RS-22-028, Supplement to Request to Expand Applicability of Prime Methods to Evaluate Fuel Centerline Melt and Cladding Strain Compliance for Framatome Fuel at Quad Cities

Supplement to Request to Expand Applicability of Prime Methods to Evaluate Fuel Centerline Melt and Cladding Strain Compliance for Framatome Fuel at Quad Cities

ML22075A212
Person / Time
Site:	Quad Cities
Issue date:	03/16/2022
From:	Simpson P Constellation Energy Generation
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-22-028
Download: ML22075A212 (7)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office 10 CFR 50.90 RS-22-028 March 16, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Supplement to Request to Expand Applicability of PRIME Methods to Evaluate Fuel Centerline Melt and Cladding Strain Compliance for Framatome Fuel at Quad Cities

References:

1. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Request to Expand Applicability of PRIME Methods to Evaluate Fuel Centerline Melt and Cladding Strain Compliance for Framatome Fuel at Quad Cities," dated January 20, 2022 (ML22020A398 (prop) / ML22020A399 (non-prop))

2. Letter from R. Kuntz (U.S. NRC) to D.P. Rhoades (Constellation Energy Generation, LLC), "Quad Cities Nuclear Power Station, Units 1 and 2 -

Supplemental Information Needed for Acceptance of Requested Licensing Action Re: Amendment to Implement Prime Methodologies for Evaluating Thermal Overpower and Mechanical Overpower Limits for Non-Global Nuclear Fuels Fuel (EPID L-2022-LLA-0014)," dated March 1, 2022 (ML22059A990)

In the Reference 1 letter, Exelon Generation Company, LLC (EGC) requested an amendment to Renewed Facility Operating License Nos. DPR-29 for Quad Cities Nuclear Power Station (QCNPS), Unit 1 and DPR-30 for QCNPS, Unit 2. Subsequently, the Quad Cities facility operating licenses were transferred to Constellation Energy Generation, LLC (CEG). The proposed change requests permission to apply the PRIME nuclear fuel thermal-mechanical analysis methods to non-GNF fuel by adding a report that supplements the analysis methodologies included in General Electric Standard Application for Reactor Fuel (GESTAR) to TS 5.6.5, "Core Operating Limits Report (COLR)," paragraph b.

March 16, 2022 U.S. Nuclear Regulatory Commission Page 2 In response to Reference 2, supplemental information is being provided to support the NRC's review of the CEG licensing request dated January 20, 2022. Attachment 1 provides the response to the request for supplemental information. Attachment 2 provides an updated markup of the proposed addition to TS 5.6.5, which is revised in response to the request for supplemental information. Attachment 2 supersedes the TS 5.6.5 mark-up provided in Reference 1 in its entirety.

CEG has reviewed the information supporting the finding of no significant hazards consideration, and the environmental consideration that were previously provided to the NRC in Reference 1.

The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

CEG is notifying the State of Illinois of this supplement to a previous application for a change to the operating license by sending a copy of this letter and its attachments to the designated State Official in accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b).

There are no regulatory commitments contained within this letter.

Should you have any questions concerning this letter, please contact Ms. Rebecca L. Steinman at (630) 657-2831.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 16th day of March 2022.

Respectfully, Patrick R. Simpson Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:

1. Response to NRC Acceptance Review Results and Sufficiency Items

2. Mark-up of QCNPS, Units 1 and 2 Technical Specifications Page cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector, Quad Cities Nuclear Power Station NRC Project Manager, Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Response to NRC Request for Supplemental Information

1. In Section 1 of Attachment 1 to the January 20, 2022 (Agencywide Document Access and Management System (ADAMS) Package Accession No. ML22020A398), license amendment request for Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities),

stated that the proposed methodology would be used as an alternative to or in conjunction with the currently approved approach of using overpower limits as provided by the non-Global Nuclear Fuels (GNF) fuel manufacturing vendor. Meanwhile, the U.S. Nuclear Regulatory Commission (NRC) staff is presently reviewing additional fuel thermal-mechanical limits contained in ANP-3198P, Revision 0, ATRIUM 10XM Fuel Rod Thermal-Mechanical Evaluation with RODEX2A for Quad Cities and Dresden, in concert with a license amendment requested by letter dated September 14, 2021 (ADAMS Package Accession No. ML21257A419).

a. It is not clear whether currently approved approach would include that described in ANP-3198P, or whether approval would be needed for the thermal-mechanical limits provided in ANP-3198P to approve those described in Report 006N8642-P, Justification of PRIME Methodologies for Evaluating TOP [Thermal Overpower] and MOP

[Mechanical Overpower] Compliance for non-GNF Fuels. Explain whether limits developed using the methods and empirical basis in Report 006N8642-P require the use of the limits described in ANP-3198P, e.g., potentially as input.

b. The January 20, 2022, request, states that Report 006N8642-P would be used as an alternative to or in conjunction with the currently approved approach of using overpower limits. Explain how the report and the methods described therein would be used in either case, in a level of detail that would support a comparison of the RLA to existing processes for developing thermal-mechanical limits for the fuel.

CEG Response to Question 1a The phrasing currently approved approach in the license amendment request dated January 20, 2022, refers to the already approved Method #2 for fast transients, as defined in GNF topical report NEDC-33840P-A Revision 1 (see ADAMS accession no. ML17230A012 for the non-proprietary version). In this NRC-approved approach, GNF is allowed to use overpower limits provided by the non-GNF fuel vendor to show compliance to the no fuel melting and cladding strain criterion. Using this approach for a Quad Cities transition core, the overpower limits would be provided by Framatome using their own NRC-approved methods.

The CEG License Amendment Request (LAR) associated with this request for supplement is requesting a change in methodology that would allow GNF to use PRIME to directly evaluate compliance to the no fuel melting and cladding strain criterion instead of the non-GNF vendor supplied limits, which is considered the "currently approved approach" described above. The details of how the non-GNF vendor prepares the limits that get supplied to GNF is outside of the scope of this methodology change request. Therefore, there is no linkage between the GNF method change request and ANP-3198P, which describes how Framatome would prepare overpower limits for the co-resident ATRIUM 10XM fuel.

ATTACHMENT 1 Evaluation of Proposed Changes CEG Response to Question 1b The phrasing as an alternative to in the license amendment request dated January 20, 2022, refers to using the methods described in GNF report 006N8642-P Revision 1 as opposed to using the already approved methods described in topical reports NEDC-33840P-A Revision 1 and NEDC-33256P-A Revision 2. The wording in conjunction with was used to allow for using 006N8642-P Revision 1 and/or NEDC-33840P-A Revision 1 (combined or separately). That wording also ensures that the approval of 006N8642-P Revision 1 does not eliminate the already approved approach of using non-GNF overpower limits to show thermal overpower (TOP) / mechanical overpower (MOP) compliance (i.e., Method #2) per NEDC-33840P-A Revision 1.

In summary, the currently approved methodology in NEDC-33840P-A Revision 1 allows GNF to use PRIME to show compliance to fast transients for non-GNF fuel, given the non-GNF fuel vendor provides overpower limits. The methodology described in 006N8642-P Revision 1 allows GNF to calculate TOP / MOP limits directly for non-GNF fuel and to show compliance to the no fuel melting and cladding strain criterion for fast transients directly (i.e., Method #1 per NEDC-33840P-A Revision 1). Neither of these methods require the Framatome limits to be calculated as described in ANP-3198P (or any specific method for that matter); therefore, there is no linkage between this GE/GNF related method change request and the Framatome-related request in the license amendment request letter dated September 14, 2021 (ADAMS Package Accession No. ML21257A419).

2. While 006N8642-P appears to provide a basis for determining the mechanical and thermal overpower limits for CWSR Zircaloy-2 fuel, the demonstration included in Chapter 4 is for an unspecified plant, meaning that it is unclear whether the analyses demonstrate compliance with the applicable design limits for Quad Cities using the methodology. Justify the applicability of the analysis included in Chapter 4 or provide an analysis and set of mechanical and thermal overpower limits that are based on Quad Cities.

CEG Response to Question 2 The calculation provided in Section 4.3 of 006N8642-P Revision 1 was provided as a sensitivity study to show the relative impact of the irradiation growth and creep models proposed for use in PRIME for Cold Work Stress Relieved (CWSR) Zircaloy-2 relative to the currently approved (per NEDC-33256P-A Revision 2) Zircaloy-2 models. The four cases analyzed were chosen to systematically show the impact of each model individually, and the models collectively, in evaluating the no fuel melting and cladding strain criterion. GNF report 006N8642-P Revision 1 is a proposed methodology to be used to show compliance; as such, Section 4.3 was not intended to be a compliance demonstration calculation nor to establish overpower limits. The methodology defined in 006N8642-P Revision 1, if approved, will be used to show compliance to the no fuel melting and cladding strain criterion for the QCNPS Unit 1 and 2 cycle-specific transients identified.

The sensitivity study performed in Section 4.3 was based on the Dresden Nuclear Power Station (DNPS) Unit 3 Cycle 28 mock reload analysis, which is a transition analysis with resident ATRIUM 10XM and fresh GNF3 fuel bundles. A mock reload analysis is a scoping Page 3

ATTACHMENT 1 Evaluation of Proposed Changes study which goes through the typical reload licensing process (RLP) to identify potential problems and develop solutions prior to performing a licensed reload analysis. The transient for which results are shown in Figure 4-3 (inadvertent start-up of the High-Pressure Coolant Injection (HPCI) system) was determined from the mock reload to be the most limiting anticipated operational occurrence (AOO) transient in terms of showing compliance to the no fuel melting and cladding strain criterion. Other AOOs that were analyzed, but shown to be less limiting, included Feedwater Controller Failures (FWCF), Load Rejection No Bypass (LRNBP) and Turbine Trip No Bypass (TTNBP). Given the similarities between DNPS Unit 3 and the QCNPS Units 1 and 2 (all BWR/3 rated at 2,957 MWt), the results of this analysis and the sensitivity study performed in Section 4.3 are concluded to be reasonably representative of Quad Cities.

3. The amendment request proposed a change to Quad Cities Technical Specification (TS) 5.6.5.b to add a core operating limit report (COLR) reference to Report 006N8642-P. The guidance provided in NRC Generic Letter 88-16, Removal of Cycle-Specific Parameter Limits from Technical Specifications (ADAMS Accession No. ML031130447), recommends that the NRC staff safety evaluation (SE) for a plant-specific methodology by NRC letter and date be included in the citation of plant-specific methodology. This formatting would also be consistent with TS 5.6.5 and the guidance provided in NUREG-1433, Revision 5, Standard Technical Specifications - General Electric BWR [boiling-water reactor]/4 Plants. Therefore, describe how the proposed TS change would ensure that the NRC staff SE is considered in COLR revisions or revise the citation similar to the following (as underlined):

006N8642-P, Revision 1, Justification of PRIME Methodologies for Evaluating TOP and MOP Compliance for non-GNF Fuels, January 2022, as approved by NRC staff SE dated XXX XX, 20XX.

CEG Response to Question 3 A revised mark-up of the proposed Technical Specification 5.6.5.b citation for GNF report 006N8642-P Revision 1 that includes a cross-reference to the NRC Safety Evaluation (SE) is provided in Attachment 2. The date placeholders (XXX XX, 20XX) will be replaced with the appropriate date corresponding to the SE at the time of issuance. Consistent with the prior mark-up that is being superseded by Attachment 2 of this submittal, the attached mark-up reflects the combined effect of the proposed changes previously submitted to the NRC as to RS-21-113, dated November 3, 2021 (ADAMS Accession No. ML21307A444).

Page 4

ATTACHMENT 2 QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-254 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 MARK-UP OF QCNPS, UNITS 1 AND 2 TECHNICAL SPECIFICATIONS PAGE

Note: Items within the cloud are pending changes associated with the GNF3 Transition amendment request. See ML21307A444 for additional details. Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

18. EMF-2292 (P)(A) Revision 0, "ATRIUMTM-10: Appendix K Spray Heat Transfer Coefficients," Siemens Power Corporation, September 2000.

19. ANF-1358(P)(A) Revision 3, "The Loss of Feedwater Heating Transient in Boiling Water Reactors," Framatome ANP, September 2005.

20. EMF-CC-074(P)(A) Volume 4 Revision 0, "BWR Stability Analysis: Assessment of STAIF with Input from MICROBURN-B2," Siemens Power Corporation, August 2000.

21. NEDC-33930P Revision 0, "GEXL98 Correlation for ATRIUM 10XM Fuel," February 2021.

The COLR will contain the complete identification for each of the TS referenced topical reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements).

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Post Accident Monitoring (PAM) Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

22. 006N8642-P, Revision 1, "Justification of PRIME Methodologies for Evaluating TOP and MOP Compliance for non-GNF Fuels," January 2022, as approved by the NRC SE dated XXX XX, 20XX.

Quad Cities 1 and 2 5.6-5 Amendment No. 264/259