ML021550019

(TMI) Unit 1) - M5 Lead Test Rods - 14R Refueling Outage Post Irradiation Examinations

ML021550019
Person / Time
Site:	Crane
Issue date:	05/20/2002
From:	Gallagher M AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
5928-02-20120 BAW-2424NP, BAW-2424P
Download: ML021550019 (23)

Text

AmerGenM AmerGen Energy Company, LLC www.exeloncorp.com An Exelon/British Energy Company 200 Exelon Way Suite 345 Kennett Square, PA 19348 May 20, 2002 5928-02-20120 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

M5' LEAD TEST RODS - 14R REFUELING OUTAGE POST IRRADIATION EXAMINATIONS THREE MILE ISLAND, UNIT 1 (TMI UNIT 1)

FACILITY OPERATING LICENSE NO. DPR-50 NRC DOCKET NO. 50-289

References:

(1) AmerGen letter to the NRC, dated April 11, 2001 (5928-01-20108),

"Additional Information-Proposed Irradiation Of Fuel Rods Beyond Current Lead Rod Burnup Limit" (2) NRC letter to AmerGen, dated May 18, 2001 (5928-01-30173), "Three Mile Island Nuclear Station, Unit 1 (TMI-1) - Re: Proposed Irradiation Of Fuel Rods Beyond Current Lead Rod Burnup Limit" (3) AmerGen letter to the NRC, dated January 18, 2001 (5928-00-20394),

"Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit" The following information is provided in accordance with the AmerGen Energy Company, LLC (AmerGen) commitment, described in References 1 and 2, to provide Post Irradiation Examination (PIE) data for the M5Tm lead test rods as well as confirmation that the M5 lead test rods meet all fuel rod design criteria throughout their fourth cycle of operation as determined by the TMI Unit 1 Cycle 14 reload licensing analyses.

The PIE results obtained following the M5 lead test rods' third cycle of operation in TMI Unit 1 Cycle 13 are presented in Framatome ANP Report BAW-2424P (Enclosure 1). Enclosure 1 contains information proprietary to Framatome ANP, as defined in 10 CFR 2.790(a)(4).

Accordingly, it is requested that Enclosure 1 be withheld from public disclosure. An affidavit certifying the basis for this application for withholding as required by 10 CFR 2.790(b)(1) is also enclosed with this letter. Enclosure 2 provides a non-proprietary version of the report. As noted

5928-02-20120 May 20, 2002 Page 2 of 2 in BAW-2424P, all measured fuel performance parameters were within the design models and no unexpected trends were observed. After irradiation in three 24-month cycles, PIE measurements show that the M5 lead test fuel rods continue to demonstrate low growth and low corrosion performance relative to Zr-4 clad fuel, as expected. Shoulder gap measurements taken on the reconstituted host assembly (NJ07U9) containing the M5 lead test rods demonstrate adequate clearance for the continued irradiation of the M5 rods in Cycle 14 to the extended bumup of -69 GWd/MTU. Following the conclusion of TMI Unit 1 operating Cycle 14, additional PIE data will be obtained from the extended burnup M5 lead test rods and will be provided to the NRC.

The preliminary safety assessment provided in Reference 3 noted that several of the M5 fuel rod design parameters would be evaluated during the cycle-specific reload licensing analyses performed by Framatome ANP for TMI Unit 1 Cycle 14. The extended burnup of four M5 fuel rods up to -69 GWd/MTU in twice-burned host Assembly NJ07U9 has been fully addressed as part of the TMI Unit 1 Cycle 14 Reload Safety Evaluation, using Framatome ANP's NRC approved reload design methods and approved fuel rod design models and methods. The fuel rods have been shown to satisfy all design criteria that are applicable for the current lead rod burnup limit. In addition, the cycle-specific evaluation of the reload design's impact on safety analyses has shown that the existing analyses of record remain applicable. The M5 lead test rods were shown to have no impact on core operation, including setpoints.

If any additional information is needed, please contact David J. Distel at (610) 765-5517.

Sincerely, Michael P. Gallagher Director, Licensing & Regulatory Affairs Mid-Atlantic Regional Operating Group

Enclosures:

(1) Framatome ANP Report BAW-2424P, "Operation Of Fuel Rods Beyond Current Limit - Three Mile Island 1 Cycle 13 PIE," April 2002, Proprietary (2) Framatome ANP Report BAW-2424NP,"Operation Of Fuel Rods Beyond Current Limit - Three Mile Island 1 Cycle 13 PIE," April 2002, Non-Proprietary (3) Framatome ANP Affidavit Certifying Request for Withholding From Public Disclosure cc: H. J. Miller, Administrator, USNRC Region I T. G. Colburn, USNRC Senior Project Manager, TMI Unit 1 J. D. Orr, USNRC Senior Resident Inspector, TMI Unit 1 File No. 00141

BAW-2424NP 77-2424NP-00 April 2002 OPERATION OF FUEL RODS BEYOND CURRENT LIMIT THREE MILE ISLAND 1 CYCLE 13 PIE A

FRAMATOME ANP 3315 Old Forest Road P.O. Box 10935 Lynchburg, Virginia 24506-0935

Framatome ANP BAW-2424NP ACKNOWLEDGMENT The work reported herein is the product of the efforts of many individuals at Framatome ANP and AmerGen Energy - Both at General Offices and at the reactor site. Their help and effort is gratefully recognized.

Principal Authors Anant Mohan John Strumpell

Framatome ANP BAW-2424NP Framatome ANP Lynchburg, Virginia Report BAW-2424NP April 2002 OPERATION OF FUEL RODS BEYOND CURRENT LIMIT THREE MILE ISLAND I CYCLE 13 PIE Key Words: Mark-B10, Post-Irradiation Examination (PIE), Fuel Assembly, Pressurized Water Reactor, Fuel Performance.

ABSTRACT The TMI-1 cycle 13 post-irradiation examination (PIE) took place in October 2001. At the end of that cycle, two test assemblies had completed three 24-month cycles. Each of the test assemblies contained four fuel rods clad with advanced alloy M5. Four of the M5 rods were removed and reconstituted into a different assembly for another cycle of irradiation. The purposes of the PIE were

"* to characterize the current condition of the M5 fuel rods,

"* to characterize the current condition of Zircaloy-4 fuel rods for comparison with the advanced-alloy rods,

• to ensure that the advanced-alloy rods could be irradiated safely for another cycle, and

• to ensure that the host assembly could safely accept these rods for another cycle of irradiation.

At the end of Cycle 13, all measured fuel performance parameters were within the design models and no unexpected trends had been observed. The M5 fuel rod growth is minimal, and the rate of shoulder gap closure for these rods is low. The peak oxide thickness for the M5 fuel rods is approximately [

] of that for the Zircaloy-4 fuel rods.

[

]. The M5 fuel rods still have significant margin for a fourth cycle of operation and for the extended burnup of -69GWd/MTU projected at the end of cycle 14.

I

Framatome ANP BAW-2424NP CONTENTS

1. Three Mile Island Unit I Cycle 13 Operation.........................................................

4

2. Purpose of PIE............................................................................................................

4

3. Post-Irradiation Examination Results.....................................................................

4 3.1 Fuel Assem bly Growth....................................................................................

5 3.2 Fuel Rod Growth and Shoulder Gap Closure................................................

5 3.3 Fuel Rod Oxide Thickness..............................................................................

5 3.4 Fuel Rod Diameter........................................................................................

6 3.5 Conclusions.........................................................................................................

7

4. References................................................................................................................

15 2

Framatome ANP BAW-2424NP LIST OF FIGURES Figure 1. Core Locations of Selected Fuel Assemblies for TMI-1 Cycles 11 to 14.....

8 Figure 2. Location of M5 Fuel Rods in Assembly NJ07VX..........................................

9 Figure 3. Fuel Assembly Growth................................................................................

9 Figure 4. Fuel Assembly Shoulder Gap Closure.......................................................

10 Figure 5. Fuel Rod Growth.........................................................................................

10 Figure 6. Fuel Rod Oxide Thickness. M5 and Zircaloy-4 Fuel Rods.......................... 11 Figure 7. Typical Fuel Rod Diameter Profiles...........................................................

11 LIST OF TABLES Table 1. Summary of Fuel Inspections.....................................................................

12 Table 2. Fuel Assembly Length and Irradiation Growth............................................

12 Table 3. Fuel Rod Irradiation Growth and Shoulder Gap..........................................

13 Table 4. Fuel Rod Oxide Thickness..........................................................................

13 Table 5. Summary of Fuel Rod Diameters..............................................................

14 3

BAW-2424NP Framatome ANP

1. Three Mile Island Unit 1 Cycle 13 Operation Cycle 13 for AmerGen Energy's Three Mile Island Unit I (TMI-1) began on October 18, 1999 and ended on October 9, 2001. The total cycle length was 691.96 EFPD. A post irradiation examination (PIE) was completed in October 2001.

2. Purpose of PIE Two Mark-B1 0 test assemblies, NJ07VX and NJ07VY, were first inserted into the core of TMI-1 for irradiation during cycle 11. These assemblies were designed to measure the corrosion of advanced alloy M5 during long, high-duty cycles. At the end of cycle 13, these assemblies had successfully completed three 24-month cycles. Peak pin burnups were about 50 GWd/MTU. At that time, four fuel rods with M5 cladding and two with Zircaloy-4 cladding were removed from NJ07VX. The four M5 rods were reconstituted into a different assembly, NJ07U9, for additional irradiation. NJ07U9 had previously been irradiated for two cycles but was out of core during cycle 13. The locations of assemblies NJ07VX and NJ07U9 during cycles 11 through 14 are shown in Figure 1, and the locations of the rods removed from NJ07VX are shown in Figure 2. The assembly designations in Figure 1 have been abbreviated by dropping the initial "NJO".

Bumup (BU) represents peak pin burnup in the assembly and is given in units of GWd/MTU.

The purposes of the PIE were

"* to characterize the current condition of the M5 fuel rods,

"* to characterize the current condition of Zircaloy-4 fuel rods for comparison with the advanced-alloy rods,

"* to ensure that the advanced-alloy rods could be irradiated safely for another cycle, and

"* to ensure that the host assembly could safely accept these rods for another cycle of irradiation.

Table I provides a summary of the PIE scope. Assembly NJ07VY was available as a backup, for example, if some rods could not be removed from NJ07VX. However, the backup was not needed.

3. Post-Irradiation Examination Results The TMI-1 cycle 13 post-irradiation examination (PIE) took place in October 2001. Fuel assembly lengths and shoulder gaps were measured for test assembly NJ07VX and assembly NJ07U9, which was to serve as a host for fuel rods from NJ07VX. Full-length profiles of fuel rod oxide thickness and diameter were measured for selected rods from NJ07VX. Fuel rod oxide thickness was measured on the west, north, east, and south sides of the fuel rods. Since the rod puller provides limited rotation, the scan on the south side of the fuel rods was approximately south-southeast, but the other directions correspond to the directions of the assembly faces.

4

Framatome ANP 3.1 Fuel Assembly Growth Fuel assembly growth data were obtained by using a dipstick probe, which compares the guide thimble length to a standard length. Based on a reference value, the change in length is determined. Table 2 summarizes the fuel assembly length and growth results. For comparison, available data from the end of cycle 12 are also provided.

Figure 3 provides plots of the fractional fuel assembly growth as a function of fuel rod bumup. The results are compared to the Mark-B upper tolerance limit (UTL).

The results show that the growth is linearly related to fuel rod bumup. The M5 test assembly fuel growth is enveloped by the Mark-B UTL.

3.2 Fuel Rod Growth and Shoulder Gap Closure Shoulder gap measurements were made on fuel assemblies NJ07VX and NJ07U9.

Shoulder gaps were measured for NJ07U9 assembly both before and after reconstitution. Table 3 summarizes shoulder gaps and the fuel rod growth. Figure 4 shows the shoulder gap closure as a function of the fuel rod bumup. The results are compared against Mark-B UTL.

The maximum fuel rod growth for the M5 fuel rods is smaller than that for Zircaloy-4 rods. The fuel rod growth at -50 GWd/MTU for M5 rods is [

] smaller than for Zircaloy-4 rods. Figure 5 shows fuel rod growth as a function of fuel rod bumup. The results are enveloped by the UTL of M5 fuel rod growth. Table 3 indicates positive M5 margins of shoulder gap closures for fuel assemblies NJ07VX and NJ07U9. The maximum predicted fuel rod bumup (-69 GWd/MTU) forthe four M5 fuel rods inserted into the reconstituted fuel assembly NJ07U9 is significantly higher than the predicted assembly bumup for NJ07U9 fuel assembly (54.793 GWd/MTU) at end of cycle 14.

However, due to the larger minimum shoulder gap available for the M5 rods relative to the Zircaloy-4 rods in the host assembly, as shown in Table 3, and the lower rod growth demonstrated by M5 data to date, the extended bumup of M5 rods to -69 GWd/MTU is acceptable.

3.3 Fuel Rod Oxide Thickness The fuel rod oxide thickness was determined with an eddy current probe passed down the fuel rod outside diameter. Full-length examinations were performed in the spent fuel pool. All rods were taken from fuel assembly NJ07VX, which had been burned for three cycles. Four fuel rods had M5 cladding and two had Zircaloy-4 cladding. The data for Zircaloy-clad rods were collected to determine the corrosion behavior of such rods in the vicinity of M5-clad rods.

The fuel rod oxide measurements were made for the full length of the rod, approximately 144 inches. The oxide was measured for all four sides of the rod. The data were recorded [

]. To eliminate noise in the eddy current signal, the measured data are smoothed with an 11-point moving average. This gives a moving average over [

] the fuel rod.

5 BAW-2424NP

Framatome ANP Table 4 summarizes the measured oxide thicknesses as well as the 11-point moving averages for each of the 6 fuel rods. The 11-point moving average oxide thickness values are used in the evaluation. For the M5 fuel rods, which have bumups of 42 to 48 GWd/MTU, the peak oxide thickness ranges from [

]. The Zircaloy-4 fuel rods have bumups of 46 to 48 GWd/MTU and peak oxide thicknesses from [

]. The peak oxide thickness for the M5 fuel rods is approximately [

] of that for the Zircaloy-4 fuel rods.

The fuel rod oxide thickness is plotted as a function of fuel rod bumup in Figure 6. The fuel rod oxide data are compared against the data for other U.S. plants. Figure 6 shows the fuel rod oxide thickness for M5 cladding at North Anna-I and TMI-1 compared to the Zircaloy-4 oxide thickness trendline.

3.4 Fuel Rod Diameter Fuel rod diameters were measured concurrently with fuel rod oxide thicknesses, so although Table 1 specifies only two diameter profiles per fuel rod, four were usually recorded. The one exception is rod 007, for which the south profile was not recorded.

Figure 7 shows typical diameter profiles for two fuel rods, one with each type of cladding. The positions are specified as the elevation in inches above the top of the lower end plug. The profiles have generally similar shapes. The increase in diameter at the ends of the rods suggests that the cladding has crept down onto the fuel pellets over most of the active length of the rods but that there is still a diametral gap near the ends.

Table 5 lists the maximum, minimum, and average fuel rod diameter for each of the profiles. Since the maxima are significantly affected by the diameters near the ends of the scans, a second set of minima, maxima, and averages is also reported. The second set is for the central portion of the active length, which was taken as the section from

[

] above the lower end plug. [

]. The diameters reported in Table 5 need to be corrected for the effects of oxidation. The average oxide thicknesses for rods with M5 and Zircaloy-4 cladding are [

], respectively, per Table 4. An oxidized diameter of do, corresponds to an unoxidized diameter d,,, of d

=d, - 2z(I1-4 I where z is the oxide thickness and R is the Pilling-Bedworth ratio. For R = 1.6, the unoxidized diameters for rods with M5 and Zircaloy-4 cladding are [

], respectively. [

].

6 BAW-2424NP

BAW-2424NP Framatome ANP 3.5 Conclusions Fuel assembly NJ07VX, with four M5 test rods successfully operated for three 24-month cycles in TMI-I.

At the end of cycle 13, all measured fuel rod oxide thicknesses are within the design models and no unexpected trends have been observed. The M5 fuel rod oxide thickness is very small in comparison with that for Zircaloy-4. For the M5 fuel rods, which have bumups of 42 to 48 GWd/MTU, the peak oxide thickness ranges from [

]. The Zircaloy-4 fuel rods have bumups of 46 to 48 GWd/MTU and peak oxide thicknesses from

] ]. The peak oxide thickness for the M5 fuel rods is approximately [

] of that for the Zircaloy-4 fuel rods.

The fuel assembly growth results show that the growth is linearly related to fuel rod bumup. The M5 test assemblies fuel growth are enveloped by'the Mark-B UTL.

The maximum fuel rod growth for the M5 fuel rods is smaller than that for Zircaloy-4 rods. The fuel rod growth at -50 GWd/MTU for M5 rods is [

] than for Zircaloy-4 rods. The results are enveloped by the UTL of M5 fuel rod growth.

The M5 fuel rods still have significant margin for a fourth cycle of operation and for the extended bumup of -69 GWd/MTU projected at the end of cycle 14. The host assembly, NJ07U9, can safely accept the M5 fuel rods for another cycle of operation to an estimated end of cycle 14 assembly bumup of 54.793 GWd/MTU.

7

BAW-2424NP IinunrA tl Core Locations of Selected Fuel.Assemblies for TMI-1 Cycles 11 to 14 7VX 13 50.0 I~

I I

I-I-- ---

4-+-

-t-t-i I

I I

East North Cycle South

[R B 2

3 4

5 6

7 8

9 10 11 12 13 14 15 8

Framatome ANP 4-North 7U9 11 A-,-- r I eLf.U I

i i

I

-i i

i i

0 I.s I-C (D

0 LL z

C 7U9-14

-69 (VA

, 'J

12 37.1

[VA 12 47.4 (VA f VA 11 22.8

= =,',-f*,

• BAW-2424NP Framatome ANP Fi-gure 2. Location of M5 Fuel Rods in Assembly NJ07VX 15 14 13 Z-2 M5-2 12 11 10 9 8

F M5-3 Z-3 7

6 5

4 3

2 1

-4-PP1TT I

__I.

liii Z-1 M5.1 Figure 3. Fuel Assembly Growth

• Mark-B Zirc-4 UTL

I NJ07VX Test Assy:

......o...

I I

I 0

0.5 1

1.5 Fuel Rod BWnup (GWdlmtU) 9 aI)

II 0

LL I

0 LL

(

o Z

[M54 Z-4 S

ZR 1.2 1

0.8 0.6 0.4 0.2 0

1 1

1

BAW-2424NP Framatome ANP Figure 4. Fuel Assembly Shoulder Gap Closure 0

0.2 0.4 0.6 0.8 Fuel Rod Bumup (GWd/mtU)

Mark-B UTL A

M5 (NJ07VX) e M5 (NJ07U9) x Zirc-4 (NJ07VX) c Zirc-4 (NJ07U9) 1 1.2 Figure 5. Fuel Rod Growth M5 FR Growth UTL

• M5 (NJ07VX)

• M5 (NJ07U9)

Ac Zirc-4 (NJ07V)g ZIrc-4 (NJ07U9g) 0.5 1

Fuel Rod Bumup (Gwd/mtU) 1.5 P

0 C

1..

_o

0.

CO 32 U) 1.2 1

0.8 0.6 0.4 0.2 0

1.2 1.0 0.8

• 20 CD 0.6 S0.4

"-. 0.2 0.0 0

10

Framatome ANP Fi=ure 6. Fuel Rod Oxide Thickness M5 and Zircaloy-4 Fuel Rods S40 C35 30 0

"25 20 x

0 5

0-10000 20000 30000 40000 50000 Fuel Rod Bumup (MWd/mtU)..

Figure 7. Typical Fuel Rod Diameter Profiles I-to E

AS 0

0.8 R.6 0.4 0.2 0

20.

40 60 80 100 Elevation Above End Plug (inches) 11 BAW-2424NP 600

-MS (GO1-W) 120 140 1/11ý 120 140

BAW-2424NP Framatome ANP Table 1.

Summary of Fuel Inspections Fuel Assembly ID NJO ---

7U9 7VX Cumulative Assembly Bumup at EOC 13 (GWd/mtU) 33.87 38.14 Core Location During Cycle 13 A-06 Design B10 B10 Number of Cycles in Operation 2

3 Examination Frequency

1. of FAs Fuel Assembly Length 2

X X

Shoulder Gaps 4 faces, 2 rods per face 2

X X

Fuel Rod Oxide (M5) 4 rods, 4 orientations I

X Fuel Rod Oxide (Zircaloy) 2 rods, 4 orientations I

X Fuel Rod Diameter (M5) 4 rods, 2 orientations I

X Fuel Rod Diameter (Zircaloy) 2 rods, 2 orientations 1

X Notes:

• • Out of core Table 2.

Fuel AssemnblyLenth and Irradiation Growth Fuel Rod Fuel End of Peak Growth

% Growth Assembly Design Cycle Bumup A/ (in)

(AL/') x 100 ID MWdIMTU M5 Test 11 22759 NJ07VX Assy 12 47425 Mark-B10 13 49978 NJ07U9 Mark-B10 12 37053 12 Table 2.

Fuel Assembly Length and Irradiation Growth I

BAW-2424NP Framatome ANP Table 3.

Fuel Rod Irradiation Growth and Shoulder Gap Design M5 Test Assy Mark-BIO As Factory Built Mark-B1 0 Reconstituted Mark-B1 0 End of Cycle 11 12 13 12 BOC 14 Fuel Rod Bumup MWd/MTU

'V)7O 22759 Fuel Clad Material Minimum Shoulder Gap (in).

Shoulder Gap Maximum Closure (in)

% Fuel Rod Growth Average Maximum Growth Growth (AL4)xl10 (A) x t00 I

4-I I

47425LI rc-44 49978 M5 I

_____ L'r-4' 37053 Zirc-4 1_

_L_

I 48800 M5 esmate)

Table 4.

Fuel Rod Oxide Thickness 11-Point Moving A' Min Oxide Max Oxide verage Measured Data Average Min Oxide Max Oxide A

Oxide All M5 rods All Zircaloy-4 rods verage Oxide 13 Fuel Ass'y ID NJ07VX NJ07U9 NJ07U9 rI "Fuel Rod 0-07 1-15 A-09 G-01 H-15 A-08 Rod No.

M5-1 M5-2 M5-3 M5-4 Z-2 Z-3 Bumup MWdIMTU 43464 46050 48218 42257 46260 47744 Face E

W N

S E

W N

S E

W N

S E

W N

S E

W N

S E

W N

S L Measured Data 414/..O

/...I I *"'P 7;,.,*_A 4

BAW-2424NP Framatome ANP Table 5.

Summary of Fuel Rod Diameters 14 111,1ý Rod Diameter (inches)

Alloy Rod Side Max.

Min.

Avg.

Max.

Min.

Av M5 A09 N

M5 A09 E

M5 A09 S

M5 A09 W

M5 G01 N

M5 G01 E

M5 G01 S

M5 G01 W

I M5 115 N

M5 115 E

M5 115 S

M5 115 W

M5 007 N

M5 007 E

M5 007 W

5 1All M5 rods Zry-4 A08 N

Zry-4 A08 E

Zry-4 A08 S

Zry-4 A08 W

Zry-4 H15 N

Zry-4 H15 E

Zry-4 H15 S

Zry-4 H15 W

All Zircaloy4 rods

Framatome ANP

4. References

1. NRC Letter 50-289, "TMI-1 Application and SER for M5 Fuel Rod Irradiation Beyond Current Burnup Limit," May 18, 2001, (38-1288511-00)

2. AmerGen Letter # 5928-01-20108 to NRC, "TMI-1 Additional Information - Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Bumup Limit," April 11, 2001, (38 1288735-00) 15 BAW-2424NP

ENCLOSURE 3 Framatome ANP Affidavit Certifying Request for Withholding From Public Disclosure

AFFIDAVIT COMMONWEALTH OF VIRGINIA

)

) ss.

CITY OF LYNCHBURG

)

1.

My name is James F. Mallay. I am Director, Regulatory Affairs, for Framatome ANP ("FRA-ANP"), and as such I am authorized to execute this Affidavit.

2.

I am familiar with the criteria applied by FRA-ANP to determine whether certain FRA-ANP information is proprietary. I am familiar with the policies established by FRA-ANP to ensure the proper application of these criteria.

3.

i am familiar with the FRA-ANP information contained in BAW-2424P, "Proposed Irradiation of Fuel Rods Beyond Current Limit in Three Mile Island 1 Cycle 13 PIE,"

April 2002, and referred to herein as "Document." This report describes the post-irradiation examination of certain test assemblies conducted in October 2001. Information contained in this Document has been classified by FRA-ANP as proprietary in accordance with the policies established by FRA-ANP for the control and protection of proprietary and confidential information.

4.

This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by FRA-ANP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5.

This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in the Document be withheld from public disclosure.

6.

The following criteria are customarily applied by FRA-ANP to determine whether information should be classified as proprietary:

(a)

The information reveals details of FRA-ANP's research and development plans and programs or their results.

(b)

Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c)

The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for FRA-ANP.

(d)

The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for FRA-ANP in product optimization or marketability.

(e)

The information is vital to a competitive advantage held by FRA-ANP, would be helpful to competitors to FRA-ANP, and would likely cause substantial harm to the competitive position of FRA-ANP.

7.

In accordance with FRA-ANP's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside FRA-ANP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8.

FRA-ANP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9.

The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this day of a_,,

72002.

Ella F. Carr-Payne NOTARY PUBLIC, STATE OF VIRGINIA MY COMMISSION EXPIRES: 8/31/05 ELLA F. CARR-PAYNE I Notary Public Commonwealth of Virginia My Commission Exps. Aug. 31,2005 I

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