JAFP-04-0189, Response to Request for Additional Information Regarding Proposed License Amendment to Safety Limit Minimum Critical Power Ratio (SLMCPR) (TAC No. MC3391). Non-proprietary Version
| ML043640136 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/14/2004 |
| From: | Ted Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| JAFP-04-0189, TAC MC3391 | |
| Download: ML043640136 (9) | |
Text
-Entergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A. Fitzpatrick NPP RO. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan Site Vice President - JAF December 14, 2004 JAFP-04-0189 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Response to Request for Additional Information Regarding Proposed License Amendment to Safetv Limit Minimum Critical Power Ratio (SLMCPR) (TAC No. MC3391)
References:
- 1) Entergy Nuclear Operations, Inc. letter to USNRC (JAFP-04-0083), Proposed License Amendment to Safety Limit Minimum Critical Power Ratio (SLMCPR), dated June 4, 2004
- 2) USNRC letter to Entergy Nuclear Operations, Inc., Request for Additional Information Concerning Safety Limits for Minimum Critical Power Ratio (TAC No. MC339 1), dated July 6, 2004.
- 3) Entergy Nuclear Operations, Inc. letter to USNRC (JAFP-04-0158), Follow-up Response to Request for Additional Information and Revision to Proposed License Amendment to Safety Limit Minimum Critical Power Ratio (SLMCPR) (TAC No. MC339 1), dated September 27, 2004.
Dear sir:
By letter dated June 4, 2004 (Reference 1), Entergy Nuclear Operations, Inc. (ENO) proposed to amend the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) by revising the Safety Limit Minimum Critical Power Ratio (SLMCPR) for both single and dual recirculation loop operation. The Staff requested additional information via Reference 2.
On November 17, 2004, a telecom was held per your Staff's request to obtain additional clarification regarding ENO's response to Reference 2 (Reference 3). Attachment I to this letter provides the additional information requested during that telecom. In accordance with IOCFR 2.390(b)(1), an affidavit attesting to the proprietary nature of the enclosed information and requesting withholding from public disclosure is included with Attachment 1. Attachment 2 contains the same information with the proprietary information removed, and is provided for public disclosure.
Al l
This supplement to the license amendment request does not change the scope or conclusions in the original application, nor does it change the no significant hazards consideration determination.
There are no commitments contained in this letter.
If you have any questions in this regard, please contact Mr. Richard Plasse at (315) 349-6793.
I declare under penalty of perjury that the forgoing is true and correct.
Executed on this the
day of December, 2004.
Sincerely, A.-
__ 44
.5>
v:
H T.A. Sullivan Site Vice President TS:rp Attachments: 1. Response to Request for Additional Information (Proprietary Version)
- 2. Response to Request for Additional Information (Non-proprietary Version) cc:
Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident Inspector U. S. Nuclear Regulatory Commission P. 0. Box 136 Lycoming, NY 13093 Mr. P. Milano, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop: 8C2 Washington, DC 20555 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 1 O'h Floor Albany, New York 12223 Mr. Peter R. Smith, President NYSERDA 17 Columbia Circle Albany, NY 12203-6399 Affidavit Affidavit I, Jens G. M. Andersen, state as follows:
(1) I am Fellow and project manager, TRACG Development, Global Nuclear Fuel -
Americas, L.L.C. ("GNF-A") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in the attachment, "Additional Information Regarding the Cycle Specific SLMCPR for FitzPatrick Cycle 17," December 1, 2004. GNF proprietary information is indicated by enclosing it in double brackets. In each case, the superscript notation (3) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.390(a)(4) for "trade secrets 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," and some portions also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Ener~v Proiect v. Nuclear Regulatorv Commission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Grout v. FDA 704F2d1280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;
- b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
- c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, of potential commercial value to GNF-A;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
5 of 7
Affidavit The information souiight to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b., above.
(S) 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 GNF-A, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.
The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GNF-A or its licensor.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A or its licensor.
6 of 7
I I Affidavit The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of '.
resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed at Wilmington, North Carolina, this 1st day of
- December, 2004.
Jens G. M. Andersen Global Nuclear Fuel - Americas, LLC 7 of 7
ATTACHMENT 2 to JAFP-04-0189 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING SLMCPR (Non-Proprietary Version)
Entergy Nuclear Operations, Inc.
JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59
I December 1, 2004 Additional Information Regarding the Cycle Specific SLMCPR for FitzPatrick Cycle 17 Proprietary Information Notice This document is the GNF non-proprietary version of the GNF proprietary report. From the GNF proprietary version, the information denoted as GNF proprietary (enclosed in double brackets) was deleted to generate this version.
Discussion The original low flow Safety Limit Minimum Critical Power Ratio (SLMCPR) evaluation for FitzPatrick Cycle 17 was performed at a core flow rate of 80% of rated flow, which corresponds to the minimum core flow for the planned Maximum Extended Load Line Limit Analysis (MELLLA) core condition.
This was assumed to be conservative to the SLMCPR of the currently approved ELLLA flow rate of 87% core flow.
Discussions were held about this during a conference call on November 17, 2004 with' NRC, Entergy and GNF representatives. At that time, NRC called for the SLMCPR to be evaluated at the ELLLA core flow rate, since MELLLA operation is not yet approved for FitzPatrick.
Results of the evaluation are provided in Table 1, which'is an extension of Table 1 previously provided with the SLMCPR results of the rated core flow conditions and of the 80% core flow conditions. Column 4 of the table contains the SLMCPR results of the 87% core flow conditions. As expected, the 87% SLMCPR falls between those of the rated core flow conditions and of the 80% core flow conditions. Thus, the ELLLA SLMCPR bounds the rated core flow SLMCPR and is bounded by the MELLLA SLMCPR Tables 2a and 2b are also extensions of the corresponding previously provided tables 2a and 2b. Column 4 contains the SLMCPR results of the 87%'core'flow conditions.' Table 2a presents the standard uncertainties applied in the SLMCPR evaluations.
Table 2b gives the exceptions to the standard uncertainties used in the evaluations.
For the lower flow evaluations, the core flow rate uncertainty and random effective TIP reading uncertainty were increased by the inverse of the core flow fraction to conservatively account for an increase in relative uncertainty that may occur as core flow decreases. Although justification may exist to continue to use the same uncertainties at lower flow as are specified for rated flow in the current GNF SLMCPR methodology, no such credit was taken for the FitzPatrick low flow Cycle 17 evaluations.
In conclusion, it has been confirmed that the SLMCPR calculated at 80% core flow is more limiting than the SLMCPR calculated at 87% core flow, and that the SLMCPR calculated at 87% core flow is more limiting than the SLMCPR calculated at 100% core flow.
1 of 3
December 1, 2004 Additional Information Regarding the Cycle Specific SLMCPR for FitzPatrick Cycle 17 Table 1 Comparison of the FitzPatrick Cycle 17 and Cycle 16 SLMCPR QUANTITY, DESCRIPT ION.
FitzPatrick FitzPatrick FitzPatrick FitzPatrick Cycle 16 Cycle 17 Cycle 17 Cycle 17 Number of Bundles in Core 560 560 560 560 Limiting Cycle Exposure Point MOC BOC MOC MOC Cycle Exposure at Limiting Point 8000 200 9000 9000 (MWd/STU)_____
% Rated Flow 100 100 80 87 Reload Fuel Type GE14 GE14 GE14 GE14 Latest Reload Batch Fraction, %
35.0 36.4 36.4 36.4 Latest Reload Average Batch Weight % Enrichment 4.05 4.05 4.05 4.05 Core Fuel Fraction for GE14(%)
35.0 71.4 71.4 71.4 Core Fuel Fraction for GE12 (%)
65.0 28.6 28.6 28.6
.Core Average Weight %
40 Enrichment 4.06 4.05 4.05 4.05 Core MCPR (for limiting rod 1.46 1.37 1.38 1.36 pattern)
MCPR Importance Parameter, MIP Lr J
LL rrLII
- rr R-factor Importance Parameter, RIP
((L1L
((
.. Lr
- 1.
J.
MIPRIP
[
J J
J ILJL Power distribution methodology GETAB Revised Revised Revised NEDO-10958-NEDC-NEDC-NEDC-A 32601P-A 32601P-A 32601P-A Power distribution uncertainty GETAB Reduced Reduced Reduced NEDO-10958-NEDC-NEDC-NEDC-A 32694P-A 32694P-A 32694P-A Non-power distribution uncertainty Revised Revised Revised Revised NEDC-NEDC-
-NEDC-NEDC-32601P-A 32601P-A 32601P-A 32601P-A Calculated Safety Limit MCPR 1.09 1.06 1.07 1.07 (DLO)
S t
m_1.10 1.06_
1.07 1.07 Calculated Safety Limit MCPR 11
.7
.9 10 (SLO )
1_ 07 1__
_09
' Corrected value from initial submittal value of 1.06.
2 Of 3
December 1, 2004 Additional Information Regarding the Cycle Specific SLMCPR for FitzPatrick Cycle 17 Table 2a Standard Uncertainties FitzPatrick FitzPatrick FitzPatrick FitzPatrick DESCRIPTION Cycle 16 Cycle 17 Cycle 17 Cycle 17 100% Flow 100% Flow 80% Flow 87% Flow Revised Revised Revised Revised Non-power Distribution NEDC-NEDC-NEDC-NEDC-Uncertainties 32601P-A 32601P-A 32601P-A 32601P-A Core flow rate (derived from 2.5 DLO 2.5 DLO 2.5 DLO 2.5 DLO pressure drop) 6.0 SLO 6.0 SLO 6.0 SLO 6.0 SLO Individual channel flow area L[ ]1.((
.11.
[
]1
((
]1 Individual channel friction factor 5.0 5.0 5.0 5.0 Friction factor multiplier
[J JL Reactor pressure JJ 1L L L J
L
.[J.L.1I Core inlet temperature 0.2 0.2 0.2 0.2 Feedwater temperature J11 rr 11 J
.J L.r Feedwater flow rate 11L rr. 11
. I
- 1..
I GETAB Reduced Reduced Reduced Power Distrbution NEDC-NEDC-NEDC-NEDC-Uncertainties 32601P-A 32694P-A 32694P-A 32694P-A GEXL R-factor rr nU Lr 1.
rJ 1L rr 1L Random effective TIP reading 1.2 DLO 1.2 DLO 1.2 DLO 1.2 DLO 2.85 SLO 2.85 SLO 2.85 SLO 2.85 SLO Systematic effective TIP reading 8.6 1
Lr
.. JL.L..
Integrated effective TIP reading N/A
[]
..J[.
IU[rr Bundle power N/A JU21 rrJL..
Effective total bundle power 4.3
((
]
((
))
((
]
uncertainty Table 2b Exceptions to the Standard Uncertainties Used in FitzPatrick Cycle 17 Core Flow Rate (DLO)
((
))
((
))
GEXL R-factor
((
1]
((
))
((
]
Random effective TIP reading (DLO)
=
((
))
II 1]
3 of 3