Text

License Amendment Request - Safety Limit Minimum Critical Power Ratio Change
	ML103500180
Person / Time
Site:	Limerick
Issue date:	12/15/2010
From:	Cowan P; Exelon Corp, Exelon Generation Co, Exelon Nuclear
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML103500177	List: ML103500180;
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	Download: ML103500180 (46)
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{{#Wiki_filter:n thu huir wwwxuIoncurp N uc] ear Pun (tt r1n u, PA 1n348 10 CFR 10 CFR 50.90 50.90 PROPRIETARY INFORMATION INFORMATION - WITHHOLD UNDER

                                                            -               UNDER 10   10 CFR 2.390 2.390 December 15, 2010 u.s.

U .S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Limerick Generating Station, Unit 2 Facility Operating License No. NPF-85 NRC Docket No. 50-353

Subject:

License Amendment Request - Safety Limit Minimum Critical Power Ratio

Change In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (Exelon) requests a proposed change to modify Technical Specification (TS) 2.1 C'Safety (Safety Limits). 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 2, Cycle 12. Unit The proposed changes have been reviewed by the Limerick Generating Station Plant The Operations Review Committee, and approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program. In order to support the upcoming refueling outage at LGS, Unit 2, Exelon requests approval of proposed amendment by March 15, 2011. Once approved, this amendment shall be the proposed implemented within 30 days of issuance. Additionally, there are no commitments contained implemented within this letter. Attachment 11 contains the evaluation of the proposed changes. Attachments 2 and 3 provide marked up TS and Bases pages and the retyped TS and Bases pages, respectively. the marked Attachment 44 (letter Attachment (letter from J. M. Downs (Global Nuclear Fuel) to J. Tusar (Exelon Generation M. Downs Company, LLC), Company, LLC), dated November 23, 2010) specifies the new SLMCPRs for LGS, Unit 2, Cycle dated November

12. Attachment

12. information proprietary to Global Nuclear Fuel. Global Nuclear Fuel Attachment 4 contains information Attachment 44 transmitted Attachment herewith contains Proprietary Information.

transmitted herewith When separated When attachments, this document is decontrolled. separated from attachments,

Amendment License Amend ment Request Safety Limit Minimum Critica Criticall Power Ratio Change December 15, 2010 Page 2 with 10 ure in accordance with CFR 10 CFR requests that the document be withheld from public disclosure oprietary containss a non-proprieta version of the ry version Globa Global l Nuclea Nuclea rr Fuel Fuel 2.390(b)(4). Attachment 55 contain supporrting ting this reques t is also contained contain in Attachment 5. ed in 5. Attachment 66 document. An affidavitit suppo contai contain nss the power flow maps for Cycles 11 and 12. power//flow 12. lvania of Pennsylvania ngg the State of Pennsy this of this In accordance with 10 CFR 50.91, Exelon is notifyi notifyin to itting a copy of this letter and transmitting attach and its attachm ents to ments tion for license amendment by transm applicaation applic the designated State Official. ning this letter, please contact Tom Loomis at (610) concerrning (610) 765-765-Should you have any questi questio ns conce ons 5510. th 15 th penalt y of perjury that the forego ing is true and correc correctt.. Execut ed on the 15 of Executed II declar declare e under penalty December 2010. Respecctfully, Respe tfully,

     /2
    //        /

Pamel Pamela a B. Cowan Director, Licensing & & Regulatory Affairs tion Comp Generaation Exelon Gener Compa ny, LLC any, ments:: 1) Attachments Attach Propossed Evaluation of Propo ed Changes

2) Markup of Techn cal Specifications and Bases Pages Techniical

3) Techniical Retyped Techn ications and Bases Pages cal Specification 4 Proprietary Version of Globa Propri Globall Nuclear Fuel Letter

5) Affidav it and Non-P Affidavit ropriet ary Version of GlobaGloball Nuclear Fuel Letter

6) Power/Flow Maps for Cycles 11 and 12 cc: USNRC Region I, Regional Admin istrator Administrato USNRC Senior Resident Inspec USNR tor, LGS Project Manager, LGS USNRC Projec USNR LGS

Janati, R. R. Janati Comm onwea lth of Penns lvania Pennsyylvania

Attac hmen t 1 Attachment 1 Limerick Lime Generating rick Gene (LGS),, Unit 2 Stationn (LGS) rating Statio Facility Facili Operating ty Opera License ting Licen NPF-855 se No. NPF-8 ation of Propo Evaluation Evalu Chan ges sed Changes Proposed

ATTACHMENT 1 1 CONTENTS um Critical Power Ratio (SLMCPR) Change

SUBJECT:

Safety Limit Minimum 1.0 10

SUMMARY

DESCRIPTI RIPTION ON 2.0 DETAILED DESCRIPTIRIPTIO N ON 3.0 TECHNICAL EVALU ATION EVALUATIO N 4.0 LATOR REGULATO RYY EVALU ATION EVALUATIO N 4.1 Requirremen able Regulatory Requi Applicable Applic ts/Crit ements eria

                                                 /Criter ia 4.2   Precedents 4.3              cant Hazar Significant No Signifi           dss Consideration Hazard 4.4   Conclusions sions 5.0  ENVIRONMENTAL CONS        IDERATION CONSIDERA 6.0  REFE RENC REFER ENCEES S

Evaluation Evalua tion ofofPropos Proposed Changes ed Chang es License Amendment Request st Attach ment 1 1 Attachment License Amendment Reque SafetyLimit Safety LimitMinimum MinimumCritical Critical Power PowerRatio Ratio Page1 1 Page 1.0 1.0

SUMMARY

DESC

SUMMARY

DESCRIPTION RIPTION This evalua This evaluation supports tion suppor ts aa reques request t toto amend amend Facility FacilityOperat Operatinging Licens License e No.No. NPF-8NPF-85 5 forfor Limerick Generating Station Limerick Generating Station (LGS), Unit 2. (LGS), Unit 2. The propos proposed change modifi ed change modifies Technical es Techni Specification cal Specif (TS) 2.1 ication (TS) 2.1 (Safe ("Safety Limits'l Specif ty Limits). ically, Specifically, The this change this change incorp incorporates revised Safety orates revised Safety Limit Limit Minimum Critical Power Minimum Critical Ratios (SLMC Power Ratios (SLMCPRs) PRs) due due to the cycle specific analysis performed by Global Global Nuclear Nuclea r Fuel Fuel for for LGS, LGS, Unit Unit 2, 2, Cycle Cycle 12. 12. to the cycle specific analysis performed by 2.0 2.0 DETAILED DESC DETAILED DESCRIPTION RIPTION The propos proposed change involv ed change involves revising es revisin g thethe SLMC SLMCPRs PRs contain contained TS 2.1 ed inin TS 2.1 for for twotwo recircu lation recirculation The loop operation and single recirculation loop operation. on. The The SLMC SLMCPR PR value value for for two-lo two-loop op loop operation and single recirculation loop operati operation is being being change changed from ~ 1.07 d from 1.07 to to ~ 1.09. 1.09. TheThe SLMC SLMCPR PR value for single-value for single-looploop operati operationon operati on is is being is being change changed from ~ 1.09 d from 1.09 to to ~ 1.12. 1.12. Marked up TS d up TS page page 2-12-1 and Bases Bases page page B B 2-1 2-1 showin showing the reques g the requested ted change changes are provid s are provided ed in in Marke Attachment Attach ment 2. 2. 3.0 3.0 TECHNICAL TECHNICAL EVALUATION EVALUATION The contained in TS 2.1 for two recircu SLMCPRs contained lation The proposed proposed TS TS change change will revise the SLMCPRs recirculation loop operation to reflect the change s in the cycle specifi c loop operation operation and and single recirculation recirculation loop operation changes in specific analysis analysis performed performed by by Global Nuclear Nuclear Fuel for LGS, Unit 2, Cycle 12. The The newnew SLMCPRs SLMCPRs are calculated calculated using NRC-approved methodology described NRC-approved methodology described in NEDE in NEDE-24011-P-A, 24011-P-A, "General General Electric Electric Standard Application for Reactor Standard Application r Reacto Fuel," Revisi Fuel, Revision on 17. A listing of listing of the associated the associated NRC-a NRC-approved pprove d methodologies metho dologi es for calcula ting calculating the SLMC SLMCPRs PRs is provid provided ed in in Section Section 1.0 1.0 ("Methodology") (Methodology) of of Attachment Attachment 4. 4. The The SLMCPR SLMCPR analysis analysis establishes establishes SLMCPR SLMCPR values ensure that during normal will ensure that will values that operation normal operation and transients, at 999% of least 99.9% at least all fuel of all in the core rods in the core do not fuel rods do not and during during abnormal abnormal operational operational transients, experience violated. The not violated. SLMCPRs are The SLMCPRs calculated to are calculated include to include experience transition transition boiling boiling ifif the the limit limit isis not cycle cycle specific specific parameters parameters and, general, are and, inin general, dominated by are dominated two key by two parameters: 1) key parameters: flatness of

1) flatness of the distribution, and and 2) flatnes s of the bundle pin-by

2) flatness of the bundle pin-by-pin power/R- -pin power/ R the core core bundle-by-bundle bundle-by-bundle MCPR MCPR distribution, Factor support the specific SLMCPRs cycle specific the cycle SLMC PRs is include d in Attach ment Factor distribution.

distribution. Information Information to to support is included in Attachment 4.4. That attachment That attachment summarizes summa rizes the the methodology, method ology, inputs, inputs, and and results results for for the change inin the the change the SLMCPRs. SLMCPRs. The The LGS, LGS, Unit Unit 2,2, Cycle Cycle 12 core will 12 core consist of will consist GE14 and of GE14 GNF2 fuel and GNF2 types. fuel types. Attachment Attachment66containscontainsthe the power/flow power/flow maps maps for Cycles 11 for Cycles and 12 11 and Measurement (draft). AA Measurement 12 (draft). Uncertainty UncertaintyRecapture Recapture (MUR)(MUR) powerpower uprate planned for uprate isis planned implementatio at for implementation n LGS, Unit at LGS, Unit 22 starting startingwith with Cycle Cycle 12.12. AAfinal final power powertotoflow mapfor flowmap Cycle 12 forCycle 12 isis under development. The under development. The revised revisedCycle Cycle 12 12 SLMCPRs SLMCPRswere werecalculated the MUR calculated atatthe MUR power level.power level. No Noplant planthardware hardwareororoperational operationalchangeschangesare requiredwith are required withthis proposedchange. thisproposed change.

Evaluation of Evaluation of Proposed Proposed Changes Changes License Amendment License Amendment Request Request Attachment Attachment 11 Safety Limit Safety Limit Minimum Minimum Critical Critical Power Power Ratio Ratio Page Page 22 4.0

4.0 REGULATORY EVALUATION

REGULATORY EVALUATION 4.1 4.1 Applicable Regulatory Applicable Regulatory Requirements/Criteria ReQuirements/Criteria 10 CFR 50.36, 10 CFR 50.36, "Technical Technical specifications," specifications, paragraph paragraph (c)(1), (c)(1), requires requires that power power reactor reactor facility TS include TS include safety safety limits limits for for process process variables variables that that protect protect the integrity of certain the integrity of certain physical barriers that barriers that guard guard against against thethe uncontrolled uncontrolled release release ofof radioactivity. radioactivity. The fuel cladding integrity SLMCPR isis established SLMCPR established to to assure assure that that at at least least 99.9% 99.9% of of the fuel rods rods in the core do not experience transition experience transition boiling boiling during during normal normal operation operation andand abnormal abnormal operating transients. Thus, the SLMCPR the SLMCPR is is required required to to be contained in be contained in TS. 4.2 4.2 Precedents Precedents The NRC The NRC hashas approved approved similar similar SLMCPR SLMCPR changes for a number of plants:

1) Letter

1) Letter from from M.M. H.H. Chernoff Chernoff (U.S.(U.S. Nuclear Regulatory Commission)

Commission) to K. W. Singer (Tennessee Valley Authority), "Browns Browns Ferry Nuclear Plant, Unit 1 1 - Issuance of

Regarding Cycle-Specific Amendment Regarding Cycle-Specific Safety Limit Minimum Critical Power Ratio (TAC NO. MD1721) (TS-455)," (TS-455), dated February 6, 2007

2) Letter from J. Wiebe (U.S. Nuclear Regulatory Commission) Commission) to C. Pardee (Exelon Generation Company, LLC), "Quad Quad Cities Nuclear Power Station, Units 1 1 and 2 - Issuance

of Amendments RE: Safety Limit Minimum Critical Power Ratio (TAC NOS. MD7374 and MD7375), dated February 28, 2008 MD7375),"

3) Letter from J. Kim (U.S. Nuclear Regulatory Commission Commission)) to Site Vice President (Entergy (Entergy Nuclear Operations, Inc.), "Pilgrim Pilgrim Nuclear Power Station -Issuance Issuance of Amendment RE:

Technical Specification Change Concerning Safety Limit Minimum Critical Power Ratio (TAC NO. ME0241)," ME0241), dated March 26, 2009

4) Letter from C. Lyon (U.S. Nuclear Regulatory Commission Commission)) to Vice President,President, Operations Operations (Entergy Operations, Inc.), Grand "Grand Gulf Nuclear Station, Unit Unit 11 - Issuance

                                                                                       -  Issuance of  of Amendment Amendment RE: Change to the Minimum Critical Power Ratio Safety            Safety Limit (TAC(TAC NO. NO. ME2474),

ME2474)," dateddated March 25, 2010

5) Letter from J. D. HugheyHughey (U.S.(U.S. Nuclear Nuclear Regulatory Regulatory Commission Commission) ) toto M. J. Pacilio M. J. Pacilio (Exelon (Exelon Generation Company, LLC), Peach LLC), "Peach Bottom Bottom Atomic Power Power Station, Unit 22 -Issuance Station, Unit Issuance of of Amendment RE: Safety Safety Limit Limit Minimum Minimum Critical Critical Power Power Ratio Ratio Value Value Change Change (TAC (TAC NO.NO.

ME3994), ME3994)," dated dated September September 28, 2010 28,2010 4.3 4.3 No Significant Hazards No Significant Hazards Consideratio Consideration n Exelon Exelon Generation Generation Company, Company, LLC LLC (Exelon) (Exelon) has has evaluated evaluated whether whether or or not not aa significant significant hazards hazards consideration is is involved involved with with the the proposed proposed amendment amendment by by focusing focusing on on the the three three standards standards setset forth in 10 CFR 50.92, Issuance of amendment, as forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: discussed below:

Evaluation of Proposed Changes License Amendment Request Attachment 11 Attachment Safety Limit Minimum Critical Power Ratio Page 33 Page

1. Does the proposed amendment involve aa significant increase in in the probability or or consequences of an accident previously evaluated?

Response: No. The derivation of the cycle specific Safety Limit Minimum Critical Power Ratios Ratios (SLMCPRs) (SLMCPR5) for incorporation into the Technical Specifications Specifications (TS), (TS), and use to and their use to determine cycle specific thermal limits, has been performed performed using the methodology methodology discussed in NEDE-24011-P-A, NEDE-2401 1-P-A, IIGeneral General Electric Standard Application for Reactor Fuel,1I Fuel, Revision 17. The basis of the SLMCPR calculation is to ensure that during normal operation operation and during abnormal operational transients, at least 99.9% 99.9% of all fuel rods in the core do do not not experience transition boiling if the limit is not violated. The new SLMCPRs preserve the existing margin to transition boiling. The MCPR safety limit is reevaluated for each reload using NRC-approved methodologies. The analyses for Limerick Generating Station (LGS), Unit 2, Cycle 12 12 have concluded that a two loop MCPR safety limit of ~ 1.09, 1.09, based on the application of Fuels NRC-approved MCPR safety limit methodology, will ensure that Global Nuclear Fuel's this acceptance criterion is met. For single-loop operation, a MCPR safety limit of ~ 1.12 1.12 also ensures that this acceptance criterion is met. The MCPR operating limits are presented and controlled in accordance with the LGS, Unit 2 Core Operating Limits Report (COLR). The requested TS changes do not involve any plant modifications or operational changes that could affect system reliability or performance or that could affect the probability of operator error. The requested changes do not affect any postulated accident precursors, do not affect any accident mitigating systems, and do not introduce any new accident initiation mechanisms. Therefore, the proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Response

The SLMCPR is a TS numerical value, calculated to ensure that during normal operation and during abnormal operational transients, at least 99.9% 99.9% of all fuel rods in the core do not experience transition boiling if the limit is not violated. The new SLMCPRs are not calculated using NRC-approved methodology discussed in NEDE-24011-P-A, calculated General NEDE-2401 1-P-A, IIGeneral Fuel,II Revision 17. The proposed changes do Electric Standard Application for Reactor Fuel, Electric not involve not any new involve any modes of operation or any plant modifications. The proposed new modes MCPR safety limits have been shown to be acceptable for Cycle 12 operation. revised MCPR revised core operating limits will continue to be developed using NRC-approved methods. The core The The proposed The MCPR safety limits or methods for establishing the core operating limits proposed MCPR not result do not do in the creation of any new precursors to an accident. Therefore, the result in

Evaluation of Evaluation of Proposed Proposed Changes Changes License Amendment License Amendment Request Request Attachment 11 Attachment Safety Safety Limit Limit Minimum Minimum Critical Power Critical Power Ratio Ratio Page 44 Page proposed TS proposed TS changes changes do do not not create create the the possibility possibility of of aa new new or different kind or different of accident kind of accident from any previously from any previously evaluated. evaluated. 3.

3. Does the Does the proposed proposed amendment amendment involveinvolve aa significant reduction in significant reduction margin of in aa margin of safety?

safety? Response: No. Response: No. There is is no no significant significant reduction reduction in in the the margin margin of of safety approved by previously approved safety previously the NRC by the NRC as a result of the proposed as proposed change change to to the SLMCPRs. The the SLMCPRs. The new SLMCPRs are new SLMCPRs are calculated usingusing methodology discussed in methodology discussed in NEDE-24011 NEDE-24011-P-A, "General Electric

                                                                                              -P-A, General       Electric Standard Application for Reactor Fuel,                    Revision 17.

Fuel," Revision 17. The SLMCPRs ensure The SLMCPRs that during ensure that during normal operation and during transients, at operational transients, during abnormal operational at least 99.9% of least 99.9% all fuel of all fuel rods in the core do not experience transition boiling limit is boiling ifif the limit violated, thereby not violated, is not thereby preserving the fuel cladding integrity. Therefore, the proposed proposed TS changes do TS changes do not not involve a significant reduction in the margin of safety previously approved by previously approved the NRC. by the NRC. Based on the above, Exelon Generation Company, LLC, concludes concludes that the proposedproposed amendment does not involve a significant hazards consideration under the standards standards setset forth forth in in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration consideration is is justified. 4.4 Conclusions In conclusion, based on the considerations 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 Commission1s Commissions regulations, and (3)(3) the issuance of the amendment will not be inimical to the common defense and security or or to the health health and safety of the public. 5.0 5.0 ENVIRONMENTAL ENVIRONMENTAL CONSIDERATION CONSIDERATION AA review review has has determined determined that the proposed amendment would change a requirement with respect respect to to installation installation or use use of a facility component located within the restricted area, as defined defined in in 10 10 CFR CFR 20, 20, or would change an inspection or surveillance requirement. However, the the proposed proposed amendment amendment does does not involve (i) not involve consideration, (ii) a (i) a significant hazards consideration, significant change significant change in in the the types types or or significant significant increase increase in in the amounts of any effluent that may be released released offsite, offsite, oror (iii) (iii) aa significant significant increase in individual increase in individual or cumulative occupational radiation exposure. exposure. Accordingly, Accordingly, the the proposed amendment meets proposed amendment meets the the eligibility criterion for categorical exclusion exclusion set set forth forth inin 1010 CFR CFR 51.22(c)(9). pursuant to 10 Therefore, pursuant 51 .22(c)(9). Therefore, 10 CFR 51.22(b), no environmental environment al impact impact statement statement or or environment environmental al assessment assessment need need be prepared in be prepared in connection with with the the proposed proposed amendment. amendment. 6.0

6.0 REFERENCES

REFERENCES 1)

1) NEDE-24011-P-A, NEDE-2401 1 -P-A, "General General Electric Application for Standard Application Electric Standard for Reactor Fuel, Revision Reactor Fuel," Revision 17.17.

ATTACHMENT A11ACHMENT 22 Markup Markup of of Technical Technical Specifications Specifications and and Bases Bases Pages Pages Revised Revised Pages Pages TS 2-1 Bases Bases B 2-1

 .u     ALLFY l.LMI 15ANQ LIMI F1NliSAFLi YSiLM LFF [NGi..

L AF [F Y iJLL fllF.RMAL..2-0WER. FiRMAjj0W LRLuw Low Prsure Pres sure or or LOW low Flow Flow fHERMAL POWER 2.1.1 [HERMAL 2.L POWER shall shall notnot exceed exceed 25% 25% of RATED FHERMAL of RAtED fHERMAL POWER POWER with with the the reactor reactor v(~ssel sstearn vessel team domedome pressure pressure loss than /85 I(~ss than psig 785 psi q or or core core Flow flow less less than than 10% of rated 10% of rated flow. HOW. APPLICABILITY; OPERAtION APLjjjjjLL[Y OPERATIONAL CONDITIONS AL CONDItION and 2. S 11 and 2. With tHERMAL With fHERMAL POWER POWER exceeding 25% 25% of of RATED RATED THERMAL THERMAL POWER POWER and and the reactor vessel the reactor vessel steam dome steam dome pressure pressure less than /85 psig or 785 psig or core core flow less less than than 10%10% of rated flow, of rated flow, be be in in at at least least HOT Ht SHUTDOWN SHUtDOWN within 2 2 hours and and comply comply with with the the requirements requirements of of Specification Specification 6.7.1. THERMAL THERMAL POWER.POWER. High Pressure and High Flow Flow 2.1.2 The 2.1.2 The MINIMUM CRITICAL POWER RATIO (MCPR) shall not be ss than 1. or two recirculation recirculation loop operation and shall not be less than Xl for sing recirculation recirculation loop operation with the reactor vessel steam steam dd me pressure greater than than 785 785 psig and core flow Flow greater than 10% of rated flow. APPLICABILITY: APPJCAB[LI1L OPERATIONAL OPERATIONAL CONDITIONS CONDITIONS 1 1. and 2. ACTION: ,. /(iCi) Q:-i[J~d With MCPR less than(['1W"ror"t~o than or two recirculation loop operation or less than9, than~ I for single recirculation loop operation and the reactor vessel steam dome pressure greater greater than 785 /85 psig and core flow greater than 10% of rated flow, be in at least HOT HOT SHUTDOWN within 2 hours and comply with the requirements of Specification 6.7.1. 6.7.1. REACTOR REACJQR COOLANT SYSTEM PRESSURE 2.1.3 The reactor 2.1.3 reactor coolant system pressure, as measured in the reactor vessel steam steam dome,dome, shall shall not exceed 1325 1325 psig.

9 psi APPLICABILITY: APPLICABILITY OPERATION CONDITIONS 1, OPERATION CONDITIONS 1, 2, 3, and 4. 2, 3, ACTION: ACTION: With With the the reactor reactor coolant coolant system system pressure, pressure, as measured in the reactor vessel steam dome, above dome, above 1325 1325 psig, psig, be be in in at at least least HOT HOT SHUTDOWN SHUTDOWN with reactor coolant system pressure pressure less less thanthan or or equal within equal to 1325 psig within 22 hours to 1325 psig hours andand comply With the comply with requirements requirements of of Specification Specification 6.7.1. 6.7.1. LIMERICK LIMERICK - UNIT - UNIT 22 2-1 2-1 Amendment No. Amendment 4-4, gJ, No. +4, 8, g],8-v, 9+, ++4, 444, 127 127

LLLYJWIL E A S ES

          ?~LO     INTRODUCTION fhe fuel

[he fuel cladding, cladding, reactorreactor pressure pressure vessel vessel andand primary primary system system piping plplng are are thethe principle barriers principle barriers to to the the release release of of radioactive radioactive materials materials to to the the environs. environs. Sdfety Limits are

           ,afety Limits          are established established to      to protect protect the    the integrity integrity of  of these these barriers barriers during during normal      plant     operations        and    anticipated normal plant operations and anticipated transients.                  transients.         rhe

[he fuel fuel cladding cladding integrity integrity Safety Limit Safety Limit is is set set such such that that no no fuel damagedamage is is calculated calculated to to occur occur if if the limit ,/2. the limit is not violated. is not violated. Because Because fuel damage damage is is not not directly directly observable, observable, a a step-back step-back

(1frQch Ch is used to establishestablish aa Safety Safety LimitLimit s~~~ the MCPR is the MCPR is notnot less less than than

~f

~ for two recirculation recirculation loo o eration eration and and L7f sing sinq e e recirculation recirculation p p' for two

                                                          ~for 7

i 100 0 up ration. MCPR greater th two recirculation loop operation and 1 fOr single recirculatlon 10~ oerantp nl /.(,-, operation represents atst? conservative margin rela ye ve to the to the conditions conditions required to maintain maintain fuel cladding integrity. The cladding integrity. The fuel fuel cladding cladding is one is one of of the the physical barn barriers which separate ers which separate the the radioactive materials from radioactive materials from the the environs. environs. rhe The integrity of this cladding cladding barrier"is barrier is related related to to its its relative relative freedom freedom from perforations or cracking. Although Although some corrosion or some corrosion or use use related related cracking cracking may may occur during the life of the cladding, fission product product migration migration from from this source is incrementally cumulative and continuously measurable. this source measurable. Fuel Fuel cladding cladding perforations, however, can result from thermal stresses stresses which occur from which occur from reactor reactor operation significantly above design conditions and the Limiting Limiting Safety Safety System Settings. While fission product migration from cladding System perforation is cladding perforation is just just as measurable as that from use related cracking, the thermally caused caused cladding perforations signal aa threshold beyond which still greater thermal cladding stresses stresses may cause gross rather than incremental cladding deterioration deterioration.. Therefore, the fuel cladding Safety Limit is defined with aa margin to the Therefore, conditions which would produce onset of transition boiling, MCPR of 1.0. conditions 1.0. These conditions represent a significant departure from the condition intended by design for planned operation. 2.1.1 2.1.1 THERMAL POWER. Low Pressure or Low Flow The use of the CGEXL) corre lation is not valid for all critical power (GEXL) correlation calculations calculations at pressures below 785 psig or core flows less than 10% of rated flow. Therefore, the fuel cladding integrity Safety Limit is established by other t-low. Therefore, means. means. This This is is done by establishing est ablishing a limiting condition 00 on core THERMAL POWER with with the following basis. Since the pressure drop in the bypass region is the following essentially essentially all elevation head, the core pressure drop at low power and flows will all elevation always always be greater than be greater than 4.54.5 psi. Analyses show that with a bundle flow of 28 x x

10) lb/hr, lO lb/hr, bundle bundle pressure drop is nearly independent of bundle power and has aa value value of of 3.5 3.5 psi.

psi. Thus,Thus, the the bundle bundle flowflow with a 4.5 psi driving head will be 9rea t e r tthan greater han 28 28 xx 10J b/ hr. Fu iO 1lb/hr 11 scal Full scaleeAT LAS ttest ATLAS data taken est datat aken at pre pressures s sur es from 14.7 from 14.7 psia psia toto 800 800 psia psia indicate indicate that the fuel assembly critical power at this flow flow is is approximately approximately 3.35 3.35 MWt. MWt. With With the design peaking the design factors, this corresponds peaking factors, to to aa THERMAL THERMAL POWER POWER of of more more than than 50% 50% of of RATED THERMAL RATED THERMAL POWER. Thus, a THERMAL POWER Thus, limit limit of of 25% 25% of of RATED RATED THERMAL for THERMAL POWER for reactor POWER reactor pressure below 785 psig is conservative. conservative. LIMERICK LIMERICK - UNIT- UNIT 22 BB 2-1 2-i Amendment No. Amendment No. +4,1-4, &J, 3, g+,8-7., ~, 44.4,

                                                                                                                                          , ++4, 127 127

ATTACHMENT 33 ATTACHMENT Retyped Technical Specifications Retyped Specifications and and Bases Bases Pages Pages Revised Pages Revised Pages rs TS 2-1 2-1 Bases B Bases B 2-1 2-1

USAELLL ?l 2.1 SAFETY {MI rs SAFETY l UMIFS I1ILRMAL POWER. rHERMAL POWER. Low Low Prpssure Pressure or or I Low ow ~low Flow 2.1.1 fHERMAL 2.1.1 FHERMAL POWER POWER ;;ha

                               ;hal11 I not   oxceed 25%

not f~xceed 25% ofof RATED RATED fHERMAL THERMAL POWER POWER with with the the reactor reactor vessel ;team vessel team domedome pres ure less pressure less than 785 psig than 785 psig or or core core flow flow less less than than 10% of 10% of rated rated low. flow. APPLICABILITY OPERATIONAL APPLICABILITY: OPERATIONAL CONDITIONS CONDITIONS 1I and (flCj 2. 2. ACTION: ACTION: With THERMAL With THERMAL POWER POWER exceeding exceeding 25% 25% ofof RATED RATED THERMAL THERMAL POWER POWER andand the the reactor reactor vessel vessel steam dome pressure steam dome pressure less less than 785 psig than 785 psig or or core core flow flow less less than than 10% 10% of of rated rated flow, flow, be in be in atat least least HOT HOT SHUTDOWN SHuTDOWN within within 22 hours hours and and comply comply with the the requirements requirements of of Specification Spec 6.7.1. i fi ca t ion 6.7. 1. THERMAL POWER. THERMAL POWER. High High Pressure Pressure and and High Flow 2.1.2 The 2.1.2 The MINIMUM MINIMUM CRITICAL CRITICAL POWER RATIO (MCPR) shall not be less than 1.09 1.09 for for two two recirculation loop recirculation loop operation and shall not be less than 1.12 for single recirculation loop loop operation with the reactor vessel steam dome pressure greater greater than 785 psig and core flow greater than 10% of rated flow. APPLICABILITY: OPERATIONAL APPLICABILITY: OPERATIONAL CONDITIONS CONDITIONS 1 1 and 2. ACTION ACTION: With MCPR less than With than 1.09 for two recirculation loop operation or less less than 1.12 1.12 for single for single recirculation recirculation loop operation and the reactor vessel vessel steam steam dome dome pressure pressure greater than greater than 785 psig and core flow greater than 10% of of rated flow, be in at at least least HOT SHUTDOWN within HOT SHUTDOWN within 22 hours and comply with the requirements of of Specification Specification 6.7.1. 6.7.1. REACTOR REACTOR COOLANT COOLANT SYSTEM SYSTEM PRESSURE PRESSURE 2.1.3 2.1.3 The The reactor reactor coolant coolant system system pressure, pressure, as as measured measured in in the the reactor reactor vessel vessel steam steam dome, dome, shall shall not exceed 1325 not exceed 1325 psig. psig. APPLICABI APPLICABILITY: LITY OPERATION OPERATION CONDITION CONDITIONS 1, 2, S 1, 2, 3,3, and and 4.4. ACTION: ACTION: With With the the reactor reactor coolant coolant system system pressure, pressure, as as measured measured in in the the reactor reactor vessel vessel steam steam dome, above 1325 dome, above 1325 psig, be psig, be in in at at least least HOT HOT SHUTDOWN SHUTDOWN with with reactor reactor coolant coolant system system pressure pressure less less than than oror equal equal to to 1325 1325 psig psig within within 22 hours hours and and comply comply with with the the requirements of Specification requirements of Specification 6.7.1. 6.7.1. LIMERICK LIMERICK - UNIT-UNIT 22 2-1 2-1 Amendment No. Amendment No. 44,

                                                                                             +/-4, 83,    &+, g+, 44.4
                                                                                                  &J, 8.,         ++4,
                                                                                             .w,

 ;YlMF BA SES 13AS  ES 2,0 LU     INfROOUCTION ENFROUIJCTIUN The The fuel fuel cladding, cladding, reactor reactor pressure vessel and primary system plplng     piping are are the the principle principle barriers harriers to  to the the release release of radioactive materials to the environs. environs.

Safety Safety Limits Limits Jre are establ establ ished shed to protect the integrity of these barriers during during normal normal plant plant operations operations and and anticipated anticipated transients, transients. rhe fuel cladding integrity integrity Safety Safety Limit Limit is is set set such such that that no fuel damage is is calculated to occur if the the limit limit is is not not violated. violated. BecauseBecause fuelfuel damage damage is not directly observable, aa step-backstep-back approach approach is is used to establish a Safety Limit such that the MCPR is not not less less than than 1.09 1.09 for for two two recirculation loop operation and 1.12 for single recirculation loop loop operation. operation. MCPR MCPR greater than 1.09 1.09 for two recirculation loop loop operation and and 1.12 1.12 for for single single recirculation recirculation loop operation represents a conservative margin relative to the conditions required to maintain fuel cladding integrity. rhe Ihe fuel cladding cladding isis one one ofof the physical barriers which separate the radioactive materials from the the environs. environs. rhe Fhe integrity integrity of this cladding barrier is related to its relative freedom freedom from from perforations or cracking. Although some corrosion or use related related cracking may occur during the life of the cladding, fission product migration from from this source is is incrementally cumulative and continuously measurable. Fuel cladding perforations, however, can result from thermal stresses which occur from from reactor operation significantly above design conditions and the Limiting Safety System System Settings. While fission product migration from cladding perforation is is just as measurable as that from use related cracking, the thermally caused caused cladding perforations signal aa threshold beyond which still greater thermal stresses may cause gross rather than incremental cladding deterioration deterioration.. Therefore, the fuel cladding Safety Limit is defined with aa margin to to the the conditions which would produce onset of transition boiling, MCPR of 1.0. These These conditions represent aa significant departure from the condition intended by by design design for planned operation. 2.1.1 THERMAL POWER. Low Pressure or Low Flow The use of the (GEXL) CGEXL) correlation is not valid for all critical critical power power calculations at pressures below 785 psig or core flows less than than 10% 10% of of rated flow. flow. Therefore, fherefore, the fuel cladding integrity Safety Safety Limit is established by by other other means. means. This This is done by establishing aa limiting condition on on core THERMAL POWER POWER with the following basis. Since the pressure pressure drop in in the the bypass bypass region region is is essentially all elevation head, the core pressure drop at at low low power power and and flows will will always be greater than 4.5 psi. Analyses show that with aa bundle bundle flow of of 2828 xx iO3 lb/hr, 10 lb/hr, bundle bundle pressure drop is nearly independent independent of of bundle bundle power power and and has has aa value value ofof 3.53.5 psi. Thus, the bundle bundle flow with aa 4.5 4.5 psi psi driving driving head head will will bebe greater than 28 xx io greater than 10 3 lb/hr. Full scale ATLAS ATLAS test test data data taken taken atat pressures pressures from 14.7 psia from 14.7 psia to 800 psia indicate that the the fuel assembly assembly critical critical power power at at this this flow is flow is approximatel approximately 3.35 MWt. With the y 3.35 the design peaking peaking factors, thisthis corresponds corresponds to to aa THERMAL THERMAL POWERPOWER ofof more thanthan 50% 50% of of RATED THERMAL THERMAL POWER. POWER. Thus, Thus, aa THERMAL THERMAL POWER POWER limit limit of of 25% 25% of of RATED RATED THERMAL THERMAL POWER POWER for reactor pressure pressure below below 785 785 psig psig is is conservati conservative. ye. LIMERICK LIMERICK - UNIT

UNIT 22 BB 2-1 2-1 Amendment Amendment No. +4, g3, No. 4-4, &J, &+, 9+, 4-4,++/-4,

                                                                                              +&7,

ATIACHMENT5 ATTACHMENT 5 Affidavit and Non-Proprietary Nuclear Fuel Letter Non-Proprietary Version of Global Nuclear Letter

Global Nuclear Global Nuclear Fuel- Fuel A.mericas

                                                                            - Americas LLC      LLC AFFIDAVIT A FF1 DAV IT I,1,Anthony Anthony P.P. Reese, Reese,statestateasas follows:

follows: (1) I1 am (I) am the the Manager, Manager, Reload Reload Design Design && Analysis, Analysis, of of Global Global Nuclear Nuclear Fuel Fuel Americas, Americas, LLC LLC (GNF-A), and (GNF-A), and have been have been delegated delegated the the function function of of reviewing reviewing the the information information described described in in paragraph (2) paragraph (2) which which isis sought sought toto bebe withheld, withheld, and and have have been been authorized authorized to to apply apply for for its its withholding. withholding. (2) The (2) The information intbrmation sought sought to to be be withheld withheld isis contained contained in in the the GNF-A GNF-A proprietary proprietary report, report, GNF-GNF 0000-0 125-7436-R0-P, GNF 0000-0125-7436-RO-P, GNF Additional Additional Information Ji/rmation Regarding Regarding the Requested Changes the Requested Changes to to (lie Technical the Technical SpecUication Specification SLMCPR, SLMCPR, LimerickLimerick 22 C12, C12, Class Class III, III, (GNF-A (GNF-A Proprietary Proprietary Information), dated Information), dated November November 20 2010. GNF-A proprietary IO. GNF-A proprietary information information in in GNF-OOOO-O GNF-0000-0125- 125-7436-R0-P isis identified 7436-RO-P identified by by aa dark dark red red dotted dotted underline underline inside double square brackets. inside double square brackets. [[This [[Ihl~

     ~~-')J<;J).<;~...i~... ;m...<;:,;.(~mp.J~= :3:]] Figures Figures and   and large large equation equation objects objects containing containing GNF-A GNF-A proprietary information proprietary           information are    are identified identified withwith double double square square brackets before and       and after the after    the object. In object.       In each each case, case, thethe superscript superscript notation :.'f refers to Paragraph (3) of this affidavit        affidavit thatthat provides the provides        the basis basis for for the proprietary determination.

determination. (3) In (3) In making making this this application application for withholding of proprietary information of which it is the it is the owner or owner or licensee, licensee, GNF-A relies upon the exemption from disclosure set forth forth in in the the Freedom of Freedom of InformationInformation Act (FOIA), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, Act, 18 18 USC Sec. USC Sec. 1905, 1905, andand NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade trade secrets secrets (Exemption 4). (Exemption 4). The The material for which exemption from disclosure is here sought sought alsoalso qualities under qualifies under the the narrower definition of trade secret, within the meanings meanings assigned assigned to to those those terms terms for for purposes purposes of FOIA Exemption 4 in, in, respectively, respectively, Critical Critical Mass Mass Energy Energy Project Project v. v. Nuclear Nuclear Regulatory Commission Commission,, 975 975 F2d F2d 871 871 (DC(DC Cir. Cir. 1992), 1992), and and Public Public Citizen Health Research Group v. Citizen Health Research Group FDA, 704 F2d 1280 (DC FDA, 704 F2d 1280 (DC Cir.Cir. 1983). 1983). (4) (4) The The information information sought sought to to be be withheld withheld isis considered considered to to be be proprietary proprietary for for the the reasons reasons set set forth forth in in paragraphs paragraphs (4)a. (4)a. and and (4)b. (4)b. Some Some examples examples of of categories categories of of information information that that fit tit into into the the definition definition of of proprietary proprietary information information are: are: a.a. Information Information that that discloses discloses aa process, process, method, method, oror apparatus, apparatus, including including supporting supporting data data and analyses, where prevention and analyses, where prevention of its use of its use by by GNF-As GNF-A's competitors competitors without without license license from from GNF-A GNF-A constitutes constitutes aa competitive competitive economic economic advantage advantage over over GNF-A GNF-A and/or and/or otherother companies. compames. b.b. In formation that, Information that, ififused used byby aa competitor, competitor, wouldwould reduce reduce their their expenditure expenditure of ofresources resources or or improve improve their their competitive competitive position position inin the the design, design, manufacture, manufacture, shipment, shipment, installation, installation, assurance assurance of ofquality, quality, oror licensing licensingofofaasimilar similarproduct. product. c.c. Information Information that that reveals reveals aspects aspects of ofpast, past, present, present, or or future future GNF-A GNF-A customer-fun customer-funded ded development plans and development plans and programs,thatprograms, thatmaymayinclude includepotential potentialproducts productsof ofGNF-A. GNF-A. GNF-0000-O I 25-7436-RO-P GN F-0000-0125-7436-RO-P AffidavitPage Page1 1ofof3 3 Affidavit

d. r nI<Jrmation that discloses Information discloses trade trade secret secret andlor and/or potentially potentially patentable matter [or subject matter patentable subject for which itit may be desirable to obtain which obtain patent patent protection.

protection. (5) To address 10 CFR 2.390(b)(4), the information information sought sought to to be withheld isis being be withheld submitted to being submitted to the NRC in confidence. The information information isis of of aa sort sort customarily held in customarily held confidence by in confidence by GNF-A, and is in thct f~lct so held. The information information sought sought to be withheld to be has, to withheld has, best of the best to the of my my knowledge and belief, belief~ consistently been held in confidence confidence by by GNF-A, GNF-A, not been disclosed not been disclosed publicly, and not been made available in public sources. disclosures to All disclosures sources. All third parties, to third parties, including any required transmittals to the NRC, been made, NRC, have been made, oror must must be made, pursuant be made, pursuant to regulatory provisions or proprietary and/or confidentiality agreements that provide provide for maintaining the information in confidence. The initial designation of this information information as as proprietary information, and the subsequent steps taken to prevent prevent its its unauthorized unauthorized disclosure are as set forth in the fbllowing f()llowing paragraphs (6) and (7). (6) Initial approval of proprietary treatment of a document is made by by the manager manager of of the the originating component, who is the person most likely to be acquainted with the value and and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited to a "need know" basis. need to know (7) The procedure for approval of external release of such a document typically requires review staff manager, project manager, principal scientist, or other equivalent authority for by the stafT 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 and/or confidentiality agreements. (8) The information identified in paragraph (2) above is classified as proprietary because it contains details of GNF-A's GNF-As fuel design and licensing methodology for the Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their Reactor (BWR). application application tor for the design, modification, and analyses methodologies and processes was achieved achieved at at a significant cost to GNF-A. The development of the evaluation process along significant the interpretation and application of the analytical results is derived from the extensive with the experience experience database constitutes a major GNF-A asset. database that constitutes (9) (9) Public disclosure of Public disclosure of the information sought to be withheld is likely to cause substantial the information harm to harm to GNF-A's competitive position and foreclose or reduce the availability of profit-GNF-As competitive profit making opportunities. The making opportunities. fuel design The fuel design and licensing methodology is part of GNF-A's GNF-As comprehensive BWR comprehensive BWR safety technology base, and its commercial value extends beyond and technology safety and the original the development cost. original development cost. The The value of thethe technology base goes beyond the extensive database and physical database physical and analytical methodology and analytical methodology includes development of the expertise to and includes determine and determine and apply apply the the appropriate evaluation appropriate evaluation process. In addition, the technology base In includes the includes the value derived from value derived providing analyses from providing done with NRC-approved methods. analyses done GNF-OOOO-O 125-7436-RO-P GNF-0000-0125-7436-RO-P Affidavit Page 2 of Affidavit of 3

The research, The research, development, development, engineering, engineering, analytical analytical andand NRC NRC review review costs costs comprise comprise aa substantial investment substantial investment of oftime time andand money money by by GNF-A, The precise value of the expertise to GNF-A. The precise value of the expertise to devise an evaluation process devise an evaluation process andand apply apply the the correct correct analytical analytical methodology methodology isis difficult difficult to to quantify, but quantify, hut itit clearly clearly isis substantial. substantial. GNF-A's GNF-As competitive competitive advantage advantage will will be be lost Lost ifif its its competitors are competitors are able able toto use use the the results results of ofthe the GNF-A GNF-A experience experience to to normalize normalize oror verify verify their their own process own process or or ififthey they are are able able toto claim claim an an equivalent equivalent understanding understanding by by demonstrating demonstrating that that they can they can arrive arrive atat the the same same oror similar similar conclusions. conclusions. The value The value of of this this information information to to GNF-A GNF-A would would be be lost lost ifif the the information information were were disclosed disclosed to to the public. the public. Making Making such such information information available available to to competitors competitors without without their their having been having been required to required undertake aa similar to undertake similar expenditure expenditure of of resources resources would would unfairly unfairly provide provide competitors competitors with a windfall, with a windfall, and and deprive deprive GNF-A GNF-A of of thethe opportunity opportunity to to exercise exercise its its competitive competitive advantage to advantage to seek seek an an adequate adequate return return on on its its large large investment investment in in developing developing andand obtaining obtaining these very these very valuable valuable analytical analytical tools. tools. II declare declare under under penalty penalty of of perjury perjury that that the the foregoing foregoing affidavit and the matters stated therein are are true and true and correct correct toto the the best best of my knowledge, of my knowledge, information, information, and belief. Executed on Executed on this 23rd day of November, 2010 Anthony P. Reese Manager, Reload Design & Analysis Global Nuclear Fuel Fuel - Americas

                                                                                               - Americas LLC LLC GNFOOOO-GNF-OOOO-O   Ol25-7436-R   O-P I25-7436-RO-P                                                                              AffidavitPage Aüidavt     Page33ofof33

GNF GNF NON*PROPRIETARY NON-PROPRIETARY INFORMATION IN FORMATION Class I GNF Attachment

                                                                   ~ovember November     2010 GNF-0000-0 125-74J6-RO-NP I 25-7436-RU-NP 0000-01125-7436-RO eDRF Section: 0000-0   25-7436-RO GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Limerick 2 Cycle 12 Limerick 2 CycLe Cycle 12            Verified Information Information                     Page Page 11 of 25 of25

GNF NON-PROPRIETARY GNF NON-PROPRIETARY INFORMATION INFORMATION Class Class II GNF GNF Attachment Attachment Proprietary Information Notice This document This document is the GNF is the GNF non-proprietary non-proprietary version of the GNF proprietary report. From the GNF proprietary GNF proprietary version, the information denoted as GNF proprietary (enclosed in double brackets) was brackets) was deleted deleted to generate generate this version. Important Notice Regarding Contents of this Report Please Read Carefully The information contained in this document is furnished solely for the purpose(s) stated in the The transmittal letter. The only undertakings of GNF-A with respect to information in this document are contained in contracts between GNF-A and its customers or participating utilities, and nothing contained in this document shall be construed as changing that contract. The use of this information by anyone for any purpose other than that for which it is intended is not infonnation 110t authorized authorized; and with respect to any unauthorized use, GNF-A makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document. Copyright 2010, Global Nuclear Fuel Fuel- Americas, LLC,

LLC, All All Rights Rights Reserved Reserved Proprietary Propri etary Intbrmation Information Notice N oti ce Verified Information Information Page Page 22 of 25 of25

GNF GNF NON-PROPRIETARY NON-PROPRIETARY INFORMATION I NFORMAT1ON Class Class II GNF GNF Attachment Attachment Table of Contents Table t.O 1.0 i'V1ETI*IOOOLOGY 1ETHODOLOGY ..3 2.0 2.0 DiSCUSSiON DISCUSSION ..4

2. I.

2.1. M uoi Cc 1\I1\.I()R Co nuii,iois TO

                                )NTRIBUTORS          rn SLMCPR SLMCPR CII\:"( C11Ni  ,E                                     A4 2,2.

2.2. DKVIvfloxs [:" DEVL\TIO:"S NRC-ApliwvI;I) U:"CERT.\[:"TIES [N NRC-ApPIHH'EJ) Uxc1.wu.\INIil:s 55 2.2. 1. 1.1./. I~-F*(lcfur R-Faclur 5

       .,2.2.2.
           , .,          ('ore

( ure Fluw Rule and

                                 /7ms Rale             Random L/fecli.e TIP (j,7(/ Ramlullll:l.feClil'e     liP Rem/ing.

I?eui/ing 5 2.2.3. 1.1.3. ( nIciie hrlervu/ f.IRf {'pdale I.PRJI Iuierv(I/ a/1(1 (111(1 ('ulcu/uled ( ulculu(ed Bumlle Bundle Power Poller 6 2.3. 2.3. D1p.R11: RE FRC)\I DEP,\Rl1r[u: NRCAipi )VEI) METlIODOL()(Jy 1R( \I NRC-ApPROVED M[F11( )l)( )I,(X1Y 7 2.4. 2..... Fi 1:1. A\:L\1. FIEL Axil. POWER PoWER SH.\PESIEWE PEN.\I.TY Pl*:N,I:IY 77 2.5. 2.5. MI:imlxI.x;v RESTRICTH)NS METlJOI)()f.OGY R1.sTRICIIoNs 8 2.6. 2.6. MJNI\w1 CcmF. M/:"I\II'\( CoRI FLOWFi.ow CO:"D1TION CosorrioN 8 2.7. 2.7. LL\1IImor Co:" U.\I1TIN( itoi, ROD Co. n~ol. Roi P*\ITERNS PvrIi*:RNs 99 2.8. 2,R, C()I~E MoNr1oRu SYSTE\( (ui MONITORI:\(r Sisn:\f 99 2.9. 2.9. Powu.i/Fi.ow M.\[> P()\VER/FI.O\\! Mu> 9

2. 10.

2.10. Coifl. LO;\DIN(; C()\{(*; D1;R.t Lo.\Dl\u DL\(Jl{.\;\( 9

2. II.

2.11. FI(l 'HE REFERENCES FIGI RE1I*:1I.>cEs 9

2. 12.

2.12. A1)DIIIoi.u, SLMCPR LICE:\SI:"G AJ)J)ITlO'l':\L Licicsi>o CONDITIONS CoNoriloNs 10 10 2.13. 2.13. StxI\I.\R\ Sl"l\Il\l.\RY 10 10 3.0

3.0 REFERENCES

REFERENCES . 11 II List of Figures F111 Iu FI<il'RE 1. CY(,l.I: 12 CYCLE 12 CORE Cotu: LOADING Lo.*o1NG DL\GR";\( DI.IR.\\I 12 12 FIGI i: FIGLRE 2. CyclE CYCLE IL CORE II Coii: LO,\D1NO Lou)1MI DL\OR.\.\1 Dl\GR.-1 13 13 Fiot RE 3, FIGt*RE). Filth 4.1 FRO\t FIGl'RE~.1 nzoi NEDC-)260IP-A NEDC32601PA I~ 14 Fiut ir: 4. FI(;(*RE~. FiGulzl 111.5I ooi FIOUREIlL5-1 NEDC32601 PA FRO\l NEDC-)260IP-A 15 15 F[(u1u 5. FIGUU~ 5, U pox rio FimRE UPDATED 111.52 FROM FIGURE 111.5-2 1ROM NEDC3260 NEDC-32601P-A I P-A 16 16 List of Tables T.\BI.E T \BLE 1.I. DEscRwrioN DESCRWrION 01: OF CoR1 CORE 17 17 T.\Bi.E T\BLE 2. 2. SLMCPR C.u.ct 1,.fl0N MEIlIODOI.OGIES C.\I.CI'f,,\TION ME"l1IODOLOGlES 18 18 T\Bl,E 3. T.m.r: 3. MoNTh MONTE C.aw C\RLO C.u.ctT.VFEJ) C.\LCL'L\TED SLMCPR SUv1CPR vs. vs. EsriI.vn: ESTI:-'fATE 19 19 T\B1.E 4. T.iwi 4. NONPowl;R DIslR 1131 lioN NON-PmvER DISTRIBUTION UNCER'L\lNTIES UNc:wrlNim s 21 21 T.i3l.E T\BLE 5. 5. POWIm D1srRli3L:rioN POwER DISTRIBUTION UNc1Rr.uNrIEs UNCERTAI:-'TIES 23 23 T.]3u T\BLE 6. 6. Cimic.u. CRITICAL POWF;RPOWER Uxl.wr.uNrlI.s UNCERT,\INTIES 25 25 Table Table of Contents Verified Verified Information Information Page Page 33 of 25 of25

GNF GNF NON-PROPRIETARY NON-PROPRIETARY INFORMATION INFORMATION Class Class I1 GNF GNF Attachment Attachment 1.0 tO Methodology Methodology GNF GNF performs performs Safety Safety Limit Limit l\Jfinimum Minimum Critical Critical Power Ratio (SLJ\tlCPR) (SLMCPR) calculation in accordance to accordance NEDE-2401II-P-A to NEDE-240 1-P-A "General General Electric Electric Standard Standard Application for tbr Reactor Fuel" Fuel (Revision 17) (Revision 17) using using the the following following NRC-approved NRC-approved methodologies and uncertainties:

    **  NEDC-3260lI P-A NEDC-3260        P-A "Methodology Methodology and Uncertainties for Safety Limit MCPR       NlCPR Evaluations" Evaluations (August 1999).

(August 1999).

    **  NEDC-32694P-A "Power NEDC-32694P-A           Power Distribution          Uncertainties     for    Safety     Limit      lVICPR MCPR Evaluations (August Evaluations"    (August 1999).

1999).

    **  NEDC-32505P-A "R-Factor NEDC-32505P-A          R-Factor Calculation Method for GEl        GEL I, GEI2 and GEl3     GE13 Fuel"Fuel (Revision 1,1, July 1999).
    **  NEDO-10958-A NEDO-l     0958-A ~'General General Electric BWR Thermal Analysis Basis (GET              (GETAB):AB): Data, Correlation and Design Application" Application (January 1977).

identifies the actual methodologies used for the Limerick 2 Cycle II Table 2 identities 11 and the Cycle 12 SLMCPR calculations. SLNtCPR 20 Discussion 2.0 In this discussion, the TLO nomenclature is used for two recirculation loops in operation, and the SLO nomenclature is used for one recirculation loop in operation. 2.1. Major Contributors to SLMCPR Change In general, the calculated safety limit is dominated by two key parameters: (1) (I) flatness tlatness of of the core bundle-by-bundle M.CPR MCPR distribution, and (2) flatness tlarness of the bundle bundle pin-by-pin pin-by-pin power/R power/R-Factor distribution. Greater flatness in in either parameter yields more rods susceptible susceptible to to boiling boiling transition and thus a higher calculated SLMCPR. MW MIP (MCPR (MCPR importance Importance Parameter) Parameter) measures measures the core bundle-by-bundle MCPR distribution and RIP (R-Factor Importance Parameter) measures the bundle pin-by-pin pin~by-pin power/R-Factor distribution. The The impact impact ofof the the fuel loading loading pattern on the calculated TLO SLMCPRSLl\JICPR using rated rated core core power power and and rated rated core core flow conditions conditions has been correlated to the parameter M1PRIP,

                                         ~llPRIP, which combines combines the MIP and  and RIP RIP values.

values. Table 33 presents the MIPNnp and RIP parameters parameters for Cycle Cycle II11 and and Cycle Cycle 12 12 along along with with the the TLO TLO SLMCPR estimate using the MIPR1P MIPRIP correlation. correlation. If If the the minimum minimum core core flow tlow case case isis applicable, applicable, the TLO SLMCPR estimate is also provided provided for for that that case case although although the the MIPRIP MIPRIP correlation correlation is is only applicable to the rated core core flow case. case. This This isis done done only only to to provide provide some some reasonable reasonable Methodology rvrethodology Verified Veriti ed Information Intormation Page Page 44 of of25 25

GNFNON-PROPRIETARY GNF NON-PROPRIETARY INFORMATION INFORMATION Class Class II GNF Attachment GNF Attachment assessment basis assessment basis ofofthe the minimum minimum core core flow tiow case case trend. trend. InEn addition, addition, Table fable 33 presents presents estimated estimated impacts on impacts on the the TLO TLO SLMCPR SLMCPR due due toto methodology methodology deviations, deviations, penalties, and/or uncertainty penalties, and/or uncertainty deviations from deviations from approved approved values. values. Based Based on on the the MIPRIP M1PR1P correlation correlation and and any any impacts impacts due due to to deviations from approved deviations from approved values, values, aa finalfinal estimated estimated TLOTLO SLlV1CPR SLMCPR isis determined. determined. Table Table 33 alsoalso provides the provides the actual actual calculated calculated Monte Monte Carlo Carlo SLl\'ICPRs. SLMCPRs. Given Given the bias and the bias and uncertainty uncertainty in in the the M1PRIP correlation

YllPRIP correlation [[{[ ]]jJ and and the the inherent inherent variation variation in in thethe Monte Carlo Monte Carlo results results [[[[ n, fl, the the change change in in the the Limerick Limerick 2 Cycle 12 calculated 2 Cycle 12 calculated Monte Monte Carlo ILO Carlo TLO SLMCPR SLMCPR using using rated rated corecore power power andand rated rated core core flow flow conditions conditions isis consistent consistent with with the corresponding the corresponding estimated estimated ILO TLO SLMCPR SLMCPR value. value.

2.2. Deviations 2.2. Deviations in in NRC-Approved NRC-Approved Uncertainties Uncertainties Tables 44 and Tables and 55 provide provide aa list list of of NRC-approved NRC-approved uncertainties along with values actually used. used, A A discussion of discussion of deviations deviations fromfrom these NRC-approved NRC-approved values follows~ follows; all of which are conservative relative to relative to NRC-approved NRC-approved values. Also, estimated impact on the SLl\1CPR SLMCPR is provided in Table Table 3 for each deviation. 3 for each deviation. 2.2.1. R-Factor At this At this time, time, GNF has generically increased the GEXL R-Factor uncertainty from [[ j]to account for an increase in channel bow due to the emerging unforeseen phenomena [[

          ]]  to account called control called   control blade shadow corrosion-induced corrosion-induced channel bow, which is not accounted for in the                                  the channel channel bow bow     uncertainty     component of the approved R-Factor uncertainty. The step a                               "cr RPEAK RPEAK" in figure in  Figure 4.1 4.! from from NEDC-3260 NEDC-32601P-A,    1P-A, which has been provided for convenience           convenience in       in Figure figure 33 of   of this attachment, this  attachment, is    is affected by this deviation. Reference 4 technically justifies                 justifies thatthat aa GEXL GEXL R      R-Factor Factor uncertainty uncertainty of   of {[

[[ ]j

                                          ]] accounts for a channel bow uncertainty      uncertainty of    of up toto [[

[[ ]]. j]. Limerick Limerick 22 has has experienced experienced control blade shadow corrosion-ind corrosion-induced uced channel channel bow bow to to the the extent extent that an increase in the that an increase in the NRC-approvedNRC-approv ed R-Factor R-Factor uncertainty uncertainty [[ [( j]]] is is deemed deemed prudentprudent to to address address its its impact. impact. Accounting Accounting for the the control control blade blade shadow shadow corrosion-ind corrosion-induced channel bow, uced channel bow, the the Limerick Limerick 22 Cycle Cycle 12 12 analysis analysis shows shows an an expected expected channel channel bow bow uncertainty uncertainty of of [[[[ ]], which is bounded by a GEX.L R-Factor which is bounded by a GEXL R-Factor uncertainty uncertainty of of [[ [[ 1].

                                                                                              ]]. Thus Thus the the use use of of aa GEXL GEXL R      R-Factor Factor uncertainty uncertainty of   of {[[[          ]j]] adequately adequately accounts accounts for  for thethe expected expected control control bladeblade shadow shadow corrosion-ind corrosion-induced  uced channel channel bow bow for for Limerick Limerick 22 Cycle Cycle 12. 12.

2.2.2. 2.2.2. Core Core FlowFlow RateRate andand Random Random Effective Effective TIP TIP Reading Reading In In Reference Reference 55 GNF GNF committed committed to to the the expansion expansion of of the the state state points used in points used in the the determinatio determination n of of the SLMCPR. Consistent with the Reference the SLMCPR. Consistent with the Reference 55 commitment commitments, s, GNFGNF performs performs analyses analyses atat the the rated rated core core power power and and minimum minimum licensed licensed core core flow flow point point inin addition addition toto analyses analyses atat the the rated rated core core power power andand rated rated core core flow flow point. point. The The approved approved SLMCPR SLMCPR methodology methodology isis applied applied atat each each state state Discussion Discussion Verified VerifiedInformation Information Page55of Page of'25 25

GNFNON-PROPRIETARY GNF NON-PROPRIETARYINFORMATION INFORMATION ClassI I Class GNFAttachment GNF Attachment pointthat point thatisisanalyzed. analyzed. Forthe For theTLO TLOcalculations calculations performed performedatat82.9% 82.9%core coreflow, flow, thetheapproved approved uncertainty uncertainty values values for for thethe core core now flow rate rate(2.5~/o) (2.5%) and and the the random random effective effective TIP T1P reading (1.2%) are reading (1.2°/0) are conservatively adjusted conservatively adjusted byby dividing dividing them them by by 82.9/1 82,9/100. 00. TheThe steps steps'"a a CORE CORE FLOW" FLOW and and "a a TIP TIP (INSTRUMENT)" (INSTRUMENT) inin Figure 4. 1 from Figure 4.1 from NEDC-3260 NEDC -3260I IP-A, P-A, \.vhich which has has been been provided provided for for convenience convenience inin Figure Figure 33 of of this this attachment, are attachment, areaffected affected by by this this deviation, deviation, respectively. respectively. Historically, these Historically, these values values have have beenbeen construed construed to to bebe somewhat somewhat dependentdependent on on the the core core tlow flow condit ions as demon strated conditions as demonstrated by the fact that by the fact that higher higher valuesvalues have have always always been been usedused whenwhen performing SLO perfonning SLO calculations. calculations. ItIt isis for for this this reason reason that that GNF GNF determined determined that that itit isis appropriate appropriate to to consider an consider an increase increase inin these these two two uncertainties uncertainties when when the the core core tlow flow is reduced. The amount is reduced. The amount of of increase isis determined increase determined in in aa conservative conservative way. way. For For bothboth parameters parameters itit isis assumed assumed that that the the absolute absolute uncerta inty remain uncertainty remains the same s the same as as the the flow flow isis decreased decreased so so that that the the percentage percentage uncertainty uncertainty increases inversely increases inversely proportional proportional to to the the change change in in core core now. flow. This This isis conservative conservative relative relative toto the the core flow uncerta inty since the variabi core tlow uncertainty since the variability in the absolute lity in the absolute tlow flow is is expected expected to to decrease decrease somewhat somewhat as the as the flow flow decreases. decreases. For For the the random random etfective effective TIP TIP uncertainty, uncertainty, there there is is no reason to to believe believe that the that the percentagepercen tage uncertainty uncertainty should should increase increase as as the core tlow flow decreases decreases for for TLO. TLO. Nevertheless, this Nevertheless, this uncertainty uncertainty is is also also increased increased as is done in the more extreme extreme case forcase for SLO SLO primarily to primarily to preserve preseie thethe historical historical precedent precedent established established by the SLO evaluation. evaluation. Note that that thethe TLO condition TLO condition is is different different than the SLO condition condition because because for TLO there is no expected tilting expected tilting of the of the core core radial radial power power shape. The treatment The treatment of of the the core core flow and random effective effective TIP reading uncerta uncertainties inties is based on on thethe assum ption that assumption that the signal the signal to noise ratio deterio deteriorates rates as core flow tlow is reduce reduced. d. GNF believe believess this this is conservative is conservative and and may may in the future provid provide e justific ation that the origina justification originall uncerta uncertainties (non-inties (non flow dependent) flow dependent) are are adequa adequately tely bound bounding.ing. The The corecore flow tlow and and random random TiP TIP reading uncerta uncertainties inties used used in in the the SLO SLO minimmlllimum core flow um core flow SLMC PR analys SLMCPR analysis remain the is remain the same as inin the the ratedrated corecore flow flow SLO SLO SLMCSLivlCPR analysis PR analys because is becaus e these these uncerta uncertaintiesinties (which (which arc are substa ntially larger substantially larger than than used used in in the the TLO TLO analys analysis) already account is) already account for for the the effects effects of of operati operating ng at at reduce reduced d core core flow. flow. 2.2.3. 2.2.3. LPRM LPRM Update Update Interva Interval l and and CalculCalculated ated Bundle Bundle Power Power To To adequa adequately tely addres address s thethe LPRMLPRM update lcalibration interva update/calibration interval l inin the the Limeri Limerick ck 22 Techni Technical cal Specif ication Specifications, s, GNF GNF has has increas increased ed the the LPRM LPRM update update uncerta inty inin the uncertainty the SLMCPR. SLMCPR analys analysis for is for Limeri Limerick ck 22 CycleCycle 12. 12. TheThe approv approved ed uncerta uncertainty inty values values for for the the contrib contribution to bundle ution to bundle power power uncerta uncertaintyinty due due toto LPRM LPRM update update [[jj and and the the resultin resulting g total total uncerta uncertainty inty inin calcula calculated ted bundle bundle power power [[j] are are conser vatively increas conservatively increased.ed. The The steps steps a"0 TIPTIP (INST (INSTRUMENT)" RUMENT) and and a a cr BUND BUNDLE LE (MOD(MODEL)" EL) inin Figure Figure 4.1 4.1 from from NEDC -326OlP-A, which NEDC-3260IP-A, which has has been been provid provided ed for for conven ience ininFigure convenience Figure33of ofthis this attachm attachment,ent, are areaffecte affected d by bythis thisdeviati deviation. on. Discus sion Discussion Verifie Verified d Inform ation Information Page66of Page of25 25

GNFNON-PROPRIETARY GNF NON-PROPRIETARY INFORMATION INFORMATION Class Class [I GNF Attachment GNF Attachment [[

                                                                                  ]]11 The The total total bundl bundlee power power uncertainty isis aa function uncertainty            function of   the LPRM of the  LPRM update update uncertainty as detailed in Section 3.3 of uncertainty   as detailed     in Section   3.3  of NEDC-NEDC 32694P-A.

32694P-A. 2.3. Departure 2.3. Departure from from NRC-Approved NRC-Approved Methodology Methodology No departures No departures from from NRC-approved NRC-approved methodologies methodologies were used in the Limerick 2 Cycle 12 SLMCPR calculations. SLMCPR calculations. 2.4. Fuel Axial Power Shape Penalty Penalty At this At this time, time, GNF has has determined that higher uncertainties and non-conserva non-conservative tive biases in thethe GEX.L correlations GEXL correlations for for the various types of axial power shapes (i.e., (i.e.) inlet, cosine, outlet outlet and and double hump) double hump) could potentially exist relative to the NRC-approv NRC-approved ed methodology values, see References References 3, 3, 6, 7 and 8. The following table identities, identifIes, by marking with an X, "X", this potential potential for for each each GNF product product line currently being offered: III [ IIII Axial bundle power shapes correspondin Axial bundle power shapes corresponding to g to the the limiting limiting SLMCPR SLMCPR control control blade blade patterns patterns are are determined determined using using the the PANACEA PANACEA 3D 3D core core simulator. simulator. These These axial axial power power shapes shapes are are classiFied classified in in accordance accordance to to the the following following table: table: II[[ Discussion Discussion Verified Verified Information Information Page77of25 Page of 25

GNF NON~PROPRrETARY GNF NON-PROPRIETARY rNFORMATrON IN FORMATION Class Class II GNF GNF Attachment Attachment II the limiting If the If limiting bundles bundles inin the the SLMCPR SLMCPR calculation exhibit an axial power shape identified by this table, GNF table, penalizes the GEXL GNF penalizes GEXL critical power uncertainties to conservatively conservatively account for the impact of impact of the axial axial power shape. Table 6 provides a list of the GEXL critical power uncertainties determined in determined in accordance accordance to the NRC-approved NRC-approved methodology contained in NEDE-240 NEDE-240lIl-P-Ai-P-A along with values actually used. along For the limiting bundles, the fuel axial power shapes in the SLMCPR analysis were examined to determine the presence of axial power shapes identified in the above table. These power shapes determine were not found~ were found, therefore, no power shape penalties were applied to the calculated Limerick 2 2 Cycle 12 Cycle 12 SLMCPR SLMCPR values. 2.5. Methodology Restrictions The four restrictions identified on Page 33 of NRC's NRCs Safety Evaluation relating to the General Electric Licensing Topical Reports NEDC-32601P, 1P, NEDC-3269 NEDC-32694P, 4P, and Amendment Atnendment 25 25 to NEDE-2401II-P-A NEDE-240 I-P-A (March 11, ii, 1999) are addressed in References I, 2, 3, and 9. No new No new GNFGNF fuel designs are being introduced in Limerick 2 Cycle 12: 12:, therefore, the NEDC NEDC-32505 P-A statement** 32S0SP-A statement.... ifif new fuel is introduced, GENE must confirm contirm that the revised R-Factor method is still valid based on new test data data" is not applicable. 2.6. Minimum Core Flow Condition For Limerick 22 Cycle 12, 12, the minimum core flow tlow SLMCPR SLMCPR calculation calculation performed performed at at 82.9% 82.9% core core flow flow andand rated core power rated core power condition was limiting as compared to the rated core core flow tlow and and rated rated core power condition. core power condition. At At low low core flows, tlows, the search search spaces spaces for the limiting limiting rod rod pattern pattern and and the the nominal rod pattern are essentially nominal rod pattern are essentially the same. Additionally same. Additionally,, the the condition condition that that MIP MIP [[([ J]]] establishes a reasonably reasonably bounding bounding limiting limiting rod rod pattern. pattern. Hence, Hence, the the rod rod pattern pattern used to calculate calculate the SLMCPR SLrv1CPR at at 100% 100% rated rated power/82.9% power/82.9% rated rated flow flow reasonably reasonably assures assures thatthat atat least 99.90/0 of the least 99.9% the fuel rods rods in in the the core core would would not be expected not be expected to to experience experience Discussion Discussion Verified Verified Information Information Page Page 88 of 25 of25

GNF NON-PROPRIETARY GNF NON-PROPRIETARY INFORMATION INFORMATION Class II Class GNF GNF Attachment Attachment boiling transition boiling transition during during normal normal operation operation oror anticipated anticipated operational occurrences during the operation of operation Limerick 22 Cycle of Limerick Cycle 12.

12. Consequently, Consequently, the SLMCPR SLMCPR value calculated from the 82.90/0 82.9%

core tlow core flow andand rated rated core power condition core power condition limiting limiting lVlCPR MCPR distribution reasonably bounds this mode of mode of operation operation forfor Limerick Limerick 22 Cycle Cycle 12. 12. 2.7. Limiting 2.7. Limiting Control Rod Patterns The limiting control rod patterns used to calculate the SLMCPR reasonably assures that at least The 99.9% of 99.9% of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of Limerick 2 2 Cycle 12. Cycle 12, 2.8. Core Monitoring System For Limerick 2 Cycle 12, the 3DMonicore system will be used as the core monitoring system. 2.9. Power/Flow Map The utility has provided the Cycle 11 and 12 power/flow map(s) in a separate attachment. 2.10. Core Loading Diagram Figures I1 and 22 provide the core-loading diagram for Cycle 12 12 and 11 II respectively, which which are are the the ReiBrence Loading Pattern as defined by NEDE-2401 Reference I-P-A. Table NEDE-240 Il-P-A. Table I1 provides provides aa description description of of the core. 2.11. Figure References Figure 33 is Figure 4.1 from NEDC-3260 NEDC-32601P-A. 1P-A. Figure Figure 44 is is Figure Figure 111.5-1 from NEDC-3260 IlI.5-I from NEDC-32601 1P-A. P-A. Figure 55 is based on Figure Figure Figure 111.5-2 llI.5-2 from NEDC.-3260 NEDC-32601P-A 1P-A andand has has been been updated updated with with GE14 GE14 and and GNF2 GNF2 data. It It has been been reviewed and approved approved byby the the NRC NRC as as supported supported byby Reference Reference 10. 10. Discussion Discussion Verified Verified Information Information Page 99 of Page 25 of25

(INF NON-PROPRIETARY GNF NON-PROPRIETARY INFORMATION INFORMATION Class II Class GNF Attachment GNF Attachmcnt 2.12. Additional 2.12. Additional SLMCPR Licensing Conditions For Limerick For Limerick 22 Cycle Cycle 12, 12, no no additional additional SLIVtCPR SLMCPR licensing conditions conditions are included 10 in the analysis. analysis. 2.13. Summary The requested The requested changes changes to the Technical Specification SLMCPR values are 1.09 for TLO and to the 1.12 I. for SLO J 2 for SLO for for Limerick Limerick 2 Cycle 12. Discussion Discussion Verified Verified Information Information Page 10 of Page 10 25 of25

GNFNON-PROPRfETARY GNF NON-PROPRIETARYfNFORMATfON INFORMATION Class Class I1 GNF Attachment GNF Attachmcnt 3.0 References 3.0 References I.I. Letter, Letter, Glen Glen A. A. \Vatford Watford (GNF-A) (GNF-A) to to U.S. U.S. Nuclear Nuclear Regulatory Regulatory Commission Commission Document Document Control Control Desk Desk with attention with attention to R. Pulsifer to R. Pulsifer (NRC), (NRC), "Confirmation Confirmation of of lOx 10 Fuel lOxlO Fuel Design Design Applicability Applicability to to Improved Improved SLMCPR, Power SLl\1CPR, Power Distribution Distribution and R-Factor !'vlethodologies", and R-Factor Methodologies, FLN-200 1-0 16, FLN-200l-0l 6, September September 24,24, 200 1 2001. 2.2. Letter, Letter, Glen Glen A. A. Watford Watford (GNF-A) (GNF-A) to to U.S. U.S. Nuclear Nuclear Regulatory Regulatory Commission Commission Document Document Control Control Desk Desk with attention to J. Donoghue with attention to 1. Donoghue (NRC), (NRC), "Confirmation Confirmation of of the the Applicability Applicability of of the the GEXL GEXLI4 14 Correlation Correlation and Associated and Associated R-Factor R-Factor Methodology Methodology for for Calculating Calculating SLMCPR SLMCPR Values Values inin Cores Cores Containing Containing GE GEI414 Fuel, FLN-200 Fuel", FLN.-200l-0 l7, October 1-0 17, October I,I, 200 2001. I.

3. Letter,

3. Letter, Glen Glen A. A. Watford Watford (GNF-A)

(GNF-A) to to U.S. U.S. Nuclear Nuclear Regulatory Regulatory Commission Commission Document Document Control Control Desk Desk with attention with attention to Joseph E. to Joseph E. Donoghue Donoghue (NRC), (NRC). "Final Final Presentation Presentation Material for for GEXL GEXL Presentation Presentation February 11,2002", Febnlary 11,2002, FLN-2002-004, FLN-2002-004, February 12,2002. 12,2002. 4.

4. Letter, John Letter, John F. F. Schardt Schardt (GNF-A)

(GNF-A) to to U.S. Nuclear Regulatory Regulatory Commission Document Control Control Desk Desk with attention with attention to Mel B. to !'vlel B. Fields (NRC), "Shadow Shadow Corrosion Effects on SLMCPR ChannelChannel Bow Bow Uncertainty , FLN-2004-0 Uncer1ainty", FLN-2004-030, 30, November 10,2004. 5.

5. Letter, Jason Letter, Jason S. Post (GENE) to U.S. Nuclear Regulatory Commission Document Control Desk Desk with with attention to attention to Chief:

Chief, Information Management Branch, et al. (NRC), Pm "Part 21 Final Report: Report: NonNon-Conservative SLl\1CPR", Conservative SLMCPR, MFN 04-108, September Septelnber 29, 2004. 6.

6. Lctter, Glen Letter, Glen A. A. Watford Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk Desk with attention to Alan Wang (NRC), NRC with attention "NRC Technology Update - Proprietary Slides Slides - July

July 31 31 - August 1,2002, August I, 2002", FLN-2002-0 15, October October3l,31,2002. 2002. 7.

7. Letter, Letter, lens Jens 6.G. Munthe Nlunthe Andersen (GNF-A) to U.S. Nuclear Nuclear Regulatory Regulatory Commission Commission Document Document Control Desk Control Desk with with attention to Alan Wang (NRC), GEXL "GEXL Correlation for for lOXlO 10XIO Fuel, Fuel", FLN-2003-FLN-2003-005, 005, May May 31, 2003.

31,2003. 8.

8. Letter, Letter, Andrew Andrew A. A. Lingenfelter Lingenfelter (GNF-A)

(GNF-A) to to U.S. U.S. Nuclear Nuclear Regulatory Regulatory Commission Comtnission Document Document Control Control Desk with cc to MC Honcharik (NRC), Desk with cc to MC Honcharik (NRC), Removal "Removal of of Penalty Penalty Being Being Applied Applied toto GEJ4 GE 14 Critical Critical Power Power Correlation Correlation forfor Outlet Outlet Peaked Peaked Axial Axial Power Power ShapeW, Shapes", FLN-2007-0 FLN-2007-031, 3l, September September 18,2007. 18,2007. 9.

9. Letter, Letter, Andrew Andrew A. A. Lingenfelter Lingenfelter (GNF-A)

(GNF-A) to to U.S. U.S. Nuclear Nuclear Regulatory Regulatory Commission Commission Document Document Control Control Desk Desk with with cccc toto MC MC Honchaiik Honcharik (NRC), (NRC), GNF2 "GNF2 Advantage Advantage Genetic Generic Compliance Compliance withwith NEDE-2401 NEDE-240 11- I-P-A P-A (GESTAR (GESTAR II), ll), NEDC-3327 NEDC-33270P, 0P, Revision Revision 2, June 2009 2, June 2009 andand GEXL GEXL Correlation Correlation for for GNF2 GNF2 Fuel, Fuel, NEDC-3329 NEDC-33292P, 2P, Revision Revision 3, 3, June June 2009, 2009", MFN MFN 09436, June 30,2009. 09-436, June 30,2009. 10.

10. Letter.

Letter, John John D. D. Hughley Hughley (NRC)(NRC) to to Michael Michael J.J. Pacilio Pacilio (Exelon (Exelon Generation Generation Company, Company, LLC),LLC), Peach "Peach Bottom Atomic Power Station, Unit 2 Bottom Atomic Power Station, Unit 2 - Issuance of issuance ofAmendment Amendment Re: Re: Safety Safety Limit Limit Minimum rvfinimum Critical Critical Power Power Ratio Ratio Value Value Change Change (TAC(TAC No. No. ME3994, rvlE3994)", ML10257 ML102571768,1768, September September28, 28, 2010. 2010. References References Verified Verifiedinformation Information Page 11II of Page of25 25

N::: GNF2-PI0CG2B396-6G7.0j6G6 0-120T2-150-Page 12 of25 Lf M= GE14-PIOCNAB409-12GZ-120T-150-T6-2951 HO 0 T6-3648 Lfl Lfl Ifl In C c () rfl r 0( (N C1N(N E-4 I I (N I D O (0 (0 0= GE14-PIOCNAB410-15GZ-120T-150-T6-2952 (0t- (0QHHt-F-E-C E-iHHIflI J) 9 11 13 1517 19 21 2:3 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 (C I I C) 4 0 0 ID 0 1.4) 0 0 0 (0 I If) LI) LI) If) p= GE14-PIOCNAB408-14GZ-120T-150-T6-2953 O Iil F1J LI) H 0 In Ill II) H (4 H H H H H H H I H t I (N 0 (NC) (NC) LI, If) E-Q= GE14-PIOCNAB410-13GZ-120T-150-T6-2955 o ( o a a a a a a a EJEJ Lf 1JjJ Jiii 6J E1i1 tIjL a If) - (N C

(N(N (N C) (N IN (N (N H I H H 0 H H H H IC I I I I R= GNF2-PIOCG2B391-14GZ-120T2-1S0-T6-372S Figure l. Cycle 12 Core Loading Diagram N til l jJ EiLJ iil1 ii Li IiL 1 1 0) 0

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GNF NON-PROPRIETARY INFORMATION 00 HOHG)OG)CIC 4. T= GNF2-PIOCG2B389-14GZ-120T2-150-T6-3645 a m iirn

4. .-a:c\ NC)(N t11 Jj EJ LJ 1jiI fj1 ME iFJ E1aJ Jii1 i1 LIJ Ji1 l!Ji1J I1i1J 1 2 2 A) C) A) C) C) u= GNF2-PI0CG2B391-1SGZ-120T2-150-T6-3646

4. OU C)UUUUUUUU 00 000000000 Cl)

C) H H f-I f-I H s-I H s-I H s-I s-I LDicL jJ tj Verified Information C tj Fjj il1 iI th tJ v= GNF2-PI0CG2B392-14GZ-120T2-150-T6-3647 I I I C) 0 Class I z C) it) (-I I1 2 o 2 2 2 2 2 2 Fuel Type ii jj1 IkE ji ii FJitJ iii IiL1 a) W= GNF2-PIOCG2B391-14GZ-120T2-150-T6-3725 a C) C) r C!) C) C) C) C) C) C) C) C) a 04

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H 0) C) H GNF Attachment A= GNF2 PIOCG2B404-12G6.0-120T2-1S0-T6-3643 C, I,. a) 45 I 0 Li r%I (4 ICC If a) z 11iI i1 1tE1J 1I i iEIliJi13 i1J LI, C, LI 4. 4. 4. t- 0) 0) H H (CO 13= GNF2 P1 0 CG 2B3 8 6 - 2G8 . 0/ 11 G7 . 0 - 1 2 OT2 - 1 SO -

(N jj I() 10 II) L.A II) LA CI) 1.0 LI) If EJ [j1 jT rjT jjT jT jThj Li 1 1ti jrl LJ N I CI) C, H s-i s-I I I H CI C) I C, C, (I) (0 II C4(N I

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H 4 H LA In If) I 11) 1(1 If) z I I H H H H H H H 0= GNF2-PIOCG2B391-15GZ-120T2-150-T6-3646 LA I I IC 1 1 I 000000 H 000 iiiiII[IiL E= GNF2-PIOCG2B392-14GZ-120T2-150-TG-3647 C-) (N (N (N (N (N (N I (N (N (N HHHHs-IHOHHH I I I I I I 1 I I F= GE14-PI0CNAB389-14GZ-120T-lSO-T6-3157 N N N N N N 0) N N N JLl Ei ti 0) C) cc (NC)

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L:::: GE14-PIOCNAB410-16GZ-120T-150-T6-2950 II II I_() II II II II II H II II Ii II

GNF GNF NON-PROPRIETARY NON-PROPRIETARY INFORMATION INFORMATION Class II GNF Attachment Figure 2. Cycle II 11 Core Loading Diagram 60 60 JJ JJ j[J J AJ 58 58 TTj 56 56 54 54 52 52 J flJ 50 50 48 48 LiJ LJ LJ[LJ LilJ FiJ 46 46 4 44 1tiiiiiiiiaiJiI1 42 40 40 iiØiI iDi 38 Tj 1j j 1j j Tj 36 36 iiiiiiiiiiI1 ffl JJ 34 34 32 32 ElI I[1I1IDiI DE1iL 30 28 28 EJ JiE EJ E Ei EiEI EiJ Ei1 EiE!i LftlJ EiE 1DiE Ei it!1 26 24 24 EiE FiiE1 EiJ Ei El1 1ii!!1 EiIi di 11ii ii E 1i1 EiE d!1 22 jT fj j Ij j [j Ij j 20 IJi Ji Ji1 EiJ EiI Ei1 IJii 1iE Ji1 EThE iI JiEI IJ lI 18 18 16 18 14 12 12 EIIIILIi[EI1 10 8 jØ 6 r jI Jj III jJj j[j jIj IIIl Ij j 44 2 11 3 5 77 9 11 13 15 17 19 21 23 25 27 29 31 33 33 3535 37 37 39 39 41 43 43 45 45 47 47 49 49 51 51 53 53 55 55 57 57 59 59 Fuel Type (F14PIOCNAB300 I 5GZ I 201150162532 A GEI-l-PlOCNAB4110-150Z-120T-15{)-T6-2832 IT (1F14-PIOCNAI33O9 I6GZ- i201-l 50T62956 fIGEI-l-P10CNAB409-IMI1-120T-150-T6-2956 BGF 14-PlOCNi\BJ97-1*:t(iZ-120T-150-T6-2833 BGE 14-P1C)CNAB397- 146Z- 120T- I 50-T6-2X33 (}h I4PIOCNAII4 1I (H*: 1016GZ 120T I 50T6295() 14-P10CNAB-lIO-16GI-120T-150-T6-2950 U G} 14-PIOCNAB38l)-14GI-120T-150-T6-] cerE 14P 10UNA133K9 14G/ I 20T 150T63 157 157 IJGE 4-P 1 OCNA K409-(IF I14-PIOCNA 12(1!- 1201- I 5016-2951 B409-12GZ-120T-150*T6-2951 (1E14-PIOCNAH389-ISGZ-1201-150-T6-315$

1) OE D 14-PIOCNAB389- 15GI-120T-150-TG-] 158 K ;E14-P10C:NAB4IO15GZ-120T-150T6-2952 KGE14-PIOCNAB41O-15GZ-120T-150-T6-2952 F GEI3P10UNA13391 I3GZ 12(11150163159 EGEI4-PIOCNAB391-1301- 120T- I50-T6-3159 GF 14-PIOCNA134()8- 14(1!- 1201_I 50l62953 1.LGEI-l-PIOCNAB408-14GZ-120T-150-T6-2953 F GEI4-PIOCNAH39I-13G80-120T- 150-T6-3160 FGEI4-PIOCNAB391-13GR.O-I:!OT-150-T6-3160 M 0E14-PIOCNAI34O5-146Z- 12(11- 150-T6-2954 GEl-l-P10CNAB405-14Gl-120T-150-T6-2954 G UFI4-PIOCNAR39O I2Gt 120T- I5UF63161 (1 GEI4*PIOCNAB390-12GI-120T*150-T6-3161 N N GE14-PIOCNAH4 1013(1! 1201-I 5i-16-2955 GEI-l-PIOCNAB41O-I.3GI-121)T-150*T6-295S Page 1313 of25 of25 Verified Information Information

GNF NON-PROPRIETARY INFORMATION IN FORMATION Class II GNF Attachment [[ [[ 11]] Figure 3. Figure 4.1 from NEDC-3260IP-A NEDC-32601P-A NEDC-3 2601I P-A Figure 3. Figure 4.1 from NEDC-3260 Page 14 14 of 25 of25 Verified Information

GNF NON~PROPRrETARY GNF NON-PROPRIETARY rNFORMATrON INFORMATION Class (lass II GNF GNF Attachment Attachmcnt [[ 1]]] Figure Figure 3.4. Figure Figure 111.5-1 111.5-1 from from NEDC-3260 NEDC-3260IP-A 1P-A Figure Figure 4.4. Figure Figure III5-I III.5-1 from from NEDC-3260 NEDC-32601P-A IP-A Page 15 Page of25 15 of 25 Verified Verified Information Information

(.NFNON-PROPRrETARY GNF NON-PROPRIETARY rNFORMATrON IN FORMATION Class I1 Class GNF Attachment GNF Attachrncnt [[ 11]] Figure 5. Updated Figure Figure 111.5-2 111.5..2 from EDC-326OlP NEDC..32601P-A

                                                                            -A Figure Figure 5.5. Updated Updated Figure Figure 111.5-2 IH.5-2 from from NEDC-3260 NEDC-32601P-A  1P-A                          16of Page 16 Page      of25 25 Verified VeritiedInformation Information

INFORMATION NON-PROPRIETARY INFORMATiON GNF NON-PROPRIETARY Class II Attachnlent GNF Attachnient Table 1. Description of Core C~'cle Cycle ii It Cycle II11 Cycle 12 Cycle 12 C~'cle 12 Cycle 12 Description Minimum Core Flow IVliniluulll Rated Core Flow Flow l\tlilliulunl Core Flow Minimum Rated Core Flow Core Flow Lhuiting Limiting Case Linlitillg Case Limiting Lim iting Case Limiting Limiting Limiting Case C.lse Number of Bundles in the 764 764 7.4 Core Limiting Cycle Exposure Liluiting Point (i.e. EOC EOC EOC EOC BOC/tv10C/EOC) BOC/MOC/EOC) Cycle Exposure at Liruiting LimitingPointPoint l3000 13000 13000 13350 13350 13350 (i\1W d/STU) (MWd/STU) 0/0 Rated COfe Flow'

  %RatedCore         Flow                  81.0                     1000 100.0                           829 82.9                     1000 100.0 Reload Fuel Type                                    GEI4 GE14                                                     GNF2 Latest Reload Batch i.b 36.6                                                     36.11 36.

Fraction ~o Fraction,

          .
                %

Latest Latest Reload Reload Average Batch vVeight Batch Weight% 0/0 3.90 3.94 Enrichment Enrichment Core Core Fuel Fuel Fraction: GEl4 GE14 1.000 l.OOO 0.639 GNF2 GNF2 0.000 0.361 Core Core Average Weight ~'o Average Weight % 3 99 3,99 3.97 Emichment Ennchmeni Table Table 1.1. Descliption DescLiplion of of Core Core lnfbrmation Verified Information 17 of 25 Page 17

GNF NON-PROPRIETARY INFORtvlATlON GNF NON-PROPRIETARY INFORMATION Class Class II GNF GNF Attachment Attachment

                                                 'fable Table 2.

2. SLl\*ICPR SLMCPR Calculation Calculation l\lethodologies Methodologies Cycle 11 C)'cle 11 Cycle Cycle 11 II Cycle Cycle 1212 C)'cle12 Cycle 12 Description Description Minimum IVlinilllulll Core Flow Core Flow I Rated Rated Core Core Flow Flow l\'!iniJnulll Minimum Core Core ,Flow Flow J Rated C Rated o.*e ,Flow Core Flow Limiting Case Liuliting Case Limiting Case Lioliting Case j Lim itillg Case Linilting Case Limiting C~lse Limiting Case Non-power Distribution Non-po\ver Distribution NEDC-32601P-A NEDC-3260IP-A I NEDC-3260 NEDC-32601P-A I P-A Uncertainty Uncertainty Power Distribution Power Distribution Methodology NEDC-32601P-A NEDC-3260 IP-A NEDC-3260 NEDC-32601P-A 1P-A 1\1ethodology Power Distribution Power Distribution Uncertainty NEDC-32694P-A NEDC-32694P-A NEDC-32694P-A NEDC-32694P-A Uncertainty Core 1V1onitoring Core Monitoring System System 3DMoiijcore 3DMonicore 3o 3 1\:1 onicore DMonicore R-Factor Calculation R-Factor Calculation Methodology NEDC-32505P-A NEDC-32505P-A NEDC-32S05P-A NEDC-3250 5P-A lVlethodology Table Table 2.2. SLMCPR SLfvlCPR Calculation Calculation Methodologi t\:1ethodologieses Verified Verified Information Information Page 1 18 of25 25 Page 8 of

GNF GNF NON-PROPRIETARY NON-PROPRIETARY INFORMATION INFORMATiON Class 1 Class I GNF Attachment GNF Attachment l'able Table 3. 3. l\'lonte Monte Carlo Calculated SL~lCPR Carlo Calculated SLN1CPR vs. Estilnate Estimate Cycle It C)'cle I1 Cycle Cycle II 11 Cycle 12 12 Cycle 12 12 Description Description ~Iinitnuln Minimum Core Flow Core Flow Rated Rated Core Flow Minirnuni Core f~low I\'lilliulUlll Flow Rated Co.'e Core Flow Limiting Case Litllitillg Case Linliting Limiting Case Limiting Case Limiting C~lSe Case [[11 Table Table 3.3. Monte t\1onte Carlo Carlo Calculated SLMCPR SL~'ICPR vs. Estimate vs. Estimate Verified Verified Information Information Page 19 Page 19 of 25 of 25

GNFNON-PROPRIETARY GNF NON-PROPRIETARYINFORMATION INFORMATION Class Class I1 GNF Attachment GNF Attachment Table 3.

                                      'fable   3. IVlonte Monte Carlo Carlo Calculated Calculated SLI\l(:PR SLNICPR vs. vs. Estimate Estimate Description Cycle ii Cycletl Minimum CoreCore Flow Flow Cycle 11 Cyclett             1          Cycle Cycle 12 12            Cycle Cycle 12 R~lted 12 COI<e Description            l\lininlunl                    Rated Core Rated  Core Flow Flow         lVlilliulunl Minimum COl'e Core "'low Flow  Rated  Core .Flow Flow Limiting   Case Liluiting Case              Limiting Case Limiting   Case              Lioliting Limiting Case Case       Limiting Limiting Case Case n

U Table Table 3,

3. Monte i\1onte Carlo Carlo Calculated Calculated SLMCPR SLlv1CPR vs.VS. Estimate Estimate Verified Veritied Information lnfonnation Page2020 of of25 25 Page

GNF GNF NON-PROPRIETARY NON-PROPRIETARY INFORMATION LNFORMATION Class Class I1. GNF GNF Attachment Attachment Table Table 4.

4. Non-Power Non-Power Distribution Distribution Uncertainties Uncertainties Nominal (NRC-Nominal (NRC- Cycle I I Cycletl Cyclell Cycle 1 1 Cyclel2 Cycle 12 C:ycle Cycle 12 Approved) Value Approved) Value Minimum Core 1\1inimulll Core Rated Rated Core Core :Flow Flow l\1ininlunl Minimum Core Rated Core Cure Flow Flow

                                     +/- (J (0/0)
                                      +/- o   (%)        Flow Lioliting Flow   Limiting Case Case         Lilniting Case Limiting Case      Flow Lioliting Linaitiiig Case  Limiting Liniiling Case Case GETAB GETAB Feedwater Flow Feedwater       Flow Measuremen 1.76 1.76                   N/A                        N/A                   N/A N/A                NJA N/A l\t1 easurementt Feedwater Feedwater Temperature Temperature                           0.76 0.76                   N/A                        N/A                   N/A N/A                NJA N/A Measurement l\.1easurement Reactor Pressure Reactor      Pressure Measurement 0.50                   N/A                        N/A                   N/A N/A                NJA N/A fvleasllrement Core Inlet Core    Inlet Temperature Temperature                           0.20                   N/A                        NJA N/A                   N/A N/A                NJA N/A Measurement 1\.1easllrement Total Core Total    Core Flow Flow Measuremen                       SLOI2.5 TLO 6.0 SLO/2.5                    N/A                        NJA N/A                   N/A N/A                NJA N/A fvleasllrementt Channel Flow Channel      Flow Area Area Variation 33.0 0                  N/A                        N/A                   N/A N/A                NJA N/A Variation Friction Factor Friction    Factor Multi                                 10.0                   NJA N/A                        N/A                   NfA N/A                 NJA N/A p1 icr l'vlultiplier Channel Friction Channel      Friction Factor                                55.00                  N/A                        N/A N/A                    N/A N/A                 N/A N/A Factor Multiplier tvlultiplier Table Table 4.4. Non-Power NOll-Povver Distribution Distribution Uncertainties Uncertainties                         Verified    Information Veritied Information                                              of25 Page 2211 of Page          25

GNF NON-PROPRIETARY INFORMATION GNF NON-PROPRIETARY INFORMATION Class Class II GNF GNF Attachment Attachment Table 4. Table 4. Non-Power Non-Power Distribution Distribution Uncertainties Uncertainties Nominal (NRC-Nonlinal (NRC- Cycle 11 Cyeletl Cyclell Cycle 11 Cyclet2 Cycle 12 Cycle Cycle 1212 Approved) VaJue Approved) Value Minimum Core l\1inimulll Core Rated Rated Core Core ,Flow Flow Minimum l\1iUiIllUDl Core Core Rated Rated Core Flow Core Flow

                                      +/- a (%)
                                   +/-a(%)                Flow Limiting Flow    Limiting CaseCase        Linliting Limiting Case Cilse    Flow Limiting Case         Linliting Limiting Case Case NEDC-3260 1 P-A NEDC-3260IP-A Feedwater Flovl Feedwater     Flow Nleasuremen t\1easurementt

[[[[ ]]U [[[[ ]]ii II 11 [[ II ]] ii [[ Ii J] ii Feedwater Feedwater Temperature Temperature ([U 11

                                             ]]               [[       1]
                                                                       ]]                  U

ii [[ U ]] Ii [[ U ]] ii Measurement Measurement Reactor Pressure Reactor Pressure Measurement Measurement [[[[ Ii

                                             ]]                [[

[[ ]] ii [[ U ]] Ii [[ II ]] Ii Ul[ ]] ii Core Inlet Core inlet Temperature Tetuperature 0,2 0.2 0.2 0.2 0.2 0.2 Measurement ivleasurement Total Core Total Core Flow 6.0 SLO/2.5 TLO SLOI3,09 TLO 6.0 SL0/3.09 SLOJ2.5 TLO 6.0 SLO/2.5 SLO/3.02 TLO 6.0 SLO/3.02 6.0 SLO/2.5 6.0 SLOJ2,5 TLO TLO Measuremen Nleasurementt Channel Flow Channel Flow Area variation Variation U [[ 11

                                             ]]               [[

U 11]] {[[[ ii]] [[ii ii Friction Factor Friction Factor IViultiplier Nlultiplier Ii Ii [1Ii [[ii IIii Channel Friction Channel Friction Factor 5.0 5.0 5.0 5.0 5500 5.0 5.0 Multiplier Factor Nlultiplier Table Table 4.

4. Non-Power Non-Power Distribution Distribution Uncertainties Uncertainties Verified Verified Information Information Page 22 of25 22 of 25 Page

GNF NON-PROPRIETARY INFORMATION GNF NON-PROPRIETARY LNFORMATION Class Class I1 GNF GNF Attachment Attachment Table Table 5. 5. Power Power Distribution Distribution Uncertainties Uncertainties Nonainat (NRC-Nonlinal (NRC- Cyeletl Cycle I I Cycle Cycle 1111 Cycle Cycle 12 12 Cycle Cycle 1212 Description Descl'iption Approved) Value Approved) Value Minimum l\;linim UlIl Core Core Rated Rated Core Core FlowFlow LVlininlum Minimum Core Core Rated Rated Core f'low Core Flow (%)

                                             +/-+/- (i (%)           Flow    Limiting Case Flow Linlitiug          Case        Limiting Limiting CaseCase     Flow    Limiting Case Flow Linliting                Linliting Limiting Case Case GETAB/NEDC-32601P-A GETAB/NEDC-32601P-A GEXL R-Factor GEXL      R-Factor                       [[[[      ]]Jj                   N/A                             NJA N/A                      N/A N/A                         N/A N/A Random EtTecti Random     Ettectieve rip Reading Reading 285 SLO/1.2 2.85    SLO!l.2 TLO    TLO              N/A                             N/A                      N/A N/A                         N/A N/A TIP Systematic Effective Systematic    Effective TIP  Reading                                  86 8.6                         N/A                             N/A                      NfA N/A                         NJA N/A TIP Reading NEDC-32694P-A, 3DlVION NEDC-32694P-A,            3DMONICO     (CORERE GEXL R-Factor RFactor                       U         1]                  [[                                                       [[

GEXL [( ]] 11

                                                                                  ]]                     [[

11 ]] 11 i] Uii Random Effecti Random Utectie ve 2.85 SLO/1.2 SLOJ1.2 TLO 2.85 SLO/1.48 TLO 2.85 SLOJ1.2 SLO/1.2 TLO ILO SLOlIA5 TLO 2.85 SLO/l.45 ILO 2.85 SLO/1,2 2.85 SLOJ1.2 ILO ILO TIP Reading TIP Reading TIP Integral TIP imegral U [[ ii

                                                      ]]                Ii               [[11                                     [[

[( ii]] Ii]] Four Bundle Four Bundle Power Power Distribution Distribution Surrounding TIP Surrounding TIP [I [[ iiJ] 11 1] Uii [( Ii]] Location Location Contribution to Contribution to Bundle Power Bundle Po\ver ii Uncertainty Uncertainty DueDue to [[ ]] ii [[ U ]] Ii Ii [[ U 1]] Uii [1Ii LPRM LPRtvt Update Update ..*_ , - - - . -- Table 5. Power Table 5. Pow'er Distribution Distribution Uncertainties Uncertainties Verified Infonl1ation Verified information Page 23 23 ot25 of 25 Page

GNF NON-PROPRIETARY INFORMATION Class II GNF Attachment Power Distribution Uncertainties Table 5. Po\\'er Uncel1ainties NOIllinal Nominal (NRC- Cycletl Cycle 11 Cycle II11 Cycle 12 12 Cycle 12 Description Approved) VaJue Value Minimum Core l\linimuill Rated Core Flow ~lilliJn unl Core Minimum Rated Core Flow Flow

                                +/- a (%)
                                +/-a(%.)        Flow Linliting Limiting Case          Limiting Case             Limiting Case Flow Linaiting          Linliting Case Limiting Contribution to Bundle Power Power Due to        [[       ]]

ii [[ ]]1] [[ [[ ]] 11 ii [[1] Failed TIP TiP

Contribution to Power Due to Bundle Power [[ [[ ]] 11 [[ ]] 1] Ii Ii Ii Failed LPRM Total Uncertai nty in Uncertainty Calculated Bundle [[ [[ ]] jJ [[ [1 ]] 1] [[ 1]

                                                                                           ]]        1]    ii

Power Povver Uncertainty of TIP Signal Nodal [[ [[ ]] 11 [[ [[ ]] Ii 11 11 ii Uncertainty Unceltainty Table 5. Power Distribution Uncertainties Uncertainties Verified Infonnation Veritied information Page 24 of 25

GNF GNF NON-PROPRIETARY NON-PROPRIETARY lNFORMATION INFORMATION Class Class I1 GNF GNF Attachment Attachment

                                           'Table Table 6. 6. Critical Po\ver Power Uncertainties Cycletl Cycle 11                  Cycle 11            C)'cle Cycle 12            Cycle 12 Nominal Value Nonlinal  value Description Description                            l\lillim MiniinunaUln COI'e Core          Rated Core .Flow Flow    iVlinitu un) Cor'e Miiiiniuni   Core   Rated Rated Core Flow
                                +/-O'(%)
                                +/-(%)
                                                                                           .'Iow                   Linliting f'low    Limiting Case Flow Linlitiug                 Limiting Case   Flow Limiting Limiting Case Case  Limiting Cnse Case

[[[[ 1]]] Table 6. Critical Table Ciitical Power Uncertainties Power Uncertainties Verified Information Information Page 25 Page of 25 25 of 25

9 1N]VH3YllV ATTACHMENT 6 MOld/i OMOd sepA .io sde Power/Flow Maps for Cycles 11 and 12 pue

Limerick VUnit Limerick nit 22 Cycle Cycle 11 11 LGS Power LGS Power Flow Flow Operation Operation Map Map OPRM Operable OPRM Operable - ALL Feedwater Feedwater Heaters Heaters In In Service Service 130 130 120 120 7 RESTRICTED REGION D RESTRICTED REGION IMMEDIATE EXIT APRM APRM SCRAM SCRAM IMMEDIATE EXIT 110 110 ApRMROD SLOeK 100 115% LOAD LINE 100 I 90 90 '0a .!a 80 80

             ~W,,; 0.0%0.0% for for Dual Dual Loop Loop
             ~w ~ i.6%
."                     7.6% for for SLO Q:                                SLO        -

'00 70 70 66.7% C...a iW) ++ 62.8% 7% Ql 0.66(W 0.660N

                        * ~W)
                         -        62.8%

3:0 60 a-0 60 INCREASED 11. a 0.66(Yv * ~W) + 55.2% CORE Fl.OW iiiE Ea Ql 50 50 .s:. 45% 45% I- OPRM Enabled OPRMEnabl Region edRegion 40 40 - 30 30

CAVITATN INRLOCi< 20 20 0 10 APPROX. NA ruRAL eiRe:. 0 0 5-__ 10 22* 45 ----r 5.25 0 - SE 1225 lOS 2025 2551 0 10 20 30 40 50 60 0 10 20 30 40 50 60 70 70 80 80 90 90 100 100 110 110 120 120 Core Core Flow Flow (% of Rated) (% of Rated) Core Plate dP (psld$1

Limerick Unit Limerick Unit 22 Cycle Cycle 12 12 (Draft) (Draft) Revised Limerick Revised LimerickPower/Flow Power/Flow Map Map (Revised (Revised TPO TPO - -101.65°~

                                                                                                                                          -401.65% CLTP)    CLTP)

Core Flow Core Flow (Mlbm/hr) (Mlbmihr) 00 1010 20 20 30 30 40 40 50 50 60 60 70 70 80 80 90 90 100 100 110 110 120 120 130 130

                                                                                                                                                                                +44004400 120 120   f  I A:

8: Natoral Ciroolation Natural Circulation Two Puop Minimrn Speed I C: Two Pump Minimum Speed 6.6% Power / I + 4000 Power I 44.4% Flow 44.4% Flow 4000 110 -f 110 I 0: 100.0% Power / 100.0% Power I 82.9% Flow 82.9% Flow 0: 8.4 Power 80.8% Flow Flow I 80. i00.C Power 100.0% Flow 100 I 100 I 5:

                                ' . 98.4% Power 00.0% Flow 100.0%

00. Flow Flow MELLLABo MELLLA unda Boundary D EE FF 3515 MWt 35I5MWt

                                                                                                                                                                                + 3600 3600

10. Floww 3458 MWt 348MVt

                                ,.                     10. Flow    P=(22. 19 I +O.89714W r O.OOI1905Wt")(l.132)                             E'
            ~         90                                                                                                                                                        + 3200
            ~         90 E         10 00.0%

Flow Flow

                                                                                                        "'"                                                                         3200
                                                                                                                                                                                          --

Iooooj

38. Flow

80 2800 ~ 2800

            .;::

rI'J

                                                                                                                                                                                          ~
            ~
               ~

c::: 70 2400 2400

--

a.. ClJ

                                                                                                                                                                                           ~
            ~                                                                                                                                         Increased                            Q a..                                                                                                                                    Core Flow                           ~

ClJ 60 I

-;

0~ Q 2000 2000 Q.,

            -;        50 B
                                                                                                                                                                                           =

a.. ClJ

                                                                                                                                                                                          .c E

ea.. A 1600 ~ 1600 ClJ

            .c        40
            ~

I I 30t I Cavitation Interlock 0 0 1200

                                                                                                                                                                                -I 1200 I 800 800 201                                            I J     :                                                                      H               G 100.0% Revised TLTP   = 3515      Mvlt 3515 MWt 10                                                  /                                               100.0% 000P
                                                                                                                                              =
                                                                                                                                              = = 3458      t--1Wt 3458 PlWt              I    I 400 400 Flow 110.0% Core Flow      = 100.0     Mlbm/hr 100.0 Mlbm/hr 0                                                                                                                                                           00 0           10         20          30          40            50 0           10         20          30          40            50        60 60            70 70             80 80         90 90        100 100                110 110            120 120 Core CoreFlow Flow(%)(%)

A final power flow map is under A final power/flow map is under development for Cycle 12. This is a draft. development for Cycle 12. This is a draft.}}

v t e Letter Sequence Request
TAC:ME5182, (Approved, Closed)
Initiation Request, Request Acceptance Administration Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance Questions 3 February 2011 4 February 2011 Answers 17 February 2011 17 March 2011 Results Approval Other: ML110750446
MONTHYEAR2011-02-03 [Table View]

ML103500180

Text

Subject:

SUBJECT:

SUMMARY

SUMMARY

SUMMARY

4.0 REGULATORY EVALUATION

Response

6.0 REFERENCES

3.0 REFERENCES

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