ML072840217

Additional Information in Support of Request for License Amendments Regarding Fuel Design and Storage Requirements for Areva Np Fuel

ML072840217
Person / Time
Site:	Brunswick
Issue date:	09/28/2007
From:	Scarola J Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 07-0102, TAC MD4061, TAC MD4062, TSC-2006-05
Download: ML072840217 (17)

Text

James Scarola Vice President Brunswick Nuclear Plant Progress Energy Carolinas, Inc.SEP 2 8 2007 SERIAL: BSEP 07-0102 10 CFR 50.90 TSC-2006-05 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Additional Information in Support of Request for License Amendments Regarding Fuel Design and Storage Requirements for AREVA NP Fuel (NRC TAC Nos. MD4061 and MD4062)

References:

1. Letter from James Scarola (CP&L) to U.S. Nuclear Regulatory Commission (Serial: BSEP 06-0128), "Request for License Amendments Regarding Fuel Design and Storage Requirements for AREVA NP Fuel," dated January 22, 2007 (ADAMS Accession Number ML070300372)

2. Letter from James Scarola (CP&L) to U.S. Nuclear Regulatory Commission (Serial: BSEP 06-0129), "Request for License Amendments Regarding Linear Heat Generation Rate and Core Operating Limits Report References for AREVA NP Fuel," dated January 22, 2007 (ADAMS Accession Number ML070300570)

Ladies and Gentlemen:

By letter dated January 22, 2007, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., requested a license amendment to revise the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed changes include: (1) revising Technical Specification 4.2.1, "Fuel Assemblies," to modify the fuel design description to encompass AREVA NP fuel assemblies, and (2) revising Technical Specification 4.3, "Fuel Storage," to remove nomenclature specific to Global Nuclear Fuels fuel storage criticality analysis methods.These changes are being made to support receipt and storage of new ATRIUM-10 fuel bundles. A request to allow use of these ATRIiUM-10 fuel bundles for BSEP Units 1 and 2 has been requested separately through Reference 2.From July 31 through August 2, 2007, the NRC performed an audit at the AREVA offices in Richland, Washington.

During the audit, the NRC requested additional information to P.O. Box 10429 Southport, NC 28461 T> 910.457.3698 F > 910.457.2803 Document Control Desk BSEP 07-0102 / Page 2 support the review of the license amendment application regarding the AREVA fuel design description and fuel storage criticality analysis.

Responses to these NRC questions are provided in Enclosure

1. Copies of AREVA Reports ANP-2642(P), Revision 0, Brunswick Nuclear Plant Spent Fuel Storage Pool Criticality Safety Analysis for ATRIUM-]O Fuel, dated September 2007, and ANP-2661(P), Revision 0, Brunswick Nuclear Plant New Fuel Storage Vault Criticality Safety Analysis for ATRIUMJ m-1O Fuel, dated September 2007, are provided in Enclosures 2 and 3, a respectively.

These reports are referenced in the responses provided in Enclosure

1. ANP-2642(P), Revision 0, and ANP-2661(P), Revision 0, contain information that AREVA considers to be proprietary as defined by 10 CFR 2.390. AREVA, as the owner of the proprietary information, has executed affidavits provided in Enclosures 4 and 5, which identify that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.

AREVA requests that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. Non-proprietary versions of ANP-2642(P), Revision 0, and ANP-2661(P), Revision 0, are provided in Enclosures 6 and 7, respectively.

There are no regulatory commitments associated with this submittal.

Please refer any questions regarding this submittal to Mr. Randy C. Ivey, Manager -Support Services, at (910) 457-2447.I declare, under penalty of perjury, that the foregoing is true and correct. Executed on September 28, 2007.Sincerely, James Scarola Document Control Desk BSEP 07-0102 / Page 3 WRM/wrm

Enclosures:

1. Response to Requests for Additional Information

2. AREVA Report ANP-2642(P), Revision 0, Brunswick Nuclear Plant Spent Fuel Storage Pool Criticality Safety Analysis for ATRIUM-JO Fuel, dated September 2007 (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)3. AREVA Report ANP-2661(P), Revision 0, Brunswick Nuclear Plant New Fuel Storage Vault Criticality Safety Analysis for ATRIUMTM-1O Fuel, dated September 2007 (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)4. AREVA Affidavit Regarding Withholding ANP-2642(P), Revision 0, from Public Disclosure

5. AREVA Affidavit Regarding Withholding ANP-2661(P), Revision 0, from Public Disclosure

6. AREVA Report ANP-2642(NP), Revision 0, Brunswick Nuclear Plant Spent Fuel Storage Pool Criticality Safety Analysis for ATRIUM-JO Fuel, dated September 2007 7. AREVA Report ANP-2661(NP), Revision 0, Brunswick Nuclear Plant New Fuel Storage Vault Criticality Safety Analysis for ATR1UMTM-IO Fuel, dated September 2007 Document Control Desk BSEP 07-0102 / Page 4 cc (with all enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Joseph D. Austin, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)ATTN: Mr. Stewart N. Bailey (Mail Stop OWFN 8B1)11555 Rockville Pike Rockville, MD 20852-2738 cc (with Enclosures 1, 4, 5, 6, and 7): Chair -North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221 BSEP 07-0102 Enclosure 1 Page 1 of 5 Response to Requests for Additional Information By letter dated January 22, 2007, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., requested a license amendment to revise the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed changes include: (1) revising Technical Specification 4.2.1, "Fuel Assemblies," to modify the fuel design description to encompass AREVA NP fuel assemblies, and (2) revising Technical Specification 4.3, "Fuel Storage," to remove nomenclature specific to Global Nuclear Fuels (GNF) fuel storage criticality analysis methods. These changes are being made to support receipt and storage of new ATRIUM-10 fuel bundles. A request to allow use of these ATRUJMTM-10 fuel bundles for BSEP Units 1 and 2 has been requested separately through Reference 2.From July 31 through August 2, 2007, the NRC performed an audit at the AREVA offices in Richland, Washington.

During the audit, the NRC requested additional informationto support the review of the license amendment application regarding the AREVA fuel design description and fuel storage criticality analysis.

Responses to these NRC questions are provided below.NRC Request 1 Provide copies of fuel storage criticality safety reports (both new and spent) to NRC.Response Enclosures 2 and 3 provide copies of AREVA Reports ANP-2642(P), Revision 0, Brunswick Nuclear Plant Spent Fuel Storage Pool Criticality Safety Analysis for ATRIUM-JO Fuel, dated September 2007, and ANP-2661(P), Revision 0, Brunswick Nuclear Plant New Fuel Storage Vault Criticality Safety Analysis for ATRIUMrM-1O Fuel, dated September 2007, respectively.

ANP-2642(P), Revision 0, and ANP-2661(P), Revision 0, contain information that AREVA considers to be proprietary as defined by 10 CFR 2.390. AREVA, as the owner of the proprietary information, has executed the affidavits provided in Enclosures 4 and 5, which identify that this proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.

AREVA has requested that this proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. Non-proprietary versions of ANP-2642(P), Revision 0, and ANP-2661(P), Revision 0, are provided in Enclosures 6 and 7, respectively.

NRC Request 2 Address seismic issues for racks with AREVA fuel.

BSEP 07-0102 Enclosure I Page 2 of 5 Response AREVA has determined that the pre-existing seismic analyses addresses the fuel as added mass in evaluating the structural integrity under postulated loads. The existing analyses encompass fuel designs previously used at BSEP with weights ranging from 22 lbs. less to 31 lbs. greater than the weight of the ATRIUM T M-10 fuel design. Therefore, the spent fuel pool and new fuel storage vault remain qualified with the introduction of the ATRIUMT11-10 fuel design.NRC Request 3 Address thermal-hydraulic decay heat removal issues for AREVA fuel in the spent fuel pool.Response Peak decay heat production occurs upon discharge to the spent fuel pool and is a function of fuel assembly power before shutdown.

ATRHJMThl-10 fuel will not increase the limiting spent fuel pool decay heat loads because it will be operated within the same core power'.constraints as current BSEP fuel. ATR1UMTIVT-10 fuel will have no significant impact on existing.

spent fuel pool thermal hydraulic analyses because it has been shown to be thermal., -hydraulically compatible with co-resident GNF fuel in ANP-2646(P), a copy of which was previously provided to NRC by letter dated July 18, 2007, ADAMS Accession Number ML072070305.

Regardless, natural circulation flow through the fuel rack cells is insensitive to the relatively small differences in hydraulic resistance between various fuel designs. CASMO calculations were performed to demonstrate that removal of moderator will decrease reactivity should voiding occur within the fuel. A 10% reduction in fuel moderator density decreases k,, by 0.014; therefore, voiding within the fuel is not a criticality concern.NRC Request 4 Address long-term material degradation (e.g., corrosion) of the AREVA fuel in the spent fuel pool.Response AREVA's ATRIUMTM-10 fuel assembly has a load chain that connects the stainless steel (CF-3) upper and lower tie plates through a stainless steel (304L) connecting bolt and a zircaloy-4 water channel. The fuel pellets are encased in zircaloy-2 fuel rods restrained by zircaloy-4 spacers. These corrosion resistant materials have extensive use in nuclear fuel BSEP 07-0102 Enclosure 1 Page 3 of 5 assemblies and are expected to withstand extended residence times in the pure water and relatively low temperature environment of the spent fuel pool.NRC Request 5 Address interaction of the HBR spent fuel racks with the Brunswick racks.Response Interaction of the BWR and PWR storage racks is addressed in Section 7.4 of Attachment 2 of the Reference I spent fuel storage expansion license amendment request as follows: The minimum separation between the proposed and existing systems will be six inches.The proposed module and the existing storage system have individually been shown to have a neutron multiplication factor lower than the nuclear criticality safety criterion of 0.95. Each system has incorporated neutron absorber materials (stainless steel for the existing; boral and stainless steel for the proposed) in its design. The adjacent faces that the systems present to one another are either stainless steel or stainless steel and boral. In this configuration and with a separation of six inches of water, there is no significant neutron communication between systems. Calculations were made to determine the interaction between the faces of two high density modules, with partially unpoisoned storage locations directly opposite each other.These calculations (described in Section 7.3 and tabulated in Table 7-3) support the conclusion that neutron multiplication factor is insensitive to intermodule water gap.The spacing study referred to above determined decreasing cell spacing from 2.967 inch to 1.244 inch increased k, by only 0.0087 (i.e., less than the calculation uncertainty);

therefore, neutron communication between storage systems incorporating stainless steel or boral poison material and spaced a minimum of six inches apart was concluded to be insignificant.

The ATRIUM T M 1-10 REBOL lattice enrichment of 3.1 weight-percent is comparable to the 3.0 weight-percent BWR enrichment analyzed in Reference 1; therefore, these conclusions remain applicable.

NRC Request 6 Address the mixed array of GE/AREVA fuel in racks at the same time.

BSEP 07-0102 Enclosure 1 Page 4 of 5 Response GE14 and ATRIUMTM-10 lattices have similar fuel rod pitch and water volumes; therefore, the neutron energy spectra associated with a mixed array of these assemblies will be similar.Hence, the most reactive single assembly type array bounds the mixed array condition.

Mixed arrays with BSEP fuel assembly types older than GE14 are bounded by arrays of GE14 or ATRIUMTM-10 because the older fuel assembly types were designed at lower reactivity levels.NRC Request 7 Address low moderation (accident conditions) in the new fuel racks caused by spraying water.Response The BSEP new fuel storage vault has design features and administrative controls in place to preclude optimum moderation conditions.

When storing fuel in the new fuel storage vault, the bottom drain in the new fuel vault is plugged to prevent the possibility of steam or water (i.e., causing partial flooding) backing up from the drain lines, the fog/spray nozzle is removed from the fire stations closest to the new fuel vault, and the new fuel vault shield plugs are installed when construction activities or construction debris that pose the risk of fire are in close proximity.

Therefore, as indicated in 10 CFR 50.68, item b3, and ANSI/ANS-57.3, Design Requirements for New Fuel Storage Facilities at Light Water Reactor Plants, a full optimum moderation evaluation is not required.NRC Request 8 Address Fe, Ni cross section data problem in ENDF/B-IV data.Response Stainless steel is not used in the new fuel storage vault model. In the spent fuel storage pool, the boral BWR storage racks are more limiting than the stainless steel PWR or the stainless steel BWR storage racks. Since the microscopic absorption cross section of boron is substantially larger than the microscopic absorption cross section for iron or nickel, small errors in their cross section values will have a small impact on the limiting array reactivity.

A sensitivity comparison has shown that for the boral BWR storage rack, a 20% change in stainless steel density changes k. less than 0.001.

BSEP 07-0102 Enclosure 1 Page 5 of 5 NRC Request 9 Include the guideline section containing analysis assumptions in the report.Response The criticality analysis reports provided under item 1 now include a full list of the modeling assumptions used.NRC Request 10 Defend the decision to not analyze 90% voids.Response Comparison of in-rack k. values shows only small differences between cases run using 40%and 80% void history, with the 40% cases generally being limiting.

This implies that 90%void history conditions will notidiffer significantly from the cases analyzed.Reference 1. Letter from E. E. Utley to U.S. Nuclear Regulatory Commission, Serial No. NO-81-688, "Request for License Amendment Spent Fuel Pool Storage Expansion," April 16, 1981.2. Letter from James Scarola to the U.S. Nuclear Regulatory Commission (Serial: BSEP 06-0129), "Request for License Amendment Regarding Linear Heat Generation Rate and Core Operating Limits Report References for AREVA NP Fuel," dated January 22, 2007 (ADAMS Accession Number ML070300570)

BSEP 07-0102 Enclosure 4 AREVA Affidavit Regarding Withholding ANP-2642(P), Revision 0, from Public Disclosure AFFIDAVIT STATE OF WASHINGTON

)) ss.COUNTY OF BENTON )1. My name is Jerald S. Holm. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.

I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.3. I am familiar with the AREVA NP information contained in the report ANP-2642(P) Revision 0, Brunswick Nuclear Plant Spent Fuel Storage Pool Criticality Safety Analyses for ATRIUM-10 Fuel, dated September 2007, and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP 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 AREVA NP 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 this Document be withheld from public disclosure.

The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information".

6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 AREVA NP.(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(d) above.7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP 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 C " day of:5--ý--

2007.%, % K.----: ..,-oP.UB I Susan K. McCoy KJ NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/10/2008 BSEP 07-0102 Enclosure 5 AREVA Affidavit Regarding Withholding ANP-2661(P), Revision 0, from Public Disclosure AFFIDAVIT STATE OF WASHINGTON

)) ss.COUNTY OF BENTON )1. My name is Jerald S. Holm. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.

I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.3. I am familiar with the AREVA NP information contained in the report ANP-2661 (P) Revision 0, Brunswick Nuclear Plant New Fuel Storage Vault Criticality Safety Analyses forATRIUM-lO Fuel, dated September 2007, and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP 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 AREVA NP 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 this Document be withheld from public disclosure.

The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information"-

6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 AREVA NP.(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(d) above.7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AIREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP 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.6'ý-'aj/<V SUBSCRIBED before me this f day of--ý ,2ý -,2O007.Susan K. McCoy NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/10/2008