LR-N04-0375, Response to Request for Additional Information, Request for Change to Technical Specifications Safety Limit Minimum Critical Power Ratio

Response to Request for Additional Information, Request for Change to Technical Specifications Safety Limit Minimum Critical Power Ratio

ML042660196
Person / Time
Site:	Hope Creek
Issue date:	09/09/2004
From:	Brothers M Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR H04-03, LR-N04-0375
Download: ML042660196 (13)

Text

PSEG Nuclear LLC I P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 o PSEG SEP 0 9 2004 NuclearLLC LR-N04-0375 LCR H04-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS SAFETY LIMIT MINIMUM CRITICAL POWER RATIO HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354

Reference:

LR-N04-0183, "Request for Change to Technical Specifications: Safety Limit Minimum Critical Power Ratio," dated April 27, 2004.

By the referenced letter, PSEG Nuclear LLC (PSEG) requested a revision to the Technical Specifications (TS) for the Hope Creek Generating Station to revise the Safety Limit Minimum Critical Power Ratio (SLMCPR) values for two recirculation loop and one recirculation loop operation. In a communication from Mr. G. Miller on July 15, 2004, and in a telephone conference on August 3, 2004, the NRC requested additional information concerning the proposed change. The requested information is provided in the Attachment 1 to this letter. In accordance with 10 CFR 50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey.

PSEG has determined that the information contained in this letter and attachment does not alter the conclusions reached in the 10CFR50.92 no significant hazards analysis previously submitted.

Attachment 1 contains information that Global Nuclear Fuel - Americas, LLC (GNF-A) considers to be proprietary as defined by 10 CFR 2.390. GNF-A requests that the proprietary information in Attachment 1 be withheld from public disclosure in accordance with 10 CFR 2.390. An affidavit in support of this request is included with Attachment 1. A non-proprietary version suitable for public disclosure is provided in Attachment 2.

4 po1 This letter forwardsproprietaryInformationin accordance with 10CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 1.

95-2168 REV. 7/99

Document Control Desk LR-N04-0375 SEP 0 9 2004 Ifyou have any questions or require additional information, please contact Mr. Paul Duke at (856) 339-1466.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 'QA A/q -/to 7 (bate) Michael H. Brothers 3 Vice President - Site Operations Attachments (2)

This letter forwards proprietaryInformation in accordancewith 10CFR 2.390. The balance of this letter may be considerednon-proprietaryupon removal of Attachment 1.

Document Control Desk SEP 0 9 2004 LR-N04-0375 C: Mr. S. Collins, Administrator- Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Collins, Project Manager - Salem & Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08C2 Washington, DC 20555 USNRC Senior Resident Inspector- Hope Creek (X24)

Mr. K. Tosch, Manager IV (without Attachment 1)

Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625 This letter forwards proprietary information In accordancewith 10CFR 2.390. The balance of this letter maybe considered non-proprietary upon removal ofAttachment 1.

Attachment I LR-N04-0375 LCR H04-03 Response to Request for Additional Information (Proprietary Version)

Affidavit Affidavit I, Jens G. M. Andersen, state as follows:

(l) 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, "Responses to DRAFT REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO REQUESTED AMENDMENT TO LICENSE NO. NPF-57 PSEG NUCLEAR LLC COMPANY HOPE CREEK GENERATING STATION DOCKET NO. 50-354" dated August 31, 2004. GNF proprietary information is indicated by enclosing it in double brackets. In each case, the superscript notation 131 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 Energy Project v. Nuclear Regulatorv Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group 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;

Affidavit

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.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b., above.

(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 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 harn 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

Affidavit 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.

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 September, 2004.

Jens G. M. Andersen Global Nuclear Fuel - Americas, LLC LR-N04-0375 LCR H04-03 Response to Request for Additional Information (Non-Proprietary Version)

August 31, 2004 Responses to DRAFT REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO REQUESTED AMENDMENT TO LICENSE NO. NPF-57 PSEG NUCLEAR LLC COMPANY HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Proprietary Information Notice This document is the GNF non-proprietary version of the GNF proprietary document. From the GNF proprietary version, the information denoted as GNF proprietary (enclosed in double brackets) was deleted to generate this version.

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August 31, 2004 The staff has reviewed the April 27, 2004, Technical Specification amendment request and has identified the following questions to be addressed by the licensee in order to complete our evaluation:

Responses are provided to each RAI below. Note that the format for each response is a re-statement of the RAI followed by a written response. These responses have been verified and are documented in GNF eDRF object 0000-0032-1325.

1. Describe the rationale for placing four twice burned type 'C' fuel assemblies in the center of the core and twelve once burned type 'E' fuel assemblies around the center core in a symmetric core loading pattern of the core design, as shown in Figure 1 of the non-proprietary version of the GNF document.

Response to RAI 1: In general, GNF core designs are quadrant symmetric. Therefore, the center cell usually consists of four bundles of the same design and operational history. Use of four twice-bumt bundles in the center cell is typical of GNF core designs for 18 month fuel cycles (such as Hope Creek Cycle 13). Four once-burnt or four fresh' bundles would usually be too reactive to satisfy shutdown margin and or thermal margin requirements. Use of thrice-bumt bundles is generally unnecessary in order to achieve reactivity and thermal margin design goals.

The fuel surrounding the (twice-burnt) bundles in the center cell is generally fresh, once-bumt or a mixture of the two. Use of twice-bumt or thrice-burnt fuel surrounding the center cell would probably over-depress the power in the center region and thus compromise neutron economy.

The bundle placement decision making process is guided by the requirement to maintain specific reactivity and thermal margin design goals while optimizing overall neutron economy.

2. Describe in detail the process of calculating the difference of the SLMCPR value between the current and the next cycle operation in terms of the multiplication of bundle-by-bundle MCPR distribution and the bundle pin-by-pin power/R-factor distribution, the constant Vc,and the standard deviation ha a. Also, justify that the equation is still valid

• forthe mixed core from different fuel vendor, and provide the values for the constant Vc" and standard deviation "V used in the approximation equation for Cycle 13 calculation and identify that the two parameters are constant or fuel dependent.

Response to RAI 2: The SLMCPR value that is calculated for any particular core configuration through an operational cycle is the value resulting from the GESAM evaluation that utilizes the applicable power and non-power uncertainties as inputs, as described in NEDC-32601 P-A and NEDC-32694P-A. The correlation, referenced in RAI 2, that "estimatesw SLMCPR values uses a combination of the bundle-by-bundle MCPR distribution and the bundle pin-by-pin power/R-factor distribution parameters as inputs. The individual values of these parameters and their combination are indicators that can be used to compare SLMCPR evaluations of different core configurations, and help explain differences. They are used to identify large differences from expected behavior that could be indicators of either an error in the evaluation or the existence of non-typical behavior that cannot be accounted for by differences in these two parameters.

The bundle-by-bundle MCPR distribution provides a measure of the number of bundles that are near the MCPR operating limit (OL) for a specific core configuration / cycle exposure point. The influence that different GEXL correlations have on the proximity of a specific bundle to the MCPR OL is implicitly considered because proximity is defined in terms of the number of GEXL standard deviations using the GEXL uncertainty appropriate for that bundle. A higher value of the MCPR distribution parameter indicates a flatter distribution. The flatter MCPR distribution tends to increase the SLMCPR. The flatter the distribution, the greater number of bundles that have the potential to participate in the SLMCPR boiling transition probability evaluation when the limiting bundle is operating at the MCPR OL.

'Additionally, fresh bundles are all placed in locations that will allow them to run uncontrolled throughout Cycle 13. This is part of the "control cell core" (CCC) loading strategy. The center control blade is frequently utilized in a CCC loading so no fresh is loaded into that cell.

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August 31, 2004 The bundle pin-by-pin powerlR-factor distribution provides a measure of the number of pins within a bundle that are near the limiting pin. A higher value of the bundle pin-by-pin power/R-factor distribution indicates a flatter distribution. The flatter the R-factor distribution, the greater number of fuel pins within a particular bundle type that have the potential to participate in the SLMCPR boiling transition probability evaluation which tends to increase the SLMCPR.

((]

The SLMCPR estimation correlation function has not historically depended on the bundle types contained in a core or the specific GEXL correlation used to determine their MCPR performance.

This follows directly from the utilization of the two parameters combined into the quantity Z that incorporates both the effect of the bundle type specific GEXL correlation to determine the bundle MCPR distribution and also the bundle type specific pin-by-pin R-factor distribution that is used to determine the number of rods expected to be in boiling transition, for a given bundle type. See pages A-31 through A-33, NEDC-32601 P-A for a discussion of this process in more detail which directly supports the conclusion that the correlation function is independent of bundle type, provided a bundle type specific GEXL correlation is employed in the SLMCPR evaluation.

Since the correlation is not dependent on bundle type, the correlation parameters c and d are constants that only depend on the selection of SLMCPR methodology and uncertainties.

Therefore, it is appropriate to employ the correlation to estimate SLMCPR values for Hope Creek Generating Station Cycle 13 operation using the c and d correlation parameters that correspond to the methodology and uncertainties 'set" indicated in Table I of Attachment 3 to PSEG Nuclear LLC letter dated April 27, 2004.

3. It appears that a higher value of the product of bundle-by-bundle MCPR distribution and the bundle pin-by-pin power/R-factor distribution would result in a higher SLMCPR, i.e.,

the Cycle 13 value would be larger than that of Cycle 12. Describe the impact on the results of the SLMCPR calculation due to the difference of the product of these two parameters and explain why the Cycle 13 SLMCPR value is much less than Cycle 12 value.

Response to RAI 3: Not withstanding the effect of other parameters the higher value of the product of bundle-by-bundle MCPR distribution and the bundle pin-by-pin powerlR-factor distribution would be expected to result in a higher SLMCPR. However, changes to other parameters that specifically affect the GNF Hope Creek SLMCPR calculations result in a lower value for Cycle 13 compared to the value calculated by the legacy fuel Vendor and used for Cycle 12.

The table attached at the back of this response provides a breakdown of the differences between selected Cycle 12 and Cycle 13 parameters and their expected effect on calculated SLMCPR values. The discussion below compares the SLMCPR evaluation that was performed at the limiting cycle evaluation point (EOC) for Cycle 13 to the SLMCPR evaluation that has been calculated at the limiting cycle evaluation point (EOC) for Cycle 12, completed subsequent to the amendment application for the purpose of comparison using consistent methodology and uncertainties.

The first difference of -0.01 is directly due to the difference of nuclear evaluation methodologies between the legacy fuel vendor and GNF. The SLMCPR value for Cycle 12, calculated by the page 3 of 5

August 31, 2004 legacy fuel vendor, for the limiting SVEA96+ fuel was 1.10. Using the GNF methodology to independently calculate the limiting SLMCPR for Cycle 12 operation yielded a limiting SLMCPR value of 1.09. No difference was observed between the Cycle 13 and Cycle 12 bundle-by-bundle MCPR distribution parameters at the respective limiting cycle evaluation points, therefore no effect is expected associated with this parameter. The bundle pin-by-pin power/R-factor distribution parameter increased slightly. The expected effect to SLCMPR was calculated to be

+0.008 using the correlation as described in the response to RAI 2.

The remaining net expected decrease of 0.042 is due to differences in GEXL correlation bias and uncertainty between the GNF developed GEXL80 MCPR correlation and the GEXL14 correlation used to determine bundle-by-bundle MCPR for the Cycle 13 GE14 new reload fuel. SVEA96+

fuel is limiting for the Cycle 12 evaluation (no GE14 fuel in Cycle 12 core) while GE14 fuel is the fuel that participates in the SLMCPR evaluation at the Cycle 13 limiting condition (EOC). As is seen in the attached table, the SVEA96+ GEXL80 correlation ((

B. The net difference of -0.034 between the two biases accounts for the change in limiting fuel from SVEA96+ in Cycle 12 to limiting fuel of GE14 at the limiting EOC evaluation condition. Similarly, SVEA96+ GEXL80 correlation uncertainty

(( )) compared to the GE14 GEXL14 uncertainty. This results in a net decrease of -0.008 due to this effect.

Summing up the expected effect of all the parameter changes between the limiting evaluation for Cycle 12 and Cyclel3 gives -0.01+0.008-0.034-0.008 = -0.044 net expected decrease in SLMCPR in going from Cycle 12 legacy vendor methodology to Cycle 13 using GNF methodology.

The observed decrease in SLMCPR (to two significant digits) of 1.10 - 1.06 = 0.04 is completely consistent with the expected decrease of 0.044. Therefore, 1.06 is an appropriate value for the DLO SLMCPR for Cyclel3. A typical increase in SLMCPR going from a DLO condition value of 1.06 to SLO is - 0.01. Therefore, the requested SLO SLMCPR of 1.08, an increase of 0.02 from the DLO value, is an appropriate value and conservative.

4. Describe in detail the major contributors for the 0.04 reduction of the SLMCPR value with respect to the Cycle 12 value and their bases for the reduction.

Response to RAI 4: See response to RAI 3.

5. Provide a description of the power shape during the Cycle 13 operation. Also, in the SLMCPR calculation for Cycle 13 is there any penalty imposed if an upskew power shape occurs at the end of the cycle.

Response to RAM 5:

The response below addresses RAI 5 as clarified by discussion with the NRC staff during the teleconference on August 3, 2004.

The description of the power shapes considered in the SLMCPR evaluation process for Cycle 13 and any penalty imposed for upskew power shape is provided in Attachment 3 to PSEG Nuclear LLC's April 27, 2004 letter. The pertinent section of Attachment 3 is repeated below for convenience purposes.

[I 1))

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August 31, 2004 Cycle 13 to Cycle 12 DLO SLMCPR Comparison (Effect of parameter changes)

Expected effect on calculated Parameter EOC Cycle 12 EOC Cycle 13 SLMCPR SLMCPR DLO:

GNF - Legacy vendor value 1.09 -1.10 N/A -0.01 MCPR distribution (( 0.00 Pin-by-pin power/R-factor distribution _ _ _] +0.008 GEXL correlation bias (GEXL8O) (GEXL14) -0.034 GEXL correlation uncertainty [1 -0.008 SLMCPR:

DLO 1.10 1.06 -0.044 page 5 of 5