RS-03-204, Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit

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

ML033280149
Person / Time
Site:	Quad Cities
Issue date:	11/14/2003
From:	Simpson P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-03-204
Download: ML033280149 (23)

Text

ExekIen.

Exelon Generation www.exeloncorp.com Nucea 4300 Winfield Road lear Warrenville, IL60555 10 CFR 50.90 RS-03-204 November 14, 2003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Quad Cities Nuclear Power Station, Unit 2 Facility Operating License No. DPR-30 NRC Docket No. 50-265

Subject:

Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests a change to Technical Specifications (TS) for Quad Cities Nuclear Power Station (QCNPS), Unit 2. The proposed change revises the values of the Safety Limit Minimum Critical Power Ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs," to 1.09 for two loop operation, and to 1.10 for single loop operation for Unit 2, Cycle 18. The proposed amendment also incorporates an editorial change to TS Section 2.1.1 to provide consistency between Unit I and Unit 2.

The request is subdivided as follows.

1. Attachment 1 contains a summary and evaluation of the proposed change.

2. Attachment 2 provides the marked-up TS page.

3. Attachment 3 provides the revised TS page with the proposed change incorporated.

4. Attachment 4 provides additional information regarding the cycle-specific SLMCPR for QCNPS, Unit 2, Cycle 18. Portions of the information in Attachment 4 are proprietary to our fuel supplier, Global Nuclear Fuel (GNF), and we request that this attachment be withheld from public disclosure in accordance with 10 CFR 2.790, "Public inspections, exemptions, request for withholding," paragraph (a)(4). This proprietary information is indicated in double brackets (e.g., f 1).

5. Attachment 5 provides an affidavit supporting the request for withholding and a non-proprietary version of Attachment 4.

EGC requests approval of this proposed change prior to February 17, 2004, to support operation of QCNPS, Unit 2, following the refueling outage scheduled to begin February 24, 2004.

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

We are notifying the State of Illinois of this request for a change to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

Ab

November 14, 2003 U. S. Nuclear Regulatory Commission Page 2 Should you have any questions concerning this letter, please contact Mr. Thomas G.

Roddey at (630) 657-2811.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of November 2003.

Respp1j Patri R. Simpson 1.

Manager, Licensing Attachments: 1. Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

2. Markup of Technical Specifications Page

3. Retyped Technical Specifications Page

4. Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 (GNF Proprietary)

5. Affidavit and Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 (GNF Non-Proprietary) cc: Regional Administrator- NRC Region IlIl NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Office of Nuclear Facility Safety - Illinois Department of Nuclear Safety

ATTACHMENT i Description of Proposed Clianges, Technical Analysis, and Regulatory Analysis

Subject:

Safety Limit Minimum Critical Power Ratio in Technical Specifications Section 2.1.1, "Reactor Core SLs".

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria

6.0 ENVIRONMENTAL CONSIDERATION

S 7.0 CEFERENCES Page 1 of 6

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

1.0 DESCRIPTION

In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests a change to Technical Specifications (TS) for Quad Cities Nuclear Power Station (QCNPS), Unit 2. The proposed change revises the values of the Safety Limit Minimum Critical Power Ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs," to 1.09 for two loop operation, and to 1.10 for single loop operation for Unit 2, Cycle 18. The proposed amendment also incorporates an editorial change to TS Section 2.1.1 to provide consistency between Unit 1 and Unit 2.

EGC requests approval of this proposed change prior to February 17, 2004, to support operation of QCNPS Unit 2 following the refueling outage scheduled to begin February 24, 2004.

EGC evaluated submittals related to QCNPS currently under review by the NRC to determine the impact of the proposed change. The information presented in this proposed change does not affect any submittal currently under review by the NRC.

2.0 PROPOSED CHANGE

TS Section 2.1.1 specifies the value for the SLMCPR. For QCNPS, Unit 2, the values specified are as follows.

For Unit 2, MCPR shall be > 1.11 for two recirculation loop operation, or for single recirculation loop operation, MCPR shall be > 1.12.

The proposed change will revise TS Section 2.1.1 to read as follows.

For Unit 2, MCPR shall be > 1.09 for two recirculation loop operation or > 1.10 for single recirculation loop operation.

3.0 BACKGROUND

The fuel cladding integrity SLMCPR is established to assure that at least 99.9% of the fuel rods in the core do not experience boiling transition during an anticipated operational occurrence (AOO). To determine the explicit value for the cycle specific safety limit, a full core statistical analysis is performed. The core model incorporates the uncertainty in the measurement of core operating parameters, critical power ratio (CPR) calculation uncertainties, and the statistical uncertainty associated with the fuel vendor's correlation. The number of rods that might experience boiling transition as a function of the nominal MCPR is calculated.

4.0 TECHNICAL ANALYSIS

The SLMCPR evaluations for Cycle 18 were performed using the NRC-approved methods and uncertainties contained in Reference 1, supplemented with QCNPS Unit 2 specific uncertainties as indicated in Table 2 of Attachment 4. These calculations use the GEXL14 correlation for GE14 fuel and GEXL96 (i.e., Reference 2) for the Framatome ANP (FANP) fuel.

Page 2 of 6

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis In general, the calculated safety limit is dominated by two key parameters: (1) flatness of the core bundle-by-bundle MCPR distributions, and (2) flatness of the bundle pin-by-pin power/R factor distributions. Less flatness in either parameter yields fewer rods susceptible t boiling transition and thus a lower calculated SLMCPR.

The results of this analysis indicate that the SLMCPR can be reduced from the current TS values. The proposed change will take advantage of the increased operational margin provided by the analysis. Attachment 4 provides additional technical information to support these proposed changes.

5.0 REGULATORY ANALYSIS

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

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluate; or (3) Involve a significant reduction in a margin of safety In support of this determination, an evaluation of each of the three criteria set forth in 10 CFR 50.92 is provided below regarding the proposed license amendment.

Overview In accordance with 10 CFR 50.90, "Application for amendment of license or construction perrmit," Exelon Generation Company, LLC (EGC) requests a change to Technical Specifications (TS) for Quad Cities Nuclear Power Station (QCNPS), Unit 2. The proposed change revises the values of the Safety Limit Minimum Critical Power Ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs," to 1.09 for two loop operation,-and to 1.10 for single loop operation for Unit 2, Cycle 18. The proposed amendment also incorporates an editorial change to TS Section 2.1.1 to provide consistency between Unit 1 and Unit-2:

Does the proposed change involve a significantincrease in the probability or consequences of an accidentpreviouslyevaluated?

The probability of an evaluated accident is derived from the probabilities of the individual precursors to that accident. The consequences of an evaluated accident are determined by the operability of plant systems designed to mitigate those consequences. Limits have been established consistent with NRC approved methods to ensure that fuel performance during normal, transient, and Page 3 of 6

ATTACHMENT 1 Description of Proposed Changes, Technical Analysis, and Regulatory Analysis accident conditions is acceptable. The proposed change conservatively establishes the SLMCPR for Quad Cities Nuclear Power Station (QCNPS), Unit 2, Cycle 18 such that the fuel is protected during normal operation and during any plant transients or anticipated operational occurrences (AOis).

Changing the SLMCPR does not increase the probability of an evaluated accident. The change does not'require any physical plant modifications, physically affect any plant components, or entail changes in plant operation.

Therefore, no individual precursors of an accident are affected.

The proposed change revises the SLMCPR to protect the fuel during normal operation as well as during any transients'or anticipated operation occurrences.

Operational limits will be established based on the proposed SLMCPR to ensure that the SLMCPR is not violated during all modes of operation. This will ensure that the fuel design safety criterion (i.e'.,'that at least 99.9% of the fuel rods do not experience transition boiling during normal operation and anticipated operational occurrences) is met. Since the proposed change does not affect operability of

-plant systems designed to mitigate any consequences of accidents, the consequences of an accident previously evaluated are not expected to increase.

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

Does the proposed change create the possibilityof a new or differentkind of accident from any accidentpreviouslyevaluated?

Creation of the possibility of a new or different kind of accident would require creating one or more new precursors of that accident. New accident precursors may be created by modifications of plant configuration,'including changes in allowable modes of operation. The proposed change does not involve any plant configuration modifications or changes to allowable modes of operation. The proposed change to the SLMCPR assures that safety criteria are maintained for QCNPS, Unit 2, Cycle 18.

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

Does the proposedchange involve a significantreduction in a margin of safety?

The SLMCPR provides a margin of safety by ensuring that at least 99.9% of the fuel rods do not experience transition boiling during normal operation and AQOs if the MCPR limit is not violated. The proposed change will ensure the appropriate level of fuel protection. Additionally, operational limits will be established based on the proposed SLMCPR to ensure that the SLMCPR is not violated during all modes of operation. This will ensure that the fuel design safety criteria (i.e.,-that no more than 0.1% of the rods are expected to be in boiling transition if the MCPR limit is not violated) are met.

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

Page 4 of 6

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis Based on the above, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 APPLICABLE REGULATORY REQUIREMENTS AND CRITERIA 10 CFR 50.36, Technical specifications," paragraph (c)(1), requires that power reactor facility TS include safety limits for process variables that protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity. The fuel cladding integrity SLMCPR is established to assure that at least 99.9% of the fuel rods in the core do not experience boiling transition during normal operation and A0Os. Thus, SLMCPR is required to be contained in TS.

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

6.0 ENVIRONMENTAL CONSIDERATION

S In accordance with 10 CFR'50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) is requesting changes to the Technical Specifications (TS) for the Quad Cities Nuclear Power'Station (QCNPS); Unit

2. The proposed change revises the values of the Safety Limit Minimum Critical Power Ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs," to 1.09 for two loop operations, and to 1.10 for single loop operation for Unit 2, Cycle 18. The proposed amendment also incorporates an editorial change to TS Section 2.1.1 to provide consistency between Unit 1 and Unit 2.

EGC evaluated the proposed change against the criteria in 10 CFR 51.21, "Criteria for and identification of licensing and regulatory actions requiring environmental assessments." EGC determined that the proposed change meets the criteria for a categorical exclusion as set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or.

otherwise not requiring environmental review," paragraph (c)(9). EGC determined that no irreversible consequences exist, in accordance with 10 CFR 50.92, "Issuance of amendment," paragraph (b); This change is proposed as an amendment to a license issued pursuant to 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities," which changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation," or that changes an inspection or a surveillance requirement, and the amendment meets the following criteria:

(i) The amendment involves no significant hazards consideration.

As demonstrated in Section 5.1, this proposed change does not involve any significant hazards consideration.

Page 5 of 6

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis (ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released.

The proposed change revises the SLMCPR. It does not allow for an increase in the unit power level and does not increase the production, nor alter the flow path or method of disposal, of radioactive waste or byproducts. Therefore, the proposed change does not affect the actual unit effluents.

(ii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed change will not result in changes in the configuration of the facility.

There will be no change in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposal result in any change to the normal radiation levels within the plant.

Therefore, there will be no increase i individual or cumulative occupational radiation exposure resulting from this change.

7.0 REFERENCES

1. Letter, Frank Akstulewicz (NRC) to Glen A. Watford (GE), "Acceptance

- for Referencing of Licensing Topical Reports NEDC-32601 P, Methodology and Uncertainties for Safety Limit MCPR Evaluations; NEDC-32694P, Power Distribution Uncertainties for Safety Limit MCPR Evaluation; and Amendment 25 to NEDE-2401 1-P-A on Cycle Specific Limit MCPR," March 11, 1999

2. GEXL96 Correlation for ATRIUM-9B fuel, NEDC-32981-P-A, Rev. 1, May 2002 Page 6 of 6

ATTACHMENT 2

- Markup of Technical Specifications Page

SLs 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core' SLs

' 2.1.1.1 With the reactor steam dome pressure < 785 psig or core flow < iO% rated core flow: -

THERMAL POWER shall be's 25% RTP.

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

For Unit 1, MCPR shall be 2 1.10Ofor two recirculation loop operation or 1.11 for single recirculation loop operation.

For Unit 2, MCPR shall be .09 for two recirculation loop perationor 2 1.10l for single recirculation loop operation, DD s h >

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

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

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

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

Quad Cities 1 and 2 2.0-1' Amendment No. 210,195,

ATTACHMENT 3 Retyped Technical Specifications Page

SLs 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs

• 2.1.1 .Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 psig or core

• flow < 10% rated core flow:

THERMAL POWER shall be 25% RTP.'

2.1.1.2 With'the reactor steam dome pressure 2 785 psig and core

.flow 10% rated core flow:

For Unit 1, MCPR shall be 1.10 for two recirculation loop operation.or 1.11 for single recirculation loop operation.

For Unit 2, MCPR shall.be 2 1.09 for two recirculation loop operation or '1.10 for single recirculation loop operation.

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

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall.be*s 1345-psig.

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

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

Quad Cities 1 and 2 2.0 -1 Amendment No.

ATTACHMENT 5 Affidavit and Additional Information Regarding the Cycle Specific'SLMCPR for Quad Cities Unit 2 Cycle 18 (GNF Non-Proprietary)

Affidovit Affidavit I, Jens G. Andersen, state as follows:

(1) I am Fellow and project manager, TRACG Development, Global Nuclear Fuel -

Americas, L.L.C. ("GNF-A") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in the attachment, "Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18," October 13, 2003.. GNF proprietary information is indicated by enclosing it in double brackets. In each case, the superscript notation (3)refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.790(a)(4) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption

- 4). The material for which exemption from disclosure is here sought is all "confidential commercial information,? and some portions also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975F2d871 (DC Cir. 1992), and.

Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).

(4) Some examples of-categories of information which fit into the definition of proprietary information are:

a. .-Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;

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

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

Affidavit -

The information sought to be withheld is considered to be proprietary forthe reasons set forth in paragraphs (4)a. and (4)b., above.

' (5) To address the 10 CFR 2.790 (b) (4), the information sought to be withheld is

- being submitted to NRC in confidence. The information is of a sort customarily held in confidence byGNF-A, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or

' subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate

' need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.

The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GNF-A or its licensor.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial 'harm to GNF-A's competitive position and foreclose or reduce the' availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A or its licensor.

Affidavit The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the'.

results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors

• without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-

• A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable

• analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed at Wilmington, North Carolina, this 14th day of October, 2003.

Jens G. Andersen Global Nuclear Fuel - Americas, LLC

Attachment Additional Information Regarding the October 13, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 References

[1] .Letter, Frank Akstulewicz (NRC) to Glen A. Watford (GE), "Acceptance for Referencing of Licensing Topical Reports NEDC-32601P, Methodology and Uncertaintiesfor Safety Limit MCPR Evaluations;NEDC-32694P, PowerDistribution Uncertaintiesfor Safety Limit MCPR Evaluation; and Amendment 25 to NEDE-240 11 -P-A on Cycle Specific Safety Limit MCPR,'" (TAC Nos.

M97490, M99069 and M97491), March 11, 1999.

[2] Letter, Thomas H. Essig (NRC) to Glen A. Watford (GE), "Acceptance for Referencing of Licensing Topical Report NEDC-32505P, Revision 1,R-FactorCalculationMethodfor GEII, GE12 and GE13 Fuel," (TAC No. M99070 and M9508 1), January 11, 1999.

[3] GeneralElectricBJUR ThermalAnalysis Basis (GETA B): Data, CorrelationandDesign Application,NEDO-10958-A,January 1977.

[4] Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of 10x10 Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies", FLN-2001-016, September 24,2001.

[5] Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Confirmation of Applicability of the GEXL14 Correlation and Associated R-Factor Methodology for Calculating SLMCPR Values in Cores Containing GE14 Fuel", FLN-2001-017, October 1,2001.

[6] GEXL96 Correlation for ATRIUM-9B Fuel, NEDC-32981P-A, Rev. 1, May 2002..

[7] Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Final Presentation Material for GEXL Presentation - February 11, 2002", FLN-2002-004, February 12, 2002.

Comparison of Quad Cities Unit 2 SLMCPR Values for Cycles 18 and 17 Table 1 summarizes the relevant input parameters and results of the SLMCPR determination for the Quad Cities Unit 2 Cycle 18 and 17 cores. The SLMCPR evaluations for Cycle 18 were performed using NRC-approved methods and uncertainties 11 , supplemented with Quad Cities Unit 2 specific uncertainties as indicated in Table 2. These calculations use the GEXL14 correlation for GE14 fuel and GEXL9616 ] for the FANP fuel.

(( )) The, dual loop operation (DLO) and single loop operation (SLO) SLMCPR values calculated for Cycle. 18 of Quad Cities Unit 2 are shown in Table 1. Other quantities that have been shown to have some impact on the determination of the SLMCPR are also shown in Table R1

((1))

In comparing the Quad Cities Unit 2 Cycle 18 and Cycle 17 SLMCPR values it is important to note the impact of the differences in the core and bundle designs. These differences are summarized in Table 1.

(( GNF Proprietary Information)) . page 1 of 7

((enclosed by double brackets.))

Attachment Additional Information Regarding the October 13, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 In general, the calculated safety limit is dominated by two key parameters: (1) flatness of the core bundle-by-bundle MCPR distributions and (2) flatness of the bundle pin-by-pin power/R-factor distributions. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR.

(( )):

Pin-by-pin power distributions'are characterized in terms of R-factors using the NRC approved methodology[2 1 ; (())

Summary

(()) have been used to compare quantities that impact the calculated SLMCPR value. Based on these bundle and core design considerations, the calculated 1.09 Monte Carlo SLMCPR for Quad Cities Unit 2 Cycle 18 is consistent with what one would expect ((1] the 1.09 SLMCPR value is appropriate.

Based.on all of the facts, observations and arguments presented above, it is concluded that the calculated SLMCPR value of 1.09 for the Quad Cities Unit 2 Cycle 18 core is appropriate.

For single loop operations (SLO) the calculated safety limit MCPR for the limiting case is 1.10 as determined by specific calculations for Quad.Cities Unit 2 Cycle 18.

Supporting Information '

The following information is provided in response to NRC questions on similar submittals regarding changes in Technical Specification values of SLMCPR. NRC questions pertaining to how GEI4 applications satisfy the conditions of the NRC SERI'1 have been addressed in Reference [4]. Other generically applicable questions related to application of the GEXL14 correlation and the applicable range for the R-factor methodology are addressed in References

[5] and [7]. Only those items that require a plant/cycle specific response are presented below since all the others are contained in the references that have already been provided to the NRC.

The core loading information for Quad Cities Unit 2 Cycles 17 and 18 is provided in Figures 1 and 2, respectively.

The power and non-power distribution uncertainties that are used in the analyses are indicated in Table 2. The referenced document numbers have'previously been reviewed and approved by the NRC. The SER (Reference [1]) specifically provides that higher uncertainty values be used when necessary as was the case for this SLMCPR evaluation for Quad Cities Unit 2 Cycle 18.

((GNF Proprietary Information)) page 2 of 7

((enclosed by double brackets))

Attachment Additional Information Regarding the October 13, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 Prepared by: Verified by:

AimdVL H. ZhaIj--

H. Zhang

• R. Szilard Technical Program Mahager Exelon Technical Manager

(( GNF Proprietary Information )) page 3 of 7

(( enclosed by double brackets.))

Attachment ' Additional Information Regarding the - October 13, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 Table Comparison of the Quad Cities Unit 2 Cycle 18 and Cycle 17 SLMCPR QUANTITY, DESCRIPTION Quad Cities Unit Quad Cities Unit 2 Cycle 17 2 Cycle 18 Number of Bundles in Core 724 - 724 Limiting Cycle Exposure Point EOC EOC Cycle Exposure at Limiting Point MWd/MTUI 14,991 15,000 Reload Fuel Type GE14 GE14 Latest Reload Batch Fraction [%] 37.0% 33.1%

Latest Reload Average Batch Weight % 4.07% 3.99%

Enrichment Batch Fraction for GE14 37.0% 70.2%

Batch Fraction for ATRIUM-9B 63.0% 29.8%

Core Average Weight % Enrichment 3.87% 3.97%

Core MCPR (for limiting rod pattern) 1.52 1.49 rr . 11 Power distribution uncertainty See Table .2, See Table 2, Column 2 - Column 2 Non-power distribution uncertainty See Table 2, See Table 2, Column 2 Column 2 Calculated Safety Limit AMCPR (DLO) 1.11 1.09 Calculated Safety Limit MCPR (SLO) 1.12 1.10

(( GNF Proprietary Infornation )) page 4 of 7

(( enclosed by double brackets ))

'Attachment Additional Information Regarding the , October 13, 2003

• Cycle Specific SLMCPR.for Quad Cities Unit 2 Cycle 18 Table 2 Comparison of Quad Cities Unit 2 Specific Inputs to NRC-accepted Values COLUMN 1 . COLUMN 2 DESCRIPTION 'Uncertainty Values (%) Quad Cities Unit 2.

previously accepted by Specific Values (%)

_ _._ _ N RC .

Non-power Distribution From Table 2.1 of Uncertainties NEDC-32601P-A .. _ .._ '_ .

Core flow rate (derived from pressure (( )) TLO. (( )) TLO drop) . '. (( ))SLO . (())SLO Individual channel flow area (( )) . (( ))

Individual channel friction factor (( )) '(( ))

Friction factor multiplier .. . (( )) (( ))

Reactor pressure . (( )) . ' .'(( ))

Core inlet temperature .. ' (( ]I. . (( ))

Feedwater temperature (( ' (( ))

Feedwater flow rate' (( )) (( )) Cycle 18

.[ JrCycle 17 Power Distribution Uncertainties GETAB uncertainties as Specific Values (%)

consistent with the Revised used to produce values Methodology of NEDC-32601P-A shown in Table 4.1 of .

.__.__.__.,__________.__ . NEDC-32601P-A .

GEXL R-factor . (( )) [ ]

Random effective TIPreading . . (( ]I TLO (( )) TLO

.___.__.___.__.__.__ - (( ))SLO ] SLO Systematic effective TIP reading. (( )) ((]

Integrated effective TIP reading (( )) . ((1]

Bundle power - (( )) . (( ))

Effective total bundle power ' '

uncertainty . ._,,,_,,_.

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(( enclosed by double brackets ))

Attachment Additional Information Regarding the October 13, 2003 Cycle Specific SLMCPR for Quad Cities Unit 2 Cycle 18 Figure 1 Reference Core Loading Pattern - Cycle 17 I 2 3 .4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Al A A A A1

. . . I ..

A AI 77 .

]. 60 2 BI AI. A I B I A I B A B A I A B .

3 _ A_ AI I cC A I CI CI CI C C C C* C I I AIA ll IA

• A _ -56

_ _ l _ I l l l __ _ ll l l _

4 A I A B B1I EI E E E E E E EIb I I IB AIA B 54 5 A IA IB D I FI E IE E D D E D IE I FI E I B AIA 52

_ l l

• I I _ _ .

6 A IA IA IC IE IE CIE ID F I C F F C FI D I CIE I EI CIA A E 80 A A B C A ID F CI F I C C F CI F c1 I EI I AI C B A A 48 A B E D4 E C B , D F C F F CJF B CF rE D ED 0 B A 46 8

A 8 F E E IF IC E F D F

C C F

D I E F CI F E E F B A1 .44

• 10 B A B E C F C F C F C F D E E D F F C F C F C E B A B 42 11 A A C D F E C B E F A C E F C c E C A F E B C E F D C A A 40 12 A CA E E ID C D D C A F D A A D F A C D F C F D E E C A A 38 13 A B C E C F C F C F E C DF D D F D E D F C F D E C B A 36 14 A A C E IE C F C FI D F D F D F F F C F D F C F. C E E C A A 34 15 A B C E D F C I. C C A C F A A F D A C E C *F C F D E. C B A 32 16 A B C E D F C F C E C -A C F A A F D A C E C F C F D E C B A 30 17 A A C E E C F C FID F D F r F F D F F D F. C F C E E C A A 28 18 A B C 'E D F C F D F E F C F D D F C E D F C F D E C B A 26 19 A A C 6 6 C F C F C C A F D A A D F A C D F D F D E E C A A 24 20 A A7 C CD F 6 C 6 F A C 6 F C *C. F E C A F E B C E F D C A A 22 21 B A B E C F C F C F.D F DC E D F D F C F cF C E6 B A B 20

~~~~~~~~ 6 .IF[lFI D F E F CI F E E BI 22 A l' F E E F CAIBIFIEI6IFICIFI6IFICIFI.C~E F D F C C F F

.B 18 23 DF C F ID F IC F D B CI FIEIDI EID B A 16 A A B C A D E F CC F C F E D A 24 A IA IA IC IE IE IC IE ID IF - -- - .- -

F C

CC F

FC C

- - . . . .A CI B A

. A 14 12 25 D . E . C . E . E IC I A A

. - IE - IF - IE I- - _ . .

F. . F .

E 26 A IA IBI DIF E D D E D EI FI IF ID IB AIA 10 27 AIA IB I IB EIE E E E E I 4-1 E E D 1-81- F BI0 AIA 4.

08

- -4.- 4.-4.- +-4. - -t 9- - - -

28 A IA IA IA Ic C Ic cIC C C C C C A A A' A 06 29 B A IA IB IA IB B A B1_ Al _ Al _

B 04 30 A IA IA IA IA A A IA IA IA 02 01 03 05 07 09 11 13 i5 . 17 19 21 23 25 27. 29 31 33 35 31 39 41 43 45 47 49 51 53 55 55 59 Number BundleNane -Core Ledd CIsb .

A ATRM9P9DATB372. 1GZ-SPC10T4WR-144-T64 152 15 B ATRM94P9DATB358-11GZ4SPC100T4WR1l44-T6B 64 15 C ATRMO-P9DAT383-11 GZSPCIOT-4WR-144-T64 136 16 C ATRM9BDATB381-13GZ-SPCOOT4WR-144-T6. 104 . . 16 E GE14-PIODNAB409-15GZ-100T-145-T6-2507 16 17 -

F GE14-PIWDNAB4O6-6ZOOT-145T6-2538 152 17 Toel 724

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Attachment Additional Information Regarding the . October 13, 2003 Cycle Specific SLMICPR for Quad Cities Unit 2 Cycle 18 Figure 2 Reference Core Loading Pattern - Cycle 18 2 2 4 5 6 7 8 I9 10 11 T12 13 14 15 16 17 1t 19 20 21 22 23 24 25 26 27 28 29 30

- l. B B B I B Bl B *60 2 B A A A A A AIA I AI IAIB 58 2 'B I B' B A IJC I A A C C A A C C IA BI BI B 56 4 B I A IAI A A D' C C D E E D C C D ,A A A A B 54 s A A I '^ ID E E E E C C E E E E I D Il

9) l A I A _ 52 Al A A IAC CIEE B EICIOIAIA1AIA I AIA I C F I C F C E E C F C Fll E C I C I A lIAI A I B 50 IA A E IF IE . F C F D D F C F DI E F iE iD IA IA IA B 48 A IC IE ID E ID F IC IF D I F DI F C D E D E C A A 8 46 9 ID CII FIE C IF D IF F D D F F D F IC IE IF IC ID A IB 44 10 B A A D E E F D F D F C F F D F F F D E E D A A A l 42 16 1i a B A C D E *F D F D F D F C F C C F C F D F D F D F E D C A B 40 7

12 B A lC C E. C F. C F D F C F D F F D F D F F C F C E C C A

, 38 18 A A C E F C F D F C F D F C D F D F C F C F C F E C A 'A 14 A A D E C F C F C F D F C F.F C F C F 0 F C F C E 0 A A A C C E D F D F C F D F D D F D F C F D F D E C E C A B 2 16 B A C E C E D F C F C F D F DC F D F C F D F D E C E C A 0 20 17 B A A D E C F C F D F D F D F F D F C F D F D F C E D A A B 28 18 B A A C E F C F. D F C F D F D D F D F C F C F *C F E C A A 19 B A C C C F C F C F C F D F F' D F D F D F C F C E C C A B 24 25* 0 B S A C E F C F C F C F C F C C F C F C F D F D F E C C A B 22

• 20 B A lA E E F F D F D F F D F D F 0 F C E E C A A B 20 B- AI D)IC1 F E .C F IC F D F ID C F F 0 F C E F C D A B 22 to B A IC IE II E P1 F C F F F CCFF E D E C A I

• 1 A A ID E F E D F CI F D D F C F D E F E D A A 14 B A 25 LB' A A A CI C E F C F C E E C F C F .E C CI A A 'A B 12 26 . A IA IA IA D D E E E E ,C C E E E E D D A IA IA IA 10

- I - I- - +- +- I- - F - +- - +- - - t - F- F - F - F -t-t 4-27 I A1 A I A A I D C C D IE E D IC IC I A A A A l ec BI lB Al C ICI A A C IC A IA IC C IA B 0o BI B 29" B A A A A A IA Al Al A Al B 04 J0 l1 lI lI l1 lI l B I B I B I B 02 01 03 05 07 09 11 130 5 17 19 21 23 25 27 29 312 JJ 35 X7 09 40 42 5 47 49 51 53 55 87 59 Nurter hI Cyde BumcflNanme Core ded A ATRM9-PBDATB383-11GZ-PC1OOT.WR-144-T6-3918 136 16 B ATRM9-P9DATB381-13GZ-SPC10T.WR-144-T63919 so0 .is C GE14-PIDNAB40915GZ-100T-145-T6-2507.

D GE14-PIODNAB406-16GZ-1 00T*45-T6-2508 152 17 E GEI4-PI0DNA8418-16GZ-10DT.145-T6-2646 s0 18 F GE14-P1cDNA9389-180Z.1OOT145-T6-2650 - 160 IB Tcdl 724

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