ML18214A706

Issuance of Amendment No. 322, Revise Technical Specification 2.1.1, Reactor Core Sls, to Change Cycle 24 Safety Limit Minimum Critical Power Ratio Numeric Values

ML18214A706
Person / Time
Site:	FitzPatrick
Issue date:	09/19/2018
From:	Tanya Hood Plant Licensing Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Hood T, NRR/DORL/LPL1, 301-415-1387
References
EPID L-2018-LLA-0146, JAFP-18-0048
Download: ML18214A706 (13)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 19, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT- ISSUANCE OF AMENDMENT NO. 322 RE: CHANGES TO THE TECHNICAL SPECIFICATION SAFETY LIMIT MINIMUM CRITICAL POWER RATIO (EPID L-2018-LLA-0146)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 322 to Renewed Facility Operating License No. DPR-59 for the James A.

FitzPatrick Nuclear Power Plant (FitzPatrick). The amendment consists of changes to the FitzPatrick Technical Specifications (TSs) in response to your application dated May 17, 2018.

The amendment revises TS 2.1.1, "Reactor Core SLs [Safety Limits]," to change Cycle 24 Safety Limit Minimum Critical Power Ratio (SLMCPR) numeric values. Specifically, the amendment modifies the TSs to decrease the numeric values of SLMCPR for FitzPatrick from

~ 1.1 O to ~ 1.07 for two recirculation loop operation and from ~ 1.13 to ~ 1.09 for single recirculation loop operation.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sililcerely,

~*; c* 1 L /~

< ___Jik fL6 {t-f:'.?if Tany~ E. Hood, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosures:

1. Amendment No. 322 to Renewed DPR-59

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 EXELON FITZPATRICK. LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-333 JAMES A. FITZPATRICK NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 322 Renewed License No. DPR-59

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated May 17, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-59 is hereby amended to read as follows:

2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 322, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented prior to startup from the fall 2018 refueling outage.

gu FOR THE NUCLEAR REGULATORY COMMISSION James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of lssuance: September 19, 2018

ATTACHMENT TO LICENSE AMENDMENT NO. 322 JAMES A. FITZPATRICK NUCLEAR POWER PLANT RENEWED FACILITY OPERATING LICENSE NO. DPR-59 DOCKET NO. 50-333 Replace the following page of the License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page Page 3 Page 3 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Pages Insert Pages 2.0-1 2.0-1

(4) Exelon Generation Company pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use, at any time, any byproduct, source and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools.

(5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as May be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and

50. 59 of Part 50, and Section 70. 32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level Exelon Generation Company is authorized to operate the facility at steady state reactor core power levels not in excess of 2536 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 322, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection Exelon Generation Company shall implement and maintain in effect all provisions of the approved fire protections program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 197 4; the SER dated August 1, 1979; the SER Supplement dated October 3, 1980; the SER Supplement dated February 13, 1981; the NRC Letter dated February 24, 1981; Technical Specification Amendments 34 (dated January 31, 1978), 80 (dated May 22, 1984), 134 (dated July 19, 1989),

135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 (dated August 10, 1990), 176 (dated January 16, 1992), 177 (dated February 10, 1992), 186 (dated February 19, 1993), 190 (dated June 29, 1993), 191 (dated July 7, 1993), 206 (dated February 28, 1994),

and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, Amendment 322 Renewed License No. DPR-59

SLs 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure< 685 psig or core flow

< 10% rated core flow:

THERMAL POWER shall be~ 25% RTP.

2.1.1.2 With the reactor steam dome pressure~ 685 psig and core flow

~ 10% rated core flow:

MCPR shall be~ 1.07 for two recirculation loop operation or

~ 1.09 for single recirculation loop operation.

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

2.1.2 Reactor Coolant System Pressure SL Reactor steam dome pressure shall be ::;; 1325 psig.

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

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

JAFNPP 2.0-1 Amendment 322

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 322 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-59 EXELON FITZPATRICK, LLC EXELON GENERATION COMPANY, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

By letter dated May 17, 2018, 1 Exelon Generation Company, LLC (Exelon, the licensee) submitted a license amendment request (LAR) for changes to the James A. FitzPatrick Nuclear Power Plant (FitzPatrick) Technical Specifications (TSs). Portions of the letter dated May 17, 2018, contain sensitive unclassified non-safeguards information and have been withheld from public disclosure pursuant to Section 2.390 of Title 10 of the Code of Federal Regulations (10 CFR).

The proposed changes in the LAR would revise the requirements in TS 2.1.1, "Reactor Core SLs [Safety Limits]," to change Cycle 24 Safety Limit Minimum Critical Power Ratio (SLMCPR) numeric values resulting from SLMCPR analyses performed. The amendment would decrease the numeric values of SLMCPR for FitzPatrick from ;;:: 1.1 Oto ;;:: 1.07 for two recirculation loop operation and from ;;:: 1.13 to;;:: 1.09 for single recirculation loop operation.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance that the U.S. Nuclear Regulatory Commission (NRC) staff considered in its review of this LAR are described below.

2.1 Applicable Regulatory Requirements Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML18137A418.

Enclosure 2

The regulation under 10 CFR 50.36, "Technical specifications," establishes the regulatory requirements related to the contents of the TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. The regulation does not specify the particular requirements to be included in a plant's TSs.

Section 50.36(c)(1 )(i)(A) to 10 CFR 50 requires, in part, that safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity.

The fuel cladding is one of the physical barriers that separate the radioactive materials from the environment. The SLMCPR is a safety limit that is required to be in the TSs to ensure that fuel design limits are not exceeded. The SLMCPR limit is contained in FitzPatrick TS 2.1.1 and it can vary from cycle to cycle.

The regulations under Appendix A to 10 CFR 50, "General Design Criteria for Nuclear Power Plants" (hereinafter referred to as GDC) establish the minimum requirements for the principal design criteria of water-cooled nuclear power plants. The principal design criteria establish the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety.

The NRC staff identified GDC 10, "Reactor design," as applicable to the LAR. This GDC requires, in part, that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits (SAFDLs) are not exceeded. The purpose of the SLMCPR is to ensure that SAFDLs are not exceeded during steady state operation and analyzed transients.

2.2 Applicable Guidance The guidance document the NRC staff considered in its review of this LAR is NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR [Light-Water Reactor] Edition" (hereinafter referred to as the SRP). The relevant sections of the SRP used in the review of this LAR include the following:

• Chapter 4, "Reactor," Section 4.2, "Fuel System Design," Revision 3, March 2007, 2 provides guidance to the NRC staff on the acceptability of the reactivity control systems, the reactor core, and fuel system design. Specifically, SRP Section 4.2 specifies all fuel damage criteria for evaluation of whether fuel designs meet the SAFDLs.

• Chapter 4, "Reactor," Section 4.4, "Thermal and Hydraulic Design," Revision 2, March 2007, 3 provides guidance to the NRC staff on the review of thermal-hydraulic design in meeting the requirement of GDC 10 and the fuel design criteria established in SRP Section 4.2. Section 4.4 of the SRP states that the critical power ratio is to be established such that at least 99.9 percent of fuel rods in the core would not be expected 2 ADAMS Accession No. ML070740002.

3 ADAMS Accession No. ML070550060.

to experience departure from nucleate boiling or boiling transition during normal operation or anticipated operational occurrences.

3.0 TECHNICAL EVALUATION

3.1 Description of Proposed Technical Specification Changes The licensee is proposing to revise the SLMCPRs contained in TS Section 2.1.1 for two recirculation loop operation and for single recirculation loop operation. Based on the analysis in the LAR, which used NRG-approved methodologies, the licensee has proposed to amend the calculations for FitzPatrick cycle-specific core reload analysis for Operating Cycle 24. The calculated SLMCPR would change from .::: 1.10 to .::: 1.07 for two recirculation loop operation and from .::: 1.13 to .::: 1.09 for single recirculation loop operation.

Specifically, the licensee requested to revise safety limit 2.1.1.2, to read as follows (changes shown in bold and italic):

With the reactor steam dome pressure .::: 685 psig and core flow .::: 10% rated core flow:

MCPR shall be.::: 1.07 for two recirculation loop operation or.::: 1.09 for single recirculation loop operation.

3.2 Technical Review The SLMCPR numeric values in FitzPatrick TS 2.1.1 are safety limits. The SLMCPR limit is established such that at least 99.9 percent of the fuel rods in the core would not be expected to experience the onset of transition boiling as a result of normal operation and transients, which in turn ensures fuel cladding damage does not occur. The SLMCPR limit is established such that fuel design limits are not exceeded during steady state operation, normal operational transients, and abnormal operational transients. As such, fuel damage is calculated not to occur if the limit is not violated. However, because fuel damage is not directly observable, a step-back approach is used to establish corresponding operating limits. The Operating Limit MCPR (OLMCPR) is established by summing the cycle-specific core reload transient analyses adders and the calculated SLMCPR values. The OLMCPR is required to be established and documented in the Core Operating Limits Report (COLR) for each reload cycle by FitzPatrick TS 5.6.5, "Core Operating Limits Report (COLR)."

The absolute value of SLMCPR tends to vary from cycle to cycle, typically due to the introduction of improved fuel bundle types, changes in fuel vendors or applicable computer codes, and changes in core loading pattern. Following the determination of the cycle-specific SLMCPR values, the OLMCPR values are derived. The cycle-specific SLMCPR numeric values are listed in TS 2.1.1 and, therefore, must be revised using the license amendment process.

Global Nuclear Fuel (GNF) performed the FitzPatrick Cycle 24 SLMCPR calculation consistent with NRG-approved methodologies and uncertainties, as documented in the following topical reports:

• NEDE-24011 P-A, "General Electric Standard Application for Reactor Fuel," Revision 26, January 2018 (GESTAR 11). 4

• NEDC-32601 P-A, "Methodology and Uncertainties for Safety Limit MCPR Evaluations,"

Revision 0, August 1999.5

• NEDC-32694P-A, "Power Distribution Uncertainties for Safety Limit MCPR Evaluations,"

Revision 0, August 1999.6

• NEDC-32505P-A, "R-Factor Calculation Method for GE 11, GE 12 and GE 13 Fuel,"

Revision 1, July 1999.7 These methodologies were used for the FitzPatrick Cycle 23 and the Cycle 24 SLMCPR calculations. The NRC staff reviewed the proposed change to ensure that the generic methods were appropriately applied to FitzPatrick. The FitzPatrick Cycle 23 core consists of 560 GNF2 fuel assemblies. No plant hardware or operational changes are required with this proposed change.

The NEDC-32505P-A report is the generic R-Factor methodology that describes the changed methodology that was adopted after part-length rods were introduced. The NRC staff's safety evaluation for NEDC-32505P-A states that the applicability of the R-Factor methodology must be confirmed when a new fuel type is introduced. The GNF letter designated FLN-2007-011, "GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II), NEDC-33270P, March 2007, and GEXL 17 Correlation for GNF2 Fuel, NEDC-33292P, March 2007," 8 was submitted to the NRC on March 14, 2007. The FLN-2007-011 letter confirmed that the R-Factor methodology of NEDC-32505P-A is applicable to GNF2, and that all of the criteria defined in NEDE-24011-P-A have been met for the GNF2 fuel design. As part of an NRC audit related to the GNF2 advanced fuel assembly design, the GNF2 fuel design was verified to have been evaluated in accordance with the topical reports listed above. This was documented in an audit report dated September 25, 2008. 9 The current cycle core design has produced similar results to the previous cycle core design.

The change in the calculated SLMCPR can be attributed to cycle-to-cycle variation. A key component of this variation is both the bundle-by-bundle MCPR distribution as well as the pin-by-pin power/R-Factor distribution. The only effect the increase in power level has is a difference in the flow uncertainty, which decreases due to the increase in the minimum core flow.

For the Cycle 23 limiting two recirculation loop operation cases, the core bundle-by-bundle MCPR distribution is not significantly different from the Cycle 24 limiting two recirculation loop 4 Proprietary; not publicly available.

5 ADAMS Accession No. ML14093A216.

6 Proprietary; not publicly available.

7 ADAMS Accession No. ML060520636.

8 ADAMS Accession No. ML070780335.

9 ADAMS Accession No. ML081630579.

operation cases; however, the bundle pin-by-pin power/R-Factor distribution is much flatter.

The bundle pin-by-pin power/R-Factor distribution being flatter for Cycle 23 versus Cycle 24 is the primary reason the SLMCPR decreased.

The Cycle 24 change in the Monte Carlo single recirculation loop operation SLMCPR from Cycle 23 is consistent with the Monte Carlo two recirculation loop operation SLMCPR change between the two cycles. The single recirculation loop operation values are greater than the two recirculation loop operation values as expected due to the increase in uncertainties used for the single recirculation loop operation case.

3.3 Evaluation of Technical Specification Changes The NRC staff reviewed the proposed changes to the TSs by considering whether the proposed change would continue to meet the requirements of 10 CFR 50.36 and GDC 10. On the basis of the analysis performed by GNF, using NRG-approved methodologies, the licensee has proposed to amend the FitzPatrick TS Section 2.1.1 to revise the SLMCPR for the Operating Cycle 24. This information regarding requested changes to the FitzPatrick TS SLMCPR is based on and is for the core rated power of 2,536 Megawatt thermal and a minimum core flow at rated thermal power of 79.8 percent (rated core flow).

The current required SLMCPR values in FitzPatrick TS are .?: 1.1 O for two recirculation loop operation and .?: 1.13 for single recirculation loop operation. Calculations performed by GNF for Cycle 24 resulted in a minimum calculated value of SLMCPR to be .?: 1.07 for two recirculation loop operation and .?: 1.09 for single recirculation loop operation. For Cycle 24, the minimum core flow SLMCPR calculation performed at 79.8 percent core flow and rated core power condition was limiting as compared to the rated core flow and rated core power condition.

GNF's calculation of the revised plant-specific SLMCPR numeric values for FitzPatrick Cycle 24 was performed as part of the reload licensing analysis for FitzPatrick Cycle 24, and is based upon NRG-approved methods, therefore, the NRC staff finds it is acceptable.

3.4 Technical Evaluation Conclusion The NRC staff verified that no departures from NRG-approved methodologies, or deviations from NRG-approved calculation uncertainties, were identified in the FitzPatrick Cycle 24 SLMCPR calculations. All calculated uncertainties for FitzPatrick Cycle 24 SLMCPR calculations were in accordance with NRG-approved methodologies.

Based on its evaluation, the NRC staff concludes that the SLMCPR will continue to provide assurance that 99.9 percent of the fuel rods in the core will not exceed the critical power ratio, and that fuel cladding integrity will be maintained under conditions of normal operation and with appropriate margin for anticipated operational occurrences. The NRC staff finds, with reasonable assurance, that the proposed change to the FitzPatrick TSs will continue to comply with the regulatory requirements and guidance identified in Section 2.0 of this safety evaluation.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment on July 31, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on July 13, 2018 (83 FR 32692). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.

Principal Contributors: T. Brimfield, NRR T. Hood, NRR Date: September 19, 2018

ML18214A706 *SE memo dated **Via E-mail OFFICE NRR/DORL/LPL 1/PM NRR/DORL/LPL 1/LA NRR/DSS/SRXB/BC* N R R/DSS/STS B/BC**

NAME THood LRonewicz JWhitman VCusumano (JBurkhardt for)

DATE 08/02/2018 08/09/2018 06/21/2018 08/08/2018 OFFICE OGC NRR/DORL/LPL 1/BC NRR/DORL/LPL 1/PM NAME AGhosh Joanna THood DATE 09/11/2018 09/18/2018 09/19/2018