View source for BSEP 11-0040, Unit I & 2, Additional Information Supporting License Amendment Request to Add Analytical Methodology ANP-10298PA to Technical Specification 5.6.5,Core Operating Limits Report (COLR) (NRC TAC ME3856 & Me...

{{Adams
| number = ML111020436
| issue date = 04/06/2011
| title = Unit I & 2, Additional Information Supporting License Amendment Request to Add Analytical Methodology ANP-10298PA to Technical Specification 5.6.5,Core Operating Limits Report (COLR) (NRC TAC ME3856 & Me...
| author name = Annacone M
| author affiliation = Progress Energy Carolinas, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| contact person = 
| case reference number = BSEP 11-0040, TAC ME3856, TAC ME3857, TSC-2010-01
| document type = Letter type:BSEP
| page count = 26
| project = TAC:ME3856, TAC:ME3857
| stage = Request
}}

=Text=
{{#Wiki_filter:~j~ Progress Energy                                                               Michael J. Annacone Vice President Brunswick Nuclear Plant April 6, 2011 SERIAL: BSEP 11-0040 TSC-2010-01 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
Brunswick Steam Electric Plant, Unit Nos. I and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Additional Information Supporting License Amendment Request to Add Analytical Methodology ANP-10298PA to Technical Specification 5.6.5, "Core Operating Limits Report (COLR) (NRC TAC Nos. ME3856 and ME3857)

==Reference:==
Letter from Michael J. Annacone to the U.S. Nuclear Regulatory Commission (Serial: BSEP 10-0052), "Request for License Amendments -
Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, "Core Operating Limits Report (COLR)," dated April 29, 2010 (ADAMS Accession Number ML101310388)
Ladies and Gentlemen:
By letter dated April 29, 2010, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., requested license amendments to revise the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2. The proposed license amendments revise Technical Specification 5.6.5.b by adding AREVA Topical Report ANP- 10298PA, A CE/A TRIUM 1OXM CriticalPower Correlation, Revision 0, March 2010, to the list of analytical methods that have been reviewed and approved by the NRC for determining core operating limits.
On March 31, 2011, CP&L informed the NRC of a newly identified issue involving the ACE/ATRIUM 1OXM Critical Power Ratio (CPR) correlation. CP&L indicated that an operability assessment was being prepared by AREVA and that the results of that assessment would be provided to the NRC when completed. The initial revision of the operability assessment was completed the evening of Friday, April 1, 2011. Based on subsequent discussions with CP&L, AREVA incorporated additional information into the operability assessment and Revision 1 was issued on Sunday, April 3, 2011.
On April 4, 2011, a telephone conference call was held between CP&L, AREVA, and NRC to discuss the results of the operability assessment, which are contained in an AREVA document titled "Operability Assessment (Rev. 1) (CR # 2011-2274)." The assessment Progress Energy Carolinas, Inc.
P.C.Bus 10429 Southport, N 28461 T> 910.457.3698 4 c
                                                                                                           *_&#xa3;*

Document Control Desk BSEP 11-0040 / Page 2 determined that: (1) only ATRIUM 1OXM CPR related limits and analyses are potentially impacted by the concern; (2) no other fuel types operated in BSEP cores are impacted; (3) the SLMCPR and corresponding CPR-related limits reported in ANP-2956(P),
Revision 0, Brunswick Unit 2 Cycle 20 Reload Safety Analysis, are acceptable; and (4) no changes are required to operating limits or instrument setpoints supporting Unit 2 Cycle 20 operation. A copy of AREVA Operability Assessment CR 2011-2274, Revision 1, is provided in Enclosure 1. This operability assessment states that the concern with the ACE correlation evolved from a previously identified concern described in AREVA document CR2010-7210. A copy of AREVA CR 2010-7210 is provided in Enclosure 2 to facilitate NRC review of the BSEP, Unit 2 operability assessment.
AREVA Operability Assessment CR 2011-2274, Revision 1 (i.e., Enclosure 1) and AREVA CR 2010-7210 (i.e., Enclosure 2) contain information considered to be proprietary to AREVA, as defined by 10 CFR 2.390. As the owner of the proprietary information, AREVA has executed the affidavit provided in Enclosure 3, which identifies that the enclosed documents have been handled and classified as proprietary, are customarily held in confidence, and have been withheld from public disclosure. AREVA requests that documents provided in Enclosures 1 and 2 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390.
Based on the April 4, 2011, discussions, the NRC requested additional information to address parts of the operability assessment. A proprietary response to the request for additional information (RAI), contained in AREVA Document No. 12-9158912-000 titled "Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Proprietary," is provided in Enclosure 4. A non-proprietary version of the response to the RAI is contained in AREVA Document No. 12-9158913-000 titled "Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary," a copy of which is provided in .
AREVA Document No. 12-9158912-000 contains information considered to be proprietary to AREVA, as defined by 10 CFR 2.3 90. As the owner of the proprietary information, AREVA has executed the affidavit provided in Enclosure 6, which identifies that the information provided in AREVA Document No. 12-9158912-000 has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. AREVA requests that the identified information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.3 90.
Until the identified issue involving the ACE/ATRIUM 1OXM CPR correlation is resolved, Safety Limit Minimum Critical Power Ratio (SLMCPR), setpoint and core operating limit values determined using the NRC-approved ANP- 10298PA methodology, shall be evaluated with methods described in AREVA Operability Assessment CR 2011-2274, Revision 1, to confirm the values determined using the NRC-approved method remain applicable and the core operating limits include margin sufficient to bound the effects of

Document Control Desk BSEP 11-0040 / Page 3 the issue described in AREVA Operability Assessment CR 2011-2274, Revision 1, on core monitoring.
CP&L is providing an operating license condition to be included in Appendix B, "Additional Conditions," of the Operating Licenses for BSEP, Units I and 2. The license condition describes the performance of a supplemental evaluation applicable to setpoints and limits determined using the NRC-approved ANP- 10298PA methodology, to ensure the limits generated with the NRC-approved methods appropriately bound the effects of the issue for each Brunswick unit. Enclosure 7 to this letter provides the license condition for each unit.
No regulatory commitments are contained in this letter. Please refer any questions regarding this submittal to Mr. Lee Grzeck, Acting Supervisor - Licensing/Regulatory Programs, at (910) 457-2487.
I declare, under penalty of perjury, that the foregoing is true and correct. Executed on April 6, 2011.
Sincerely, M hael J. Afnnacone WRM/wrm

==Enclosures:==
: 1. AREVA Operability Assessment CR 2011-2274, Revision 1 (Proprietary Information - Withhold from Public Disclosure in Accordance With 10 CFR 2.390)
: 2. AREVA CR 2010-7210 (Proprietary Information - Withhold from Public Disclosure in Accordance With 10 CFR 2.390)
: 3. AREVA Affidavit Regarding Withholding CR 2011-2274 and CR 2010-710 from Public Disclosure
: 4. Response to Request for Additional Information, AREVA Document No. 12-9158912-000 titled "Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Proprietary" (Proprietary Information - Withhold from Public Disclosure in Accordance With 10 CFR 2.390)
: 5. Response to Request for Additional Information, AREVA Document No. 12-9158913-000 titled "Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary"

Document Control Desk BSEP 11-0040 / Page 4
: 6. AREVA Affidavit Regarding Withholding AREVA Document No. 12-9158912-000, "Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Proprietary" from Public Disclosure
: 7. License Condition cc (with Enclosures):
U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Philip B. O'Bryan, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)
ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 cc (with Enclosures 3, 5, 6, and 7 Only):
Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, III, Section Chief Radiation Protection Section North Carolina Department of Environment and Natural Resources 1645 Mail Service Center Raleigh, NC 27699-1645

BSEP 11-0040 Enclosure 3 AREVA Affidavit Regarding Withholding CR 2011-2274 and CR 2010-7210 from Public Disclosure

AFFIDAVIT COMMONWEALTH OF VIRGINIA                 )
                                         ) ss.
CITY OF LYNCHBURG                        )
: 1.       My name is Pedro Salas. I am Manager, Corporate Regulatory Affairs, for AREVA NP Inc. (AREVA NP) and as such I am authorized to execute this Affidavit.
: 2.      I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
: 3.      I am familiar with the AREVA NP information contained in Condition Report 2010-7210 with Issue Title/Brief Description, "The K-Factor Calculated as Part of the ACE Correlation can be Non-Physical," originated October 2010 and Condition Report 2011-2274 with Issue Title/Brief Description, "ACE K-Factor Length Assumption for ATRIUM1 OXM,"
originated March 2011 and referred to herein as "Documents." Information contained in these Documents has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.
: 4. These Documents contain information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in these Documents as proprietary and confidential.
: 5. These Documents have been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in these Documents

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 NP to determine whether information should be classified as proprietary:
(a)     The information reveals details of AREVA NP'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 NP.
(d)    The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.
(e)    The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.
The information in these Documents is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(c) above.
: 7.      In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in these Documents has been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
: 8.       AREVA NP 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.
this    Z1'Th SUBSCRIBED before me day of                                         ,2011.
Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/14 Reg. # 7079129 SHERRY L. MCFADEN Notary Public Commonwealth ot Virginia 7079129 My Commission Expires Oct 31, 2014

BSEP 11-0040 Enclosure 5 Response to Request for Additional Information, AREVA Document No. 12-9158913-000 titled "Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary"

A 20004-018 (10/18/2010)
AREVA AREVA NP Inc.
Technical Data Record (TDR)
Document No.:   12   - 9158913 -  000 Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary Page 1 of 10

A AREVA 20004-018 (10/18/2010)
Document No.: 12-9158913-000 Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary Safety Related?        [-- YES        E NO Does this document contain assumptions requiring verification?                 L--  YES      '7 NO Does this document contain Customer Required Format?                   [:YES              NO Signature Block P/LP, R/LR,                           Pages/Sections Name and                                            A/A-CRF,                           PreparedlReviewed/
Title/Discipline                    Signature           A/A-CRI         Date             Approved or Comments K. R. Greene                                                      P                       Responses to Q1, Q2, and Q3 Sr Proj. Eng. / TH                /,.2i,,     .*   ..--
M. T. Bunker                                                                              Responses to Q1, Q2, and Q3 Supervisor I N       n
* LR              -/       Responses to Q, Q5, and Q6 E. E. Riley                                                                               Responses to Q4, Q5, and Q6 Supervisor / Neutronics                                          LP                 O S. W. Evans                                                       R            ,      ~Responses to Q4, Q5, and Q6 Engineer / Neutronics           A                                          .'
D. W. Pruitt, Manager         -                                   A                       All Thermal-Hydraulics              t        ..(       ..
Richland D. E. Garber, Manager                                             A                       All Neutronics Richland                                                           __ ___ 1...                        __t A. B. Meginnis, Manager                                           A                       All, Project Licensing                               ,        _/
Note: P/LP designates Preparer (P), Lead Preparer (LP)
R/LR designates Reviewer (R), Lead Reviewer (LR)
A/A-CRF designates Approver (A), Approver of Customer Requested Format (A-CRF)
A/A-CRI designates Approver (A), Approver - Confirming Reviewer Independence (A-CRI)
Page 2

A                                                                               20004-018 (10/18/2010)
Document No.: 12-9158913-000 AREVA Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary Record of Revision Revision        Pages/Sections/
No.         Paragraphs Changed                   Brief Description / Change Authorization 000       All                       New document
          .9                         4
          .9                         4 9                         4
          .9                         4 4                          4 4                          4 Page 3

A                                                                                                         Document No.: 12-9158913-000 AR EVA Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary Table of Contents Page 1.0   INTRO DUCTIO N ...........................................................................................................................       5 2.0   RESPO NSES ................................................................................................................................      6 Page 4

A                                                                       Document No.: 12-9158913-000 AR EVA Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary REQUEST FOR ADDITIONAL INFORMATION BRUNSWICK STEAL ELECTRIC PLANT UNITS 1 AND 2 PROGRESS ENERGY CAROLINAS, INC FACILITY OPERATING LICENSE NOS DPR-62 AND DPR-71 TAC NUMBERS ME3856 AND ME3857

==1.0 INTRODUCTION==

This document provides responses to an NRC RAI on an operability assessment for Brunswick Unit 2 Cycle 20. As such, the information presented has been prepared consistent with the requirements for operability assessments as described in the NRC Inspection Manual Part 9900 Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety," April 16, 2008.
Page 5

A                                                                           Document No.: 12-9158913-000 AREVA Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary 2.0 RESPONSES As a follow-up of conference call on April 4, 2011 between BSEP, AREVA and the NRC staff on Operability assessment, Revision 1 for CR 2011-2274, listed below are questions on operability assessment. This operability assessment performed by AREVA NP is based on concern that was identified in CR 2010-7210 in regard to [
                                                                                                 ] Listed below are NRC staff requests for additional information on the operability assessment.
Q1. Page 1 of CR 2011-2274 states that [
                                                                ] Explain what characteristics of the BSEP ATRIUM 1OXM fuel qualifies as "newer" ATRIUM 1OXM design?
Response: The term "newer" describes the ATRIUM 1OXM design relative to the ATRIUM 10 design. The dominating feature is the placement of the grid spacers closer together in the upper part of the assembly than in the lower part of the assembly. The grid spacers enhance the deposition of the entrained liquid onto the fuel rod surface in the area above the grid spacer which significantly enhances the bundle critical power performance in this area. This design characteristic enhances the critical power performance in the upper part of the bundle such that under some downskew power conditions, the dryout elevation is significantly lower than in bundle designs with equal distant spacers.
Q2. Page 2, Point 2 states that [
                                          ] What is the functional dependency of the number of axial planes on the accuracy of the assembly critical power?
Response: [
I Page 6

A                                                                        Document No.: 12-9158913-000 AREVA Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary Q3. Page 2, Point 4. Explain how close were the results from the ACE ATRIUM 1OXM correlation using [
                                                                                                 ]
Response: [
I Q4. Page 4, Monitoring During Cycle 20 Operation. AREVA NP states that [
I Response: [
I Page 7

A                                                                     Document No.: 12-9158913-000 AREVA Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary
[
Indiate Revsio Asessent Oerailit fte hissecion mpacs.
CWE aae7 Q5.
Q5. Pagae 7 CRWE Impacts. This section of the Operability Assessment, Revision 1 indicates that "[
Response: [
I Page 8

A                                                   Document No.: 12-9158913-000 AREVA Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary I
Page 9

A                                                                         Document No.: 12-9158913-000 AREVA Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Non Proprietary Q6. Page 7 Impact on Instrument Setpoints. Explain the impact, if any, of the modified ACE correlation on the core hydrodynamic stability analysis performed for Brunswick Unit 2 as reported in ANP-2956(P), Revision 0.
Response: [
I Page 10

REVISION 

==SUMMARY==

Revision 38 of OAI-68 consists of the following changes:
* Revised Attachment 2 page 1 Of 27 to read: Telecommunications Building and Area
* Revise section 3.0 Upon declaration of a hurricane watch, ensure that IT&T Telecommunications has assigned a representative to be at the site to assist in preparations for severe weather with a working Progress Energy System UHF radio.
    " Upon declaration of a hurricane watch, verify that the appropriate backups of local servers have been performed
    " Upon declaration of a hurricane warning, if required issue guidance to site regarding moving and wrapping computers (or unplugging at work station), data backup, and any plans for network shut down
* Secure loose items at the Met Tower Building/area, and the Telecommunications Building/Area as necessary
* Removed Warehouse A from Attachment 2 page 17 of 27
* Revise section 3.0 of Attachment 2 page 25 of 27: System Engineers perform walk downs to identify potential storm - related concerns including missile hazards and flood concerns, or ongoing maintenance activities/temporary conditions that could adversely affect an SSC'S ability to maintain its design functions during a Severe Weather Event. Use Attachment 6, Recommended Minimum System Walk downs for Severe Weather.#413760).
[OAI-68                                    Rev. 37                          Page 54 of 55]

BSEP 11-0040 Enclosure 6 AREVA Affidavit Regarding Withholding AREVA Document No. 12-9158912-000, "Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses - Proprietary" from Public Disclosure

AFFIDAVIT STATE OF WASHINGTON            )
                               ) ss.
COUNTY OF BENTON               )
: 1.      My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
: 2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
: 3. I am familiar with the AREVA NP information contained in the document 12-9158912-000, entitled, "Brunswick Unit 2 Cycle 20 Operability Assessment RAI Responses,"
dated April 5, 2011 and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP 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 NP 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 NP to determine whether information should be classified as proprietary:
(a)    The information reveals details of AREVA NP'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 NP.
(d)    The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.
(e)    The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.
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 NP'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 NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
: 8. AREVA NP 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         "          2011.
                                                                     " NOT, 10~
Susan K. McCoy                                                       , O      1 NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/10/12

BSEP 11-0040 Enclosure 7 License Condition Carolina Power & Light (CP&L) is providing a license condition to be included in Appendix B, "Additional Conditions," of the Operating Licenses (OLs) for Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The license condition is in support of issuance of the license amendments revising Technical Specification 5.6.5.b to add AREVA Topical Report ANP-10298PA, ACE/ATRIUM JOXM CriticalPower Correlation,Revision 0, March 2010, to the list of analytical methods that have been reviewed and approved by the NRC for determining core operating limits. The license condition describes the performance of a supplemental evaluation applicable to setpoints and limits determined using the ANP-10298PA method to ensure the limits generated with the NRC-approved method appropriately account for the effects of the issue described in AREVA Operability Assessment CR 2011-2274, Revision 1.
Appendix B Additional Conditions Amendment                                                               Implementation Number              Additional Conditions                               Date XXX (Unit 1)        Safety Limit Minimum Critical Power Ratio           Upon implementation of (SLMCPR), setpoint, and core operating limit        Amendment No.
values determined using the ANP- 10298PA, ACE/ATRIUM 1OXM Critical Power Correlation (i.e., TS 5.6.5.b.21), shall be evaluated with methods described in AREVA Operability Assessment CR 2011-2274, Revision 1 to verify the values determined using the NRC-approved method remain applicable and the core operating limits include margin sufficient to bound the effects of the K-factor calculation issue described in AREVA Operability Assessment CR 2011-2274, Revision 1. The results of the evaluation shall be documented and submitted to the NRC, for review, at least 60 days prior to startup of each operating cycle.
XXX (Unit 2)         Safety Limit Minimum Critical Power Ratio          Upon implementation of (SLMCPR), setpoint, and core operating limit        Amendment No.
values determined using the ANP-10298PA, ACE/ATRIUM 1OXM Critical Power Correlation (i.e., TS 5.6.5.b.21), shall be evaluated with methods described in AREVA Operability Assessment CR 2011-2274, Revision I to verify the values determined using the NRC-approved

BSEP 11-0040 Enclosure 7 Amendment                                                     Implementation Number    Additional Conditions                               Date method remain applicable and the core operating limits include margin sufficient to bound the effects of the K-factor calculation issue described in AREVA Operability Assessment CR 2011-2274, Revision 1. The results of the evaluation shall be documented and submitted to the NRC, for review, at least 60 days prior to startup of each operating cycle.}}