ML12115A228

Enclosure 5 to Mfn 12-032 - NEDO-33173, Supplement 2, Part 2-A, Revision 1, Applicability of GE Methods to Expanded Operating Domains - Pin-by-Pin Gamma Scan at FitzPatrick, October 2006

ML12115A228
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Site:	FitzPatrick, PROJ0710
Issue date:	04/30/2012
From:	GE-Hitachi Nuclear Energy Americas
To:	Office of Nuclear Reactor Regulation
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ML121150469	List: ML12115A228
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MFN 12-032, TAC ME1891, DRF 0000-0012-1297, DRF Section 0000-0141-4409-R0 NEDO-33173, Suppl 2 Part 2-A, Rev 1
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ENCLOSURE 5 MFN 12-032 NEDO-33173, Supplement 2, Part 2-A Non-Proprietary Information- Class I (Public) IMPORTANT NOTICE This is a non-proprietary version of NEDC-33173, Supplement 2, Part 2P-A, from which the proprietary information has been removed. Portions of the enclosure that have been removed are indicated by an open and closed bracket as shown here [[ ]]. Note the NRC's Final Safety Evaluations are enclosed in NEDO-33173, Supplement 2, Part 2-A. Portions of the Safety Evaluations that have been removed are indicated with a single square bracket as shown here. [ ].

NEDO-33173 Supplement 2 Part 2-A Revision 1 DRF 0000-0012-1297 DRF Section 0000-0141-4409-R0 April 2012 Non-Proprietary Information - Class I (Public) Licensing Topical Report Applicability of GE Methods to Expanded Operating Domains - Pin-by-Pin Gamma Scan at FitzPatrick October 2006 Copyright 2009-2012 GE-Hitachi Nuclear Energy Americas LLC All Rights Reserved NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) ii INFORMATION NOTICE This is a non-proprietary version of the document NEDC-33173, Supplement 2, Part 2P-A, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here [[ ]]. Within the US NRC Safety Evaluations, the proprietary portions of the document that have been removed are indicated by an open and closed bracket as shown here [ ]. IMPORTANT NOTICE REGARDING THE CONTENTS OF THIS REPORT Please Read Carefully The information contained in this document is furnished for the purpose(s) of obtaining NRC approval of the "Applicability of GE Methods to Expanded Operating Domains - Revision 2." The only undertakings of GEH with respect to information in this document are contained in contracts between GEH and participating utilities, and nothing contained in this document shall be construed as changing those contracts. The use of this information by anyone other than those participating entities and for any purposes other than those for which it is intended is not authorized; and with respect to any unauthorized use, GEH makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document. Copyright 2009-2012, GE-Hitachi Nuclear Energy Americas LLC, All Rights Reserved.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION

Notice: Document transmitted herewith contains proprietary information. When separated from Enclosure 1, this document is decontrolled. OFFICIAL USE ONLY - PROPRIETARY INFORMATION March 15, 2012 Mr. Jerald G. Head Senior Vice President, Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC.

P.O. Box 780, M/C A-18 Wilmington, NC 28401-0780

SUBJECT:

FINAL SAFETY EVALUATION FOR GE HITACHI NUCLEAR ENERGY AMERICAS TOPICAL REPORT NEDC-33173P, REVISION 2 AND SUPPLEMENT 2, PARTS 1-3, "ANALYSIS OF GAMMA SCAN DATA AND REMOVAL OF SAFETY LIMIT CRITICAL POWER RATIO (SLMCPR) MARGIN" (TAC NO. ME1891)

Dear Mr. Head:

By letter dated August 14, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092300243), GE-Hitachi Nuclear Energy Americas (GEH) submitted Topical Report (TR) NEDC-33173P, Revision 2 and Supplement 2, Parts 1-3, "Analysis of Gamma Scan Data and Removal of Safety Limit Critical Power Ratio (SLMCPR) Margin," to the U.S. Nuclear Regulatory Commission (NRC) staff. By letter dated May 11, 2011, an NRC draft safety evaluation (SE) regarding our approval of NEDC-33173P, Revision 2 and Supplement 2, Parts 1-3 was provided, with revisions provided by e-mail dated November 29, 2011, for your review and comment. By letter dated November 7, 2011, and e-mail dated November 30, 2011, GEH identified GEH proprietary information in the draft SE, but found no factual errors or clarity concerns. Additionally, based on recommendations by the Advisory Committee for Reactor Safeguards and further consideration and review by the NRC staff, we have slightly modified the SE. The changes made are in Sections 3.3 and 4.0 of the enclosed final SE.

The NRC staff has found that NEDC-33173P, Revision 2 and Supplement 2, Parts 1-3 is acceptable for referencing in licensing applications for GEH designed boiling water reactors to the extent specified and under the limitations delineated in the TR and in the enclosed final SE.

The final SE defines the basis for our acceptance of the TR.

Our acceptance applies only to material provided in the subject TR. We do not intend to repeat our review of the acceptable material described in the TR. When the TR appears as a reference in license applications, our review will ensure that the material presented applies to the specific plant involved. License amendment requests that deviate from this TR will be subject to a plant-specific review in accordance with applicable review standards.

In accordance with the guidance provided on the NRC website, we request that GEH publish accepted proprietary and non-proprietary versions of this TR within three months of receipt of this letter. The accepted versions shall incorporate this letter and the enclosed final SE after the OFFICIAL USE ONLY - PROPRIETARY INFORMATION J. Head - 2 - OFFICIAL USE ONLY - PROPRIETARY INFORMATION title page. Also, they must contain historical review information, including NRC requests for additional information and your responses. The accepted versions shall include an "-A" (designating accepted) following the TR identification symbol.

As an alternative to including the RAIs and RAI responses behind the title page, if changes to the TR were provided to the NRC staff to support the resolution of RAI responses, and the NRC staff reviewed and approved those changes as described in the RAI responses, there are two ways that the accepted version can capture the RAIs:

1. The RAIs and RAI responses can be included as an Appendix to the accepted version.

2. The RAIs and RAI responses can be captured in the form of a table (inserted after the final SE) which summarizes the changes as shown in the approved version of the TR. The table should reference the specific RAIs and RAI responses which resulted in any changes, as shown in the accepted version of the TR.

If future changes to the NRC's regulatory requirements affect the acceptability of this TR, GEH and/or licensees referencing it will be expected to revise the TR appropriately, or justify its continued applicability for subsequent referencing. Sincerely, /RA/ Robert A. Nelson, Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 710

Enclosures:

1. Proprietary Final SE

2. Non-Proprietary Final SE

cc w/encl 2 only: See next page

OFFICIAL USE ONLY - PROPRIETARY INFORMATION J. Head - 2 - OFFICIAL USE ONLY - PROPRIETARY INFORMATION title page. Also, they must contain historical review information, including NRC requests for additional information and your responses. The accepted versions shall include an "-A" (designating accepted) following the TR identification symbol.

As an alternative to including the RAIs and RAI responses behind the title page, if changes to the TR were provided to the NRC staff to support the resolution of RAI responses, and the NRC staff reviewed and approved those changes as described in the RAI responses, there are two ways that the accepted version can capture the RAIs:

1. The RAIs and RAI responses can be included as an Appendix to the accepted version.

2. The RAIs and RAI responses can be captured in the form of a table (inserted after the final SE) which summarizes the changes as shown in the approved version of the TR. The table should reference the specific RAIs and RAI responses which resulted in any changes, as shown in the accepted version of the TR.

If future changes to the NRC's regulatory requirements affect the acceptability of this TR, GEH and/or licensees referencing it will be expected to revise the TR appropriately, or justify its continued applicability for subsequent referencing. Sincerely, /RA/ Robert A. Nelson, Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 710

Enclosures:

1. Proprietary Final SE

2. Non-Proprietary Final SE

cc w/encl 2 only: See next page

DISTRIBUTION: PUBLIC (Letter and Non-Proprietary SE only)

PLPB R/F RidsNrrDpr RidsNrrDprPlpb RidsNrrPMSPhilpott RidsNrrLADBaxley RidsOgcMailCenter RidsAcrsAcnwMailCenter RidsNrrDss RidsNrrDssSnpb JJolicoeur (Hardcopy) ADAMS Accession Nos.: Package: ML113340474; Final SE (Non-Proprietary): ML113340473; Cover letter: ML113340215; Final SE (Proprietary); ML113340123 NRR-043 OFFICE PLPB/PM PLPB/LA SNPB/BC PLPB/BC DPR/DD NAME SPhilpott DBaxley AMendiola JJolicoeur RNelson DATE 2/28/12 2/24/12 3/12/12 3/13/12 3/15/12 OFFICIAL RECORD COPY GE-Hitachi Nuclear Energy Americas Project No. 710 cc:

Mr. James F. Harrison GE-Hitachi Nuclear Energy Americas LLC Vice President - Fuel Licensing P.O. Box 780, M/C A-55 Wilmington, NC 28401-0780 james.harrison@ge.com Ms. Patricia L. Campbell Vice President, Washington Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 1299 Pennsylvania Avenue, NW 9th Floor Washington, DC 20004 patriciaL.campbell@ge.com Mr. Andrew A. Lingenfelter Vice President, Fuel Engineering Global Nuclear Fuel-Americas, LLC P.O. Box 780, M/C A-55 Wilmington, NC 28401-0780 Andy.Lingenfelter@gnf.com Edward D. Schrull GE-Hitachi Nuclear Energy Americas LLC Vice President - Services Licensing P.O. Box 780, M/C A-51 Wilmington, NC 28401-0780 Edward.schrull@ge.com

ENCLOSURE 2 APPENDIX I - SAFETY EVALUATION OF SUPPLEMENT 2 TO NEDC-33173P FINAL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION NEDC-33173P, REVISION 2 AND SUPPLEMENT 2, PARTS 1-3 "ANALYSIS OF GAMMA SCAN DATA AND REMOVAL OF SAFETY LIMIT MINIMUM CRITICAL POWER RATIO (SLMCPR) MARGIN" GE-HITACHI NUCLEAR ENERGY AMERICAS, LLC PROJECT NO. 710 1.0 INTRODUCTION AND BACKGROUND The interim methods licensing topical report (NEDC-33173P-A, "Applicability of GE [General Electric] Methods to Expanded Operating Domains," hereafter "IMLTR") provides the basis for the application of the suite of GE-Hitachi (GEH) and Global Nuclear Fuel (GNF) computational methods to perform safety analyses relevant to extended power uprate (EPU) and maximum extended load line limit analysis plus (MELLLA+) licensing (Reference 1). During its review of the IMLTR, the NRC staff identified concerns regarding the power distribution uncertainties applied in the calculation of the safety and operating limits. These power distribution uncertainties include the [ ] and the pin power peaking uncertainty (peak)1. In its safety evaluation (SE) of the IMLTR, the NRC staff imposed penalties on the safety limit minimum critical power ratio (SLMCPR) to account for inadequate qualification of these component uncertainties for modern fuel designs operating under conditions of expanded operating domains (such as EPU or MELLLA+) (Reference 2).

By letter dated November 22, 2006, GE committed to provide an updated qualification of the nuclear design methods to expanded operating domains in the form of gamma scans (Reference 3). Gamma scanning is a method for characterizing the core power distribution near the end of cycle and provides a means for determining the local bundle and local pin power distribution.

Gamma scanning, in principle, works by detecting the 1.6 MeV gamma ray emission from lanthanum-140 (140La) decay. The fuel inventory of 140La is predominantly a function of barium-140 (140Ba) beta decay. The 140Ba distribution is characteristic of the recent fission density distribution. Therefore, end-of-cycle (EOC) measurements using gamma scan techniques characterize the core power distribution near the EOC (Reference 4). 1 Nomenclature for these uncertainty parameters is specific to the GE-Hitachi and Global Nuclear Fuel analysis methods.

I-2 Gamma scanning has been a standard means for quantifying power distribution uncertainties and has formed the basis for power distribution uncertainties in GEH methods (References 5 and 6). Gamma scanning has been utilized throughout the nuclear industry to establish power distribution uncertainties for boiling water reactors (BWRs) (Reference 4). By letter dated August 14, 2009 (Reference 7), GEH submitted a revision to the IMLTR (Reference 8, hereafter "IMLTR Revision 2") and Supplement 2 to the IMLTR (hereafter "Supplement 2") in three parts (Parts 1 through 3 are References 9, 10, and 11, respectively).

Supplement 2 is intended to fulfill the commitment made by GEH in its letter dated November 22, 2006 (Reference 3). IMLTR Revision 2 references the expanded gamma scan database and provides changes to the IMLTR that remove references to the SLMCPR penalties imposed by the NRC staff in its SE for the IMLTR. Specifically, the condition specified in Section 9.4, "SLMCPR 1," of the NRC staff's SE for the IMLTR (hereafter "Limitation 4") imposes an additive penalty of 0.02 to the SLMCPR for EPU operation. The condition specified in Section 9.5, "SLMCPR 2" (hereafter "Limitation 5") imposes an adder of 0.03 to the SLMCPR for MELLLA+ operation. Supplement 2 provides the details of gamma scan campaigns performed at Cofrentes Nuclear Power Plant (CNC) and James A. FitzPatrick Nuclear Power Plant (JAF). These scans are consistent with the gamma scan campaigns described in the November 22, 2006, letter. The NRC has acknowledged that the proposed gamma scan campaigns formed a reasonable basis to qualify the neutronic methods uncertainties. By its letter dated August 14, 2009, GEH requested that the NRC staff review and approve IMLTR Revision 2 and Supplement 2, and revise the SE for the original IMLTR to remove Limitations 4 and 5. 2.0 REGULATORY EVALUATION Title 10 of the Code of Federal Regulations Section 50.34, "Contents of applications; technical information," provides requirements for the content of safety analysis reports for operating reactors. The purpose of the IMLTR is to provide a licensing basis that allows the NRC to issue SEs for expanded operating domains including constant pressure power uprate, EPU, and MELLLA+ applications. The SE for the IMLTR approves the use of GEH/GNF methods for expanded operating domains. Licensees applying for EPU or MELLLA+ license amendments may refer to the IMLTR as a basis for the license change request regarding the applicability of GEH/GNF methods to the requested changes. In its SE for the IMLTR, the NRC staff specified its approval by including several limitations and conditions. Licensees referencing the IMLTR must demonstrate compliance with the limitations and conditions to ensure that the licensee-specific application of the IMLTR is within the scope of the NRC staff's approval.

Limitation 4 of the IMLTR SE imposes an additive penalty of 0.02 to the cycle-specific SLMCPR for EPU operation, and Limitation 5 imposes an additive penalty of 0.03 to the cycle-specific I-3 SLMCPR for MELLLA+ operation. Removal of these limitations requires NRC review and approval. 3.0 TECHNICAL EVALUATION Limitations 4 and 5 were imposed to address specific uncertainties in the GEH neutronic analysis methods, particularly the assembly and pin power uncertainties. GEH has submitted Supplement 2, which provides the results of bundle gamma scan campaigns to address the bundle power uncertainty and pin-wise gamma scan campaigns to address the pin power uncertainty. The NRC staff has separately reviewed these campaigns and the qualification of the uncertainties in these parameters and documents its findings in this SE. 3.1 Bundle Gamma Scan Campaigns at CNC 3.1.1 Description of CNC CNC is a large (624 bundle), high power density BWR/6 in Spain. Core designs for CNC are typically highly heterogeneous since it has been the practice at CNC to use different fuel vendors in its fuel reloads. The gamma scan campaign results provided by Supplement 2 were performed at the EOC for Cycles 13 and 15. The Cycle 13 (c13) CNC core was comprised of GE11, GE12, and SVEA-96 fuel, while the Cycle 15 (c15) CNC core was comprised of GE12, SVEA-96, SVEA Optima 2, and GE14 (owing in part to the reload of partial batches of GE14 and SVEA Optima 2 at the beginning of cycle (BOC) 15) (References 9 and 11).

The highly heterogeneous CNC core designs between c13 and c15 make qualification against these data particularly challenging for any vendor's nuclear design methods. Of particular interest in the current review is the prevalence of modern fuel bundle designs in the c13 and c15 core designs. The GE12, SVEA-96, SVEA Optima 2, and GE14 fuel designs include 10X10 lattice geometries with part-length fuel rods. During c13, CNC was operating at approximately 104 percent of originally licensed thermal power (%OLTP). In the intervening period between c13 and c15, CNC was uprated to 112 %OLTP. The core power density was increased from 52 kilowatts/liter (kW/l) to 58.6 kW/l between its original commissioning and c15, (References 9 and 11). While operating only at 112 %OLTP, the CNC power density is near the very highest of the expanded GEH cycle-tracking database. Power densities for the expanded cycle-tracking database are presented in Table 25-1 in GEH's response to MELLLA+ Methods RAI 25 (Reference 12, hereafter MFN 05-029). This high power density makes the CNC c15 operation characteristic of EPU operation at 120 %OLTP for the domestic fleet of BWRs. CNC is operated with a flow control window (FCW) at the highest licensed thermal power level. At 112 %OLTP, the FCW extends between approximately 88 percent rated core flow (%RCF) and 105 %RCF. At 104 %OLTP this FCW extends between 80 %RCF and 105 %RCF. Operation during c13 and c15 are therefore characteristic of operation using spectral control at high power density conditions through the FCW (References 9 and 11). The NRC staff finds I-4 that these data are, to a certain extent, representative of the spectral control strategies expected for operation with a MELLLA+ FCW. However, the NRC staff notes that the flow ranges do not extend as low as those proposed for domestic BWRs at MELLLA+ conditions (Reference 13).

Supplement 2 Part 3 provides the power-to-flow map for CNC during c13 and c15, as well as the operating points where traversing in-core probe (TIP) measurements were performed. These operating maps demonstrate that the operating cycles have utilized the full extent of the FCW (Reference 11).

Therefore, the NRC staff finds that qualification against the c13 and c15 CNC data provides a robust means of qualifying the neutronic methods uncertainties. The NRC staff further notes that these data are representative of: (1) modern fuel designs, (2) operation under high power density conditions typical of domestic EPU cores, and (3) operation with expanded FCWs. 3.1.2 [ ] The uncertainty in the bundle power is factored into the calculation of the cycle-specific SLMCPR. When determining the bundle power uncertainty, [ ]. As the individual bundle powers are not measured during normal operation, the [ ] can be determined by using techniques such as gamma scanning. The [ ] was initially determined based on a battery of gamma scan campaigns performed at Quad Cities Nuclear Power Station, Edwin I. Hatch Nuclear Plant (Hatch), and Millstone Power Station (Reference 5). More recently, the [] for the improved steady state methods was quantified in Reference 6 based on the Hatch gamma scan data. This uncertainty is determined by [ ]. 3.1.3 Gamma Scan Data Collection and Processing The gamma scan data are collected for each scanned bundle by averaging the measured gamma source using a collimated detector for each of the four bundle corners. This radial averaging is performed for 25 axial locations along the bundle. The averaged axial data are proportional to the bundle power.

The data must be adjusted to account for measurement corrections such as dead-time and extent of measurement. Supplement 2 states that the appropriate measurement corrections have been considered in the gamma scan data. In addition to the measurement corrections, Supplement 2 describes the process used to account for axially varying geometry. With the advent of part-length fuel rods, the bundle gamma transport characteristics vary axially along the bundle height. This is due to variations in I-5 the geometric view factors for gamma transport from the rod gamma sources to the collimated detector. To adjust the measurement data, GEH calculated corrections to account for the geometric view factors using the Monte Carlo N-Particle transport code (MCNP). This analysis is similar to the calculational approach used to calculate gamma instrument response. The NRC staff agrees with the assessment in Supplement 2 that this approach should not be considered experimental, but rather a component of the nuclear calculational methodology, and that the corrections for geometric effects were appropriately determined and utilized.

Of the bundles that were scanned, only those bundles that were part of a full four-bundle set were considered in the qualification of the []. This makes the calculation and measurement of the [] consistent in terms of the measurement data. This amounts to eight four-bundle sets per campaign. The NRC staff finds this approach reasonable. In its request for additional information (RAI) 1, the NRC staff requested that GEH specify the location of the TIP strings relative to the four-bundle sets. GEH responded to this RAI by providing Figure 1-1 and Figure 1-2. These figures provide the locations of the TIP strings, with each TIP instrument tube identified by the TIP string number (Reference 14).

In RAI 2 the NRC staff asked whether it was possible to evaluate the scanned bundles that were not in a four-bundle set. Per GEH's response to RAI 2, calculating [] for TIP string locations where not all four of the adjacent fuel assemblies have gamma scan measurements, would require substituting analytical calculated values for the missing data. This process would taint the resulting statistics and make them misleading. [ ]. However, [ ] such as the one cited in the NRC staff's RAI (bundle AA0104) is considered in the overall bundle root mean square (RMS) statistics provided in Table 4-1 of Supplement 2 Part 1 (Reference 8). The NRC staff finds that the data collected and the processes used to account for measurement corrections and geometric view factors, are acceptable. The data was collected over the full bundle at various radial and axial locations, giving the NRC staff reasonable assurance that these measurements provide a comprehensive scan of the bundle to determine the total bundle power. 3.1.4 Gamma Scan Results Two gamma scan campaigns were performed at CNC; the first following c13 and the second following c15. The scanned bundles were distributed throughout the core in sets of neighboring bundles. Figure 2-1 of Reference 9 and Figure 4-7 of Reference 11 provide the core maps that illustrate the relative locations of the scanned bundles for c13 and c15, respectively. 3.1.4.1 Stretch Power Uprate (c13) The gamma scan data from c13 were used to quantify the [ ] for the bundles that were potentially minimum critical power ratio (MCPR)-limiting. Specifically, [

I-6 ]. Therefore, the NRC staff finds that [ ] is reasonable for establishing the bundle power uncertainty for the potentially limiting bundles. Table 5-1 of Supplement 2, Part 1 (Reference 9) provides the [] for several analysis cases. The relevant case is Case 3 from the table, which considers the [ ] and incorporates the adaptive core monitoring. This case is consistent with the core monitor accuracy in predicting the power of the potentially limiting bundles in the core. The RMS difference in the [ ]. The Table 5-1 results also consider PANAC10 results; however, PANAC10 methods have not been approved for application to EPU or MELLLA+ applications (see Limitation 1 from the NRC staff's SE for the IMLTR). The [ ] CNC c13 gamma scan based [] is to be compared to the standard production uncertainty assumed in the SLMCPR analysis provided by Reference 5

([]). These values are very comparable. This standard production value is based on the comparison of PANAC10 calculations to historical gamma scan data for 7X7 and 8X8 fuel. When the PANAC11-specific [ ] is calculated using the Hatch gamma scan data, the [ ] (Reference 6). The PANAC11 assessment accounts for improvements in the PANAC11 and TGBLA06 methods relative to their predecessor codes:

PANAC10 and TGBLA04. Supplement 2 combines the PANAC11 [ ] assessment based on the Hatch data (50 four-bundle sets) and the assessment based on the more recent CNC c13 data (8 four-bundle sets) The statistical combination of these assessments yields a [ ]. First, the NRC staff notes that the [ ] value determined purely from the 8 four-bundle sets from CNC c13 indicates very close agreement with the value assumed in the SLCMPR analysis [ ]. The NRC staff understands that these CNC c13 gamma scan data are relatively limited compared to the historical gamma scan database that considered many more four-bundle sets. Therefore, while the CNC c13 data indicates a slightly higher uncertainty, these data are too sparse to conclude that the [] has increased at stretch power uprate (SPU) conditions. Further, based on the relatively limited quantity of data from the CNC c13 data alone, the NRC staff finds it reasonable to consider a subset of the historical gamma scan data (Hatch c1 and c3 data).

When these data are considered as a single set, the data indicate a small decrease in the [ ] that is largely attributed to improvements in the TGBLA06 and PANAC11 physical models.

However, these data remain insufficient to fully justify the continued applicability of the historically-determined [ ] on their own. In addition to the statistical assessment of the [] based on the CNC c13 data, the NRC staff reviewed the trending of the gamma scan measurements with power, exposure, and axial location. Figure 4-10 of Supplement 2 Part 1 (Reference 9) provides a plot of the error in the calculated bundle power as a function of the measured bundle power. The figure does not demonstrate any discernable bias in the calculated power with increasing bundle power levels. This provides I-7 the NRC staff with assurance that the neutronic methods are sufficiently robust over a range of bundle powers.

Figure 4-5 of Supplement 2 Part 1 (Reference 9) provides a plot of the error in the calculated bundle power as a function of the bundle exposure. The figure shows that data are scattered above and below the mean value of zero. These data do not indicate any bias. The data are presented for different fuel bundle types. As the scanned fuel types were loaded in different batches, the GE11, SVEA, and GE12 fuel data are clustered. The NRC staff observed that the relative difference in measured and calculated bundle powers for all bundles remained within the one standard deviation uncertainty in bundle power according to Reference 5 [ ] over the full range of exposure. This provides the NRC staff with reasonable assurance that the bundle power uncertainty is applicable over the full range of exposure and is not expected to change as a function of the bundle exposure. The NRC staff reviewed any trends in the local power distribution calculations with axial elevation. As the void fraction itself is not measured, the NRC staff relied on trends along the axial elevation of the bundle to serve as a surrogate for any trend in the uncertainties or errors that is potentially sensitive to the in-channel void fraction (which increases with axial elevation). Figure 4-12 of Supplement 2 Part 1 (Reference 9) provides a plot of the adapted axial power shape against the data collected for the scanned bundles at each axial location. The comparison of the monitored power shape and the measured power shape does not indicate any bias in terms of increasing biases or uncertainties with increasing axial elevation. Therefore, these data indicate that the computational efficacy does not degrade with increasing nodal void fraction. 3.1.4.2 EPU (c15) In the CNC c15 database, the gamma scan results for several bundles were excluded due to errors in the measurements. These errors were attributed to a missing absorber component in the gamma scan measurements. Therefore, the NRC staff agrees that these data are erroneous and should be removed from the dataset. Several comparisons between measurements were considered for this database. In particular, results were presented for bundle power calculations and measurements that included low-power, peripheral assemblies. Generally, when deriving the [ ] the non-limiting peripheral bundles are excluded from the dataset.

The NRC staff reviewed the integral performance of PANAC11 to predict the bundle powers. Table 9-2 of Supplement 2 Part 3 (Reference 11) provides the comparison of the adapted and non-adapted PANAC11 bundle power calculations to the gamma scan measurements. Three scenarios are presented where, in certain cases, low-powered bundles are removed from the qualification database. The NRC staff compared the bundle RMS errors to the bundle power uncertainty of [ ] for the TGBLA06/PANAC11 code system as reported in Reference 6.

With just four erroneous measurements removed from the data set, the bundle RMS error for the adapted cases is []. This value is slightly improved when the low-powered I-8 assemblies are removed from the database, resulting in a value of [ ] when five low-powered assemblies are removed. In all three scenarios, the bundle power uncertainty compares well with the accuracy reported in Reference 6.

The NRC staff further notes that the experimental uncertainty in the gamma scan measurement itself is [ ]. Therefore, better agreement with the experimental data could not be expected. These comparisons demonstrate excellent agreement between the measurements and calculations of the bundle powers with only a small uncertainty that is associated with the calculational methods. Additionally, the SLMCPR calculational process utilizes a higher bundle power uncertainty as determined for TGBLA04/PANAC10 methods (which have been shown to be less accurate than TGBLA06/PANAC11). The PANAC10-based bundle power uncertainty is

[ ]2 (Reference 5).

The [ ]. In total, eight four-bundle sets were considered. This is partially attributed to the removal of a four-bundle set due to elimination of one of the bundles within the set that was at the core periphery (see Figures 9-21 and 10-2 of Supplement 2 Part 3). Table 10-1 of Supplement 2 Part 3 provides a summary of the statistical results. The NRC staff notes that removing additional bundles from consideration does not impact the [ ] since these bundles were not part of a four-bundle set. The results show a [ ] for the eight four-bundle sets. Including the removed peripheral fuel bundle in the dataset [ ] (adapted case) (Reference 11). The NRC staff notes that the [] utilized in the SLMCPR determination is [ ].

The NRC staff agrees that removing the peripheral bundles from consideration is acceptable since large gradient errors in these bundles affect the accurate prediction of the bundle powers. These bundles are low in power and are not potentially limiting in terms of thermal margin. However, the NRC staff compared [] for both cases to the PANAC11 [ ] as reported in Reference 6. The NRC staff finds that the CNC c15 gamma scan data comparison with PANAC11 is consistent with the performance of PANAC11 when compared with the Hatch c1 and c3 gamma scan data. When the EPU and SPU (c15 and c13, respectively) data are considered together, the average

[] determined from these data is [ ]. This average value based on both CNC gamma scan campaigns agrees well with the PANAC11-specific [ ]. This indicates essentially no degradation in the [ ] calculations with the introduction of 10X10 fuel and higher core power-to-flow ratios relative to the original Hatch qualification data. In addition to the statistical assessment of the [] based on the CNC c15 data, the NRC staff reviewed the trending of the gamma scan measurements with bundle type, power, exposure, and axial location. 2 This value is the [ ]

I-9 Figure 9-4 of Supplement 2 Part 3 (Reference 11) provides a plot of the adapted predicted barium concentration versus the measured lanthanum concentration. The measured concentration is a measure of the near EOC power. The data are presented for all of the scanned fuel bundles, including GE12, GE14, SVEA Optima 2 and SVEA-96. These bundles are designed by different vendors and all are based on a 10X10 lattice array. As is evident from the plot, no discernable trends in the uncertainty are apparent as a function of either the bundle power or the specific bundle design for these 10X10 fuel designs.

Figure 9-5 of Supplement 2 Part 3 indicates some [ ]. Figure 9-6 of Supplement 2 Part 3 provides a figure showing the power error as a function of the bundle exposure for the adapted case. [ ]. The larger errors are inconsequential as these bundles are in non-limiting locations and the bundle powers are very low. Generally, the figure indicates a [ ]. Overall, no discernable trends are observed as a function of exposure. Figure 9-8 of Supplement 2 Part 3 provides plots of the measured and calculated axial power shape. The data indicate good agreement. [ ]. Figure 9-20 of Supplement 2 Part 3 provides a similar data comparison with the spread in the errors depicted alongside the average. Figures 9-14 through 9-18 of Supplement 2 Part 3 provide plots of the nodal predicted and measured powers. These plots provide another way to visualize trends with either power or bundle design. The figures indicate good agreement in the nodal power predictions over a large range of powers for all of the bundle types. As these data are nodal powers, they likewise indicate good agreement over the full range of axial location. 3.1.5 Supporting TIP Data and Comparison to the Experience Base CNC is a gamma TIP plant. GEH provided comparisons of calculated and measured TIP responses. In addition to the gamma scan measurement results, the NRC staff reviewed these supporting data for consistency with the expanded EPU database.

The c15 TIP data are provided in Appendix A of Supplement 2 Part 3. The axial power shape evolves from a bottom-peaked to a top-peaked shape over the cycle. The individual and core I-10 average axial measurements are provided. The results indicate consistent agreement and bundle, axial, and nodal TIP RMS differences are within expected ranges. The NRC staff compared the CNC c15 TIP comparisons to those data provided to the NRC staff in response to MELLLA+ Methods RAI 25 (see MFN 05-029, Reference 12). The NRC staff plotted the c15 TIP differences as a function of power-to-flow ratio for direct comparison to the gamma TIP results provided in Figure 25-19 of MFN 05-029. Figure 3.1.5-1 of this SE provides the c15 TIP comparisons. The power-to-flow ratios encompass those experienced by the plants operating in the expanded database and demonstrate consistent trends in local power distribution RMS differences. The four-bundle power differences appear to have [ ] depicted in Figure 25-19 of MFN 05-029. In RAI 3, the NRC staff requested that GEH provide a figure similar to Figure 25-19 from MFN 05-029 (Reference 12) based on the c13 TIP data. GEH provided a response to this RAI in the form of Figure 3-1 (Reference 14). GEH pointed out in this response that the CNC c13 and c15 data are quite compatible with the information in Figure 25-19. In each case, [ ] as compared to Figure 25-19. The NRC staff evaluated the applicability of the CNC gamma scan data based on comparisons of key operating parameters for c15 against those identified by the NRC staff in Section 2.1.1 of the SE for the IMLTR. Figures 2-1 through 2-4 of the NRC staff's SE for the IMLTR (Reference 1) summarize the range of key operating parameters for several EPU plants and a high power density SPU plant. The NRC staff compared these figures to those provided in Supplement 2 Part 3, Section 6.

• Maximum Bundle Power Supplement 2 Part 3, Figure 6-1 is analogous to Figure 2-1 from the IMLTR SE. These figures plot the maximum bundle powers as a function of the cycle exposure. The range of maximum bundle powers is consistent between the experience base and CNC c15. The SVEA Optima 2 bundles reach slightly higher bundle powers [ ] compared to the reference experience base, but are largely consistent with the highest bundle powers for the reference plants.

• Maximum Bundle Power-to-Flow Ratio Supplement 2 Part 3 Figure 6-5 is analogous to Figure 2-2 from the IMLTR SE. These figures plot the maximum ratio of bundle power-to-flow as a function of the cycle exposure. The range of power-to-flow ratios is consistent between CNC c15 and the reference plants. Both figures show maximum values of approximately [ ]. The CNC c15 power-to-flow ratios decrease along with the core average power-to-flow ratio near the EOC. This is consistent with the overall operation during c15 as I-11 shown in Figure 4-8 of Supplement 2 Part 3. The NRC staff finds that the range of maximum bundle power-to-flow ratios is consistent between CNC and the IMLTR reference plants.

• Exit Void Fraction Supplement 2 Part 3 Figure 6-7 is analogous to Figure 2-3 from the IMLTR SE. These figures plot the maximum exit void fraction as a function of the cycle exposure. The figures demonstrate consistent maximum void fractions of approximately [ ].

• Peak Linear Heat Generation Rate Supplement 2 Part 3 Figure 6-8 is analogous to Figure 2-4 from the IMLTR SE. These figures plot the maximum bundle linear heat generation rate (LHGR) as a function of the cycle exposure. Figure 6-8 illustrates the higher peak LHGRs for the fresher fuel assemblies (GE14 and SVEA Optima 2). For these bundles, the peak LHGR reaches approximately [ ]. Figure 2-4 shows somewhat higher peak LHGR near the BOC, in certain cases exceeding []. However, these results are indicative of the peak LHGR for the core while the CNC results are plotted as a function of the bundle type as well. The once-burnt fuel assemblies (GE12 and SVEA-96) illustrate this point as they achieve substantially lower peak LHGR during the cycle. Therefore, some differences between the peak LHGRs are expected. Overall, the NRC staff finds that the peak LHGRs achieved by the higher-powered fresh assemblies considered in Supplement 2 Part 3 are within the range of peak LHGRs shown in Figure 2-4 of the IMLTR SE, and therefore the evaluations for the CNC and the IMLTR reference plants are consistent.

The NRC staff reviewed the TIP data, key operating parameters, and predicted void conditions for CNC c13 and c15. These comparisons demonstrate consistency between the CNC results and the expanded EPU database. On this basis, the NRC staff finds that the overall performance of the nuclear methods is expected to also be consistent for various EPU core designs and CNC. Therefore, the NRC staff is reasonably assured that CNC gamma scan data provides a sufficient basis to justify [] for domestic EPU plants. 3.1.6 Bundle Power Uncertainty Conclusions The NRC staff has reviewed the bundle power gamma scan data provided in Supplement 2.

These data support the claim that the TGBLA06/PANAC11 computational methods remain applicable to EPU conditions and retain the capability to calculate the individual bundle powers within those uncertainty values applied in the SLMCPR calculations. The NRC staff has reviewed gamma scan trends with power, exposure, void fraction, and geometry. In its review, the NRC staff discerned no evidence of degradation in the calculational capability of the code suite to calculate the bundle powers. Further, the NRC staff requested that GEH confirm that the differences between measurements and data were normally distributed. In response to RAI 21 (Reference 15), GEH provided the results of an Anderson-Darling normality test. The response is consistent with a similar RAI (III-3) the NRC staff issued in its review of NEDC-32694P-A (Reference 5) and likewise indicates that the data are normally I-12 distributed. The consistency of the calculational accuracy over these varying nodal conditions provides assurance that the methods are sufficiently robust in their treatment of the nuclear phenomena that extrapolation to EPU conditions is adequately treated. The NRC staff notes that the CNC c13 and c15 core designs present a particular challenge to the nuclear methods on the basis of the highly heterogeneous nature of the core design. The analytical methods demonstrated acceptable performance in their capabilities for this core design, including the accurate prediction of the power in bundles manufactured by a different fuel vendor. The NRC staff reviewed the operational characteristics of CNC and found that the power density was near the highest power density of plants currently operating at EPU conditions. Additionally, operation during c13 and c15 at CNC utilized a limited FCW that extends to relatively low flow rates, making these data particularly relevant to qualification of the nuclear methods for the extension to MELLLA+ applications. The NRC staff must note that the bundle power uncertainty utilized in the SLMCPR calculation is based on qualification of the TGBLA04/PANAC10 code suite, and therefore, the lower uncertainties demonstrated as part of the subject qualification are expected, given the improvements in the current standard production versions (TGBLA06/PANAC11). The NRC staff, however, based its review on demonstration that the currently approved uncertainties are sufficient to bound operation in expanded operating domains and that no change in the currently approved uncertainty values is proposed in the subject submittal. The NRC staff's SE for the IMLTR imposed a penalty of 0.01 for the SLMCPR to account for potentially increased uncertainty in the []. On the basis of the expanded qualification for CNC at SPU and EPU conditions, the NRC staff has found that the [] remains within the accuracy purported in Reference 5, even considering challenges to the methods including: high power density, operation along a FCW at EPU power levels, modern fuel bundle designs, and mixed core conditions. On this basis, the NRC staff approves the reduction of the SLMCPR adder imposed by Limitations 4 and 5 by a margin of 0.01. 3.2 Pin-wise Gamma Scan Campaigns at JAF 3.2.1 Description of JAF and Scanned Bundles JAF is a 560 bundle, D-lattice BWR/4 with a SPU to approximately 104 %OLTP. At SPU conditions, the reactor power density is 51.2 kW/l (Reference 10). This power density is at the lower power density range of the expanded GEH cycle-tracking database from MFN 05-029 (Reference 12). Pin-wise gamma scan data were collected for GE14 fuel assemblies depleted at JAF during Cycles 16 and 17 (c16 and c17, respectively). The c16 core introduced the first reload batch of GE14 fuel and is comprised predominantly of GE12 fuel. The c17 core is approximately 70 percent GE14 fuel following another reload batch of GE14 fuel (Reference 10).

I-13 Gamma scans were performed for one once-burnt GE14 fuel bundle (designated JLM420) and for one twice-burnt GE14 fuel bundle (designated JLD505). The exposures were approximately 20 gigawatt-days per metric ton (GWD/MT) for the once-burnt and 40 GWD/MT for the twice-burnt bundles. The gamma scans were performed on a rod basis to measure the rod power distribution within these bundles. The scanned rods were selected along the symmetry axis (lattice diagonal). Some rods in symmetric lattice locations were also scanned. 3.2.2 Power Peaking Factor Uncertainty The power peaking factor uncertainty is a [ ]. These uncertainties were generically defined in the GEH SLMCPR process in Reference 16. During its review of the IMLTR, the NRC staff determined that the infinite lattice peaking factor uncertainty was not adequately qualified for modern fuel bundle designs and expanded operating domains (Reference 1). This uncertainty is a [ ]. Overall qualification using pin-wise gamma scan data provides a direct means for qualifying the overall code system against direct measurement of the local pin power distribution. Therefore the Supplement 2 assessment did not individually consider these component uncertainties. Table 7.1-1 of Supplement 2 Part 2 provides a summary of the component uncertainties comprising the total peak. These component uncertainties include [ ]. The general approach outlined in Supplement 2 Part 2 is to demonstrate pin peaking uncertainties that are within the total uncertainty assumed in the safety limit analysis.

For conservatism, the NRC staff compared the gamma scan campaign comparison results to a smaller uncertainty. This smaller uncertainty was determined according to [ ]. This approach conservatively ignores [ ] on the pin power distribution uncertainty. This approach was adopted as it is inherently conservative [ ] and allows the NRC staff to limit its review of the [ ] of the scanned bundles. The NRC staff's review method is a conservative, alternate approach to the one described in Supplement 2 Part 2.

The combination of the uncertainties related to [ ]. Therefore, the NRC staff considered pin power uncertainties less than [ ] to be acceptable evidence that the uncertainties assumed in the safety analysis are conservative.

I-14 3.2.3 Gamma Scan Results Section 5 of Supplement 2 Part 2 provides a description of the traditional basis for the comparison of gamma scan data. The traditional basis refers to the method employed by GEH to characterize the pin power distribution uncertainty using integral gamma scan results from scans performed at Duane Arnold Energy Center and reported in Reference 5. Section 5 describes the process of accounting for measurement reproducibility. In simplistic terms, the measurement uncertainty is determined by performing repeated scans for a reference fuel rod.

This establishes the contribution to the total uncertainty attributed to deviations associated with measurement itself. In the traditional basis, this component is referred to as the reproducibility. Consistent with the previously approved traditional basis, reference rod measurements were performed during the JAF gamma scan campaign to quantify the measurement reproducibility. The NRC staff finds that this approach is consistent with the previously approved basis and is therefore acceptable.

Section 5 of Supplement 2 Part 2 also provides the results and statistics for each axial level. The corrected standard deviation reported in this section for each axial level is a measure of the uncertainty in the prediction of the pin power distribution. Specifically, the NRC staff considered the off-line adapted PANAC11 results as these calculations most closely approximate the performance of the 3D MONICORE core monitoring system which is used during normal operation to evaluate thermal margins. Figure 3.2.3-1 in this SE provides a plot of the pin power corrected standard deviation as a function of the axial height for both of the scanned bundles. These plots are derived from the data presented in Tables 5.2-1 and 5.3-1 of Supplement 2 Part 2 (Reference 10). The NRC staff plotted these data to visualize any trends in the pin power distribution uncertainty as a function of the axial height. Axial height serves as a surrogate to visualize any trend in the calculation of the pin power distribution uncertainty as a function of void fraction. Figure 2.9.3 of Supplement 2 Part 2 (Reference 10) provides a plot of the void distribution in both of the scanned bundles as calculated by PANAC11 and illustrates that the void fraction varies over a wide range for both bundles. Figure 3.2.3-1 shows that there are no trends observed for the data. In Figure 3.2.3-1, the NRC staff also plotted the linear average of the axial results. The agreement between the two scanned bundles indicates consistency in the performance of the methods. The very close agreement in the accuracy of the methods between the two scanned bundles likewise indicates that there is no strong trending with the bundle or nodal exposure. The NRC staff compared the corrected standard deviation (which is a measure of the uncertainty associated with the methods) to the pin power distribution uncertainty figure of merit

([ ] established in Section 3.2.2 of this SE). The NRC staff found that the uncertainties in the local pin power distribution are within the uncertainty figure of merit.

Therefore, these data indicate that the pin power distribution uncertainty used in the safety limit analysis is conservative.

I-15 Supplement 2 Part 2 also provides detailed figures that provide the results of the measurement and calculation comparisons on a rod-by-rod basis. These figures are provided in Section 5.4 of Supplement 2 Part 2. To assist the NRC staff, Section 8 of Supplement 2 Part 2 provides isometric figures that illustrate trends in rod-by-rod uncertainties for bundle JLM420. The NRC staff reviewed these rod-by-rod data to determine if the methods indicate any systematic biases and to examine if any observed biases are expected to be exacerbated at EPU or MELLLA+ operating conditions. The figures provided in Section 8 appear to indicate a [ ]. This appears to the NRC staff to be a [ ]. The NRC staff requested additional information regarding this corner rod in several RAIs. In reference to Figures 2.3-1 and 2.4-1 of Supplement 2, Part 2, GEH was asked to indicate where the nearest instrument tube is located relative to the scanned bundles. GEH responded by providing Figure 5-1 (Reference 14), showing the locations of the TIP strings in JAF, with each TIP instrument tube identified by the TIP string number. The TIP string is located at the bottom, right-hand corner of the bundle with the TIP string number. GEH pointed out that the four-bundle cells highlighted in Figure 5-1 are the four-bundle cells surrounding the TIP string. However, GEH did not identify the four bundles around a control rod. GEH also pointed out that JLD505 is not adjacent to an instrument tube in either c16 or c17, while JLM420 is adjacent to an instrument tube. 3.2.4 Supporting TIP Data and Comparison to the Experience Base Appendix A of Supplement 2 Part 2 provides non-adapted TIP comparisons for JAF c17. These data are provided as additional confirmation of the validity of the neutronic methods. The NRC staff reviewed these data for consistency with the expanded EPU database of TIP measurement comparisons. The NRC staff found that the nodal, axial, and radial TIP comparisons were generally very good. With respect to the radial TIP comparisons, the NRC staff requested additional information in RAI 18 regarding an anomalous point near the EOC exposure. GEH responded to this RAI by noting that toward the end of c17, the TIP machine was found to be in-operable. Specifically, the TIPs associated with this machine were not normalized to the same integral values as the TIP data from the other TIP machine. Consequently, the nodal RMS difference between the measured and the calculated TIPs increased significantly. The problem was corrected by the next TIP set. The cycle average radial TIP RMS is [ ]. This is largely consistent with the four-bundle power uncertainty derived from the database in Reference 6 [ ] and the results from the expanded EPU database detailed in Table 25-14 of MFN 05-029 (Reference 12) [ ]. The NRC staff compared the key operating parameters for the gamma scanned bundles against relevant key operating parameters for high power-density plants considered in the NRC staff review of the IMLTR. These key operating parameters for various plants are plotted in Figures 2-1 through 2-4 in the SE for the IMLTR (Reference 1). These parameters include maximum bundle power, maximum power-to-flow ratio, maximum exit void fraction, and peak LHGR.

I-16

• Maximum Bundle Power Figure 2.7-1 of Supplement 2 Part 2 is analogous to Figure 2-1 from the IMLTR SE. Figure 2.7-1 provides the peak bundle power as a function of cycle exposure for JAF c17. The NRC staff notes that the peak bundle power shifts from one bundle to another during normal exposure. However, Figure 2.7-1 also provides the power histories for the scanned bundles (JLM420 and JLM505). The figure shows that throughout cycle exposure, JLM420 is operated at bundle powers very near the maximum for the core. There is a short duration where bundle JLM420 is partially controlled. During c17, JLD505 is also burnt at high bundle power considering that this bundle had already been irradiated during c16. The maximum bundle powers for JAF c17 range between [ ]. This is similar to the average maximum bundle power for the EPU plants plotted in Figure 2-1 of the IMLTR SE; however, peak bundle powers for the EPU reference plants included several at powers as high as 7.5 MW. Therefore, the NRC staff would consider the high-duty bundles to be representative of EPU, but would not consider the operation of these bundles during JAF c17 to be bounding of EPU operation. It is clear from Figure 2.7-1, however, that the bundles considered in the gamma scan campaign (JLM420 and JLD505) were high-duty bundles. These bundles may not achieve instantaneous peak bundle powers that bound the EPU operating experience, but they were selected based on aggressive power histories, such that the exposure averaged bundle powers appear to significantly exceed average bundle powers for EPU operation. From visual inference, the JLM420 exposure average bundle power appears to be approximately [ ] whereas 5.5 MW is typical for average bundle power at EPU conditions. Considering that the bundles used in the gamma scan campaign were high-duty bundles, the NRC staff accepts these bundles as being reasonably representative of bundles operated in EPU cores.

• Maximum Bundle Power-to-Flow Ratio Figure 2.7-2 of Supplement 2 Part 2 is analogous to Figure 2-2 from the IMLTR SE. This figure plots the maximum bundle power-to-flow ratio as a function of the cycle exposure. The JAF c17 maximum bundle power-to-flow ratios are consistent with the ratios plotted in Figure 2-2 of the IMLTR SE. At SPU power levels, the radial peaking factors tend to be higher than at EPU conditions. As such, flow tends to favor lower power bundles and the peak powered bundles receive relatively lower apportionments of the total core flow relative to an EPU core. Therefore, the agreement is expected. The NRC staff notes that the EPU reference plants plotted in Figure 2-2 of the IMLTR SE include some bundles operated at maximum bundle power-to-flow ratios [ ] whereas the maximum ratio for JAF c17 is [ ]. The difference is slight, however, and the NRC staff notes that JAF c17 operation is consistent with EPU operation in terms of limiting bundle power-to-flow ratio. As can be seen the JLM420 bundle operating history includes bundle power-to-flow ratios that approach the limiting conditions during c17. Likewise, JLD505 attains aggressive bundle power-to-flow ratios, particularly early and late in the cycle. Other than the period of exposure where JLM420 is controlled, this bundle operates consistently near the highest power-to-flow ratio. As stated previously, the maximum bundle power shifts from bundle to bundle during I-17 cycle operation. Therefore, Figure 2.7-1 depicts how aggressively the bundles were depleted.

The NRC staff concludes that the bundles selected for the gamma scan campaign were operated at high power and were therefore depleted at power-to-flow ratios consistent with EPU operation.

• Exit Void Fraction Figure 2.7-3 of Supplement 2 Part 2 is analogous to Figure 2-3 from the IMLTR SE. This figure plots the exit void fraction as a function of the cycle exposure. Figure 2.7-3 depicts the exit void fractions for bundles JLM420 and JLD505. The exit void fractions remain consistently large through the entire cycle of exposure, which is consistent with the high power operating histories for these bundles. The void fraction remains [ ] for both bundles, except for the period of control. These conditions are slightly lower than the maximum void fractions expected for EPU operation (85 to 90 percent) and less than the maximum exit void fraction expected for MELLLA+ operation (greater than 90 percent). While the maximum void fractions are [ ] the NRC staff notes that the void fractions are consistently high for both bundles over the cycle exposure. Therefore, while the instantaneous void fractions may not encompass those for EPU operation, the void histories are relatively high. On this basis, the NRC staff finds that the gamma scans were performed on bundles that can be reasonably expected to be representative of void history conditions for EPU cores. However, at EPU conditions the void fractions, power-to-flow ratios, and the maximum bundle powers are higher. On this basis, the NRC staff does not consider the JAF comparisons to be bounding. Based on the consistency of the high power operation and void fraction, however, the NRC staff considers the exposure histories for these bundles to be aggressive for SPU operation and therefore representative of EPU operation.

• Peak Linear Heat Generation Rate Figure 2.7-4 of Supplement 2 Part 2 is analogous to Figure 2-4 from the IMLTR SE. These figures plot the peak LHGR as a function of the cycle exposure. Figure 2.7-4 plots the maximum LHGR for JAF c17 as well as the individual maximum LHGRs for bundles JLM420 and JLD505. In addition, Figure 2.7-4 also plots the peak LHGR at the limiting maximum fraction of limiting power density (MFLPD) node. Figure 2.7-4 shows that the JLM420 LHGR approaches the maximum for the core early during cycle exposure. The JLD505 LHGRs are lower; however the LHGR limit for the higher exposure nodes is also lower. The plot of the peak LHGR at the limiting MFLPD node shows that lower LHGRs are allowable at higher exposures. Between the peak LHGR curve and the limiting MFLPD curve, Figure 2.7-4 shows that JLM420 and JLD505 were operated near LHGR limits. The early LHGR exposure for JLM420 was approximately [ ]. This is consistent with Figure 2-4 from the IMLTR SE. However, peak LHGR is constrained by the fuel design specific thermal-mechanical operating limits and therefore early cycle peak LHGRs are constrained to the same maximum. From about mid-cycle to the EOC, the JLD505 peak LHGR tracked closely with the limiting MFLPD peak LHGR, indicating an aggressive operating history for this once-burnt assembly.

I-18 The NRC staff requested additional information regarding the operating history for JLD505 in RAI 8. In response to this RAI, GEH provided a series of figures (Figures 8-1 through 8-4 in Reference 14). Based on the comparison of key operating parameters, the NRC staff concludes that the JAF scanned bundles are representative of EPU operation. 3.2.5 Local Power Range Monitor Calibration Interval Considerations The NRC staff requested additional information regarding quantification for the basis of the uncertainty attributed to instrument failure. In addition, the NRC staff also pointed out that upon cursory review of NEDC-32694P-A, "Power Distribution Uncertainties for Safety Limit MCPR Evaluations," Appendix B (Reference 5), the basis appears to be based [ ]. GEH answered all of the NRC staff's concerns in detail in its response to RAI 20 (Reference 14).

GEH pointed out in the responses to RAI 20 that LPRM update uncertainties for currently operating BWRs with modern fuel designs and current LPRM detector types have been examined for representative population of the entire BWR fleet. To evaluate the LPRM uncertainty, GEH evaluated [ ]. Current data was obtained from 12 cycles of 7 plants, as shown in Table 20-1 of the RAI 20 response (Reference 14).

Table 20-1 shows a list of plants that includes D, C, and S lattices, small plants and large plants, and both thermal (neutron) TIP monitoring systems and gamma TIP monitoring systems. As shown in Figures 20-1, 20-2, and 20-33 of Reference 14, the LPRM update uncertainty evaluations demonstrate essentially no exposure dependency. As summarized in Table 20-3, the one sigma (standard deviation or RMS) uncertainty values are well within the currently accepted GEH licensing basis for LPRM update uncertainty. In particular, the current LPRM update uncertainty of [ ] for LHGR evaluations is quite well supported by the summary data provided in Table 3, "% Change in MFLPD" of Reference 14. In follow-up discussions with GEH regarding the responses to RAI 20, the NRC staff questioned the combined impact on LPRM update uncertainty if simultaneous extrapolations of both LPRM calibration interval and power-to-flow ratio are considered. The NRC staff requested that GEH quantify this impact on LPRM update uncertainty and the resultant impact on LHGR uncertainty. In its response to RAI 20 Supplement 1 (Reference 15), GEH demonstrated that considering these simultaneous extrapolations would result in a bounding LPRM update uncertainty of [] percent. Using this value brings the total LHGR uncertainty to [] percent, which still allows for sufficient margin to the LHGR process limit of [] percent. The NRC staff finds this assessment of the combined impact on LHGR uncertainty acceptable. 3.2.6 Pin-wise Power Uncertainty Conclusions. The NRC staff's SE for the IMLTR imposed a penalty of 0.01 for the SLMCPR to account for potentially increased peak. On the basis of the expanded qualification for JAF, the NRC staff has found that the peak remains within the accuracy defined in Reference 5. On this basis, the I-19 NRC staff approves the reduction of the SLMCPR adder imposed by Limitations 4 and 5 by a margin of 0.01. 3.3 Special Considerations for MELLLA+ In its SE for the IMLTR, the NRC staff imposed a penalty to the SLMCPR for EPU operation of 0.02 (see IMLTR SE Limitation 4). This adder is comprised of a penalty addressing increased bundle power uncertainty and another addressing increased peak. In addition, the NRC staff increased the penalty to 0.03 for MELLLA+ operation to account for additional thermal margin (see IMLTR SE Limitation 5). The additional 0.01 value is to account for: (1) the fact that operation at lower core flow conditions at rated or EPU power levels are generally more limiting, and (2) potential changes in the uncertainties due to the higher bundle power-to-flow ratio on both pin and bundle powers (Reference 1). In its SE for the IMLTR, the NRC staff recommends scrutinizing any gamma scan data for applicability to the MELLLA+ operating domain to ensure that the peak is derived from spectrally hard conditions similar to those expected for MELLLA+ core conditions (Reference 1). The NRC staff reviewed the core monitoring calculations performed for the bundles scanned as part of the JAF c17 campaign. Figure 2.9.3 of Supplement 2 Part 2 provides a plot of the PANAC11 predicted axial void distribution for the scanned GE14 bundles. While the JLM420 bundle achieves high void fraction [ ] the average void fraction for these bundles remains well below the expected range of exit void fraction for limiting bundles operating at MELLLA+ low-flow conditions. In addition, [ ] - which are expected to be significantly increased for MELLLA+ operation. Therefore, the NRC staff cannot conclude that the spectral conditions experienced by the JAF bundles during the c17 campaign were inclusive of the conditions expected for MELLLA+ operation. The JAF c17 gamma scan campaign, however, has addressed concerns regarding the neutronic methods. First, these scans have served to provide the NRC staff with assurance that the methods remain robust for application to modern fuel bundle designs. Additionally, while not fully reaching anticipated void fractions for MELLLA+ operation, these data do provide assurance that the methods remain robust for high bundle power application where the void fraction exceeds 70 percent. Trend data for the overall rod power uncertainty statistics provides assurances that discernable trends in the methods' performance do not occur over a wide range of void fractions up to approximately 75 percent. The NRC staff further notes that the uncertainties in the rod powers were significantly lower than those assumed in the SLMCPR analysis. This is due in part to conservatism in the uncertainty values as they were developed on the basis for the less accurate TGBLA04/PANAC10 methodology.

In RAI 14 the NRC staff requested additional information to characterize what appears to be a

[ ]. GEH responded to RAI 14 by comparing the results for two bundles - one that appeared to show [

I-20 ]. GEH stated that more detailed calculations could be made to [ ]. Since the normal design process does not consider the effects of the [ ] this improved statistical comparison would not be representative of the accuracy of the design process, and so, has not been included. The NRC staff agrees with this assessment of [ ] and finds GEH's assessment of this issue acceptable. In RAI 17, the NRC staff requested that GEH consider the extrapolation of any biases to MELLLA+ conditions and the subsequent ramification for TIP simulation. GEH responded to RAI 17 by referencing the RAI 14 response and stating that no additional impact for these potential biases are foreseen for MELLLA+ operating conditions. The NRC staff found the response to RAI 17 to be acceptable. Further, GEH has committed to provide future cycle tracking information (hot and cold eigenvalue and TIP data comparisons - see the response to RAI 6 in Reference 17). The NRC staff imposed a limitation to this effect in its SE for the IMLTR (Limitation 23, Reference 1). The evaluation of the core-tracking data will provide the basis to establish if MELLLA+ operation indicates any changes in the performance of the nuclear methods or any needs to revise the uncertainties applied in the determination of the safety and operating limits. In the IMLTR SE (Reference 1) the NRC staff identified the potential for anomalies to influence the predictive capabilities of the core monitoring and simulation methods. In the interim, the NRC staff has not reviewed operational data demonstrating the capability of the GEH nuclear methods for MELLLA+ operation. Therefore, the NRC staff cannot conclude that extrapolation of the GEH methods to MELLLA+ is possible without additional analytical thermal margin provided in the form of Limitation 5. Therefore, while the gamma scan data have provided adequate qualification to support the reduction in this SLMCPR penalty, data derived from operation at CNC and JAF is insufficient to fully bound the operational characteristics of MELLLA+ operation. Additionally, since the gamma scan data was limited to conditions with power-to-flow ratios up to 42 MWt/Mlbm/hr, the staff remains concerned with maintaining additional margin for MELLLA+ conditions with power-to-flow ratios above 42 MWt/Mlbm/hr in view of the uncertainties in extrapolating beyond the range of the available data. The NRC staff has previously noted that the CNC data provides particular relevance to qualification for MELLLA+ operation given the utilization of a FCW during c15 operation at high thermal power. This is to be contrasted with the conditions of the JAF gamma scan campaign.

The NRC staff does not have reasonable assurance that the uncertainties have been adequately justified for applicability to MELLLA+ conditions. Therefore, the NRC staff continues to impose a penalty to the SLMCPR for MELLLA+ applications. The penalty to be added to the SLMCPR will be 0.01 for MELLLA+ applications with power-to-flow ratios up to 42 I-21 MWt/Mlbm/hr. For MELLLA+ applications with power-to-flow ratios above 42 MWt/Mlbm/hr, the penalty to be added to the SLMCPR will be 0.02.

GEH's responses to the NRC staff's RAI 13 and 14 provide additional details diagnosing and quantifying the trends in pin power distribution. On the basis of these detailed evaluations, the NRC staff concludes that the trends in power distribution have been adequately explained and there is assurance that additional error or bias would not be introduced by further extrapolation to higher void conditions. However, anomalies associated with MELLLA+ operation have not been addressed. Such an anomaly, as postulated during the initial review of the IMLTR, could occur if modeling assumptions are not valid at the hard spectral conditions for MELLLA+ operation. However, such an anomaly would affect the overall transport solution methodology and would be observable in detailed TIP comparisons. Therefore, the NRC staff will revisit Limitation 5 during its review of the MELLLA+ cycle-tracking evaluation that will be provided by GEH. 4.0 CONCLUSION In Reference 18, GEH committed to revise NEDC-33173P (IMLTR) with the analysis of the new gamma scan data and sufficient reanalysis of existing data currently summarized in NEDC-32694P-A (Reference 5). The purpose of the revision was to justify the use of GEH's analytical methods in expanded operating domains, up to and including MELLLA+, without the use of the additional SLMCPR margin specified in the NRC staff's SE for the IMLTR. The NRC acknowledged the acceptability of the approach committed in Reference 18 as providing a basis to finalize the neutronic methods uncertainty qualification. With Reference 7, GEH submitted to the NRC a three-part supplement to the IMLTR documenting the analysis of bundle and pin-by-pin gamma scans, and a revision to the IMLTR removing the need for the temporary additional SLMCPR margin. GEH considers that the enclosed Supplements support the original uncertainties used in its methods. The submitted revision to the IMLTR is labeled Revision 2. Revision 1 to the IMLTR is the acceptance (-A) version of the originally approved IMLTR. No changes are being proposed in Revision 2 other than the changes supporting the removal of the additional SLMCPR margin. All other Limitations and Conditions of the Revision 1 SE remain applicable. Limitations 4 and 5 of the NRC's SE for the Methods LTR impose a 0.02 adder to the cycle-specific SLMCPR value for EPU operation and a 0.03 adder for MELLLA+ operation. GEH requested that the NRC review and approve NEDC-33173P, Supplement 2, Parts 1-3, and Revision 2, and issue a revision to the NRC staff's SE for NEDC-33173P removing Limitations 4 and 5. Based on the NRC staff's review of this supplement and revision to the IMLTR, the NRC staff approves GEH's request with one exception. Limitation 5 stipulates that for operation at MELLLA+, including operation at the EPU power levels at the achievable core flow state-point, a 0.03 value shall be added to the cycle-specific SLMCPR value. The added value of 0.03 will now be reduced to 0.01 for power-to-flow ratios up to 42 MWt/Mlbm/hr, and to 0.02 for power-to-flow ratios above 42 MWt/Mlbm/hr. This adder may be removed if GEH submits MELLLA+

I-22 operation data, subject to NRC staff review and approval. Thus, for operation at MELLLA+,

including operation at EPU power levels at the achievable core flow state-point, a 0.01 value shall be added to the cycle-specific SLMCPR value for power-to-flow ratios up to 42 MWt/Mlbm/hr, and a 0.02 value shall be added to the cycle-specific SLMCPR value for power-to-flow ratios above 42 MWt/Mlbm/hr. The NRC staff will revisit the applicability of this limitation during its review of the MELLLA+ cycle-tracking data that will be provided by GEH following the first MELLLA+ implementation for a GNF-fueled reactor.

To this end, the NRC staff has revised IMLTR SE Limitations 4 and 5 as follows without further review. Limitation 4 from the SE for the IMLTR states: For EPU operation, a 0.02 value shall be added to the cycle-specific SLMCPR value.

This adder is applicable to SLO [single loop operation], which is derived from the dual loop SLMCPR value.

On the basis of the subject review, the NRC staff finds that Supplement 2, Parts 1-3 provide the additional data and analysis needed to finalize the neutronic methods uncertainty qualification and justify GEH's original uncertainties used in its methods for EPU operation. Therefore, the NRC staff has revised Limitation 4 in Section 9.4 of the IMLTR SE as follows: This Limitation has been removed according to Appendix I of this SE. Limitation 5 from the SE for the IMLTR states:

For operation at MELLLA+, including operation at the EPU power levels at the achievable core flow state-point, a 0.03 value shall be added to the cycle-specific SLMCPR value. On the basis of the subject review, the NRC staff finds that Supplement 2, Parts 1-3 provide the additional data and analyses needed to finalize the neutronic methods uncertainty qualification and justify GEH's original uncertainties used in its methods for MELLLA+ operation, except as stated above. Therefore, the NRC staff has revised Limitation 5 in Section 9.5 of the IMLTR SE as follows:

This Limitation has been revised according to Appendix I of this SE. For operation at MELLLA+, including operation at the EPU power levels at the achievable core flow state-point, a 0.01 value shall be added to the cycle-specific SLMCPR value for power-to-flow ratios up to 42 MWt/Mlbm/hr, and a 0.02 value shall be added to the cycle-specific SLMCPR value for power-to-flow ratios above 42 MWt/Mlbm/hr.

The NRC staff reviewed IMLTR Supplement 2, Parts 1-3, and Revision 2 only insofar as it justifies revisions to Limitations 4 and 5. The NRC staff review in this matter does not impact I-23 any other aspects of the original review of the IMLTR. Therefore, all other NRC staff guidance, limitations, and conclusions documented in the SE for the IMLTR remain applicable as originally stated. 5.0 REFERENCES 1. TR NEDC-33173P-A, Revision 1, "Applicability of GE Methods to Expanded Operating Domains," dated September 2010. (ADAMS Package Accession No. ML102920129) 2. Final SE by the Office of Nuclear Reactor Regulation for NEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains," dated July 21, 2009.

(ADAMS Package Accession No. ML092020255) 3. Letter from GE Energy to NRC, MFN 06-434, "Updated Response to RAI 28-2 - NEDC-33173P (TAC No. MD0277)," dated November 22, 2006. (ADAMS Accession No. ML063350054) 4. Electric Power Research Institute Report NP-214, "Gamma Scan Measurements at Quad Cities Nuclear Power Station Unit 1 Following Cycle 2," dated July 1976. 5. TR NEDC-32694P-A, "Power Distribution Uncertainties for Safety Limit MCPR Evaluations," dated August 1999. (ADAMS Accession No. ML003740151) 6. TR NEDC-32773P, Revision 1, "Advanced Methods Power Distribution Uncertainties for Core Monitoring," dated January 1999. 7. Letter from GEH to NRC, MFN 09-552, "NEDC-33173P, Revision 2 and Supplement 2, Parts 1-3 - Analysis of Gamma Scan Data and Removal of Safety Limit Critical Power Ratio (SLMCPR) Margin," dated August 14, 2009. (ADAMS Package Accession No. ML092300242) 8. TR NEDC-33173P, Revision 2, "Applicability of GE Methods to Expanded Operating Domains," dated August 2009. (ADAMS Package Accession No. ML092300242) 9. TR NEDC-33173P, Supplement 2, Part 1, "Applicability of GE Methods to Expanded Operating Domains - Power Distribution Validation for Cofrentes Cycle 13," dated August 2009. (ADAMS Package Accession No. ML092300242) 10. TR NEDC-33173P, Supplement 2, Part 2, "Applicability of GE Methods to Expanded Operating Domains - Pin-by-Pin Gamma Scan at FitzPatrick October 2006," dated August 2009. (ADAMS Package Accession No. ML092300242) 11. TR NEDC-33173P, Supplement 2, Part 3, "Applicability of GE Methods to Expanded Operating Domains - Power Distribution Validation for Cofrentes Cycle 15," dated August 2009. (ADAMS Package Accession No. ML092300242) 12. Letter from GE to NRC, MFN 05-029, "Responses to RAIs - Methods Interim Process (TAC No. MC5780)," dated April 8, 2005. (ADAMS Package Accession No. ML051050022) 13. TR NEDC-33006P-A, Revision 3, "General Electric Boiling Water Reactor Maximum Extended Load Line Limit Analysis Plus," dated June 2009. (ADAMS Package Accession No. ML091800530) 14. Letter from GEH to NRC, MFN 10-355, "Response to Request for Additional Information Re: GE-Hitachi Nuclear Energy Americas Topical Report NEDC-33173P, Revision 2 and Supplement 2, Parts 1-3 - Analysis of Gamma Scan Data and I-24 Removal of Safety Limit Critical Power Ratio Margin (TAC No. ME1891)," dated December 17, 2010. (ADAMS Package Accession No. ML103640071) 15. Letter from GEH to NRC, MFN 10-355 Supplement 1, "Response to Supplemental Request for Additional Information Re: GE-Hitachi Nuclear Energy Americas Topical Report NEDC-33173P, Revision 2 and Supplement 2, Parts 1-3 - Analysis of Gamma Scan Data and Removal of Safety Limit Critical Power Ratio Margin (TAC No. ME1891)," dated November 16, 2011. (ADAMS Package Accession No. ML113220162) 16. TR NEDC-32601P-A, "Methodology and Uncertainties for Safety Limit MCPR Evaluations," dated August 1999. (ADAMS Accession No. ML003740145) 17. Letter from GE Nuclear Energy to NRC, MFN 04-026, "Completion of Responses to MELLLA Plus AOO RAIs (TAC No. MB6157)," dated March 4, 2004. (ADAMS Package Accession No. ML040700161) 18. Letter from GEH to NRC, MFN 06-434, "Updated Response to RAI 28-2 - NEDC-33173P (TAC No. MD0277)," dated November 22, 2006. (ADAMS Accession No. ML063350054) Principal Contributors: P. Yarsky A.C. Attard S. Philpott Date:

I-25 [

] Figure 3.1.5-1: Cofrentes Cycle 15B TIP Comparisons I-26 [

] Figure 3.2.3-1: Trends in Pin Power Differences with Axial Height NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) iii TABLE OF CONTENTS Abbreviations and Acronyms List ...................................................................................................xAbstract .......................................................................................................................................... xiRevisions ....................................................................................................................................... xii1. Introduction .............................................................................................................................. 1-11.1 Overview ......................................................................................................................... 1-11.2 Gamma Scan Measurements ........................................................................................... 1-11.3 Analysis / Comparisons .................................................................................................. 1-11.4 Nomenclature For Analysis Approaches ........................................................................ 1-22. PLANT AND FUEL DESCRIPTION ..................................................................................... 2-12.1 Bundles JLM420 And JLD505 Core Locations ............................................................. 2-12.2 Descriptions of Bundles .................................................................................................. 2-32.3 Cycle 16 Operation ......................................................................................................... 2-52.4 Cycle 17 Operation ......................................................................................................... 2-72.5 Key Operating Parameters .............................................................................................. 2-92.6 Section 2.1.1 of SE ......................................................................................................... 2-92.7 Characterization of Operating Conditions - Gamma Scan Bundles ............................. 2-102.8 Depletion History Bundles JLM420 and JLD505 ........................................................ 2-152.9 EOC17 Information ...................................................................................................... 2-193. Bundle Measurements .............................................................................................................. 3-13.1 Water Submersible Gamma Spectrometer ...................................................................... 3-13.2 Measurement Details ...................................................................................................... 3-34. Design Calculations ................................................................................................................. 4-14.1 Statistical Comparisons .................................................................................................. 4-15. Traditional Basis for Gamma Scan Comparisons .................................................................... 5-15.1 Duane Arnold Gamma Scan ........................................................................................... 5-15.2 Summary - Bundle JLM420 - Traditional Basis .......................................................... 5-25.3 Summary - Bundle JLD505 - Traditional Basis ............................................................ 5-65.4 Details of Traditional Comparisons - Nodal Depletions .............................................. 5-106. Pin Nodal, Bundle, and Axial Root Mean Square (RMS) Comparisons ................................. 6-16.1 Description of Statistics .................................................................................................. 6-36.2 Pin Nodal, Rod Averaged, and Axial Average Statistical Summary ............................. 6-46.3 Summary Plots of Pin Nodal RMS ................................................................................. 6-66.4 Summary of Rod Averaged RMS Comparisons ............................................................. 6-96.5 Summary of Axial Averaged RMS Comparisons ........................................................ 6-127. Summary of Uncertainties ....................................................................................................... 7-17.1 Pin-by-Pin Gamma Scan Impact on Uncertainties for MELLLA+ Analyses ................ 7-1 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) iv 7.2 Summary of Measured Uncertainties -Pin-by-Pin XY .................................................. 7-28. Trending and Visualization ...................................................................................................... 8-18.1 Trends in Uncertainties vs. Nodal Parameters ................................................................ 8-18.2 XYZ Plots of {(TGBLA/Meas)-1} Pin-by-Pin Errors - Bundle JLM420 ..................... 8-18.3 XYZ Plots of {(P11/Meas)-1} Pin-by-Pin Errors - Bundle JLM420 - Off-line Adaptation ..................................................................................................................... 8-78.4 XYZ Plots of {(TGBLA/Meas)-1} Pin-by-Pin Errors - Bundle JLD505 .................... 8-138.5 XYZ Plots of {(P11/Meas)-1} Pin-by-Pin Errors - Bundle JLD505 - Off-line Adaptation ................................................................................................................... 8-198.6 Potential Trends [[ ]] ................................................................................................................................ 8-259. References ................................................................................................................................ 9-1 Appendix A Off-Line Non-Adapted TIP Comparisons Appendix B GEH Responses to NRC RAIs on NEDC-33173P Revision 2 Appendix C GEH Responses to Supplemental RAIs on NEDC-33173P Revision 2 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) v LIST OF FIGURES Figure 2.1-1 TIP Locations for FitzPatrick .................................................................................. 2-2Figure 2.2-1. Description of Bundle 2794 - JLM420 ................................................................. 2-3Figure 2.2-2. Description of Bundle 2562 - JLD505 ................................................................. 2-4Figure 2.3-1. Core Bundle Type Map Cycle 16 .......................................................................... 2-6Figure 2.3-2. Power and Flow as a Function of Exposure Cycle 16 .......................................... 2-6Figure 2.4-1. Core Bundle Type Map Cycle 17 .......................................................................... 2-8Figure 2.4-2. Power and Flow as a Function of Exposure Cycle 17 .......................................... 2-8Figure 2.7-1. Maximum Bundle Power in MWt vs. Cycle 16 Exposure .................................. 2-11Figure 2.7-2. Maximum Power / Flow Ratio vs. Cycle 16 Exposure ....................................... 2-11Figure 2.7-3. Exit Void Fraction vs. Cycle 16 Exposure .......................................................... 2-12Figure 2.7-4. Peak LGHR vs. Cycle 16 Exposure .................................................................... 2-12Figure 2.7-5. Maximum Bundle Power in MWt vs. Cycle 17 Exposure .................................. 2-13Figure 2.7-6. Maximum Power / Flow Ratio vs. Cycle 17 Exposure ....................................... 2-13Figure 2.7-7. Exit Void Fraction vs. Cycle 17 Exposure .......................................................... 2-14Figure 2.7-8. Peak LGHR vs. Cycle 17 Exposure .................................................................... 2-14Figure 2.8-1. Bundle JLM420 Void Fractions and Adjacent Rod Position .............................. 2-16Figure 2.8-2. Bundle JLM420 kW/ft and Adjacent Rod Position ............................................ 2-17Figure 2.8-3. Bundle JLD505 Void Fractions and Adjacent Rod Position .............................. 2-17Figure 2.8-4. Bundle JLD505 kW/ft and Adjacent Rod Position ............................................. 2-18Figure 2.9-1 EOC17 Nodal Exposures for Bundles JLM420 and JLD505 .............................. 2-19Figure 2.9-2 EOC17 Nodal Powers for Bundles JLM420 and JLD505 ................................... 2-20Figure 2.9-3 EOC17 Nodal Void Fractions for Bundles JLM420 and JLD505 ....................... 2-20Figure 3.1-1. Components of The Water Submersible Gamma Spectrometer ........................... 3-1Figure 3.1-2. Deployment of the WSGS at FitzPatrick .............................................................. 3-2Figure 5.4.1-1. Color Code For XY Lattice Data Bundle JLM420 .......................................... 5-11Figure 5.4.1-2. Measured Normalized 140La for Bundle JLM420 (93 in. to 123 in.) ............... 5-12Figure 5.4.1-3. Measured Normalized 140La for Bundle JLM420 (27 in. to 87 in.) ................. 5-13Figure 5.4.1-4. TGBLA Predicted Normalized 140La for Bundle JLM420 (93 in. to 123 in.) . 5-14Figure 5.4.1-5. TGBLA Predicted Normalized 140La for Bundle JLM420 (27 in. to 87 in.) ... 5-15Figure 5.4.1-6. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLM420 (93 in. to 123 in.) ........ 5-16Figure 5.4.1-7. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLM420 (27 in. to 87 in.) .......... 5-17Figure 5.4.2-1. Color Code For XY Lattice Data Bundle JLD505 ........................................... 5-19Figure 5.4.2-2. Measured Normalized 140La for Bundle JLD505 (93 in. to 123 in.) ................ 5-20Figure 5.4.2-3. Measured Normalized 140La for Bundle JLD505 (27 In. to 87 In.) ................. 5-21Figure 5.4.2-4. TGBLA Predicted Normalized 140La for Bundle JLD505 (93 in. to 123 in.) .. 5-22Figure 5.4.2-5. TGBLA Predicted Normalized 140La for Bundle JLD505 (27 in. to 87 in.) .... 5-23 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) vi Figure 5.4.2-6. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLD505 (93 in. to 123 in.) ........ 5-24Figure 5.4.2-7. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLD505 (27 in. to 87 in.) .......... 5-25Figure 6.3.1-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Adapted Off-line .......................................................................................................................... 6-6Figure 6.3.2-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Off-line ...... 6-7Figure 6.3.3-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Nodal Depletions ............................................................................................................... 6-8Figure 6.4.1-1. Rod Averaged RMS for Bundle JLM420 Adapted Off-line .............................. 6-9Figure 6.4.1-2. Rod Averaged RMS for Bundle JLD505 Adapted Off-line ............................... 6-9Figure 6.4.2-1. Rod Averaged RMS for Bundle JLM420 Off-line .......................................... 6-10Figure 6.4.2-2. Rod Averaged RMS for Bundle JLD505 Off-line ........................................... 6-10Figure 6.4.3-1. Rod Averaged RMS for Bundle JLM420 Nodal Depletion ............................. 6-11Figure 6.4.3-2. Rod Averaged RMS for Bundle JLD505 Nodal Depletion ............................. 6-11Figure 6.5.1-1. Axial Averaged Predicted Ba and Measured La for Bundle JLM420 Adapted Off-line ................................................................................................................. 6-12Figure 6.5.1-2. Axial Averaged Predicted Ba and Measured La for Bundle JLD505 Adapted Off-line ................................................................................................................. 6-12Figure 6.5.2-1. Axial Averaged Predicted Ba and Measured La for Bundle JLM420 Off-line 6-13Figure 6.5.2-2. Axial Averaged Predicted Ba and Measured La for Bundle JLD505 Off-line 6-13Figure 6.5.3-1. Axial Averaged Predicted Ba and Measured La for Bundle JLM420 Nodal Depletion .............................................................................................................. 6-14Figure 6.5.3-2. Axial Averaged Predicted Ba and Measured La for Bundle JLD505 Nodal Depletion .............................................................................................................. 6-14Figure 8.2-1. {(TGBLA/Meas)-1} For Bundle JLM420 at 27 In. .............................................. 8-2Figure 8.2-2. {(TGBLA/Meas)-1} For Bundle JLM420 at 45 In. .............................................. 8-2Figure 8.2-3. {(TGBLA/Meas)-1} For Bundle JLM420 at 63 In. .............................................. 8-3Figure 8.2-4. {(TGBLA/Meas)-1} For Bundle JLM420 at 81 In. .............................................. 8-3Figure 8.2-5. {(TGBLA/Meas)-1} For Bundle JLM420 at 87 In. .............................................. 8-4Figure 8.2-6. {(TGBLA/Meas)-1} For Bundle JLM420 at 93 In. .............................................. 8-4Figure 8.2-7. {(TGBLA/Meas)-1} For Bundle JLM420 at 99 In. .............................................. 8-5Figure 8.2-8. {(TGBLA/Meas)-1} For Bundle JLM420 at 111 In. ............................................ 8-5Figure 8.2-9. {(TGBLA/Meas)-1} For Bundle JLM420 at 123 In. ............................................ 8-6Figure 8.3-1. {(P11/Meas)-1} For Bundle JLM420 at 27 In. ..................................................... 8-7Figure 8.3-2. {(P11/Meas)-1} For Bundle JLM420 at 45 In. ..................................................... 8-8Figure 8.3-3. {(P11/Meas)-1} For Bundle JLM420 at 63 In. ..................................................... 8-8Figure 8.3-4. {(P11/Meas)-1} For Bundle JLM420 at 81 In. ..................................................... 8-9Figure 8.3-5. {(P11/Meas)-1} For Bundle JLM420 at 87 In. ..................................................... 8-9Figure 8.3-6. {(P11/Meas)-1} For Bundle JLM420 at 90 In. ................................................... 8-10Figure 8.3-7. {(P11/Meas)-1} For Bundle JLM420 at 93 In. ................................................... 8-10 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) vii Figure 8.3-8. {(P11/Meas)-1} For Bundle JLM420 at 99 In. ................................................... 8-11Figure 8.3-9. {(P11/Meas)-1} For Bundle JLM420 at 102 In. ................................................. 8-11Figure 8.3-10. {(P11/Meas)-1} For Bundle JLM420 at 111 In. ............................................... 8-12Figure 8.3-11. {(P11/Meas)-1} For Bundle JLM420 at 123 In. ............................................... 8-12Figure 8.4-1. {(TGBLA/Meas)-1} For Bundle JLD505 at 27 In. ............................................. 8-14Figure 8.4-2. {(TGBLA/Meas)-1} For Bundle JLD505 at 45 In. ............................................. 8-14Figure 8.4-3. {(TGBLA/Meas)-1} For Bundle JLD505 at 63 In. ............................................. 8-15Figure 8.4-4. {(TGBLA/Meas)-1} For Bundle JLD505 at 81 In. ............................................. 8-15Figure 8.4-5. {(TGBLA/Meas)-1} For Bundle JLD505 at 87 In. ............................................. 8-16Figure 8.4-6. {(TGBLA/Meas)-1} For Bundle JLD505 at 93 In. ............................................. 8-16Figure 8.4-7. {(TGBLA/Meas)-1} For Bundle JLD505 at 99 In. ............................................. 8-17Figure 8.4-8. {(TGBLA/Meas)-1} For Bundle JLD505 at 111 In. ........................................... 8-17Figure 8.4-9. {(TGBLA/Meas)-1} For Bundle JLD505 at 123 In. ........................................... 8-18Figure 8.5-1. {(P11/Meas)-1} For Bundle JLD505 at 27 In. .................................................... 8-19Figure 8.5-2. {(P11/Meas)-1} For Bundle JLD505 at 45 In. .................................................... 8-20Figure 8.5-3. {(P11/Meas)-1} For Bundle JLD505 at 63 In. .................................................... 8-20Figure 8.5-4. {(P11/Meas)-1} For Bundle JLD505 at 81 In. .................................................... 8-21Figure 8.5-5. {(P11/Meas)-1} For Bundle JLD505 at 87 In. .................................................... 8-21Figure 8.5-6. {(P11/Meas)-1} For Bundle JLD505 at 90 In. .................................................... 8-22Figure 8.5-7. {(P11/Meas)-1} For Bundle JLD505 at 93 In. .................................................... 8-22Figure 8.5-8. {(P11/Meas)-1} For Bundle JLD505 at 99 In. .................................................... 8-23Figure 8.5-9. {(P11/Meas)-1} For Bundle JLD505 at 102 In. .................................................. 8-23Figure 8.5-10. {(P11/Meas)-1} For Bundle JLD505 at 111 In. ................................................ 8-24Figure 8.5-11. {(P11/Meas)-1} For Bundle JLD505 at 123 In. ................................................ 8-24Figure 8.6-1. {(P11/Meas)-1} vs. [[ ]] ................................................................................................................. 8-26Figure 8.6-2. {(P11/Meas)-1} vs. [[ ]] ................................................................................................................... 8-26Figure 8.6-3. {(P11/Meas)-1} vs. [[ ]] ................................................................................................................. 8-27Figure 8.6-4. {(P11/Meas)-1} vs. [[ ]] ....................................................................................................................... 8-27Figure 8.6-5 [[ ]] ................................................................. 8-28Figure A.1-1. Cycle 17 TIP RMS Values .................................................................................. A-2Figure A.2-1. Axial Average TIP Comparison at 2288 MWd/ST ............................................. A-3Figure A.2-2. Individual TIP Comparisons At 2288 MWd/ST ................................................. A-3Figure A.2-3. Axial Average TIP Comparison at 4210 MWd/ST ............................................. A-4Figure A.2-4. Individual TIP Comparisons At 4210 MWd/ST ................................................. A-4Figure A.2-5. Axial Average TIP Comparison at 7838 MWd/ST ............................................. A-5 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) viii Figure A.2-6. Individual TIP Comparisons At 7838 MWd/ST ................................................. A-5Figure A.2-7. Axial Average TIP Comparison at 9735 MWd/ST ............................................. A-6Figure A.2-8. Individual TIP Comparisons At 9735 MWd/ST ................................................. A-6Figure A.2-9. Axial Average TIP Comparison at 11160 MWd/ST ........................................... A-7Figure A.2-10. Individual TIP Comparisons At 11160 MWd/ST ............................................. A-7Figure A.2-11. Axial Average TIP Comparison at 11753 MWd/ST ......................................... A-8Figure A.2-12. Individual TIP Comparisons At 11753 MWd/ST ............................................. A-8Figure A.2-13. Axial Average TIP Comparison at 13472 MWd/ST ......................................... A-9Figure A.2-14. Individual TIP Comparisons At 13472 MWd/ST ............................................. A-9Figure A.2-15. Axial Average TIP Comparison at 15754 MWd/ST ....................................... A-10Figure A.2-16. Individual TIP Comparisons At 15754 MWd/ST ........................................... A-10 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) ix LIST OF TABLES Table 2.1-1 Bundle Locations in Cycles 16 and 17 .................................................................... 2-1Table 2.3-1 Bundle Inventory Cycle 16 ...................................................................................... 2-5Table 2.4-1 Bundle Inventory Cycle 17 ...................................................................................... 2-7Table 2.8-1 Maximum Values in Cycles 16 and 17 .................................................................. 2-16Table 5.1-1 Duane Arnold Gamma Scan Results ........................................................................ 5-1Table 5.2-1 Results for Adapted Off-line - Bundle JLM420 ..................................................... 5-3Table 5.2-2 Results for Non-Adapted Off-line - Bundle JLM420 ............................................. 5-4Table 5.2-3 Results for TGBLA06 Nodal Depletions - Bundle JLM420 .................................. 5-5Table 5.3-1 Results for Adapted Off-line - Bundle JLD505 ...................................................... 5-7Table 5.3-2 Results for Non-Adapted Off-line - Bundle JLD505 .............................................. 5-8Table 5.3-3 Results for TGBLA06 Nodal Depletions - Bundle JLD505 ................................... 5-9Table 6.0-1 Number of Measurements ....................................................................................... 6-2Table 6.2-1. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary - Adapted Off-line .......................................................................................................................... 6-5Table 6.2-2. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary Off-line ....... 6-5Table 6.2-3. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary - Nodal Depletions ............................................................................................................... 6-5Table 7.1-1 Components of Pin Power Peaking Uncertainty ..................................................... 7-1Table 7.2-1 Comparisons of Pin Power Peaking Measurement Statistics .................................. 7-2Table A.1-1 Cycle 17 Non-Adapted TIP Sets ........................................................................... A-2 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) x ABBREVIATIONS AND ACRONYMS LIST Term Definition BAZ Bottom of the Active (Fuel) Zone BOC Beginning of Cycle BOP Balance of Plant BTU British Thermal Unit BWR Boiling Water Reactor CFR Code of Federal Regulations CPR Critical Power Ratio CR Control Rod EOC End of Cycle Exp Exposure FW Feedwater GE General Electric Company GEH GE Hitachi Nuclear Energy GENE GE Nuclear Energy GETAB General Electric Thermal Analysis Basis GNF Global Nuclear Fuel LHGR Linear Heat Generation Rate LPRM Local Power Range Monitor LTR Licensing Topical Report MAPLHGR Maximum Average Planar Linear Head Generation Rate MAPRAT Maximum Average Planar Ratio MCPR Minimum Critical Power Ratio Meas Measured MLHGR Maximum Linear Heat Generation Rate MOC Middle of Cycle NN Narrow-Narrow (Corner of the fuel lattice most distant from control rod) NRC Nuclear Regulatory Commission (USA) OLMCPR Operating Limit Minimum Critical Power Ratio OLMLHGR Operating Limit Minimum Linear Heat Generation Rate RMS Root Mean Square RPS Reactor Protection System RTP Rated Thermal Power S.E. Safety Evaluation SLMCPR Safety Limit Minimum Critical Power Ratio SRSS Square Root of the Sum of Squares TIP Traversing In-core Probe USNRC United States Nuclear Regulatory Commission Wt Weight WW Wide-Wide (Closest corner of the fuel lattice to the control rod)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) xi ABSTRACT Gamma scan is a non-destructive method to determine the relative fission product inventory in nuclear fuel. A pin-by-pin gamma scan on two GE14 10x10 fuel assemblies was completed in 2006 at the James A. FitzPatrick nuclear power station. The agreement between the measurements and predictions using the TGBLA06 lattice physics code and the PANAC11 BWR core simulator is excellent, with pin-by-pin RMS errors less than [[ ]]. The data validate the applicability of lattice power distribution uncertainties for modern BWR core and fuel designs, as well as for current operational strategies.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) xii REVISIONS Revision Description of Change 0 Original document 1 -A Version As shown below, numerous changes were made, consistent with commitments made in the RAI response package for NEDC-33173P Revision 2 and Supplement 2 Parts 1 - 3. During the review as part of the RAI response process, a number of conservative inputs in various spreadsheets used to produce the statistics and plots in Supplement 2 Part 2 were identified. For internal consistency, the affected portions of the LTR were updated and revised. Figure 2.1-1: Added a new figure showing TIP locations. (RAI 5) Figures 2.2-1 and 2.2-2: Corrected figure numbers. Section 2.7: Added Cycle 16 information; changed Cycle 7 to Cycle 17. (RAI 7 and 8) Figures 2.7-1 through 2.7-4: Added new Cycle 16 information plots. (RAI 7) Figures 2.9-1, 2.9-2, and 2.9-3: Modified to include all 11 measurement points. Figure 3.2-1: Added this figure showing locations of spacers and fuel rods. (RAI 5) Table 5.1-1: Revised the corrected standard deviation at 57 inches from the bottom of the active fuel zone. (See Note Below) Revised Tables 5.2-1, 5.2-2, 5.3-1, and 5.3-2. Table 5.2-3: Revised the standard deviation and the corrected standard deviation for Node 19, which resulted in a revision to the average corrected standard deviation. (See Note Below) Figures 5.4.1-1 and 5.4.2-1: Added the bundle identifier to the figure title. (See Note Below) Figure 5.4.1-2: Replaced in response to revised data for Elevation 111 inches. Figure 5.4.1-6: Replaced with a new figure.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) xiii Figures 5.4.2-4 through 5.4.2-7: Revised to correctly reflect input. Sections 6 and 6.1: Clarified equations for statistics. (RAI 9) Section 6.2: Changed the range for pin nodal RMS for gamma scan. Revised Tables 6.2-1, 6.2-2, 6.2-3, and 7.2-1. Sections 6.3.1 and 6.3.2: Revised the RMS value in the second paragraph. Revised Figures 6.3.1-1, 6.3.2-1, 6.3.3-1, 6.4.1-1, 6.4.1-2, 6.4.2-1, 6.4.2-2, 6.5.1-1, 6.5.1-2, 6.5.2-1, and 6.5.2-2. Sections 6.4.1, 6.4.2, 6.5.1, and 6.5.2: Revised the RMS values. Figure 6.4.3-2: Revised for readability. Section 7.2: Text added to second paragraph. (RAI 9) Figures 8.2-1 through 8.3-11: Revised or added. Sections 8.4 and 8.5: Added these new sections for Bundle JLD505. (RAI 13) Figures 8.6-1 through 8.6-4: Revised figure numbers. Section 8.6.1: Added new information. (RAI 15) Section A.1: Added new third paragraph. (RAI 18) Note: These changes were not included in the previous submittal and were noticed during the verification of the final -A report. In two cases, the changes reflect minor differences in the standard deviation in Tables 5.1-1 and 5.2-3. These changes do not affect the average standard deviation in Table 5.1-1 and result in a reduction in the average standard deviation in Table 5.2-3. The other changes represent clarification of figure titles by adding the specific bundle identifier.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 1-1 1. INTRODUCTION 1.1 OVERVIEW Power distribution validation data for operating boiling water reactors is routinely taken in the form of traversing in-core probe (TIP) measurements. In this case, the average power of the four bundles surrounding the instrument tube is detected via a neutron sensitive or gamma sensitive detector. For potentially greater resolution and at greater effort and cost, gamma scanning is an independent, non-destructive method to determine the relative fission product inventory in nuclear fuel. Gamma scan measurements for the purpose of power distribution validation may be made on either bundle average or pin-by-pin measurements. The subject of this document is pin-by-pin gamma scan measurements made at the FitzPatrick nuclear power station in October of 2006 at the end of cycle 17 (EOC17). Two bundles were scanned. The first, JLM420, was a GE14 once-burnt fuel assembly originally loaded at beginning of Cycle 17 (BOC17). The second, JLD505, was a twice-burnt GE14 fuel assembly, originally loaded at BOC16. For each bundle, the bundle upper tie plate was removed and individual fuel pins transferred to the water submersible gamma spectrometer located in the spent fuel pool for measurement. The fuel assembly was then reassembled. Subsequently, the once-burnt GE14 bundle, JLM420, was re-loaded into the core during the outage. The comparison of the data obtained from these gamma scans with GNF methods show that the differences are well within the uncertainties employed in the determination of the BWR SLMCPR. 1.2 GAMMA SCAN MEASUREMENTS Gamma scan programs vary by specification of the physical locality of the measurement, time of performing the measurement, measuring time, and number of measurements. For example, the technique for measurements of "power" calls for detection of the 1.6 MeV gamma ray that accompanies beta decay of 140La with a half-life of 40.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 140La accumulates in fuel mainly from the beta decay of the fission product 140Ba that has a half-life of 12.8 days. After about 10 days following reactor shutdown, 140La atom density is proportional to the 140Ba atom density and decays with the 140Ba half-life. The 140Ba distribution in fuel is characteristic of the fission distribution or integrated power history over the last 5 half-lives, or approximately 60-120 days of reactor operation. Thus, the scan results can be used to determine "recent" core power distribution. The 12.8 day half-life of 140Ba also makes it imperative that the gamma scan data be collected as soon as possible after core shutdown, usually during refueling operations, since bundles with powers of interest are normally reinserted for additional use. Spectral lines from other isotopes may be measured using specific techniques and target fuel conditions for the determination of plenum fission gas (85Kr) and/or fuel exposure (137Cs/144Pr). However, power comparisons are the sole subject of this report. 1.3 ANALYSIS / COMPARISONS A follow-on comparison of the measured 140Ba distribution with predictions using the analytical tools of GNF (i.e., TGBLA/PANACEA) constitutes a validation of methods that may be used for NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 1-2 methods licensing or determination of other licensing uncertainties. The "Improved Steady-State Methods," also known as TGBLA06 / PANAC11, for core design, licensing, and core monitoring (Reference [1]) are the current GNF methods; this methodology is examined in this report. The general procedure used to compare to the measured gamma scan data includes the following elements. First, the power/flow history of the core is input to the nodal simulator. During this process, the TIP predictions from the core tracking may be compared to the measured TIP response for the first phase of the power distribution validation process. The second step is to integrate the power history over the last 60-120 days of operation to generate the predicted nodal relative and pin-by-pin 140Ba concentrations. The final step is to statistically compare the experimental and predicted 140Ba predictions and explain the relationships on a bundle, nodal, and axial statistical basis. This process may also be repeated using the measured 6 inch average TIP readings that may be input to the adaptive methodology described in References [2] and [3] for consistent confirmation of SLMCPR uncertainties. 1.4 NOMENCLATURE FOR ANALYSIS APPROACHES This document provides summaries of the comparisons of design calculations of 140Ba with measured 140La as a means of demonstrating the GNF capabilities for calculating nodal pin powers. There are three analytic approaches summarized herein for predicting the pin-by-pin 140Ba. These three approaches are: The standard off-line TGBLA06 / PANAC11 non-adapted models used in GNF applications for reload design and licensing (referred to as "off-line"); The standard on-line TGBLA06 / PANAC11 application used in 3DMonicoreTM with TIP and LPRM shape adaptation for on-line monitoring. The on-line process can be re-run off-line by supplying the TIP and LPRM data that allows the adaptation process to be re-created off-line (referred to as "adapted off-line"); and also The use of the lattice code TGBLA06 for nodal depletions, where the operating conditions provided as inputs to the lattice code are derived from the off-line non-adapted (referred to as "nodal depletion").

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-1 2. PLANT AND FUEL DESCRIPTION Entergy Corporation's 852 MWe James A. FitzPatrick nuclear power station, which entered service in 1976, is located on the shore of Lake Ontario in the town of Scriba in Oswego County, about 90 miles east of Rochester, New York. The FitzPatrick reactor is a high power density (51.2 kW/l) D-Lattice BWR/4 with 560 fuel assemblies that operated at 100% of the current licensed thermal power for most of Cycles 16 and 17, using a power coast-down for cycle extension at the end of both cycles. The original licensed power level was 2436 MWt; the current licensed power level is 2536 MWt, a 4.1% increase. The cycle 16 core was composed of a fairly homogeneous loading of GE12 and GE14 fuel assemblies. These GE 10x10 product lines include part length rods. The reload fuel assemblies in Cycle 17 were 10x10 GE14 product line, replacing more of the 10x10 GE12 fuel assemblies. 2.1 BUNDLES JLM420 AND JLD505 CORE LOCATIONS Table 2.1-1 summarizes general information regarding the two bundles that were disassembled, gamma scanned, and then reassembled. The once-burnt bundle JLM420 was reinserted into the core at the completion of the gamma scan measurements. More information regarding the bundle designs for these bundles is provided in the following two sub-sections. Table 2.1-1 Bundle Locations in Cycles 16 and 17 Bundle ID IAT Type Bundle Name Cycle 16 Location Site Coordinates Cycle 16 Location PANACEA Coordinates EOC16 Exposure GWd/ST EOC16 Exposure GWd/MT JLD505 19 [[ ]] [23-38] (12,8) 19.4 21.38 Bundle ID IAT Type Bundle Name Cycle 17 Location Site Coordinates Cycle 17 Location PANACEA Coordinates EOC17 Exposure GWd/ST EOC17 Exposure GWd/MT JLM420 1 [[ [11-22] (06,16) 20.42 22.51 JLD505 19 ]] [25-32] (13,11) 38.1 42.00 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-2 Figure 2-1 provides the locations of the TIP strings in FitzPatrick, with each TIP instrument tube identified by the TIP string number. The TIP string is located at the bottom, right hand corner of the bundle with the TIP string number. Note that the four bundle cells highlighted are the four bundle cell surrounding the TIP string, and do not identify the four bundles around a control rod. The TIP locations do not change between cycles; the locations of the bundles scanned in Cycles 16 and 17 are identified by the same coloring scheme used in Sections 2.3 and 2.4 below. Note that JLD505 is not adjacent to an instrument tube in either Cycle 16 or 17, while JLM420 is adjacent to an instrument tube in Cycle 17. 12345678910111213141516171819202122232425261522503484272829303146544642740JLD505 in Cycle 16821222324252638JLD505 in Cycle 17936JLM420 in Cycle 1710341132121516171819203013281426152416910111213142217201818191620456781421122210230824123062504260213579111315171921232527293133353739414345474951 Figure 2.1-1 TIP Locations for FitzPatrick NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-3 2.2 DESCRIPTIONS OF BUNDLES [[ ]] Figure 2.2-1. Description of Bundle 2794 - JLM420 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-4 [[ ]] Figure 2.2-2. Description of Bundle 2562 - JLD505 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-5 2.3 CYCLE 16 OPERATION Cycle 16 started on 10/30/2002 and ended 09/24/2004. The inventory of fuel in the core is provided in Table 2.3-1. The location of bundle JLD505 in Cycle 16 is provided in Figure 2.3-1. A series of 79 off-line core-tracking cases deplete the core to the cycle average exposure of 14,994.87 MWd/ST at End of Cycle 16 (EOC16). At the end of the cycle, there were two blades at notch 00, and two at notch 16. These control blades were located asymmetrically in the core. Figure 2.3-2 provides the power and flow conditions for Cycle 16. Table 2.3-1 Bundle Inventory Cycle 16 Bundle Name IAT # in Core #Fresh Avg Exp GWd/ST 13 2 0 27.40 14 82 0 31.59 15 84 0 31.91 16 56 0 18.33 17 132 0 18.18 18 8 0 13.93 19 120 120 0.00 20 76 76 0.00 Total 560 0 15.83 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-6 Figure 2.3-1. Core Bundle Type Map Cycle 16 Figure 2.3-2. Power and Flow as a Function of Exposure Cycle 16 7075808590951001051100200040006000800010000120001400016000Cycle Exposure, MWd/ST% Power or FlowPower %Flow %1234567891011121314151617181920212223242526114151514141414151514522Bundle IAT15141614161717161416151550315151513171717171414171717171415151448415151617182020202017172020202018171615154651415171720202017201719191720172020201717151444615161720172016191619141419161916201720171615427151720171915191619171919171916191519172017154081514182020151916191419171719141916191520201814153891415172020161916191419171919171914191619162020171514361015161720171916191419171915151917191419161917201716153411151417202016191419171915191915191719141916202017141532121416172017191719171915191717191519171917191720171614301314171417191419171915191714141719151917191419171417142814141714171914191719151917141417191519171914191714171426151416172017191719171915191717191519171917191720171614241615141720201619141917191519191519171914191620201714152217151617201719161914191719151519171914191619172017161520181415172020161916191419171919171914191619162020171514181915141820201519161914191717191419161915202018141516201517201719151916191719191719161915191720171514211516172017201619161914141916191620172017161512221415171720202017201719191720172020201717151410231515161718202020201717202020201817161515082414151514171717171414171717171315151506251515161416171716141614150426141515141414141515140213579111315171921232527293133353739414345474951 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-7 2.4 CYCLE 17 OPERATION Cycle 17 started on 11/01/2004 and ended 10/08/2006. The inventory of fuel in the core is provided in Table 2.4-1. The location of bundles JLD505 and JLM420 in Cycle 17 are provided in Figure 2.4-1. A series of 79 off-line core-tracking cases deplete the core to a cycle average exposure of 15,754.33 MWd/ST at EOC17. At the end of the cycle, all control blades were withdrawn. Figure 2.4-2 provides the power and flow conditions for Cycle 17. TIP comparisons of the off-line non-adapted model with the measured TIPs are provided in Appendix A. Table 2.4-1 Bundle Inventory Cycle 17 Bundle Name IAT # in Core #Fresh Avg Exp GWd/ST 1 180 180 0.00 2 24 24 0.00 16 40 0 32.07 17 112 0 33.27 18 8 0 29.18 19 120 0 19.48 20 76 0 18.10 Total 560 204 15.99 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-8 Figure 2.4-1. Core Bundle Type Map Cycle 17 Figure 2.4-2. Power and Flow as a Function of Exposure Cycle 17 70.0075.00 80.0085.0090.0095.00100.00105.00110.00020004000600080001000012000140001600018000Cycle Exposure MWd/ST% Power or FlowPower %Flow %1234567891011121314151617181920212223242526117171717171717171717522Bundle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he Safety Evaluation (SE) by the NRC that covers the Licensing Topical Report NEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains,", Reference [8], discusses "Key Operating Parameters" in Section 2.1.1 of the SE. A portion of this section is paraphrased below. 2.6 SECTION 2.1.1 OF SE The core thermal-hydraulic conditions for operation at EPU and MELLLA+ can be measured by review of the following key parameters: (1) Power of Peak Bundle The bundle power (in MW) is a fundamental direct input to the critical power ratio (CPR) safety parameter calculation, the linear heat generation rate (LHGR), the initial conditions for loss-of-coolant accident (LOCA) response, and the calculation of other intermediate quantities. It represents a local metric of operating conditions and is relevant particularly to the performance of the steady-state nuclear methods. (2) Coolant Flow for Peak Bundle The active bundle flow (in Mlbm/hr) is also a direct input to the calculation of the CPR safety parameter, as well as other intermediate quantities. (3) Exit Void Fraction for Peak Power Bundle The void fraction results from the integration of the bundle power and flow, as well as the axial distribution of power deposition along the bundle. (4) Maximum Channel Exit Void Fraction The peak power bundle (hot channel) may not always coincide with the bundle with the highest channel exit void fraction, since this parameter is based not only on total bundle power, but also on bundle flow. (5) Core Average Exit Void Fraction The core average exit void fraction is a core-wide metric on the amount of heat being carried by the coolant. (6) Peak LHGR The peak LHGR (in kW/ft) is a reasonable measure of degree of peaking in the core since it is comprised of the combination of radial, axial, and local (pin) power peaking. It is also a key design constraint and monitoring parameter. (7) Peak Nodal or Pin Exposure The nodal and pellet exposures are determined by integration of the energy extracted from the local physical area of the fuel given its original specific mass.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-10 2.7 CHARACTERIZATION OF OPERATING CONDITIONS - GAMMA SCAN BUNDLES The purpose for this section is to characterize some of the operating parameters for the bundles used in the FitzPatrick gamma scan. The following information is based on the non-adapted off-line core tracking. Figure 2.7-1. provides information regarding the bundle power (expressed in MWt) as a function of Cycle 16 exposure. Figure 2.7-2. provides information regarding the ratio (bundle power in MWt) / (bundle flow in lb/hr) as a function of Cycle 16 exposure. Figure 2.7-3. provides information regarding the exit void fraction for the two gamma scan fuel assemblies as a function of Cycle 16 exposure. Figure 2.7-4. provides information regarding the bundle peak Linear Heat Generation Rate (LHGR) in kW/ft as a function of Cycle 16 exposure. The LHGR limit is a function of nodal exposure. The kW/ft at the node of Maximum Fraction of Limiting Power Density (MFLPD) is plotted as well as the peak kW/ft for the core and the maximum kW/ft for each of the two gamma scanned fuel bundles. Figure 2.7-5. provides information regarding the bundle power (expressed in MWt) as a function of Cycle 17 exposure. Figure 2.7-6. provides information regarding the ratio (bundle power in MWt) / (bundle flow in lb/hr) as a function of Cycle 17 exposure. Figure 2.7-7. provides information regarding the exit void fraction for the two gamma scan fuel assemblies as a function of Cycle 17 exposure. Figure 2.7-8. provides information regarding the bundle peak Linear Heat Generation Rate (LHGR) in kW/ft as a function of Cycle 17 exposure. The LHGR limit is a function of nodal exposure. The kW/ft at the node of Maximum Fraction of Limiting Power Density (MFLPD) is plotted as well as the peak kW/ft for the core and the maximum kW/ft for each of the two gamma scanned fuel bundles.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-11 [[ ]] Figure 2.7-1. Maximum Bundle Power in MWt vs. Cycle 16 Exposure [[ ]] Figure 2.7-2. Maximum Power / Flow Ratio vs. Cycle 16 Exposure NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-12 [[ ]] Figure 2.7-3. Exit Void Fraction vs. Cycle 16 Exposure [[ ]] Figure 2.7-4. Peak LGHR vs. Cycle 16 Exposure NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-13 [[ ]] Figure 2.7-5. Maximum Bundle Power in MWt vs. Cycle 17 Exposure [[ ]] Figure 2.7-6. Maximum Power / Flow Ratio vs. Cycle 17 Exposure NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-14 [[ ]] Figure 2.7-7. Exit Void Fraction vs. Cycle 17 Exposure [[ ]] Figure 2.7-8. Peak LGHR vs. Cycle 17 Exposure NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-15 2.8 DEPLETION HISTORY BUNDLES JLM420 AND JLD505 Bundle JLM420 was loaded in PANACEA location (06,16) in Cycle 17. At the end of cycle 17: The Cycle incremental exposure was 15,754.3 MWd/ST. The bundle average exposure for bundle JLM420 was 20,736.5 MWd/ST. The maximum nodal exposure seen on this bundle was [[ ]] MWd/ST. Bundle JLD505 was loaded in PANACEA location (12,08) in Cycle 16 and in (13,11) in Cycle 17. At the end of cycle 17: The Cycle incremental exposure was 15,754.3 MWd/ST. The bundle average exposure for bundle JLD505 was 38,119.4 MWd/ST. The maximum nodal exposure seen on this bundle was [[ ]] MWd/ST. The maximum values seen in power and void fraction are summarized in Table 2.8-1. (These values are the maximum value seen in any of the off-line non-adapted core tracking cases, for Cycle 17 for JLM420 and for Cycles 16 and 17 for bundle JLD505). The bundle average void fraction and the void fraction in the top node are provided in the following four figures: Figure 2.8-1. Bundle JLM420 Void Fractions and Adjacent Rod Position Figure 2.8-2. Bundle JLM420 kW/ft and Adjacent Rod Position Figure 2.8-3. Bundle JLD505 Void Fractions and Adjacent Rod Position Figure 2.8-4. Bundle JLD505 kW/ft and Adjacent Rod Position Note that the "Max Nodal Power Density" and "Max Bundle kW/ft" values in these figures are specifically those for the nodes at which gamma scan measurements were made.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-16 Table 2.8-1 Maximum Values in Cycles 16 and 17 Bundle Core Average Power Density kW/L Max Nodal Power Density kW/L (1) Max Bundle Average Void Fraction Max Exit Void Fraction Max Bundle kW/ft (1) Max Bundle Radial Power Peaking JLM420 51.2 [[ ]] JLD505 51.2 [[ ]] (1) Maximum Value Seen for Gamma Scanned Bundles [[ ]] Figure 2.8-1. Bundle JLM420 Void Fractions and Adjacent Rod Position NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-17 [[ ]] Figure 2.8-2. Bundle JLM420 kW/ft and Adjacent Rod Position [[ ]] Figure 2.8-3. Bundle JLD505 Void Fractions and Adjacent Rod Position NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-18 [[ ]] Figure 2.8-4. Bundle JLD505 kW/ft and Adjacent Rod Position NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-19 2.9 EOC17 INFORMATION The following plots provide insights as to the nodal exposure, nodal power, and nodal void fractions seen at EOC17: Figure 2.9.1. EOC17 Nodal Exposures for Bundles JLM420 and JLD505 Figure 2.9.2. EOC17 Nodal Powers for Bundles JLM420 and JLD505 Figure 2.9.3. EOC17 Nodal Void Fractions for Bundles JLM420 and JLD505 Vertical red lines denote the axial heights at which gamma scan measurements were made. [[ ]] Figure 2.9-1 EOC17 Nodal Exposures for Bundles JLM420 and JLD505 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 2-20 [[ ]] Figure 2.9-2 EOC17 Nodal Powers for Bundles JLM420 and JLD505 [[ ]] Figure 2.9-3 EOC17 Nodal Void Fractions for Bundles JLM420 and JLD505 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 3-1 3. BUNDLE MEASUREMENTS 3.1 WATER SUBMERSIBLE GAMMA SPECTROMETER The Water Submersible Gamma Spectrometer (WSGS) measures gamma emissions from individual irradiated fuel rods or individual irradiated fuel bundles in the plant spent fuel pool. Figure 3.1-1 identifies the various components of the WSGS, while Figure 3.1-2 shows the WSGS deployed in the FitzPatrick spent fuel pool. Figure 3.1-1. Components of The Water Submersible Gamma Spectrometer NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 3-2 Figure 3.1-2. Deployment of the WSGS at FitzPatrick NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 3-3 3.2 MEASUREMENT DETAILS For the once-burnt bundle JLM420, measurements at 11 axial elevations for [[ ]] different fuel rods were made. Multiple measurements were made on the "reference" rod and on the "weak" rod. A total of [[ ]] separate rod measurements were made. For the reference rod, including four measurements for potential azimuthal dependencies in the measurements, a total of [[ ]] rod measurements were made. There were also [[ ]] measurements of the weak rod. [[ ]] For the twice-burnt bundle JLD505, again measurements at 11 axial elevations for [[ ]] different fuel rods were planned, for a total of [[ ]] separate rod measurements had been made on [[ ]] rods. By the end of the campaign, [[ ]] rod measurements had been made because of the need to repeat measurements that had larger experimental counting uncertainties. The first [[ ]] measurements were made with identical conditions to JLM420; with the exception of new calibrations used with a new detector. After the first [[ ]] measurements, experimental difficulties were compensated for with a slight reconfiguration of the scanner while maintaining reference rod repeat measurements. [[ ]]. Figure 3.2-1 provides a graphical description of the measurement heights with respect to spacers and rod lengths. [[ ]] Figure 3.2-1 Locations of Spacers and Axial Measurement Points NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 4-1 4. DESIGN CALCULATIONS This document provides summaries of the comparisons of design calculations of 140Ba with measured 140La as a means of demonstrating the GNF capabilities for calculating nodal pin powers. There are three analytic approaches summarized herein for predicting the pin-by-pin 140Ba. These include: The standard off-line TGBLA06 / PANAC11 non-adapted models used in GNF applications for reload design and licensing (off-line); The standard on-line TGBLA06 / PANAC11 application used in 3DMonicoreTM with TIP and LPRM shape adaptation for on-line monitoring (adapted off-line); and also The use of the lattice code TGBLA06 for nodal depletions, where the operating conditions provided as inputs to the lattice code are derived from the off-line non-adapted (nodal depletions). For the first two analytic approaches, the pin-by-pin power distributions from the PANAC11 core tracking are post processed to produce the pin-by-pin 140Ba distributions as described in Section 4.1 of Reference [4]. In the third approach, the pin-by-pin 140Ba distributions are obtained directly from the pin-by-pin depletions in the lattice code TGBLA06. 4.1 STATISTICAL COMPARISONS Comparisons between the (normalized) predicted 140Ba pin-by-pin distributions with the (normalized) measured 140La distributions demonstrate that the uncertainties in the predictions are significantly less than the uncertainties used for pin-by-pin power distributions in the GNF calculation process used in support of licensing calculations.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-1 5. TRADITIONAL BASIS FOR GAMMA SCAN COMPARISONS In previous GE pin-by-pin Gamma scans, repeat measurements on a reference rod during the course of the experiment were used as a statistical approach to include an evaluation of the uncertainty in the measurements to correct the measured standard deviation. This section provides comparisons of the FitzPatrick measurements to design calculations using this "traditional" approach. Section 6 will use alternate statistical presentation more in line with that used for TIP comparisons. 5.1 DUANE ARNOLD GAMMA SCAN The most recent GE system gamma scan was performed at the Duane Arnold site in 1987. Individual pin-by-pin gamma scans were performed on a "1984 Lead Test Assembly", an 8x8 bundle with four part length rods. The statistical analysis is based on calculating the value of {(predicted / measured)-1} and then forming the standard deviation of this value. In this traditional process, the pin-by-pin values for each axial plane are separately normalized to an average value of 1.0. A series of repeat measurements of a "Reference Rod" at each axial elevation provides information regarding the uncertainty of the measurement process (termed "Measurement Reproducibility"). Table 5.1-1 summarizes the Duane Arnold gamma scan. The [[ ]] standard deviation value provides a reasonable target for the current gamma scan campaign; the intent of the current campaigns is to validate the pin power uncertainties used in the SLMCPR Limit evaluation process. [[ ]] Table 5.1-1 Duane Arnold Gamma Scan Results Height from BAZ Std Dev (TGBLA/Meas)-1 (Comparison Std Dev) Std Dev Measurement Reproducibility Corrected Std Dev [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-2 5.2 SUMMARY - BUNDLE JLM420 - TRADITIONAL BASIS For the once-burnt bundle JLM420, measurements at 11 axial elevations for [[ ]] different fuel rods were made. Multiple measurements were made on the "reference" rod and on the weak rod. There are a number of potential comparisons to design tools that are possible. Pin-by-pin measurements of 140La at multiple axial heights are made. The design tools are then used to predict the Barium distribution, and the measured and predicted distributions are compared. The first set of comparisons use the PANAC11 and post-processing programs to predict the pin-by-pin Barium distributions. Within this context, there are various models that might be used within this combination of programs. These include two modes of PANACEA usage: (a) non-adapted off-line PANAC11, (b) TIP and LPRM shape adapted (on-line) PANAC11; both of these models use pin power reconstructed local peaking. A third option is to compare to detailed lattice depletions, where the depletion conditions are taken from the 3D PANAC11 core tracking. The pin-by-pin comparison statistics can be organized by treating (i.e., normalizing) each X-Y plane of the fuel assembly individually (similar to the calculation of local peaking in the infinite lattice TGBLA06 calculation), or by normalizing to the full set of measured data. In the summary tables in this section, the standard deviation of the quantity {(Predicted 140Ba / Measured 140La) -1} is reported, corrected for the measurement reproducibility of the reference rod ([[ ]]). The traditional measure has been the standard deviation normalized to each X-Y plane; a value of [[ ]] is comparable to the best of the historical pin-by-pin gamma scan measurements. Comparisons for bundle JLM420 are summarized in the following tables. Note that BAZ is the Bottom of the Active Zone. Results for Bundle JLM420 are provided in the following tables: Table 5.2-1 Results for Adapted Off-line - Bundle JLM420 Table 5.2-2 Results for Non-Adapted Off-line - Bundle JLM420 Table 5.2-3 Results for TGBLA06 Nodal Depletions - Bundle JLM420 The results for the non-adapted core tracking are remarkably similar to the adapted off-line cases. This is of course because the effects of the axial shape differences are removed by the application of the traditional comparison process. Note that the number of axial nodes considered for the nodal depletion cases (nine) is smaller than considered for the PANAC11 adapted and non-adapted cases. (The two averaged nodes were not considered in the TGBLA06 analysis).

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-3 Table 5.2-1 Results for Adapted Off-line - Bundle JLM420 Height from BAZ (in.) Std Dev {(P11/Meas)-1} (Comparison Std Dev) Std Dev of [[ ]] Measurements of Rod [[ ]] (Measurement Reproducibility) Corrected Std Dev [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-4 Table 5.2-2 Results for Non-Adapted Off-line - Bundle JLM420 Height from BAZ (in.) Std Dev {(P11/Meas)-1} (Comparison Std Dev) Std Dev of [[ ]] Measurements of Rod [[ ]] (Measurement Reproducibility) Corrected Std Dev [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-5 Table 5.2-3 Results for TGBLA06 Nodal Depletions - Bundle JLM420 Node Height from BAZ (in.) Std Dev {(TGBLA/Meas)-1} (Comparison Std Dev) Std Dev of [[ ]] Measurements of Rod [[ ]] (Measurement Reproducibility) Corrected Std Dev TGBLA06 Infinite Lattice Nodal Core Tracking [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-6 5.3 SUMMARY - BUNDLE JLD505 - TRADITIONAL BASIS For bundle JLD505, [[ ]] measurements were planned for [[ ]] rods. By the completion of the experiment, [[ ]] measurements had been made on [[ ]] rods. The first [[ ]] measurements were performed with an identical geometrical arrangement as was used on the first bundle, JLM420. After the first [[ ]] measurements on bundle JLD505, experimental difficulties resulted in a slight reconfiguration. The counting characteristics of the two sets of measurements were different. [[ ]]. Results for Bundle JLD505 are provided in the following tables: Table 5.3-1- Results for Adapted Off-line - Bundle JLD505 Table 5.3-2- Results for Non-Adapted Off-line - Bundle JLD505 Table 5.3-3- Results for TGBLA06 Nodal Depletions - Bundle JLD505 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-7 Table 5.3-1 Results for Adapted Off-line - Bundle JLD505 Height from BAZ (in.) Std Dev {(P11/Meas)-1} (Comparison Std Dev)Std Dev of [[ ]] Measurements of Rod [[ ]] (Measurement Reproducibility) Corrected Std Dev [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-8 Table 5.3-2 Results for Non-Adapted Off-line - Bundle JLD505 Height from BAZ (in.) Std Dev {(P11/Meas)-1} (Comparison Std Dev) Std Dev of [[ ]] Measurements of Rod [[ ]] (Measurement Reproducibility) Corrected Std Dev [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-9 Table 5.3-3 Results for TGBLA06 Nodal Depletions - Bundle JLD505 Node Height from BAZ (in.) Std Dev {(TGBLA/Meas)-1} (Comparison Std Dev) Std Dev of [[ ]] Measurements of Rod [[ ]] (Measurement Reproducibility) Corrected Std Dev TGBLA06 Infinite Lattice Nodal Core Tracking [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-10 5.4 DETAILS OF TRADITIONAL COMPARISONS - NODAL DEPLETIONS This section will provide more details on one of the three analytic comparisons (the TGBLA06 nodal depletions). 5.4.1 Bundle JLM420 - Nodal Depletions In the following figures, various sets of data for bundle JLM420 are provided on a pin-by-pin basis (normalized measured 140La, normalized predicted 140Ba, and (Predicted/Measured) -1. These two-dimensional data will be provided for the nine different axial elevations for which TGBLA06 nodal depletions were developed. In the following figures, the measured 140La decay corrected count rate data is normalized so that the average value is 1.0 for each XY slice at each elevation The color code for this presentation of the data is supplied in Figure 5.4.1-1. The following figures provide the measured 140La data, the predictions of 140Ba using the TGBLA nodal depletion process, and the pin-by-pin comparisons between measured 140La and predicted 140Ba: Figure 5.4.1-2. Measured Normalized 140La for Bundle JLM420 (93 in. to 123 in.) Figure 5.4.1-3. Measured Normalized 140La for Bundle JLM420 (27 in. to 87 in.) Figure 5.4.1-4. TGBLA Predicted Normalized 140La for Bundle JLM420 (93 in. to 123 in.) Figure 5.4.1-5. TGBLA Predicted Normalized 140La for Bundle JLM420 (27 in. to 87 in.) Figure 5.4.1-6. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLM420 (93 in. to 123 in.) Figure 5.4.1-7. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLM420 (27 in. to 87 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-11 [[ ]] Figure 5.4.1-1. Color Code For XY Lattice Data Bundle JLM420 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-12 [[ ]] Figure 5.4.1-2. Measured Normalized 140La for Bundle JLM420 (93 in. to 123 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-13 [[ ]] Figure 5.4.1-3. Measured Normalized 140La for Bundle JLM420 (27 in. to 87 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-14 [[ ]] Figure 5.4.1-4. TGBLA Predicted Normalized 140La for Bundle JLM420 (93 in. to 123 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-15 [[ ]] Figure 5.4.1-5. TGBLA Predicted Normalized 140La for Bundle JLM420 (27 in. to 87 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-16 [[ ]] Figure 5.4.1-6. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLM420 (93 in. to 123 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-17 [[ ]] Figure 5.4.1-7. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLM420 (27 in. to 87 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-18 5.4.2 Bundle JLD505 - Nodal Depletions In the following figures, various sets of data for bundle JLD505 are provided on a pin-by-pin basis (normalized measured 140La, normalized predicted 140Ba, and {(Predicted/Measured) -1}. These two-dimensional data will be provided for the nine different axial elevations for which TGBLA06 nodal depletions were developed. In the following figures, the measured 140La decay corrected count rate data is normalized so that the average value is 1.0 for each XY slice at each elevation. The color code for this presentation of the data is supplied in Figure 5.4.2-1. The following figures provide the measured 140La data, the predictions of 140Ba using the TGBLA nodal depletion process, and the pin-by-pin comparisons between measured 140La and predicted 140Ba: Figure 5.4.2-2. Measured Normalized 140La for Bundle JLD505 (93 in. to 123 in.) Figure 5.4.2-3. Measured Normalized 140La for Bundle JLD505 (27 in. to 87 in.) Figure 5.4.2-4. TGBLA Predicted Normalized 140La for Bundle JLD505 (93 in. to 123 in.) Figure 5.4.2-5. TGBLA Predicted Normalized 140La for Bundle JLD505 (27 in. to 87 in.) Figure 5.4.2-6. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLD505 (93 in. to 123 in.) Figure 5.4.2-7. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLD505 (27 in. to 87 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-19

[[ ]] Figure 5.4.2-1. Color Code For XY Lattice Data Bundle JLD505 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-20 [[ ]] Figure 5.4.2-2. Measured Normalized 140La for Bundle JLD505 (93 in. to 123 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-21 [[ ]] Figure 5.4.2-3. Measured Normalized 140La for Bundle JLD505 (27 In. to 87 In.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-22 [[ ]] Figure 5.4.2-4. TGBLA Predicted Normalized 140La for Bundle JLD505 (93 in. to 123 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-23 [[ ]] Figure 5.4.2-5. TGBLA Predicted Normalized 140La for Bundle JLD505 (27 in. to 87 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-24 [[ ]] Figure 5.4.2-6. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLD505 (93 in. to 123 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 5-25 [[ ]] Figure 5.4.2-7. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLD505 (27 in. to 87 in.)

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-1 6. PIN NODAL, BUNDLE, AND AXIAL ROOT MEAN SQUARE (RMS) COMPARISONS The traditional comparison process provides insights as to the comparison of pin-by-pin power distribution within an X-Y plane, but the axial shape of the comparison is eliminated from consideration by the normalization process. This section provides a different view of the comparison process, analogous to the techniques common to the TIP comparison process. Similar to the TIP comparison process, the following three quantities are evaluated and compared: Pin Nodal RMS Rod RMS Axial Average RMS In these comparisons, all measurements at all elevations are normalized to a value of 1.0. The Pin Nodal RMS evaluations provide insights as to the ability of the code packages to calculate the fuel rod kW/ft for a particular height of a particular fuel rod. The Rod RMS evaluations provide insights as to the ability of the code package to calculate the axially integrated fuel rod power. The axial average RMS evaluation provides insights as to the accuracy with which the bundle average axial power distribution is calculated. As contrasted with the TIP comparison process (See Appendix A), however, where all TIP strings have the same number of measurements, it is noted that not all rods that are gamma scanned in the fuel assembly are measured for 140La, and the number of measurements finally obtained for each rod j may be different. For example, for part length rods there will be fewer measurements than for full-length rods. Also, for various reasons, there may not be measurements finally available for all axial elevations of all rods. Some data at a particular elevation may be missing, or the experimental counting uncertainties may be too large, causing the data for this measurement to be eliminated. Also, there may be multiple measurements for any particular rod. For the purpose of the statistical comparisons, the average value of all measurements for any particular axial elevation of each rod is computed, and the average value of these measurements at that location are used. The following table provides more details. The first set is for the TGBLA comparisons, while the second is for the PANAC11 based comparisons.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-2 Table 6.0-1 Number of Measurements HeightfromBAZJLD505JLM420HeightfromBAZJLD505JLM420274258274258455458455458635458635458815458815458874649874649 9346499046499946499346491114649994649 12346491024649Total43447711146491234649Total526575 NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-3 6.1 DESCRIPTION OF STATISTICS 6.1.1 Definitions Let: M(k, j) = Normalized Measured 140La at axial elevation k for rod j C(k, j) = Normalized Calculated (predicted) 140Ba at axial elevation k for rod j K(j) = Number of axial measurements for rod j J = Number of rods for which measurements are available for this fuel assembly J(k) = Number of measurements made at each axial level k N = Total number of measurements (all rods at all elevations) The measured 140La and calculated 140Ba are normalized in the same manner, as follows: [[ ]] 6.1.2 Pin Nodal RMS [[ ]] 6.1.3 Rod RMS The axially integrated rod power for those axial points where measurements are made is first calculated. There can be a different number of points for each different rod. [[ ]] 6.1.4 Axial Average RMS First, the average value at each axial level is calculated for all measured points (kM) and for all calculated points (kC). These average values are then normalized to an average value of 1.0. At each axial level, the RMS of the difference between the kM and kC is computed. [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-4 6.2 PIN NODAL, ROD AVERAGED, AND AXIAL AVERAGE STATISTICAL SUMMARY The pin nodal, rod averaged, and axial average statistics for each of the three analytical comparisons for the two bundles gamma scanned at FitzPatrick are provided below. As will be seen later, the TIP comparisons (Off-line non-adapted calculated TIPS compared to measured TIPs) will document a cycle average of [[ ]] nodal RMS value (with [[ ]] for the end of cycle TIP comparison). This TIP value represents (more or less) a result averaged over the four bundles surrounding the TIP string. This compares to the gamma scan values of between [[ ]] for the pin nodal RMS. Thus the pin nodal gamma scan results are of the same order of magnitude of the TIP comparisons, and the gamma scan and the TIP results are consistent and complement each other. Note that the statistics presented in the following three tables are for each bundle separately. Table 6.2-1. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary -Adapted Off-line Table 6.2-2. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary - Off-line Table 6.2-3. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary - Nodal Depletions NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-5 Table 6.2-1. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary - Adapted Off-line Bundle Pin Nodal RMS Rod Averaged RMS Axial Averaged RMS JLM420 JLD505 Table 6.2-2. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary Off-line Bundle Pin Nodal RMS Rod Averaged RMS Axial Averaged RMS JLM420 JLD505 Table 6.2-3. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary - Nodal Depletions Bundle Pin Nodal RMS Rod Averaged RMS Axial Averaged RMS JLM420 JLD505

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-6 6.3 SUMMARY PLOTS OF PIN NODAL RMS 6.3.1 Summary Plot for Adapted Off-line - Pin Nodal RMS This section provides a comparison of the normal on-line TIP and LPRM-adapted design tools with the results of the gamma scan. This case is generated with TIP and LPRM shape adapted PANAC11 core tracking. This adapted off-line core tracking reproduces the thermal limits seen in the on-line monitoring. Figure 6.3.1-1. combines the results of the prediction of 140Ba generated with PANAC11 for both measured bundles versus the measured 140La. The RMS value for this comparison is [[ ]]. This value represents the combined RMS value for both bundles. In Figure 6.3.1-1., the predicted 140Ba is the normalized predicted 140Ba number density from TGBLA06 for that particular rod, and the measured 140La is the normalized measured decay corrected count rates for 140La. Both predicted and measured values are normalized to an average value of 1.0. [[ ]] Figure 6.3.1-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Adapted Off-line NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-7 6.3.2 Summary Plot for Off-line - Pin Nodal RMS This comparison provides a summary of the off-line non-adapted results with the gamma scan measurements. Figure 6.3.2-1 combines the results of the prediction of 140Ba generated for both measured bundles versus the measured 140La. The RMS value for this comparison is [[ ]]. This value represents the combined RMS value for both bundles. [[ ]]. Again, both predicted and measured values are normalized to an average value of 1.0. [[ ]] Figure 6.3.2-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Off-line NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-8 6.3.3 Summary Plot for Nodal Depletions - Pin Nodal RMS This case provides a comparison of the use of the lattice code TGBLA06 to compute the predicted 140Ba (generated by replicating the nodal tracking from the PANAC11 off-line core tracking with the lattice code) with the gamma scan measurements. In this approach the nodal PANAC11 values for power density, void fraction, and control rod presence are used in the TGBLA06 code to deplete to the end of cycle. Figure 6.3.3-1. combines the results of the prediction of 140Ba generated with TGBLA06 for both measured bundles versus the measured 140La. The RMS value for this comparison is [[ ]]. This value represents the combined RMS value for both bundles.

[[ ]] Figure 6.3.3-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Nodal Depletions NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-9 6.4 SUMMARY OF ROD AVERAGED RMS COMPARISONS 6.4.1 Rod Averaged RMS Comparisons for Adapted Off-line Figures 6.4.1-1. and 6.4.1-2. compare the measured 140La and predicted 140Ba distributions on a rod-by-rod basis for the two gamma scanned bundles. In these figures, the "radial" value is derived by first calculating the "average" value of the (normalized to 1.0 over all measurements) 140La measured for that fuel rod. The average value of 140Ba predicted for that same number of axial elevations is then computed. Corner rods (tan), rods next to corner rods (grey), water rods (yellow), and gadolinium rods (green) are color coded in the lattice map. For bundle JLM420, the rod average RMS value is [[ ]]. For bundle JLD505, the rod average RMS value is [[ ]]. [[ ]] Figure 6.4.1-1. Rod Averaged RMS for Bundle JLM420 Adapted Off-line [[ ]] Figure 6.4.1-2. Rod Averaged RMS for Bundle JLD505 Adapted Off-line NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-10 6.4.2 Rod Averaged RMS Comparisons for Off-line Figures 6.4.2-1. and 6.4.2-2. compare the measured 140La and predicted 140Ba distributions on a rod-by-rod basis for the two gamma scanned bundles for the Off-line core tracking process. Corner rods (tan), rods next to corner rods (grey), water rods (yellow), and gadolinium rods (green) are color coded in the lattice map. For bundle JLM420 the rod average RMS value is [[ ]]. For bundle JLD505 the rod average RMS value is [[ ]]. [[ ]] Figure 6.4.2-1. Rod Averaged RMS for Bundle JLM420 Off-line [[ ]] Figure 6.4.2-2. Rod Averaged RMS for Bundle JLD505 Off-line NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-11 6.4.3 Rod Averaged RMS Comparisons for Nodal Depletions Figures 6.4.3-1. and 6.4.3-2. compare the measured 140La and predicted 140Ba distributions on a rod-by-rod basis for the two gamma scanned bundles for the TGBLA nodal depletion process. Corner rods (tan), rods next to corner rods (grey), water rods (yellow), and gadolinium rods (green) are color coded in the lattice map. For bundle JLM420, the rod average RMS value is [[ ]]. For bundle JLD505, the rod average RMS value is [[ ]]. [[ ]] Figure 6.4.3-1. Rod Averaged RMS for Bundle JLM420 Nodal Depletion [[ ]] Figure 6.4.3-2. Rod Averaged RMS for Bundle JLD505 Nodal Depletion NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-12 6.5 SUMMARY OF AXIAL AVERAGED RMS COMPARISONS 6.5.1 Axial Averaged RMS Comparisons for Adapted Off-line Figures 6.5.1-1. and 6.5.1-2. compare the axial averaged predicted 140Ba and the measured 140La for the TIP and LPRM adapted case. For bundle JLM420, the axial RMS value is [[ ]]. For bundle JLD505, the axial RMS value is [[ ]]. [[ ]] Figure 6.5.1-1. Axial Averaged Predicted Ba and Measured La for Bundle JLM420 Adapted Off-line [[ ]] Figure 6.5.1-2. Axial Averaged Predicted Ba and Measured La for Bundle JLD505 Adapted Off-line NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-13 6.5.2 Axial Averaged RMS Comparisons for Off-line Figures 6.5.2-1. and 6.5.2-2. compare the axial averaged predicted 140Ba and the measured 140La for the off-line case (i.e., non-adapted off-line core tracking). For bundle JLM420, the axial RMS value is [[ ]]. For bundle JLD505, the axial RMS value is [[ ]]. [[ ]] Figure 6.5.2-1. Axial Averaged Predicted Ba and Measured La for Bundle JLM420 Off-line [[ ]] Figure 6.5.2-2. Axial Averaged Predicted Ba and Measured La for Bundle JLD505 Off-line NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 6-14 6.5.3 Axial Averaged RMS Comparisons for Nodal Depletion Figures 6.5.3-1. and 6.5.3-2. compare the axial averaged predicted 140Ba and the measured 140La for the TGBLA nodal depletion case. For bundle JLM420, the axial RMS value is [[ ]]. For bundle JLD505, the axial RMS value is [[ ]]. [[ ]] Figure 6.5.3-1. Axial Averaged Predicted Ba and Measured La for Bundle JLM420 Nodal Depletion [[ ]] Figure 6.5.3-2. Axial Averaged Predicted Ba and Measured La for Bundle JLD505 Nodal Depletion NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 7-1 7. SUMMARY OF UNCERTAINTIES 7.1 PIN-BY-PIN GAMMA SCAN IMPACT ON UNCERTAINTIES FOR MELLLA+ ANALYSES As discussed in NEDC-32601P-A (Section 3.1), the uncertainties in pin power peaking factor is a combination of three uncertainty factors, [[ ]] These uncertainties can be combined as summarized in Table 7.1-1. Table 7.1-1 Components of Pin Power Peaking Uncertainty Component NEDC-32601P NEDC-33173P Table 2-11 [[ ]] The "Total Uncertainty" is again calculated using the SRSS. These uncertainties are evaluated on a lattice basis (that is, for one XY slice of a fuel assembly at any one axial height). The next section compares the measurement / analysis results with these uncertainties.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 7-2 7.2 SUMMARY OF MEASURED UNCERTAINTIES -PIN-BY-PIN XY As documented in Sections 5.2 and 5.3, the results of the gamma scan comparisons for all three modeling approaches provide better statistics (using the traditional basis approach) than the uncertainties summarized in NEDC-32601P-A. This set of comparisons is based on normalization of the data to 1.0 for each axial level separately. In these comparisons, therefore, the effects of bundle axial and radial power distributions have been removed. These are lattice comparisons, or XY comparisons, consistent with the traditional approach as summarized in Section 5.2. As such, the measured and predicted pin values at each axial level are normalized to 1.0 for that level. The value reported for the Corrected Standard Deviation is therefore the average of the standard deviations for all levels (i.e., the average is not weighted by the number of pins measured at each level). The measured comparison values explicitly include the actual effects of all [[ ]] Table 7.2-1 Comparisons of Pin Power Peaking Measurement Statistics Bundle Core Tracking Modeling Corrected Std Dev JLM420 Adapted Off-line JLM420 Off-Line JLM420 Nodal Depletion JLD505 Adapted Off-line JLD505 Off-Line JLD505 Nodal Depletion As shown in Table 7.2-1, the largest uncertainty is [[ ]], which is significantly smaller than the value of [[ ]] from Section 3.1.4 of NEDC-32601P-A.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-1 8. TRENDING AND VISUALIZATION The purpose for doing the gamma scan measurements is to provide confirmation that the lattice and 3-D steady state models provide reasonable evaluations of key operating thermal margins and power distributions. The experimental data and the comparisons to calculated data may help reveal potential weaknesses in the design process. For this reason, reviewing the data for any trends in the uncertainties in the calculation results is a useful exercise. All trends and information in this section focus on bundle JLM420, the lower exposure, higher reactivity fuel assembly. 8.1 TRENDS IN UNCERTAINTIES VS. NODAL PARAMETERS Section 2.6 discussed some key operating parameters that can be used for characterization of the operating conditions seen for fuel assemblies. In looking for trends, it may be interesting to see if there is any correlation in the accuracy of the design tools with respect to power, void fraction and exposure. Some of the key operating parameters in Section 2.6 reference bundle integral quantities. Here, the measurements regard pin-by-pin information, and the potential for trending in the uncertainty is compared to nodal quantities, not to bundle integral quantities. No evidence of a dependency (or trend) of the pin-by-pin uncertainties for bundle JLM420 could be identified for the following items: Nodal Power Nodal Exposure Nodal Void Fraction Channel Distortion (Channel Bow) 8.2 XYZ PLOTS OF {(TGBLA/MEAS)-1} PIN-BY-PIN ERRORS - BUNDLE JLM420 One method of identifying trends in the uncertainties is to visualize the error in the calculation process. In this discussion, "TGBLA" refers to the normalized pin-by-pin 140Ba predicted by TGBLA06 nodal depletions, and "Measured" refers to the normalized 140La measured in the gamma scan campaign. In Figures 8.2-1. through 8.2-9., the quantity {(TGBLA/Measured)-1} is displayed for each pin at the nine elevations for which TGBLA06 nodal depletions were compared to the measured data. In these figures, the lattice is viewed from the location of the instrument tube - that is, the narrow-narrow corner is nearest the front, and the control rod location would be towards the back of the figure. Each row of fuel pins is assigned a different color in these plots. [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-2 [[ ]] Figure 8.2-1. {(TGBLA/Meas)-1} For Bundle JLM420 at 27 In. [[ ]] Figure 8.2-2. {(TGBLA/Meas)-1} For Bundle JLM420 at 45 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-3 [[ ]] Figure 8.2-3. {(TGBLA/Meas)-1} For Bundle JLM420 at 63 In. [[ ]] Figure 8.2-4. {(TGBLA/Meas)-1} For Bundle JLM420 at 81 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-4 [[ ]] Figure 8.2-5. {(TGBLA/Meas)-1} For Bundle JLM420 at 87 In. [[ ]] Figure 8.2-6. {(TGBLA/Meas)-1} For Bundle JLM420 at 93 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-5 [[ ]] Figure 8.2-7. {(TGBLA/Meas)-1} For Bundle JLM420 at 99 In. [[ ]] Figure 8.2-8. {(TGBLA/Meas)-1} For Bundle JLM420 at 111 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-6 [[ ]] Figure 8.2-9. {(TGBLA/Meas)-1} For Bundle JLM420 at 123 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-7 8.3 XYZ PLOTS OF {(P11/MEAS)-1} PIN-BY-PIN ERRORS - BUNDLE JLM420 - OFF-LINE ADAPTATION In Figures 8.3-1. through 8.3-9., the quantity {(P11/Measured)-1} is displayed for each pin at the eleven elevations for which PANAC11 predicted pin-by-pin 140Ba was compared to the measured 140 La data. In these figures, the lattice is viewed from the location of the instrument tube - again, the narrow-narrow corner is nearest the front, and the control rod location would be towards the back of the figure. [[ ]]. [[ ]] Figure 8.3-1. {(P11/Meas)-1} For Bundle JLM420 at 27 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-8 [[ ]] Figure 8.3-2. {(P11/Meas)-1} For Bundle JLM420 at 45 In. [[ ]] Figure 8.3-3. {(P11/Meas)-1} For Bundle JLM420 at 63 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-9 [[ ]] Figure 8.3-4. {(P11/Meas)-1} For Bundle JLM420 at 81 In. [[ ]] Figure 8.3-5. {(P11/Meas)-1} For Bundle JLM420 at 87 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-10 [[ ]] Figure 8.3-6. {(P11/Meas)-1} For Bundle JLM420 at 90 In. [[ ]] Figure 8.3-7. {(P11/Meas)-1} For Bundle JLM420 at 93 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-11 [[ ]] Figure 8.3-8. {(P11/Meas)-1} For Bundle JLM420 at 99 In. [[ ]] Figure 8.3-9. {(P11/Meas)-1} For Bundle JLM420 at 102 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-12 [[ ]] Figure 8.3-10. {(P11/Meas)-1} For Bundle JLM420 at 111 In. [[ ]] Figure 8.3-11. {(P11/Meas)-1} For Bundle JLM420 at 123 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-13 8.4 XYZ PLOTS OF {(TGBLA/MEAS)-1} PIN-BY-PIN ERRORS - BUNDLE JLD505 In Figures 8.4-1. through 8.4-9., the quantity {(TGBLA/Measured)-1} is displayed for bundle JLD5050 for each pin at the nine elevations for which TGBLA06 nodal depletions were compared to the measured data. In these figures, the lattice is viewed from the location of the instrument tube - that is, the narrow-narrow corner is nearest the front, and the control rod location would be towards the back of the figure. Each row of fuel pins is assigned a different color in these plots. [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-14 [[ ]] Figure 8.4-1. {(TGBLA/Meas)-1} For Bundle JLD505 at 27 In. [[ ]] Figure 8.4-2. {(TGBLA/Meas)-1} For Bundle JLD505 at 45 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-15 [[ ]] Figure 8.4-3. {(TGBLA/Meas)-1} For Bundle JLD505 at 63 In. [[ ]] Figure 8.4-4. {(TGBLA/Meas)-1} For Bundle JLD505 at 81 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-16 [[ ]] Figure 8.4-5. {(TGBLA/Meas)-1} For Bundle JLD505 at 87 In. [[ ]] Figure 8.4-6. {(TGBLA/Meas)-1} For Bundle JLD505 at 93 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-17 [[ ]] Figure 8.4-7. {(TGBLA/Meas)-1} For Bundle JLD505 at 99 In. [[ ]] Figure 8.4-8. {(TGBLA/Meas)-1} For Bundle JLD505 at 111 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-18 [[ ]] Figure 8.4-9. {(TGBLA/Meas)-1} For Bundle JLD505 at 123 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-19 8.5 XYZ PLOTS OF {(P11/MEAS)-1} PIN-BY-PIN ERRORS - BUNDLE JLD505 - OFF-LINE ADAPTATION In Figures 8.5-1. through 8.5-9., the quantity {(P11/Measured)-1} is displayed for each pin at the eleven elevations for which PANAC11 predicted pin-by-pin 140Ba was compared to the measured 140 La data. In these figures, the lattice is viewed from the location of the instrument tube - again, the narrow-narrow corner is nearest the front, and the control rod location would be towards the back of the figure. [[ ]]. [[ ]] Figure 8.5-1. {(P11/Meas)-1} For Bundle JLD505 at 27 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-20 [[ ]] Figure 8.5-2. {(P11/Meas)-1} For Bundle JLD505 at 45 In. [[ ]] Figure 8.5-3. {(P11/Meas)-1} For Bundle JLD505 at 63 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-21 [[ ]] Figure 8.5-4. {(P11/Meas)-1} For Bundle JLD505 at 81 In. [[ ]] Figure 8.5-5. {(P11/Meas)-1} For Bundle JLD505 at 87 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-22 [[ ]] Figure 8.5-6. {(P11/Meas)-1} For Bundle JLD505 at 90 In. [[ ]] Figure 8.5-7. {(P11/Meas)-1} For Bundle JLD505 at 93 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-23 [[ ]] Figure 8.5-8. {(P11/Meas)-1} For Bundle JLD505 at 99 In. [[ ]] Figure 8.5-9. {(P11/Meas)-1} For Bundle JLD505 at 102 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-24 [[ ]] Figure 8.5-10. {(P11/Meas)-1} For Bundle JLD505 at 111 In. [[ ]] Figure 8.5-11. {(P11/Meas)-1} For Bundle JLD505 at 123 In.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-25 8.6 POTENTIAL TRENDS [[ ]] [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-26 [[ ]] Figure 8.6-1. {(P11/Meas)-1} vs. [[ ]] [[ ]] Figure 8.6-2. {(P11/Meas)-1} vs. [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-27 [[ ]] Figure 8.6-3. {(P11/Meas)-1} vs. [[ ]] [[ ]] Figure 8.6-4. {(P11/Meas)-1} vs. [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 8-28 8.6.1 Potential Impact [[ ]] [[ ]] Figure 8.6-5 [[ ]]

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 9-1 9. REFERENCES 1. Letter from USNRC to G. A. Watford (GE), "Amendment 26 to GE Licensing Topical Report NEDE-24011-P-A, 'GESTAR II' - Implementing Improved GE Steady-State Methods," November 10, 1999. 2. GE Nuclear Energy, "Power Distribution Uncertainties for Safety Limit MCPR Evaluations," NEDC-32694P-A, August 1999. 3. GE Nuclear Energy, "Advanced Methods Power Distribution Uncertainties for Core Monitoring," NEDC-32773P, Revision 1, January 1999. 4. GE Hitachi Nuclear Energy, NEDC-33173P, Supplement 2 Part 1, Licensing Topical Report, Applicability of GE Methods to Expanded Operating Domains - Power Distribution Validation for Cofrentes Cycle 13, August 2009. 5. GE Nuclear Energy, "Methodology and Uncertainties for Safety Limit MCPR Evaluations," NEDC-32601P-A, August 1999. 6. GE Nuclear Energy, Letter, J. S. Post to NRC, Document Control Desk, "Part 21 Evaluation; Power Distribution Uncertainty Reassessment," MFN05-082, August 18, 2005. 7. GE Nuclear Energy "Applicability of GE Methods to Expanded Operating Domains" NEDC-33173P," February 2006. 8. Letter from TB Blount (NRC) to JG Head (GEH), Subject: Final Safety Evaluation for GE Hitachi Nuclear Energy Americas, LLC Licensing Topical Report NEDC-33173P, "Applicability Of GE Methods To Expanded Operating Domains" (TAC No. MD0277), July 21, 2009.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-1 Appendix A OFF-LINE NON-ADAPTED TIP COMPARISONS The definitions of statistics used in these TIP comparisons are provided in the Cofrentes LTR. A.1 CYCLE 17 NON-ADAPTED TIP SETS There were only eight TIP sets run during the cycle. These are summarized in Table A.1-1 and Figure A.1-1. From sometime after April, 2006 until very near the end of cycle in October, 2006, there was apparently a problem with one of the TIP machines. Apparently for these TIPs, the values were not normalized to the same integral value as the TIP data from the other TIP machines. As a result, the nodal RMS difference between the measured and calculated TIPs increased dramatically for the June, 2006 TIP set, as shown in the following table and plots. This problem was apparently corrected by the last TIP set. However, this did not affect the 3DM / PANAC11 shape adaptive process, in that the radial component of the TIP data is not used in the adaptive process. Therefore the plant thermal margins calculated in the shape adaptive process were not affected, as the axial shape of the TIP measurements was not affected by the TIP mechanical problems, nor was the LPRM calibration process in 3DM / PANAC11. In addition, the exposure and void history accumulation in the on-line 3DM / PANAC11 is based on the non-adapted power distribution. Thus, the only implication is that the TIP radial RMS for this one case is seen to be quite large, with no actual impact on plant monitoring due to the inherent robustness of the 3DM / PANAC11 system. A.2 CYCLE 17 - COMPARISON OF CORE AVERAGE AXIAL TIPS - NON-ADAPTED This subsection provides snapshots of the comparison of the measured and calculated core average axial TIPs at the eight exposure points in Cycle 17. The progression from a more bottom peaked power distribution at the middle of cycle to a more top peaked power distribution at the end of cycle can be inferred from the core average axial TIP plots.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-2 Table A.1-1 Cycle 17 Non-Adapted TIP Sets Case Qualifier MWd/ST MW(t) Mlbm/hr Bundle RMS Axial RMS Nodal RMS Core Avg Ex. Void Maximum Exit Void 1 FMTS10502031 2288 2537 75.2 2 FMTD10504281 4210 2534 74.4 3 FMTD10510211 7838 2536 76.3 4 FMTD10601121 9735 2535 75.1 5 FMTD10603161 11160 2530 71.0 6 FMTD10604111 11753 2535 72.8 7 FMTD10606271 13473 2531 73.6 8 FMTS1061006 15754 2271 77.0 RMS Mean St. Deviation Minimum [[ ]] Figure A.1-1. Cycle 17 TIP RMS Values NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-3 [[ ]] Figure A.2-1. Axial Average TIP Comparison at 2288 MWd/ST [[ ]] Figure A.2-2. Individual TIP Comparisons At 2288 MWd/ST NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-4 [[ ]] Figure A.2-3. Axial Average TIP Comparison at 4210 MWd/ST [[ ]] Figure A.2-4. Individual TIP Comparisons At 4210 MWd/ST NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-5 [[ ]] Figure A.2-5. Axial Average TIP Comparison at 7838 MWd/ST [[ ]] Figure A.2-6. Individual TIP Comparisons At 7838 MWd/ST NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-6 [[ ]] Figure A.2-7. Axial Average TIP Comparison at 9735 MWd/ST [[ ]] Figure A.2-8. Individual TIP Comparisons At 9735 MWd/ST NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-7 [[ ]] Figure A.2-9. Axial Average TIP Comparison at 11160 MWd/ST [[ ]] Figure A.2-10. Individual TIP Comparisons At 11160 MWd/ST NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-8 [[ ]] Figure A.2-11. Axial Average TIP Comparison at 11753 MWd/ST [[ ]] Figure A.2-12. Individual TIP Comparisons At 11753 MWd/ST NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-9 [[ ]] Figure A.2-13. Axial Average TIP Comparison at 13472 MWd/ST [[ ]] Figure A.2-14. Individual TIP Comparisons At 13472 MWd/ST NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) A-10 [[ ]] Figure A.2-15. Axial Average TIP Comparison at 15754 MWd/ST [[ ]] Figure A.2-16. Individual TIP Comparisons At 15754 MWd/ST NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) B-i

APPENDIX B GEH RESPONSES TO NRC RAIS ON NEDC-33173P REVISION 2 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 1 For the maps providing the locations of the scanned bundles in NEDC-33173P Supplement 2, Part 1, "Applicability of GE Methods to Expanded Operating Domains - Power Distribution Validation for Cofrentes Cycle 13," (hereafter referred to as Supplement 2 Part 1) and NEDC-33173P Supplement 2, Part 3, "Applicability of GE Methods to Expanded Operating Domains -

Power Distribution Validation for Cofrentes Cycle 15," (hereafter referred to as Supplement 2 Part 3), please provide the location of the traversing in-core probe (TIP) strings. Response Figures 1-1 and 1-2 provide the locations of the TIP strings, with each TIP instrument tube identified by the TIP string number. The TIP string is located at the bottom, right hand corner of the bundle with the TIP string number. Note that the four bundle cells highlighted are the four bundle cells surrounding the TIP string, and do not identify the four bundles around a control rod. The TIP locations do not change between cycles; the locations of the bundles scanned in Cycles 13 and 15 are identified by the same coloring scheme used in Supplement 2 Part 1 and Supplement 2 Part 3.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 1-1 TIP Locations in Cycle 13 [[ ]] Figure 1-2 TIP Locations in Cycle 15 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 2 Supplement 2 Part 1 and Supplement 2 Part 3 do not consider all of the bundle scan data in the determination of the [[ ]] uncertainty. For the individual bundles surrounding a TIP cell that do not have three neighboring bundles (for example bundle AA0104 from Supplement 2 Part 1) is it possible to calculate the [[ ]] is known from the integrated TIP measurement? Please explain. Response Note that bundle AA0104 is not adjacent to a TIP string in Cycle 13, and is on the periphery in another un-monitored location in Cycle 15. However, there are other TIP string locations where all four of the adjacent fuel assemblies do not have gamma scan measurements. To calculate the [[ ]] values for these cases, analytical calculated data would need to be substituted for the missing data. This process might result in improved statistics, but these statistics would be misleading and tainted by the use of analytical data. The [[ ]]. The agreement on [[ ]] such as AA0104 is considered, for example, in the overall bundle RMS statistics provided in Table 4-1 of Supplement 2 Part 1.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 3 To assist the staff in comparing Cofrentes to the expanded extended power uprate (EPU) database, please provide one or two plots similar to Figure 25-19 from the Response: to RAI 25 in GE Letter (MFN 05-029), from Quintana, L., to USNRC, "Response:s to RAIs - Methods Interim Process (TAC No. MC5780)," dated April 8, 2005 characterizing the trends in TIP error with [[ ]]; please compare the Cofrentes cycle 13 and 15 data to the expanded database. Response The requested information is provided in Figure 3-1. As can be seen, the Cofrentes Cycle 13 and 15 data are quite compatible with the information in Figure 25-19 from the response to RAI 25 in MFN 05-029. In each case, no dependency of the [[ ]] relationship with approximately the same slope for each curve as compared to Figure 25-19. [[ ]] Figure 3-1 - TIP RMS vs. [[ ]], Cofrentes Cycles 13 and 15 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 4 Supplement 2 Part 3, Appendix A appears to contain several errors. (a) The TIP comparison figures in this Appendix are labeled "Cycle 19," please reconcile this inconsistency. (b) The units specified in the label for Figure A.2-20 are in error, please correct.

Response All of the plots in Appendix A are corrected with "Cycle 15" rather than "Cycle 19". As an example, the corrected page A-13 is provided on the following page. The units on Figure A.2-20 have been corrected. These revisions will be included in the acceptance version of Supplement 2 Part 3.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Example of corrected page A-13: [[ ]]

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 5 In Figures 2.3-1 and 2.4-1 of NEDC-33173P Supplement 2, Part 2, "Applicability of GE Methods to Expanded Operating Domains - Pin-by-Pin Gamma Scan at FitzPatrick October 2006,"

(hereafter referred to as Supplement 2 Part 2) please indicate where the nearest instrument tube is located relative to the scanned bundles. Response Figure 5-1 provides the locations of the TIP strings in FitzPatrick, with each TIP instrument tube identified by the TIP string number. The TIP string is located at the bottom, right hand corner of the bundle with the TIP string number. Note that the four bundle cells highlighted are the four bundle cells surrounding the TIP string, and do not identify the four bundles around a control rod. Note that JLD505 is not adjacent to an instrument tube in either Cycle 16 or 17, while JLM420 is adjacent to an instrument tube in Cycle 17. 12345678910111213141516171819202122232425261522503484272829303146544642740JLD505 in Cycle 16821222324252638JLD505 in Cycle 17936JLM420 in Cycle 1710341132121516171819203013281426152416910111213142217201818191620456781421122210230824123062504260213579111315171921232527293133353739414345474951 Figure 5-1 - TIP Locations for FitzPatrick NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 6 Please provide a figure that depicts the axial elevations where scans were performed relative to the axial geometric features of the GE14 bundles. This figure should illustrate the location of spacers and part length rods. Response Figure 6-1 provides the requested visualization (the top peaked axial power shape at EOC is also provided). The two measured bundles are standard GE14 designs, each having the same axial heights of the spacers, full, and part length rods. Spacers are indicated by red squares; measurement points by red triangles. The part length rod heights are also visualized. [[ ]] Figure 6-1 Visualization of Axial Heights NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 7 In Section 2.7 of Supplement 2 Part 2, should "Cycle 7" read "Cycle 17"?

Response That is correct. The acceptance version of Supplement 2 Part 2 will include this correction. (See Appendix A)

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 8 Please provide a series of figures that are substantially similar to Figures 2.7-1 through 2.7-4 except please plot the key operating parameters for bundle JLD505 during cycle 16.

Response Figures 8-1, 8-2, 8-3, and 8-4 provide the requested information. [[ ]] Figure 8-1 Maximum Bundle Power in MWt vs. Cycle 16 Exposure [[ ]] Figure 8-2 Maximum Power / Flow Ratio vs. Cycle 16 Exposure NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 8-3 Exit Void Fraction vs. Cycle 16 Exposure [[ ]] Figure 8-4 Peak LHGR vs. Cycle 16 Exposure NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 9 Please clarify how the statistics are determined for regions of the bundle where there are empty and vanished pin locations. That is, in Section 6.1, please provide a better description of how J is used if J is axially dependent. Response With axially varying numbers of fuel rods (empty and vanished pin locations), it is again useful to first clarify the normalization process used in comparing measured and calculated values. For multiple measurements on the same rod, an average (nodal) value is first calculated for each of the measurement points. Thus, some rods may have more measurements than other rods; however, for the comparison process, each (nodal) measurement uses one (average) value for that location. These measurement values are relative values; the measurement data and the calculated data is first normalized so that the average value is 1.000 over all measured nodes. Note that Section 6 has been revised to provide additional details on the process used to produce the statistics provided in Section 6. As a complicating factor, the TGBLA based process only uses node centered measurements, consistent with the nodalization used in the PANAC11 3D process. Table 9-1 compares the number or pin measurements for the two bundles at each axial height, while Table 9-2 provides this same information for the PANAC11 based statistics. Table 9-1 Number of Measurements Used in TGBLA Statistical Comparisons Height from BAZ, in. JLD505 JLM420 27 42 58 45 54 58 63 54 58 81 54 58 87 46 49 93 46 49 99 46 49 111 46 49 123 46 49 Total 434 477 BAZ: Bottom of the Active (Fuel) Zone NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Table 9-2 Number of Measurements Used in PANAC11 Statistical Comparisons Height from BAZ, in. JLD505 JLM420 27 42 58 45 54 58 63 54 58 81 54 58 87 46 49 90 46 49 93 46 49 99 46 49 102 46 49 111 46 49 123 46 49 Total 526 575 BAZ: Bottom of the Active (Fuel) Zone For the pin nodal RMS calculation, the normalized measured data is directly compared to the normalized calculated data as described in Section 6.1.2. Note that this equation has been revised for clarity, incorporating N = Total number of measurements. Also note that these comparisons for pin nodal RMS are not intended to depict a precisely volumetric consistent evaluation of relative nodal powers as would be obtained from a full three-dimensional evaluation with PANAC11. As is clear from the response to RAI 6, the measurement points are not equally spaced and do not represent the same volumetric sizes. Rather, the available measurement values are compared to the corresponding predicted values. For the rod RMS calculation, this same data set is used to calculate the average value for each rod. Different rods will have different numbers of data points, with more data points for full length rods than for part length rods. In addition, some data points for some rods may be missing because of measurement difficulties. For each of the fuel rods, the average value of the measured data for that rod is then compared to the predicted values, where the number of data points for each rod in the predicted data is exactly consistent with the number of measured data points for that rod. Thus, the average values for each fuel rod necessarily do not depict the same volumetric value. Section 6.1.3 has also been revised for clarity and will be included in the acceptance version of Supplement . (See Appendix A) For the axial average RMS calculations, for each axial level, the averages are calculated, and the [[ ]] for each axial level is formed. The sum of these numbers is then divided by the number of axial levels. Again, Section 6.1.4 has been revised to clarify the calculation process. (See Appendix A)

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) For bundle JLD505, for example, the number of axial levels measured for full length rods is [[ ]]. To further clarify this calculation see Table 9-3 for bundle JLD505. Again, the number of rod measurements used at each axial level is not the same, due to (a) part length rods and (b) experimental difficulties in the first axial height. Table 9-3 Details Axial Average RMS for Bundle JLD505 (Adapted Off-Line) Height from BAZ Avg PredictedBa-140 Avg MeasuredLa-140 (Avg Pred - Avg Meas)^2CountPred Count Meas [[ ]]

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 10 Please clarify what is meant by "Axial Averaged RMS for Bundle-" in Section 6.5. These figures appear to depict the measured and calculated axial power distributions that are radially averaged. Please describe the differences between the figures in Section 6.5 and Figure 2.9.2. Response Figure 2.9-2 provides the nodal power for bundles JLM420 and JLD505 at EOC17 from the off-line unadapted PANAC11 core tracking for FitzPatrick. As such, the average nodal power for all bundles in the core is 1.00. The data presented here is for all [[ ]] nodes. Also note that Figure 2.9-2 contains no "measured" data, only calculated data. The axial power data in Figure 2.9-2 shows a reduction in the nodal power for these bundles just above the axial point where the part length rods terminate. Using the PANAC11 core power distributions, the calculated TIPs from PANAC11 can be compared to the measured TIPs, as shown in Figure A.2-15 at EOC17 (note that this is for the core average information). The individual TIPs shown in Figure A.2-16 represent (more or less) the average of the four bundles surrounding the TIP instrument. This process of TIP comparisons is one method of validating the power distribution calculations of PANAC11. As shown in Table A.1-1, the nodal RMS for this EOC17 TIP comparison is [[ ]] The complete core is composed of GE10x10 fuel, and the EOC TIP measurements show no discernable trend at the axial point were the part length rods terminate. The data in Section 6.5 provide a comparison of the axial averaged predicted 140Ba and the measured 140La of only those rods that were measured during the gamma scan campaign. Note that the "RMS" label on these plots was replaced with "Predicted Ba and Measured La". While this is only for a limited number of axial measurement points, and for only a sub-set of all the fuel rods in the fuel assembly, the comparison nevertheless provides useful insight into the capabilities for the TGBLA06 / PANAC11 system of codes to calculate the pin-by-pin power distributions within the bundles in the core, since power and 140Ba are approximately linearly dependent. Both the predicted 140Ba and the measured 140La demonstrate an increase at the axial point were the part length rods terminate. When the data for individual rods are examined, it is seen that fuel rods on the corners of the bundle do not demonstrate nearly the magnitude of increase as those fuel rods that are more interior to the fuel assembly. That is, the specific operating conditions of individual rods produce some variances in the 140Ba production rate, and the 140Ba is both calculated and measured to increase above this axial point. The axial RMS for these comparisons is slightly better than the TIP nodal RMS; this is because a smaller axial range is compared, and then only for a smaller subset of fuel rods. The robustness and detail of the TGBLA06 / PANAC11 system of codes are confirmed by this ability to correctly calculate different distributions of power, TIPs, and 140Ba production.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 11 To assist the staff in comparing Supplement 2 Part 2 to the traditional gamma scan qualification, please provide the following reference: L. M. Shiraishi, Gamma Scan Measurements of the Lead Test Assembly at The Duane Arnold Energy Center Following Cycle 8, NEDC-31569-P, April 1988. Response This report is considered proprietary in it's entirety. It is included as Appendix B to Enclosure 1.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 12 Please clarify Table 7.2-1. In particular, are the standard deviations quoted in this table consistent with the traditional basis for the pin power peaking uncertainty? In other words, are these averaged root-mean-squared (RMS) differences for the different axial levels? Response The data in Table 7.2-1 is taken from Tables 5.2-1, 5.2-2, and 5.2-3 for bundle JLM420, and from Tables 5.3-1, 5.3-2 and 5.3-3 for bundle JLD505. The data is therefore consistent with the traditional basis for the pin power peaking uncertainty, calculated from the average standard deviation for the different axial levels.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 13 Please supplement Supplement 2 Part 2 with a section that is substantially similar to Section 8.3 except based on the JLD505 gamma scan data. Response Section 8.3 provides 3D plots comparing [(P11/Meas) - 1] for bundle JLM420 at different elevations. Section 8.2 provides similar plots for [(TGBLA/Meas) - 1] for bundle JLM420. In a similar fashion, the comparisons for [(TGBLA/Meas) - 1] for bundle JLD505 are first provided, and then those comparing [(P11/Meas) - 1] for bundle JLD505. Note that fuel rod [[ ]] at elevation [[ ]] inches appears anomalous; while no reason has been found to exclude this one experimental point, the measurement appears suspect. Sections 8.4 and 8.5 have been added to the Supplement 2 Part 2 report and will be included in the acceptance version. (See Appendix A) The Revision 0 Section 8.4 becomes Section 8.6. Bundle JLD505 [(TGBLA/Meas) - 1] (Figures 13-1 to 13- 9) [[ ]] Figure 13-1 Bundle JLD505 [(TGBLA/Meas) - 1] at 27 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-2 Bundle JLD505 [(TGBLA/Meas) - 1] at 45 Inches [[ ]] Figure 13-3 Bundle JLD505 [(TGBLA/Meas) - 1] at 63 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-4 Bundle JLD505 [(TGBLA/Meas) - 1] at 81 Inches [[ ]] Figure 13-5 Bundle JLD505 [(TGBLA/Meas) - 1] at 87 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-6 Bundle JLD505 [(TGBLA/Meas) - 1] at 93 Inches [[ ]] Figure 13-7 Bundle JLD505 [(TGBLA/Meas) - 1] at 99 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-8 Bundle JLD505 [(TGBLA/Meas) - 1] at 111 Inches [[ ]] Figure 13-9 Bundle JLD505 [(TGBLA/Meas) - 1] at 123 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Bundle JLD505 [(P11/Meas) - 1] (Figures 13-10 to 13-19) [[ ]] Figure 13-10 Bundle JLD505 [(P11/Meas) - 1] at 27 Inches [[ ]] Figure 13-11 Bundle JLD505 [(P11/Meas) - 1] at 45 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-12 Bundle JLD505 [(P11/Meas) - 1] at 63 Inches [[ ]] Figure 13-13 Bundle JLD505 [(P11/Meas) - 1] at 81 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-14 Bundle JLD505 [(P11/Meas) - 1] at 87 Inches [[ ]] Figure 13-15 Bundle JLD505 [(P11/Meas) - 1] at 90 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-16 Bundle JLD505 [(P11/Meas) - 1] at 93 Inches [[ ]] Figure 13-17 Bundle JLD505 [(P11/Meas) - 1] at 99 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-18 Bundle JLD505 [(P11/Meas) - 1] at 102 Inches [[ ]] Figure 13-19 Bundle JLD505 [(P11/Meas) - 1] at 111 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 13-20 Bundle JLD505 [(P11/Meas) - 1] at 123 Inches NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 14 The [[ ]] to be biased. However, this is based on a limited data sample. Please perform transport calculations to assess if the magnitude of the observed trend in [[ ]]. If the [[ ]] please explain the observed trend in [[ ]]. Response The [[ ]] to be biased, [[ ]] More detailed calculations of the [[ ]].

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 15 Please update Section 8.4.1 of Supplement 2 Part 2 to include a disposition of the NN rod power for plants with thermal TIPs. Response The impact of a difference between the design predicted and actual power of the NN rod on the TIP signal was evaluated in a conservative manner by using infinite lattice calculations. In these calculations, the NN rod power was changed by means of variation of the NN pin enrichment.

The value of the flux at the detector location was obtained for each of these variations. To ascertain the impact on the TIP signal of these pin power changes, the thermal group flux changes were used. In addition, these calculations were completed at different void fractions and uncontrolled depletions over the life of the fuel assembly were evaluated. [[ ]]. Also note that if the NN rod had a higher pin power than predicted, the depletion process in the reactor would tend to "burn" this difference away; the NN rod would deplete faster and approach the nominal predicted power later in exposure. In a similar manner, if the NN rod had a lower pin power than predicted at lower exposures, it would deplete at a slower rate, and would approach the nominal predicted power later in exposure. Thus, the normal depletion process tends to self-heal biases in predicted pin powers. Figure 15-1 provides insights as to the impact of changes in NN rod powers on the fluxes in the detector location for [[ ]]. Figure 15-2 provides insights as to the self healing process of the pin powers due to depletion. Figure 15-3 provides detailed information on the impact of changes in NN pin powers on thermal flux in the detector over the complete exposure range of the life of the fuel assembly (evaluated at [[ ]]

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 15-1 Detector Fluxes for Three Groups as a Function of Relative NN Rod Power [[ ]] Figure 15-2 Relative NN Rod Power As a Function of Exposure NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 15-3 Impact of Changes in NN Pin Powers on the 1/(Thermal Flux in the Detector)

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 16 Please update Section 8.4.1 of Supplement 2 Part 2 with a discussion addressing nodal power uncertainty in addition to P4B uncertainty. Response Please refer to the response to RAI 14. The nodal power uncertainties resulting from a [[ ]] are included in the overall statistical comparisons from the gamma scan results.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 17 Please update Section 8.4.1 of Supplement 2 Part 2 with a discussion of the extrapolation of potential biases to MELLLA+ operating conditions." Response Please refer to the response to RAI 14. No additional impact for these potential biases are foreseen for MELLLA+ operating conditions.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 18 The [[ ]] errors for the second to last exposure point provided in Appendix A for the TIP comparisons are very large compared to the expected differences [[ ]] expected). From visual inference, this error appears to be a result of large radial power differences observed for TIP strings 10 and 16. TIP string 10 is adjacent to JLM420. Please discuss the implications of these results. Response From sometime after April, 2006 until very near the end of cycle in October, 2006, there was a problem with one of the TIP machines. For the TIPs associated with this one machine, the values were not normalized to the same integral value as the TIP data from the other TIP machines. As a result, the nodal RMS difference between the measured and calculated TIPs increased dramatically for the June, 2006 TIP set. This problem was corrected by the last TIP set. However, this did not affect the 3DM / PANAC11 shape adaptive process, in that [[ ]] calculated in the shape adaptive process were not affected, as the axial shape of the TIP measurements was not affected by the TIP mechanical problems, nor was the LPRM calibration process in 3DM / PANAC11. In addition, the exposure and void history accumulation in the on-line 3DM / PANAC11 is based on the [[ ]]. Thus, the only implication is that the TIP radial RMS for this one case is seen to be quite large, with no actual impact on plant monitoring due to the inherent robustness of the 3DM / PANAC11 system.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 19 Please explain how the average corrected standard deviation in the tables in Section 5 of Supplement 2 Part 2 is calculated. Response First we define experiment as the standard deviation of [(Calculated / Measured) minus 1] at some given elevation, and reference as the standard deviation of repeat measurements of the activity of the [[ ]]. For each axial level, the "Corrected Standard Deviation" at that axial level for the "traditional" process is evaluated by calculating corrected as follows: [[ ]] After the corrected is calculated at each axial level, the average value for all axial nodes is then calculated. It is recognized that this process, used for the Duane Arnold pin-by-pin gamma scan in evaluating the "1986 Lead Test Assembly" data [[ ]].

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 Table 2-11 of NEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains," Revision 2, includes a correction to the update uncertainty. The staff notes that the corrected Revision 0, linear heat generation rate (LHGR) uncertainty is [[ ]]percent. The updated uncertainty is expected to be a function of the exposure interval between local power range monitor (LPRM) calibrations. (a) Please provide descriptive details regarding the basis for the quantification of this uncertainty component. This description should address the component of the update uncertainty attributed to instrument failure. (b) Upon cursory review of NEDC-32694P-A, "Power Distribution Uncertainties for Safety Limit MCPR Evaluations," Appendix B, the basis appears to be based on[[ ]]. Please justify how these results are representative for the entire fleet. (c) Upon cursory review of NEDC-32694P-A, Appendix B, it would appear that if [[ ]]. Please justify the applicability of these data to quantify an uncertainty associated with calibration intervals of [[ ]] MWD/T or higher. (d) Please specify the maximum LPRM calibration interval (in terms of exposure) to which the generic NEDC-32694P-A, Appendix B, update uncertainty value is applicable. (e) Please justify the LPRM calibration interval provided in (d). In this justification, please consider the standard technical specifications (STS) surveillance requirement (SR) 3.0.2 which allows a 25 percent extension of the calibration interval to address potential plant conditions impairing calibration. (f) Several plants have applied for LPRM calibration interval extensions. If a plant with an extended LPRM calibration interval applies for an EPU, please describe how the plant-specific LPRM calibration interval is accounted for in the uncertainty analysis. (g) Several plants that have applied for LPRM calibration interval extensions have referenced improved LPRM devices (e.g., NA300 series devices). Please describe how the plant-specific hardware is considered in the safety analyses for plants referencing the IMLTR. (h) Several plants have applied for LPRM calibration interval extensions and justified the approach relative to the nodal uncertainty analysis provided under the GE Thermal Analysis Basis (NEDE-10958P-A, "General Electric Thermal Analysis Basis Data, Correlation and Design Application"). When these plants reference the IMLTR, component uncertainties are reduced, such as [[ ]] These NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) reduced uncertainties are consistent with the improved 3D MONICORE system. Therefore, conservatism credited in the safety evaluation for the initial LPRM calibration interval does not exist when these plants reference the IMLTR as the basis for their safety limit uncertainties. Please explain how the extended LPRM calibration interval is considered in the safety analysis for these plants. (i) Several plants define the LPRM calibration interval in units of effective full power hours (EFPH). Plants that define the interval using units of EFPH that apply for an EPU are likewise applying for an extension of the LPRM calibration interval in terms of accumulated exposure between calibrations. Please explain how these plants are addressed in the IMLTR based LHGR uncertainty analysis?

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Response Before answering each of the specific concerns, additional information is first supplied which supplements information previously provided. LPRM update uncertainties for currently operating BWRs with modern fuel designs and current LPRM detector types have been examined for a representative population of the BWR fleet. The purpose for this new information is to demonstrate that the LPRM update uncertainty is not exposure dependent over a wide range of exposure increments between TIP / LPRM calibrations. New Information To evaluate the LPRM uncertainty, it is only necessary to evaluate the difference in the core peak thermal margins before and after a TIP set, which can be obtained directly from plant data. Current data was obtained from seven plants and twelve cycles of these seven plants, as shown in Table 20-1. As can be seen, this list of plants includes D, C, and S lattices, small plants and large plants, and both thermal (neutron) TIP monitoring systems and gamma () TIP monitoring systems. Table 20-1 Types of Plants Analyzed Plant Name BWR/ Type Lattice Type# of Bundles TIP Type Cycles Plant "A" Plant "B" Plant "C" Plant "D" Plant "E" Plant "F" Plant "G" A total of 115 TIP / LPRM calibrations were examined for the seven plants (twelve different cycles for these seven plants). For each TIP set during the cycle, the peak thermal margins determined by LPRM adaption just prior to the TIP set can be compared to the thermal margins determined by LPRM adaption for the first 3DM case following the TIP set. The three thermal margins compared are TIP and LPRM adapted thermal margins: MFLPD : maximum fraction of linear power density: ratio of the maximum rod linear heat generation rate (MLHGR) to the LHGR limit. This is based on the peak linear heat generation rate for any particular fuel rod. MAPRAT: ratio of maximum average node planar linear heat generation rate to the limit. This is a measure of the nodal power, as it is the average linear heat generation rate of all fuel pins at that axial elevation for that bundle MFLCPR: maximum fraction of limiting critical power ratio (proportional to the inverse bundle power). Some of the plants analyzed have already extended the period between TIP / LPRM calibrations to [[ ]] EFPH. The data from these operating plants includes [[ ]].

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) The LPRM instrumentation types for these seven plants are summarized in Table 20-2. BWR/6 plants normally use NA250's. As shown in Table 2 the remainder of the plants use NA300 LPRM detectors. Table 20-2 - Types of LPRM Detectors Plant Name Cycle Number LPRMsNumber LPRM Strings Fraction NA250 Fraction NA300 Fraction Empty Plant "A" Plant "B" Plant "B" Plant "C" Plant "D" Plant "D" Plant "E" Plant "E" Plant "F" Plant "F" Plant "G" Plant "G" Results As shown in Figures 20-1, 20-2, and 20-3, the LPRM update uncertainty evaluations demonstrate essentially no exposure dependency. As summarized in Table 20-3, the one sigma (Standard Deviation or RMS) uncertainty values are well within the currently accepted GNF licensing basis for LPRM update uncertainty. In particular, the current LPRM update uncertainty of [[ ]] is quite well supported by the summary data provided in Table 20-3, "% Change in MFLPD". Table 20-3 Summary of LPRM Update Uncertainties  % Change in MFLCPR % Change in MFLPD % Change in MAPRAT Std Dev RMS

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) MFLCPR COMPARISONS Figure 20-1 summarizes the MFLCPR comparisons for the seven plants. As can be seen, the data over the full exposure range from zero exposure to [[ ]] MWd/ST show no dependency with the exposure interval between the TIP / LPRM calibrations. [[ ]] Figure 20-1 MFLCPR LPRM Update- Change in Thermal Margin Following LPRM Calibration NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) MFLPD COMPARISONS Figure 20-2 summarizes the MFLPD comparisons for the seven plants. As can be seen, the data over the full exposure range from zero exposure to [[ ]] MWd/ST show a very slight upward rise as a function of the exposure interval between the TIP / LPRM calibrations. [[ ]] Figure 20-2 MFLPD LPRM Update- Change in Thermal Margin Following LPRM Calibration NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) MAPRAT COMPARISONS Figure 20-3 summarizes the MAPRAT comparisons for the seven plants. As can be seen, the data over the full exposure range from zero exposure to [[ ]] MWd/ST show a slight upward rise as a function of the exposure interval between the TIP / LPRM calibrations. [[ ]] Figure 20-3 MAPRAT LPRM Update- Change in Thermal Margin Following LPRM Calibration NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Specific Responses RAI 20 (a) (a) Please provide descriptive details regarding the basis for the quantification of this uncertainty component. This description should address the component of the update uncertainty attributed to instrument failure. Response The pertinent portion of Table 2-11 is provided below: Table 2-11 Summary of Uncertainty Components for LHGR Evaluations Component NEDE-32601 (1) Revision 0 (1) Revision 0 (2) Revision 2 [[ ]] Notes from NEDC-33173P Rev 2: (1) Values from NEDC-33173P Revision 0 Safety Evaluation Table 3-11 [Reference 37] (2) Separate from the Methods LTR Supplement 2 uncertainty qualification, it was noticed that the update uncertainty should be [[ ]] as stipulated in RAI II.5 of NEDC-32694P-A [Reference 13]. As can be seen, there was no specification of the contributions to LHGR impacts due to failed TIP and LPRMs. As shown in Table 20-3 above, a value of [[ ]] for the LPRM update uncertainty has been derived from plant data. This plant data (115 points) represents 7 plants, 12 cycles, both gamma and neutron TIPs, and includes conditions with failed LPRMs and failed TIPs. The resulting [[ ]] uncertainty can clearly be applied across the data range to an exposure of approximately [[ ]] MWD/ST. The trends, as discussed in the response to RAI 20(d), suggest that the [[ ]] uncertainty is conservative to an exposure of [[ ]]. To be consistent with the above discussion, the line denoting Update uncertainty in Table 2-11 will be modified in the acceptance version of NEDC-33173P to include the revised component definition and the additional note. Revised Table 2-11 Summary of Uncertainty Components for LHGR Evaluations Component NEDE-32601 (1) Revision 0 (1) Revision 0 (2) Revision 2 [[ ]] (1) Values from NEDC-33173P Revision 0 Safety Evaluation Table 3-11 [Reference 37] (2) Separate from the Methods LTR Supplement 2 uncertainty qualification, it was noticed that the update uncertainty should be [[ ]] as stipulated in RAI II.5 of NEDC-32694P-A [Reference 13]. (3) This component of the LHGR uncertainty is valid up to an exposure of [[ ]] MWD/ST.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 (b) (b) Upon cursory review of NEDC-32694P-A Appendix B, the basis appears to be based on [[ ]], during which [[ ]] TIP measurements were made. Please justify how these results are representative for the entire fleet. Response The re-evaluation of this item is now based on a much larger set of data representative of the entire fleet.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 (c) (c) Upon cursory review of NEDC-32694P-A Appendix B, it would appear that if [[ ]] TIP measurements were considered for [[ ]] that the exposure interval between the LPRM calibrations would be less than [[ ]] MWD/T. If a cycle exposure of [[ ]] GWD/T is assumed, the interval between LPRM calibrations, on average, would only be [[ ]]MWD/T. Please justify the applicability of these data to quantify an uncertainty associated with calibration intervals of [[ ]] MWD/T or higher. Response Based on the new data documented previously and illustrated in Figures 20-1, 20-2, and 20-3 above, there is essentially no exposure dependency to the LPRM update uncertainty for any of the thermal margins. The trend, as a function of exposure increment between TIP sets, demonstrates that the LPRM depletion models are functioning as designed within the calibration interval and that there are no non-linear affects. The plant data [[ ]] represents 7 plants, 12 cycles, both gamma and neutron TIPs, and includes conditions with failed LPRMs and failed TIPs. The resulting [[ ]] uncertainty can be applied to an exposure of approximately [[ ]] MWD/ST. Therefore, the [[ ]] uncertainty as currently specified is conservative.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 (d) (d) Please specify the maximum LPRM calibration interval (in terms of exposure) to which the generic NEDC-32694P-A Appendix B update uncertainty value is applicable. Response Using the minor linear slope of the average error from the fit of the data as shown on Figure 20-2 the average error at [[ ]] is calculated to be [[ ]]. Using this value and the same standard deviation, [[ ]], the total RMS error is estimated to be [[ ]], leaving margin to the [[ ]] which is applied in the overall uncertainty evaluation for the linear heat generation rate. Therefore, the maximum calibration interval is conservatively specified to be [[ ]]. To further examine the data, consider the two outliers on Figure 20-2: [[ ]] is well in excess of 4 from the standard deviation of the data, and, [[ ]] is roughly 3.7 from the standard deviation of the data. These extreme points are included in the Figure 20-2 statistics and significantly affect the appearance of a trend as well as the standard deviation. Note that these points are included in the above determination that [[ ]] is conservative to an exposure of [[ ]]. For the purpose investigation, we will eliminate the [[ ]] points, divide the data into exposure intervals, and calculate the standard deviation for the different exposure intervals. The data points were separated into three different exposure ranges of equal exposure ([[ ]]). Figure 20-4 demonstrates that for the three exposure groups there is very little variation in the standard deviation of the change in the MFLPD thermal margins before and after TIP / LPRM calibrations.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 20-4 Change in Standard Deviation with Exposure for MFLPD NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 (e) (e) Please justify the LPRM calibration interval provided in (d). In this justification please consider the standard technical specifications (STS) surveillance requirement (SR) 3.0.2 which allows a 25 percent extension of the calibration interval to address potential plant conditions impairing calibration. Response As presented in the response to RAI 20 (d), the maximum LPRM calibration interval can be at least [[ ]] MWd/ST. Based on the 25% extension allowance a technical specifications (TS) calibration interval of [[ ]] MWd/ST is supported. For a particular plant, the specific TS extension allowance would determine the appropriate TS calibration interval.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 (f) (f) Several plants have applied for LPRM calibration interval extensions. If a plant with an extended LPRM calibration interval applies for an EPU, please describe how the plant-specific LPRM calibration interval is accounted for in the uncertainty analysis. Response Because no exposure dependency to the thermal margin LPRM update uncertainty was observed in Figures 20-1, 20-2, and 20-3 of this document, and since the plants included data for EPU operation, there is no need to make any special accounting in the uncertainty analyses for these plants.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 (g) (g) Several plants that have applied for LPRM calibration interval extensions have referenced improved LPRM devices (e.g., NA300 series devices). Please describe how the plant-specific hardware is considered in safety analyses for plants referencing the IMLTR. Response Because the data provided in this memo includes a large amount of data derived from plants with NA300 series devices, no special consideration for NA300 series devices is necessary.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 (h) (h) Several plants have applied for LPRM calibration interval extensions and justified the approach relative to the nodal uncertainty analysis provided under GE Thermal Analysis Basis (NEDO-10958P-A). When these plants reference the IMLTR, component uncertainties are reduced, such as the gradient uncertainty. These reduced uncertainties are consistent with the improved 3D MONICORE system.

Therefore, conservatism credited in the safety evaluation for the initial LPRM calibration interval does not exist when these plants reference the IMLTR as the basis for their safety limit uncertainties. How is the extended LPRM calibration interval considered in the safety analysis for these plants? Response See the Response: for item (f) above.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 (i) (i) Several plants define the LPRM calibration interval in units of effective full power hours (EFPH). Plants that define the interval using units of EFPH that apply for an EPU are likewise applying for an extension of the LPRM calibration interval in terms of accumulated exposure between calibrations. How are these plants addressed in the IMLTR based LHGR uncertainty analysis? Response The translation between EFPH and MWd/ST exposure accumulation between calibrations depends on the rated power of the plant and the core weight of the fuel in the core for that particular cycle. The MWd/ST/Day is calculated by forming the ratio (PRATED MWt) / (Core Weight ST). The EFPH corresponding to [[ ]] MWd/ST is calculated using 24 hrs * [[ ]] MWd/ST) / (MWd/ST/Day)]. Thus for each different plant, a different EFPH corresponding to [[ ]] MWd/ST would be established. However, a more effective approach in the long term would be to use MWd/ST units in the Technical Specifications.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Appendix A - Revision 1 of NEDC-33173P Supplement 2 Part 2 As committed in the RAI responses, revisions and additional content will be incorporated into the acceptance version of Supplement 2 Part 2. In addition to the incorporation of the changes committed in the RAI responses, slight improvements in the statistical comparisons between the measured and calculated results will be incorporated. During the review as part of the RAI response process, a number of conservative inputs in various spreadsheets used to produce the statistics and plots in Supplement 2 Part 2 were identified. For internal consistency, the affected portions of the LTR have been updated and revised. The change pages follow in Appendix A. These revised pages will be the basis for the acceptance version. The affected pages are summarized in the following table. Page Number in Rev 1 Type of Revision Note 2-2 Added Figure 2.1-1 showing TIP locations (added new page) RAI 5 2-10 Added Cycle 16 information; Changed Cycle 7 to Cycle 17 RAI 7 and 8 2-11, 2-12 Added Cycle 16 information plots (new pages) RAI 7 2-19, 2-20 Modified Figures 2.9-1, 2.9-2, and 2.9-3 to include all 11 measurement points (Verifier comment) See EXCEL Files "Visualizing_heights.XLS" and "eoc axials.xls" 3-3 Added Figure 3.2-1 showing locations of spacers and fuel rods RAI 5 5-3 Table 5.2-1 Revised Spreadsheet Revision 5-4 Table 5.2-2 Revised Spreadsheet Revision 5-7 Table 5.3-1 Revised Spreadsheet Revision 5-8 Table 5.3-2 Revised Spreadsheet Revision 5-12 Figure 5.4.1-2 - Replaced as Data for Elevation 111 inches is revised. Spreadsheet Revision 5-16 Figure 5.4.1-6 - Replaced as a result. Spreadsheet Revision 5-22 through 5-25 Figures 5.4.2-4 through 5.4.2-7 were not copied correctly from the EXCEL spreadsheet Revision 6-1, 6-2 Equations for statistics clarified. RAI 9 6-3 Range for pin nodal RMS for gamma scan changed from (3.9% and 5.1%) to (3.9% to 4.9%) Spreadsheet Revision 6-4 Tables 6.2-1, 6.2-2, and 6.2-3 Revised Spreadsheet Revision 6-5 RMS value in second paragraph and Figure 6.3.1-1 revised Spreadsheet Revision 6-6 RMS value in second paragraph and plot revised Spreadsheet Revision 6-8 RMS values and two figures revised Spreadsheet Revision 6-9 RMS value and two figures revised Spreadsheet Revision 6-10 Two figures revised for readability Revision NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Page Number in Rev 1 Type of Revision Note 6-11 RMS value and two figures revised Spreadsheet Revision 6-12 RMS value and two figures revised Spreadsheet Revision 7-2 Text added to second paragraph; Table 7.2 revised RAI 9, Spreadsheet Revision 8-2 thru 8-12 Figures 8.2-1 through 8.3-11 revised or added. Spreadsheet Revision 8-13 thru 8-24 Sections 8.4 and 8.5 added for Bundle JLD505 RAI 13 8-25, 8-26, 8-27 Figure numbers revised. Due to added Sections 8.4 and 8.5 8-28 New information RAI 15 A-1 Added new third paragraph. RAI 18 With one exception the modified statistical results show smaller values in the revised document. The only exception is seen in Table 6.2-2, page 6-4, where the revised Axial Average RMS for bundle JLD505 was revised [[ ]]

Figure 2.1-1 TIP Locations for FitzPatrick 2.7 CHARACTERIZATION OF OPERATING CONDITIONS - GAMMA SCAN BUNDLES

Figure 2.7-1. Maximum Bundle Power in MWt vs. Cycle 16 Exposure Figure 2.7-2. Maximum Power / Flow Ratio vs. Cycle 16 Exposure Figure 2.7-3. Exit Void Fraction vs. Cycle 16 Exposure Figure 2.7-4. Peak LGHR vs. Cycle 16 Exposure 2.9 EOC17 INFORMATION Figure 2.9-1 EOC17 Nodal Exposures for Bundles JLM420 and JLD505 Figure 2.9-2 EOC17 Nodal Powers for Bundles JLM420 and JLD505 Figure 2.9-3 EOC17 Nodal Void Fractions for Bundles JLM420 and JLD505

3-3 3.2 MEASUREMENT DETAILS For the once-burnt bundle JLM420, measurements at 11 axial elevations for [[ ]] different fuel rods were made. Multiple measurements were made on the "reference" rod and on the "weak" rod. A total of [[ ]] separate rod measurements were made. For the reference rod, including four measurements for potential azimuthal dependencies in the measurements, a total of [[ ]] rod measurements were made. There were also [[ ]] measurements of the weak rod. [[ ]] For the twice-burnt bundle JLD505, again measurements at 11 axial elevations for [[ ]] different fuel rods were planned, for a total of [[ ]] separate rod measurements had been made on [[ ]] rods. By the end of the campaign, [[ ]] rod measurements had been made because of the need to repeat measurements that had larger experimental counting uncertainties. The first [[ ]] measurements were made with identical conditions to JLM420; with the exception of new calibrations used with a new detector. After the first [[ ]] measurements, experimental difficulties were compensated for with a slight reconfiguration of the scanner while maintaining reference rod repeat measurements. [[ ]]. Figure 3.2-1 provides a graphical description of the measurement heights with respect to spacers and rod lengths. [[ ]] Figure 3.2-1 Locations of Spacers and Axial Measurement Points Table 5.2-1 Results for Adapted Off-line Bundle JLM420 Height from BAZ (in.) Std Dev {(P11/Meas)-1} (Comparison Std Dev) Std Dev of Measurements of Rod (Measurement Reproducibility) Corrected Std Dev Table 5.2-2 Results for Non-Adapted Off-line Bundle JLM420 Height from BAZ (in.) Std Dev {(P11/Meas)-1} (Comparison Std Dev) Std Dev of Measurements of Rod (Measurement Reproducibility) Corrected Std Dev Table 5.3-1 Results for Adapted Off-line Bundle JLD505 Height from BAZ (in.) Std Dev {(P11/Meas)-1} (Comparison Std Dev) Std Dev of Measurements of Rod (Measurement Reproducibility) Corrected Std Dev Table 5.3-2 Results for Non-Adapted Off-line Bundle JLD505 Height from BAZ (in.) Std Dev {(P11/Meas)-1} (Comparison Std Dev) Std Dev of Measurements of Rod (Measurement Reproducibility) Corrected Std Dev Figure 5.4.1-2. Measured Normalized 140La for Bundle JLM420 (93 in. to 123 in.)

Figure 5.4.1-6. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLM420 (93 in. to 123 in.)

Figure 5.4.2-4. TGBLA Predicted Normalized 140La for Bundle JLD505 (93 in. to 123 in.)

Figure 5.4.2-5. TGBLA Predicted Normalized 140La for Bundle JLD505 (27 in. to 87 in.)

Figure 5.4.2-6. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLD505 (93 in. to 123 in.)

Figure 5.4.2-7. Pin-by-Pin {(TGBLA/Meas)-1} For Bundle JLD505 (27 in. to 87 in.)

6. PIN NODAL, BUNDLE, AND AXIAL ROOT MEAN SQUARE (RMS) COMPARISONS

6-2 Description of Statistics 6.1.1 Definitions Let: M(k, j) = Normalized Measured 140La at axial elevation k for rod j C(k, j) = Normalized Calculated (predicted) 140Ba at axial elevation k for rod j K(j) = Number of axial measurements for rod j J = Number of rods for which measurements are available for this fuel assembly J(k) = Number of measurements made at each axial level k N = Total number of measurements (all rods at all elevations) The measured 140La and calculated 140Ba are normalized in the same manner, as follows: [[]] 6.1.2 Pin Nodal RMS [[]] 6.1.3 Rod RMS The axially integrated rod power for those axial points where measurements are made is first calculated. There can be a different number of points for each different rod. [[]] 6.1.4 Axial Average RMS First, the average value at each axial level is calculated for all measured points (kM) and for all calculated points (kC). These average values are then normalized to an average value of 1.0. At each axial level, the RMS of the difference between the kM and kC is computed. [[]]

6.2 PIN NODAL, ROD AVERAGED, AND AXIAL AVERAGE STATISTICAL SUMMARY

Table 6.2-1. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary Adapted Off-line Table 6.2-2. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary Off-line Table 6.2-3. Pin Nodal, Rod Averaged, and Axial Average Statistical Summary Nodal Depletions 6.3 SUMMARY PLOTS OF PIN NODAL RMS 6.3.1 Summary Plot for Adapted Off-line Pin Nodal RMS Figure 6.3.1-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Adapted Off-line 6.3.2 Summary Plot for Off-line Pin Nodal RMS Figure 6.3.2-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Off-line 6.3.3 Summary Plot for Nodal Depletions Pin Nodal RMS

Figure 6.3.3-1. Combined Pin Nodal RMS for Bundles JLM420 and JLD505 for Nodal Depletions 6.4 SUMMARY OF ROD AVERAGED RMS COMPARISONS 6.4.1 Rod Averaged RMS Comparisons for Adapted Off-line Figure 6.4.1-1. Rod Averaged RMS for Bundle JLM420 Adapted Off-line Figure 6.4.1-2. Rod Averaged RMS for Bundle JLD505 Adapted Off-line 6.4.2 Rod Averaged RMS Comparisons for Off-line Figure 6.4.2-1. Rod Averaged RMS for Bundle JLM420 Off-line Figure 6.4.2-2. Rod Averaged RMS for Bundle JLD505 Off-line 6.4.3 Rod Averaged RMS Comparisons for Nodal Depletions Figure 6.4.3-1. Rod Averaged RMS for Bundle JLM420 Nodal Depletion Figure 6.4.3-2. Rod Averaged RMS for Bundle JLD505 Nodal Depletion 6.5 SUMMARY OF AXIAL AVERAGED RMS COMPARISONS 6.5.1 Axial Averaged RMS Comparisons for Adapted Off-line Figure 6.5.1-1. Axial Averaged Predicted Ba and Measured La for Bundle JLM420 Adapted Off-line Figure 6.5.1-2. Axial Averaged Predicted Ba and Measured La for Bundle JLD505 Adapted Off-line 6.5.2 Axial Averaged RMS Comparisons for Off-line Figure 6.5.2-1. Axial Averaged Predicted Ba and Measured La for Bundle JLM420 Off-line Figure 6.5.2-2. Axial Averaged Predicted Ba and Measured La for Bundle JLD505 Off-line 7.2 SUMMARY OF MEASURED UNCERTAINTIES PIN-BY-PIN XY

Table 7.2-1 Comparisons of Pin Power Peaking Measurement Statistics Bundle Core Tracking Modeling Corrected Std Dev Figure 8.2-1. {(TGBLA/Meas)-1} For Bundle JLM420 at 27 In. Figure 8.2-2. {(TGBLA/Meas)-1} For Bundle JLM420 at 45 In.

Figure 8.2-3. {(TGBLA/Meas)-1} For Bundle JLM420 at 63 In. Figure 8.2-4. {(TGBLA/Meas)-1} For Bundle JLM420 at 81 In.

Figure 8.2-5. {(TGBLA/Meas)-1} For Bundle JLM420 at 87 In. Figure 8.2-6. {(TGBLA/Meas)-1} For Bundle JLM420 at 93 In.

Figure 8.2-7. {(TGBLA/Meas)-1} For Bundle JLM420 at 99 In. Figure 8.2-8. {(TGBLA/Meas)-1} For Bundle JLM420 at 111 In.

Figure 8.2-9. {(TGBLA/Meas)-1} For Bundle JLM420 at 123 In.

8.3 XYZ PLOTS OF {(P11/MEAS)-1} PIN-BY-PIN ERRORS BUNDLE JLM420 OFF-LINE ADAPTATION Figure 8.3-1. {(P11/Meas)-1} For Bundle JLM420 at 27 In.

Figure 8.3-2. {(P11/Meas)-1} For Bundle JLM420 at 45 In. Figure 8.3-3. {(P11/Meas)-1} For Bundle JLM420 at 63 In.

Figure 8.3-4. {(P11/Meas)-1} For Bundle JLM420 at 81 In. Figure 8.3-5. {(P11/Meas)-1} For Bundle JLM420 at 87 In.

Figure 8.3-6. {(P11/Meas)-1} For Bundle JLM420 at 90 In. Figure 8.3-7. {(P11/Meas)-1} For Bundle JLM420 at 93 In.

Figure 8.3-8. {(P11/Meas)-1} For Bundle JLM420 at 99 In. Figure 8.3-9. {(P11/Meas)-1} For Bundle JLM420 at 102 In.

Figure 8.3-10. {(P11/Meas)-1} For Bundle JLM420 at 111 In. Figure 8.3-11. {(P11/Meas)-1} For Bundle JLM420 at 123 In.

8.4 XYZ PLOTS OF {(TGBLA/MEAS)-1} PIN-BY-PIN ERRORS BUNDLE JLD505 Figure 8.4-1. {(TGBLA/Meas)-1} For Bundle JLD505 at 27 In. Figure 8.4-2. {(TGBLA/Meas)-1} For Bundle JLD505 at 45 In.

Figure 8.4-3. {(TGBLA/Meas)-1} For Bundle JLD505 at 63 In. Figure 8.4-4. {(TGBLA/Meas)-1} For Bundle JLD505 at 81 In.

Figure 8.4-5. {(TGBLA/Meas)-1} For Bundle JLD505 at 87 In. Figure 8.4-6. {(TGBLA/Meas)-1} For Bundle JLD505 at 93 In.

Figure 8.4-7. {(TGBLA/Meas)-1} For Bundle JLD505 at 99 In. Figure 8.4-8. {(TGBLA/Meas)-1} For Bundle JLD505 at 111 In.

Figure 8.4-9. {(TGBLA/Meas)-1} For Bundle JLD505 at 123 In.

8.5 XYZ PLOTS OF {(P11/MEAS)-1} PIN-BY-PIN ERRORS BUNDLE JLD505 OFF-LINE ADAPTATION Figure 8.5-1. {(P11/Meas)-1} For Bundle JLD505 at 27 In.

Figure 8.5-2. {(P11/Meas)-1} For Bundle JLD505 at 45 In. Figure 8.5-3. {(P11/Meas)-1} For Bundle JLD505 at 63 In.

Figure 8.5-4. {(P11/Meas)-1} For Bundle JLD505 at 81 In. Figure 8.5-5. {(P11/Meas)-1} For Bundle JLD505 at 87 In.

Figure 8.5-6. {(P11/Meas)-1} For Bundle JLD505 at 90 In. Figure 8.5-7. {(P11/Meas)-1} For Bundle JLD505 at 93 In.

Figure 8.5-8. {(P11/Meas)-1} For Bundle JLD505 at 99 In. Figure 8.5-9. {(P11/Meas)-1} For Bundle JLD505 at 102 In.

Figure 8.5-10. {(P11/Meas)-1} For Bundle JLD505 at 111 In. Figure 8.5-11. {(P11/Meas)-1} For Bundle JLD505 at 123 In.

8.6 POTENTIAL TRENDS [[]]

Figure 8.6-1. {(P11/Meas)-1} vs. Figure 8.6-2. {(P11/Meas)-1} vs.

Figure 8.6-3. {(P11/Meas)-1} vs. Figure 8.6-4. {(P11/Meas)-1} vs.

8.6.1 Potential Impact [[]]

9. REFERENCES

Appendix A OFF-LINE NON-ADAPTED TIP COMPARISONS A.1 CYCLE 17 NON-ADAPTED TIP SETS

A.2 CYCLE 17 - COMPARISON OF CORE AVERAGE AXIAL TIPS NON-ADAPTED NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Appendix B L. M. Shiraishi, Gamma Scan Measurements of the Lead Test Assembly at The Duane Arnold Energy Center Following Cycle 8, NEDC-31569-P, April 1988 Appendix B is an archive document that was not prepared for US NRC submittal. It is Proprietary in its entirety and no Non-Proprietary version is provided.

NEDO-33173 SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) C-i

APPENDIX C GEH RESPONSES TO SUPPLEMENTAL RAIS ON NEDC-33173P REVISION 2 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 20 Supplement 1 The response to RAI 20 provides justification for an extended LPRM calibration interval based on extrapolation of the error to higher LPRM calibration intervals. However, previous data indicate a trend of increasing local power distribution uncertainty with increasing power-to-flow ratio. If simultaneous extrapolation in both LPRM calibration interval and power-to-flow ratio is considered, what is the magnitude of the update uncertainty for MELLLA+ operation? Using this revised update uncertainty, what is the uncertainty in LHGR? Response: 1 Summary The RAI 20 responses previously submitted (MFN 10-355, December 17, 2010), provided summaries of the change in thermal margins following a TIP calibration (of the LPRMs) as a function of the exposure interval between the TIP calibrations. No calibration interval dependency was seen in the change in CPR (MFLCPR) or nodal average kW/ft (MAPRAT, ECCS nodal limit comparison), with only a slight upward trend in the change in the local peak kW/ft (MFLPD).

In a similar manner, the change in thermal margins can be evaluated as a function of the core power to core flow ratio (P/F). When this is done, no dependency is seen in the change in thermal margins for MFLCPR or MAPRAT when considered as a function of P/F, while only a slight upward trend of MFLPD with P/F is seen. Thus, there is no SLMCPR impact as a result of these trends. The only impact may be a slight increase in the LPRM update uncertainty component of the LHGR total uncertainty.

The current [[ ]]% allowance for the LPRM update uncertainty results in a total LHGR uncertainty of [[ ]]% compared to the process limit of [[ ]]%. The LPRM update uncertainty component could grow to [[ ]]% before adversely impacting the [[ ]]% process limit on total LHGR uncertainty. A simultaneous extrapolation in both LPRM calibration interval and power-to-flow ratio results in a [[ ]]% nominal LPRM update uncertainty, evaluated at [[ ]]. Using the [[ ]]% nominal LPRM update uncertainty combined with the standard squared error results in a bounding LPRM update uncertainty of [[ ]]%. Using this [[ ]]% uncertainty value for the LPRM update uncertainty, a total uncertainty of [[ ]]% results, which continues to demonstrate margin to the [[ ]]% total LHGR uncertainty process limit. 1.1 Identification of P/F Operating States The ratio of total reactor power to total core flow (P/F) has previously been identified as a key parameter for understanding potential effects in the progression to EPU and MELLLA+ operation in MFN 05-029. The 'target upper value' used in this discussion is [[ ]]. The following plot of actual operational data (P/F plotted vs. Cycle Exposure, where RP is reactor power and WCT is core flow) is extracted from all of the available off-line core tracking cases from the core tracking database (all BWR 2-6 plants supported by GNF / GEH), and is composed of more than [[ ]] data points. As can be seen, the majority of the plant data NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) is below [[ ]], but clearly plants have been occasionally operating in the range of [[ ]]. However, the available database of TIP comparison cases does not extend to this full range. [[ ]] Figure 20 S1-0 1.2 TIP RMS as a Function of Reactor Power / Core Flow - Non-Adapted RAI 25 (MFN 05-029, April 8, 2005) discussed TIP RMS values as a function of P/F for non-adapted off-line core tracking with PANAC11. In particular, Figure 25-19 (page 94 of MFN 05-029) provides TIP RMS differences vs. P/F ratio for Gamma TIP Cycles. For clarity, this figure is included in this discussion as Figure 20 S1-1. As per the MFN 05-029 discussion (page 49), for the Gamma TIP plants, the linear trend line indicates [[ ]]. The Axial RMS [[ ]]. The Bundle RMS [[ ]] Extrapolating the trend lines for the Gamma TIP plants to [[ ]], the Nodal and Axial RMS values would be on the order of [[ ]]%, while the Bundle RMS would be less than [[ ]]%.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 20 S1-1 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 1.3 TIP RMS Addition of Cofrentes Data - Non-Adapted When data from the Cofrentes Cycle 15 non-adapted off-line core tracking is added to this plot (Figure 20 S1-2), the trends of the Cofrentes data are seen to be quite consistent with the previous data. This presentation of the data has too much information, so individual components are provided in the following Figures 20 S1-3, -4, and -5. As is seen, there is no [[ ]], while a [[ ]]. [[ ]] Figure 20 S1-2 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 20 S1-3 [[ ]] Figure 20 S1-4 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 20 S1-5 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 1.4 TIP RMS Impact of Adaption in On-Line Core Monitoring In the on-line core monitoring with 3D MonicoreŽ using PANAC11, shape adaption is used to modify the thermal margins. In the shape adaption process, [[ ]]. Figures 20 S1-6, -7, and -8 show the impact of the on-line adaptive process on the TIP RMS values for the bundle, axial, and nodal comparisons. As can be seen, the [[ ]] is not affected by this process. Any [[ ]] is eliminated, and the [[ ]] becomes essentially the same as the [[ ]]. Thus, for core monitoring with 3D MonicoreŽ, any potential concerns regarding the impact of [[ ]] that might lead to increased uncertainty in the thermal margins are eliminated by the adaption process. [[ ]] Figure 20 S1-6 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) [[ ]] Figure 20 S1-7 [[ ]] Figure 20 S1-8 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 1.5 LPRM Update Uncertainty as a Function of Reactor Power / Core Flow The original RAI 20 response (MFN 10-355, December 17, 2010) discussed the LPRM update uncertainty as a function of the exposure interval between TIP calibrations. Data from a relatively large number of TIP calibrations were retrieved to enable evaluation of the change in thermal margins as a result of the re-calibration of the LPRMs using the TIP measurements. All of this data was obtained from 3D MonicoreŽ on-line shape adapted core tracking. For the majority of the database that had been constructed, data on the reactor power and core flow had also been obtained, so that trending of the change in thermal margins with the P/F ratio could also be examined. One sub-set of data, however, did not contain data for the P/F ratio. Therefore only [[ ]] were used for this trending vs. P/F ratio. Again, changes in [[ ]] were considered. Figure 20 S1-9 provides the change in [[ ]] as a result of a TIP calibration, plotted as a function of the P/F ratio. As can be seen, there is no trending of the change in [[ ]] as a function of the P/F ratio. The reason for this lack of trending is that the shape adaption process does not materially impact the [[ ]], and hence the use of TIP and LPRM shape adaption does not cause any significant change in the [[ ]] distributions. [[ ]] Figure 20 S1-9 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) Figures 20 S1-10 and 20 S1-11 provide the trending with the change in [[ ]] and [[ ]] following TIP calibration as a function of P/F. As can be seen, there is no trending with [[ ]], but a slight upward trend with [[ ]]. [[ ]] Figure 20 S1-10 [[ ]] Figure 20 S1-11 NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) 1.6 Double Extrapolation of Slight [[ ]] Trending Because slight trending exists in [[ ]] for LPRM updates for both the exposure interval and P/F individually, it is reasonable to consider these slight tendencies in combination. The RAI 20 Supplement 1 question reads in part: "If simultaneous extrapolation in both LPRM calibration interval and power-to-flow ratio is considered, what is the magnitude of the update uncertainty for MELLLA+ operation?" To evaluate this question, the "Change in [[ ]]" is assumed to be a linear function of both the "Exposure Interval between TIP sets" and the ratio "RP/WCT", and a least squared fit analysis in three dimensions is used, with , (1) where represents the "Change in [[ ]]", represents the "Exposure Interval between TIP sets" and represents the ratio "RP/WCT", where RP is the Reactor Power in MWt and WCT is the total core flow in Mlb/hr. The symbols , and are the least square fit parameters. Using this approach, the extrapolated "Change in [[ ]]" at with the "Exposure Interval between TIP sets" equal to [[ ]] and the ratio RP/WCT = [[ ]] MWt / Mlb/hr, is [[ ]]%. Graphically, the process is shown below in Figure 20 S1-12. [[ ]] Figure 20 S1-12: Change in [[ ]] as a function of Exposure Interval and RP/WCT NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) The individual least square estimates of the "Change in [[ ]]" is given by and the error mean square is given by The evaluated value of the EMS is [[ ]]. A total RMS estimate can be computed by taking the square root of the sum of the square of the extrapolated value and the EMS, which yields a result of [[ ]]% for the doubly extrapolated LPRM update uncertainty. The current [[ ]]% allowance for the LPRM update uncertainty results in a total LHGR uncertainty of [[ ]]% compared to the process limit of [[ ]]%. The LPRM update uncertainty component could grow to [[ ]]% before adversely impacting the [[ ]]% process limit on total LHGR uncertainty.

A simultaneous extrapolation in both LPRM calibration interval and power-to-flow ratio results in a [[ ]]% nominal LPRM update uncertainty, evaluated at [[ ]] MWt/Mlb/hr power to flow ratio and [[ ]] TIP calibration interval. Using the [[ ]]% nominal LPRM update uncertainty combined with the standard squared error results in a bounding LPRM update uncertainty of [[ ]]%. Using this [[ ]]% uncertainty value for the LPRM update uncertainty, a total uncertainty of [[ ]]% results, which continues to demonstrate margin to the [[ ]]% total LHGR uncertainty process limit.

NEDO-33173, SUPPLEMENT 2 PART 2-A NON-PROPRIETARY INFORMATION - CLASS I (PUBLIC) RAI 21 Please provide justification for the assumption made in the SLMCPR calculation that the power distribution uncertainties are normally distributed. Response: This question is similar to Question III - 3 in NEDC-32694P-A, page A-11 (MFN-005-98, January 9, 1998). The data for the power allocation factor comparisons from the Cofrentes Gamma Scan provides essentially the same results as the previous confirmation. In MFN-005-98, the Anderson-Darling Normality Test was satisfied with a P-Value of [[ ]] from Millstone Cycle 7 gamma scan data were removed. For the Cofrentes data, the Anderson-Darling Normality Test was satisfied with a P-Value of [[ ]]. Figure 21-1 below provides the normal probability plot for the Cofrentes power allocation factors (data for both Cycle 13 and Cycle 15 gamma scans is combined). As was noted in the MFN-005-98 response to Question III

- 3, the P-value is the probability that the proposition that the distribution is not normal is false.

Normally, a P-Value of 0.1 or higher is sufficient to show the distribution is normal. [[ ]] Figure 21-1