RS-03-242, Supplemental Information for Technical Specifications Change for Minimum Critical Power Ration Safety Limit

Supplemental Information for Technical Specifications Change for Minimum Critical Power Ration Safety Limit

ML033650053
Person / Time
Site:	Quad Cities
Issue date:	12/23/2003
From:	Simpson P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-03-242
Download: ML033650053 (13)

Text

Exelkn.

Exelon Generation 4300 Winfield Road Warrenville, IL 60555 www.exelonCoTP.Com1 Nuclear 10 CFR 50.90 RS-03-242 December 23, 2003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Unit 2 Facility Operating License No. DPR-30 NRC Docket No. 50-265

Reference:

Supplemental Information for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S.

NRC, "Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit," dated November 14, 2003 In the above referenced letter, Exelon Generation Company, LLC (EGC) submitted a request for a change to the operating license and Technical Specifications (TS) for Quad Cities Nuclear Power Station (QCNPS), Unit 2. The proposed change revises the values of the Safety Limit for the Minimum Critical Power Ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs," for Unit 2, Cycle 18, for both two loop operation and single loop operation to 1.09 and 1.10, respectively.

On December 18, 2003, Global Nuclear Fuel (GNF) provided EGC with revised calculations used in the determination of the SLMCPR limits for QCNPS Unit 2, Cycle 18. These changes occurred following a review of the previously calculated results. EGC is submitting copies of these documents as Attachments 1 and 2 of this letter.

The following changes are reflected in Table 1 of the revised documents.

The limiting cycle exposures identified in Table 1 were revised for Cycle 18. For Cycle 18, the limiting dual loop operation (DLO) SLMCPR of 1.09 occurs at 12,000 Megawatt-Days per Metric Tonne (MWD/MT), however the single loop operation (SLO)

SLMCPR of 1.10 occurs at 15,000 MWD/MT. Revised text on pages 1 and 2 of the attachments to this letter reflect these changes.

Due to changes in the limiting exposure point, core MCPR for Cycle 18 was revised from 1.49 to 1.43.

The MCPR Importance Parameter (MIP) and R-factor Importance Parameter (RIP) in Table 1 were revised for Cycles 17 and 18. The revised values for Cycle 17 reflect the most recent analysis performed for that cycle. The Cycle 18 values were updated based on the revised limiting exposure point.

4Vd

December 23, 2003 U. S. Nuclear Regulatory Commission Page 2 The following change was made to Table 2.

The Cycle 17 value for the GEXL R-factor was provided in Column 2 to identify the difference between Cycles 17 and 18.

The QCNPS Unit 2, Cycle 18, SLMCPR values were not impacted in the revision, and these values remain consistent with those provided in the referenced letter.

Some of the information contained in Attachment 1 is classified as proprietary to our fuel supplier, GNF, and is identified as text contained between opening double brackets ((() and closing double brackets (]). The proprietary information is of the type that GNF maintains in confidence and withholds from public disclosure. It has been handled and classified as proprietary as supported by the affidavit in Attachment 2. EGC hereby requests that this information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790, "Public inspections, exemptions, requests for withholding." Attachment 2 provides an edited, non-proprietary version of the information in Attachment 1.

EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment I of the above referenced letter. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed TS change does not involve a significant hazards consideration.

Should you have any questions related to this letter, please contact Mr. Thomas G. Roddey at (630) 657-2811.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23I day of December 2003.

Respectfully, P. R. Simpson Manager -

Licensing Attachments:

1.

Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 - December 18, 2003 (GNF Proprietary Version)

2.

Affidavit and Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 - December 18, 2003 (GNF Non-Proprietary Version) cc:

Regional Administrator - NRC Region IlIl NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Office of Nuclear Facility Safety - Illinois Department of Nuclear Safety

ATTACHMENT 2 Affidavit and Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 - December 18, 2003 (GNF Non-Proprietary Version)

Affidavit Affidavit I, Jens G. M. Andersen, state as follows:

(1) I am Fellow and project manager, TRACG Development, Global Nuclear Fuel -

Americas, L.L.C. ("GNF-A") 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 the attachment, "Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18," December 18, 2003. GNF proprietary information is indicated by enclosing it in double brackets. In each case, the superscript notation (3) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.790(a)(4) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information," and some portions also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dI280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, of potential commercial value to GNF-A;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

Affidavit The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b., above.

(5) To address the 10 CFR 2.790 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.

The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GNF-A or its licensor.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A or its licensor.

Affidavit The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed at Wilmington, North Carolina, this 18th day of

December, 2003.

) (n-t Jens G. M. Andersen Global Nuclear Fuel - Americas, LLC

Attachment Additional Information Regarding the December 18, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 References

[1]

Letter, Frank Akstulewicz (NRC) to Glen A. Watford (GE), "Acceptance for Referencing of Licensing Topical Reports NEDC-3260 1 P, Methodology and Uncertainties for Safety Limit MCPR Evaluations; NEDC-32694P, Power Distribution Uncertainties for Safety Limit MCPR Evaluation; and Amendment 25 to NEDE-2401 1-P-A on Cycle Specific Safety Limit MCPR," (TAC Nos.

M97490, M99069 and M97491), March 11, 1999.

[2]

Letter, Thomas H. Essig (NRC) to Glen A. Watfordi (GE), "Acceptance for Referencing of Licensing Topical Report NEDC-32505P, Revision 1, R-Factor Calculation Methodfor GEHI, GE12 and GE13 Fuel," (TAC No. M99070 and M95081), January 11, 1999.

[3]

General Electric BWR Thermal Analysis Basis (GETAB): Data, Correlation and Design Application, NEDO-10958-A, January 1977.

[4]

Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of 10x10 Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies", FLN-2001-016, September 24, 2001.

[5]

Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Confirmation of Applicability of the GEXL14 Correlation and Associated R-Factor Methodology for Calculating SLMCPR Values in Cores Containing GE14 Fuel", FLN-2001-017, October 1, 2001.

[6]

GEXL96 Correlation for ATRJUM-9B Fuel, NEDC-3298 I P-A, Rev. I, May 2002.

[7]

Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Final Presentation Material for GEXL Presentation - February 11, 2002", FLN-2002-004, February 12, 2002.

Comparison of Quad Cities Unit 2 SLMCPR Values for Cycles 18 and 17 Table I summarizes the relevant input parameters and results of the SLMCPR determination for the Quad Cities Unit 2 Cycle 18 and 17 cores. The SLMCPR evaluations for Cycle 18 were performed using NRC-approved methods and uncertaintiest1 1, supplemented with Quad Cities Unit 2 specific uncertainties as indicated in Table 2.

These calculations use the GEXL14 correlation for GE14 fuel and GEXL96161 for the FANP fuel.

(( ))

The dual loop operation (DLO) and single loop operation (SLO) SLMCPR values calculated for Cycle 18 of Quad Cities Unit 2 are shown in Table 1. Other quantities that have been shown to have some impact on the determination of the SLMCPR are also shown in Table 1.

(( ].1 In comparing the Quad Cities Unit 2 Cycle 18 and Cycle 17 SLMCPR values it is important to note the impact of the differences in the core and bundle designs.

These differences are summarized in Table 1.

((GNF Proprietary Information))

page 1 of 7

((enclosed by double brackets ))

Attachment Additional Information Regarding the December 18, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 In general, the calculated safety limit is dominated by two key parameters: (1) flatness of the core bundle-by-bundle MCPR distributions and (2) flatness of the bundle pin-by-pin power/R-factor distributions. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR.

(( ))

Pin-by-pin power distributions are characterized in terms of R-factors using the NRC approved methodology[21. ((1]

Summary

(( )) have been used to compare quantities that impact the calculated SLMCPR value. Based on these bundle and core design considerations, the calculated 1.09 Monte Carlo SLMCPR for Quad Cities Unit 2 Cycle 18 is consistent with what one would expect lE ]i the 1.09 SLMCPR value is appropriate.

Based on all of the facts, observations and arguments presented above, it is concluded that a SLMCPR value of 1.09 for the Quad Cities Unit 2 Cycle 18 core is appropriate.

For single loop operations (SLO) the safety limit MCPR at the limiting exposure of 15,000 MWD/MT is 1.10 as determined by specific calculations for Quad Cities Unit 2 Cycle 18.

Supporting Information The following information is provided in response to NRC questions on similar submittals regarding changes in Technical Specification values of SLMCPR. NRC questions pertaining to how GE14 applications satisfy the conditions of the NRC SERW]I have been addressed in Reference [4]. Other generically applicable questions related to application of the GEXL14 correlation and the applicable range for the R-factor methodology are addressed in References

[5] and [7]. Only those items that require a plant/cycle specific response are presented below since all the others are contained in the references that have already been provided to the NRC.

The core loading information for Quad Cities Unit 2 Cycles 17 and 18 is provided in Figures I and 2, respectively.

The power and non-power distribution uncertainties that are used in the analyses are indicated in Table 2. The referenced document numbers have previously been reviewed and approved by the NRC. The SER (Reference [I ]) specifically provides that higher uncertainty values be used when necessary as was the case for this SLMCPR evaluation for Quad Cities Unit 2 Cycle 18.

((GNF Proprietary Information))

page 2 of 7

(( enclosed by double brackets ))

Attachment Additional Information Regarding the December 18, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 Prepared by:

Verified by:

I-f zhla A4ow2L H. Zhang Technical Program Manager R. Szilard Exelon Technical Manager

(( GNF Proprietary Information ))

(( enclosed by double brackets ))

page 3 of 7

Attachment Additional Information Regarding the December 18, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 Table I Comparison of the Quad Cities Unit 2 Cycle 18 and Cycle 17 SLMCPR QUANTITY, DESCRIPTION Quad Cities Unit Quad Cities Unit 2 Cycle 17 2 Cycle 18 Number of Bundles in Core 724 724 Cycle Exposure at Limiting Point [MWd/MTU]

14,991 12,000*

Reload Fuel Type GE14 GE14 Latest Reload Batch Fraction [%1 37.0%

33.1%

Latest Reload Average Batch Weight %

4.07%

3.99%

Enrichment Batch Fraction for GE 14 37.0%

70.2%

Batch Fraction for ATRIUM-9B 63.0%

29.8%

Core Average Weight % Enrichment 3.87%

3.97%

Core MCPR (for limiting rod pattern) 1.52 1.43

[t~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~1]

Power distribution uncertainty See Table 2, See Table 2, Column 2 Column 2 Non-power distribution uncertainty See Table 2, See Table 2, Column 2 Column 2 Calculated Safety Limit MCPR (DLO) 1.11 1.09*

Calculated Safety Limit MCPR (SLO) 1.12 1.10*

• The limiting DLO SLMCPR of 1.09 occurs at 1.10 occurs at 15,000 MWD/MT.

12,000 MWD/MT, however the limiting SLO SLMCPR of

(( GNF Proprietary Information ))

(( enclosed by double brackets ))

page 4 of 7

Attachment Additional Information Regarding the December 18, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 Table 2 Comparison of Quad Cities Unit 2 Specific Inputs to NRC-accepted Values COLUMN 1 COLUMN 2 DESCRIPTION Uncertainty Values (

Quad Cities Unit 2 previously accepted by Specific Values (%)

NRC Non-power Distribution From Table 2.1 of Uncertainties NEDC-3260 1 P-A Core flow rate (derived from pressure

(()) TLO

(( )) TLO drop)

(( ]}SLO

(( ))SLO Individual channel flow area

(( ))

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Individual channel friction factor

(())

(())

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(( ]1 LF ]i Reactor pressure

(( ))

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[L ))

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(( ))

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(( 1

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I] Cycle 18

(( )) Cycle 17 Power Distribution Uncertainties GETAB uncertainties as Specific Values (%)

consistent with the Revised used to produce values Methodology of NEDC-32601P-A shown in Table 4.1 of NEDC-3260 1 P-A GEXL R-factor

((1]

[4)) Cycle 18

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(( ))

(( ))

Integrated effective TIP reading

(( ))[F

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Bundle power

(( ))

(( ))

Effective total bundle power

'0 ]

(( ))

uncertainty

(( GNF Proprietary Information ))

(( enclosed by double brackets ))

page 5 of 7

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Attachment Additional Information Regarding the December 18, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 Figure 2 Reference Core Loading Pattern - Cycle 18 1

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Al Al B A I A A

A I

D I I E E

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E E

E E I l

D AI Al AI A

B A

A A

A l D

CI C I D E

E 0

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0 A l A l A l A

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B B

B IA I

C IA I A C

C A

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B A I A IA I

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EL BI BIa B

3 e

B B

B 01 03 05 07 09 11 13 15 17 Bundle N.an 19 A

ATRM9-P9DATB383-1 1GZ-SPCI OT-9WR-144-T6-3918 B

ATRM9-P9DATB381-13GZ-SPC 1 O0T-9WR-144T6-3919 C

GE14-PIODNAB409-15GZ-1 OOT-14 5-T&2507 0 GE14-P160NAB406-16GZ-IOOT-145-T6-2508 E GE14-PIODNAB418-16GZ-1IDt-145-T6-2646 F

GE1 4-P1 ODNAB389-1 BGZ-100T-145-T6-2650 Tola 21 23 25 27 NuWber i, Core 136 80 116 152 60 160 la1 724 29 31 33 35 37 39 41 Cycle Loaded 16 16 17 17 18 18 43 45 47 49 51 53 55 57 59

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(( enclosed by double brackets ))

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