ML063480063
| ML063480063 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/11/2006 |
| From: | Crouch W Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC3743, TAC MC3744, TAC MC3812, TS-418, TS-431, TVA-BFN-418, TVA-BFN-431 | |
| Download: ML063480063 (21) | |
Text
Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 December 11, 2006 TVA-BFN-TS-431 TVA-BFN-TS-418 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop OWFN, P1-35 Washington, D. C. 20555-0001 Gentlemen:
In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -
TECHNICAL SPECIFICATIONS (TS) CHANGES TS-431 AND TS-418 -
EXTENDED POWER UPRATE (EPU) - RESPONSE TO ROUND 11 - REQUEST FOR ADDITIONAL INFORMATION (RAI) - ADDITIONAL SBWB RAIs (TAC NOS. MC3812, MC3743, AND MC3744)
This letter is in response to an NRC email RAI regarding loss-of-coolant accident (LOCA) analyses performed in support of TVA's Extended Power Uprate (EPU) license amendment requests. For tracking purposes, TVA is referring to this RAI as Round 11. The Unit 1 and Units 2/3 EPU amendment requests were originally submitted on June 28, 2004 (ADAMS Accession No. ML041840109) and on June 25, 2004 (ML041840301), respectively.
The subject email RAI was received on November 27, 2006, and provided three additional SBWB RAI questions on LOCA methods and results; SBWB 54/79, SBWB 55/80, and SBWB 56/81. The RAIs also pertain to TVA's November 7, 2006, submittal (ML063110435), which provided revised EPU peak clad
U.S. Nuclear Regulatory Commission Page 2 December 11, 2006 temperatures for GE13 fuel as updated to account for a recent General Electric (GE) report on sensitivity to the assumed axial power shape (top-peaked versus mid-peaked) for small break LOCA cases. BFN Unit 1 will restart in Spring 2007 with a core of GE13 and GE14 fuel. The current Unit 2 core also includes GE13 fuel although all GEl3 fuel will be discharged during the upcoming Spring 2007 Unit 2 refuel outage. Unit 3 contains no GE13 fuel. provides a proprietary response to SBWB 55/79, SBWB 56/80, and SBWB 57/81 and contains information that GE Company considers to be proprietary in nature and subsequently, pursuant to 10 CFR 9.17(a) (4), 2.390(a) (4) and 2.390(d) (1), GE requests that such information be withheld from public disclosure. Enclosure 2 is a redacted version of with the proprietary material removed and is suitable for public disclosure. Enclosure 3 contains an affidavit from GE supporting this request for withholding from public disclosure.
TVA has determined that the additional information provided by this letter does not affect the no significant hazards considerations associated with the proposed TS changes. The proposed TS changes still qualify for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c) (9).
No new regulatory commitments have been made in this submittal. If you have any questions regarding this letter, please contact me at (256)729-2636.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 1ith day of December, 2006.
Sincerely, William D. Crouch Manager of Licensing and Industry Affairs
U.S. Nuclear Regulatory Commission Page 3 December 11, 2006
Enclosures:
- 1. Response to Round 11 Request for Additional Information
- (Proprietary Information Version)
- 2. Response to Round 11 Request for Additional Information
- (Non-Proprietary Information Version)
State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-3415 NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 NRC Unit 1 Restart Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611-6970 Margaret Chernoff, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Eva A. Brown, Project Manager U.S. Nuclear Regulatory Commission (MS 08G9)
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739
Non-Proprietary Information ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, and 3 TECHNICAL SPECIFICATIONS (TS) CHANGES TS-431 AND TS-418 EXTENDED POWER UPRATE (EPU)
RESPONSE TO ROUND 11 REQUEST FOR ADDITIONAL INFORMATION (NON-PROPRIETARY INFORMATION VERSION)
This enclosure provides TVA's response to a November 27, 2006, NRC email Request for Additional Information (RAI). TVA is referring to the email RAI as Round 11 for tracking purposes.
Non-Proprietary Information Page 1 of 13 NRC RAI SBWB-54/79 In a letter dated November 7, 2006, TVA provided a revision to the estimated peak clad temperature (PCT) for GE 13 fuel. Explain why the PCT decreases for the GE 13 fuel at the higher power level.
GE Response
((
)) The GE13 results are provide in Table SBWB-54/79-1 below and discussed as follows.
Prior to the evaluation of the top-peaked power shape on small breaks, the licensing basis PCT for GE13 fuel was 1810'F at 3458 MWt and 1780'F at 3952 MWt and were based on the Design Basis Accident (DBA) break. ((
((
)) Therefore, the impact of the top-peaked power shape for GE13 was rounded up and reported as +25'F at 3952 MWt.
((
E2-1
Non-Proprietary Information Page 2 of 13 Table SBWB-54/79-1 GE13 PCT Impact Summary Results at Results at 3458 MWt 3952 MWt Original Licensing Basis PCT 1810-F 1780°F Top-peaked adjusted licensing PCT 1845 0 F 1805°F E2-2
Non-Proprietary Information Page 3 of 13 NRC RAI SBWB-55/80 Identify the limiting break sizes for each of the PCTs presented in the November 7, 2006 Table and explain the impact of the use of the more limiting top peaked axial power shape on PCT for both the limiting large and small breaks.
GE Response Table SBWB-55/80-1 below shows the Licensing Basis PCTs for GEl3 and GE14 at 3458 MWt and for 3952 MWt, which were provided in the November 7, 2006 submittal, including the location and size of the limiting break in the recirculation line. The November 7, 2006, 10 CFR 50.46 Report incorporates the effect of the top-peaked axial power shape on the small breaks.
Figure SBWB-55/80-1 shows the effect of axial power shape on the Appendix K PCT for GE14 fuel at 3952 MWt for the limiting large break (DBA recirculation suction line break) with battery failure. ((
The limiting small break for GE14 is the 0.06 ft2 break in the recirculation discharge line with battery failure. ((
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Non-Proprietary Information Page 4 of 13
)) Figure SBWB-55/80-5 shows the effect of axial power shape on the Appendix K PCT for GE14 fuel at 3952 MWt for the limiting small break. Figure SBWB-55/80-6 shows the vapor upflow from the hot bundle to the upper plenum.
((I
((I E2-4
Non-Proprietary Information Page 5 of 13 Table SBWB-55/80-1 Core Power 3458 MWt 3952 MWt Fuel Type GE13 GE14 GE13 f GE14 Licensing Basis PCT Prior to Top-Peaked Considerations PCT 1810OF 1760°F 1780°F 1830°F Location Suction Suction Suction Discharge Size DBA DBA DBA 0.06 ft" Licensing Basis PCT After Top-Peaked Considerations PCT 1845 0 F 1760OF 1805°F 1830°F Location Discharge Suction Discharge Discharge Size 0.07 ft2 DBA 0.06 ft2 0.06 ft2 E2-5
Non-Proprietary Information Page 6 of 13 Figure SBWB-55/80-1. Peak Cladding Temperature for the DBA Break with Battery Failure (GE14 at 3952 MWt)
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Non-Proprietary Information Page 7 of 13 Figure SBWB-55/80-2. Nodal Peak Cladding Temperatures with Mid-Peaked Shape for the DBA Break with Battery Failure (GE14 at 3952 MWt)
E2-7
Non-Proprietary Information Page 8 of 13 Figure SBWB-55/80-3. Nodal Peak Cladding Temperatures with Top-Peaked Shape for the DBA Break with Battery Failure (GE14 at 3952 MWt)
E2-8
Non-Proprietary Information Page 9 of 13 1))
Figure SBWB-55/80-4. Vapor Upflow Between Hot Bundle and Upper Plenum for the DBA Break with Battery Failure (GE14 at 3952 MWt)
E2-9
Non-Proprietary Information Page 10 of 13 Figure SBWB-55/80-5. Peak Cladding Temperature for the 0.06 ft 2 Break with Battery Failure (GE14 at 3952 MWt)
E2-10
Non-Proprietary Information Page 11 of 13
((I Figure SBWB-55/80-6. Vapor Upflow Between Hot Bundle and Upper Plenum for the 0.06 ft 2 Break with Battery Failure (GE14 at 3952 MWt)
E2-11
Non-Proprietary Information Page 12 of 13 NRC RAI SBWB-56/81 Provide a comparison of the mid-peaked and top peaked axial power profiles used in the corrected limiting large and small breaks.
GE Response The axial power shapes provided are not dependent on the break size and location, but the axial power shape for the hot bundle depends on the fuel type and the power/flow conditions. Figure SBWB-56/81-1 shows the axial power shapes in the hot bundle as a function of the distance above the bottom of the core. The hot bundle shapes are based on GE 14 fuel with the plant operating at rated EPU power (3952 MWt) and flow. The hot bundles for the mid- and top-peaked shapes have the same peak linear heat generation rate and initial critical power ratio (ICPR). However, the axial peak-to-average ratio is different for the two shapes because the bundle power is different for the same ICPR.
E2-12
Non-Proprietary Information Page 13 of 13
((a Figure SBWB-56/81-1. Axial Power Shapes in the Hot and Average Bundles 11 E2-13
ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, and 3 TECHNICAL SPECIFICATIONS (TS) CHANGES TS-431 AND TS-418 EXTENDED POWER UPRATE (EPU)
RESPONSE TO ROUND 11 REQUEST FOR ADDITIONAL INFORMATION GE AFFIDAVIT FOR ENCLOSURE 1
General Electric Company AFFIDAVIT I, George B. Stramback, state as follows:
(1) I am Manager, Regulatory Services, General Electric Company ("GE") 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 Enclosure 1 to GE letter GE-ER1-AEP-06-354, Larry King to J. Valente (TVA), GE Responses to NRC Request for Additional Information - SBWB-54/7, 55/80 and 56/81, dated December 5, 2006.
The Enclosure 1 (GE Responses to NRC Request for Additional Information -
SBWB-54/7, 55/80 and 56/81) proprietary information is delineated by a double 3 underline inside double square brackets. In each case, the superscript notation{ )
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, GE 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" (Exemption 4). The material for which exemption from disclosure is here sought 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 Regulatory 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 General Electric's competitors without license from General Electric 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 aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric; GBS-06-06-af TVA GE-ER1-AEP-06-354 SAFER-GESTR EPU RAI Responses 12-5-06.doc Affidavit Page I
- d. 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 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 GE, 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 GE, 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. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(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. Access to such documents within GE 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 GE 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), above, is classified as proprietary because it contains detailed information about the results of SAFER-GESTR analytical models, methods and processes, including computer codes, which GE has developed, obtained NRC approval of, and applied to perform evaluations of loss-of-coolant accident events in the GE Boiling Water Reactor ("BWR").
The development and approval of the BWR loss-of-coolant accident analysis computer codes was achieved at a significant cost to GE, on the order of several million dollars.
The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.
GBS-06-06-af TVA GE-ER1-AEP-06-354 SAFER-GESTR EPU RAI Responses 12-5-06.doc Affidavit Page 2
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE'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 GE.
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.
GE's competitive advantage will be lost if its competitors are able to use the results of the GE 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 GE 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 GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing 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.
I:,xecuted on this _______ day of ýGtar4a 2006.
Genter .E. StrCm panck Gen~eral Electric Company GBS-06-06-af TVA GE-ER1-AEP-06-354 SAFER-GESTR EPU RAI Responses 12-5-06.doc Affidavit Page 3