RS-11-022, Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit

Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit

ML111590206
Person / Time
Site:	Quad Cities
Issue date:	06/07/2011
From:	Hansen J Exelon Generation Co, Exelon Nuclear
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML111590210	List: RS-11-022, Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit
References
RS-11-022, CAW-11-3135
Download: ML111590206 (39)

Text

corn com Nuclear 10 CFR 50.90 RS-1 1-022 June 7, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Unit 1 Renewed Facility Operating License No. DPR-29 NRC Docket No. 50-254

Subject:

Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Appendix A, Technical Specifications (TS), of Renewed Facility Operating License No. DPR-29 for Quad Cities Nuclear Power Station (QCNPS), Unit 1. The proposed change revises the value of the single recirculation loop operation (SLO) safety limit minimum critical power ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs." Specifically, the proposed change would replace the current SLO SLMCPR requirement for QCNPS Unit 1 with a new SLMCPR requirement. This proposed change does not affect the QCNPS Unit 1 two recirculation loop operation (TLO)

SLMCPR or either of the SLMCPR values for Unit 2. This change is needed to support the next cycle of operation (i.e., Cycle 22) for QCNPS Unit 1 for cycle exposure greater than 4000 MWd/MT, which is currently scheduled to occur in November 2011.

In October 2010, Westinghouse notified EGC of an error in their McSLAP computer code. The McSLAP code is used to calculate the SLMCPR for the Dresden Nuclear Power Station (DNPS) and QCNPS units. It was determined that the McSLAP code incorrectly accounted for the pin power uncertainty. As a result, the calculated SLMCPR for DNPS Units 2 and 3 and QCNPS Units 1 and 2 were determined to be non -

conservative. Additionally, the operating limit MCPR (OLMCPR) for these units was also determined to be non-conservative. As a result of this error, Westinghouse initiated corrective action program steps to evaluate the impact of this error and identify any necessary compensatory measures. Two additional errors in the McSLAP code were found by Westinghouse as part of the extent of cause review of the error found in October 2010. These errors were in the statistical treatment of uncertainties. These additional errors were found and communicated to EGC in March 2011. These additional errors were also documented in the EGC corrective action program.

June 7, 2011 U. S. Nuclear Regulatory Commission Page 2 Westinghouse has subsequently completed calculation of the revised SLMCPR for the upcoming Cycle of operation (i.e., Cycle 22) at QCNPS Unit 1. The revised SLMCPR provides the basis for this amendment request. A separate submittal will be made to address the need for revision of the QCNPS Unit 2 and DNPS Units 2 and 3 SLMCPRs as necessary. to this letter provides an evaluation supporting the proposed changes.

The marked-up TS pages, with the proposed changes indicated, for QCNPS Unit 1 are provided in Attachment 2 to this letter. to this letter provides a description of the SLMCPR evaluation for QCNPS Unit 1, Cycle 22. Attachment 3 contains information proprietary to Westinghouse Electric Company, LLC that is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit, provided in Attachment 4, sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." Accordingly, it is requested that the information in Attachment 3 be withheld from public disclosure in accordance with 10 CFR 2.390. Attachment 5 to this letter provides a non-proprietary version of the Westinghouse report provided in Attachment 3.

The proposed change has been reviewed by the QCNPS Plant Operations Review Committee and approved by the EGC Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program and procedures.

Westinghouse has determined that the SLMCPR values currently in TS Section 2.1.1 are conservative for the first 4000 MWd/MT of QCNPS Unit 1, Cycle 22. Therefore, EGC requests approval of the proposed changes by September 30, 2011 to support continued operation of QCNPS Unit 1 beyond 4000 MWd/MT and timely correction of the non-conservative Safety Limit at QCNPS Unit 1. Once approved, the amendment will be implemented within 30 days. This implementation period will provide adequate time for the affected station documents to be revised using the appropriate change control mechanisms.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," EGC is notifying the State of Illinois of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Timothy A Byam at (630) 657-2804.

June 7, 2011 U. S. Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 7th day of June 2011.

Jeff re ManagerV Licensing Exelon Generation Company, LLC Attachments: : Evaluation of Proposed Change : Markup of Proposed QCNPS Technical Specifications Page : QCNPS Unit 1 Cycle 22 SLMCPR (Proprietary) : Westinghouse Application for Withholding and Affidavit for QCNPS Unit 1, Cycle 22 : QCNPS Unit 1 Cycle 22 SLMCPR (Non-Proprietary)

ATTACHMENT 1 Evaluation of Proposed Change

Subject:

Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Page 1 of 8

ATTACHMENT 1 Evaluation of Proposed Change 1.0 Summary Description In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Appendix A, Technical Specifications (TS), of Renewed Facility Operating License No. DPR-29 for Quad Cities Nuclear Power Station (QCNPS), Unit 1. The proposed change revises the value of the single recirculation loop operation (SLO) safety limit minimum critical power ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs." Specifically, the proposed change would replace the current SLO SLMCPR requirement for QCNPS Unit 1 with a new SLMCPR requirement. This proposed change does not affect the QCNPS Unit 1 two recirculation loop operation (TLO)

SLMCPR or either of the SLMCPR values for Unit 2. This change is needed to support the next cycle of operation (i.e., Cycle 22) for QCNPS Unit 1 for cycle exposure greater than 4000 MWd/MT, which is currently scheduled to occur in November 2011.

2.0 Detailed Description In October 2010, Westinghouse was using the McSLAP computer code for non -

SLMCPR work for a non-EGC customer and identified unexpected behavior in the results. Investigation of the anomaly identified that the error extended beyond the specific analysis being performed and impacted the EGC SLMCPR analysis.

Westinghouse notified EGC of the error in the McSLAP computer code since it is used by Westinghouse to calculate the SLMCPR for the Dresden Nuclear Power Station (DNPS) and QCNPS units. It was determined that there was an error in the McSLAP code treatment of pin power uncertainty. As a result, the calculated SLMCPR for DNPS Units 2 and 3 and QCNPS Units 1 and 2 were determined to be non-conservative.

Additionally, the operating limit MCPR (OLMCPR) for these units was also determined to be non-conservative.

As a result of the error identified in October 2010, Westinghouse initiated corrective action program steps to evaluate the impact of the error and identify any necessary compensatory measures. Part of the corrective action program evaluation included an extent of cause review and during this review Westinghouse identified two additional errors in the McSLAP code. These errors were in the statistical treatment of uncertainties.

Preliminary calculations indicated that the SLMCPR and OLMCPR were non-conservative and these errors impacted all SLMCPR calculations performed by Westinghouse for the previous and current cycles for DNPS and QCNPS. Based on the known errors, an OLMCPR penalty was implemented for the four units to address the current operating cycle, to support continued operation for the four units, and ensure the SLMCPR was protected.

Westinghouse and EGC have completed a reanalysis of the SLMCPR with the errors in the McSLAP code corrected and have determined the new TS SLMCPR and OLMCPR values required to support conservative operation at QCNPS Unit 1. The new TS SLMCPR values provide a basis for this amendment request. Any required changes to Page 2 of 8

ATTACHMENT 1 Evaluation of Proposed Change the TS SLMCPR for DNPS Units 2 and 3 and QCNPS Unit 2 will be submitted under a separate amendment request as necessary.

Westinghouse has determined that the SLMCPR values currently in TS Section 2.1.1 are conservative for the first 4000 MWd/MT of QCNPS Unit 1, Cycle 22. Therefore, EGC will not be implementing any administrative limits to support continued operation of QCNPS Unit 1 for the first 4000 MWd/MT of Cycle 22. The proposed new SLMCPR will support operation at QCNPS Unit 1 beyond 4000 MWd/MT.

QCNPS TS Section 2.1.1.2 specifies the value for the SLMCPR. The current TS states:

"For two recirculation loop operation, MCPR shall be >_ 1.11, or for single recirculation loop operation, MCPR shall be >_ 1.13."

The proposed change will revise the QCNPS TS Section 2.1.1.2 to read as follows.

"For Unit 1, two recirculation loop operation, MCPR shall be >_ 1.11, or for single recirculation loop operation, MCPR shall be >_ 1.14."

"For Unit 2, two recirculation loop operation, MCPR shall be > 1.11, or for single recirculation loop operation, MCPR shall be >_ 1.13." provides the marked-up TS page for QCNPS indicating the proposed changes.

3.0 Technical Evaluation For QCNPS Unit 1, Cycle 22, EGC will load Westinghouse SVEA-96 Optima2 reload fuel for the third consecutive cycle. SVEA-96 Optima2 reload fuel was also loaded in QCNPS Unit 1 Cycles 20 and 21. In Cycle 22, all remaining legacy GE14 fuel will be discharged, resulting in a full core loading of SVEA-96 Optima2 assemblies. Therefore, the Westinghouse NRC-approved methodology described in Reference 1, and further clarified in the response to Request for Additional Information (RAI) D13 of Reference 2, was used to determine the SLMCPRs for Cycle 22. Further clarification of the Westinghouse SLMCPR methodology was also provided to the NRC in support of the transition to SVEA-96 Optima2 fuel in References 3, 4, 5, and 6.

The same SLMCPR methodology described in these references was followed to establish appropriate SVEA-96 Optima2 SLMCPRs for QCNPS Unit 1, Cycle 22. EGC has previously used this Westinghouse methodology for core reload evaluations at DNPS and QCNPS as documented in Reference 4. This submittal was originally approved by the NRC in Reference 7 and supported QCNPS Unit 2 Cycle 19, DNPS Unit 3 Cycle 20, QCNPS Unit 1 Cycle 20, and DNPS Unit 2 Cycle 21, all of which were cores containing one reload of SVEA-96 Optima2 fuel. In addition, the same methodology was used to analyze the QCNPS and DNPS cores that contained two reloads of SVEA-96 Optima2 fuel.

Page 3 of 8

ATTACHMENT 1 Evaluation of Proposed Change The SVEA-96 Optima2 SLMCPR for QCNPS Unit 1, Cycle 22 is based on a Reference Core design (i.e., SVEA-96 Optima2 bundle designs, core loading pattern and state point depletion strategy) that represents realistic current plans for the Cycle 22 loading and operation. The Reference Core loading pattern for QCNPS Unit 1, Cycle 22 is provided in Figure 1 to Attachment 3. In general, the calculated SLMCPR is dominated by the flatness of the assembly CPR distribution across the core, and the flatness of the relative pin CPR distribution based on pin-by-pin power/R-Factor distribution in each bundle. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher SLMCPR.

Information to support the cycle specific SLMCPRs is included in Attachment 3 that summarizes the methodology, inputs, and results for the change in the SLO SLMCPR. also includes a current QCNPS Unit 1 power-flow map (i.e., Figure 3) which is applicable to Cycle 22.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, "Technical specifications," paragraph (c)(1), requires that power reactor facility TS include safety limits for process variables that protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity. The fuel cladding integrity SLMCPR is established to assure that at least 99.9% of the fuel rods in the core do not experience boiling transition during normal operation and anticipated operational occurrences (AOOs). Thus, the SLMCPR is required to be contained in TS.

The proposed amendment to the QCNPS TS revises the SLMCPR for QCNPS Unit 1 to be conservative and does not remove the SLMCPR from the TS.

10 CFR 50, Appendix A, General Design Criterion (GDC) 10 requires that the reactor core and associated coolant, control, and protection systems be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of AOOs. To ensure compliance with GDC 10, EGC has performed the plant-specific SLMCPR analyses using NRC-approved methodologies as prescribed in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants,"

Section 4.4. The SLMCPR ensures that sufficient conservatism exists in the operating limit MCPR such that, in the event of an AOO, there is a reasonable expectation that at least 99.9% of the fuel rods in the core will avoid boiling transition for the power distribution within the core including all uncertainties.

4.2 Precedent As documented above, EGC has submitted amendment requests to revise the SLMCPR for both DNPS and QCNPS based on use of Westinghouse methodologies that were generically approved by the NRC for use in core reload evaluations.

Page 4 of 8

ATTACHMENT 1 Evaluation of Proposed Change 4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Appendix A, Technical Specifications (TS), of Renewed Facility Operating License No. DPR-29 for Quad Cities Nuclear Power Station (QCNPS), Unit 1. The proposed change revises the value of the single recirculation loop operation (SLO) safety limit minimum critical power ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs." Specifically, the proposed change would replace the current SLO SLMCPR requirement for QCNPS Unit 1 with a new SLMCPR requirement. This proposed change does not affect the QCNPS Unit 1 two recirculation loop operation (TLO)

SLMCPR or either of the SLMCPR values for Unit 2. This change is needed to support the next cycle of operation (i.e., Cycle 22) for QCNPS Unit 1 for cycle exposure greater than 4000 MWd/MT, which is currently scheduled to occur in November 2011.

According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

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

EGC has evaluated the proposed change to the TS for QCNPS Unit 1, using the criteria in 10 CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The probability of an evaluated accident is derived from the probabilities of the individual precursors to that accident. The consequences of an evaluated accident are determined by the operability of plant systems designed to mitigate those consequences. Limits have been established consistent with NRC-approved methods to ensure that fuel performance during normal, transient, and accident conditions is acceptable. The proposed change to revise the QCNPS Unit 1 SLO SLMCPR requirement conservatively establishes the SLMCPR at the value for a core of all SVEA-96 Optimal fuel, such that the fuel is protected during normal operation and during plant transients or anticipated operational occurrences (AOOs).

Page 5 of 8

ATTACHMENT 1 Evaluation of Proposed Change The proposed SLMCPR value for QCNPS Unit 1 does not increase the probability of an evaluated accident. The change does not require any physical plant modifications, physically affect any plant components, or entail changes in plant operation. Therefore, no individual precursors of an accident are affected.

The proposed change revises the SLO SLMCPR value for QCNPS Unit 1 to protect the fuel during normal operation as well as during plant transients or AOOs. Operational limits will be established based on the proposed SLMCPR to ensure that the SLMCPR is not violated. This will ensure that the fuel design safety criterion (i.e., that at least 99.9% of the fuel rods do not experience transition boiling during normal operation and AOOs) is met.

Since the proposed change does not affect operability of plant systems designed to mitigate any consequences of accidents, the consequences of an accident previously evaluated will not increase.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No Creation of the possibility of a new or different kind of accident requires creating one or more new accident precursors. New accident precursors may be created by modifications of plant configuration, including changes in allowable modes of operation. The proposed changes do not involve any plant configuration modifications or changes to allowable modes of operation. The proposed SLMCPR value does not result in the creation of any new precursors to an accident. The proposed change to revise the QCNPS Unit 1 SLO SLMCPR requirement assures that safety criteria are maintained for QCNPS Unit 1, Cycle 22.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The SLMCPR provides a margin of safety by ensuring that at least 99.9%

of the fuel rods do not experience transition boiling during normal operation and AOOs if the SLMCPR limit is not violated. The proposed change will ensure the current level of fuel protection is maintained by continuing to ensure that at least 99.9% of the fuel rods do not experience transition boiling during normal operation and AOOs if the SLMCPR limit is not violated. The proposed SLMCPR value was developed using NRC-Page 6 of 8

ATTACHMENT 1 Evaluation of Proposed Change approved methods. Additionally, operational limits will be established based on the proposed SLMCPR value to ensure that the SLMCPR is not violated. This will ensure that the fuel design safety criterion (i.e., that no more than 0.1 % of the rods are expected to be in boiling transition if the MCPR limit is not violated) is met.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

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

5.0 ENVIRONMENTAL CONSIDERATION

EGC has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation." However, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," paragraph (c)(9).

Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. CENPD-300-P-A, "Reference Safety Report for Boiling Water Reactor Reload Fuel," dated July 1996

2. CENPD-389-P-A, "10x10 SVEA Fuel Critical Power Experiments and CPR Correlations: SVEA-96+," dated August 1999 Page 7 of 8

ATTACHMENT 1 Evaluation of Proposed Change

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

"Additional Information Supporting Request for License Amendment Regarding Transition to Westinghouse Fuel," dated January 26, 2006

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

"Request for License Amendment Regarding Transition to Westinghouse Fuel,"

dated June 15, 2005

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

"Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit"' dated December 15, 2005

6. Letter from Mr. P. R. Simpson (Exelon Generation Company, LLC) to U. S. NRC, "Additional Information Supporting Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit," dated February 13, 2006 Letter from U. 7.S. NRC to Mr. C. M. Crane (Exelon Generation Company, LLC),

"Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments Re: Transition to Westinghouse Fuel and Minimum Critical Power Ratio Safety Limits (TAC Nos. MC7323, MC7324, MC7325 and MC7326)," dated April 4, 2006 Page 8 of 8

ATTACHMENT 2 Markup of Proposed QCNPS Technical Specifications Page

SLs 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 psig or core flow < 10% rated core flow:

THERMAL POWER shall be <_ 25% RTP.

2.1.1.2 With the reactor steam dome pressure > 785 psig and core flow ? 10% rated core flow:

shall be ` 1 .1 3 .

2.1.1.3 Reactor vessel water level shall be greater than the top of active irradiated fuel.

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be 5 1345 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

2.2.1 Restore compliance with all SLs; and 2.2.2 Insert all insertable control rods.

Quad Cities 1 and 2 2.0-1 Amendment No. 237/232

Quad Cities TS 2.1. 1.2 Insert:

"For Unit 1, two recirculation loop operation, MCPR shall be ? 1.11, or for single recirculation loop operation, MCPR shall be 2:1.14."

"For Unit 2, two recirculation loop operation, MCPR shall be ? 1.11, or for single recirculation loop operation, MCPR shall be _> 1.13."

ATTACHMENT 4 Westinghouse Application for Withholding and Affidavit for QCNPS Unit 1, Cycle 22

Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: NF-BEX-11-3 Rev. 1 CAW-1 1-3135 April 8, 2011 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

NF-BEX-11-3 Rev. I P-Attachment, "Quad Cities Unit I Cycle 22 SLMCPR" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-1 1-3135 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-11-3135, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, J. A. Gresham, Manager Regulatory Compliance Enclosures

CAW-11-3135 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

J. A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 911 day of April 2011 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cynthia olesky, Notary Public Manor Boo, westmoreland County My Commission rxpires July 16, 2014 Member. Pennsylvania Assodatlon of Notaries

2 CAW-11-3135 (1) I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW- 11-3135 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use 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 a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW- 11-3135 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in, NF-BEX 3 Rev. I P-Attachment, "Quad Cities Unit I Cycle 22 SLMCPR" (Proprietary) for review and approval, being transmitted by Exelon letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of Quad Cities Unit 1 Cycle 22 SLMCPR, and may be used only for that purpose.

This information is part of that which will enable Westinghouse to:

(a) Support Exelon's use of Westinghouse Fuel at Quad Cities.

5 CAW-11-3135 (b) Assist the customer to obtain license change.

Further this information has substantial commercial value as follows:

(a) Westinghouse can use this information to further enhance their licensing position with their competitors.

(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar analyses and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

ATTACHMENT 5 QCNPS Unit 1 Cycle 22 SLMCPR (Non-Proprietary)

Westinghouse Non-Proprietary Class 3 Quad Cities Unit 1 Cycle 22 SLMCPR Westinghouse Electric Company Nuclear Fuel 1000 Westinghouse Drive Cranberry Township, PA 16066

© 2011 Westinghouse Electric Company LLC, All Rights Reserved NF-BEX-11-3, Rev. I NP-Attachment

1.0 Introduction This document contains a description of the Safety Limit Minimum Critical Power Ratio (SLMCPR) evaluation for Quad Cities Nuclear Power Station Unit 1 (QCNPSI) Cycle 22.

Dual recirculation loop operation (DLO) and single recirculation loop operation (SLO)

SLMCPRs of [ ]a'c, respectively, have been calculated for the Westinghouse SVEA-96 Optima2 assemblies in QCNPS1 Cycle 22. Application of the Westinghouse methodology in Reference 1 requires modification of the QCNPS 1 Technical Specifications, Reference 3, to support DLO and SLO SLMCPRs of [ ] a'c, respectively, for the SVEA-96 Optimal fuel in Cycle 22. The SLMCPR values for QCNPS 1 Cycle 21 and Cycle 22 are shown in Table 1.

For QCNPS1 Cycle 22, Exelon Generation Company, LLC, (EGC) will load Westinghouse SVEA-96 Optimal reload fuel for the third consecutive cycle. SVEA-96 Optimal reload fuel was also loaded in QCNPSI Cycle 20 and Cycle 21. In Cycle 22, all remaining legacy GE14 fuel shall be discharged, resulting in a full core loading of SVEA-96 Optima2 assemblies.

Therefore, the Westinghouse NRC-approved methodology described in Reference 1, and further clarified in the response to Request for Additional Information (RAI) D13 of Reference 2, was used to determine the SLMCPRs for Cycle 22. Further clarification of the Westinghouse SLMCPR methodology was also provided to the NRC in support of the transition to SVEA-96 Optima2 fuel in the Quad Cities and Dresden Units as follows:

The response to NRC Request 19 in Reference 5 which supported the Licensing Amendment Request for transition to SVEA-96 Optima2 fuel in the Dresden and Quad Cities plants provided in Reference 4, The technical information supporting the Quad Cities Nuclear Power Station Unit 2 (QCNPS2) Technical Specification SLMCPR changes transmitted by Reference 6 as supplemented by the clarifying information in Reference 7.

The same SLMCPR methodology described in these references was followed to establish appropriate SVEA-96 Optimal SLMCPRs for QCNPS 1 Cycle 22.

The EGC proposed license amendment to use the Westinghouse methodology for core reload evaluations at the Dresden and Quad Cities units was submitted to the NRC in Reference 4.

This submittal was approved by the NRC, and supported QCNPS2 Cycle 19, Dresden Nuclear Power Station Unit 3 (DNPS3) Cycle 20, QCNPSI Cycle 20, and Dresden Nuclear Power Station Unit 2 (DNPS2) Cycle 21, all of which are cores containing a reload of SVEA-96 Optima2 fuel, and QCNPS2 Cycle 20 and DNPS3 Cycle 21 which contain two reloads of SVEA-96 Optima2 fuel.

Condition 7 in the NRC safety evaluation for Reference 1 requires that the conservative factor be applied to the GE14 Operating Limit Minimum Critical Power Ratio (OLMCPR) and that this factor be identified in licensee applications. Since no legacy GE14 fuel assemblies are Page 2 of 17 NF-BEX- 11-3, Rev. I NP-Attachment

loaded into the QCNPSI Cycle 22 core, this factor is not relevant for this cycle and will not be included in the Cycle 22 Core Operating Limits Report.

I 1 a,c 2.0 SVEA-96 Optima2 SLMCPR for Cycle 22 The SVEA-96 Optima2 SLMCPR for QCNPS1 Cycle 22 is based on a Reference Core design (SVEA-96 Optima2 bundle designs, core loading pattern and state point depletion strategy) that represents realistic current plans for the Cycle 22 loading and operation. The Reference Core loading pattern for QCNPS1 Cycle 22 is shown in Figure 1. The Reference Core design was generated via collaboration between EGC and Westinghouse based on EGC's cycle assumptions and design goals. The Reference Core was designed to meet the cycle energy requirements, to satisfy all licensing requirements, to provide adequate thermal margins and operational flexibility, and to meet other design and manufacturing criteria established by EGC and Westinghouse.

In general, the calculated SLMCPR is dominated by the flatness of the assembly CPR distribution across the core, and the flatness of the relative pin CPR distribution based on the pin-by-pin power/R-factor distribution in each bundle. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher SLMCPR.

The calculation of the SLMCPR as a function of cycle exposure captures the interplay between the relative fuel assembly CPR and the bundle relative pin-by-pin CPR distributions established from the power/R-factor distributions and allows a determination of the maximum (limiting) SLMCPR for the entire cycle. This limiting SLMCPR is conservatively applied throughout the entire cycle.

The SVEA-96 Optimal SLMCPR for QCNPS 1 Cycle 22 was determined as a function of cycle exposure based on radial assembly power distributions with about the same "flatness" as the Page 3 of 17 NF-BEX- 11-3, Rev. I NP-Attachment

cycle exposure-dependent radial power distributions from [

1 a,c Accordingly, the SVEA-96 Optimal SLMCPR for DLO was calculated at 100% power and 100% flow at various exposures throughout the cycle to assure that the limiting SLMCPR was identified. In addition, the DLO SLMCPRs were calculated at 100% power at the minimum allowed core flow at rated power (95.3% flow), as well as the maximum licensed core flow at rated power (108% flow) to confirm that a limiting SLMCPR had been established. Figure 3 shows a current QCNPS 1 power-flow map which is applicable to Cycle 22. Consistent with Figure 3, a flow window of 95.3% to 108 % of rated core flow was analyzed.

SLO SVEA-96 Optima2 SLMCPR calculations were also performed. These SLMCPR calculations were performed at [

Ia,c The SLO calculations used the same procedure as the DLO cases, except that the SLO cases applied a larger uncertainty for the core flow.

The SLMCPR results for Cycle 22 are plotted in Figure 4. As shown in Figure 4, the DLO SLMCPR [

j a,c Since the uncertainties at each DLO point are the same, this behavior is due to the interplay between the assembly relative CPRs and the relative fuel rod CPRs. In general, as the number of assemblies or fuel rods with CPRs in the vicinity of the assembly or fuel rods with the minimum CPR increases, the number of fuel rods with a potential for experiencing dryout increases. Therefore, a larger SLMCPR is required to assure that less than 0.1% of the rods are in dryout.

Experience has shown that the assembly CPR distributions tend to become [

I a,c Consequently, the peak SLMCPR tends to occur when the assembly CPR and rod CPR distributions combine to place the maximum number of fuel rod CPRs close to the minimum CPR.

This behavior is shown for the QCNPS 1 Cycle 22 SLMCPR by the relative assembly CPR histograms shown in Figures 5 through 7, respectively.

Inspection of the DLO histograms in Figures 5 through 7 leads to the following observations, which explain the SLMCPR behavior in Figure 4:

I a,c I

Page 4 of 17 NF-BEX- 11-3, Rev. I NP-Attachment

a,c I

Therefore, the DLO SLMCPR results at rated conditions in Figure 4 can be explained in terms of I 1 a,c The adequacy of a DLO SLMCPR of [

1 a,c The SLO results calculated at [

a,c I

The relative fuel rod CPRs in the SLMCPR calculations are [

a,c Page 5 of 17 NF-BEX- 11-3, Rev. I NP-Attachment

a,c I

In addition to the strong dependence on assembly CPR and relative fuel rod CPR distributions, the SLMCPR is strongly dependent on the distribution of assembly and relative fuel pin CPRs about their mean values leading to an overall distribution of fuel rod CPRs relative to their mean values. The wider these distributions, the higher the SLMCPR must be to prevent 0.1%

of the fuel rods from experiencing boiling transition. The distributions of fuel rod CPRs relative to their mean values are determined by the uncertainties relative to the mean CPRs.

Accordingly, the uncertainties used in establishing the SVEA-96 Optimal SLMCPR for Cycle 22 are shown in Table 2.

3.0 References

1. Licensing Topical Report, Reference Safety Report for Boiling Water Reactor Reload Fuel, CENPD-300-P-A, July 1996.

2. CENPD-389-P-A, 10x10 SVEA Fuel Critical Power Experiments and CPR Correlations: SVEA-96+,

August 1999.

3. Quad Cities Technical Specifications, Section 2.1.1.2

4. Letter, Patrick R. Simpson (Exelon Generation Company, LLC) to NRC, Request for License Amendment Regarding Transition to Westinghouse Fuel, dated June 15, 2005.

5. RS-06-009, Additional Information Supporting Request for License Amendment Regarding Transition to Westinghouse Fuel, January 26, 2006.

6. Letter from Patrick R. Simpson, Exelon Nuclear, to U.S. NRC, "Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit ", QCNPS, Unit 2, December 15, 2005.

7. RS-06-024, "Additional Information Supporting Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit", QCNPS, Unit 2, February 13, 2006.

Page 6 of 17 NF-BEX- 1 1-3, Rev. 1 NP-Attachment

Table 1 Comparison of Cvcle 21 and 22 Cores Description Cycle 21 Cycle 22 Number of Bundles in Core 724 724 Limiting Cycle Exposure Point Near EOC Near MOC Cycle Exposure at Limiting Point, EFPH 16809 EFPH 8357 EFPH Reload Fuel Type SVEA-96 Optima2 SVEA-96 Optima2 Reload Batch Average Weight % Enrichment 3.99 w/o 4.08 w/o Reload Batch Fraction (%) 37% 30.4%

Batch Fraction of SVEA-96 Optima2 Fuel 72.9% 100.0%

Batch Fraction of GNF GE14 Fuel 27.1% 0.0%

Core Average Weight % Enrichment 4.02 w/o 4.03 w/o Calculated Safety Limit MCPR (DLO) a,c a,c Calculated Safety Limit MCPR (SLO) a,c a,c Page 7 of 17 NF-BEX- 11-3 Rev. 1 NP-Attachment

Table 2 - Uncertainties used in Quad Cities 1 Cycle 22 SVEA- 96 Optima2 SLMCPR Determination a,c Page 8 of 17 NF-BEX-11-3 Rev. I NP-Attachment

Figure 1 - Quad Cities I Cycle 22 - Reference Loading Pattern 01 03 05 07 09 11 13 15 17 19 21 23 25 27 Legends 29 Center QA20 0C20 0820 0820 0820 ASYTYP 0A20 0820 0020 QC20 0A20 QA20 0920 OA20 OB20 0820 0C20 0C20 0021 OD21 CAN 0A20 OC20 0820 GB20 OB20 0820 0F21 0122 0021 0122 OC20 OB20 OC20 0020 Q021 QD21 0122 0122 0F21 QH22 0021 QA20 OB20 0820 OB20 0021 0122 0122 01422 0021 OH22 QF21 OH22 0820 OC20 QC20 0820 0820 QE21 Q122 QG22 0821 0021 OG22 01422 0021 0A20 0820 OC20 0021 OE21 0122 0022 QD21 0021 0021 OD21 0F21 0022 0820 OB20 0021 0122 0122 OG22 OD21 OG22 QH22 OG22 OF21 QH22 0021 0A20 0820 OB20 OD21 0122 OG22 0021 QG22 QD21 0022 0821 0022 OD21 0022 0A20 1 0820 OC20 0820 Q122 OH22 GE21 0021 QH22 OG22 0021 0F21 OD21 OG22 0021 OC20 OC20 QC20 OF21 0122 QD21 QE21 OE21 OG22 QE21 0F21 0021 OG22 0F21 0021 OB20 OC20 0021 0122 OF21 OH22 QG22 QD21 OF21 OG22 0021 01322 QE21 0622 0821 Q820 OA20 QD21 OD21 OH22 OF21 OH22 QG22 OH22 0021 QG22 0F21 OG22 0821 0022 OB20 0A20 OA20 0122 OD21 OH22 QD21 OF21 0021 QG22 0821 0021 0021 0022 OD21 30 0820 0A20 0A20 0122 OD21 OH22 0021 OF21 OD21 OG22 0821 0021 OE21 01322 0021 28 0820 QA20 0021 OD21 OH22 OF21 OH22 QG22 QH22 0021 0022 OF21 0022 0821 0022 26 0620 QC20 0021 0122 OF21 OH22 OG22 0021 OF21 OG22 0021 0022 0021 OG22 QE21 24 OC20 QC20 QC20 OF21 0122 0021 OE21 OE21 QG22 0021 0821 0021 GG22 0821 0021 22 0A20 QB20 OC20 0820 0122 OH22 OE21 OD21 OH22 OG22 0021 0821 0021 QG22 0821 OA20 0820 0820 0021 0122 OG22 0021 QG22 0021 OG22 0821 OG22 0021 0022 0820 0820 OD21 0122 0122 QG22 OD21 OG22 01422 0022 OF21 01422 0021 0A20 OB20 OC20 OD21 GE21 0122 OG22 0021 0021 0821 QD21 0022 0821 OB20 OC20 OC20 QB20 OB20 QE21 0122 OG22 0821 0821 OG22 QH22 0021 0A20 0820 QB20 G820 OD21 0122 0122 QH22 0021 OH22 OF21 0H22 OC20 0920 QC20 OC20 OD21 0021 0122 0122 OF21 01422 0021 0A20 1 QC20 1 0620 1 OB20 0820 0820 0821 0122 OD21 0122 0820 1 QA20 1 0820 OB20 0C20 0C20 OD21 0021 0A20 QA20 0820 0020 0C20 0A20 0A20 0A20 OC20 0820 0820 0820 Page 9 of 17 NF-BEX- 11-3, Rev. I NP-Attachment

Figure 1 - Quad Cities 1 Cycle 22 - Reference Loading Pattern 59 31 33 Le 35 37 39 41 ge 43 45 47 49 nd 51 53 55 57 s Center 60 OB20 0820 0820 0C20 OA20 ASYTYP 58 OA20 OA20 0020 0020 0820 QA20 56 0A20 0021 0021 0020 OC20 OB20 0820 0A20 0820 54 0122 0021 0122 OF21 OB20 QB20 0820 0820 QC20 0A20 52 0021 OH22 QF21 0122 0122 Q021 OD21 OC20 OC20 QB20 QC20 50 OH22 0F21 OH22 0021 OH22 0122 0122 OD21 Q820 0820 OB20 OA20 48 0021 OH22 0022 0321 OE21 OG22 Q122 QE21 OB20 OB20 QC20 OC20 OB20 46 OF21 0022 0021 0021 0021 OD21 0022 Q122 OE21 10021 OC20 OB20 QA20 44 0021 OH22 0021 0022 OH22 OG22 OD21 OG22 0122 0122 0021 0820 OB20 42 0022 0021 0022 0021 OG22 0021 OG22 QD21 OG22 0122 0021 0820 OB20 QA20 40 0021 0022 0021 0F21 QD21 Q022 OH22 1 0021 GE21 1 OH22 0122 OB20 OC20 0820 0A20 38 0021 OF21 QG22 0021 0F21 QE21 OG22 0021 OE21 0021 0122 OF21 OC20 OC20 QC20 36 0021 0022 0021 OG22 0021 QG22 OF21 QD21 0022 QH22 QF21 Q122 0021 OC20 0820 34 0022 0021 0022 0F21 OG22 OD21 OH22 1 QG22 OH22 QF21 OH22 0021 1 QD21 OA20 OB20 32 0021 OG22 021 0021 0021 QG22 OD21 OF21 Q021 1 QH22 0021 0122 0A20 OA20 QB20 30 0021 0022 0021 0021 0E21 QG22 0021 QF21 OD21 QH22 0021 0122 QA20 QA20 QB20 0022 0021 0022 0F21 OG22 QD21 OH22 OG22 OH22 1 QF21 QH22 OD21 OD21 QA20 QB20 0021 0022 QE21 0022 0021 OG22 0F21 OD21 0022 1 QH22 OF21 0122 OD21 OC20 0820 0021 0F21 0022 0021 OF21 OE21 OG22 1 GE21 OE21 1 OD21 0122 QF21 OC20 OC20 QC20 0021 0022 0021 0021 OD21 OG22 OH22 1 0021 OE21 OH22 Q122 OB20 OC20 Q820 QA20 0022 0021 0022 OE21 0022 0021 OG22 1 OD21 OG22 0122 0021 0820 Q820 0A20 0021 OH22 OF21 0022 OH22 QG22 OD21 1 OG22 0122 0122 OD21 OB20 0820 QF21 0022 0021 0021 0021 0021 OG22 Q122 OE21 1 OD21 OC20 QA20 0021 OH22 0022 0021 OE21 OG22 Q122 OE21 0820 0820 QC20 0820 0H22 0F21 QH22 0021 01122 0122 0122 1 OD21 0820 0820 OB20 0021 0H22 0F21 0122 0122 OD21 OD21 OC20 OC20 QBZO OC20 0122 0021 0122 0F21 0820 0820 OB20 0820 GC20 1 0A20 QA20 0021 0021 0C20 0C20 OB20 0A20 0A20 OC20 0020 0820 CA20 0820 0820 0820 0C20 QA20 Page 10 of 17 NF-BEX-11-3, Rev. 1 NP-Attachment

Figure 2 - Quad Cities 1 Cycle 21 - Reference Loading Pattern 01 03 05 07 09 11 13 15 17 19 21 23 25 27 29 Legends Center 2826 2825 2828 2825 2825 ASYTYP 2825 2825 2825 2825 2826 2826 2825 1 2825 2826 1 2825 2826 0820 0820 OA20 QA20 2825 1 2825 1 2826 2825 1 QA20 OB20 OB20 OF21 OF21 OF21 2826 2825 2825 2825 1 QA20 QF21 OF21 OC20 QE21 OE21 QC20 2825 2825 2826 OB20 OA20 QF21 QE21 QE21 OE21 OD21 0620 OE21 2825 2825 2825 QB20 2828 OF21 1 OC20 OE21 OC20 QD21 OC20 OE21 0620 2825 2826 2826 OA20 OF21 OD21 OD21 OC20 0021 QC20 OD21 OB20 Q021 2826 2825 QA20 OF21 OC20 0021 OC20 OD21 QA20 0021 OD21 0820 OB20 2825 2825 QA20 OF21 QE21 OE21 OC20 QD21 OB20 0021 0820 OD21 0820 OD21 2826 2825 2826 QB20 OF21 OE21 OC20 0021 QA20 QD21 0820 0021 OC20 0021 OB20 2825 2826 OB20 OB20 OC20 OE21 QD21 QC20 Q021 QB20 OD21 OB20 OD21 0820 OD21 2826 2825 OB20 OF21 OE21 0021 OC20 OD21 OB20 OD21 OC20 OD21 QB20 0021 OA20 2825 2826 OA20 OF21 OE21 OB20 OE21 0820 1 OD21 0820 0021 0820 OD21 QB20 OD21 2825 2825 OA20 OF21 QC20 QE21 0820 OD21 10820 OD21 0820 0021 OA20 0021 OB20 2825 2825 0A20 QF21 QC20 OE21 OB20 OD21 0820 0021 Q820 OD21 0A20 OD21 0820 2825 2826 0A20 OF21 QE21 QB20 OE21 0820 1 0021 OB20 0021 OB20 OD21 0820 OD21 2826 2625 0820 OF21 QE21 OD21 OC20 0021 1 0820 0021 QC20 Q021 OB20 QD21 OA20 2825 2826 0820 OB20 OC20 OE21 QD21 OC20 1 OD21 OB20 OD21 OB20 OD21 0820 OD21 2828 2825 2826 OB20 OF21 OE21 OC20 OD21 10A20 OD21 0820 OD21 QC20 0021 0820 2825 2825 QA20 OF21 OE21 OE21 QC20 1 0021 0820 0021 OB20 QD21 QB20 OD21 2826 2825 QA20 OF21 QC20 OD21 QC20 OD21 QA20 OD21 QB20 0021 0820 2825 2826 2828 QA20 OF21 QD21 1 0021 OC20 OD21 QC20 Q021 QB20 OD21 2825 2825 2825 OB20 2828 OF21 1 OC20 OE21 OC20 0021 OC20 OE21 0820 2825 2825 2826 0820 OA20 OF21 CE21 OE21 OE21 OD21 Q820 QE21 2826 2825 2825 2825 1 QA20 OF21 OF21 OC20 OE21 OE21 QC20 2825 2825 2826 2825 0A20 OB20 0820 OF21 OF21 OF21 2825 1 2825 2826 2825 2826 QB20 QB20 OA20 QA20 2825 2825 2825 2825 2826 2825 2826 1 2825 1 2826 1 2825 1 2825 Page 11 of 17 NF-BEX- 11-3, Rev. I NP-Attachment

Figure 2 - Quad Cities 1 Cycle 21 - Reference Loading Pattern 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 Legends Center 2825 2825 2826 2825 2826 ASYTYP 2825 2828 2825 2825 2825 2825 QA20 QA20 Q820 Q820 2825 2825 2828 2525 2825 QF21 QF21 OF21 0820 OB20 QA20 2825 2826 2825 2825 OC20 OE21 OE21 OC20 QF21 OF21 0A20 2825 2825 2825 2826 QE21 OB20 Q021 OE21 OE21 QE21 OF21 OA20 OB20 2826 2825 2825 0820 0621 0020 0021 QC20 0E21 0C20 OF21 2826 0820 2825 2815 2825 0021 0620 0021 0C20 0021 OC20 0021 0021 0F21 0A20 2826 2626 2825 0020 0021 0820 0021 0A20 0021 0C20 0021 0020 0021 QA20 2825 2826 0021 0620 0021 0820 0021 OB20 0021 0020 0821 0E21 0021 QAZO 2825 2825 0820 0021 0020 0021 0920 0021 OA20 0021 0020 0521 0F21 0820 2826 2825 2828 0021 0920 0021 0820 0021 0620 QD21 0C20 0021 0821 0020 0620 0820 2826 2825 0A20 0021 OB20 0021 0020 0021 0820 0021 0C20 0021 0821 OF21 0920 2825 2826 0021 0820 0021 0820 0021 0620 0021 0820 QE21 0820 0621 OF21 0A20 2826 2825 0820 0021 OA20 0021 0620 0021 OB20 0021 0820 0E21 0C20 0F21 0A20 2825 2825 0820 0021 0A20 0021 0520 0021 0820 0021 0820 0E21 0020 0F21 0A20 2825 2825 0021 p820 0021 0820 0021 0820 OD21 0820 0821 0820 0521 0021 0020 2828 2825 0A20 0021 0820 0021 QC20 0021 0820 OD21 0020 0021 0521 0F21 0620 2825 2826 0021 0820 0021 0820 0021 0820 0021 0020 QD21 0E21 0020 0820 0620 2826 2825 0820 0021 0C20 0021 0820 0021 OA20 0021 0020 0821 OF21 0820 2826 2825 2826 0021 0820 0021 0820 0021 0820 0021 0020 0521 0621 0021 0A20 2825 2825 0820 0021 0820 0021 0A20 0021 0020 0021 0C20 0021 0A20 2825 2826 0021 0820 0021 Qczo 0021 0020 0021 0021 0F21 00,20 2826 2826 2825 0920 0821 0C20 0021 0020 0821 0C20 0021 2826 0820 2825 2825 2825 I

OE21 OB20 I OD21 QE21 OE21 OE21 OF21 QA20 OB20 2826 2825 2825 QC20 OE21 QE21 OC20 OF21 QF21 OA20 2825 2825 2825 2828 QF21 OF21 QF21 0020 OB20 OA20 2825 1 2826 2825 2825 QA20 OA2o 0820 QB20 2826 2825 2828 1 2825 2825 2825 2828 2825 2825 2825 2825 2825 2825 2826 2825 2826 Page 12 of 17 NF-BEX- 11-3, Rev. I NP-Attachment

Bundle Cycle Name Number Enrichment Type Loaded QA20 Opt2-3.99-15GZ8.00-3G6.00 56 3.99 20 QB20 Opt2-4.00-13GZ8.00-3G6.00 112 4.00 20 QC20 Opt2-4.05-12GZ7.00-2G6.00 68 4.05 20 QD21 Opt2-3.98-18GZ8.00 148 3.98 21 QE21 Opt2-3.99-16GZ8.00 64 3.99 21 QF21 Opt2-4.01-14GZ6.00 56 4.01 21 QG22 Opt2-4.07-19GZ7.50/5.50 104 4.07 22 QH22 Opt2-4.07-17GZ7.50/5.50 56 4.07 22 Q122 Opt2-4.12-12G5.50-2GZ5.50 60 4.12 22 Bundle Cycle Name Number Enrichment Type Loaded 2825 0E14-P1 ODNAB409-17GZ-100T-145-T6-2825 128 4.09 19 2826 GE14-P1 ODNAB408-15GZ-100T-145-T6-2826 68 4.08 19 QA20 Opt2-3.99-15GZ8.00-3G6.00 56 3.99 20 QB20 Opt2-4.00-13GZ8.00-3G6.00 136 4.00 20 QC20 Opt2-4.05-12GZ7.00-2G6.00 68 4.05 20 QD21 Opt2-3.98-18GZ8.00 148 3.98 21 QE21 Opt2-3.99-16GZ8.00 64 3.99 21 QF21 Opt2-4.01-14GZ6.00 56 4.01 21 100% ZPU Power - 2957 MW.,,

1008 Core Flow - 98.0 Mlb/hr I 3200 A: 93.6 k  ? / 23.0 k F E 3: 59.2 P / 35.5 F C: 100. 0 % e / 95.3 % F 0: 100.0  ? / 100.0 F 12800 100.0 %  ? / 108.0 F F: 27.0 k  ? / 108.0 k F G: 18.8 % P / 36.6 k'

.., 39.9:  ? 88.5 k F 10 40 50 60 Core Fiow (%)

Page 13 of 17 NF-BEX-11-3, Rev. I NP-Attachment

Figure 4 - Quad Cities 1 Cycle 22 SLMCPR Results for SVEA-96 Optima2 Fuel

-Ia,c Page 14 of 17 NF-BEX-1 1-3, Rev. I NP-Attachment

Figure 5 - Assembly Histograms a,c Page 15 of 17 NF-B EX-11-3 Rev. 1 NP-Attachment

Figure 6 - Assembly Histograms a,c Page 16 of 17 NF-BEX-11-3 Rev. 1 NP-Attachment

Figure 7 - Assembly Histograms a,c Page 17 of 17 NF-BEX-11-3 Rev. 1 NP-Attachment