operational mode MCPR limit is not required. The RWE analysis used the Nominal Trip Setpoint (NTSP) of 106% ; for the Rod Block Monitor (RBM) setpoint. This analysis also used the conservative assumptions that the plant is operating with a limiting rod pattern and worst case LPRM failure condition. An alternate analytical methodology would use the 110% analytical limit with a nominal rod pattern and expected j
i Page 10 of 19 ! Attachment 1 NRC-89-0052 LPRM failure rates. The analysis which used the NTSP of 106% has sufficient conservatism to allow for potential inctrument ! error and is as conservative as the alternate analytical l methodology and therefore acceptable. ( I. Chance in Licensed Rated Thermal Power from 3292 MWT to 3293 MHI The actual Fermi 2 analyzed plant conditions for both Cycle 1 and Cycle 2 was 3293 MWT versus the 3292 MWT value stated in the Technical Specifications and the Operating License. This is a change in the rated thermal power of the plant to reflect the true analyzed condition of the plant. As stated above, the 3293 MWT was used in the initial analysis of the plant, but was not corrected in the Cycle 1 Technical Specification. J. Replacement of the GNWS method with the BPWS method Fermi-2 is a group notch plant converting from the Group Notch Withdrawal Sequence (GNWS) operational mode to the Banked Position Withdrawal Sequence (BPWS) operational mode for protection against exceeding the design basis accident design limits for the control rod drop accident (CRDA). The results show that the peak enthalpy in the CRDA would be much less than the 280 cal /gm design limit even with a maximum , incremental rod worth corresponding to 95% probability at the l 95% confidence level. The rod worth minimizer (RWM) will be programmed to enforce the BPWS operational mode. The RWM will ! provide the withdrawal sequence monitoring function that enforces adherence to established startup, shutdown and low power level control rod sequences. The BPWS sequences are designed to limit incremental control rod worth. This change involves only the operational mode and the additional verification that only a BPWS operational mode is programmed in the RWM. There are no changes or modifications made to the Fermi 2 facility and no changes to any Surveillance Requirements (other than the verification of BPWS operational mode), or margins of safety. SIGNIFICANT HAZARDS EVALUATION A Significant Hazards Consideration evaluation is performed for each group of Technical Specification changes described in the preceding paragraphs. The standards used to arrive at a determination that a request for amendment requires no significant hazards consideration are included in the Commission's Regulations,
Page 11 of 19 Attachment 1 NRC-89-0052 10CFR50.92(c). Each group of changes are evaluated in conformance with 10CFR50.92 (c) by responding to each of the following three questions:
- 1. Does the proposed license amendment involve a significant increase in the probability or consequences of an I accident previously evaluated?
- 2. Does the proposed license amendment create the possibility of a new or different kind of accident from any previously evaluated?
- 3. Does the proposed amendment involve a significant reduction in margin of safety?
A. Safety limit minimum critical power ratio (MCPR) for reload cores.
- 1. The new Safety Limit MCPR is set such that no fuel damage is calculated to occur provided this limit is not violated. It is determined using the NRC approved General Electric Thermal Analysis Basis (GETAB), which !
is a statistical modei that combines uncertainties in operating parameters with uncertainties used to calculate critical power. For reload cores, some of the uncertainties used in the determination of the Safety Limit MCPR are increased. The Safety Limit MCPR increase accounts for these increased uncertainties. The Safety Limit MCPR for reload cores has received previous NRC approval and are updated to be consistent with the reload analyses and generalized to reflect a more extensive reference to the General Electric reload licensing topical report; General Electric Standard Application for Reactor Fuel - GESTAR II: NEDE-24011-P-A and US (hereafter referred to as GESTAR). The new Safety Limit MCPR accomplishes the same purpose as the previous limit and therefore does not increase the probability or consequences of an accident previously evaluated. l
- 2. The operation of the plant does not change due to the new Safety Limit MCPR nor does this change result in any modifications to the Fermi 2 facility; therefore, this change does not create the possibility of a new or different kind of accident than previously evaluated.
- 3. Increasing the Safety Limit MCPR maintains the margin of safety established by the current limit. Both limits I
Page 12 of 19 Attachment 1 NRC-89-0052 ) l have received previous NRC approval. Therefore, this change does not involve a significant reduction in the margin of safety. l B. Maximum average planar linear heat generation rate (MAPLHGR) for new GE8X8EB extended burnup fuel bundles.
- 1. 10CRF50.46 establishes acceptance criteria for fuel and Emergency Core Cooling Systems (ECCS). MAPLHGR limits are established to ensure that the acceptance criteria are met.
l This change provides MAPLHGR limits for the BC318D and BC318E bundles. The MAPLHGRs have been calculated using NRC approved methods. The results of the analysis provided in the Fermi 2 Reload 1 Licensing Submittal demonstrate that the acceptance criteria of 10CFR50.46 are met with substantial margin. This change therefore does not increase the probability or consequences of an accident previously evaluated.
- 2. The mode of plant operation does not change due to the MAPLHGR limits nor does the MAPLHGR limit change result in any modifications to the Fermi 2 facility, therefore this change does net create the possibility of a different kind of accle at than previously evaluated.
- 3. The acceptance criteria of 10CFR50.46 establish the margins of safety for fuel and the ECCS. Calculations using NRC approved models described in GESTAR yield results well within these acceptance criteria.
Therefore, the proposed amendment does not involve a significant reduction in the margin of safety. The proposal changes the structure of the Technical Specification for MAPLHGR (3/4.2.1) to reflect the location of fuel lattice dependent MAPLHGR limits in documentation outside of the Technical Specifications. The location of the actual limits is strictly an administrative arrangement to protect the proprietary nature of this information. The necessary MAPLHGR limits continue to be required regardless: of where the specific values are located. Since the change is strictly ad61nistrative, it falls under example (i) of Examples of Amendments Not Likely to Involve Significant Hazards Considerations listed in 51FR7751. The change, due to its strictly administrative nature, does not affect the manner of plant operation or the results of any accident evaluated. Therefore, the change does not:
Page 13 of 19 Attachment 1 NRC-89-0052
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Involve a significant reduction in a margin of safety.
C. Change in Tau, coefficients associated with the change from GENESIS methods to the NRC approved GEMINI methods.
- 1. The change to the GEMINI methods requires that the Option B scram time (Taug) coefficients be changed to the approved values for these methods. Both coefficients l (the mean and standard deviation) are nodified to the NRC approved values for the GEMINI methods. It accomplishes the same purpose as the previous coefficients and therefore does not increase the probability or consequences of an accident previously evaluated.
- 2. The mode of plant operation does not change due to the new GEMINI Option B scram time (Tau g ) coefficients nor does this change result in any modifications to the Fermi 2 facility; therefore, this change does not create the possibility of a new or different kind of accident than previously evaluated.
- 3. Modifying the scram time (Tau,) coeMcienu maMahs the margin of safety established by the current limit.
Both the GENESIS and GEMINI methodologies ha7e received previous NRC approval. Therefore, this change does not involve a reduction in the margin of safety. D. New linear heat generation rate (LHGR) limit for the GE8X8EB extended burnup fuel bundles of 14.4 kW/ft.
- 1. The LHGR limit is established to maintain fuel integrity.
The LHGR limit for the BC3? BD and BC318E bundles has been approved generically by the NRC and provides reliability similar to that of the fuel being removed from service. Since the reliability of the fuel is unchanged this change does not involve an increase in the probability of occurrence or consequences of an accident previously evaluated.
- 2. The mode of plant operation does not change due to the LHGR limits nor does this change result in modifications
- . _ _ , _ _ _ _ - _ _ _ . . _ _ _ + _ _ _ _ _ _ . _ . _ _ _ _ .
I l i Page 14 of 19 j Attachment 1 NRC-89-0052 l l to the Fermi 2 facility; therefore, this change does not 1 create the possibility of a new or different kind of accident than previously evaluated. d l 3. The NRC approved acceptance criteria described in GESTAR I established the margins of safety for fuel. Calculations ! using NRC models described in GESTAR yield results well within these acceptance criteria. Therefore, the proposed amendment does not involve a reduction in the margin of safety. E. Use of new NRC approved fuel designs. i
- 1. This change requires that all fuel loaded into Fermi 2 meet NRC approved criteria when analyzed with NRC approved methods. NRC review and approval of the criteria and methods is specifically intended to preclude any increase in the probability of occurrence or consequences of an accident previously analyzed. Any methods or criteria change which could result in such an increase would receive generic NRC approval prior to use in Fermi 2. Further, any specific application at Fermi 2 of generically approved fuel design would receive NRC review and approval at that time.
- 2. NRC review and approval of the criteria and methods is specifically intended to preclude the creation of the possibility of a new or different kind of accident from any previously evaluated. Any change which could create such a possibility would be evaluated generically prior to use in Fermi 2.
- 3. NRC review and approval of the criteria and methods is specifically intended to preclude a significant reduction in the margin of safety. Any change which could include a significant reduction in the margin of safety would receive generic approval prior to application.
F. New Kf Curve for the change to the GEXL-PLUS correlation and generalization of the definition of the Critical Power Ratio.
- 1. The change in K f results in a corresponding change in MCPR limits. The probability of an accident will not be affected by the change in MCPR limits. The new limits are more conservative than those they replace. The consequences of an accident will therefore be unaffected or less severe.
- 2. The mode of plant operation does not change due to the l
Page 15 of 19 j Attachment 1 4 NRC-89-0052 1 l MCPR limit nor does the MCPR limit change result in any modifications to the Fermi 2 facility; therefore, this change does not create the possibility of a new or different kind of accident than previously evaluated. ,
- 3. The new limits are more conservative than those they replace; therefore, any change in margin of safety would be to increase it.
The change in the definition of Critical Power Ratio from the GEXL correlation to the use of an NRC approved critical power correlation is made to reflect the use of the NRC approved GEXL-PLUS correlation in the Cycle 2 analysis. This change also allows the use of any future correlations which may receive NRC approval; however, any specific application of such correlations must still receive prior NRC approval. Thus, this change is strictly an administrative change made to preclude unnecessary future changes to this definition. As such the change falls under example (i) of Examples of Amendments Not Likely to Involve Significant Hazards Considerations listed in 51FR7751. The change, due to its strictly administrative nature, does not affect the manner of plant operation or the results of any accident evaluated. Therefore, the change does not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Involve a significant reduction in a margin of safety.
G. Incorporate new exposure dependent Operating Limit MCPRs.
- 1. Use of new exposure dependent Operating Limit MCPRs does not affect the initiating event of any accident and therefore the probability of an accident occurrence is not increased. The new operating MCPR limits were calculated using NRC approved methods and satisfy NRC approved criteria which are similar to the methods and criteria used to establish the Cycle 1 limits. Thus the exposure dependent MCPR curves do not involve an increase in the consequences of an accident previously evaluated.
- 2. The mode of plant operation does not change due to the MCPR limits nor does the MCPR limit change result in any modification to the Fermi 2 facility; therefore, these
Page 16 of 19 Attachment 1 NRC-89-0052 changes do not create the possibility of a different type of accident than previously evaluated.
- 3. The methods used to determine the Cycle 2 operating limits are substantially the same as those used to determine the Cycle 1 limits. The exposure dependent operating MCPR limits were calculated according to the same criteria used to determine the Cycle 1 MCPR limits and maintain the same margin of safety.
H. Incorporate MCPR Operating Limit for use in Control Cell Core (CCC) Operational Mode and associated Surveillance Requirements. An additional Rod Withdrawal Error (RWE) Analysis was performed for the CCC operational mode. This condition is expected to exist throughout Cycle 2. The CCC operational mode include all A2 sequence control rods, Al sequence shallow rods (inserted less than or equal to notch position 36), all peripheral rods, and rods inserted at position 46. This MCPR safety limit is applicable only following completion of the proposed Surveillance Requirement 4.2.3.2 which verifies that the control Cell Core conditions are satisfied. Normal control rod operability checks, coupling checks, scram time testing, and friction testing of non-CCC control rods does not require the utilization of the more restrictive non-CCC operational mode MCPR limits. For operability and coupling checks control rods are intentionally inserted and withdrawn by one or two notch increments. The reactivity change associated with this small amount of rod movement is below analytical concerns. For friction and scram time testing of non-CCC control rods, the withdrawal of the i inserted non-CCC rod is not of concern because the immediate withdrawal of the rod just inserted can only return the core to the previous operating state. The only rods which may be inadvertently withdrawn are CCC mode rods. The inadvertent withdrawal of any of these rods was analyzed with the RWE analysis. This analysis is based upon limiting control rod patterns chosen from all possible rod patterns, not just CCC j operational mode patterns. Therefore, the use of the more i restrictive non-CCC operational mode MCPR limit is not ! required.
- 1. The new MCPR operating limit for this additional case involves no plant changes and no change in the manner of plant operation except that the operating Limit MCPR is lowered to reflect the CCC operational mode. Since the RWE analysis ensures that the consequences of the RWE
.9 , . Page 17 of 19 Attachment 1-NRC-89-0052 remains. within -required limits and the .RWE is the limiting consideration ~ in _ establishing the' Operating Limit MCPRs, the consequences of previously evaluated accidents are unchanged. In the CCC operational mode this operating limit satisfies the same criteria as the Cycle 1 operating MCPR limits and the consequences of any accident will not be increased. The value of the Operating Limit MCPR will not affect the probability of an accident. The proposed Surveillance Requirement 4.2.3.2 provides adequate assurance that this Operating - Limit MCPR value. will . not be misapplied. Therefore,_the probability of any evaluated accident is unchanged.
- 2. There are no facility . changes and the only change in operation is the reduction of the Operating MCPR limits.
This change in limits will not create the' possibility of a different kind of accident than previously evaluated.
- 3. The margin of safety.is unaffected since the change is based on an RWE analysis which' ensures that the margin to boiling transition. is unchanged. The proposed Surveillance Requirement 4.2.3.2 enhances the margin of safety by providing assurance that the CCC mode MCPR limits are properly applied. The margin of safety for the RWE is maintained for CCC operation at the same level as for non-CCC operation in Cycle 1.
I. Change in licensed rated thermal power from 3292 MWT to 3293 MWT to reflect the actual analyzed design power.
- 1. The probability of an accident will not be affected by the rated thermal power change from 3292 MWT to 3293 MWT since the manner of plant operations does not change.
The revised rated thermal power reflects the true analyzed condition of the plant. The consequences of an. accident will therefore be unaffected.
- 2. The manner of plant operation does not change due to the rated thermal power nor does this change result in any modifications to the Fermi 2 facility; therefore, this change does not create the possibility of a new or different kind of accident than previously evaluated.
- 3. The revised rated thermal power reflects the true analyzed condition of the plant and therefore no change in margin of safety is possible. The margin of safety 1 for the revised rated thermal power is the same as was
)
Page 18 of 19 Attachment 1 NRC-89-0052 l analyzed in Cycle 1. l J. Replacement of the GNWS. method with the BPWS method
\.
- 1. Implementing the Banked Position Withdrawal ' Sequence (BPWS) method involves no plant' changes and only . the -
sequence of rod withdrawal.-is affected. Both the Group Notch Withdrawal Sequence (GNWS) and the BPWS method will mitigate the consequences of a control rod drop accident-(CRDA). The BPWS will further. reduce the worth of the strongest worth control rod dropping out of the core. The consequences of a potential control rod drop accident with eight inoperable rods are either unchanged 'or. reduced.- Surveillance Requirement 4.1. 4.1.d has been modified to provide additional assurance that .the RWM will be properly loaded and the BPWS properly; enforced. The initiating scenario for a CRDA is one caused by a mechanical malfunction of the. control rod and its drive mechanism. . The BPWS withdrawal sequence change has no effect upon the mechanical performance of the control rod or its drive mechanism. Therefore, the probability of a CRDA is unchanged.
- 2. There are no facility changes and the only' change in operation is the change in the withdrawal sequence. This change will not create the possibility of a new or different kind of accident than previously evaluated.
- 3. The additional restriction of BPWS further reduces the worth of the strongest control rod from dropping out of the core. Additional assurance is also provided with the verification that the BPWS is properly loaded in the RWM and enhances the margin of safety. The margin of safety for the' control rod drop accident with eight inoperable rods is the same level or better than in Cycle 1.
For'each of the proposed Technical Specification changes, it has been demonstrated that the criteria of 10CFR50.92 are satisfied, and so it is judged that no significant hazards considerations exist. ENVIRONMENTAL IMPACT Detroit Edison Company has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for i environmental considerations. As shown above, the proposed changes do not involve a significant hazards consideration, nor increase __ _____________J
Page 19 of 19 Attachment 1 NRC-89-0052 the types and amounts of effluent that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit 2dison concludes that the proposed Technical Specification changes meet the criteria given in 10CFR51.22 (c) (9) for a categorical exclusion from the requirement for an. Environmental Impact Statement. CONCLUSION Based on the evaluation above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the proposed amendments will not be inimical to the common defense and security or to the health and safety of the public. These Technical Specification changes reflect the results of transient and accident analyses for Reload 1, Cycle 2. The reload design was performed by GE Nuclear Energy with the NRC approved met hodology described in GESTAR. The proposed Technical Specification changes ensure the plant conditions remain within the bounds of the initial conditions of the analyses. Detroit Edison therefore believes that this proposal is acceptable and requests prompt consideration and approval. These changes are requested to be effective upon startup from Fermi 2's first refueling outage. 1 i l _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . . _ __ __ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . . ___.__.__________________J}}