RS-11-176, Supplemental Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit
| ML113070426 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/02/2011 |
| From: | Gullott D Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CAW-11-3293, RS-11-176, TAC ME6383 | |
| Download: ML113070426 (17) | |
Text
Exelon Generation Company, LLC www.exeloncorp.com 4300 Winfield Road Nuclear Warrenville, IL 60555 Attachment I contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.
RS-11-176 10 CFR 50.90 November 2, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Unit 1 Renewed Facility Operating License No. DPR-29 NRC Docket No. 50-254
Subject:
Supplemental Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No. ME6383)
References:
- 1. Letter from Mr. Jeffrey L. Hansen (Exelon Generation Company, LLC(EGC)) to U. S. NRC, "Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit," dated June 7, 2011
- 2. Letter from U. S. NRC to Mr. Michael J. Pacilio (EGC), "Quad Cities Nuclear Power Station, Unit 1 - Request for Additional Information Related to Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No. ME6383)," dated August 22, 2011
- 3. Letter from Mr. David M. Gullott (EGC) to U. S. NRC, "Additional Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit," dated September 21, 2011 In Reference 1, Exelon Generation Company, LLC (EGC) requested an amendment to Appendix A, Technical Specifications (TS), of Renewed Facility Operating License No. DPR-29 for Quad Cities Nuclear Power Station (QCNPS), Unit 1. The proposed change revises the value of the single recirculation loop operation (SLO) safety limit minimum critical power ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs." Specifically, the proposed change would replace the current SLO SLMCPR requirement for QCNPS Unit 1 with a new SLMCPR requirement. This proposed change does not affect the QCNPS Unit 1 two recirculation loop operation (TLO) SLMCPR or either of the SLMCPR values for Unit 2. This change is needed to support the current cycle of operation (i.e., Cycle 22) for QCNPS Unit 1 for cycle exposure greater than 4000 MWd/MT, which is currently scheduled to occur on December 1, 2011.
Attachment 1 contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.
November 2, 2011 U. S. Nuclear Regulatory Commission Page 2 In Reference 2, the NRC requested that EGC provide additional information in support of their review of Reference 1. The NRC request for additional information (RAI) and the specific EGC responses were provided in Reference 3.
Upon further review of the information provided in Reference 3, it became clear that additional information is required to support the NRC's review of the Reference 1 submittal. Specifically, supplemental information is required associated with NRC Question No. 5 in Reference 2. The supplemental information is provided in Attachment 1. Attachment 1 contains information that is proprietary to Westinghouse Electric Company, LLC (Westinghouse) and should be withheld from public disclosure in accordance with paragraph (b)(4) of 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." An affidavit attesting to the proprietary nature of this information is provided in Attachment 2. Attachment 3 is a non-proprietary version of Attachment 1.
The information provided in this letter does not affect the No Significant Hazards Consideration or the Environmental Consideration provided in Attachment 1 of the original license amendment request as described in the Reference 1 submittal.
In accordance with 10 CFR 50.91(b), "State consultation," EGC is providing the State of Illinois with a copy of this letter and its attachment to the designated State Official.
This letter contains no new regulatory commitments. If you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of November, 2011.
Respectfully, David M. Gullott Manager - Licensing Exelon Generation Company, LLC Attachments:
- 1. Supplemental Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit - Proprietary Version
- 2. Westinghouse Affidavit Supporting Proprietary Nature of Information in Attachment 1
- 3. Supplemental Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit - Non-Proprietary Version
ATTACHMENT 2 Westinghouse Affidavit Supporting Proprietary Nature of Information in Attachment 1
Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@ westinghouse.com Rockville, MD 20852 Proi letter: NF-BEX-11-172 CAW-11-3293 November 1, 2011 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
USBWR- 11-33 P-Attachment, Revision 2, "Supplement to Responses to NRC Request for Additional Information on Quad Cities Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No. ME6383)" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-1 1-3293 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.
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-1 1-3293, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
Very truly yours, 4 J. A. Gresham, Manager Regulatory Compliance Enclosures
CAW-1 1-3293 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
Before me, the undersigned authority, personally appeared J. A. Gresham, 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-
. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this ___ day of November 2011 COMMONWEALTH O PENNSYLVANIA Notarial Seal Cynthia Olesky, Notary Pubik:
Manor Boro, Westmoreland County My Commission Expkes July 15, 2014 Member. Pennsvivania Association of Notaries
2 CAW-11-3293 (1) I am Manager, Regulatory Compliance, 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.
(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 Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) 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.
(i) 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
3 CAW-11-3293 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(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.
4 CAW-11-3293 (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.
(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.
(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii) 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 in USBWR-11-33 P-Attachment, Revision 2, "Supplement to Responses to NRC Request for Additional Information on Quad Cities Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No.
ME6383)" (Proprietary), for submittal to the Commission, being transmitted by Exelon letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of Quad Cities Unit 1 Cycle 22 SLMCPR, and may be used only for that purpose.
5 CAW-11-3293 This information is part of that which will enable Westinghouse to:
(a) Support Exelon's use of Westinghouse Fuel at Quad Cities.
(b) Assist the customer to obtain license change.
Further this information has substantial commercial value as follows:
(a) Westinghouse can use this information to further enhance their licensing position with their competitors.
(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 analyses 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.
ATTACHMENT 3 Supplemental Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit -
Non-Proprietary Version
Westinghouse Non-Proprietary Class 3 USBWR-11-33 NP-Attachment, Revision 2 Supplement to Responses to NRC Request for Additional Information on Quad Cities Technical Specification Change for Minimum Critical Power Ratio Safety Limit (TAC No. ME6383) (Non-Proprietary)
Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066
© 2011 Westinghouse Electric Company LLC All Rights Reserved
Page 2 of 5 USBWR-1 1-33 NP-Attachment, Revision 2 RAI-Supplement 01 The McSLAP computer code system is the code system that implements the Monte Carlo Safety Limit evaluation methodology described in Section 5.3.2.2 of Reference 1. This methodology was reviewed and approved as documented in Reference 1. [
a,c I
Figure RAI-S-01-1 Overview of programs and files used in an application of McSLAP a,c
Page 3 of 5 USBWR-11-33 NP-Attachment, Revision 2 I
a,c
Page 4 of 5 USBWR-11-33 NP-Attachment, Revision 2 Ia,c The above methodology is used on a cycle-specific basis in determining the cycle SLMCPR.
RAI-Supplement 02 A non-conservative 1% impact on the SLMCPR value for Quad Cities Nuclear Power Station (QCNPS), Unit 1, Cycle 22 is observed for the SLO and not for TLO as discussed in Reference 3.
This is due to the fact that the impact on the reported SLO was 0 .01 higher than the impact on the reported TLO SLMCPR.
a,c I
Page 5 of 5 USBWR-11-33 NP-Attachment, Revision 2 a,c I
In summary, the impact of the three McSLAP errors described in Reference 3 result in a SLMCPR that is 0.01 higher for the reported SLO while the impact for the three errors results in no change in the reported SLMCPR for TLO. Reference 2 includes reported SLMCPR values that have been corrected to account for all three McSLAP errors.
References:
- 1. CENPD-300-P-A, "Reference Safety Report for Boiling Water Reactor Reload Fuel," July 1996
- 2. "Quad Cities Unit 1 Cycle 22 SLMCPR, Revision 2 (Proprietary)" (Attachment 12 to RS 155, Letter from D. M. Gullott (Exelon) to USNRC, "Additional Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit," RS-11-155, September 2011)
- 3. Letter from D. M. Gullott (Exelon) to USNRC, "Additional Information Supporting the Request for Technical Specification Change for Minimum Critical Power Ratio Safety Limit," RS-11-155, September 2011
Exelon LS-AA-1 17-1002 Revision 3 Page 1 of I Nuclear TYPICAL LICENSING AND REGULATORY AFFAIRS CORRESPONDENCE CONCURRENCE FORM Station(s): Quad Cities Nuclear Power Station Correspondence No.: RS-11-176 Subject/Document: Supplemental Information Supporting the LAR for QDCNPS, Unit 1, MCPR SL Document Prepared by: Mitch Mathews Location: Cantera Extension: 2819 Required Review and Disciplines Assigned by: David Gullott / LicensingManager Title Type of Review Required: M Technical Verification Team Review (Reference LS-AA-1 17) q Individual or Series Review q No Technical Review Note: If the subject document falls within the scope of AD-AA-102, "Station Qualified Review," one of the reviewers must be a Station Qualified Reviewer.
Disciplines Required:
q Maintenance q Radiation Protection q Chemistry q Training q Operations q Engineering - l&C q Radwaste Reg Assurance / Licensing q Rx Engineering q Design Engineering q Engr - Mach Systems q Programs Engineering q Nuclear Fuels q Work Management q Engr - Elect Systems q Other:
Review Concurrence: Signature indicates that the individual has reviewed the subject document and concurs that the content is factual and accurate. Concurrence via e-mail shall be provided using the declaration provided in LS-AA-1 17.
Print Name na Discipline at Mark E. Wagner/ Quad Cities Reg. Assurance Mitchel A. Mathews/ Corporate Licensing 11/2/2011 Does this letter contain commitments? q Yes No If yes, corporate or site commitment coordinator has been notified: Date:
Required Reviews and Signatures (check as appropriate):
q Station Qualified Review Required: Date:
q PORC Approval Required: PORC Meeting No.
q x Corporate Licensing Concurrence Required: Mitchel A. Mathews Date: 11/2/2011
© Site Regulatory Assurance Concurrence Required: Mark E Wagner Date: t 2-1 eft q Station Manager Approval Required: Date:
[] Site Vice President Approval Required: Date:
Note: The completed original of this form will be retained by the organization transmitting the submittal (i.e., either Licensing or site Regulatory Assurance) in accordance with RM-AA-101, "Records Management Program."