Text

Request for License Amendment Regarding Spent Fuel Storage Pool Criticality Methodology for Fuel Channel Bow/Bulge
	ML15348A396
Person / Time
Site:	Quad Cities
Issue date:	12/14/2015
From:	Simpson P; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
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ML15348A395	List: RS-15-326, Request for License Amendment Regarding Spent Fuel Storage Pool Criticality Methodology for Fuel Channel Bow/Bulge;
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	RS-15-326
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4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office Proprietary Information - Withhold From Public Disclosure Under 10 CFR 2.390 RS-15-326 10 CFR 50.90 December 14, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Request for License Amendment Regarding Spent Fuel Storage Pool Criticality Methodology for Fuel Channel Bow/Bulge 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 Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, respectively. The proposed change would allow use of a new Criticality Safety Analysis (CSA) fuel channel bow/bulge methodology for performing the criticality safety evaluation for the new ATRIUM 10XM fuel design in the spent fuel pool. A description and evaluation of the proposed change is attached.

This license amendment request was discussed with the NRC in a pre-application meeting on May 11, 2015. During the meeting, the NRC questioned the treatment of tolerances and uncertainties in the analysis. To address the concerns, the NRC requested EGC to include more detail concerning the treatment of tolerances and uncertainties. Accordingly, the requested information is attached.

This request is subdivided as follows.

Attachment 1 provides a description and evaluation of the proposed change.

Attachment 2 provides AREVA, Inc. Report FS1-0024092, Revision 1.0, "Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Analyses - Proprietary Version."

Attachment 3 provides a comparison of the approach used in the NRC-approved SVEA-96 Optima2 CSA to the approach used in the proposed ATRIUM 10XM CSA, as well as a comparison of the SVEA-96 Optima2 and ATRIUM 10XM biases and uncertainties. This information was requested by the NRC in a pre-application meeting that was held on May 11, 2015.

Attachments 2 and 3 contain Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 2 and 3, this document is decontrolled.

December 14, 2015 U.S. Nuclear Regulatory Commission Page2 contains information proprietary to AREVA, Inc.; it is supported by an affidavit signed by AREVA, Inc., 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, 11 Public inspections, exemptions, requests for withholding. 11 Accordingly, it is respectfully requested that the information which is proprietary to AREVA, Inc. be withheld from public disclosure in accordance with 10 CFR 2.390. A nonproprietary version of Attachment 2 is provided in Attachment 5. contains information proprietary to Holtec International; it is supported by an affidavit signed by Holtec International, the owner of the information. The affidavit, provided in , 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. Accordingly, it is respectfully requested that the information which is proprietary to Holtec International be withheld from public disclosure in accordance with 10 CFR 2.390. A nonproprietary version of Attachment 3 is provided in Attachment 7.

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

EGC requests approval of the proposed change by December 14, 2016. Once approved, the amendment will be implemented within 60 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, 11 Notice for public comment; State consultation, 11 paragraph (b), EGC is notifying the State of Illinois of this application for license amendment 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. Kenneth M. Nicely at {630) 657-2803.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of December 2015.

Attachments:

1. Evaluation of Proposed Change

2. AREVA, Inc. Report FS1-0024092, Revision 1.0, 11 lnformation to Support EXELON RAI Responses for Spent Fuel Pool Criticality Analyses - Proprietary Version 11

December 14, 2015 U.S. Nuclear Regulatory Commission Page 3

3. Table 1: Criticality Safety Analysis (CSA) Approach Comparison, and Table 2:

Comparison of the ATRIUM 10XM and SVEA-96 Optima2 Biases and Uncertainties (Proprietary Version)

4. AREVA, Inc. Affidavit

5. AREVA, Inc. Report FS1-0024106, Revision 1.0, "Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Analyses - Nonproprietary Version"

6. Holtec International Affidavit

7. Table 1: Criticality Safety Analysis (CSA) Approach Comparison, and Table 2:

Comparison of the ATRIUM 10XM and SVEA-96 Optima2 Biases and Uncertainties (Nonproprietary Version) cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

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

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Page 1

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 Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, respectively. The proposed change would allow use of a new Criticality Safety Analysis (CSA) fuel channel bow/bulge methodology for performing the criticality safety evaluation for the new ATRIUM 10XM (A10XM) fuel design in the spent fuel pool (SFP).

2.0 DETAILED DESCRIPTION EGC is planning to transition from Westinghouse SVEA-96 Optima2 fuel to the new AREVA A10XM fuel design at QCNPS in spring 2017. Based on the EGC plans to transition to a new fuel design, Holtec International revised the SFP CSA to account for the new A10XM fuel.

While this revised SFP CSA supports the planned transition to A10XM fuel, this new analysis is not required to support the NRC review and approval of the separate fuel transition amendment request submitted on February 6, 2015 (i.e., Reference 1).

In Reference 2, the NRC issued Amendment No. 253 to Renewed Facility Operating License No. DPR-29 and Amendment No. 248 to Renewed Facility Operating License No. DPR-30 for QCNPS Units 1 and 2, respectively. These amendments established the SFP CSA methodologies for QCNPS. The revised SFP CSA for A10XM fuel has been performed in accordance with these NRC reviewed and approved methodologies, with the exception of the treatment of fuel channel bow/bulge. The NRC Safety Evaluation associated with Amendment Nos. 253 and 248 stated:

While the methodology evaluated by NRC staff in the NCS analyses submitted for review was found to be acceptable, the methodology did omit details on the appropriate approach to use in evaluation of fuel channel bowing/bulging or reconstituted fuel. The licensee provided a satisfactory explanation for not including these conditions in the current analysis, but declined to provide a detailed explanation of how these conditions might be modeled (including potential conservatisms/non-conservatisms, uncertainties, and biases). Therefore, the findings in this safety evaluation do not extend to such conditions.

Consequently, the fuel channel bow/bulge methodology used in the revised SFP CSA for A10XM fuel is submitted at this time for NRC review and approval.

3.0 TECHNICAL EVALUATION

QCNPS Updated Final Safety Analysis Report (UFSAR) Section 9.1.2 documents the QCNPS, Units 1 and 2 SFP safety design bases as summarized below. The similarity of the SFP storage rack designs for the two units permit a single set of supporting analyses to apply to both units.

The spent fuel assembly racks, with NETCO-SNAP-IN rack inserts, are designed to ensure subcriticality in the storage pool. A maximum keff of 0.95 is maintained with the racks fully Page 2

ATTACHMENT 1 Evaluation of Proposed Change loaded with fuel of the highest anticipated reactivity and flooded with unborated water at a temperature corresponding to the highest reactivity.

The spent fuel storage pools have been designed to withstand the anticipated earthquake loadings as a Class I structure.

The high-density racks are engineered to achieve the dual objective of maximum protection against structural loading (such as ground motion) and the maximization of available storage locations.

There are various legacy fuel assembly designs, including the current SVEA-96 Optima2 design that are qualified for storage in the QCNPS Units 1 and 2 SFPs as documented in QCNPS UFSAR Section 9.1.2.3.

EGC is planning to transition from Westinghouse SVEA-96 Optima2 fuel to the AREVA A10XM fuel design at QCNPS. To support future operations, the A10XM fuel assembly is designed to be compatible with the QCNPS reactor core and co-resident legacy fuel. The A10XM fuel assembly is constructed of similar materials within a spatial envelope that is similar to the currently licensed SVEA-96 Optima2 legacy fuel type. The A10XM design must be qualified for storage in the QCNPS Units 1 and 2 SFPs.

A CSA for the QCNPS Units 1 and 2 SFPs has been performed to support the planned transition to A10XM fuel. The A10XM CSA uses the CSA methodology approved in Reference 2 with the exception of the fuel channel bow/bulge treatment. Specifically, the A10XM CSA was performed using the computer codes CASMO-4 and MCNP5, a peak reactivity lattice, a minimum Boron-10 areal density in the QCNPS SFP rack inserts of 0.0116 g/cm2, and incorporating fuel assembly and storage rack manufacturing tolerances consistent with the CSA approved in Reference 2. Attachment 3, Table 1, provides a comparison of the A10XM CSA and the CSA approaches approved in Reference 2. This comparison was requested by the NRC in a pre-application meeting that was held on May 11, 2015.

Fuel channel bulging and bowing is a depletion related geometry change that changes the proximity of the channel to the fuel rods. The volume of moderator inside the channel is impacted by this change in distance from the channel to fuel rods. Thus, the fuel to moderator ratio may change during depletion, as a result of fuel channel bulging and bowing.

A fuel channel bow/bulge bias and uncertainty is not included in the total biases and uncertainties for the A10XM fuel (see Attachment 3, Table 2) because the peak reactivity of the A10XM lattices is at about 10-15 GWD/MTU. As shown in Attachment 2, Figures 1 and 3, fuel geometry changes are not expected to occur for the A10XM fuel design at such low exposures.

Beyond this exposure range, the fuel channel bow/bulge does increase. However, the reactivity increase from this geometry change is offset by the decrease in reactivity of the fuel with exposure.

The results of the A10XM SFP CSA demonstrate that the total biases and uncertainties for the A10XM fuel are less than the total biases and uncertainties for the SVEA-96 Optima2 fuel (see Page 3

ATTACHMENT 1 Evaluation of Proposed Change , Table 2). Therefore, the keff of an A10XM assembly is bounded by the keff of an equivalent reactivity SVEA-96 Optima2 assembly.

The CSA for the storage of A10XM assemblies in the QCNPS spent fuel storage racks with NETCO-SNAP-IN rack inserts has been performed. The results for the normal condition show that keff is < 0.95, with a 95 percent probability at a 95 percent confidence level, with the storage racks fully loaded with A10XM fuel at the Technical Specifications 4.3.1.1.c maximum in-rack k-infinity limit. The results for the bounding accident condition (i.e., missing insert with centric fuel positioning) also show that keff is < 0.95, with a 95 percent probability at a 95 percent confidence level, with the storage racks fully loaded with A10XM fuel at the Technical Specifications 4.3.1.1.c maximum in-rack k-infinity limit.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.68, "Criticality accident requirements," paragraph (b)(4) states that the keff of the spent fuel storage racks loaded with fuel of the maximum fuel assembly reactivity and flooded with unborated water must not exceed 0.95, at a 95 percent probability, 95 percent confidence level. A SFP CSA has been performed to demonstrate that this requirement is met.

Paragraph (b)(7) of 10 CFR 50.68 states that the maximum nominal U-235 enrichment of the fresh fuel assemblies is limited to 5.0 percent by weight. QCNPS new fuel is below 5.0 percent by weight U-235 enrichment.

The following General Design Criterion (GDC) is applicable to this amendment request.

It should be noted that, although QCNPS is not formally committed to the GDC due to the vintage of the station, an evaluation was performed addressing the QCNPS conformance with the GDC. This evaluation is documented in the UFSAR Section 3.1, "Conformance with NRC General Design Criteria." This evaluation concluded that QCNPS fully satisfies the intent of the (then draft) GDC.

GDC 5, "Sharing of structures, systems, and components," specifies that structures, systems, and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units. The spent fuel storage pool has been designed to withstand the anticipated earthquake loadings as a Class I structure.

Each unit has its own SFP measuring 33 x 41 feet. The fuel storage pools of Units 1 and 2 are connected by a double-gated transfer canal. The fuel pool is a reinforced-concrete structure, lined with seam-welded, stainless steel plate, welded to reinforcing members embedded in concrete. The 3/16-inch stainless steel liner will prevent leakage in the unlikely event the concrete develops cracks. To avoid unintentional draining of the pool, there are no penetrations that would permit the pool to be drained below a safe storage level. The passage between the fuel storage pool and the reactor cavity is located above the reactor vessel, is constructed with two, double-sealed gates and has a monitored drain between the gates. This arrangement permits detection of leaks from Page 4

ATTACHMENT 1 Evaluation of Proposed Change the passage and repair of a leaking gate. The depth of water in the fuel storage pool is approximately 37 feet 9 inches and the depth of the water in the transfer canal during refueling is 22 feet 9 inches. The proposed change only modifies the methodology for treating fuel channel bow/bulge in the SFP CSA; therefore, compliance with GDC 5 is not affected by the proposed change.

GDC 62, "Prevention of criticality in fuel storage and handling," states that criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations. The evaluation of QCNPS's conformance with GDC 62 is discussed in Section 9.1.2, "Spent Fuel Storage," of the QCNPS UFSAR. A SFP CSA has been performed to demonstrate that keff will remain less than or equal to 0.95 while accounting for potential A10XM fuel channel bow/bulge. Therefore, compliance with GDC 62 is not affected by the proposed change.

4.2 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 Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, respectively. The proposed change would allow use of a new Criticality Safety Analysis (CSA) fuel channel bow/bulge methodology for performing the criticality safety evaluation for the new ATRIUM 10XM fuel design in the spent fuel pool (SFP).

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 any 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, 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.

Page 5

ATTACHMENT 1 Evaluation of Proposed Change

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

Response: No The proposed change involves a revised CSA for the QCNPS Units 1 and 2 SFPs using a new fuel channel bow/bulge methodology. The proposed change does not alter or modify the fuel, fuel handling processes, spent fuel storage racks, number of fuel assemblies that may be stored in the SFP, decay heat generation rate, or the SFP cooling and cleanup system.

The proposed change was evaluated for impact on the following previously evaluated events and accidents:

A fuel handling accident (FHA),

A fuel mispositioning event,

A seismic event, and

A loss of SFP cooling event.

The probability of a FHA is not increased because implementation of the proposed change will employ the same equipment and processes to handle fuel assemblies that are currently used. The FHA radiological consequences are not increased because the fuel channel bow/bulge methodology used in the CSA does not impact the radiological source term of a single fuel assembly.

Therefore, the proposed change does not significantly increase the probability or consequences of an FHA.

Operation in accordance with the proposed change will not significantly increase the probability of a fuel mispositioning event because fuel movement will continue to be controlled by approved fuel handling procedures. These procedures continue to require identification of the initial and target locations for each fuel assembly that is moved. The consequences of a fuel mispositioning event are not changed because the reactivity analysis demonstrates that the new subcriticality criteria and requirements will be met for the worst-case fuel mispositioning event.

Operation in accordance with the proposed change will not change the probability of a seismic event. The consequences of a seismic event are not increased because the forcing functions for seismic excitation are not increased and because the mass of storage racks has not changed.

Operation in accordance with the proposed change will not change the probability of a loss of SFP cooling event because the systems and events that could affect SFP cooling are unchanged. The consequences are not significantly increased because there are no changes in the SFP heat load or SFP cooling systems, structures or components due to the proposed change in fuel channel bow/bulge methodology used in the CSA.

Page 6

ATTACHMENT 1 Evaluation of Proposed Change 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 Onsite storage of spent fuel assemblies in the QCNPS, Units 1 and 2, SFPs is a normal activity for which QCNPS has been designed and licensed. As part of assuring that this normal activity can be performed without endangering the public health and safety, the ability to safely accommodate different possible accidents in the spent fuel pool have been previously analyzed. These analyses address accidents such as radiological releases due to dropping a fuel assembly; and potential inadvertent criticality due to misloading a fuel assembly. The proposed change does not alter the method of fuel movement or spent fuel storage and does not create the potential for a new accident.

The proposed use of a new fuel channel bow/bulge methodology for performing the QCNPS revised SFP CSA does not change or modify the fuel, fuel handling processes, spent fuel racks, number of fuel assemblies that may be stored in the pool, decay heat generation rate, or the SFP cooling and cleanup system.

The limiting fuel assembly mispositioning event does not represent a new or different type of accident. The mispositioning of a fuel assembly within the fuel storage racks has always been possible. The proposed change involves a revised CSA for the QCNPS, Units 1 and 2, SFPs using a new fuel channel bow/bulge methodology. The associated analysis results show that the storage racks remain sub-critical, with substantial margin, following a worst-case fuel misloading event.

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

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

Response: No The proposed change involves a revised CSA for the QCNPS, Units 1 and 2, SFPs using a new fuel channel bow/bulge methodology. This change was evaluated for its effect on margins of safety related to criticality and spent fuel heat removal capability.

QCNPS Technical Specifications Section 4.3, "Fuel Storage," Specification 4.3.1.1.a requires the spent fuel storage racks to maintain the effective neutron multiplication factor, keff, less than or equal to 0.95 when fully flooded with unborated water, which includes an allowance for uncertainties. Therefore, for SFP criticality considerations, the required safety margin is five percent.

Page 7

ATTACHMENT 1 Evaluation of Proposed Change The proposed change ensures, as verified by the associated criticality analysis, that keff continues to be less than or equal to 0.95, thus preserving the required safety margin of five percent.

The proposed use of a new fuel channel bow/bulge methodology for performing the QCNPS SFP CSA does not affect spent fuel heat generation or the spent fuel cooling systems.

In addition, the radiological consequences of a dropped fuel assembly remain unchanged as the anticipated fuel damage due to a fuel handling accident is unaffected by the use of a new fuel channel bow/bulge methodology to perform the CSA. The proposed change also does not increase the capacity of the Unit 1 and Unit 2 spent fuel pools beyond the current capacity of no more than 3657 and 3897 fuel assemblies, respectively.

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

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

4.3 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 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 needs to be prepared in connection with the proposed amendment.

Page 8

ATTACHMENT 1 Evaluation of Proposed Change

6.0 REFERENCES

1. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Request for License Amendment Regarding Transition to AREVA Fuel," dated February 6, 2015

2. Letter from B. Mozafari (U.S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC),

"Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments Regarding NETCO Inserts (TAC Nos. MF2489 and MF2490)(RS-13-148)," dated December 31, 2014 Page 9

ATTACHMENT 4 AREVA, Inc. Affidavit

AFFIDAVIT STATE OF WASHINGTON )

) SS.

COUNTY OF BENTON )

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.

3. I am familiar with the AREVA information contained in the report FS1-0024092, Revision 1, "Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Analyses - Proprietary Version," dated October 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary inforniation is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA's research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.

7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.

I

8. AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this _ _ __

7 "f"--

day of a~t..54"" I 2015.

~~~:~

Susan K. McCoy NOTARY PUBLIC, STATE OF W : :TON MY COMMISSION EXPIRES: 1/14/2016 SS::

ATTACHMENT 5 AREVA, Inc. Report FS1-0024106, Revision 1.0, "Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Analyses - Nonproprietary Version"

IDENTIFICATION REVISION I

FS1-0024106 11 1.0 I

AREVA Front End BG Fuel BL A

AREVA TOTAL NUMBER OF PAGES: 13 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Analyses - Nonproprietary Version ADDITIONAL INFORMATION:

ATRIUM 10XM, EXELON, Quad Cities, Dresden Charge Number: P.500089-C-DRE325100B5, "RAI Support for Fuel Transition" This is the Nonproprietary version of FS 1-0024092.

PROJECT DISTRIBUTION TO PURPOSE OF DISTRIBUTION ANDERSON Michael HANDLING Restricted AREVA MON Kevin EIR - Engineering MORRIS Jeffrey CATEGORY WILL Anthony Information Report STATUS This document is electronically approved. Records regarding the signatures are stored in the Fuel BU Document Database. Any attempt to modify this file may subject employees to civil and criminal penalties. EDM Object Id: 0901216780811c61 - Release date (YYYY/MM/00): 2015/10/07 20:46:02 [Western European Time]

Role Name Date <YYXYIMM/OOl Orgaojzation Writer ANDERSON Michael 2015/10/07 19:58:20 AREVA Inc.

Reviewer MON Kevin 2015110/07 20:37:11 AREVA Inc.

Approver MEGINNIS Alan 2015/10/07 20:41:06 AREVA Inc.

Approver MORRIS Jeffrey 2015/10/07 20:45:56 AREVA Inc.

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lnnergemelnschaflllchen Verbrlngung der auropllschen bzw. deutschan Ausfuhrganehmlgungspfllcht. Die mil "ECCN unglelch N" gekennzelchneten GOiar untarllagen der US-Reaxportgenehmlgungspfllcht. Auch ohne Kennzelchan, bzw. bel Kennzelchen "AL: N" oder "ECCN: N", kann slch elne Genehmlgungspfllcht, unter andarem durch den Endverblelb und Verwandungszweck der Gater, ergeben.

SAFETY RELATED DOCUMENT: y Export classification AL: OE001 ECCN: OE001 Goods labeled with "AL not equal to N" are subject to European or German export authorization CHANGE CONTROL RECORDS: France: N when being exported within or out of the EU. Goods labeled with "ECCN not equal to N" are subject This document, when revised, must be USA: y to US reexport authorization. Even without a label, or with label "AL: N" or"ECCN: N", authorization may be required due to the final whereabouts and purpose for which the goods are to be used.

reviewed or approved by the following regions: Germany: N CW01L Rav. 4.3-3/4115

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 2/13 Analyses - Nonproprietary Version REVISIONS REVISION DATE EXPLANATORY NOTES 1.0 See 1st page New document.

release date This is the Nonproprietary version of FS1-0024092.

AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 3/13 Analyses - Nonproprietary Version TABLE OF CONTENTS

1. PURPOSE ........................................................................................................................................ 4

2. METHODOLOGY/APPROACH ........................................................................................................ 5

3. ASSUMPTIONS ............................................................................................................................... 6 3.1. ASSUMPTIONS ....................................................................................................................................... 6 3.2. ASSUMPTIONS REQUIRING VERIFICATION ....................................................................................... 6

4. DETERMINATION OF VALUES ...................................................................................................... 7 4.1. EQUIVALENT FAST FLUENCE .............................................................................................................. 7 4.2. EXPECTED FUEL ROD GROWTH ......................................................................................................... 7 4.3. CLADDING CREEP ................................................................................................................................. 7 4.4. CHANNEL BOW AND BULGE ................................................................................................................ 7

5. REFERENCES ............................................................................................................................... 13 LIST OF TABLES Table 1 Assembly Fast Fluence by Exposure .............................................................................................7 LIST OF FIGURES Figure 1 Mean Bulge by Exposure for Different Channel Geometries .........................................................9 Figure 2 Bulge Standard Deviations by Exposure for Different Channel Geometries ...............................10 Figure 3 Mean Bow by Exposure for Different Channel Geometries .........................................................11 Figure 4 Bow Standard Deviations by Exposure for Different Channel Geometries .................................12 AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 4/13 Analyses - Nonproprietary Version

1. PURPOSE As a part of the licensing of ATRIUM 10XM fuel assemblies for the Dresden and Quad Cities units, the customer, EXELON, has had spent fuel rack criticality analyses performed by another vendor. The submittal of these analyses to the NRC has resulted in two Requests for Additional Information (RAIs) related to AREVA fuel assembly and fuel channel performance. These RAIs read as follows:

11. Sections 2.3.11.1.1 and 2.3.11.1.2 of the HI-2146153 analysis explain that fuel rod growth, cladding creep, and crud buildup do not need to be evaluated because these factors are not expected to be significant at the peak reactivity burnup of the design basis lattice. Changes to the fuel rod geometry as a result of irradiation may result in a positive reactivity impact.

Provide information regarding the expected fuel rod growth, cladding creep, and crud buildup at this burnup, and explain why the reactivity impact would not be significant.

13. Section 2.3.11.2 of the HI-2146153 analysis does not describe clearly how the geometry is changed to evaluate fuel channel bulging and bowing. The text refers to the channel outer exposed width tolerance, but it is not clear if the outer exposed width is changed by varying the channel inner width or the channel wall thickness.

Describe how the MCNP model was altered for Case 2.3.11.2.1. Also, discuss how the channel bowing tolerance was determined and how it bounds any expected ATRIUM 10XM channel bulging/bowing.

The customer has requested that such information be provided for fuel assembly exposures in the ranges of 10-20 GWd/MTU and 40-50 GWd/MTU.

Specific AREVA information requested to support responses to these RAIs are: 1) expected fuel rod growth; 2) cladding creep; 3) crud buildup; and 4) channel bowing and bulge. For fuel rod crud buildup, such data are core-dependent and must be supplied by the customer.

AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 5/13 Analyses - Nonproprietary Version

2. METHODOLOGY/APPROACH This Engineering Information Record provides values responsive to the requests described in §1 based on design bases related to fuel channel design or design basis data for the RODEX4 methodology, which is used to analyze the thermal-mechanical performance of ATRIUM 10XM fuel rods.

AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 6/13 Analyses - Nonproprietary Version

3. ASSUMPTIONS 3.1. ASSUMPTIONS There are no assumptions made in this EIR.

3.2. ASSUMPTIONS REQUIRING VERIFICATION There are no assumptions requiring verification as all values are obtained from quality records.

AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 7/13 Analyses - Nonproprietary Version

4. DETERMINATION OF VALUES 4.1. EQUIVALENT FAST FLUENCE Since the growth of the Zircaloy comprising the fuel rods is well correlated with fast neutron fluence, mechanistic or correlative models of fuel rod growth and cladding creep are provided as a function of this fluence. Since the customer has requested the information described above as a function of assembly-averaged exposure, it is necessary to provide fast fluence ranges that correspond to those exposure ranges. Approximate values are shown in Table 1 [2, Fig. 2].

Table 1 Assembly Fast Fluence by Exposure 4.2. EXPECTED FUEL ROD GROWTH For expected fuel rod growth, which includes both growth and PCMI-induced creep, appropriate values in are found in the response to RAI #3 in the first round of RAIs to the RODEX4 topical report [1, BAW-10247Q1(P), p. 4]. Upper limits for both of the exposure ranges, based on the BWR data compilation are

[ ] for the 10 GWd/MTU to 20 GWd/MTU range, and [ ] for the 40 GWd/MTU to 50 GWd/MTU range.

4.3. CLADDING CREEP Cladding creep, manifesting itself in diametral reduction is shown the RODEX4 topical report [1, Figure 4.16]. For the first exposure interval of 10 GWd/MTU to 20 GWd/MTU, the maximum reduction is less than [ ], while for the second exposure interval of 40 GWd/MTU to 50 GWd/MTU, the maximum reduction is bounded by [ ].

4.4. CHANNEL BOW AND BULGE The RODEX4 methodology does not consider channel bulge as bulge occurs predominantly at axial locations where there is little or no in-channel voiding. In addition, the RODEX4 methodology places no limits on channel bowing, but explicitly computes bowing based on fast fluence gradients across the channel and accordingly penalizes linear power margins. As a part of the channel mechanical design methodology, channel bow and bulge statistics are provided as inputs to a Monte Carlo methodology for assessing interference with control blades [3, §7.0]. Plots of these statistics are provided as function of exposure and lattice geometry in Figure 1 through Figure 4 [3, Figures 7.7 through 7.10]. The values denoted as D-lattice 2.54 mm correspond to 100 mil D-lattice channels, while those denoted as D-lattice 2.10 mm correspond to 80 mil D-lattice channels. [ ]

AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 8/13 Analyses - Nonproprietary Version

[

] reasonably bounds the observed population of channels for each exposure range.

AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 9/13 Analyses - Nonproprietary Version Figure 1 Mean Bulge by Exposure for Different Channel Geometries AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 10/13 Analyses - Nonproprietary Version Figure 2 Bulge Standard Deviations by Exposure for Different Channel Geometries AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 11/13 Analyses - Nonproprietary Version Figure 3 Mean Bow by Exposure for Different Channel Geometries AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 12/13 Analyses - Nonproprietary Version Figure 4 Bow Standard Deviations by Exposure for Different Channel Geometries AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

N° FS1-0024106 Rev. 1.0 Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Handling: Restricted AREVA Page 13/13 Analyses - Nonproprietary Version

5. REFERENCES 1 BAW-10247PA, Revision 0. Realistic Thermal-Mechanical Fuel Rod Methodology for Boiling Water Reactors. April 2008.

2 [

]

3 EMF-93-177(P)(A), Revision 1. Mechanical Design for BWR Fuel Channels. August 2005.

AREVA - Fuel BL This document is subject to the restrictions set forth on the first or title page

ATTACHMENT 6 Holtec International Affidavit

HOLTEC INTERNATIONAL Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 Fax(856)797-0909 Holtec International Document ID 2127008-AFF-Ol AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Debabrata (Debu) Mitra Majumdar, being duly sworn, depose and state as follows:

(1) I have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.

(2) The information sought to be withheld is information provided in the following reports.

a. Table 1: Criticality Safety Analysis (CSA) Approach Comparison

b. Table 2: Comparison of the ATRIUM lOXM and SVEA-96 Optima Biases and Uncertainties.

These tables contain Holtec proprietary information. A non-proprietary version of the tables is provided for disclosure.

(3) In making this application for withholding of proprietary information of which it is the owner, Holtec International 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 10CFR Part 9.l 7(a)(4), 2.390(a)(4), and 2.390(b)(l) 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, 704F2d1280 (DC Cir. 1983).

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Holtec International Document ID 2127008-AFF-01 AFFIDAVIT PURSUANT TO 10 CFR 2.390 (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 Holtec's competitors without license from Holtec International 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 Holtec International, its customers, or its suppliers;

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

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

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraph 4.b, above.

(5) The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or 2of5

Holtec International Document ID 2127008-AFF-Ol AFFIDAVIT PURSUANT TO 10 CFR 2.390 proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(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.

Access to such documents within Holtec International 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 designee), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.

Disclosures outside Holtec International 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 classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed descriptions of analytical approaches and methodologies not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec' s competitor to copy our technology and offer it for sale in competition with our company, causing us financial injury.

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Holtec International Document ID 2127008-AFF-01 AFFIDAVIT PURSUANT TO 10 CFR 2.390 (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part ofHoltec International's comprehensive spent fuel storage 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.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.

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.

Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International 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 Holtec International 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 Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

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Holtec International Document ID 2127008-AFF-01 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY )

) ss:

COUNTY OF BURLINGTON )

Mr. Debabrata (Debu) Mitra Majumdar, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.

Executed at Marlton, New Jersey, this 1st day of December, 2015.

Debabrata (Debu) Mitra Majumdar, Ph.D.

Holtec International Subscribed and sworn before me this 1 day of ___D_e_c_e_m~b~er___, 2015.

MARIA C. MASSI NOTARY PUBLIC OF NEW JERSEY M¥ Commission Expires April 25, 2020 5of5

ATTACHMENT 7 Table 1: Criticality Safety Analysis (CSA) Approach Comparison, and Table 2: Comparison of the ATRIUM 10XM and SVEA-96 Optima2 Biases and Uncertainties (Nonproprietary Version)

NON-PROPRIETARY VERSION Computer Codes MCNP5-1.51 MCNP5-1.51 CASM04-2.05.14 CASM04-2.05.14 MCNP5 Verification and Holtec International Report No. Holtec International Report No.

Validation Hl-2104790, Revision 1, Hl-2104790, Revision 1, "Nuclear Group Computer Code "Nuclear Group Computer Benchmark Calculations." Code Benchmark Calculations."

MCNP5 Cross Section Library ENDF/B-Vll ENDF/B-Vll CASM04 Cross Section 70 group ENDF (supplemented 70 group ENDF (supplemented Library for some cases) for some cases)

Depletion Uncertainty 5% of reactivity decrement 5% of reactivity decrement Lattice Reactivity Basis Peak in-rack from MCNP5-1.51 Peak in-rack from MCNP5-1.51 using nominal fuel assembly using nominal fuel assembly and storage rack dimensions and storage rack dimensions, exceeded Tech Spec 4.3.1.1.c maximum k-infinity value*

Axial Burnup Profile Uniform Uniform SFP Water Temperature Bounding Bounding Core Operating Parameters Bounding Bounding Fuel Assembly Tolerances - Enrichment - Enrichment

- Gadolinia loading - Gadolinia loading

- Pellet density - Pellet density

- Pellet outer diameter - Pellet outer diameter

- Cladding inner diameter - Cladding inner diameter

- Cladding outer diameter - Cladding outer diameter

- Pin pitch - Pin pitch

- Sub-bundle pitch - Channel wall thickness

- Combined channel width dimensions

- Combined channel wall thicknesses

NON-PROPRIETARY VERSION De-channeled Legacy fuel types only (not Channeled and De-channeled SVEA-96 Optima2)

Boron Areal Density of Rack (corresponds (corresponds Inserts to minimum certified value) to minimum certified value)

Water Gaps between SFP Ignored Ignored Rack Modules Rack Insert Thickness Minimum Minimum SFP Storage Rack Tolerances - Cell inner width - Cell inner width

- Cell pitch - Cell pitch

- Cell wall thickness - Cell wall thickness

- Rack insert width - Rack insert width Fuel Assembly Positioning in Eccentric Positioning - 2x2 and Eccentric Positioning - 2x2 and Rack Cell 8x8 cell based infinite array 8x8 cell based infinite array Abnormal Conditions - SFP temperature exceeding - SFP temperature exceeding the normal range the normal range

- Dropped fuel assembly - Dropped fuel assembly

- Storage cell distortion - Storage cell distortion

- Missing insert - Missing insert

- Misleading of a fuel assembly - Misleading of a fuel assembly into a SFP cell with no* insert into a SFP cell with no insert

- Mislocated fuel assembly (fuel - Mislocated fuel assembly (fuel assembly positioned outside assembly positioned outside the storage rack) the storage rack)

- Mis-installment of an insert - Mis-installment of an insert (incorrect orientation) (incorrect orientation)

- Mechanical wear of the insert - Mechanical wear of the insert

- Rack movement - Rack movement Storage Rack Interfaces Evaluated using 74x7 4 model Dispositioned**

The lattice used is not qualified for storage in the spent fuel pool because it exceeds the Technical Specifications k-infinity limit. This lattice was used to determine the total uncertainties and biases for the A 1OXM fuel design and demonstrate that an A 1OXM lattice with a maximum k-infinity less than or equal to the Technical Specifications limit will maintain the spent fuel pool kett < 0.95.

- Dispositioned means that a specific code run was not made to determine the impact of the storage rack interfaces for the ATRIUM 1OXM fuel. The results of the code run in the NRG-approved CSA were reviewed and the differences between the Optima fuel and ATRIUM 10XM fuel were considered to determine that the NRG-approved analysis is bounding for the ATRIUM 1OXM fuel.

NON-PROPRIETARY VERSION Eccentric Positioning and Fuel Assembly Channel Reactivity Effect Bias Uncertainty 5% Depletion Uncertainty Statistical combination of the positive fuel tolerances Statistical combination of the positive rack tolerances Fuel Orientation in SFP Rack Cell Bias Uncertainty MCNP Benchmark Bias Uncertainty MCNP Calculation Uncertainty (2 sigma)

Statistical Combination of Uncertainties Eccentric Positioning and Fuel Assembly Channel Reactivity Effect Bias Fuel Orientation in SFP Rack Cell Bias MCNP Benchmark Bias Sum of Biases ATRIUM 1OXM Total Uncertainties and Biases SVEA-96 Optima2 Total Uncertainties and Biases

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office Proprietary Information - Withhold From Public Disclosure Under 10 CFR 2.390 RS-15-326 10 CFR 50.90 December 14, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Request for License Amendment Regarding Spent Fuel Storage Pool Criticality Methodology for Fuel Channel Bow/Bulge 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 Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, respectively. The proposed change would allow use of a new Criticality Safety Analysis (CSA) fuel channel bow/bulge methodology for performing the criticality safety evaluation for the new ATRIUM 10XM fuel design in the spent fuel pool. A description and evaluation of the proposed change is attached.

This license amendment request was discussed with the NRC in a pre-application meeting on May 11, 2015. During the meeting, the NRC questioned the treatment of tolerances and uncertainties in the analysis. To address the concerns, the NRC requested EGC to include more detail concerning the treatment of tolerances and uncertainties. Accordingly, the requested information is attached.

This request is subdivided as follows.

Attachment 1 provides a description and evaluation of the proposed change.

Attachment 2 provides AREVA, Inc. Report FS1-0024092, Revision 1.0, "Information to Support EXELON RAI Responses for Spent Fuel Pool Criticality Analyses - Proprietary Version."

Attachment 3 provides a comparison of the approach used in the NRC-approved SVEA-96 Optima2 CSA to the approach used in the proposed ATRIUM 10XM CSA, as well as a comparison of the SVEA-96 Optima2 and ATRIUM 10XM biases and uncertainties. This information was requested by the NRC in a pre-application meeting that was held on May 11, 2015.