CNS-14-114, Units 1 & 2 - License Amendment Request for Methodology Report DPC-NE-3001-P, Revision 1, Multidimensional Reactor Transients and Safety Analysis Physics Parameters - Response to NRC Request for Additional Information
| ML14321A531 | |
| Person / Time | |
|---|---|
| Site: | Catawba, McGuire, Mcguire  |
| Issue date: | 11/10/2014 |
| From: | Henderson K Duke Energy Carolinas, Duke Energy Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14321A530 | List: |
| References | |
| CNS-14-114, DPC-NE-3001-P, Rev 1, TAC MF3119, TAC MF3120, TAC MF3121, TAC MF3122 | |
| Download: ML14321A531 (11) | |
Text
Kelvin Henderson
~DUKE Vice President ENERGY. Catawba Nuclear Station Duke Energy CN01VP 14800 Concord Road CNS-14-114 York, SC 29745 o: 803.701.4251 November 10, 2014 f: 803.701.3221 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Subject:
Duke Energy Carolinas, LLC ("Duke Energy" or "Duke")
McGuire Nuclear Station, Units 1 and 2; Docket Nos. 50-369, 50-370 Catawba Nuclear Station, Units 1 and 2; Docket Nos. 50-413 and 50-414 License Amendment Request for Methodology Report DPC-NE-3001-P, Revision 1, MultidimensionalReactor Transients and Safety Analysis Physics Parameters Methodology (Proprietary)
Response to NRC Request for Additional Information (RAI)
(TAC Nos. MF3119, MF3120, MF3121, and MF3122)
References:
- 1. Letter from Duke Energy to NRC, License Amendment Request for Methodology Report DPC-NE-3001-P, Revision 1, MultidimensionalReactor Transients and Safety Analysis Physics ParametersMethodology (Proprietary), dated November 14, 2013
- 2. Letter from NRC to Duke Energy, Catawba Nuclear Station, Units 1 and 2 and McGuire Nuclear Station, Units 1 and 2 - Request for Additional Information Regarding License Amendment Request Re: Methodology Report DPC-NE-3001-P, Revision 1, Multidimensional Reactor Transients and Safety Analysis Physics Parameters Methodology (TAC Nos. MF3119, MF3120, MF3121, and MF3122), dated May 22, 2014
- 3. Letter from Duke Energy to NRC, License Amendment Request for Methodology Report DPC-NE-3001-P, Revision 1, MultidimensionalReactor Transients and Safety Analysis Physics ParametersMethodology (Proprietary), Response to NRC Request for Additional Information (RAI)
(TAC Nos. MF3119, MF3120, MF3121, and MF3122), dated June 27, 2014
- 4. Letter from NRC to Duke Energy, Catawba Nuclear Station, Units 1 and 2, and McGuire Nuclear Station, Units 1 and 2 - Request for Additional Information Regarding License Amendment Request Re: Methodology Report DPC-NE-3001-P, Revision 1, Multidimensional Reactor Transients and Safety Analysis Physics Parameters Methodology (TAC Nos. MF3119, MF3120, MF3121, and MF3122), dated October 14, 2014 Attachment A to this letter contains proprietary information.
AoD Withhold from public disclosure under 10 CFR 2.390.
Upon removal of Attachment A, this letter is uncontrolled. www.duke-energy.com
U.S. Nuclear Regulatory Commission Page 2 November 10, 2014 The Reference 1 letter requested NRC review and approval of proposed changes to the Facility Operating Licenses (FOLs) based on DPC-NE-3001-P, MultidimensionalReactor Transients and Safety Analysis Physics ParametersMethodology. The Reference 2 letter formally provided RAIs which were discussed in a telephone conference call between Duke Energy and the NRC on May 6, 2014. The Reference 3 letter provided Duke Energy's docketed responses to these RAIs. The Reference 4 letter formally provided additional RAIs which were discussed in a telephone conference call between Duke Energy and the NRC on October 1, 2014. The purpose of this letter is to formally respond to the Reference 4 RAIs. Attachments A and B to this letter provide the proprietary and non-proprietary versions, respectively, of the responses to these RAIs. The format of Attachments A and B is to restate each RAI, followed by its response.
As DPC-NE-3001-P contains information that is proprietary to Duke Energy, in accordance with 10 CFR 2.390, Duke Energy requests that this information be withheld from public disclosure.
An affidavit is included (Attachment C to this letter) from Duke Energy attesting to the proprietary nature of the information in this RAI response submittal. The specific information that is proprietary to Duke Energy is identified in the submittal.
Also, as the response to RAI question 1 contains information that is proprietary to Studsvik Scandpower (SSP), in accordance with 10 CFR 2.390, Duke Energy requests that this information be withheld from public disclosure. An affidavit is included (Attachment C to this letter) from SSP attesting to the proprietary nature of the information in this RAI response submittal. The specific information that is proprietary to SSP is identified in the submittal.
This RAI response submittal does not affect the conclusions of the Regulatory Evaluation or the Environmental Consideration which were provided in the Reference 1 letter.
Pursuant to 10 CFR 50.91, a copy of this RAI response submittal has been forwarded to the appropriate State of North Carolina and State of South Carolina officials.
There are no regulatory commitments contained in this letter or its attachments.
If you have any questions or need additional information on this matter, please contact L.J.
Rudy at (803) 701-3084.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on November 10, 2014.
Very rlus Kelvin Henderson Vice President, Catawba Nuclear Station LJR/s Attachments Attachment A to this letter contains proprietary information.
Withhold from public disclosure under 10 CFR 2.390.
Upon removal of Attachment A, this letter is uncontrolled.
U.S. Nuclear Regulatory Commission Page 3 November 10, 2014 xc (with all attachments):
V.M. McCree Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 J. Zeiler Senior Resident Inspector (McGuire)
U.S. Nuclear Regulatory Commission McGuire Nuclear Station G.A. Hutto, III Senior Resident Inspector (Catawba)
U.S. Nuclear Regulatory Commission Catawba Nuclear Station G.E. Miller (addressee only)
NRC Project Manager (McGuire and Catawba)
U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 xc (with Attachments B and C only):
W.L. Cox, III Section Chief Division of Environmental Health, Radiation Protection Section North Carolina Department of Environment and Natural Resources 1645 Mail Service Center Raleigh, NC 27699 S.E. Jenkins Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201 Attachment A to this letter contains proprietary information.
Withhold from public disclosure under 10 CFR 2.390.
Upon removal of Attachment A, this letter is uncontrolled.
Attachment B Response to NRC Requests for Additional Information (RAIs)
(Non-Proprietary Version)
B-I
REQUEST FOR ADDITIONAL INFORMATION MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST METHODOLOGY REPORT DPC-NE-3001-P, REVISION 1 DOCKET NOS. 50-369, 50-370, 50-413, AND 50-414 By letter dated November 14, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13325B142), Duke Energy Carolinas, LLC (Duke, the licensee),
submitted a license amendment request for Catawba Nuclear Station, Units 1 and 2, and McGuire Nuclear Station, Units 1 and 2. The proposed amendment requested review and approval to the Methodology Report DPC-NE-3001-P, Revision 1, "Multidimensional Reactor Transients and Safety Analysis Physics Parameters Methodology." By letter dated June 27, 2014 (ML14183B259), Duke provided a response to NRC staff RAIs on the subject amendment request.
The Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and response and has determined that additional information is needed to complete its review.
SNPB-RAI-1) Please submit the following documents, which were referenced as support for the validation and verification of the models in SIMULATE-3K:
" SSP-98/13, Revision 6, "SIMULATE-3K Models & Methodology"
- SSP-04/443, Revision 2, "LWR Core Reactivity Transients.
SIMULATE-3K Models and Assessment" Please also provide the following document, which was referenced in support of the SIMULATE-3 methodology:
- SOA-95/18, "SIMULATE-3 Methodology, Advanced Three Dimensional Two-Group Reactor Analysis Code" Duke Energy Response:
The submittal package for this RAI response includes a copy of each of the requested Studsvik Scandpower (SSP) documents. These documents are SSP proprietary, and in accordance with 10 CFR 2.390, Duke Energy requests that this information be withheld from public disclosure. The associated affidavit attesting to the proprietary nature of these documents is included as part of this RAI response submittal.
SNPB-RAI-2) The hot full power (HFP) steam line break (SLB) analysis is initiated from nominal conditions, according to Section 5.3.1, because it uses the statistical core design (SCD) methodology described in DPC-NE-2005P-A. This is appropriate for departure from nucleate boiling ratio (DNBR) analysis, because the uncertainties have been statistically convoluted into the DNBR limit.
B-2
Duke appears to use the same analysis to check the fuel centerline temperature against the centerline fuel melt (CFM) limit. If this reading of the methodology is correct, please justify use of the nominal SCD initial conditions to be appropriate.
If this reading is incorrect, please clarify the methodology that will be used to calculate fuel centerline temperature and compare to the limit.
Duke Energy Response:
RETRAN-02 is used to determine the core power response and limiting state point conditions following a HFP steam line break. The break size and the moderator temperature coefficient (MTC) are varied to determine the limiting DNBR and CFM state points. These state points are different, with the CFM state point determined by the maximum core power level attained. The maximum core power level is primarily a function of the break size and MTC. Because these parameters are dominant, the uncertainty in flow, temperature and pressure are maintained at their nominal values.
However, the core power level uncertainty is important, and is therefore applied to the SIMULATE-3 predicted Fq power distribution prior to comparison against CFM linear heat rate limits.
SNPB-RAI-3) With respect to Section B2.2.1, How did Duke account for thermal conductivity degradation impacts. What, if any codes have been employed for the purpose described in the section, and how are they used?
Duke Energy Response:
B-3
Attachment C Affidavits
AFFIDAVIT of Joseph Michael Frisco, Jr.
- 1. I am Acting Senior Vice President of Nuclear Engineering, Duke Energy Corporation, and as such have the responsibility of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear plant licensing and am authorized to apply for its withholding on behalf of Duke Energy.
- 2. I am making this affidavit in conformance with the provisions of 10 CFR 2.390 of the regulations of the Nuclear Regulatory Commission (NRC) and in conjunction with Duke Energy's application for withholding which accompanies this affidavit.
- 3. I have knowledge of the criteria used by Duke Energy in designating information as proprietary or confidential.
- 4. Pursuant to the provisions of paragraph (b) (4) of 10 CFR 2.390, the following is furnished for consideration by the NRC in 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 by Duke Energy and has been held in confidence by Duke Energy and its consultants.
(ii) The information is of a type that would customarily be held In confidence by Duke Energy. The information consists of analysis methodology details, analysis results, supporting data, and aspects of development programs, relative to a method of analysis that provides a competitive advantage to Duke Energy.
(iii) The information was transmitted to the NRC in confidence and under the provisions of 10 CFR 2.390, it is to be received in confidence by the NRC.
(iv) The information sought to be protected is not available in public to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in the submittal is that which is marked in the proprietary version of the response to the Request for Additional Information from the Nuclear Regulatory Commission dated October 14, 2014 concerning Revision 1 to the Duke methodology report DPC-NE-3001-P, MultidimensionalReactor Transientsand Safety Analysis Physics Parameters Methodology. This information enables Duke Energy to:
(a) Support license amendment requests for its McGuire and Catawba reactors.
(b) Perform reload design calculations on McGuire and Catawba reactor cores.
(vi) The proprietary information sought to be withheld from public disclosure has substantial commercial value to Duke Energy.
(a) Duke Energy uses this information to reduce vendor and consultant expenses associated with supporting the operation and licensing of nuclear power plants.
Page 1 of 2
(b) Duke Energy can sell the Information to nuclear utilities, vendors, and consultants for the purpose of supporting the operation and licensing of nuclear power plants.
(c) The subject information could only be duplicated by competitors at similar expense to that Incurred by Duke Energy.
- 5. Public disclosure of this information is likely to cause harm to Duke Energy because It would allow competitors in the nuclear industry to benefit from the results of a significant development program without requiring a commensurate expense or allowing Duke Energy to recoup a portion of its expenditures or benefit from the sale of the information.
Joseph Michael Frisco, Jr. affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.
ph Michael FrisJ Subscribed and sworn e:
' Dfte Notary Public My commission expires: ,k\mbe)' (p0 DIX>-
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Affidavit I, Jerry Umbarger, state as follows:
I. I am Chief Financial Officer of Studsvik Scandpower, Inc. (SSP) and have reviewed the information described in paragraph 2 which is sought to be withheld.
- 2. The information sought to be withheld consists of documentation for the computer codes SIMULATE-3K and SJMULATE-3 and responses to NRC questions concerning said computer codes contained in Duke's response to NRC Request for Additional Information dated October 14 ,2014. The basis for proprietary determination is provided in paragraph 3.
- 3. In making this application for withholding of proprietary information of which it is the owner, SSP relies on the exemption from disclosure set forth in the Freedom of Information Act ("FOIA'), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations IOCFR 9.17(aX4) and 2.390(a)(4) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information".
- 4. The information sought to be withheld is considered to be proprietary for the following reasons:
" Information that discloses a process, method and supporting data and analyses, where prevention of its use by SSP's competitors without license from SSP constitutes a competitive economic advantage over other companies;
" Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
- 5. To address the 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by SSP, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by SSP, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
- 6. The information identified in paragraph 2 is classified as proprietary because it contains details of SSP's computer code methodology. The development of the methods used in these analyses was achieved at a significant cost to SSP.
I
- 7. Public disclosure of the information sought to be withheld is likely to cause substantial harm to SSP's competitive position and foreclose or reduce the availability of profit-making opportunities. The computer codes and methodology are key components of the software and services sold by SSP, and its commercial value extends beyond the original development cost.
SSP's competitive advantage will be lost if its competitors are able to use the results of the SSP's experience.
The value of this information to SSP would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive SSP of the opportunity to exercise its competitive advantage to seek an adequate return on its investment.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information and belief.
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Subscribed and sworn to before me on this $90 y of - 2014 Witness my hand and official seal.
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