ML071100453

Westinghouse Application for Withholding, Affidavit, and Non-Proprietary Version of Attachment 2 (Attachment 3)

ML071100453
Person / Time
Site:	Quad Cities
Issue date:	04/04/2007
From:	Maurer B Westinghouse
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAW-07-2264 NF-BEX-07-49 NP
Download: ML071100453 (22)

Text

ATTACHMENT 3 Westinghouse Application for Withholding, Affidavit, and Non-Proprietary Version of Attachment 2

Westinghouse Enclosures cc : Jon Thompson (NRC)

APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM. PUBLIC DISCLOSURE Very truly yours, Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-07-2264 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Subject : Recommended Responses to NRC Requests for Additional Information Regarding the QC 1 C20 SLMCPR" (Proprietary)

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-07-2264, and should be addressed to B. F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

B. f. Maurer, Acting Manager Regulatory Compliance and Plant Licensing U.S. Nuclear Regulatory Commission Direct tel : (412) 374-4419 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: maurerbf@westinghouse.com Proi. Ltr. Ref.: NF-BEX-07-49 P-Attachment, Revision 1 Our ref: CAW-07-2264 April 4, 2007

COMMONWEALTH OF PENNSYLVANIA :

COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared B. F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief.

Notary Public NW FPDW@W N NQWW 8*W Sharon L Ma ft Notwy Pubic Mmwv& Soro, Akgharty Cwty My Conmission EVinw Jan. 29, 2011 Member, Pennsylvania Association of Noterfet AFFIDAVIT ss CAW-07-2264 B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing

(2)

I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse "Application for Withholding" accompanying this Affidavit.

I am Acting Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4)

Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

2 CAW-07-2264 The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii)

The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows :

(a)

The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

3 CAW-07-2264 (b)

It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c)

Its use 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 a similar product.

(d)

It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e)

It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f)

It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following :

(a)

The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b)

It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c)

Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d)

Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

4 CAW-07-2264 (e)

Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv)

The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v)

The proprietary information sought to be withheld in this submittal is that which is appropriately marked "Recommended Responses to NRC Requests for Additional Information Regarding the QC IC20 SLMCPR" (Proprietary), dated Apri14, 2007, being transmitted by Exelon Nuclear letter and Application for Withholding Proprietary Information from Public Disclosure to the Document Control Desk. The proprietary information as submitted by Westinghouse Electric Company for the Quad Cities Unit 1 Cycle 20 and is in response to NRC's request for additional information.

This information is part of that which will enable Westinghouse to :

(a)

Support Exelon's use of Westinghouse fuel at Quad City and Dresden.

(b)

Assist customer to obtain license change.

Further this information has substantial commercial value as follows :

(a)

Westinghouse can use this fuel design with its associated correlation to further enhance their licensing position over their competitors.

5 CAW-07-2264 (b)

The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar fuel design and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Westinghouse Non-Proprietary Class 3 NF-BEX-07-49 NP-Attachment Revision 1 Recommended Responses to NRC Requests for Additional Information Regarding the QC1 C20 SLMCPR (Non-Proprietary)

Westinghouse Electric Company Nuclear Fuel 4350 Northern Pike Monroeville, PA 15146 2007 Westinghouse Electric Company LLC, All Rights Reserved

Westinghouse Non-Proprietary Class 3 NF-BEX-07-49 NP-Attachment Revision 1 Recommended Responses to NRC Requests for Additional Information Regarding the QC1 C20 SLMCPR NRC Question 1 Describe how the minimum critical power ratio safety limit (SLMCPR) analysis is conducted for legacy fuel. Discuss the burnup characteristics of modeled fuel type QAG4.

Response to NRC Question 1 Consistent with the Westinghouse methodology described in Reference 1, the treatment of the SLMCPR in mixed cores containing non-Westinghouse fuel [

]a,c The Cycle 19 SLMCPR was determined by GNF based on plant-and cycle-specific analyses using GNF's NRC-approved methodology and uncertainties as supplemented with QC 1-specific uncertainties. As discussed in the response to NRC Question 3, the GNF evaluation confirmed that the DLO and SLO SLMCPRs of 1.10 and 1.11, respectively, bounded the calculated Cycle 19 results and, therefore, continued to be appropriate for Cycle 19.

l a,c With regard to the burnup characteristics of the QAG4 fuel, the QC IC20 core contains 5 GE 14 assembly types and 3 SVEA-96 Optima2 assembly types, where the phrase "assembly type" refers to a unique nuclear design. The eight assembly types are as follows :

Page 1 of 13

NF-BEX-07-49 NP-Attachment Revision 1 Prior to Cycle 20, core follow calculations are performed using the Westinghouse 3-D core simulator, POLCA7. The core power and burnup distributions are determined using POLCA7 core models that explicitly model each assembly type's nuclear and thermal-hydraulic characteristics.

Similarly, for Cycle 20 SLMCPR calculations, the bunup and power distributions at each Cycle 20 statepoint are determined using a POLCA7 Cycle 20 Reference Core model that explicitly models each assembly type's nuclear and thermal-hydraulic characteristics.

Therefore, the burnup and power distributions upon which the Cycle 20 SLMCPR calculations are based are calculated with nuclear models describing the actual GE 14/SVEA-96 Optimal mixed cores.

For the Cycle 20 SLMCPR calculation, the actual mixed core power distribution is retained at each statepoint. However, in accordance with Reference 1, the SLMCPR is calculated [

NRC Question 2 n,c Fuel vendor documentation identifies a subset of legacy fuel, loaded in potentially limiting positions in the core, that was loaded in cycle 18A. Compare predicted exposures of fuel loaded in cycles 18, 18A, and 19 at the start of QC 1820.

Page 2 of 13 Assembly Design Assembly Designation Cycle Loaded Number in Cycle 20 GE14 2564 18 128 GE14 2565 18 104 GE14 2647 18A 36 GE14 2825 19 128 GE14 2826 19 68 SVEA-96 optima QA20 20 56 SVEA-96 tima2 QB20 20 136 SVEA-96 tima2 QC20 20 68

Response to NRC Question 2 NF-BEX-07-49 NP-Attachment Revision 1 At the beginning of Cycle 20 (BOC20), for the assemblies in non-peripheral core locations, the bundle-average exposures of the Cycle 18 fuel are projected to be approximately 30 to 36 GWD/MT, compared with approximately 22 to 25 GWD/MT for the Cycle 18A fuel, and approximately 18 to 22 G"/MT for the Cycle 19 fuel.

The Quad Cities Unit 1 Cycle 20 core loading is shown on Figure 1 of NF-BEX-06-281 Rev. 0. As shown, the Cycle 20 core does place twenty GE 14 Cycle 18A fuel assemblies in the interior of the core in potentially limiting positions. However, since these Cycle 18A assemblies had low initial enrichment and have relatively low reactivity and normalized power in Cycle 20, none of the Cycle 18A assemblies are limiting with respect to the determination of the Cycle 20 SLMCPR.

Although it would be expected from the ranges of BOC20 bundle-average exposures that the Cycle 18A fuel would have higher reactivity than the Cycle 18 fuel, the opposite is true. The initial enrichment of the Cycle 18A fuel was only 1.94 w/o U235, compared to approximately 4.1 w/o U235 for the GE14 fuel loaded in Cycle 18 and Cycle 19.

Because of this lower initial enrichment, although the Cycle 18A fuel has lower exposure than the Cycle 18 fuel at BOC20, the Cycle 18A fuel has lower reactivity.

The Cycle 18A fuel was designed with relatively low initial enrichment due to the circumstances regarding Cycle 18 and 18A design and operation. Cycle 18 was originally designed for twenty-four months of operation. However, during Cycle 18, it was determined that the Framatome-ANP ATRIUM-9B bundles that were loaded in Cycle 17 were susceptible to fuel failures. Therefore, Cycle 18 was shut down early after only about seven months of operation, the 233 ATRIUM-9B assemblies from Cycle 17 were discharged, the core was shuffled, and 233 GE14 assemblies were loaded. These Cycle 18A GE 14 fuel assemblies were designed with low initial enrichment in order to mimic the reactivity of the discharged Cycle 17 fuel as much as possible and to provide adequate design reactivity margins and thermal margins in Cycle 18A.

Therefore, although the Cycle 20 core does place some of the Cycle 18A fuel assemblies in potentially limiting positions, the Cycle 18A fuel is not limiting with respect to the determination of the Cycle 20 SLMCPR NRC Question 3 Provide the highest SLMCPR technical specification values for the legacy fuel for Quad Cities Unit 1.

Response to NRC Question 3 To be provided by Exelon.

Page 3 of 13

NRC Question 4 Model assembly type QAG4 using the USAG14 correlation and provide assembly histograms through 10201 EFPH comparing the CPR performance of the QAG4 bundles when modeled using D4.1.1 as compared to USAG14 to show that there is no significant impact of modeling with D4.1.1, which is not explicitly approved to model the lattice geometry contained in fuel assembly QAG4.

Response to NRC Question 4 The requested histograms are shown in Figures 4-1 through 4-6, which facilitate comparison of the relative CPR distribution from the "Licensing Analysis" model [

As shown in the histograms in Figures 4-1 through 4-6, [

NF-BEX-07-49 NP-Attachment Revision 1 a,c Page 4 of 13

NF-BEX-07-49 NP-Attachment Revision 1 ax The relatively low SLMCPR values early in the cycle are a consequence of the substantial contribution of the feed fuel to the SLMCPR even early in the cycle in the mixed core case and the tendency for both the assembly CPRs and relative feed fuel rod CPRs to simultaneously become "flatter" late in the cycle. As discussed in Reference 2, experience has shown that the assembly CPR distributions tend to become [

Ia,c Therefore, our experience indicates that the peak SLMCPR consistently occurs when the assembly CPR and fuel rod CPR distributions combine to place the maximum number of fuel rod CPRs close to the minimum CPR which occurs sufficiently late in the cycle for the feed fuel to establish the SLMCPR and provides bounding SLMCPR values which are applied throughout the cycle.

It is concluded that the simultaneous application of the maximum GE 14 and SVEA-96 Optima2 SLMCPRs established throughout the cycle will protect a mixed core SLMCPR early in the cycle when the once-burned fuel can contribute to the SLMCPR.

Later in the cycle, when the once-burned fuel no longer contributes to the SLMCPR, the Licensing Analysis SLMCPR becomes equal to the SLMCPR established by mixed core CPR distributions.

NF-BEX-07-49 NP-Attachment Revision 1

] ac, it should also be noted that the overall Westinghouse methodology for assuring conservative CPR treatment of non-Westinghouse legacy fuel includes the use of the "conservative adder" required in SE Condition 7 to Reference 1. As described in the response to NRC Request 8 of Reference 3, [

a,c Page 6 of 13

References NF-BEX-07-49 NP-Attachment Revision 1 1.

CENPD-300-P-A, Reference Safety Report for Boiling Water Reactor Reload Fuel, July 1996 2.

Exelon Letter transmitting NF-BEX-06-281, Rev.0, Quad Cities Unit 1 Cycle 20 SLMCPR.

3.

RS-06-009, Additional Information Supporting Request for License Amendment Regarding Transition to Westinghouse Fuel, January 26, 2006.

4.

Letter from NRC (John Honcharik) to EXELON GENERATION COMPANY, LLC, dated November 7, 2006, Dresden Nuclear Power Station, Unit 3-Issuance of Amendment RE: Minimum Critical Power Ration Safety Limit (TAC No.

MD2706)

Page 7 of 13

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NF-BEX-07-49 NP-Attachment Revision 1 Figure 4-5 2,c Page 12 of 13

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