ML14064A324

000N2495-R1-NP, Rev. 0, Nine Mile Point Nuclear Station Unit 2 Comparison of Mellla+ Reference Design to Cycle 15 Design Characteristics.

ML14064A324
Person / Time
Site:	Nine Mile Point
Issue date:	02/28/2014
From:	Trosman L Global Nuclear Fuel
To:	Office of Nuclear Reactor Regulation
References
000N2495-R1-NP, Rev. 0
Download: ML14064A324 (17)

Text

ATTACHMENT (3)

NINE MILE POINT NUCLEAR STATION UNIT 2, COMPARISON OF MELLLA+ REFERENCE DESIGN TO CYCLE 15 DESIGN CHARACTERISTICS (000N2495-R1-NP)

(NON-PROPRIETARY)

Nine Mile Point Nuclear Station, LLC February 25, 2014

GNF Global Nuclear Fuel Global Nuclear Fuel 3901 Castle Hayne Rd Wilmington, NC 28401 A Joint Venture of GE.Tohiba,. & Hitachi 00ON2495-R1-NP Revision 0 February 2014 GNF ProprietaryInformation - Class I (Public)

Nine Mile Point Nuclear Station Unit 2 Comparison of MELLLA+ Reference Design to Cycle 15 Design Characteristics Responsible Engineer:

L. Trosman Approving Manager:

R.Fawcett Authorizing Document: WA GNFO2 KG 1004 Rev 1 Verification Status: Verified

000N2495-Rl-NP Revision 0 GNF ProprietaryInformation - Class I (Public)

IMPORTANT NOTICE REGARDING THE CONTENTS OF THIS REPORT Please Read Carefully Disclaimer The only undertakings of Global Nuclear Fuel (GNF) respecting information in this document are contained in the contract between the company receiving this document and GNF.

Nothing contained in this document shall be construed as changing the applicable contract.

The use of this information by anyone other than a customer authorized by GNF to have this document, or for any purpose other than that for which it is intended, is not authorized. With respect to any unauthorized use, GNF makes no representation or warranty, and assumes no liability as to the completeness, accuracy or usefulness of the information contained in this document, or that its use may not infringe privately owned rights.

Information Notice This is a non-proprietary version of the document 000N2495-R1-P, Revision 0, 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 R I].

Page ii

000N2495-Rl-NP Revision 0 GNF Proprietary Information - Class I (Public)

REVISION

SUMMARY

Rev 0 Initial Issue Summary of Changes I

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000N2495-R1-NP Revision 0 GNF ProprietaryInformation - Class I (Public)

TABLE OF CONTENTS Section Paqe REV ISIO N SU MMARY .................................................................................................................................................... iii AC RO NYMS AND ABBREV IATIO NS .......................................................................................................................... v

1. SC OPE AND SU MMARY ............................................................................................................................... 1

2. COMPA RISO NS ............................................................................................................................................... 1 2.2 Energy Req uirem ents .................................................................................................................................. 1 2.3 Fuel Utilizatio n ................................................................................................................................................ 1 2.4 Sig nifica nt Ana lytica l Inputs ..................................................................................................................... 2 2.5 Reactivity Ma rg ins ........................................................................................................................................ 2 2.6 Therm a l Lim it Marg ins ................................................................................................................................ 3 Page iv

000N2495-R1-NP Revision 0 GNF ProprietaryInformation - Class I (Public)

ACRONYMS AND ABBREVIATIONS Item Short Form Description 1 BOC Beginning Of Cycle 2 ECCS Emergency Core Coolant System 3 MAPLHGR Maximum Average Planar Linear Heat Generation Rate 4 MELLLA+ Maximum Extended Load Line Limit Analysis Plus 5 MOC Middle Of Cycle 6 MWd Energy units MegaWatts-days 7 MWd/ST Exposure units MWd thermal energy per core weight Short Tons 8 N/A Not Applicable 9 NRC Nuclear Regulatory Commission 10 OLMCPR Operating Limit for Minimum Critical Power Ratio 11 OLTP Original Licensed Thermal Power 12 SAR Safety Analysis Report 13 SLCS Standby Liquid Control System 14 SRO Strongest Rod Out Page v

000N2495-R1-NP Revision 0 GNF ProprietaryInformation - Class I (Public)

1. SCOPE AND

SUMMARY

The Nine Mile Point Nuclear Station Unit 2 (NMP2) MELLLA+ project consists of the evaluations necessary to support the extensions of the NMP2 operating domain to permit operation up to 120% (3988 MWt) of OLTP at core flows as low as 85% of rated (RCF). A MELLLA+ SAR was performed with a reference core design designated hereafter as Reference Design. The scope of this report is to compare the Reference Design to the Cycle 15 design which is anticipated to apply the MELLLA+ domain once approval is obtained.

This report supports the commitment made by Nine Mile Point Nuclear Station Unit 2 to the NRC in a MELLLA+ pre-submittal meeting to supplement the MELLLA+ SAR. It should be noted Limitation and Condition 12.4, "Reload analysis submittal", from the final SE for NEDC-33006P, "Maximum Extended Load Line Limit Analysis Plus," requires that "... the SRLR for the initial MELLLA+ submittal implementation cycle shall be submitted for NRC staff confirmation." There is no SE requirement to provide a comparison report.

The items included in this comparison are as follows:

• Energy requirements,

• Fuel Utilization,

• Significant analytical inputs (i.e., design basis),

" Reactivity Margins, and

" Thermal limits.

2. COMPARISONS 2.1 Energy Requirements Item Parameter Units Reference Design Cycle 15 1 Total Energy MWd 2,801,012 2,580,225 2 Coastdown Length Days 40 56 2.2 Fuel Utilization Item Parameter Units Reference Design Cycle 15 3 Batch Size Bundles Bundle Average Wt. % U235 Enrichment 5 Fuel Design N/A GE14 GE14 Page 1

000N2495-R1-NP Revision 0 GNF ProprietaryInformation - Class I (Public) 2.3 Significant Analytical Inputs Item Parameter Units Reference Design Cycle 15 6 Power MWt 3988 3988

% of 7 Flow Window Rated85 Rated to 105 87 to 104 Exp Exp (MWd/ST) Values (MWd/ST) Values 8 Hot Target N/A Eigenvalues Exp Exp Cold Target (MWd/ST) Values (MWd/ST) Values 9 Eigenvalues N/A (Distributed)

Thermal Mechanical 10 Model N/A PRIME PRIME 2.4 Reactivity Margins Item Parameter Units Reference Design Cycle 15 Cold SRO Minimum 11 Shutdown Margin -  % Ak Minimum occurs at BOC SLCS Minimum 12 Shutdown Margin-  % Ak Minimum occurs at BOC Page 2

000N2495-R1-NP Revision 0 GNF ProprietaryInformation - Class I (Public) 2.5 Thermal Limits Item Parameter Units Reference Design Cycle 15 13 OLMCPR N/A (( ((

Exp LHGR Exp LHGR (GWd/MT) (kW/ft) (GWd/MT) (kW/ft) 14 U02 Thermal N/A Mechanical Limit Exp MAPLHGR Exp MAPLHGR (GWd/MT) (kW/ft) (GWd/MT) (kW/ft) 0.0 12.82 16.00 12.82 21.09 12.82 15 MAPLHGR Limit* N/A 63.50 8.00 70.00 5.00

• [

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ATTACHMENT (4)

AFFIDAVIT FROM GLOBAL NUCLEAR FUEL - AMERICAS, LLC (GNF-A) JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION CONTAINED IN ATTACHMENT (6)

Nine Mile Point Nuclear Station, LLC February 25, 2014

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 GNF-A proprietary report 000N0123-FBIR-P, Fuel Bundle Information Report for Nine Mile Point 2 Reload 14 Cycle 15, Revision 0, December 2013. GNF-A proprietary information in 000N0123-FBIR-P, Fuel Bundle Information Report for Nine Mile Point 2 Reload 14 Cycle 15, Revision 0, December 2013 is identified by a dotted underline inside double square brackets. ((Thi.ssentence is an.example.1 31 )) Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation (31 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.

00ON0123-FBIR-P Affidavit Page 1 of 3

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology. The development of 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 00ON0123-FBIR-P Affidavit Page 2 of 3

process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 11th day of December 2013.

Lukas Trosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel - Americas, LLC 00ON0123-FBIR-P Affidavit Page 3 of 3

ATTACHMENT (5)

AFFIDAVIT FROM GLOBAL NUCLEAR FUEL - AMERICAS, LLC (GNF-A) JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION CONTAINED IN ATTACHMENT (7)

Nine Mile Point Nuclear Station, LLC February 25, 2014

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 GNF-A proprietary report 000N2495-R1 -P, Nine Mile Point Nuclear Station Unit 2 Comparisonof MELLLA +

Reference Design to Cycle 15 Design Characteristics,Revision 0, February 2014.

GNF-A proprietary information in 000N2495-RI-P, Nine Mile Point Nuclear Station Unit 2 Comparison of MELLLA+ Reference Design to Cycle 15 Design Characteristics,Revision 0, February 2014 is identified by a dotted underline inside double square brackets. ((This sentence is an exa.mpe..13.,)) In each case, the superscript notation 313 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.

00ON2495-RI-P Affidavit Page 1 of 3

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A.

(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 00ON2495-RI-P Affidavit Page 2 of 3

process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 7th day of February 2014.

uaTrosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel - Americas, LLC 00ON2495-Rl-P Affidavit Page 3 of 3