ML113260348

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

ML113260348
Person / Time
Site:	Quad Cities
Issue date:	11/22/2011
From:	Gullott D M Exelon Generation Co, Exelon Nuclear
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML113260347	List: ML113260348 RS-11-180, Quad Cities, Unit 2 - Request for Technical Specification Change for Safety Limit Minimum Critical Power Ratio
References
RS-11-180, CAW-11-3308
Download: ML113260348 (43)

Text

www.exeloncorp.com Exelon Generation 4300 Winfield Road Warrenville, IL 60555 Nuclear Attachment 4 contains Proprietary Information.

Withhold from public disclosure under 10 CFR 2.390.

When separated from Attachment 4, this document is decontrolled.

RS-11-180 November 22, 2011 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Unit 2 Renewed Facility Operating License No. DPR-30 NRC Docket No. 50-265

Subject:

Request for Technical Specification Change for Safety Limit Minimum Critical Power Ratio In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Unit 2. The proposed change revises the QCNPS, Unit 2 safety limit minimum critical power ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs." This change is required to support the upcoming QCNPS Unit 2, Cycle 22 operation. Cycle 22 is the fourth cycle with reload quantities of SVEA-96 Optimal fuel which is installed in QCNPS Unit 2, and is a 100% SVEA-96 Optimal core.

The proposed amendment reflects an increase of the QCNPS Unit 2 two recirculation loop SLMCPR from 1.11 to ? 1.12; and an increase in the QCNPS Unit 2 single recirculation loop SLMCPR from ? 1.13 to 2:1.14. The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using the criteria in 10 CFR 50.92(c), and it has been determined that the change does not involve a significant hazards consideration. The bases for these determinations are included in the attached submittal. contains the evaluation of the proposed change and Attachment 2 provides the marked up TS page. contains Proprietary Information.

Withhold from public disclosure under 10 CFR 2.390.

When separated from Attachment 4, this document is decontrolled.

November 22, 2011 U. S. Nuclear Regulatory Commission Page 2 Attachment 4 (i.e., the Westinghouse Electric Company "Quad Cities Unit 2 Cycle 22 SLMCPR" Evaluation Report) specifies the new SLMCPRs for QCNPS Unit 2, Cycle 22. As Attachment 4 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit (i.e., Attachment 3) signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure.

A non-proprietary version of this information is provided in Attachment 5.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-11-3308 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.The attached license amendment request is subdivided as follows: provides an evaluation of the proposed change. provides the current TS page with the proposed change indicated with markups.Attachment 3 provides the Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW-1 1-3308, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice. provides the Westinghouse Electric Company "Quad Cities Unit 2 Cycle 22 SLMCPR" Evaluation Report - Proprietary Version. provides the Westinghouse Electric Company "Quad Cities Unit 2 Cycle 22 SLMCPR" Evaluation Report - Non-Proprietary Version.

EGC requests approval of the proposed amendment by March 22, 2012, to support the upcoming refueling outage. Once approved, the amendment shall be implemented after Cycle 21 is completed and prior to the operation of Cycle 22.

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

EGC is notifying the State of Illinois of this application for a change to the TS by sending a copy of this letter and its attachments to the designated State Official in accordance with 10 CFR 50.

91,"Notice for public comment; State consultation," paragraph (b).

The proposed change does not include any new commitments.

Should you have any questions concerning this letter, please contact Joseph A.Bauer at (630) 657-2804.

November 22, 2011 U. S. Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22nd day of November 2011.

Respectfully, David M. Gullott Manager - Licensing Attachments:1.Evaluation of Proposed Change 2.Mark-up of Proposed Technical Specifications Page Changes 3.Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW-11-3305, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice 4Westinghouse Electric Company, "Quad Cities Unit 2 Cycle 22 SLMCPR," Evaluation Report - Proprietary Version 5.Westinghouse Electric Company "Quad Cities Unit 2 Cycle 22 SLMCPR" Evaluation Report - Non-Proprietary Version cc: Illinois Emergency Management Agency - Division of Nuclear Safety ATTACHMENT1 Evaluation of Proposed Change

Subject:

Request for Technical Specification Change for Safety Limit Minimum Critical Power Ratio 1.0

SUMMARY

DESCRIPTION

2.0 DETAILED

DESCRIPTION

4.0 REGULATORY EVALUATION

4.1Applicable Regulatory Requirements/Criteria4.2Precedents4.3No Significant Hazards Consideration4.4Conclusions

5.0 ENVIRONMENTAL

CONSIDERATON

6.0 REFERENCES

Page 1 of 8 ATTACHMENT 1 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION The proposed change would revise the Quad Cities Nuclear Power Station (QCNPS), Unit 2 Safety Limit Minimum Critical Power Ratio (SLMCPR) in Technical Specification (TS) Section 2.1.1, "Reactor Core SLs." Specifically, the proposed change modifies the QCNPS, Unit 2 SLMCPRs for both two loop and single loop recirculation operation in TS Section 2.1.1.2. The change to TS Section 2.1.1.2 is necessary as a result of QCNPS, Unit 2, Cycle 22 cycle-specific analyses. The proposed change to the SLMCPRs was determined utilizing the most current version of the applicable computer codes.

The analyses performed to support the proposed cycle-specific SLMCPR changes utilized the NRC-approved Westinghouse Electric Company, LLC methodology.

The proposed change is described in detail in Section 2.0 below.

The requested approval date of March 22, 2012, will allow time for the QCNPS, Unit 2 Core Operating Limits Report (COLR) to be implemented prior to QCNPS, Unit 2, Cycle 22 operation.

2.0 DETAILED

DESCRIPTION The proposed change involves revising the SLMCPRs contained in TS Section 2.1.1.2 for both two recirculation loop and single recirculation loop operation for QCNPS, Unit 2, Cycle 22.

Analysis determined that the QCNPS, Unit 2 SLMCPR value for two recirculation loop operation requires revision from ? 1.11 to ? 1.12. Additionally, the QCNPS, Unit 2 SLMCPR value for single recirculation loop operation requires revision from z 1.13 to 2:1.14. A detailed evaluation addressing the need for these revisions is provided in Attachment 4, "Quad Cities Unit 2 Cycle 22 SLMCPR." The proposed new SLMCPRs will support operation at QCNPS, Unit 2, for Cycle 22.

QCNPS TS Section 2.1.1.2 specifies the value for the SLMCPR. The current TS states: "For two recirculation loop operation, MCPR shall be ? 1.11, or for single recirculation loop operation, MCPR shall be ? 1.13.11 The proposed change will revise the QCNPS TS Section 2.1.1.2 to read as follows.

For Unit 1, two recirculation loop operation, MCPR shall be ? 1.11, or for single recirculation loop operation, MCPR shall be z 1.13.

For Unit 2, two recirculation loop operation, MCPR shall be ? 1.12, or for single recirculation loop operation, MCPR shall be ? 1.14. provides the marked-up TS page for QCNPS indicating the proposed changes.

Page 2 of 8 ATTACHMENT 1 Evaluation of Proposed Change

3.0 TECHNICAL EVALUATION

QCNPS, Unit 2, Cycle 22 is the fourth Unit 2 cycle with reload quantities of SVEA-96 Optima2 fuel, and is a 100% SVEA-96 Optima2 core. Dual recirculation loop operation (DLO) and single recirculation loop operation (SLO) SLMCPRs of 1.12 and 1.14, respectively, have been calculated for the Westinghouse SVEA-96 Optima2 assemblies in Cycle 22. Application of the NRC-approved Westinghouse methodology (i.e., Reference 1) requires a revision to the Unit 2 TS, Section 2.1.1.2 to support DLO and SLO SLMCPRs of 1.12 and 1.14, respectively, for the SVEA-96 Optima2 fuel in Cycle 22.

As noted above, EGC will load SVEA-96 Optimal reload fuel for the fourth consecutive cycle in QCNPS Unit 2. SVEA-96 Optima2 reload fuel was also loaded in QCNPS Unit 2 Cycle 19, Cycle 20, and Cycle 21. Therefore, the NRC-approved Westinghouse methodology described in Reference 1, and further clarified in the response to Request for Additional Information (RAI)

D13 of Reference 2, was used to determine the SLMCPRs for Cycle 22. Further clarification of the Westinghouse SLMCPR methodology was also provided to the NRC in support of the transition to SVEA-96 Optimal fuel in the Quad Cities and Dresden Units as follows:

The response to NRC Request 19 in Attachment 5, Reference 5 which supported the Licensing Amendment Request for transition to SVEA-96 Optimal fuel in the Dresden and Quad Cities plants provided in Attachment 5, Reference 4; and The technical information supporting the QCNPS Unit 2 Technical Specification SLMCPR changes transmitted by Attachment 5, Reference 6 as supplemented by the clarifying information in Attachment 5, Reference 7.

A comprehensive description of the Westinghouse SLMCPR methodology was provided to the NRC in the technical information supporting the QCNPS Unit 1 Technical Specification SLMCPR changes requested in Attachment 5, Reference 8 as supplemented with clarification information in Attachment 5, References 9 and 10.

The same SLMCPR methodology described in these references was followed to establish appropriate SVEA-96 Optima2 SLMCPRs for QCNPS Unit 2 Cycle 22.

The SVEA-96 Optima2 SLMCPR for QCNPS Unit 2 Cycle 22 is based on a Reference Core design (i.e., SVEA-96 Optimal bundle designs, core loading pattern and state point depletion strategy) that represents realistic current plans for the Cycle 22 loading and operation. The Reference Core loading pattern for QCNPS Unit 2 Cycle 22 is shown in Attachment 5, Figure 1; and Attachment 5, Table 3 shows a summary of the core loading.

Additional detailed Information to support the QCNPS Unit 2 cycle-specific SLMCPRs is included in Attachment 4. This attachment summarizes the MCPR SL analysis, methodology, inputs, results, and the reasons for the increase in the SLMCPR.

Page 3 of 8 ATTACHMENT 1 Evaluation of Proposed Change

4.0 REGULATORY EVALUATION

4.1Applicable Regulatory Requirements

/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.

10 CFR 50.36, "Technical specifications," paragraph (c)(1), requires that power reactor facility TS include safety limits for process variables that protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity. The fuel cladding integrity SLMCPR is established to assure that at least 99.9% of the fuel rods in the core do not experience boiling transition during normal operation and anticipated operational occurrences (AOOs). Thus, the SLMCPR is required to be contained in TS. The proposed amendment to the QCNPS TS revises the SLMCPR for QCNPS Unit 2 and does not remove the SLMCPR from the TS.

10 CFR 50, Appendix A, General Design Criterion (GDC) 10 requires that the reactor core and associated coolant, control, and protection systems be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of AOOs. To ensure compliance with GDC 10, EGC has performed the plant-specific SLMCPR analyses using NRC-approved methodologies as prescribed in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 4.4. The SLMCPR ensures that sufficient conservatism exists in the operating limit MGPR such that, in the event of an AOO, there is a reasonable expectation that at least 99.9% of the fuel rods in the core will avoid boiling transition for the power distribution within the core including all uncertainties.

4.2Precedents 1.Letter from U. S. NRC to C. M. Crane (Exelon Generation Company, LLC), "Quad Cities Nuclear Power Station, Unit 2 - Issuance of Amendment Re: Minimum Critical Power Ratio Safety Limit (TAC No. MC9243)," dated March 31, 2006 2.Letter from U. S. NRC to C. M. Crane (Exelon Generation Company, LLC), "Quad Cities Nuclear Power Station, Unit 1 - Issuance of Amendment Re: Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No. MD4008), dated May 2, 2007 3.Letter from U. S. NRC to C. G. Pardee (Exelon Generation Company, LLC), "Quad Cities Nuclear Power Station, Unit 2 - Issuance of Amendment Re: Safety Limit Minimum Critical Power Ratio (TAC Nos. MD7374 and MD7375)," dated February 28, 2008 4.3No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) is requesting a change to the Technical Specifications (TS) of Facility Operating License Nos. DPR-30 for Quad Cities Nuclear Power Station (QCNPS), Unit 2.

" Page 4 of 8 ATTACHMENT 1 Evaluation of Proposed Change According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(1)Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2)Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)Involve a significant reduction in a margin of safety.

In support of this determination, an evaluation of each of the three criteria set forth in 10 CFR 50.92 is provided below:

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

Response: No.

The Safety Limit Minimum Critical Power Ratio (SLMCPR) is defined in the TS Bases Section B 2.1.1 as that limit "that, in the event of an AOO [Anticipated Operational Occurrence] from the limiting condition of operation, at least 99.9% of the fuel rods in the core would be expected to avoid boiling transition." The SLMCPR satisfies the requirements of General Design Criterion 10 of Appendix A to 10 CFR 50 regarding acceptable fuel design limits. The SLMCPR is reevaluated for each reload using NRC-approved methodologies. The analyses for QCNPS, Unit 2, Cycle 22, have concluded that a two-loop SLMCPR of; 1.12; and a single-loop SLMCPR of 2:1.14, as determined by the application of the NRC-approved Westinghouse Electric Company SLMCPR methodology, will ensure that this acceptance criterion is met. The MCPR operating limits are presented and controlled in accordance with the QCNPS, Unit 2 Core Operating Limits Report (COLR).

The requested Technical Specification 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 changes to the SLMCPRs do not involve a significant increase in the probability or consequences of any accident previously evaluated.

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

Response: No.

Creation of the possibility of a new or different kind of accident requires creating one or more new accident precursors. New accident precursors may be created by modifications Page 5 of 8 ATTACHMENT 1 Evaluation of Proposed Change of plant configuration, including changes in allowable modes of operation. The proposed changes do not involve any plant configuration modifications or changes to allowable modes of operation. The proposed SLMCPR values do not result in the creation of any new precursors to an accident. The proposed change to revise the QCNPS Unit 2 SLMCPR requirements assures that safety criteria are maintained for QCNPS Unit 2, Cycle 22.

In addition, the QCNPS, Unit 2, Cycle 22 is the fourth Unit 2 cycle with reload quantities of SVEA-96 Optimal fuel, and is a 100% SVEA-96 Optimal core. SVEA-96 Optima2 reload fuel was previously successfully loaded in QCNPS Unit 2 Cycle 19, Cycle 20, and Cycle 21.

The NRC-approved Westinghouse SLMCPR methodology was used to determine the SLMCPRs for these previous cycles. This same methodology was used to determine the SLMCPRs for Cycle 22.

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

3.Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The SLMCPR provides a margin of safety by ensuring that at least 99.9% of the fuel rods do not experience transition boiling during normal operation and AOOs if the SLMCPR limit is not violated. The proposed change will ensure the current level of fuel protection is maintained by continuing to ensure that at least 99.9% of the fuel rods do not experience transition boiling during normal operation and AOOs if the proposed SLMCPR limits are not violated.The proposed SLMCPR values were developed using an NRC-approved methodology. Additionally, operational limits will be established based on the proposedSLMCPR values to ensure that the SLMCPR is not violated. This will ensure that the fuel design safety criterion (i.e., that no more than 0.1 % of the rods are expected to be in boiling transition if the MCPR limit is not violated) is met.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above evaluation, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

4.4 Conclusions

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

Page 6 of 8 ATTACHMENT 1 Evaluation of Proposed Change

5.0 ENVIRONMENTAL CONSIDERATION

EGC has evaluated this proposed operating license amendment consistent with the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21, "Criteria for and identification of licensing and regulatory actions requiring environmental assessments." EGC has determined that this proposed change meets the criteria for a categorical exclusion set forth in paragraph (c)(9) of 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," and as such, has determined that no irreversible consequences exist in accordance with paragraph (b) of 10 CFR 50.92, "Issuance of amendment." This determination is based on the fact that this change is being proposed as an amendment to the license issued pursuant to 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities," which changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation," or which changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria: (I)The amendment involves no significant hazards consideration.

As demonstrated in Section 5.1, "No Significant Hazards Consideration," the proposed change does not involve any significant hazards consideration.(ii)There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed change does not result in an increase in power level, does not increase the production nor alter the flow path or method of disposal of radioactive waste or byproducts. It is expected that all plant equipment would operate as designed in the event of an accident to minimize the potential for any leakage of radioactive effluents; thus, there will be no change in the amounts of radiological effluents released offsite.

Based on the above evaluation, the proposed change will not result in a significant change in the types or significant increase in the amounts of any effluent released offsite.(iii)There is no significant increase in individual or cumulative occupational radiation exposure.There is no change in individual or cumulative occupational radiation exposure due to the proposed change. The proposed action will not change the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposed action result in any change in the normal radiation levels within the plant.

Therefore, in accordance with 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page 7 of 8 ATTACHMENT 1 Evaluation of Proposed Change

6.0 REFERENCES

1.

Fuel, CENPD-300-P-A," July 1996 2.CENPD-389-P-A, 10x10 SVEA Fuel Critical Power Experiments and CPR Correlations:

SVEA-96+, August 1999 Page 8 of 8 ATTACHMENT 2 Quad Cities Nuclear Power Station Unit 2 Markup of Proposed Technical Specifications Page MARKED UP TS PAGE 2.0-1 SLs 2.0 2.0 SAFETY LIMITS (SLs)2.1SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 prig or core flow < 10% rated core flow:

THERMAL POWER shall be _< 25% RTP.

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

For treciratio looperatiMCshale>_ 1 1, orr sie re 'rcula on tooper ion,PR all be _ 1.13 2.1.1.3 Reactor vessel water level shall be greater than theI t of active irradiated fuel.

2.1.2 Reactor

Coolant System Pressure SL Reactor steam dome pressure shall be <_ 1345 psig.2.2SL Violations With any SL violation, the following actions shall be completed wit (in 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s: 2.2.1 Restore compliance with all SLs; and

2.2.2 Insert

all insertable control rods.For Unit 1, two recirculation loop operation, MCPR shall be >_ 1.11, or for single recirculation loop operation, MCPR shall be ? 1.13.For Unit 2, two recirculation loop operation, MCPR shall be ? 1.12, or for single recirculation loop operation, MCPR shall be > 1.14.

p Quad Cities 1 and 22.0-1Amendment No.

ATTACHMENT 3 Quad Cities Nuclear Power Station Unit 2 Westinghouse Electric Company, LLC Application for Withholding Proprietary Information from Public Disclosure, CAW-1 1-3308 Affidavit Proprietary Information Notice and Copyright Notice Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory CommissionDirect tel: (412) 374-4643 Document Control DeskDirect fax:

(724) 720-0754 11555 Rockville Pikee-mail: greshaja@westinghouse.com Rockville, MD 20852Proj letter: NF-BEX-11-181 CAW-1 1-3308 November 14, 2011 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

NF-BEX-11-181 P-Attachment,"Quad Cities Unit 2 Cycle 22 SLMCPR" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-11-3308 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-1 1-3308, and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

J.A. Gresham, Manager Regulatory Compliance Enclosures CAW-11-3308 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fa ct set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief-1.A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 14th day of November 2011 COMMONWEALTH O PENNSYLVANIA Notarial sealCynthia Olesky, Notary PubUC Manor Boro, wesixnoreland County My Commission Expires July 16, 2014 Member. permsvlvarda Assxiadm of Notaries ss 2CAW-11-3308 (1)I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2)I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission i n determining whether the information sought to be withheld from public disclosure should be withheld.(i)The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii)The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public.

Westinghouse has a rational basis for determining the types of information customarily held in confidence by it- and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a)The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of (3)(4) 3CAW-11-3308 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b)It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c)Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d)It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e)It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f)It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following: (a)The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.(b)(c) 4CAW-11-3308 (d)Each component of proprietary information pertinent to a particular competitive, advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a, competitive advantage.(e)Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f)The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iii)The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(iv)The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(v)The proprietary information sought to be withheld in this submittal is that which is appropriately marked in, NF-BEX-l1-181 P-Attachment, "Quad Cities Unit 2 Cycle 22 SLMCPR" (Proprietary) for review and approval, being transmitted by Exelon letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of Quad Cities Unit 2 Cycle 22 SLMCPR, and may be used only for that purpose.

This information is part of that which will enable Westinghouse to: (a)Support Exelon's use of Westinghouse Fuel at Quad Cities.

5CAW-11-3308 (b)Assist the customer to obtain license change.

Further this information has substantial commercial value as follows: (a)Westinghouse can use this information to further enhance their licensing position with their competitors.(b)The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar analyses and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non

-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information.so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections,(4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

ATTACHMENT 5 Quad Cities Nuclear Power Station Unit 2 Westinghouse Electric Company, LLC Evaluation Report"Quad Cities Unit 2 Cycle 22 SLMCPR" Non-Proprietary Version Westinghouse Non-Proprietary Class 3 Quad Cities Unit 2 Cycle 22 SLMCPR Westinghouse Electric Company Nuclear Fuel 1000 Westinghouse Drive Cranberry Township, PA 16066 C© 2011 Westinghouse Electric Company LLC, All Rights Reserved NF-BEX-11-181 NP-Attachment

1.0 Introduction

This document contains a description of the Safety Limit Minimum Critical Power Ratio (SLMCPR) evaluation for Quad Cities Nuclear Power Station Unit 2 (QCNPS2) Cycle 22.

Cycle 22 is the fourth cycle with reload quantities of SVEA-96 Optimal fuel which is installed in QCNPS2, and is a 100% SVEA-96 Optimal core. Dual recirculation loop operation (DLO) and single recirculation loop operation (SLO) SLMCPRs of 1.12 and 1.14, respectively, have been calculated for the Westinghouse SVEA-96 Optima2 assemblies in QCNPS2 Cycle 22.

Application of the Westinghouse methodology in Reference 1 requires modification of the QCNPS2 Technical Specifications, Reference 3, to support DLO and SLO SLMCPRs of 1.12 and 1.14, respectively, for the SVEA-96 Optima2 fuel in Cycle 22. The SLMCPR values for QCNPS2 Cycle 21 and Cycle 22 are shown in Table 1.

For QCNPS2 Cycle 22, Exelon Generation Company, LLC, (EGC) will load WestinghouseSVEA-96 Optima2 reload fuel for the fourth consecutive cycle. SVEA-96 Optima2 reload fuel was also loaded in QCNPS2 Cycle 19, Cycle 20, and Cycle 21. Therefore, the Westinghouse NRC-approved methodology described in Reference 1, and further clarified in the response to Request for Additional Information (RAI) D13 of Reference 2, was used to determine the SLMCPRs for Cycle 22. Further clarification of the Westinghouse SLMCPR methodology was also provided to the NRC in support of the transition to SVEA-96 Optimal fuel in the Quad Cities and Dresden Units as follows:

The response to NRC Request 19 in Reference 5 which supported the Licensing Amendment Request for transition to SVEA-96 Optimal fuel in the Dresden and Quad Cities plants provided in Reference 4, The technical information supporting the QCNPS2 Technical Specification SLMCPR changes transmitted by Reference 6 as supplemented by the clarifying information in Reference 7.

Comprehensive description of the Westinghouse SLMCPR methodology was provided to theNRC in the technical information supporting the Quad Cities Nuclear Power Station Unit 1 (QCNPSI) Technical Specification SLMCPR changes requested in Reference 8 and supplemented with clarification information in References 9 and 10.

The same SLMCPR methodology described in these references was followed to establish appropriate SVEA-96 Optimal SLMCPRs for QCNPS2 Cycle 22.

The EGC proposed license amendment to use the Westinghouse methodology for core reload evaluations at the Dresden and Quad Cities units was submitted to the NRC in Reference 4.

Reference 4 was approved by the NRC and supported QCNPS2 Cycle 19, Dresden Nuclear Power Station Unit 3 (DNPS3) Cycle 20, QCNPS 1 Cycle 20, and Dresden Nuclear Power Station Unit 2 (DNPS2) Cycle 21, all of which are first reloads of SVEA-96 Optima2 fuel for each unit. Reference 4 also supports the subsequent reloads for Dresden and Quad Cities units.

NF-BEX-11-181 NP-AttachmentPage 2 of21 Condition 7 in the NRC safety evaluation for Reference 1 requires that the conservative factor be applied to the GE14 Operating Limit Minimum Critical Power Ratio (OLMCPR) and that this factor be identified in licensee applications. Since no legacy GE14 fuel assemblies will be loaded into the QCNPS 2 Cycle 22 core, this factor is not relevant for this cycle and will not be included in the Cycle 22 Core Operating Limits Report.

I a,c 2.0SVEA-96 Optima2 SLMCPR for Cycle 22 The SVEA-96 Optimal SLMCPR for QCNPS2 Cycle 22 is based on a Reference Core design (SVEA-96 Optimal bundle designs, core loading pattern and state point depletion strategy) that represents realistic current plans for the Cycle 22 loading and operation. The Reference Core loading pattern for QCNPS2 Cycle 22 is shown in Figure 1 and Table 3 shows summary of the core loading. For comparison the core loading pattern for Cycle 21 is shown in Figure 2 and summarized in Table 4. The Reference Core design in Cycle 22 was generated via collaboration between EGC and Westinghouse based on EGCs cycle assumptions and design goals as described in the EGC general procedures that can be found in the response RAT-01 a to the NRC Request in Reference 9, which supported the licensing amendment request for QCNPSI Technical Specification SLMCPR changes. The Reference Core was designed to meet the cycle energy requirements, to satisfy all licensing requirements, to provide adequate thermal margins and operational flexibility, and to meet other design and manufacturing criteria established by EGC and Westinghouse. In general, the calculated SLMCPR is impacted by the flatness of the assembly CPR distribution across the core, and the flatness of the relative pin CPR distribution based on the pin-by-pin power/R-factor distribution in each bundle.

Greater flatness is indicated by more bundles/rods with CPRs closer to the minimum SLMCPR as shown in Figures 5 through 7 and 9 through 10. Greater flatness in either parameter yields NF-BEX-11-181 NP-AttachmentPage 3 of 21 more rods susceptible to boiling transition and thus a higher SLMCPR. [

I a,c SLO SVEA-96 Optimal SLMCPR calculations were also performed. These SLMCPR calculations were performed at [

I a,c The SLO calculations used the same procedure as the dual loop cases, except that the SLO cases applied a larger uncertainty for the core flow.The SLMCPR results for Cycle 22 are plotted in Figure 4. As shown in Figure 4, the DLO SLMCPR [I a,c NF-BEX-11-181 NP-AttachmentPage 4 of 21 Experience has shown that the assembly CPR distributions tend to become [

Ia,c Consequently, the peak SLMCPR tends to occur when the assembly CPR and rod CPR distributions combine to place the maximum number of fuel rod CPRs close to the minimum CPR.

This behavior is shown for the QCNPS2 Cycle 22 SLMCPR by the relative assembly CPR histograms shown in Figures 5 through 7. The histograms show the distribution of the assembly CPRs in the core at a specific point in the cycle. A high number of assemblies close to the limit indicates flatter CPR distribution.

Inspection of the DLO SLMCPR results in Figures 5 through 7 lead to the following observations, which explain the SLMCPR behavior in Figure 4:

I a,c Therefore, the DLO SLMCPR results at rated conditions in Figure 4 can be explained in terms of [Ia,c The adequacy of a DLO SLMCPR of 1.12 for the range of core flows at rated power permitted by Reference 3 was demonstrated by [

I a,c NF-BEX-11-181 NP-AttachmentPage 5 of 21 Therefore, the results in Figure 4 confirm the adequacy of a DLO SLMCPR of 1.12 for a QCNPS2 Cycle 22 flow window at rated power conditions of 95.3% to 108% flow. Figure 8 shows the fuel assembly minimum critical power ratio for the most limiting point in the cycle.

The values are shown [] a'c The SLO results calculated at [

SLMCPR of 1.14 for Single Loop Operation.

The relative fuel rod CPR distributions in the SLMCPR calculations are [

I a,c The adequacy of the existing backup stability regions to bound QCNPS2 Cycle 22 operation will be evaluated on a cycle specific basis using the calculated SLMCPR and associated OLMCPR in accordance with Reference 11.

For QCNPS2 Cycle 22 there is a non-conservative increase in the SLMCPR of 0.01 in comparison with the SLMCPR values documented in QCNPS2 Technical Specifications, Reference 3, for both DLO and SLO. [

I a,c There are no 10 CFR Part 21 reportable issues related to the fuel design applied to the QCNPS2 Cycle 22 fuel assemblies.

NF-BEX-11-181 NP-AttachmentPage 6 of 21

3.0 References

1.CENPD-300-P-A, Reference Safety Report for Boiling Water Reactor Reload Fuel, July 1996 2.CENPD-389-P-A, 1Ox]0 SVEA Fuel Critical Power Experiments and CPR Correlations: SVEA-96+, September 1999 3.Quad Cities Technical Specifications, Section 2.1.1.2 4.Letter from Patrick R Simpson (Exelon Generation Company, LLC) to U.S. NRC, RS-05-078, Request for License Amendment Regarding Transition to Westinghouse Fuel, June 15, 2005 5.Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, RS-06-009, Additional Information Supporting Request for License Amendment Regarding Transition to Westinghouse Fuel, January 26, 2006 6.Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, RS-05-176, Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit, QCNPS, Unit 2, December 15, 2005 7.Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, RS-06-024, Additional Information Supporting Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit, QCNPS, Unit 2, February 13, 2006 8.Letter from Jeffrey L. Hansen (Exelon Generation Company, LLC) to U.S. NRC, RS-11-022, Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit, QCNPS, Unit 1, June 7, 2011 9.Letter from D. M. Gullot (Exelon Generation Company, LLC) to U.S. NRC, RS-1 1-155, Additional Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit, QCNPS, Unit 1, September 21, 2011 10.Letter from D. M. Gullot (Exelon Generation Company, LLC) to U.S. NRC, RS-11-176, Supplement to Responses to NRC Request for Additional Information on Quad Cities Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No. ME6383), November 2, 2011 11.CENPD-295-P-A, Thermal-Hydraulic Stability Methodology for Boiling Water Reactors, July 1996 NF-BEX-11-181 NP-AttachmentPage 7 of 21 Table 1 Comparison of Cycle 21 and 22 Cores Descri p tion Cycle 21 Cycle 22 Number of Bundles in Core 724 724 Limiting Cycle Exposure Point Near EOC Near EOC Cycle Exposure at Limiting Point, EFPH 14178 EFPH 15690 EFPH Reload Fuel Type SVEA-96 Optima2 SVEA-96 Optima2 Reload Batch Average Weight % Enrichment 4.03 w/o 4.09 w/o Reload Batch Fraction (%)

34.8%34.3%Batch Fraction of SVEA-96 Optima2 Fuel 100.0%100.0%Core Average Weight % Enrichment 3.99 w/o 4.04 w/o Calculated Safety Limit MCPR (DLO) 1.11*SVEA-96 Optima2 1.12 SVEA-96 Optima2 Calculated Safety Limit MCPR (SLO) 1.13*SVEA-96 Optima2 1.14 SVEA-96 Optima2

• From QCNPS2 Technical Specifications, Reference 3 NF-BEX-11-181 NP-AttachmentPage 8 of21 Table 2 - Uncertainties used in Quad Cities 2 Cycle 22 SVEA-96 Optima2 SLMCPR Determination a,c NF-BEX-11-181 NP-AttachmentPage 9 of 21 Figure I - Quad Cities 2 Cycle 22 - Reference Loading Pattern UC20 UC20 UD20 UD20 I UE21 UD20 UC20 UG21 UD20 UE21 UF21 UE21 UJ22 UJ22 UG21 UJ22 UE21 UI22 UF21 UH22 UH22 UF21 UI22 UE21 UF21 U122 1 UE21 UH22 1 UF21 1 UI22 UI22 UI22 UE21 UE21 UJ22 UJ22 UD20 UE21 UF21 UC20 UC20 UC20 UC20 UC20 1JC20 UC20 UC20 UC20 UC20 UC20 UD20 UD20 UG21 UG21 UE21 UG21 UJ22 UJ22 U122 UJ22 UE21 UI22 UH22 UF21 U122 UI22 UIZZ UF21 U122 Ulll UF21 UE21 UI22 UE21 UE21 UE21 UE21 UH22 UF21 UH22 UI22 UH22 UI22 UE21 UH22 UE21 UI22 UE21 UH22 UE21 UE21 UE21 UH22 UE21 UE21 UE21 UI22 UH22 UE21 UE21 UI22 UE21 UH22 UE21 UH22 UH22 UH22 UE21 UH22 UE21 UE21 UE21 UH22 UE21 UE21 UE21 UE21 UH22 UE21 UH22 UH22 UH22 UE21 UH22 UE21 U122 UE21 UH22 UE21 UE21 UE21 U712 UK22 UEZ 1 UE21 UE21 UE21 UH22 UE21 UH22 UE21 UI21 UE21 UH22 UH22 UI22 UH22 UI22 UE21 UE21 15E21 UE21 UH22 UF21 UI22 UF21 UE21 0122 UE21 UI22 UI21 UI22 UF21 UI22 UJ22 UE21 UIZZ UH22 UF21 UE21 UG21 UJ22 UJ22 UI22 UC20 UD24 UD20 UG21 UG21 UC20 UC20 UC20 UC20 UC20 UC20 UC2o UC20 UC20 UC20 Legends Center ASYTYF U122 UE21 UI22 UF21 UJ22 UI22 UI22 UH22 UJ22 UI22 UI22 60 58 56 54 52 50 UC20 UC20 UC20 15D20 UC20 UC20 UC20 UD20 UC20 UC20 UC20 UC20 UC20 UC20 1 UC20 UC20 UC20 UG21 U122 UG21 UJ22 UD20 UJ22 UD20 UG21 UC20 UE21 UC20 UD20 UC20 UD20 UC20 UC20 14 12 10 08 06 04 02 01030507091113151719 21 23 25 27 29 UC20 UC20 I UC20 UC20 UC20 UC20 UD20 UD20 UG21 UJ22 UH22 UE21 UI22 UE21 UH22 UE21 U122 UE21 UH22 UH22 UE21 UI22 UE21 UH22 UE21 UI22 UE21 UH22UJ22 UG21 UD20 UC20 UD20 UI22 UF21 UE21 U122 UJ22 UG21 UD20 UC20 UC20 UI22 UH22 UH22 UI22 UH22 UI22 UJ22 UE21 UD20 UC20 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 UD20 UC20 Fresh bundles are shown in bold italic.

NF-FEX-11-181 NP-Attachment Page 10 of 21 Figure 1 - Quad Cities 2 Cycle 22 - Reference Loading Pattern 31 33 35 37 39 41 43 45 47 49 51 53 5557 59 Legends Center 60 UC20 UC20 UC20 UC20 UC20 ASYTYP 58 UC20 UC20 UC20 UC20 UC20 UD20 56 UG21 UG21 UD20 UD20 UC20 UC20 UC20 UC20 UC20 54 UI22 UJ22 UJ22 UG21 UE21 UD20 UD20 UC20 UC20 UC20 52 UF21 UH22 UI22 UE21 UJ22 UG21 UE21 UD20 UD20 UC20 UC20 50 U122 UF21 UI22 UI22 UI22 UJ22 UJ22 UE21 UC20 UD20 UC20 UC20 48 UE21 UI22 UE21 UF21 UI22 UH22 UJ22 UF21 UG21 UC20 UD20 UC20 UC20 46 UF21 UH22 UE21 UE21 UE21 UE21 U122 UG21 UF21 UE21 UD20 UC20 UC20 44 1 UE21 UI22 UH22 1 U122 I UH22 I UI22 I UF21 I UI22 I UJ22 I UJ22 UE21 I UD20 1 UC20 UH22 UE21 U122 UE21 UH22 UE21 UIZZ UE21 UH22 UJ22 UG21 UD20 UC20 UD20 UE21 UH22 UE21 UE21 UE21 UH11 UH22 UE21 Ulll UI12 UJ22 UE21 UC20 UC20 UE21 UH22 U722 UE21 UE21 UE21 UI22 UE21 UF21 UI22 UF21 UG21 UD20 UC20 UE21 UH22 UE21 UI22 UE21 UI22 UH22 UE21 UE21 UI22 UIZZ UJ22 UD20 UC20 UH22 UE21 UH22 UH22 UH22 UE21 U122 UH22 UI22 UF21 UH22 UJ22 UG21 UC20 UE21 UH22 1 UE21 UE21 UE21 UH22 UE21 UF21 UE21 UI22 UF21 UIZZ UG21 UC20 UE21 UH22 UE21 UE21 UE21 UH22 UE21 UF21 UE21 UI22 UF21 UI22 UG21 UC20 UH22 UE21 UH22 UH22 UH22 UE21 U122 UH22 UI22 UF21 UH22 UJ22 UG21 UC20 UE21 UH22 UE21 U712 UE21 UI22 UH22 UE21 UE21 UI22 UIZZ U,22 UD20 UC20 UE21 UH22 U122 UE21 UEZI UE21 U,22 UE21 UF21 UI22 UE21 UG21 UD20 UC20 UE21 UH22 UE21 UE21 UE21 UH22 UH22 UE21 U122 0122 UJ22 UE21 UC20 UC20 U1122 UE21 UI22 UE21 UH22 UE21 UI22 UE21 UH22 UJ22 UG21 UD20 UC20 UD20 42 40 38 36 34 32 30 28 26 24 22 20 UC20 UC20 UC20 UD20 UC20 UC20 UD20 UC20 UC20 UC20 18 1 UE21 UI22 UH22 1 UI22 I UH22 I UI22 I UF21 I U122 I UJ22 I UJ22 UE21 UD20 UC20 16 1 UF21 UH22 1 UE21 UE21 UG21 UC20 UC20 14 1 UE21 UI22 UE21 UF21 UF21 UC20 UC20 12 1 UI22 UF21 U122 U122 UE21 UC20 10 1 UF21 UH22 U122 UE21 UD20 08 1 UI22 UJ22 UJ22 06 1 UG21 UG21 UD20 I UD20 04 1 UC20 UC20 UC20 02 1 UC20 UC20 UC20 UC20 Fresh bundles are shown in bold italic.

NF-BEX-11-181 NP-Attachment Page 11 of 21 Figure 2 - Quad Cities 2 Cycle 21 - Reference Loading Pattern Fresh bundles are shown in bold italic.

NF-BEX-11-181 NP-AttachmentPage 12 of21 Figure 2 - Quad Cities 2 Cycle 21 -

Reference Loading Pattern 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 Legends Center 60 UA19 UB19 UA19 UA19 1 UA19 ASYTYP 58 UB19 UB19 UA19 UA19 UA19 56 UD20 UC20 UA19 1 UA19 1 UA19 UA19 54 UG21 UG21 UD20 UD20 UD20 UB19 UB19 UB19 UA19 UA19 52 UC20 UF2I UC20 UG21 UC20 UD20 UA19 UB19 UB19 UA19 UA19 50 UE2I UE21 UE21 UE21 UF21 UG21 UD20 UC20 UC20 UB19 UA19 UA19 48 UC20 UE2I t UC20'UE21 LUC20 UF21 UF2I UG21 UD20 UC20 UB19 UA19 UA19 46 UE21 UC20 UE2I 1UC20 UF21 UD20 UE21 UF21 1 UG21 UC20 UB19 I UB19 UA19 44 UC20 UE21 UC20 UE21 UC20 1 UE21 I UD20 UE21 UF2l UD20 UA19 1 UB19 UA19 42 1 UE21 UC20 UE21 UC20 1 UE21 UC20 1 UE21 UD20 1 UF21 UG21 UD20 1 UB19 UA19 I UAI9 UC20 UE21 UC20 UE21 UC20 UEZI UC20 UF21 UC20 UF21 UC20 UD20 UAI9 UB19 UA19 UE21 UC20 UE21 UC20 UE21 UC20 UE21 UC20 UE2l UE21 UG2I UD20 UC20 UA19 UA19 UC20 UE21 UC20 UE21 UC20 UEZI UC20 UE21 UC20 UE21 UC20 UD20 UC20 UA19 UA19 UE21 UC20 UE21 UC20 UE21 UC20 UE21 UC20 UE21 UEZI UFZI UG21 UC20 UB19 UBI9 UC20 UE21 UC20 UE21 UC20 UE21 UC20 UE21 UC20 UE21 UC20 UG2I UD20 UBI9 UA19 UC20 UE2l UC20 UE21 UC20 UE21 UC20 UE21 UC20 UEZI UC20 UG21 UD20 UBI9 UA19 UE21 UC20 UE21 UC20 UE21 UC20 UEZI UC20 UE21 UE21 UF21 UGll UC20 UB19 UB19 UC20 UEZI UC20 UEZI UC20 UE21 UC20 UE21 UC20 UE21 UC20 UD20 UC20 UA19 UAI9 UE21 UC20 UE21 UC20 UE21 UC20 UE21 UC20 UEZI UE21 UGZI UD20 UC20 UA14 UA19 UC20 UEZI UC20 UE21 UC20 UEZI UC20 UFZI UC20 UF21 UC20 UD20 UA19 UBI9 UA19 20 UE21 UC20 UE21 UC20 UE21 UC20 UE21 UD20 UF21 UG21 UD20 UB19 UA19 UA19 18 UC20 UE21 UC20 UE21 UC20 UE2I UD20 UE2I UF2l UD20 UA19 UB19 UA19 16 UE21 UC20 UE21 UC20 UF21 UD20 UE21 UF21 UG21 UC20 UB19 UB19 UA19 14 UC20 UE21 UC20 UE21 UC20 UF21 UF21 UG2l UD20 UC20 UB19 UA19 UA19 12 UE2I UE21 UE21 UF21 UG21 UD20 1 UC20 UC20 UB19 UA 19 UA19 10 UC20 UF2I UC20 UD20 UA19IUB19 UB19 UA19 UA 19 08 UG21 UG21 UD20 UD20 UD20 UB19 UB19 1 UB19 UA19 UA 19 06 UD20 UC20 UC20 UA19 UA19 UA19 I UA19 UA19 UA19 04 UB19 1 11819 UA19 UA19 1 11B19 UA19 02 UA19 UB19 UA19 UA19 1 UA19 Fresh bundles are shown in bold italic.

NF-BEX-11-181 NP-Attachment Page 13 of 21 40 38 36 34 32 30 28 26 24 22 Bundle Type Name Number Enrichment Cycle Loaded UC20 Opt2-3.99-15GZ8.00-3G6.00 160 3.99 20 UD20 Opt2-4.05-12GZ7.00-2G6.00 64 4.05 20 UE21 Opt2-4.02-14GZ8.00-4GZ5.50-14GZ5.50 168 4.02 21 UF21 Opt2-4,04-14GZ8.00-2GZ5.50-14GZ5.50 44 4.04 21 UG21 Opt2-4.07-14G5.50-2GZ5.50 40 4.07 21 UH22 Opt2-4.07-18GZ8.00-16GZ6.00 88 4.07 22 U122 Opt2-4.08-16GZ8.00-14GZ6.00 112 4.08 22 UJ22 Opt2-4.13-12GZ66.00-2GZ6.00 48 4.13 22 Bundle Type Name Number Enrichment Cycle Loaded UA19 Opt2-3.89-16GZ8.00-2G6.00 136 3.89 19 UB19 Opt2-3.94-13GZ7.00-2G6.00 76 3.94 19 UC20 Opt2-3.99-15GZ8.00-3G6.00 196 3.99 20 UD20 Opt2-4.05-12GZ7.00-2G6.00 64 4.05 20 UE21 Opt2-4.02-14GZ8.00-4GZ5.50-14GZ5.50 168 4.02 21 UF21 Opt2-4.04-14GZ8.00-2GZ5.50-14GZ5.50 44 4.04 21 UG21 Opt2-4.07-14G5.50-2GZ5.50 40 4.07 21 100% %PU Power

=2957 11W^100% Core Flow- 98.0 MTh/br E:43.6 %P / 23.0 % F B;S4.2 % P/35.5 % P Ct 100.0% P / 95.3 % F A: 100.0 % P l 100.0 % PE: 160.0 8 P / 108.0 % F Pr27 ,0% P / 108.0 % 'P G:18.836.6 % F 86.9 8 P / 88.5 8 F vitnf 0u 1n1 dock limo 10 2030 40 3o60 70 8o 90 100 110120 Core Flow (%)NF-BEX-11-181 NP-AttachmentPage 14 of 21 Figure 4 -

Quad Cities 2 Cycle 22 SLMCPR Results for SVEA-96 Optima2 Fuel a,c NF-BEX-11-181 NP-AttachmentPage 15 of 21 Figure 5 - Assembly Histograms a,c NF-BEX-11-181 NP-AttachmentPage 16 of 21 Figure 6 - Assembly Histograms a,c NF-BEX-11-181 NP-AttachmentPage 17 of 21 Figure 7 - Assembly Histograms a,c NF-BEX-11-181 NP-AttachmentPage 18 of 21 Figure 8 -

QCNPS, Unit 2, Cycle 22 -

Minimum CPR Distribution for the Limiting Point in the Cycle a,c NF-BEX-11-181 NP-AttachmentPage 19 of 21 Figure 8 - QCNPS, Unit 2, Cycle 22 - Minimum CPR Distribution for the Limiting Point in the Cycle a,c NF-BEX-11-181 NP-AttachmentPage 20 of 21 Figure 9 - Rod CPR Distribution for UH22 at the Limiting Point in Cycle 22 a,c Figure 10 - Rod CPR Distribution for UE21 at the Limiting Point in Cycle 21 a,c NF-BEX-11-181 NP-AttachmentPage 21 of 21