RS-16-139, Supplement to Request for License Amendment Regarding Transition to Areva Fuel

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Supplement to Request for License Amendment Regarding Transition to Areva Fuel
ML16174A374
Person / Time
Site: Dresden, Quad Cities  Constellation icon.png
Issue date: 06/22/2016
From: Simpson P
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16174A373 List:
References
RS-16-139
Download: ML16174A374 (21)


Text

Exelon Generation 4300 Winfield Road Warrenville, IL 6055, www.exeloncorp com PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390(a)(4)

RS-16-139 10 CFR 50.90 June 22, 2016 U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Supplement to Request for License Amendment Regarding Transition to AREVA Fuel

References:

( 1) Letter from P. R. Simpson (Exelon Generation Company, LLC (EGC)) to U.S. NRC, "Request for License Amendment Regarding Transition to AREVA Fuel," dated February 6, 2015 (2) Letter from P. R. Simpson (EGC) to U.S. NRC, "Response to Request for Additional Information Regarding Request for License Amendment Regarding Transition to AREVA Fuel," dated January 28, 2016 In Reference 1, EGC requested amendments to Renewed Facility Operating License Nos.

DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. The proposed changes support the transition from Westinghouse SVEA-96 Optima2 (Optima2) fuel to AREVA, Inc. (AREVA) ATRIUM 10XM fuel at DNPS and QCNPS. Specifically, EGC proposed to revise Technical Specification (TS) 5.6.5, "Core Operating Limits Report (COLR)," Paragraph b, to delete methodologies that are no longer required and to add the AREVA analysis methodologies to the list of approved methods to be used in determining the core operating limits in the COLR. Also, in support of the planned transition to AREVA ATRIUM 10XM fuel, EGC proposed to revise DNPS and QCNPS TS 3.2.3, "Linear Heat Generation Rate (LHGR)," and TS 3.7.7, "Main Turbine Bypass System."

ATTACHMENTS 2 AND 5 CONTAIN PROPRIETARY INFORMATION-WITHHOLD UNDER 10 CFR 2.390(a)(4) -WHEN SEPARATED FROM ATTACHMENTS 2 AND 5, THIS DOCUMENT IS DECONTROLLED

June 22, 2016 U.S. Nuclear Regulatory Commission Page2 Subsequent to submittal of the referenced letters, AREVA identified an inconsistency in the discussion of the available emergency core cooling systems (ECCS) injection flow during ECCS line breaks. The inconsistency is associated with the first footnote in the tables presenting the available ECCS for recirculation line breaks. This error doesn't affect the analyses that were performed. This issue has been documented in the AREVA Corrective Action Program (CAP) and evaluated in accordance with the AREVA Quality Assurance (QA) Program. A detailed discussion of this error is contained in Attachment 2.

Additionally, AREVA recently identified issues associated with the calculation of the Minimum Critical Power Ratio Safety Limit (SLMCPR). These issues are associated with the application of the SAFLIM3D code that was used to establish the SLMCPRs reported in Reference 1 and in support of the response to an NRC request for additional information (RAI) contained in Reference 2. These issues have also been documented in the AREVA CAP and evaluated in accordance with the AREVA QA Program. An evaluation was performed to determine the impact of these errors on the analyses submitted in support of the referenced license amendment request. The details of these issues and a quantification of their impact are contained in Attachment 5.

Attachments 2 and 5 contain information that is proprietary to AREVA and are requested to be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4). Affidavits attesting to the proprietary nature of the information contained in Attachments 2 and 5 are contained in Attachments 1 and 4, respectively. Non-proprietary versions of Attachments 2 and 5 are provided as Attachments 3 and 6, respectively.

The analyses in the referenced letters were developed for a representative core, and only utilized to support the license amendment request. The identified issues will be corrected through the CAP process and will not affect calculations used for actual core operation.

In accordance with 10 CFR 50.91 (b), EGC is notifying the State of Illinois of these issues by transmitting a copy of this letter and its attachments to the designated State Official.

EGC has also reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Reference 1, Attachment 1. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendments do not involve a significant hazards consideration. In addition , the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendments.

June 22, 2016 U.S. Nuclear Regulatory Commission Page3 There are no regulatory commitments contained in this letter. Should you have any questions related to this letter, please contact Mr. Mitchel A Mathews at (630) 657-2819.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22nd day of June 2016.

r Patrick R. Simpson Manager - Licensing Attachments:

1. AREVA, Inc. Affidavit Attesting to the Proprietary Nature of Information Contained in AREVA File No. FS1-0027493, "Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Proprietary Version)," dated June 16, 2016
2. AREVA, Inc. File No. FS1-0027493, "Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Proprietary Version)," dated June 16, 2016
3. AREVA, Inc. File No. FS1-0027494, "Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Non-Proprietary Version)," dated June 16, 2016
4. AREVA, Inc. Affidavit Attesting to the Proprietary Nature of Information Contained in AREVA, Inc. File No. FS1-0027556, "Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR Analysis (Proprietary Version)," dated June 18, 2016
5. AREVA, Inc. File No. FS1-0027556, "Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR Analysis (Proprietary Version)," dated June 18, 2016
6. AREVA, Inc. File No. FS1-0027557, "Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR Analysis (Non-Proprietary Version),"

dated June 18, 2016 cc: Regional Administrator- NRC Region Ill NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Illinois Emergency Management Agency- Division of Nuclear Safety

ATTACHMENT 1 AREVA, Inc. Affidavit Attesting to the Proprietary Nature of Information Contained in AREVA File No. FS1-0027493, "Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Proprietary Version)," dated June 16, 2016

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 Document FS1-0027493, Revision 1, "Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Proprietary Version)," dated June 2016 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 withhelq from public disclosure. The request for withholding of proprietary information 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.
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 day of J "'Y":--&- ==

, 2016.

SUSAN KMCCOY NOTARY PUBLIC* WASHINGTON MY COMMISSION EXPIRES 01-14-2020 Susan K. McCoy _

NOTARY PUBLIC, STATE OFWASHI TON MY COMMISSION EXPIRES: 1/14/2020

ATTACHMENT 3 AREVA, Inc. File No. FS1-0027494, "Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Non-Proprietary Version)," dated June 16, 2016

IDENTIFICATION REVISION I

FS1-0027494 11 1.0 I AREVA Front End BG Fuel BL A

AREVA TOTAL NUMBER OF PAGES: 3 Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Non-Proprietary Version)

ADDITIONAL INFORMATION:

This is the Non-Proprietary Version of FS1-0027493 Rev 1.0.

PROJECT DISTRIBUTION TO PURPOSE OF DISTRIBUTION Darrell Carr Ryan Stout HANDLING Restricted AREVA Jerry Ingham MieAzuma EIR - Engineering Robert Schnapp Tom Galioto CATEGORY Information Report Alan Meginnis Tony Will Dirk Howlett Katherine Kerr STATUS Adrian Constantinescu Susan McCoy This document 1s electronically approved . Records regarding the signatures are stored in the Fuel BU Document Dalabase. Any attempt to modify this file may subject employees to civil and criminal penalties. EDM Object Id: 0901216780958de0 - Release date (YYYY/MM/DD): 2016/06/16 21 :48:36 [Western European Time]

Bo!~ Name Dale lYYYY/MMlQDl O!:ll!!!!i~lio!J Writer CARR Darrell 2016/06/16 18:53:31 AREVA Inc.

Reviewer INGHAM Jerry 2016/06/16 21 :03:32 AREVA Inc.

Approver MEGINNIS Alan 2016/06/16 21 :48:30 AREVA Inc Approver SCHNEPP Robert 2016/06/16 21 :21:07 AREVA Inc ga~kl!l!!l!! !i!!R!!!! AL: OE001 ECCN: OE001 RELEASE DATA: Les merchandises portant ta ditsignation "AL in6gal N" sont soumlses a la r6glementalion europitenne au allemande en mat'6re de contr61e des exportations au sein ou hors de l'UE. Les merchandises portant la designation "ECCN ln6gal N" sont soumlses A la r6glementatlon arMricaina Les man:llandlses portent Jes d6slgnatlons *Al N" OU "ECCN:N" peuvenl, salon la desllnallon ou rutillsatlon finales du produ~. 6galemenl 4lre soumises a autortsatk>n

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N* FS 1-0027494 Rev. 1.0 Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Non-Proprietary A Handling: Restricted AREVA Page 2/3 Version) AREVA REVISIONS REVISION DATE EXPLANATORY NOTES 1.0 See 151 page New document.

release date This is the Non-Proprietary Version of FS1-0027493 Rev 1.0.

AREVA - Fuel BL This document is sub eel to the restrictions set forth on the first or title a e

No FS 1-0027494 Rev. 1.0 Clarification of ECCS Availability in Quad Cities ATRIUM 10XM LOCA Analysis (Non-Proprietary A Handling: Restricted AREVA Page 3/3 Version) AREVA References 1 and 2 were included as part of the license amendment request supporting the transition to ATRIUM 10XM fuel at Quad Cities Nuclear Power Station, Units 1 and 2 and Dresden Nuclear Power Station, Units 2 and 3. Recently, an inconsistency was identified in the discussion of the available emergency core cooling systems (ECCS) during ECCS line breaks. The inconsistency is associated with the first footnote in the tables presenting the available ECCS for recirculation line breaks (i.e.,

Reference 1, Table 5.1 and Reference 2, Table 4.9).

The footnotes currently state:

"Systems remaining, as identified in this table for recirculation line breaks, are applicable to all non-ECCS line breaks. For ECCS line breaks, the systems remaining are those listed for recirculation breaks, less the ECCS in which the break is assumed."

A more appropriate footnote would be:

"Systems remaining, as identified in this table for recirculation line breaks, are applicable to all non-ECCS line breaks. For ECCS line breaks, in most cases the systems remaining are those listed less the ECCS system in which the break is assumed. The exception is the evaluation of small LPCI line breaks. For the evaluation of small LPCI line breaks when the loop selection logic is not able to determine the intact loop, flow through the LPCI injection valve in the broken LPCI line is credited."

As discussed in Section 4.6 of Reference 1, for recirculation line breaks with a break area of less than(<)

0.15 square feet (ft2 ), all available LPCI flow is assumed to be injected into the broken loop. This statement is reiterated in the second footnote of Reference 1, Table 5.1 . The discussion in Reference 1, Section 5.3.5 indicates [

] The current footnotes indicate that no LPCI flow is credited in the broken LPCI line, thereby creating the inconsistency.

The inconsistency in the footnotes discussed above does not change any results or conclusions in the analyses that support, or are presented in, References 1 and 2.

References

1. ANP-3328P Revision 1, "Quad Cities Units 1 and 2 LOCA Break Spectrum Analysis for ATRIUM 10XM Fuel," AREVA, August 2015.
2. ANP-3356P Revision 0, "Quad Cities Units 1 and 2 LOCA-ECCS Analysis MAPLHGR Limits for ATRIUM 10XM Fuel," AREVA, December 2014.

AREVA - Fuel BL This document Is sub ect to the restr1ctions set forth on the first or title a e

ATTACHMENT 4 AREVA, Inc. Affidavit Attesting to the Proprietary Nature of Information Contained in AREVA, Inc. File No. FS1-0027556, "Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR Analysis (Proprietary Version)," dated June 18, 2016

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 Document FS 1-0027556, Revision 1, "Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR Analysis (Proprietary Version)," dated June 2016 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. ,i1.
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 information 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.
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 I ] fl-- - *** - - *- * - * -- 1 day of J ~ ,2016. SUSAN KMCCOY NOTARY PUBLIC* WASHINGTON MY COMMISSION EXPIRES S' -' ~ *-,

Susan K. McCoy NOTARY PUBLIC, STATE OF WASHIN 0 MY COMMISSION EXPIRES: 1/14/2020

ATTACHMENT 6 AREVA, Inc. File No. FS1-0027557, "Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR Analysis (Non-Proprietary Version),"

dated June 18, 2016

IDENTIFICATION REVISION I

FS1-0027557 11 1.0 I

AREVA Front End BG Fuel BL A

AREVA TOTAL NUMBER OF PAGES: 5 Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR Analysis (Non-Proprietary Version)

ADDITIONAL INFORMATION:

This is the Non-Proprietary Version of FS1 -0027556 Rev 1.0.

PROJECT QC2-24 DISTRIBUTION TO PURPOSE OF DISTRIBUTION Darrell Carr Ryan Stout HANDLING Restricted AREVA Jerry Ingham MieAzuma EIR - Engineering Robert Schnapp Tom Galioto CATEGORY Alan Meginnis Tony Will Information Report Dirk Howlett Earl Riley STATUS Adrian Constantinescu Susan McCoy 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: 090121678095af23 - Release date (YYYY/MM/DD): 2016/06/18 02:43:01 [Western European Time]

B2l11 Nam11 Dale IYYYYIMMlDQ} O[!li!!Jizatio!J Writer CARR Darrell 201 6/06/18 02:34 :46 AREVA Inc.

Reviewer CONSTANTINESCU Adrian 2016/06/18 02:38:07 AREVA Inc.

Approver QUICK Kevin 2016/06/18 02:42:53 AR VAlnc.

Approver MEGINNIS Alan 2016/06/18 02:42 :02 AREVA Inc.

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N" FS1-0027557 Rev. 1.0 Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR A Handling: Restricted AREVA Page 2/5 Analysis (Non-Proprietary Version) AREVA REVISIONS REVISION DATE EXPLANATORY NOTES 1.0 See 151 page New document.

release date This is the Non-Proprietary Version of FS1-0027556 Rev 1.0.

AREVA - Fuel BL This document is sub eel to the restrictions set forth on the first or title a e

N" FS1-0027557 Rev. 1.0 Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR A Handling: Restricted AREVA Page 3/5 Analysis (Non-Proprietary Version) AREVA References 1 and 2 were included as part of the license amendment request supporting the transition to ATRIUM 1OXM fuel at Quad Cities Nuclear Power Station, Units 1 and 2 and Dresden Nuclear Power Station, Units 2 and 3. The SAFLIM3D code (Reference 3) was used to establish the safety limit MCPR (SLMCPR} reported in Reference 1 and support a response to a request for additional information (RAI} in Reference 2. The SLMCPR evaluations were performed for a representative Quad Cities transition core design composed of ATRIUM 10XM and OPTIMA2 fuel. As noted in Reference 4, Seeton 5, [

1 A calculation process concern was also identified. The SAFLIM3D code [

1 These issues only affect the SLMCPR analyses for cores with OPTIMA2 fuel . Therefore, the only potentially affected portions of the Dresden and Quad Cities fuel transition license amendment request are the proprietary and non-proprietary versions of References 1 and 2.

Assessments of the impact of these issues on the results and conclusions presented in References 1 and 2 were performed with a corrected version of SAFLIM3D and a process that [

] The results of the assessments are presented below.

Table 1 presents a comparison of the SLMCPR results from Reference 1, Table 4.2 and the results obtained with the corrected version of SAFLIM3D and the updated calculation process. Both analyses support a two-loop operation (TLO} SLMCPR of 1.1 O and a single-loop operation (SLO} SLMCPR of 1.11.

The TLO results show an increase in the percentage of rods expected to experience boiling transition and the SLO results show a relatively small decrease. All results and conclusions presented in Reference 1 except those presented in Table 4.2 remain applicable. It is noted that all the limits presented in Reference 1 are based on the TLO and SLO SLMCPR values of 1.12 and 1.14 respectively; the current values in the Quad Cities Technical Specifications.

The response to RAl-20 presented in Reference 2 includes results from sensitivity analyses performed with SAFLIM3D. (

] Calculations with the corrected AREVA- Fuel BL This document Is sub eel to the restrictions set forth on the flrst or UUe

N" FS1-0027557 Rev. 1.0 Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR A Handling: Restricted AREVA Page 4/5 Analysis (Non-Proprietary Version) AREVA code and updated process confirm the Reference 2 conclusion that there is no difference in the results that would be reported.

The response to RAl-20 part b presents results of sensistivity analyses to assess the impact of the uncertainties due to the OPTIMA2 water cross design. Results of updated calculations show the number of rods predicted to be in boiling transition [

] All other results and conclusions presented in Reference 2 remain applicable.

References

1. ANP-3361 P Revision 0, "Quad Cities Unit 2 Cycle 24 Representative Cycle Design Reload Safety Analysis," AREVA, Decemer 2014.
2. ANP-3463P Revision 0, "Response to RAl's for Dresden Nuclear Power Station Units 2 and 3, Quad Cities Nuclear Power Station Units 1 and 2 Transition to AREVA Fuel," AREVA, January 2016.
3. ANP-10307PA Revison 0, "AREVA MCPR Safety Limit Methodology for Boiling Water Reactors,"

AREVA NP, June 2011.

4. ANP-3338P Revision 1, "Applicability of AREVA BWR Methods to the Dresden and Quad Cities Reactors Operating at Extended Power Uprate," AREVA, August 2015.

AREVA - Fuel BL This document Is sub eel lo the restrictlons set forth on the first or UUe e

N" FS1-0027557 Rev. 1.0 Impact of Corrections to Quad Cities Unit 2 Cycle 24 Representative Cycle Design SLMCPR A Handling: Restricted AREVA Page 5/5 Analysis (Non-Proprietary Version) AREVA Table 1 Comparison of Safety Limit Results Reference 1 Results Corrected Results Percentage of Rods in Percentage of Rods in SLMCPR Boiling Transition Boiling Transition TL0-1 .10 0.0513 0.0864 SL0-1.11 0.0293 0.0264 AREVA- Fuel BL This document Is sub ect to the restrictions set forth on the first or title e