ML080650101

Response to Round 16 Request for Additional Information SRXB-73

ML080650101
Person / Time
Site:	Browns Ferry
Issue date:	02/21/2008
From:	Langley D Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD5262, TVA-BFN-TS-431
Download: ML080650101 (10)

Text

Tennessee Valley Authority, Post Office Box 2000, Decatur, Aabama 35609-2000 February 21, 2008 TVA-BFN-TS-431 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop OWFN, Pl-35 Washington, D. C. 20555-0001 Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee-ValleyAuthority BROWNS FERRY NUCLEAR PLANT (BFN) - UNIT 1 - TECHNICAL SPECIFICATIONS (TS) CHANGE TS-431 - EXTENDED POWER UPRATE (EPU) - RESPONSE TO ROUND 16 REQUEST FOR ADDITIONAL INFORMATION (RAI) - SRXB-73 (TAC NOS. MD5262)

By a letter dated June 28, 2004 (ADAMS Accession No. ML041840109), TVA submitted a license amendment application to the NRC for the EPU operation of BFN Unit 1. The proposed amendment would change the Unit 1 operating license to increase the maximum authorized core thermal power level of Unit 1 by approximately 14 percent to 3952 megawatts.

On February 6, 2008 (ML080370225) the NRC staff issued a Round:16PRAI regarding the Unit 1 EPU license amendment request. Enclosure 1 to this letter provides TVA's response to the Round 16 RAI question SRXB-73. The remaining Round 16 RAI questions will be answered by March 6, 2008, with the exception of RAI EMEB-167/134, which is a steam dryer question that will be answered by March 31, 2008 in the RAI Round 15 Group 3 steam dryer response.

Note that Enclosure 1 is a proprietary response to the RAI and contains information that Global Nuclear Fuel-Americas Dcx)ýc)

U.S. Nuclear Regulatory Commission Page 2.

February 21, 2008 (GNF-A) 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), GNF-A requests that such information be withheld from public disclosure. Enclosure 2 is a redacted version of Enclosure 1 with the proprietary material removed and is suitable for public disclosure. Enclosure 3 contains an affidavit from GNF-A 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)ý.

No new regulatory commitments are made in this submittal...

If you have any questions regarding this letter, please contact me at (256)729-7658.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 2 1 st day of February, 2008.

Sincerely D. T. Langley, Manager of Licensing and Industry Affairs

Enclosures:

1. Response to Round 16 Request for Additional Information SRXB-73 (Proprietary Information Version)

2. Response to Round 16 Request for Additional Information SRXB-73 (Non-proprietary Information Version)

3. GNF-A Affidavit

U.S. Nuclear Regulatory Commission Page 3 February 21, 2008 Enclosures cc (Enclosures):

State Health Officer Alabama State Department of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017 NRC Senior Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970 Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 Eva 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)

UNIT 1 TECHNICAL SPECIFICATIONS (TS) CHANGE TS-431 EXTENDED POWER UPRATE (EPU)

RESPONSE TO ROUND 16 REQUEST FOR ADDITIONAL INFORMATION SRXB-73 (NON-PROPRIETARY INFORMATION VERSION)

This enclosure provides TVA's response to. NRC's February 6, 2008, Round 16 Request for Additional Information (RAI) question SRXB-73.

E2-1

NON-PROPRIETARY INFORMATION NRC RAI SRXB-73 (Unit 1 only)

The NRC is looking for TVA to demonstrate that the operating experience with reactors near equilibrium operation is directly applicable to the Cycle 8 Unit 1 core design. To address this concern regarding the applicability of the design basis eigenvalue, the licensee provided plant specific Cycle 7 (restart core) operating data for the initial startup and one mid-cycle cold critical measurement. Additional information is still needed to evaluate the performance of the design basis eigenvalue determination process with an absence of plant specific operational data.

To assist the evaluation of the methods uncertainties regarding the determination of the eigenvalue, provide any additional data for hot operating conditions and design targets. Specifically, for Cycle 7, provide a comparison of the plant operating critical eigenvalues to the hot critical design bases. Also, provide the results of any low power hot statepoints with high control blade densities.

TVA Response to SRXB-73 (Unit 1 only)

The below table provides additional hot eigenvalue data for selected low power hot statepoints for BFN Unit 1 Cycle 7.

Control rod density is also provided in the table. A review of the Unit 1 low power operating history indicated there were no steady state, equilibrium xenon points available. However, the data points shown below are for cases where the reactor was near the indicated power level for a period of at least thirty six hours and as such are reasonable representations of the expected hot eigenvalues at reduced powers.

Cycle Power Level Control Rod Density Hot Eigenvalue Exposure (% of rated) (% of available rods (MWd/ST)

• inserted) 30 40.5 16.4 1.0099 53 53.6 12.6 1.0085 1589 52.6 11.4 1.0070 2626 23.7 27.9 1.0054 Megawatt-days/short ton (MWd/ST)

The actual hot eigenvalues observed to date for BFN Unit 1 Cycle 7, along with the original design hot eigenvalue basis arid the revised hot eigenvalue basis, are provided in the following figure. Also shown in the figure is hot eigenvalue data from several typical reload cycles which utilized General Electric E2-2

NON-PROPRIETARY INFORMATION (GE) fuel. The original design hot eigenvalue basis, which had been selected based on ((

], was revised after actual operating data was attained early in Cycle 7. As is evident from the figure, the BFN Unit 1 Cycle 7 core has trended favorably against the revised hot eigenvalue basis curve and the Cycle 7 hot eigenvalue behavior is more characteristic of a typical reload core than of the initial core basis that was originally selected. Since the core design and fresh fuel designs for BFN Unit 1 Cycle 8 are typical of GE fuel reload cores, the eigenvalue behavior in Cycle 8 is expected to continue to be characteristic of typical reload core behavior. Therefore, selecting the Cycle 8 eigenvalues based on reload core performance is an appropriate assumption.

((

E2-3

ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNIT 1 TECHNICAL SPECIFICATIONS (TS) CHANGE TS-431 EXTENDED POWER UPRATE (EPU)

RESPONSE TO ROUND 16 REQUEST FOR ADDITIONAL INFORMATION SRXB-73 AFFIDAVIT This enclosure provides GNF-A's affidavit for Enclosure 1.

Global Nuclear Fuel - Americas AFFIDAVIT I, Anthony P. Reese, state as follows:

(1) I am Reload Licensing Manager, Fuel Engineering, Global Nuclear Fuel-Americas, LLC ("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, "NRC Requests for Additional Information (RAI) for Browns Ferry 1 Cycle 8 Shut Down Margin Designs RAI 73" dated February 2008. GNF proprietary information is identified by a dotted underline inside double square brackets. ((lwhs.senten.ce is.an ex..ape. .)) 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" (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 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 aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

-Affidavit Page 1 of 3

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 GNF-A, 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 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. 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, 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.

Affidavit Page 2 of 3

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information 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 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.

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 on this 7 th day of February 2008.

onyy P. Reese Reload Licensing Manager, Fuel Engineering Global Nuclear Fuel - Americas, LLC Affidavit Page 3 of 3