ML22347A241

Issuance of Amendment Nos. 294 and 290 Control Rod Scram Times (Public) -

ML22347A241
Person / Time
Site:	Quad Cities
Issue date:	02/06/2023
From:	Robert Kuntz NRC/NRR/DORL/LPL3
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
Shared Package
ML22347A240	List: ML22347A241
References
EPID L-2022-LLA-0014
Download: ML22347A241 (1)

Text

OFFICIAL USE ONLY PROPRIETARY INFORMATION February 6, 2023 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 294 AND 290 RE: EXPANDED APPLICABILITY OF PRIME METHODS (EPID L-2022-LLA-0014)

Dear Mr. Rhoades:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 294 to Renewed Facility Operating License No. DPR-29 and Amendment No.

290 to Renewed Facility Operating License No. DPR-30 for Quad Cities Nuclear Power Station, Units 1 and 2, respectively. The amendments consist of changes to the technical specifications (TSs) in response to your application dated January 20, 2022, as supplemented by letters dated March 16, 2022, and August 10, 2022.

The amendments revise Technical Specification 5.6.5, Core Operating Limits Report (COLR) paragraph b, to add Report 0006N8642-P, Revision 1, Justification of PRIME Methodologies for Evaluating TOP [Thermal Overpower] and MOP [Mechanical Overpower] Compliance for non-GNF [Global Nuclear Fuel] Fuels, January 2022.

Enclosure 3 to this letter contains sensitive unclassified non-safeguards information. When separated from Enclosure 3, this document is DECONTROLLED.

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION D. Rhoades A copy of the safety evaluation is also enclosed. The Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Robert F. Kuntz, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265

Enclosures:

1. Amendment No. 294 to DPR-29

2. Amendment No. 290 to DPR-30

3. Proprietary Safety Evaluation

4. Non-Proprietary Safety Evaluation cc w/encls: Listserv OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION CONSTELLATION ENERGY GENERATION, LLC AND MIDAMERICAN ENERGY COMPANY DOCKET NO. 50-254 QUAD CITIES NUCLEAR POWER STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 294 Renewed License No. DPR-29

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Constellation Energy Generation, LLC (the licensee) dated January 20, 2022, as supplemented by letters dated March 16, 2022, and August 10, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1 OFFICIAL USE ONLY PROPRIETARY INFORMATION

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 3.B. of Renewed Facility Operating License No. DPR-29 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 294, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: February 6, 2023

OFFICIAL USE ONLY PROPRIETARY INFORMATION CONSTELLATION ENERGY GENERATION, LLC AND MIDAMERICAN ENERGY COMPANY DOCKET NO. 50-265 QUAD CITIES NUCLEAR POWER STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 290 Renewed License No. DPR-30

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Constellation Energy Generation, LLC (the licensee) dated January 20, 2022, as supplemented by letters dated March 16, 2022, and August 10, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2 OFFICIAL USE ONLY PROPRIETARY INFORMATION

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 3.B. of Renewed Facility Operating License No. DPR-30 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 290 are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: February 6, 2023 OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION ATTACHMENT TO LICENSE AMENDMENT NOS. 294 AND 290 RENEWED FACILITY OPERATING LICENSE NOS. DPR-29 AND DPR-30 QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265 Replace the following pages of the Renewed Facility Operating Licenses and Appendix A, Technical Specifications, with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Remove Insert License DPR-29 License DPR-29 Page 4 Page 4 License DPR-30 License DPR-30 Page 4 Page 4 TSs TSs 5.6-5 5.6-5 OFFICIAL USE ONLY PROPRIETARY INFORMATION

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 294, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

C. The licensee shall maintain the commitments made in response to the March 14, 1983, NUREG-0737 Order, subject to the following provision:

The licensee may make changes to commitments made in response to the March 14, 1983, NUREG-0737 Order without prior approval of the Commission as long as the change would be permitted without NRC approval, pursuant to the requirements of 10 CFR 50.59. Consistent with this regulation, if the change results in an Unreviewed Safety Question, a license amendment shall be submitted to the NRC staff for review and approval prior to implementation of the change.

D. Equalizer Valve Restriction Three of the four valves in the equalizer piping between the recirculation loops shall be closed at all times during reactor operation with one bypass valve open to allow for thermal expansion of water.

E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined sets of plans1, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: Quad Cities Nuclear Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 2, submitted by letter dated May 17, 2006.

Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The CSP was approved by License Amendment No. 249 as modified by License Amendment No. 259.

1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Renewed License No. DPR-29 Amendment No. 294

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 290, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

C. The licensee shall maintain the commitments made in response to the March 14, 1983, NUREG-0737 Order, subject to the following provision:

The licensee may make changes to commitments made in response to the March 14, 1983, NUREG-0737 Order without prior approval of the Commission as long as the change would be permitted without NRC approval, pursuant to the requirements of 10 CFR 50.59. Consistent with this regulation, if the change results in an Unreviewed Safety Question, a license amendment shall be submitted to the NRC staff for review and approval prior to implementation of the change.

D. Equalizer Valve Restriction Three of the four valves in the equalizer piping between the recirculation loops shall be closed at all times during reactor operation with one bypass valve open to allow for thermal expansion of water.

E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans1, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: Quad Cities Nuclear Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 2, submitted by letter dated May 17, 2006.

Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The CSP was approved by License Amendment No. 244 and modified by License Amendment No. 254.

1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Renewed License No. DPR-30 Amendment No. 290

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, as approved by NRC Staff SE dated December 15, 2022.

22. 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 February 6, 2023. .

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.

Quad Cities 1 and 2 5.6-5 Amendment No. 294/290

OFFICIAL USE ONLY PROPRIETARY INFORMATION ENCLOSURE 3 PROPRIETARY SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 294 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-29 AND AMENDMENT NO. 290 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-30 CONSTELLATION ENERGY GENERATION, LLC AND MIDAMERICAN ENERGY COMPANY QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265 All proprietary text in the safety evaluation is bolded and enclosed within double brackets

((sensitive text)).

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION ENCLOSURE 4 NON-PROPRIETARY SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 294 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-29 AND AMENDMENT NO. 290 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-30 CONSTELLATION ENERGY GENERATION, LLC AND MIDAMERICAN ENERGY COMPANY QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265 OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION NON-PROPRIETARY SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 294 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-29 AND AMENDMENT NO. 290 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-30 CONSTELLATION ENERGY GENERATION, LLC AND MIDAMERICAN ENERGY COMPANY QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265

1.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) January 20, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22020A399), as supplemented by letters dated March 16, 2022 (ML22075A212) and August 10, 2022 (ML22222A101), Exelon Generation Company, LLC requested changes to the technical specifications (TSs), for the Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities). The license amendment request (LAR) proposed changes would revise TS 5.6.5, Core Operating Limits Report (COLR), paragraph b, to add Report 006N8642-P, Revision 1, Justification of PRIME Methodologies for Evaluating TOP [Thermal Overpower] and MOP

[Mechanical Overpower] for non-GNF [Global Nuclear Fuels] Fuels, (006N8642-P). On February 1, 2022, Exelon became Constellation Energy Generation, LLC (the licensee)

(ML22032A333).

The supplemental letter dated August 10, 2022, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on July 12, 2022 (87 FR 41360).

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2.0 REGULATORY EVALUATION

2.1 Description of Proposed Changes Constellation is transitioning from using Framatome ATRIUM 10XM fuel and associated safety analysis methods to Global Nuclear Fuels (GNF) GNF3 fuel and the associated safety analysis methods described in the General Electric Standard Application for Reload Fuel (GESTAR-II),

which is documented in the NRC-approved topical report NEDE-24011P-A, Revision 30, dated April 4, 2020 (ML20104C087). The PRIME methodologies are incorporated into NEDE-24011P-A, and are described in the NRC-approved topical reports, NEDC-33256P The PRIME Model for Analysis of Fuel Rod Thermal - Mechanical Performance Part 1 - Technical Bases NEDC-33257P, The PRIME Model for Analysis of Fuel Rod Thermal - Mechanical Performance Part 2 - Qualification, and NEDC -33528P, The PRIME Model for Analysis of Fuel Rod Thermal - Mechanical Performance Part 3 - Application Methodology, Revision 2, October 2021 (ML21279A280). Although the safety analysis methods used to determine core operating limits for GNF3 fuel are included in NEDE-24011P-A, including the PRIME methodology, and already referenced in the Quad Cities TS, the PRIME methodology is not approved for use by the NRC staff to analyze the performance of Framatome fuel.

Quad Cities TS 5.6.5.b contains a list of analytical methods used to determine the core operating limits. The licensee is proposing to add a new report to TS 5.6.5.b to support the transition to GNF3 fuel. The new report is identified as follows:

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 February 6, 2023.

2.2 Regulatory Requirements Section 182a of the Atomic Energy Act (AEA) of 1954, as amended, requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The NRC regulatory requirements related to the content of the TS are contained Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, Technical specifications. The regulation in 10 CFR 50.36 requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The regulation requires, in part, that the TSs include items in the following categories: (1) safety limits, limiting safety system settings, and limiting control settings, (2) limiting conditions for operation, (3) surveillance requirements, (4) design features, and (5) administrative controls. The regulation 10 CFR 50.36(c)(5) describes administrative controls as the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

The fuel system safety review, including the fuel thermal-mechanical analysis, provides assurance that the fuel system is not damaged as a result of normal operation and anticipated operational occurrences (AOOs).

The regulatory requirements applicable to the fuel thermal-mechanical limits are based on General Design Criterion (GDC) 10, Thermal Hydraulic System Design, contained in appendix A, General Design Criteria for Nuclear Power Plants, to Part 50, Domestic Licensing of Production and Utilization Facilities (10 CFR 50, appendix A). However, the Quad Cities units were licensed prior to the promulgation of these criteria and hence meet the intent of the draft OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION Principal Design Criteria published in 1967 by the Atomic Energy Commission, as discussed in Chapter 3 of the Quad Cities Updated Final Safety Analysis Report (UFSAR). Therefore, the review is based on the criteria contained section 3.1.2 of the Quad Cities UFSAR (ML22049A114). Specifically, the NRC staff considered Criterion 6, Reactor Core Design, which states:

The reactor core shall be designed to function throughout its design lifetime, without exceeding acceptable fuel damage limits which have been stipulated and justified. The core design, together with reliable process and decay heat removal systems, shall provide for this capability under all expected conditions of normal operation with appropriate margins for uncertainties and for transient situations which can be anticipated, including the effects of the loss of power to recirculation pumps, tripping out of a turbine generator set, isolation of the reactor from its primary heat sink, and loss of all offsite power.

According to the licensees January 20, 2022, submittal, NRC approval would allow the licensee to expand the use of PRIME and its associated methodologies to demonstrate compliance with the fuel melt and cladding strain criteria for Framatome ATRIUM 10XM fuel during the transition to GNF3 fuel. These criteria are among the acceptable fuel damage limits referenced in Quad Cities licensing basis Criterion 6.

2.3 Guidance NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor] Edition, (SRP) section 4.2 Fuel System Design (ML07074002) provides guidance to evaluate fuel damage criteria. The NRC staff uses the review guidance provided in SRP 4.2 to evaluate the acceptability of fuel performance analysis methods like PRIME.

The NRC staffs guidance for the review of TSs is in SRP Chapter 16.0, Technical Specifications, Revision 3, dated March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared standard technical specifications (STS) for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with boiling water reactor (BWR) STS NUREG-1433, General Electric Plants, BWR/4, (ML21272A357).

Regulatory Guide (RG) 1.236, Pressurized-Water Reactor Control Rod Ejection and Boiling-Water Reactor Control Rod Drop Accidents (ML20055F490) describes methods and procedures that the staff of the NRC considers acceptable when analyzing the initial response to a postulated control rod ejection accident for pressurized-water reactors (PWRs) and a postulated control rod drop accident for BWRs. Although this RG is not directly applicable to fuel performance evaluations, it contains a material property correlation (i.e., hydrogen uptake) that applies generally to BWR fuel and was referenced by the licensee in its submittal, as discussed in section 3.3 of this safety evaluation (SE).

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3.0 TECHNICAL EVALUATION

3.1 Introduction The PRIME methodology is approved for use to model the thermal-mechanical performance of BWR fuel. Section 4.0 of the NRC staff SE finding PRIME acceptable, which is included in NEDC-33256P-A, provides conditions and limitations for the NRC staffs approval. The PRIME methodology has been incorporated into GESTAR-II, which is referenced in the Quad Cities TS and incorporated into the Quad Cities licensing basis. Therefore, the scope of the present review is for the acceptability of using PRIME to generate thermal and mechanical overpower (TOP and MOP, respectively) limits for Framatome fuel.

This plant-specific review is necessary because applying NEDC-33256P-A to Framatome fuel would be inconsistent with Limitation 1 of the PRIME approval SE, ((

)).

In order to apply PRIME to Framatome fuel, the licensee addressed three main topics. First, the licensee provided updates to the PRIME methodology to determine TOP limits for Framatome fuel. This material included additional justification to support application of the PRIME correlation for fuel melting temperature to Framatome-fabricated fuel, and updates to the PRIME methods for calculating fuel temperature to accommodate modeling Framatome fuel.

Second, the licensee addressed application of the PRIME methodology to determine MOP limits for Framatome fuel. This material included a review of the limits applied for cladding strain and justification of the application to Framatome fuel, and additional updates to the methods for calculating the cladding strain. Third, the licensee provided updates to and justification for PRIME correlations for irradiation elongation and creep, as these correlations had been specific to (( )). This treatment is specific to the GNF fuel product line, whereas Framatome fuel is cold-worked, stress-relieved cladding.

Section 4 of Report 006N8642P, also demonstrates the application of the updated correlations to Framatome fuel, demonstrating changes in predicted fuel performance for a potentially limiting anticipated operational occurrence.

3.2 Thermal Overpower The limit that is placed on fuel for TOP protection is set forth in GESTAR-II which is currently part of the Quad Cities licensing bases. The criterion is that fuel centerline melting must be precluded for normal operations and under AOOs. The PRIME methodology adopts this acceptance criterion via a proprietary melting temperature correlation for uranium dioxide.

Assurance is provided that the criterion is met by analyzing fuel in a postulated, overpower condition and demonstrating that the fuel temperature does not exceed the melting point. Report 006N8642P provides a justification for application of the existing fuel melt correlation to Framatome fuel and proposed updates to the PRIME overpower analysis methods to suitably model the fuel in a transient overpower condition for Quad Cities.

The fuel melt correlation in the PRIME methodology includes a ((

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)). Regardless of the correlation used, the melt temperature is a material property of uranium dioxide and would not change provided the fuel material remains uranium dioxide, which is the case for both Framatome and GNF fuel. The correlation also provides an offset for gadolinia concentration, which is a burnable absorber used in both fuel designs. Based on the conservative nature of the PRIME fuel melt correlation and its applicability to both GNF and Framatome fuel designs, the NRC staff determined that the fuel melt correlation within PRIME is acceptable for application to Framatome fuel.

To ensure fuel melting is precluded, GNF performs a statistical analysis of an overpower transient ((

)). In this category, fabrication parameter uncertainties are a contributor, and the exact value of those uncertainties for Framatome fuel is Framatome proprietary and hence unknown to GNF. Instead, GNF ((

)). Since these uncertainties represent a small contributor to the overall uncertainty in GNFs approach, the NRC staff determined that this treatment is acceptable for Framatome fuel, especially in view of the overall modeling approach discussed below.

The acceptance criterion applied by GNF precludes fuel melt, meaning the fuel centerline predicted for the transient must be below the melt temperature. In its review, the NRC staff considered several aspects of this analytic method that render it conservative. First, the

(( )) assumption is conservative and non-mechanistic because, for any transient following a credible initiating event, a reactor scram or operator intervention could reasonably be expected to terminate the overpower condition sooner than (( )).

Second, the way that fuel melt leads to cladding failure is that the melt process causes the pellet to expand to an extent that the fuel cladding fails. However, such a failure would not be expected to occur due to a limited amount of fuel melting at the centerline. Therefore, using the fuel melt temperature as an acceptance criterion is also conservative. This conservatism is also applicable to the Framatome fuel, since it is based on the performance and properties of the fuel pellet itself, and both vendors supply uranium dioxide fuel.

The NRC staff considered the above conservatisms, in addition to the minor amount that fabrication parameter uncertainty contributes to the overall uncertainty in the thermal overpower evaluation methods and determined that the approach is acceptable for modeling legacy Framatome fuel in the Quad Cities reactor cores. Therefore, the NRC staff determined that the PRIME thermal overpower evaluation methods provide reasonable assurance that fuel melt is precluded during conditions of normal operation, including allowance for anticipated operational occurrences, consistent with Criterion 6 in the Quad Cities licensing basis.

3.3 Mechanical Overpower A limit on cladding strain is used to preclude a fuel cladding failure due to fuel pellet-cladding mechanical interaction (PCMI). This limit is referred to as the MOP limit. Section 3.0 of 006N8642-P provides a brief discussion of the phenomena associated with the MOP analysis, a OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION justification to apply the current MOP acceptance criterion (a limit on cladding strain) to Framatome fuel, and finally a description of updates to the PRIME methodology and further justification to apply the methodology to Framatome fuel.

As described in section 3.1 of 006N8642-P, the primary driver for cladding straining during an AOO is thermal expansion of the fuel pellet. When the pellet expands in an overpower condition, the cladding yields upon expansion of the uranium oxide (UO2) pellet. The PRIME methodology is used to analyze fuel in an overpower condition in both slow and fast transients to predict the cladding strain resulting from the transient.

This analysis is performed using a worst-tolerance approach where all design and operating parameters that impact calculated cladding strain are placed at their worst-tolerance (i.e., most conservative for the purposes of the strain calculation) limit.

The transient strain limit provided in 006N8642-P, ((

)).

Since (( )) of hydrogen content represents a conservative threshold, below which the fuel cladding would not be so embrittled as to necessitate ((

)), the NRC staff determined that ((

)) in accordance with the PRIME methodology would be acceptable for application to legacy Framatome fuel.

As described above, a conservative analysis is performed of transient cladding strain by placing all design and operating parameters that impact calculated cladding strain at their worst-tolerance values. The specific parameters are listed in Table 2 of NEDC-33258P-A, Revision 2.

Section 3.3 of 006N8642-P identified several of these parameters that are dependent on the fuel design and manufacturing processes and stated that, for manufacturing tolerance inputs that are not available for non-GNF fuel, GNF fabrication parameters would be used.

Additionally, the analysis will ((

)) to account for additional uncertainties associated with non-GNF fuels. In consideration of the design similarities between the fuel types (i.e., both bundle designs are a 10x10 orthogonal fuel matrix), the NRC staff determined that applying a OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION conservative representation based on the GNF fuel fabrication parameters would be acceptable for application to legacy Framatome fuel.

Section 3.3 of 006N8642-P also discussed modeling treatment for corrosion and crud models, which affect predicted cladding strain behavior, and some of which will differ based on the cladding metallurgy. For crud, 006N8642-P stated that the PRIME model ((

)). For oxide, 006N8642-P stated that the ((

))

oxide values would be either provided or confirmed to be appropriate for non-GNF claddings.

Since the PRIME model for crud is (( )), the NRC determined that it is acceptable for application to legacy Framatome fuel.

As to the oxide model, the NRC reviewed available design information concerning the ATRIUM 10XM fuel product in use at Quad Cities, to establish that the licensee has such information available to either ((

)), including notably section 3.2 of ANP-3324P, Revision 1, Fuel Rod Thermal-Mechanical Design Report, which was submitted to the NRC staff to support its review of the transition from Westinghouse to Framatome fuel design and safety analysis at Quad Cities (ML15251A385). Based on this review, the NRC staff determined that licensee has sufficient information available to support this approach, and on that basis, determined that it is acceptable because the licensee will ensure that the existing model can be applied to the Framatome fuel. In summary, the NRC staff determined that application of PRIME methods to address crud and oxide behavior within the cladding strain evaluation, modified as described Section 3.3 of 006N8642-P, is acceptable for application to legacy Framatome fuel.

Based on the review described above, the NRC staff determined that 006N4862-P provided sufficient justification and methodological changes, such that predicted cladding strain for legacy Framatome fuel can be adequately modeled to demonstrate that cladding failures due to PCMI remain precluded. Therefore, the NRC staff determined that the licensee has addressed the requirements of Criterion 6 of the Quad Cities licensing basis acceptably, with respect to fuel cladding failures associated with PCMI.

3.4 Overarching Review Considerations In the review summarized above, the NRC staff considered several factors in determining that the modeling approaches that GNF will apply to Framatome fuel to analyze MOP and TOP limits are acceptable, in consideration of the fact that some information about the legacy Framatome fuel is unknown to GNF, and the model updates for irradiation growth and irradiation creep are based on somewhat qualitative assessments. These included:

The Framatome fuel will be second- and third-cycle fuel. Although second-cycle fuel can be limiting in cases (and the review described above concluded that modeling even potentially limiting fuel is acceptable), as depletion continues, the potential for this fuel to become limiting in an overpower transient will diminish in time. Therefore, the NRC staff did not review, and makes no regulatory finding concerning, the application of PRIME methods for MOP and TOP limit analysis acceptable for fresh Framatome fuel.

The NRC staff confirmed, based on the supplemental letter dated March 16, 2022, that the demonstration analysis provided in section 4.3 of 006N8642-P was performed for a BWR/3 with highly similar plant design characteristics to Quad Cities. Therefore, the NRC staff did OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION not review, and makes no regulatory finding concerning, the application of PRIME methods for MOP and TOP limit analysis for any other facility.

As noted above, the NRC staff determined that the GNF3 and ATRIUM 10XM fuel designs are dimensionally similar, to the extent that both are 10x10 orthogonal fuel pin matrices constrained by the Quad Cities fuel lattice design. The NRC staff did not review, and makes no regulatory finding concerning, the application of PRIME methods for MOP and TOP limit analysis for any other Framatome fuel design, such as ATRIUM 11.

3.5 Evaluation of TS 5.6.5 Change Quad Cities TS 5.6.5.b contains a list of analytical methods used to determine the core operating limits. The licensee is proposing to add a new report to TS 5.6.5.b to support the transition to GNF3 fuel. The new report, 006N8642-P, documents the expansion of the applicability of using PRIME and its associated methodologies to demonstrate that non-GNF fuel complies with the acceptance criteria for fuel melt and cladding strain.

The NRC staff reviewed the technical acceptability of the new report as discussed above in SE, sections 3.1 through 3.5, and found it acceptable. The NRC staff also reviewed the proposed TS changes for technical clarity and consistency with the existing guidance for customary terminology and formatting. The NRC staff concludes that the proposed change to Quad Cities TS 5.6.5.b is consistent with the guidance provided in Chapter 16.0 of the SRP and NUREG-1433 with respect to identifying COLR analytical methods. Based on the discussion above, the NRC finds that the new report added to TS 5.6.5.b is acceptable because it is consistent with guidance and helps to assure operation of the facility in a safe manner and, therefore, 10 CFR 50.36(c)(5) requirements continue to be met.

3.6 Technical Conclusion Based on the above review, the NRC staff determined that Constellations request to apply the PRIME methodology for MOP and TOP analysis for legacy Framatome fuel is acceptable.

Such analyses will provide reasonable assurance that fuel cladding failures are precluded under conditions of normal operation and anticipated operational occurrences, specifically postulated overpower conditions, as a result of fuel melt or PCMI, consistent with Quad Cities licensing basis Criterion 6. Therefore, the NRC staff determined that the licensees proposal to incorporate a reference to 006N8642-P into the Quad Cities TS as a reference used to determine core operating limits is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations the Illinois State official was notified of the proposed issuance of the amendment on January 11, 2023. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the requirements with respect to installation or use of a facilitys components located within the restricted area as defined in 10 CFR part 20. The NRC staff has determined that the amendments involve 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 OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding July 12, 2022 (87 FR 41360). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 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) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Benjamin Parks, NRR Date of Issuance: February 6, 2023 OFFICIAL USE ONLY PROPRIETARY INFORMATION

ML22347A240 (Package)

ML22347A234 (Non-Public)

ML22347A241 (Public)

OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR//DSS/STSB/BC NRR/DSS/SFNB NAME RKuntz SRohrer VCusumano SKrepel DATE 12/13/2022 12/14/2022 12/19/2022 11/28/2022 OFFICE OGC NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME BAyersman NSalgado RKuntz DATE 1/17/2023 2/6/2023 2/6/2023