NLS2012040, Enclosure 2, GNF S-0000-0140-2518-R0-NP, GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR - Cooper Cycle 28
| ML12157A207 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/30/2012 |
| From: | Global Nuclear Fuel |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NLS2012040, eDRFSection 0000-0140-2518-R1 GNF S-0000-0140-2518-R0-NP | |
| Download: ML12157A207 (30) | |
Text
NLS2012040 Page 1 of 26 ENCLOSURE 2 "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR - Cooper Cycle 28" (GNF-A Report No. S-0000-0140-2518-RO-NP)
Non-Proprietary Version Cooper Nuclear Station NRC Docket 50-298, License DPR-46
Non-Proprietary Information - Class I (Public)
April 2012 GNF S-0000-0 140-2518-RO-NP eDRFSection: 0000-0140-2518-RI GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Cooper Cycle 28 Copyright 2012 Global Nuclear Fuel - Americas, LLC All Rights Reserved Cooper Cycle 28 Page I of 25
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Information Notice This is a non-proprietary version of the document GNF S-0000-0140-2518-RO-P, which has the proprietary information removed.
Portions of the document that have been removed are indicated by an open and closed bracket as shown here ((
Important Notice Regarding Contents of this Report Please Read Carefully The design, engineering, and other information contained in this document is furnished for the purpose of providing information regarding the requested changes to the Technical Specification SLMCPR for Cooper. The only undertakings of Global Nuclear Fuel - Americas, LLC (GNF-A) with respect to information in this document are contained in contracts between GNF-A and Nebraska Public Power District (NPPD), and nothing contained in this document shall be construed as changing that contract. The use of this information by anyone other than NPPD, or for any purpose other than that for which it is intended is not authorized; and with respect to any unauthorized use, GNF-A makes no representation or warranty, express or implied, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.
Information Notice Page 2 of 25
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Table of Contents 1.0 M ethodology........................................................................................................................
4 2.0 D iscussion.............................................................................................................................
4 2.1.
M ajor Contributors to SLM CPR Change.....................................................................
4 2.2.
Deviations in N RC-A pproved Uncertainties.................................................................
5 2.2.1.
R-Factor......................................................................................................................
5 2.2.2.
Core Flow Rate and Random Effective TIP Reading.............................................
6 2.3.
Departure from N RC-A pproved M ethodology............................................................
6 2.4.
Fuel Axial Pow er Shape Penalty..................................................................................
7 2.5.
M ethodology Restrictions.............................................................................................
8 2.6.
M inim um Core Flow Condition....................................................................................
8 2.7.
Lim iting Control Rod Patterns....................................................................................
9 2.8.
Core M onitoring System...............................................................................................
9 2.9.
Power/Flow M ap.......................................................................................................
9 2.10.
Core Loading D iagram..............................................................................................
9 2.11.
Figure References...................................................................................................
9 2.12.
Additional SLM CPR Licensing Conditions...............................................................
9 2.13.
10 CFR Part 21 Evaluation.......................................................................................
10 2.14.
Sum m ary......................................................................................................................
10 3.0 References..........................................................................................................................
11 List of Figures Figure 1. Current Cycle Core Loading Diagram.....................................................................
12 Figure 2. Previous Cycle Core Loading D iagram...................................................................
13 Figure 3. Figure 4.1 from NEDC-32601P-A............................................................................
14 Figure 4. Figure 111.5-1 from N EDC-32601P-A.....................................................................
15 Figure 5. Relationship Betw een M IP and CPR M argin...........................................................
16 List of Tables Table 1. Description of Core....................................................................................................
17 Table 2. SLM CPR Calculation M ethodologies.......................................................................
18 Table 3. M onte Carlo Calculated SLM CPR vs. Estim ate.........................................................
19 Table 4. N on-Power Distribution Uncertainties.....................................................................
21 Table 5. Power D istribution Uncertainties..............................................................................
23 Table 6. Critical Power Uncertainties.....................................................................................
25 Table of Contents Page 3 of 25
Non-Proprietary Information - Class I (Public) 1.0 Methodology Global Nuclear Fuel (GNF) performs Safety Limit Minimum Critical Power Ratio (SLMCPR) calculation in accordance to NEDE-24011-P-A "General Electric Standard Application for Reactor Fuel" (Revision
- 18) using the following Nuclear Regulatory Commission (NRC)-approved methodologies and uncertainties:
" NEDC-32601P-A, "Methodology and Uncertainties for Safety Limit MCPR Evaluations," August 1999.
" NEDC-32694P-A, "Power Distribution Uncertainties for Safety Limit MCPR Evaluations," August 1999.
" NEDC-32505P-A, "R-Factor Calculation Method for GEl I, GE12 and GE13 Fuel,"
Revision 1, July 1999.
" NEDO-10958-A, "General Electric BWR Thermal Analysis Basis (GETAB): Data, Correlation and Design Application," January 1977.
Table 2 identifies the actual methodologies used for the Cycle 27 and the Cycle 28 SLMCPR calculations.
2.0 Discussion In this discussion, the TLO nomenclature is used for two recirculation loops in operation, and the SLO nomenclature is used for one recirculation loop in operation.
2.1.
Major Contributors to SLMCPR Change In general, the calculated safety limit is dominated by two key parameters: (1) flatness of the core bundle-by-bundle Minimum Critical Power Ratio (MCPR) distribution; and (2) flatness of the bundle pin-by-pin power/R-Factor distribution. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR. The MCPR Importance Parameter (MIP) measures the core bundle-by-bundle MCPR distribution, and the R-Factor Importance Parameter (RIP) measures the bundle pin-by-pin power/R-Factor distribution. The effect of the fuel loading pattern on the calculated TLO SLMCPR using rated core power and rated core flow conditions has been correlated to the parameter MIPRIP, which combines the MIP and RIP values.
Table 3 presents the MIP and RIP parameters for the previous cycle and the current cycle along with the TLO SLMCPR estimate using the MIPRIP correlation. If the minimum core flow case is applicable, the TLO SLMCPR estimate is also provided for that case although the MIPRIP correlation is only applicable to the rated core flow case. This is done only to provide some reasonable assessment basis of the minimum core flow case trend. In addition, Table 3 presents estimated effects on the TLO SLMCPR due to methodology deviations, penalties, and/or Methodology Page 4 of 25
Non-Proprietary Information - Class I (Public) uncertainty deviations from approved values. Based on the MIPRIP correlation and any effects due to deviations from approved values, a final estimated TLO SLMCPR is determined. Table 3 also provides the actual calculated Monte Carlo SLMCPRs. The bias and uncertainty in the MIPRIP correlation is ((
)), and the inherent variation in the Monte Carlo results is ((
The intent of the final estimated TLO SLMCPR is to provide an estimate to check the reasonableness of the Monte Carlo result. It is not used for any other purpose. The methodology and final SLMCPR is based on the rigorous Monte Carlo analysis.
The items in Table 3 that result in the increase of the estimated SLMCPR are discussed in Section 2.2.
Cycle 28 will be the first full reload of GNF2 for Cooper. The critical power uncertainty for GNF2 is defined in Table 6. As seen in Table 6, the critical power uncertainty for GNF2 is higher than the previous cycle's fuel type (GEI4). As such, the GEXL uncertainty of the new fuel type tends to make the final SLMCPR higher.
2.2.
Deviations in NRC-Approved Uncertainties Tables 4 and 5 provide a list of NRC-approved uncertainties along with values actually used. A discussion of deviations from these NRC-approved values follows, all of which are conservative relative to NRC-approved values. Also, the estimated effect on the SLMCPR is provided in Table 3 for each deviation.
2.2.1.
R-Factor At this time, GNF has generically increased the GEXL R-Factor uncertainty from ((
)) to account for an increase in channel bow due to the emerging unforeseen phenomena called control blade shadow corrosion-induced channel bow, which is not accounted for in the channel bow uncertainty component of the approved R-Factor uncertainty. The step "a RPEAK" in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, is affected by this deviation. Reference 4 technically justifies that a GEXL R-Factor uncertainty of ((
)) accounts for a channel bow uncertainty of up to The subject plant has predicted control blade shadow corrosion-induced channel bow to the extent that an increase in the NRC-approved R-Factor uncertainty of ((
)) is deemed prudent to address its effect.
Accounting for the control blade shadow corrosion-induced channel bow, the subject cycle analysis shows an expected channel bow uncertainty of
((
)), which is bounded by a GEXL R-Factor uncertainty of ((
)). Thus the use of a GEXL R-Factor uncertainty of ((
)) adequately accounts for the expected control blade shadow corrosion-induced channel bow for the subject cycle.
Discussion Page 5 of 25
Non-Proprietary Information - Class I (Public) 2.2.2.
Core Flow Rate and Random Effective TIP Reading In Reference 5 GNF committed to the expansion of the state points used in the determination of the SLMCPR. Consistent with the Reference 5 commitments, GNF performs analyses at the rated core power and minimum licensed core flow point in addition to analyses at the rated core power and rated core flow point. The approved SLMCPR methodology is applied at each state point that is analyzed.
For the TLO calculations performed at 76.8% core flow, the approved uncertainty values for the core flow rate (2.5%) and the random effective Traversing In-Core Probe (TIP) reading (1.2%)
are conservatively adjusted by dividing them by 76.8/100. The steps "a CORE FLOW" and "a TIP (INSTRUMENT)" in Figure 4.1 from NEDC-32601P-A, which has been provided for convenience in Figure 3 of this attachment, are affected by this deviation, respectively.
Historically, these values have been construed to be somewhat dependent on the core flow conditions as demonstrated by the fact that higher values have always been used when performing SLO calculations. It is for this reason that GNF determined that it is appropriate to consider an increase in these two uncertainties when the core flow is reduced. The amount of increase is determined in a conservative way. For both parameters it is assumed that the absolute uncertainty remains the same as the flow is decreased so that the percentage uncertainty increases inversely proportional to the change in core flow. This is conservative relative to the core flow uncertainty because the variability in the absolute flow is expected to decrease somewhat as the flow decreases. For the random effective TIP uncertainty, there is no reason to believe that the percentage uncertainty should increase as the core flow decreases for TLO.
Nevertheless, this uncertainty is also increased as is done in the more extreme case for SLO primarily to preserve the historical precedent established by the SLO evaluation. Note that the TLO condition is different than the SLO condition because for TLO there is no expected tilting of the core radial power shape.
The treatment of the core flow and random effective TIP reading uncertainties is based on the assumption that the signal to noise ratio deteriorates as core flow is reduced. GNF believes this is conservative and may in the future provide justification that the original uncertainties (non-flow dependent) are adequately bounding.
The core flow and random TIP reading uncertainties used in the SLO minimum core flow SLMCPR analysis remain the same as in the rated core flow SLO SLMCPR analysis because these uncertainties (which are substantially larger than used in the TLO analysis) already account for the effects of operating at reduced core flow.
2.3.
Departure from NRC-Approved Methodology No departures from NRC-approved methodologies were used in the subject cycle SLMCPR calculations.
Discussion Page 6 of 25
Non-Proprietary Information - Class I (Public) 2.4.
Fuel Axial Power Shape Penalty At this time, GNF has determined that higher uncertainties and non-conservative biases in the GEXL correlations for the various types of axial power shapes (i.e., inlet, cosine, outlet, and double hump) could potentially exist relative to the NRC-approved methodology values (References 3, 6, 7, and 8).
The following table identifies, by marking with an "X', this potential for each GNF product line currently being offered:
Axial bundle power shapes corresponding to the limiting SLMCPR control blade patterns are determined using the PANACEA 3D core simulator. These axial power shapes are classified in accordance to the following table:
((
1]
If the limiting bundles in the SLMCPR calculation exhibit an axial power shape identified by this table, GNF penalizes the GEXL critical power uncertainties to conservatively account for the effect of the axial power shape. Table 6 provides a list of the GEXL critical power uncertainties determined in accordance to the NRC-approved methodology contained in NEDE-2401 1-P-A along with values actually used.
For the limiting bundles, the fuel axial power shapes in the SLMCPR analysis were examined to determine the presence of axial power shapes identified in the above table. These power shapes were not found; therefore, no power shape penalties were applied to the calculated SLMCPR values.
Discussion Page 7 of 25
Non-Proprietary Information - Class I (Public) 2.5.
Methodology Restrictions The four restrictions identified on page 3 of NRC's Safety Evaluation relating to the General Electric licensing topical reports NEDC-32601P, NEDC-32694P, and Amendment 25 to NEDE-2401 1-P-A (March 11, 1999) are addressed in References 1, 2, 3, and 9.
The four restrictions for GNF2 were determined acceptable by the NRC review of "GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II)," NEDC-33270P, Revision 0, March 14, 2007. Specifically, in the NRC audit report ML081630579 for the said document, Section 3.4.1 (page 59) states:
"The NRC staff's SE of NEDC-32694P-A (Reference 19 of NEDC-33270P) provides four actions to follow whenever a new fuel design is introduced.
These four conditions are listed in Section 3.0 of the SE. The analysis and evaluation of the GNF2 fuel design was evaluated in accordance with the limitations and conditions stated in the NRC staff's SE, and is acceptable."
GNF's position is that GNF2 is an evolutionary fuel product based on GE14. It is not considered a new fuel design as it maintains the previously established lOx 10 array and 2 water rod makeup, as stated by the NRC audit report ML081630579, Section 3.4.2.2.1 (page 59):
"The NRC staff finds that the calculational methods, evaluations and applicability of the OLMCPR and SLMCPR are in accordance with existing NRC-approved methods and thus valid for use with GNF2 fuel."
As such, no new GNF fuel designs are being introduced in the subject cycle; therefore, the NEDC-32505P-A statement "...if new fuel is introduced, GENE must confirm that the revised R-Factor method is still valid based on new test data" is not applicable.
2.6.
Minimum Core Flow Condition For the subject cycle, the minimum core flow SLMCPR calculation performed at 76.8% core flow and rated core power condition was limiting as compared to the rated core flow and rated core power condition. For convenience, Figures 111.5-1 and 111.5-2 from NEDC-32601 P-A have been provided in Figures 4 and 5, respectively, in order to show this minimum core flow condition relative relationship to the data on these figures. For this condition, the MIP ((
Discussion Page 8 of 25
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Therefore, this demonstrates that the MIP criterion for determining what constitutes a reasonably bounding limiting rod pattern is still valid for this minimum core flow condition. Hence, the rod pattern used to calculate the SLMCPR at 100% rated power/76.8% rated flow reasonably assures that at least 99.9% of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of the subject cycle. Consequently, the SLMCPR value calculated from the 76.8% core flow and rated core power condition limiting MCPR distribution reasonably bounds this mode of operation for the subject cycle.
2.7.
Limiting Control Rod Patterns The limiting control rod patterns used to calculate the SLMCPR reasonably assures that at least 99.9% of the fuel rods in the core would not be expected to experience boiling transition during normal operation or anticipated operational occurrences during the operation of the subject cycle.
2.8.
Core Monitoring System The utility has requested that GNF perform the SLMCPR calculation applying the GETAB power distribution methodology and uncertainties. Due to the presence of third party proprietary information, the utility has provided, in a separate attachment, the basis that the GETAB power distribution methodology and uncertainties are applicable for the GARDEL core monitoring system.
2.9.
Power/Flow Map The utility has provided the current and previous cycle power/flow map in a separate attachment.
2.10.
Core Loading Diagram Figures 1 and 2 provide the core-loading diagram for the current and previous cycle respectively, which are the Reference Loading Pattern as defined by NEDE-2401 I -P-A. Table I provides a description of the core.
2.11.
Figure References Figure 3 is Figure 4.1 from NEDC-32601P-A. Figure 4 is Figure 111.5-1 from NEDC-32601P-A.
Figure 5 is based on Figure 111.5-2 from NEDC-32601P-A, and has been updated with GE14 and GNF2 data.
2.12.
Additional SLMCPR Licensing Conditions For the subject cycle, no additional SLMCPR licensing conditions are included in the analysis.
Discussion Page 9 of 25
Non-Proprietary Information - Class I (Public) 2.13.
10 CFR Part 21 Evaluation There are no known 10 CFR Part 21 factors that affect the subject cycle SLMCPR calculations.
2.14.
Summary The requested changes to the Technical Specification SLMCPR values are L. I for TLO and
- 1. 13 for SLO for the subject cycle.
Discussion Page 10 of 25
Non-Proprietary Information - Class I (Public) 3.0 References
- 1. Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of 10x10 Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies,"
FLN-2001-016, September 24, 2001.
- 2. Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Confirmation of the Applicability of the GEXL14 Correlation and Associated R-Factor Methodology for Calculating SLMCPR Values in Cores Containing GE14 Fuel," FLN-2001-017, October 1,2001.
- 3. Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Joseph E. Donoghue (NRC), "Final Presentation Material for GEXL Presentation - February 11, 2002," FLN-2002-004, February 12, 2002.
- 4. Letter, John F. Schardt (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Mel B. Fields (NRC), "Shadow Corrosion Effects on SLMCPR Channel Bow Uncertainty," FLN-2004-030, November 10, 2004.
- 5. Letter, Jason S. Post (GENE) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Chief, Information Management Branch, et al. (NRC), "Part 21 Final Report: Non-Conservative SLMCPR," MFN 04-108, September 29, 2004.
- 6. Letter, Glen A. Watford (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Alan Wang (NRC), "NRC Technology Update -
Proprietary Slides - July 31 - August 1, 2002," FLN-2002-015, October 31, 2002.
- 7. Letter, Jens G. Munthe Andersen (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with attention to Alan Wang (NRC), "GEXL Correlation for IOXI0 Fuel," FLN-2003-005, May 31, 2003.
- 8. Letter, Andrew A. Lingenfelter (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with cc to MC Honcharik (NRC), "Removal of Penalty Being Applied to GE14 Critical Power Correlation for Outlet Peaked Axial Power Shapes,"
FLN-2007-031, September 18, 2007.
- 9. Letter, Andrew A. Lingenfelter (GNF-A) to U.S. Nuclear Regulatory Commission Document Control Desk with cc to SS Philpott (NRC), "Amendment 33 to NEDE-2401 l-P, General Electric Standard Application for Reactor Fuel (GESTAR II) and GNF2 Advantage Generic Compliance with NEDE-2401 1-P-A (GESTAR II),
NEDC-33270P, Revision 3, March 2010," MFN 10-045, March 5, 2010.
References Page 11 of 25
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FUEL TYPE A = GE14-PIODNAB381-15GZ-100T-150-T6-3187 (Cycle 26)
E = GNF2-P10DG2B389-12GZ-1 00T2-150-T6-4116 (Cycle 28)
B = GE14-P10DNAB393-17GZ-1 00T-150-T6-2801 (Cycle 27)
F = GE1 4-P10DNAB383-2G6.0/10G5.0-100T-1 50-T6-3032 (Cycle 25)
C = GE14-P10DNAB383-2G6.012G5.0T-10 50-T6-3033 (Cycle 27)
G = GE14-P10DNAB383-2G6.0/12G5.0-100 T-150-T6-3033 (Cycle 25)
D = GNF2-P10DG2B390-14GZ-100T2-150-T6-4115 (Cycle 28)
H = GE14-P10DNAB377-13GZ-100T-150-T6-3188 (Cycle 26)
Figure 1. Current Cycle Core Loading Diagram Page 12 of 25
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Figure 3. Figure 4.1 from NEDC-32601P-A Figure 3. Figure 4.1 from NEDC-32601P-A Page 14 of 25
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Figure 4. Figure III.5-1 from NEDC-32601P-A Figure 4. Figure 111.5-1 from NEDC-32601P-A Page 15 of 25
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Figure 5. Relationship Between MIP and CPR Margin Figure 5. Relationship Between MIP and CPR Margin Page 16 of 25
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Table 1. Description of Core Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case Number of Bundles in the 548 548 Core Limiting Cycle Exposure Point (i.e., Beginning of Cycle (BOC)/Middle of EOC EOC MOC MOC Cycle (MOC)/End of Cycle (EOC))
Cycle Exposure at Limiting Point 9000 9000 6500 6500 (MWd/STU)
% Rated Core Flow 76.8 100 76.8 100 Reload Fuel Type GE14 GNF2 Latest Reload Batch 25.5 32.8 Fraction, %
Latest Reload Average Batch Weight %
3.86 3.90 Enrichment Core Fuel Fraction:
GNF2 0.0 32.8 GE 14 100.0 67.2 Core Average Weight %
3.84 3.85 Enrichment Table 1. Description of Core Page 17 of 25
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Table 2. SLMCPR Calculation Methodologies Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case Non-Power Distribution NEDC-32601 P-A NEDC-32601P-A Uncertainty Power Distribution NEDO-10958-A NEDO-10958-A Methodology Power Distribution NEDO-10958-A NEDO-10958-A Uncertainty Core Monitoring System GARDEL GARDEL R-Factor Calculation NEDC-32505P-A NEDC-32505P-A Methodology Table 2. SLMCPR Calculation Methodologies Page 18 of 25
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Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Previous Cycle Previous Cycle Rated Current Cycle Current Cycle Rated Description Minimum Core Flow Core Flow Limiting Minimum Core Flow Core Flow Limiting Limiting Case Case Limiting Case Case 1[
Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Page 19 of 25
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Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Description Previous Cycle Minimum Core Flow Limiting Case Previous Cycle Rated Core Flow Limiting Case Current Cycle Minimum Core Flow Limiting Case Current Cycle Rated Core Flow Limiting Case Table 3. Monte Carlo Calculated SLMCPR vs. Estimate Page 20 of 25
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Table 4. Non-Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow
+/- * (%)
Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case GETAB Feedwater Flow Measurement 1.76 N/A N/A N/A N/A Measurement Feedwater Temperature 0.76 N/A N/A N/A N/A Measurement Reactor Pressure Mea sure 0.50 N/A N/A N/A N/A Measurement Core Inlet Temperature 0.20 N/A N/A N/A N/A Measurement Total Core Flow 6.0 SLO/2.5 TLO N/A N/A N/A N/A Measurement Channel Flow Area 3.0 N/A N/A N/A N/A Variation Friction Factor 10.0 N/A N/A N/A N/A Multiplier Channel Friction FactorMutipi 5.0 N/A N/A N/A N/A Factor M ultiplier IIIIII Table 4. Non-Power Distribution Uncertainties Page 21 of 25
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Table 4. Non-Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow a o (%)
Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case NEDC-32601P-A Feedwater Flow Measurement Feedwater Temperature
((
Er Er Er
))
Er Measurement Reactor Pressure Measurement
((
Er
][
Er Er Core Inlet Temperature 0.2 0.2 0.2 0.2 0.2 Measurement Total Core Flow Measurementw6.0 SLO/2.5 TLO 6.0 SLO/2.5 TLO 6.0 SLO/2.5 TLO 6.0 SLO/2.5 TLO 6.0 SLO/2.5 TLO Measurement Channel Flow Area Variation
((_]_
[_]_[_]_[_]_[_]
Friction Factor R
EE Multiplier Individual Channel 5.0 5.0 5.0 5.0 5.0 Friction Factor Table 4. Non-Power Distribution Uncertainties Page 22 of 25
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Table 5. Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Description Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow
+/- * (%)
Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case GETAB/NEDC-32601P-A GEXL R-Factor E[
Er EL EL E]
((
))
Random Effective 2.85 SLO/1.2 TLO 2.85 SLO/1.2 TLO 2.85 SLO/1.2 TLO 2.85 SLO/1.2 TLO 2.85 SLO/1.2 TLO TIP Reading Systematic Effective 8.6 8.6 8.6 8.6 8.6 TIP Reading I
I I
NEDC-32694P-A, 3DMONICORE GEXL R-Factor EL N/A N/A N/A N/A Random Effective 2.85 SLO/1.2 TLO N/A N/A N/A N/A TIP Reading TIP Integral E[
N/A N/A N/A N/A Four Bundle Power Distribution Disribtio N/A N/A N/A N/A Surrounding TIP Location Contribution to Bundle Power Budl Powe N/A N/A N/A N/A Uncertainty Due to LPRM Update Table 5. Power Distribution Uncertainties Page 23 of 25
Non-Proprietary Information - Class I (Public)
Table 5. Power Distribution Uncertainties Nominal (NRC-Previous Cycle Previous Cycle Current Cycle Current Cycle Description Approved) Value Minimum Core Rated Core Flow Minimum Core Rated Core Flow a * (%)
Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case Contribution to Bundle Power Due to
((
N/A N/A N/A N/A Failed TIP Contribution to Bundle Power Due to E[
N/A N/A N/A N/A Failed LPRM Total Uncertainty in Calculated Bundle
[E N/A N/A N/A N/A Power Uncertainty of TIP Signal Nodal
((
N/A N/A N/A N/A Uncertainty Table 5. Power Distribution Uncertainties Page 24 of 25
Non-Proprietary Information - Class I (Public)
Table 6. Critical Power Uncertainties Previous Cycle Previous Cycle Current Cycle Current Cycle Minimum Core Rated Core Flow Minimum Core Rated Core Flow Flow Limiting Case Limiting Case Flow Limiting Case Limiting Case Table 6. Critical Power Uncertainties Page 25 of 25
NLS2012040 Page 1 of 4 ENCLOSURE 3 10 CFR 2.390 Affidavit from Global Nuclear Fuels - Americas Cooper Nuclear Station NRC Docket 50-298, License DPR-46
Global Nuclear Fuel - Americas AFFIDAVIT I, Lukas Trosman, state as follows:
(1) I am Engineering Manager, Reload Design and Analysis, 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 Enclosure I of GNF's letter, VSP-NPP-HPI-12-043, V. Perry (GNF-A) to G. Stuchal (Nebraska Public Power District),
entitled "GNF Additional Information for SLMCPR Technical Specification Submittal Letter for Cooper Cycle 28," dated April 25, 2012.
GNF-A proprietary information in, which is entitled "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR, Cooper Cycle 28," is identified by a dotted underline inside double square brackets. ((Thi.s..s.nte.n.ces.a.nxa.mple.))
A "3[
marking at the beginning of a table, figure, or paragraph closed with a "))" marking at the end of the table, figure or paragraph is used to indicate that the entire content between the double brackets is proprietary.
In each case, the superscript notation 13) 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, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (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.
VSP-NPP-HPI-12-043 Enclosure I Affidavit Page I 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 this methodology, along with the testing, development and approval was achieved at a significant cost to GNF-A.
The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNF-A asset.
(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.
VSP-NPP-HPI-12-043 Enclosure I Affidavit Page 2 of 3
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 25th day of April 2012.
Lukas Trosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel - Americas, LLC VSP-NPP-HPI-12-043 Enclosure I Affidavit Page 3 of 3