CP-201300826, Supplemental Information Supporting LAR 13-01, Spent Pool Criticality Analysis
| ML13205A056 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/16/2013 |
| From: | Madden F Luminant Generation Co, Luminant Power |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| CP-201300826, TXX-13109, CAW-13-3760, TAC MF1365, TAC MF1366 | |
| Download: ML13205A056 (16) | |
Text
MFOCFE568 CP-201300826 TXX-13109 July16, 2K3 U,&~Nulear Regulatory Caummsion ATI'f: Dommmwt Conedg Desk Waidngkni DC 21D554M0 SUOCr COMANCHE PEAK NUCLIAR POWER PLANT (CPNPP)
DOCKET NOS W4 AND 9)4 SUPPLEMIENTAL RNFOMATION SuPPORTIN LAR 13-01 SPENT L POOL cRCA ANALYSS (ITAC Nos. MP1365 AND) ?i4166)
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Dear Sir or Maddent Pa Ier nces t, Lumiatn Generat Cozmy, LLC (Lmnhua Power) submtted LAR 13.01t* the NRC prp*i a revisio to Tcwla Spcoto 3.7.1? seadi spent fuel stae based on a I'st.4kw-a l' methoo
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U. S. Nuclear Regulatory Commission TXX-13109 Page 2 July 16, 2013 Subsequently, the NRC concluded that supplemental information was necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment (Reference 2). The attachments to this letter provide Luminants Power's response to the four (4) supplemental questions in Reference 2.
Attachments 1 and 2 provide Luminant Power's response to the four (4) supplemental questions. As contains information proprietary to Westinghouse Electric Company LLC, Attachment 3 provides a non-proprietary version of Attachment 1.
As Attachment 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by the enclosed affidavit signed by Westinghouse, the owner of the information. The affidavit 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 Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-13-3760 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
This communication contains no new licensing basis commitments regarding CPNPP Units 1 and 2.
Should you have any questions, please contact J. D. Seawright at (254) 897-0140.
I state under penalty of perjury that the foregoing is true and correct.
Executed on July 16, 2013.
Sincerely, Luminant Generation Company LLC Rafael Flores By:
4
?KI)%LL
/Fred W. Madden Director, Oversight & Regulatory Affairs
U. S. Nuclear Regulatory Commission TXX-13109 Page 3 July 16, 2013 Attachments -
- 1. Supplemental information supporting LAR 13-01, Questions 1, 2, and 4 (Proprietary)
- 2. Supplemental information supporting LAR 13-01, Question 3
- 3. Supplemental information supporting LAR 13-01, Questions 1, 2, and 4 (Non-Proprietary)
Enclosure Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-13-3760, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice c -
A. T. Howell, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak Mr. Robert Free Environmental Monitoring & Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P. 0. Box 149347 Austin, Texas 78714-9347 to TXX-13109 Page I of 2 Supplemental Information Supporting LAR 13-01, Question 3 NRC Question #3:
Section 5.7, "Accident Description," of WCAP-17728 does not discuss the effect of accidents and design basis events on the neutron absorbing material being credited for storage racks in Region I of the SFP. Please provide an accident analysis that considers the effect of accidents and design basis events on the neutron absorbing material being credited for storage racks in Region I of the SFP.
CPNPP Response:
The proposed changes in LAR 13-01 involve new criticality analysis for the existing spent fuel storage racks, and make no changes to the mechanical and structural properties of the storage racks. Therefore, the affects of accident conditions on the structural and material properties, including the Region I absorbing material (BORAL), were not explicitly considered in WCAP-17728. This type of accident has been considered previously, and approved by the NRC, in Amendment 87 of the CPNPP Operating License (reference ML012560143). As stated in the "No Significant Hazards Consideration" section of LAR 13-01, "the margin of safety with respect to mechanical, material or structural considerations is not changed by this proposed License Amendment Request."
The mechanical, material, and structural analysis demonstrates that the active fuel region of the Region I racks will not deform or degrade during accident conditions, and are summarized below:
Fuel Handling Accidents Amendment 87 included analysis for several fuel handling accidents on the rack geometry. The conclusions of this analysis (Reference section 7.6 of Enclosure 1 to TXX-00144, ML012560143) state "The drop accident events postulated for the CPSES SFPs were analyzed and found to produce localized damage well within the design limits for the racks." The analysis results demonstrated that any deformation to the Region I storage racks would be limited to the region above the active fuel and BORAL absorber plates. Other types of drop accidents also demonstrate that the geometry of the racks is not affected in the active fuel region.
Temperature Accident Affects The SFP Temperature excursion accident in WCAP-17728-P Section 5.7.2 demonstrates the acceptability of this accident condition based on criticality impacts (primarily density changes of the SFP water). This accident does not have an impact on the neutron absorbing material due to the properties of BORAL. As discussed in section 3.3 of Enclosure 1 to TXX-00144 (ML012560143), "the two materials [which compose BORAL], boron carbide and aluminum, are chemically compatible and ideally suited for long-term use in the radiative, thermal and chemical environment of a nuclear reactor or a spent fuel pool."
to TXX-13109 Page 2 of 2 Supplemental Information Supporting LAR 13-01, Question 3 Design Basis Events The seismic analysis of the CPNPP Spent Fuel Storage Racks is also documented in to TXX-00144 (ML012560143). Section 2.6.2.d describes the metal sheathing fastened to the outside wall of the Region I storage cells. "The sheathings serve to locate and position the poison sheet accurately and to preclude its movement under seismic conditions."
Section 6.0 of this document contains the structural and seismic analysis results, which conclude in the Technical Analysis (Attachment 2 to TXX-00144, ML012560143) that "Based on the comprehensive parametric study (e.g., varying coefficients of friction and fuel loading conditions of the rack) and adequate factors of safety, it is concluded that the spent fuel storage Region I / Region II rack modules will perform their safety function and maintain their structural integrity under postulated loading conditions."
The seismic analysis performed in support of Amendment 87 did not explicitly model any potential reactivity affects caused by loss of BORAL neutron absorbing material during a seismic event. There is no known degradation mechanism or operating experience to support performing seismic BORAL loss analysis. From the EPRI 2012 Technical Report titled "Strategy for Managing the Long Term Use of BORAL in Spent Fuel Storage Pools" (Section 4.3):
The B4C captured in the aluminum is unlikely to travel since the corrosion rate is low and the blister, even if breached, would tend to retain any loose material in the blister.
A mechanical damage event due tofiiel handling could serve to allow loose material in the blister to be expelled. Currently, there is no plant inspection or laboratory evidence supporting such a scenario.
The sheathing design of the CPNPP storage racks prevents interaction with fuel during fuel handling, and would support the BORAL plates during a seismic event, restricting the potential movement of B4C material. Additionally, the criticality analysis of WCAP-17728-P utilizes conservative assumptions for the Neutron Absorber Loading of the BORAL material. This conservative assumption is adequate to bound any potential minor loss of B4C material due to blister type degradation.
The CPNPP BORAL Monitoring Program, which is included in the proposed Technical Specifications of LAR 13-01 (as Program 5.5.22), is being implemented to ensure that neutron absorber degradation (including blistering or any other type of degradation) is identified and evaluated as appropriate. If degradation is identified which would challenge the CPNPP criticality analysis, the issue will be investigated and evaluated, and the appropriate regulatory process will be followed to address the degradation.
to TXX-1 3109 Page 1 of 3 Westinghouse Non-Proprietary Class 3 Supplemental Information Supporting LAR 13-01 Questions 1, 2, and 4 NRC Question #1 The methodology for the Inter-Region Interface analysis used in Section 5.4.2 of WCAP-17728 (Enclosure 2 to letter dated March 28, 2013) was not provided and does not follow the guidance of Interim Staff Guidance (ISG) DSS-ISG-2010-1, "Staff Guidance Regarding the Nuclear Criticality Safety Analysis for Spent Fuel Pools," dated September 29, 2011 (ADAMS Accession No. ML110620086). Please provide a description and justification for the methodology used in WCAP-17728, Section 5.4.2.
CPNPP Response The methodology used for the Inter-Region Interface analysis in Section 5.4.2 of WCAP-17728-P is identical to the methodology described in WCAP-17483-P "Westinghouse Methodology for Spent Fuel Pool and New Fuel Rack Criticality Safety Analysis" which is currently under review at the NRC (ADAMS Accession No. ML113640206).
[
r aC to TXX-13109 Page 2 of 3 Westinghouse Non-Proprietary Class 3 Supplemental Information Supporting LAR 13-01 Questions 1, 2, and 4 NRC Question #2 Section 5.5, "Normal Condition Description," of WCAP-17728 describes the normal SFP conditions considered for CPNPP, Units 1 and 2. However, it appears that the evaluation of accident conditions discussed in Section 5.5 of WCAP-17728 did not address all of the normal conditions as the initial state of the SFP at the onset of the accident. Please provide an accident analysis that considers all of the normal conditions as the initial state of the SFP at the onset of the accidents.
CPNPP Response The evaluation of the Spent Fuel Pool (SFP) normal conditions address all conditions under which systems and equipment are operated as expected, with no internal or external challenges, including all the operational configurations and handling activities for which the SFP was designed to operate in the course of normal operations over its life. Fuel stored in the pool is organized in configurations for which the burnup limits are established assuming static fuel assembly position in the rack. [
I a~c to TXX-13109 Page 3 of 3 Westinghouse Non-Proprietary Class 3 Supplemental Information Supporting LAR 13-01 Questions 1, 2, and 4 NRC Question #4 Section 6.2.1, "Outlier Assemblies," of WCAP-17728 discusses how the licensee may deal with fuel assemblies that are outside the bounds of its analysis. Fuel assemblies that are outside the bounds of the analysis should not be stored unless there is a full NRC-approved methodology for all possible type of fuel assemblies to be stored in the future. Please provide a full description and justification for the nuclear criticality safety methodology that will be used for fuel assemblies to be stored in future that are outside the bounds of the analyses.
CPNPP Response Since it is not possible to anticipate all future plant operating parameters, the intent of Section 6.2 of WCAP-17728-P is to provide a methodology to identify any assemblies which may not satisfy all aspects of the Area of Applicability (AOA) of the analysis. If this is found to be the case, then an evaluation of that assembly needs to follow the methods described in WCAP-17728-P as provided in bullet 2 of Section 6.3, "Analysis Restrictions".
Luminant has developed a process that will be put into place to identify assemblies that need to be evaluated. If the parameter to be evaluated [
],C the fuel cannot be stored in the Spent Fuel Pool (SFP) until an evaluation or new analysis has been performed in accordance with relevant plant change controls.
If the parameter [
],c it shall be placed in either Region I or in Array II-E in Region II.
Enclosure to TXX-13109 Page 1 of 3 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-13-3760, Accompanying Affidavit, Proprietary Information Notice and Copyright Notice
(fWestinghouse Westinghouse Electric Company Engineering, Equipment and Major Projects 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 Proj letter: NF-TB-13-79 CAW-13-3760 July 12, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
CE-13-454, Attachment 1, "Westinghouse Suggested Responses to the NRC Supplemental Information Request on the Spent Fuel Pool License Amendment Request Submitted by Luminant" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3 760 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 Luminant Generation Company LLC.
-Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3760 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
Very truly yours, Bradley F. Maurer, Principal Engineer Plant Licensing Enclosures
CAW-13-3760 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
Before me, the undersigned authority, personally appeared Bradley F. Maurer, 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:
Bradley F. Maurer, Principal Engineer Plant Licensing Sworn to and subscribed before me this 12th day of July 2013 Notary Public
-COMMONWEALTH OF PENNSYLVANIA I
Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County M My Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
2 CAW-13-3760 (1) 1 am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects, 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-13-3760 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-13-3760 (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 CE-13-454, Attachment 1, "Westinghouse Suggested Responses to the NRC Supplemental Information Request on the Spent Fuel Pool License Amendment Request Submitted by Luminant" (Proprietary), dated July 2013, for submittal to the Commission, being transmitted by Luminant Generation Company LLC.
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 Westinghouse's request for NRC approval of WCAP-17728, and may be used only for that purpose.
5 CAW-13-3760 This information is part of that which will enable Westinghouse to:
(a)
Obtain NRC approval of WCAP-17728, "Comanche Peak Nuclear Power Plant Units I and 2 Spent Fuel Pool Criticality Safety Analysis".
(b)
Demonstrate the sub-criticality of the Comanche Peak spent fuel pools.
Further this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar information to its customers for the purpose of demonstrating the sub-criticality of the spent fuel pool.
(b)
Westinghouse can sell support and defense of spent fuel pool criticality analyses.
(c)
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 technical evaluation justifications 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.