ML11340A067

Review of Realistic Large Break LOCA Analysis

ML11340A067
Person / Time
Site:	Calvert Cliffs
Issue date:	12/01/2011
From:	John Stanley Constellation Energy Nuclear Group, Calvert Cliffs, EDF Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11340A067 (6)

Text

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 CENG.

a joint venture of rgy- J r CALVERT CLIFFS NUCLEAR POWER PLANT December 1, 2011 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Review of Realistic Large Break LOCA Analysis

REFERENCES:

(a) Letter from T. E. Trepanier (CCNPP) to Document Control Desk (NRC),

dated November 23, 2009, License Amendment Request - Transition from Westinghouse Nuclear Fuel to AREVA Nuclear Fuel (b) Letter from D. V. Pickett (NRC) to G. H. Gellrich (CCNPP), dated February 18, 2011, Amendment Re: Transition from Westinghouse Nuclear Fuel to AREVA Nuclear Fuel In Reference (a), we requested various Technical Specification changes needed to support a transition from Westinghouse nuclear fuel to AREVA nuclear fuel. In 2011, operation began on Unit 2 with the first core loading of AREVA fuel. Along with the physical fuel change, a change from Westinghouse Turbo fuel design and evaluation methods to AREVA Advanced CE-14 high thermal performance fuel design and evaluation methods was also required. These design and evaluation methods and their acceptance criteria were approved by the Nuclear Regulatory Commission (NRC) in Reference (b) with restrictions.

One restriction provided in Appendix C of each Unit's Operating License is as follows:

"The approval of the emergency core cooling system evaluation performed in accordancewith the methodology of Technical Specification 5.6.5.b. 7 shall be valid only for Calvert Cliffs Unit 1, Cycle 21 [Unit 2, Cycle 19]. To remove this condition, Calvert Cliffs shall obtain NRC approvalof the analysis of once-and twice-burnedfuel for core designs following Unit 1 Cycle 21 [Unit 2, Cycle 19]. "

This license condition is related to one aspect of the methodology used in evaluating the acceptability of once- and twice-burned fuel in future core reloads. Specifically, the NRC staff expressed concern that fuel thermal conductivity degradation concerns expressed in Information Notice 2009-23 were not

Document Control Desk December 1, 2011 Page 2 adequately addressed in the realistic large break loss-of-coolant accident submitted with the original request (Reference a).

Operation of either Unit beyond the initial cycle loaded with AREVA fuel is not permitted until NRC approval is obtained for the Emergency Core Cooling System evaluation assuming once- and twice-burned AREVA fuel. This restricts operation of Unit 1 after the 2014 refueling outage and Unit 2 after the 2013 refueling outage. Attachment (1) provides the evaluation of once- and twice-burned fuel for Calvert Cliffs and forms the basis of the request for NRC approval needed for continued operation. This evaluation addresses the specific thermal conductivity degradation issues identified by the NRC staff.

The method used to address the issue has been discussed with the NRC staff during the summer and fall of 2011 and the NRC staff indicated that it believed the approach proposed by AREVA is acceptable.

An AREVA evaluation is provided as Attachment (1). This evaluation contains information that is proprietary to AREVA; therefore, it is accompanied by an affidavit signed by AREVA, the owner of the information (Attachment 2). The affidavit sets forth the basis on which the information may be withheld for public disclosure by the Commission, and address, with specificity, the considerations listed in 10 CFR 2.390(b)(4). Accordingly, it is requested that the information that is proprietary to AREVA be withheld from public disclosure. The non-proprietary version of the evaluation (Attachment 3) is included for public disclosure.

Calvert Cliffs plans to refuel and operate with the second cycle of AREVA fuel beginning with the refueling outages in 2013 for Unit 2 and 2014 for Unit 1. Calvert Cliffs requests review and approval of the attached evaluation to allow the second (and subsequent) cycles of operation with AREVA fuel in Units I and 2 by January 1, 2013 with an implementation period of 90 days.

Should you have questions regarding this matter, please contact Mr. Douglas E. Lauver at (410) 495-5219.

trul yours Jamess J1.Stanley Manager, Engineering Services JJS/PSF/bjd Attachments: (1) Proprietary - ANP-3043(P), Calvert Cliffs RLBLOCA Summary Report (2) AREVA Proprietary Affidavit (3) Non-Proprietary - ANP-3043(NP), Calvert Cliffs RLBLOCA Summary Report cc: D. V. Pickett, NRC Resident Inspector, NRC W. M. Dean, NRC S. Gray, DNR

ATTACHMENT (2)

AREVA PROPRIETARY AFFIDAVIT Calvert Cliffs Nuclear Power Plant, LLC December 1, 2011

AFFIDAVIT STATE OF WASHINGTON )

) ss.

COUNTY OF BENTON )

1. My name is Alan B. Meginnis. 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-3043(P) Revision 0, entitled, "Calvert Cliffs RLBLOCA Summary Report," dated November 2011 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), 6(d) and 6(e) 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 ____

day of 2011.

Susan K. McCoy NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/10/12