ML101100608

Removal of Mixing Vane Grid Spacing Restriction in Appendix B to Fleet Report DOM-NAF-2-A, Response to Request for Additional Information

ML101100608
Person / Time
Site:	Millstone, Kewaunee, Surry, North Anna
Issue date:	04/16/2010
From:	Price J Dominion Energy Kewaunee, Dominion Nuclear Connecticut, Dominion Resources Services, Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
09-528B, FOIA/PA-2011-0115
Download: ML101100608 (12)

Text

Dominion Resources Services, Inc.

,11011 I)ominion Boulevard, Glen Allen, V,\ )'"

,\ ,*b \ddress: www.dom.corn April 16, 2010 U.S. Nuclear Regulatory Commission Serial No. 09-528B Attention: Document Control Desk NL&OS/GDM R1 Washington, DC 20555 Docket Nos. 50-305 50-336/423 50-338/339 50-280/281 License Nos. DPR-43 DPR-65/NPF-49 NPF-4/7 DPR-32/37 DOMINION ENERGY KEWAUNEE, INC.

DOMINION NUCLEAR CONNECTICUT, INC.

VIRGINIA ELECTRIC AND POWER COMPANY KEWAUNEE POWER STATION MILLSTONE POWER STATION UNITS 2 AND 3 NORTH ANNA POWER STATION UNITS 1 AND 2 SURRY POWER STATION UNITS 1 AND 2 REMOVAL OF MIXING VANE GRID SPACING RESTRICTION IN APPENDIX B TO FLEET REPORT DOM-NAF-2-A RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION In an August 28, 2009 letter (Serial No.09-528), Dominion Energy Kewaunee, Inc.,

Dominion Nuclear Connecticut, Inc., and Virginia Electric and Power Company (collectively "Dominion") requested NRC approval to remove a mixing vane grid spacing restriction contained in Appendix B of Fleet Report DOM-NAF-2-A, "Qualification of the Westinghouse WRB-1 CHF Correlation in the Dominion VIPRE-D Computer Code."

Specifically, the subject restriction states that "VIPRE-DIWRB-1 will not be used for fuel with less than 13" mixing vane grid spacing." Dominion provided technical justification for removing the restriction in the August 28, 2009 letter. In addition, Dominion provided supplemental information in a subsequent letter dated November 20, 2009 (Serial No.

09-528A.)

In an e-mail dated March 9, 2010, the NRC provided a draft request for additional information (RAI) associated with Dominion's submittals. A conference call was held on March 16,2010 to discuss the questions contained in the RAI, and at the conclusion of the call, Dominion stated that it would formally respond to the RAI on the docket.

Dominion's response is provided in the attachment.

Serial No. 09-5288 Docket Nos. 50-305/336/423/338/339/280/281 Page 2 of 3 If you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Sincerely, r

J. AI n ce Vic Pr sident - Nuclear Engineering Do i . n Energy Kewaunee, Inc.

Dominion Nuclear Connecticut, Inc.

Virginia Electric and Power Company

Attachment:

• Response to Request for Additional Information, Removal of the Grid Spacing Restriction in Appendix B to Fleet Report DOM-NAF-2-A Commitments made in this letter None cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406-1415 U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 U.S. Nuclear Regulatory Commission Region III 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 Mr. P. S. Tam NRC Senior Project Manager - Kewaunee Power Station U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8 H4A Rockville, Maryland 20852-2738

Serial No. 09-5288 Docket Nos. 50-305/3~16/423/338/339/280/281 Page 3 of 3 Ms. C. J. Sanders NRC Project Manager - Millstone Power Station Units 2 and 3 U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8 B1A Rockville, Maryland 20852-2738 Ms. K. R. Cotton NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station

Serial No. 09-5288 Docket Nos. 50-305/336/423/338/339/280/281 ATTACHMENT Response to Request for Additional Informaticm Removal of the Grid Spacing Restriction in Appendix B to Fleet Report DOM-NAF-2-A DOMINION ENERGY KEWAUNEE, INC.

DOMINION NUCLEAR CONNECTICUT, INC.

VIRGINIA ELECTRIC AND POWER COMPANY KEWAUNEE POWER STATION MILLSTONE POWER STATION UNITS 2 AND3 NORTH ANNA POWER STATION UNITS 1 AND 2 SURRY POWER STATION UNITS 1 AND 2

Serial No. 09-5288 Docket Nos. 50-305/336/423/338/339/280/281 Attachment Response to Request for Additional Informaticm Removal of the Grid Spacing Restriction in Appendix B to Fleet Report DOM-NAF-2-A Introduction By letter dated August 28, 2009 (Reference 1), Dominion Enerqy Kewaunee, Inc.,

Dominion Nuclear Connecticut, Inc., and Virginia Electric and Power Company (collectively "Dominion") requested NRC approval to remove a mixing vane grid spacing restriction contained in Appendix B of Fleet Report DOM-NAF-2-A (Reference 2),

"Qualification of the Westinghouse WRB-1 CHF Correlation in the Dominion VIPRE-D Computer Code." Specifically, the subject restriction states that "VIPRE-DIWRB-1 will not be used for fuel with less than 13" mixing vane grid spacing." Dominion provided the technical justification for removing the restriction in the subject letter (Reference 1).

Dominion provided supplemental information to further support the request and to facilitate NRC review in a November 20, 2009 letter (Reference 3). The NRC accepted the Dominion request for review via Reference 4.

The NRC staff forwarded by email a draft Request for Additional Information (RAI) to complete the review of the proposed change that consisted of five questions (Reference 5). A teleconference was held on March 16, 2010 between the NRC and Dominion staff to discuss the draft questions. The questions were finalized and the aforementioned email became a formal RAI (Reference 5). Dominion's response to the RAI questions is provided herein.

Background

Appendix B of DOM-NAF-2-A documents Dominion's qualification of the WRB-1 correlation with the VIPHE-D code. Table B.8-1 lists the departure from nucleate boiling ratio (DNBR) design limit of 1.17 for VIPRE-DIWRB-1, which is the value that yields a 95% non-DNB probability at a 95% confidence level (95/95 limit). Appendix B also includes a restriction that states "VIPRE-DIWRB-1 will not be used for fuel with less than 13" mixing vane grid spacing." The purpose of this restriction was to preclude the use of the VIPRE-DIWHB-1 code/correlation with Westinghouse fuel with Intermediate Flow Mixing Vane grids (IFM), which have a nominal 13" grid spacing. The restriction was originally placed on WRB-1 in the issuance of the Safety Evaluation Report (SER) for the COBRAlWRB-1 topical report, VEP-NE-3-A (Reference 6). When the VIPRE-D fleet report was developed, the restriction from the COBRA SER was included in the WRB-1 qualification in Appendix B of DOM-NAF-2-A (Reference 2).

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Serial No. 09-5288 Docket Nos. 50-305/336/423/338/339/280/281 Attachment In Reference 7 the NRC issued a license amendment for the Indian Point Nuclear Generating Unit No. 3 (IP3) to accommodate the transition from VANTAGE 5 fuel without IFMs to VANTAGE+ with IFMs for Cycle 10. In Section 2.3 of the safety evaluation for that amendment, the NRC staff stated:

"The Westinghouse rod bundle critical heat flux (CHF) correlation, WRB-1, predicts critical heat flux in rod bundles based on subchannel local fluid conditions. This correlation was initially approved for the standard 14X14, 15X15 and the 17X17 standard Westinghouse fuel (lI\lCAP-8762).

Evolution of the standard 17X17 and 15X15 fuel have been developed by Westinghouse and their behavior simulated by using an NRC-approved scaling technique. This scaling technique was validated for all four of the different 17X17 fuel types, but not for the 15X15 OFA and the VANTAGE+

(w/IFMs) fuel. No testing was conducted to verify that the scaling technique applied to the 15X15 standard fuel; however, cycle 10 analyses has shown that there is substantial departure from nucleete boiling ratio (DNBR) margin. Consequently, until such time as fuel tests are conducted on the 15X15 VANTAGE+ (w/IFMs) to validate the scaling technique and the applicability of the WRB-1 correlation, [it] is acceptable for the upcoming cycle -, 0 only. Also, DNB analyses must be submitted to the staff for review and approval prior to cycle 11."

Westinghouse conducted confirmatory DNB testing on the 15X1' 5 VANTAGE+ fuel design with IFMs in December 1998 and January 1999. The DNB test results were discussed with the NRC during a March 17, 1999 meeting. Westin!~house documented this meeting in a letter to the NRC dated March 29, 1999 (Reference 8). The measured and predicted critical heat flux for the range of the experimental data were used to statistically determine the 95/95% DNBR limit. The test data yielded a limiting DNBR value of 1.114, which is less than the WRB-1 design limit of 1.17. The results of this testing demonstrated that the use of the WRB-1 correlation for the 15X15 VANTAGE+

fuel with IFMs was conservative and confirmed its applicability for this fuel type.

Westinghouse concluded that the DNB tests verified the application of the WRB-1 correlation with a 95/95 correlation limit of 1.17 to the 15X15 VANTAGE+ fuel.

Subsequently, in Refer,ence 9 the NRC issued a license amendment to remove a footnote in the IP3 TSs stating "Current DNB analysis contains adequate margin for Cycle 10. Prior to achieving criticality in Cycle 11, the DNB analysis must be reviewed and approved by the NRC staff." In the associated SER, the NRC staff stated:

"The NRC staff reviewed the conditions of Amendment 175 safety evaluation and the presentation of the DNB test results documented in a letter from Westinghouse dated March 29, 1999. The restriction in the footnote of TS Section 3. 1 was intended to ensure that adequate DNB margin would exist on cycle-specific basis until the fuel vendor Page 2 of 8

Serial No. 09-5288 Docket Nos. 50-305/3:36/423/338/339/280/281 Attachment demonstrated the applicability of the WRB-1 correlation to the 15X15 VANTAGE+ fuel design. The staff reviewed the licensee's amendment request and the documentation of the DNB tests pertormea by Westinghouse and determined that, because the new test data yielded a DNBR lower than the bounding limit of 1.17, the WRB-1 correlation is applicable to the 15X15 VANTAGE+ fuel; therefore, use of the WRB-1 correlation is acceptable for 15X15 VANTAGE+ fuel beyond Cycle 10 and removal of the footnote is acceptable. The DNB testing obviates the need for using the scaling technique; therefore, any question as to the acceptability of this technique is no longer relevant. "

Thus, the NRC approved the application of the Westinghouse WRB-1 correlation with 95/95 correlation limit of 1.17 to the 15X15 VANTAGE+ fuel with IFMs.

Westinghouse submitted Reference 10 to the NRC, which described evaluations performed for the 15x15 Upgrade fuel design. This submittal served as Westinghouse notification to the NRC, as required by the SER on Westinghouse Fuel Criteria Evaluation Process (FCEP), that the NRC-approved process in WCAP-12488-A (Reference 11) was used for the validation of the WRB-1 DNB correllation applicability to the 15X15 Upgrade fue! design. The Westinghouse FCEP specifies the guidelines relevant to determine correlation applicability to a new grid design. In Reference 10, Westinghouse presented the results of the evaluation process and concluded that the WRB-1 DNB correlation with 95/95 correlation limit of 1.17 and the associated correlation ranges are acceptable for application to the 15X15 Upqrade fuel assembly design.

Dominion employed a two-step process to confirm two necessary methodology elements for analysis of the 15x15 Upgrade design. First, it was necessary to confirm the applicability of the qualification of the VIPRE-DIWRB-1 qualification as documented in Appendix B of DOM-f\IAF-2-A to the Westinghouse 15X15 Upgrade fuel product. The second element was to support removal of the 13" grid spacing restriction. As a first step, Dominion replicated the Westinghouse evaluation of the confirmatory CHF test data and provided the results of this evaluation to the NRC in References 1 and 3.

Reference 1 summarized the Dominion results in narrative terms. Reference 3 provided the detailed numerical and technical description of the Westinghouse proprietary data and data analysis. No significant differences were found between the Westinghouse and VIPRE-D results. The application of VIPRE-DIWRB-1 with H5/95 DNBR limit of 1.17 was demonstrated to be conservative for grid spacings of 13" for 15X15 fuel (i.e.,

15X15 fuel with IFMs). The second step of the process applies the conclusions of the Westinghouse FCEP evaluation for the 15X15 Upgrade in Reference 10. Therefore, Dominion has concluded that the VIPRE-DIWRB-1 design limit of 1.17 and associated statistics can be conservatively applied to the safety analysis of the Westinghouse 15X15 Upgrade fuel product with IFMs.

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Serial No. 09-5288 Docket Nos. 50-305/336/423/338/339/280/281 Attachment It is with respect to the 'first step described in the above paragraph that the NRC staff provided an RAI to complete the review of the proposed change in References 1 and 3.

Dominion's response to the RAI questions is provided below.

NRC Question 1 11120109 supplement, page 4 of 8, Equation 2, reference is made to the T-statistic test.

It appears that this should be the F-Statistic test. The same applies in the sentence above the equation, "comparing T statistic" should be "comparing F-statistic. "

Dominion Response Dominion understands that the NRC staff requires clarification of the terminology used in Equation 2 and associated paragraphs on page 4 of 8 of RefE~rence 3. Dominion utilized the F-Test to determine whether the variances for the WRB**1 database and the test data are equal as discussed on page 4 of 8 of the supplemental material dated November 20, 2009. However, in Equation 2, and in the preceding and following sentences, reference is made to the "T statistic". The 'T" used here identifies the specific calculation of the test statistic for use in the F-Test and did not refer to the use of the T-Test as is discussed on page 5 of the supplement. In each instance on page 4 where "T" or "T statistic" is used, substitute "F" or "F statistic", as shown below.

"The hypothesis is tested by comparing the F statistic ... " (2nd paragraph) 52 "F = 2 WRBI " (Equation 2) 5 t est data

"... since the F statistic is less than ... " (3fd paragraph)

NRC Question 2 11120109 supplement, Page 4 of 8, Table 1, row 5.

(a) =

Is sigma cetcuteteo using nor N n-1 in the denominator?

(b) What is the standard deviation corrected for?

(c) The correction factor (n-1)IN are identically 1 (one). What is accomplished by taking the square root of 1?

Dominion Response The calculation of the DNBR limit as described in Table 1 of Reference 3 for Test 100 was arranged in a form to be consistent with the previously reviewed calculation of the DNBR design limit for VIPRE-DIWRB-1 code/correlation as described in Table B.6-2 in Appendix B of DOM-NAIF-2-A (Reference 2).

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Serial No. 09-5288 Docket Nos. 50-305/3~~6/423/338/339/280/281 Attachment The qualification of the VIPRE-DIWRB-1 code/correlation in Appendix B of DOM-NAF-2-A utilized 945 data points from 19 test series (n). Normally, the number of degrees of freedom (N) would be the total number of data minus one (n-1). However, because Westinghouse used these experimental data to correlate the 12 constants that appear in the WRB-1 correlation, the total number of degrees of freedom was corrected to account for this. Thus, the standard deviation of the database in Appendix B (aM/p) was corrected accordingly to account for this reduced number of degrees of freedom.

Equation B.6.2 of Reference 2 N =n - 1 - 12 O"N =O"M/P' [ (n -1) / N ] %

The DNBR design limit for the test data from Test 100 with VIPRE-DIWRB-1 code/correlation is calculated as described in Table 1 of Reference 3. The calculations in Table 1 are identical to those described in Table B.6-2 in Appendix B of DOM-NAF A. In Table 1, the Stanclard Deviation (sigma) of the test data is calculated using n-1.

The number of degrees of freedom is the total number of data minus one. No additional correction to the degrees of freedom is necessary to account for the correlation of the 12 constants. Hence, the correction factor, (n-1)/N, is identically 1 (one).

The specific responses to the questions are then:

(a) The standard deviation of the sample population, sigma or aM/p, is determined using n-1 in the denominator.

(b) The standard deviation of the database may be corrected to account for a reduced number of degrees of freedom. The number of degrees of freedom is the total number of data minus one. No additional correction to the degrees of freedom is necessary to account for the correlation of the 12 constants. Thus, for Test 100, the number of degrees of freedom, N, is equal to n-1.

(c) The Corrected Standard Deviation, ON, is determined by multiplying the Standard Deviation of the sample, aM/p, by the correction factor, which is the ratio of (n-1)IN. The value of this correction factor is identically one.

Thus, the Corrected Standard Deviation is equal to the Standard Deviation of the sample. The purpose of presenting the calculation of the DNBR design limit for Test 100 as described in Table 1 of Reference 3 is to provide a calculation comparable in all ways to the established method of Table B.6-2 in Appendix B of DOM-NAF-2-A.

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Serial No. 09-5288 Docket Nos. 50-305/336/423/338/339/280/281 Attachment NRC Question 3 11/20/09 supplement, Page 6 of 8, Figure 2. There is only one data point for low quality

<< -0.1) and only one point for high quality (>0.2).

Dominion Response The qualification of the VIPRE-DIWRB-1 code/correlation in Appendix B of DOM-NAF-2-A utilized 945 data points from 19 test series. Westinghouse conducted confirmatory DNB testing on the 15)(15 fuel design (with Intermediate Flow Mixers) in December 1998 and January 1999. Only one test series was run (Test 100). It is to be expected that the range for the local conditions for Test 100 would be smaller and a subset of those in the 19 test series.

NRC Question 4 8/28/09 submittal, page 2 of 6, the last sentence of the 4th paragraph provides the ranges of operation for the VIPRE-D code. Comparing these ranges with the plots provided in attachment l' of supplemental information for DOM-NAF-2-A, one notes that discrepancy exists between the tabulated data and the plotted data for both the Mass Flux and Local Quality. The upper end range of the Mass flux is less (-2.9), versus the tabulated value of 3.7. Similarly, the upper end of the quality is less than .2, while the tabulated data is .3. Please provide a table containing the operational ranges of the fuel in question.

Dominion Response Appendix B of DOM-NAF-2-A (Reference 2) documented the qualification of the Westinghouse WRB-1 CHF Correlation with the VIPRE-D code and the code/correlation departure from nucleate boiling ratio (DNBR) design limits. Appendix B provided the range of application for the VIPRE-DIWRB-1 code/correlation set:

1440 s Pressure s 2490 psia 0.9:S; Mass Flux s 3.7 Mlbm/hr-ff Local Quality s 0.30 Local Heat Flux s 1.0 Mbtu/hr-ft2 The qualification of the VIPRE-DNVRB-1 code/correlation in Appendix B utilized 945 data points from 19 test series. Westinghouse conducted confirmatory DNB testing on the 15X15 fuel design (with Intermediate Flow Mixers) in December 1998 and January 1999. Only one test series was run (Test 100). It is to be expected that the range for the local conditions for Test 100 would be smaller and a subset of those for the 19 test series. The F-Test was used to demonstrate that the variances for the WRB-1 database and the Test 100 data were equal. Thus, the test data can be conservatively considered Page 6 of 8

Serial No. 09-5288 Docket Nos. 50-305/336/423/338/339/280/281 Attachment as part of the WRB-1 database, which is also the same conclusion Westinghouse reported in Reference 8 from performing the F-Test. Therefore, the range of applicability for VIPRE-DIWRB-1 will continue to be that provided in DOM-NAF-2-A, Appendix B (Reference 2), as listed above.

NRC Question 5 11/20/09 supplement, Tebte 2 on page 7 of 8 of attachment 1, shows the DNBR limit for VIPRE-D to be 1.112 while that for VIPRE-W is 1.108. The VIPRE-D value is more conservative. But tne VIPRE-DIWRB-1 has a DNBR of 1.17, which is more conservative than 1.112. Which DNBR value does Dominion intend to use in the reload analysis?

Dominion Response The F-Test was utilized to determine whether the variances for the WRB-1 database and the test data are equal. It was determined that the variances are the same (i.e.,

both the WRB-1 database and the additional test data have the same variability). Thus, it is concluded that the test data can be conservatively considered as part of the WRB-1 database. This conclusion was reached by Westinghouse in Reference 8.

The T-Test was utilized to compare the means of the two populations with equal variance. The T-Test for the test data failed, but was found to be conservative since the mean of the test data was greater than the mean of the VIPRE-DIWRB-1 code/correlation of D0Iv1-NAF-2-A, Appendix B. The Westinghouse evaluation also involved a failed T-Test for equal means in Reference 8, but found it conservative with respect to the WRB-1 database.

Thus, Dominion has concluded that the DNBR design limit of 1.17 for the VIPRE-DIWRB-1 code/correlation as established in DOM-NAF-2-A, Appendix B (Reference 2) is conservative with respect to Test 100. Further, Dominion concludes that a DNBR design limit of 1.17 for the VIPRE-DIWRB-1 code/correlation can be utilized in the applicatio-i to Westinghouse 15X15 Upgrade fuel design containing IFM grids. Dominion will use this value in safety analysis to support reloads with the Westinghouse 15X15 Upgrade fuel.

REFERENCES

1. Letter from J. Alan Price (Dominion) to NRC, "Dominion Energy Kewaunee, Inc.,

Dominion Nuclear Connecticut, Inc., Virginia Electric And Power Company, Kewaunee Power Station, Millstone Power Station Units 2 and 3, North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2, Removal of Mixing Vane Grid Spacing Restriction in Appendix B to Fleet Report DOM-NAF Evaluation of 4x4 DNB Test of 15,,15 Vantage+ with IFMs Using VIPRE-DIWRB-1," dated August 28, 2009; Serial No.09-528. [ADAMS Accession No. ML092430338]

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Serial No. 09-5288 Docket Nos. 50-305/336/423/338/339/280/281 Attachment

2. Fleet Report, DOM-NAF-2, Rev. 0.1-A, "Reactor Core Thermal-Hydraulics using the VIPRE-D Computer Code," July 2009. [ADAMS Accession No. ML092190894]

3. Letter from J. Alan Price (Dominion) to NRC, "Dominion Energy Kewaunee, Inc.,

Dominion Nuclear Connecticut, Inc., Virginia Electric And Power Company, Kewaunee Power Station, Millstone Power Station Units 2 and 3, North Anna Power Station Units 1 and ~~, Surry Power Station Units 1 and 2, Removal of Mixing Vane Grid Spacing Restriction in Appendix B to Fleet Report DOM-NAF Supplemental Information," dated November 20, 2009; Serial No. 09-528A. [Non-Proprietary ADAMS Accession No. ML093310330]

4. Email from Peter Tam (NRC) to Gary D. Miller & Craig D. Sly (Dominion), "Dominion

- Mixing Vane Grid Spacing Restriction submittals (TAC ME2321, 2, 3, 4, 5, 6, and 7)," dated December 8, 2009. [ADAMS Accession No. ML093430415]

5. Email from Peter Tarn (NRC), "Dominion Fleet Report DOM-NAF Draft RAI (TAC ME2321 thru ME232 7 ) ," March 9, 2010. [ADAMS Accession No. ML100700236]

6. Topical Report, VEP-NE-3-A, "Qualification of the WRB-1 CHF Correlation in the Virginia Power COBHA Code," July 1990.

7. Letter from G. F. Wunder (NRC/NRR) to J. Knubel (NYPA), "Issuance of Amendment for Indian Point Nuclear Generating Unit NO.3 (TAe No. M97482),"

July 15, 1997. [ADAMS Accession No. ML003779946]

8. Letter from H. A. Sepp (Westinghouse) to Document Control Desk (NRC) (NSD-NRC-99-5828), "Notification of FCEP Application for DNB Testing and Revalidation of WRB-1 Applicability to the 15x15 VANTAGE+ Fuel Design, (Proprietary),"

March 29, 1999. ..

9. Letter from G. F. Wunder (NRC/NRR) to J. Knubel (NYPA), "Indian Point Nuclear Generation Unit No. 3 - Issuance of Amendment RE: Removal of Footnote from Technical Specifications (TAC NO. MA5193)," September 2, 1999. [ADAMS Accession No. MLOO 3780850]

10. Letter from Westinghouse (J. A. Gresham) to J. S. Wermiel (NRC), LTR-NRC-04-8, "Fuel Criterion Eva uation Process (FCEP) Notification of the 15x15 Upgrade Design," February 6, 2004.

11.WCAP-12488-P-A, "'Nestinghouse Fuel Criteria Evaluation Process," October 1994.

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