ML12017A165

Response to Request for Additional Information - License Amendment Request Concerning Safety Limit Minimum Critical Power Ratio Change

ML12017A165
Person / Time
Site:	Limerick
Issue date:	01/13/2012
From:	Jesse M D Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML120170371	List: ML12017A165
References
Download: ML12017A165 (22)

Text

Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com Exelon.Nuclear PROPRIETARY INFORMATION

-WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 January 13, 2012 U.S.Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C.20555-0001 Limerick Generating Station, Unit 1 Facility Operating License No.NPF-39 NRC Docket No.50-352

Subject:

Response to Request for Additional Information

-License Amendment Request Concerning Safety Limit Minimum Critical Power Ratio Change

References:

1)Letter from M.D.Jesse (Exelon Generation Company, LLC)to U.S.Nuclear Regulatory Commission,"License Amendment Request-Safety Limit Minimum Critical Power Ratio Change," dated October 12, 2011 2)Letter from P.Bamford (U.S.Nuclear Regulatory Commission) to M.J.Pacilio,"LimerickGenerating Station, Unit1-Request for Additional Information Regarding Proposed Technical Specification Safety Limit Minimum Critical Power Ratio Changes (TAC NO.ME7333)," dated December 21, 2011 In the Reference 1 letter, Exelon Generation Company, LLC (Exelon)requested a proposed change to modify Technical Specification (TS)2.1 ("Safety Limits").Specifically, this change incorporates revised Safety Limit Minimum Critical Power Ratios (SLMCPRs)due to the cycle specific analysis performed by Global Nuclear Fuel for Limerick Generating Station (LGS), Unit 1, Cycle 15.In the Reference 2 letter, the U.S.Nuclear Regulatory Commission requested additional information.

Attachment 1 provides the Exelon response to questions 2 and 7.Attachment 2 provides the Global Nuclear Fuel response to questions 1, 3, 4, 5, and 6.Attachment 2 transmitted herewith contains Proprietary Information.

When separated from attachments, this document is decontrolled.

Response to Request for Additional InformationLicense Amendment Request Concerning Safety Limit Minimum Critical Power Ratio Change January 13, 2012 Page 2 Attachment 2 (letter from C.F.Lamb (Global Nuclear Fuel)to J.Tusar (Exelon Generation Company, LLC).dated January 10.2012)contains information proprietary to Global Nuclear Fuel.Global Nuclear Fuel requests that Attachment 2 be withheld from public disclosure in accordance with 10 CFR 2.390.Attachment 3 contains a non-proprietary version of the Global Nuclear Fuel document.An affidavit supporting this request is also contained in Attachment 4.Additionally, there are no commitments contained within this letter.Should you have any questions concerning this letter, please contact Tom Loomis at (610)765*5510.I declare under penalty of perjury that the foregoing is true and correct.Executed on the 13 th day of January 2012.Respectfully, Michael D.Jesse Director, Licensing Exelon Generation Attachments:

1)Exelon Response to RAI Questions 2 and 7 for LAR Concerning SLMCPR Change 2)Global Nuclear Fuel Response to Questions 1 t 3, 4, 5, and6-Proprietary Version 3)Global Nuclear Fuel Response to Questions 1, 3, 4, 5, and6-Proprietary Version 4)Affidavit cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS R.R.Janati, Commonwealth of Pennsylvania ATTACHMENT 1 Exelon Response to RAI Questions 2 and 7 for LAR Concerning SLMCPR Change Exelon Response to RAI Questions 2 and 7 for LAR Concerning SLMCPR Change Question: Attachment 1 Page 1 design is an iterative process designedtodevelop an optimal configuration that meets requirements.

In the LAR, Attachment 6, for the slides titled"Preliminary Utilization Plan for Limerick 1 Cycle 1 and"Pre-Estimation

-Linear Reactivity," please provide the most current updated parameters applicable to LGS, Unit1, Cycle 15.II Response: The final Energy Utilization Plan used for Limerick Generating Station (LGS), Unit 1 Cycle 15 is identical to the Energy Utilization Plan provided in the"Preliminary Energy Utilization Plan (EUP)for Limerick 1 Cycle 15" slide.No changes were made to the preliminary Energy Utilization Plan.For the"Pre-Estimation

-Linear Reactivity" slide, the Equilibrium Cycle Estimate approach is not relevant to LGS, Unit 1, Cycle 15 as noted on the slide.This technique (estimation approach)is used when equilibrium conditions in fuel type, cycle length, and power level will be achieved.The Equilibrium Cycle Estimation approach was not used because LGS, Unit 1 will not achieve equilibrium with the current fuel type, cycle length, and power level.LGS, Unit 1 is planning to implement an EPU (Extended Power Uprate)in Cycle 17 which will prevent reaching an equilibrium core of GNF2 fuel at the Cycle 15 power level.Question: 117.Please provide an updated version of power/flow map for Cycle 15 operation, including stability Option III features of scram region and controlled entry region, based on the Boiling Water Reactor Owners Group position, as specified in NEDO-31960, for SLO and TLO.II Response: The following is the power/flow map for back-up stability protection at LGS, Unit 1.LGS, Unit 1 does not use the controlled entry region.Instead, this region is conservatively treated as an IIlmmediate Exit ll region on the power/flow map.The power/flow map also shows the IIlmmediate Scram ll region.The Backup Stability Protection (BSP)region boundaries are calculated based on aspecifiedcore decay ratio per the approved stability methodology described in GESTAR (Section S.4.2.2, pg.US-3a).The core decay ratio is a function of principal reactor core parameters (e.g., power and power distribution, flow, subcooling, fuel design, etc.).The core decay ratio is independent of the core flow mode-it is the same for two loop operation (TLO)and single loop operation (SLO).Therefore, the calculated BSP regions are bounding and applicable for both TLO and SLO.The power/flow map generally depicts a II na tural circulation ll flow line anda" max imum rod line ll*The BSP region boundaries are calculated based on points on the natural circulation line and the maximum rod line (identified as the MELLLA line)and the BSP regions are depicted as areas between the maximum rod line, the natural circulation line and the BSP region boundaries in the high-power, low-flow region of the map.However, the natural circulation line is approximate and the core flow measurement uncertainty is larger at low flow conditions.

In the past, this has resulted in operating conditions in which the indicated power/flow condition was below (to the left of)the natural circulation line on the power/flow map.To address this situation, an operational decision was made to conservatively extend operating boundaries (e.g., maximum rod line, Exelon Response to RAI Questions 2 and 7 for LAR Concerning SLMCPR Change Attachment 1 Page 2 stability regions, etc.)back to flowll.This operational enhancement to the power/flow map provide additional for unlikely, but circumstance of conditions.

Exelon Response to RAI Questions 2 and 7 for LAR Concerning SLMCPR Change Attachment 1 Page 3 LGS Power Flow Operation Map OPRM Jnoperable

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loii Core Flow (%of Rated)..,__"'_.,130 120 110 100 i 90..!i 60 l"" 70 E I..60-w E!so"" 40 30 20 10 0 13 ATTACHMENT 3 Global Nuclear Fuel Response to Questions 1, 3, 4, and6-Non-Proprietary Version ENCLOSURE 2 CFL-EXN-HH1-12-001 Response to NRC RAls for Limerick Unit 1 Cycle 15 SLMCPR Submittal Non-Proprietary Information

-Class I (Public)INFORMATION NOTICE This is a non-proprietary version of CFL-EXN-HH1-12-001 , which has the proprietary information removed.Portions of the document that have been removed are indicated by white space inside an open and closed bracket as shown here[[]].

CFL-EXN-HH 1-12-001 2 Non-Proprietary Information DOCKET NO.50-352 By letter dated October 12, 2011 (Agencywide Documents Access and Management System Accession No.ML 112870080), Exelon Generation Company, LLC (Exelon, the licensee)submitted a license amendment request (LAR)proposing to modify Technical Specification (TS)2.1,"Safety Limits," for Limerick Generating Station (LGS), Unit 1.The requested change involves revised Safety Limit Minimum Critical Power Ratios (SLMCPRs)calculated as a result of the cycle-specific analysis performed by Global Nuclear Fuel (GNF)to support operation in the upcoming LGS, Unit 1, Cycle 15.The Nuclear Regulatory Commission (NRC)staff has been reviewing the submittal and has determined that additional information is needed to complete its review.

CFL-EXN-HH 1-12-001 Enclosure 2 RAI-01: Non-Proprietary Information In the LAR, Attachment 5, RAI-06-1 and RAI-06-2, provide core maps to show those bundles experiencing 0.1 boiling transition criterion for limiting cases of single-loop operation (SLO)and two-loop operation (TLO)..identify the bundle group and number of bundles in Figure 1 corresponding to their burnup status (once-burned, twice-burned, or fresh fuel)for Cycle 15.Response to RAI-01: Table RAI-01-1 contains the bundle group, number of bundles, bundle type, burnup status and fuel type associated with the Cycle 15 core loading map presented in Figure 1 of Attachment 4 of the LAR.All of the data presented in Table RAI-01-1 is equivalent for both TLO and SLO.Table RAI-01-1 Bundle Group, Number of Bundles, Bundle Type, Burnup Status and Fuel Type for Both TLO and SLO[[]]

CFL-EXN-HH1-12-001 2 RAI...02: Non-Proprietary Information I (Public)Page 3 of 9 Core design is an iterative designed to develop an optimal configuration that meets operational requirements.

In the LAR, Attachment 6, for the slides titled"Preliminary Energy Utilization Plan for Limerick 1 Cycle 1 and"Pre-Estimation

-Linear Reactivity," please provide the most current updated parameters applicable to LGS, Unit 1, Cycle 15.Response to RAI...02: Exelon will provide a response to this RAI.

CFL-EXN-HH 1-12-001 Enclosure 2 RAI-03: Non-Proprietary Information

-I (Public)Page 4 of 9 GNF2 fuel deviates from traditional 1 Ox1 0 design through the introduction of a new part length rod configuration, the use of higher linear power, and the use of mixing vanes.The staff considers this a new fuel design with regards to the four restrictions identified in the Safety Evaluation of General Electric (GE)Licensing Topical Reports NEDC-32601 P, NEDC-32694 and Amendment to NEDE-24011-P-A.

Given that LGS, Unit 1 Cycle 15 uses a core loading pattern which inciudesGNF2 fuel, please provide the following:

(1)an evaluation of the four restrictions in NEDC-32601 P, NEDC-32694 and Amendment 25 to NEDE-24011-P-A, (2)a description that explains under what conditions the methodologies listed in Section 1.0 of Attachment 4 are applied to the LGS, Unit 1, Cycle 15 application, (3)the reason why GNF2 has much higher critical power uncertainty than that of GE14, as shown in Table 6 of Attachment 4, and (4)a clarification for the statement"no new GNF fuel designs are being introduced in Limerick 1 Cycle 15" in Section 2.5 of Attachment 4.Response to RAI-03-1: The four restrictions for GNF2 were determined acceptable by the NRC review of the"GNF2 Advantage Generic Compliance with NEDE024011-P-A (GESTAR II)," NEDC-33270P, Revision 0, FLN-2007-011, March 14, 2007.Specifically, in the NRC audit report ML081630579 for the said document, Section 3.4.1 page 59 states: "The NRC staff's SE of NEDC-32694P-A (Reference 69 of NEDE 33207P)provides four actions to follow whenever a new fuel design is introduced.

These four conditions are listed in Section 3.0 of the SE.The analysis and evaluation of the GNF2 fuel design was evaluated in accordance with the limitations and conditions stated in the NRC staff's SE, and is acceptable." Additionally, the NRC audit report, ML081630579, Section 3.4.2.2.1 page 59 states: "The NRC staff finds that the calculational methods, evaluations and applicability of the OLMCPR and SLMCPR are in accordance with existing NRC-approved methods and thus valid for use with GNF2 fuel."

CFL-EXN-HH 1-12-001 Enclosure 2 Non-Proprietary Information I (Public)Page 5 of 9 Response to RAI-03-2: There are three..._+........_I....._,."'t"" listed in Section 1.0 of Attachment 4.The applicability of each of the three are: A.P-A"Methodology and Uncertainties for Safety Limit MCPR Evaluations" (August 1999).B.NEDC-32694P-A"Power Distribution for Safety Limit MCPR Evaluations" (August 1999).C.NEDC-32505P-A"R-Factor Calculation Method for GE11, GE12 and GE13 Fuel" (Revision 1, July 1999).Attachment 4 Table 2 identifies the actual methodologies used for the Cycle 15 and Cycle 14 SLMCPR calculations.

References A and B are directly applicable to the analysis.Reference C is the generic R-Factor methodology report that describes the changed methodology that was adopted after part length rods were introduced.

The NRC staff's SE for NEDC-32505P-A has a requirement that the applicability of the R-Factor methodology is confirmed when a new fuel type is introduced.

The confirmation for GNF2 was determined to be acceptable by the NRC staff review of the"GEXL 17 Correlation for GNF2 Fuel," NEDC-33292P, Revision 0, FLN-2007-011, March 14, 2007 in the NRC audit report ML081630579, Section 3.5.5 page 62.Response to RAI-03-3: It should be noted that the correlation uncertainty, or standard deviation, for GEXL correlations tends to be in the range of[[]].There is no definitive explanation for the higher uncertainty with GEXL 17.While it is acknowledged that the GEXL 17 standard deviation is slightly higher than that associated with GEXL 14, the absolute magnitude remains typical and GEXL 17 adequately predicts the onset of boiling transition for GNF2.Response to RAI-03-4: GNF's position is that GNF2 is an evolutionary fuel product based on GE14.It is not considered a new fuel design as it maintains the previously established 1 Ox1 0 array and two water rod makeup.

CFL-EXN-HH 1-12-001 2 Non-Proprietary Information RAI-04: In the LAR, Attachment"GNF to RAI-03 Applied to LGS Unit 1 ," it states that Unit 1 Cycle 15 is the first full reload of GNF2.Figure 1 of Attachment 4, indicates that Cycle 15 will contain both and GNF2 fuel.clarify the"full reload" statement against Figure1.Response to RAI-04: The statement"full reload" refers to the fact that all fresh (reload)fuel introduced in Cycle 15 is of the same fuel type (GNF2).

CFL-EXN-HH 1-12-001 Enclosure 2 Non-Proprietary Information

-Class I (Public)Page 7 of 9 RAI-05: Please identify the breakdown of the 1 Ox1 0 data shown in Attachment 4, Figure 5, by fuel type (Le.(GE14, GNF2), because Figure 5 only shows combined data points for the two fuel types.Response to RAI-05: The 10x10 (GE14, GNF2)points shown in Figure 5 of Attachment 4 reflect transition cores with a mix of 1 Ox1 0 fuel products.Thus, there are not specific GNF2 data points in Figure 5.The table following Figure 5 provides the GE14 and GNF2 batch sizes, and the corresponding

[[]]for the 10x10 (GE14, GNF2)points in the figure.The table is in ascending order of the abscissa of Figure 5 for ease of correlation to the figure.Sums of batch sizes and[[]]may not add to 1000/0 due to rounding and/or the presence of other fuel products in the core.31.0 38.5 28.6 71.4 64.4 35.6 31.0 38.5 31.0 38.5 64.4 35.6 28.6 71.4 28.6 71.4 67.4 32.6 64.4 35.6 67.4 32.6]]67.4 32.6]]

CFL-EXN-HH1-1 RAI-06: Non-Proprietary Information

-Class I (Public)Page 8 of 9 Please clarify that there is no adverse impact relating to the GNF2 bent spacer wing operating experience to Unit 1, Cycle 15, operation.

If there is an adverse impact, please provide an assessment of the impacts of such operation on fuel thermal performance.

Response to RAI-06: GNF2 bent spacer wing related Part 21 issues are not applicable to Limerick Unit 1 Cycle 15 because the GNF2 fuel in this cycle is not impacted by the Part 21 issue.

CFL-EXN-HH 1-12-001 2 RAI-07: Non-Proprietary Information I (Public)Page 9 of 9 provide an updated version of power/flow map for Cycle 15 operation, including stability Option III of scram region and controlled entry region, on the Boiling Water'-LlLll'LlL"-J1 Owners Group position, as specified in NEDO-31960, for SLO and TLO.Response to RAI-07: Exelon will provide a response to this RAI.

ATTACHMENT 4 Affidavit ENCLOSURE 3 CFL-EXN-HH 1-12-001 Affidavit GlobalN uclearFuel Americas AFFIDAVIT I, Lukas Trosman, state as follows: (1)Manager, Reload Design and Analysis, Global Nuclear Fllel (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)information sought to be withheld is contained in Enclosures 1 of GNF's letter, CFL-EXN-HHI-12-001, C.Lamb (GNF-A)to J.Tusar (Exelon Nuclear), entitled Response to NRC RAIs for Limerick Unit 1 Cycle 15 SLMCPR Submittal," dated January 10, 2012.GNF-A proprietary information in Enclosure 1, which is entitled"Response to NRC RAIs for Limerick Unit 1 Cycle 15 SLMCPR Submittal," is identified a dotted underline inside double square brackets. A"" marking at the beginning of a table, figure, or paragraph closed with a"" marking at the end of the table, figure or paragraph is used to indicate that the entire content between the double brackets is proprietary.

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 2.390(a)(4) for"trade secrets" (Exemption 4).The material for which exemption from disclosure is here sought 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, 975 F2d 871 (DC Cir.1992), and Public Citizen Health Research Group v.FDA, 704 F2d 1280 (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 aspects of past, present, or future GNF-Afunded development plans and programs, resulting in potential products to GNF-A;CFL-EXN-HHI-12-001 Affidavit Page 1 of 3 d.protection.

subject matter for wllich it may be U"-J....,....cLcL...to be withheld is considered to be proprietary for the reasons 1"\r:l1":lI'l'1f']I1\l'\c (4)a.and (4)b.above.(5)To 10 CFR 2.390 (b)(4), the information sought to be withheld is being submitted to NRC in confidence.

information is of a sort customarily held in confidence by GNF-A, and is in factsoheld.The information sought to be withheld 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, made, or must be made, pursuant to regulatory provisions or proprietary r:ln1-j3j31rY1t3nTC which provide for maintenance of the information in confidence.

Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6)and (7)following.

(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 toGNF-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 this methodology, along with the testing, development and approval was achieved at a significant cost to GNF-A.The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNF-A asset.(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 information 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 CFL-EXN-HH 1-12-00 1 Affidavit Page 2 of 3 development of the to determine and apply the appropriate evaluation In addition, technology base includes the value derived from providing done with NRC-approved methods......u.....'_.a......"L.a...development, analytical, and NRC review costs comprise of time and money by GNF-A.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 theGNF-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 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 on this 10th day of January 2012.Lukas Trosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel-Americas, LLC CFL-EXN-HH 1-12-00 1 Affidavit Page 3 of 3