ML14188B673

Forwards Proprietary Hb Robinson Unit 2,Cycle 14 SAR & Mechanical Licensing Rept for Hb Robinson High Thermal Performance Fuel Assemblies. Repts Withheld (Ref 10CFR2.790)

ML14188B673
Person / Time
Site:	Robinson
Issue date:	02/06/1990
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML14188B674	List: ML14188B673
References
NLS-90-010, NLS-90-10, NUDOCS 9002140201
Download: ML14188B673 (6)

Text

ACCELERATED DITRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9002140201 DOC.DATE: 90/02/06 NOTARIZED: YES DOCKET #

FACIL:50-261 H.B. Robinson Plant, Unit 2, Carolina Power & Light C 05000261 AUTH.NAME AUTHOR AFFILIATION / '

CUTTER,A.B. Carolina Power & Light Co. L/ / f-/gI RECIP.NAME RECIPIENT AFFILIATION /6 Document Control Branch (Document Control Desk) R

SUBJECT:

Forwards proprietary ANF-89-160, "HB Robinson Unit 2,Cycle 14 SAR" & ANF-89-164(P), "Mechanical Licensing Rept...." .

DISTRIBUTION CODE: APO1D COPIES RECEIVED:LTR _

TITLE: Proprietary Review Distribution - Operating Reactor ENCL e SIZE: 14 \

D S

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL A PD2-1 LA 1 1 PD2-1 PD 1 1 LO,R 3 3 D INTERNAL: AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 OGC/HDS1 1 0 REG FILE Oc 1 1 D EXTERNAL: LPDR 1 0 NRC PDR 1 0 S R

I D

S A

D D

NOTE TO ALL "RIDS" RECIPIENTS:

S PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P1-37 (EXT. 20079) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 8

.0 CP&L Carolina Power & Light Company P.O. Box 1551

• Raleigh, N.C. 27602 SERIAL: NLS-90-010 FEB 0 6 1990 A. B CUTTER Vice President Nuclear Services Department United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 SUPPORTING INFORMATION FOR CYCLE 14 Gentlemen:

This letter transmits information in support of Cycle 14 operation at the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR2), specifically: "H. B.

Robinson Unit 2, Cycle 14 Safety Analysis Report" (ANF-89-160), "Mechanical Licensing Report for H. B. Robinson High Thermal Performance Fuel Assemblies" (ANF-89-164(P)), and changes required to the Technical Specification Bases.

Carolina Power & Light Company will utilize Advanced Nuclear Fuels (ANF) High Thermal Performance (HTP) fuel during Cycle 14. Changes to the Technical Specification Bases are required to implement the Cycle 14 core design. The attached reports summarize the evaluations performed to assure that the new design is compatible with existing fuel and appropriate for use at HBR2. Note that these evaluations required the use of the currently unapproved "ANFP" DNBR correlation. A topical report, "Departure From Nucleate Boiling Correlation for High Thermal Performance Fuel" (ANF-1224(P)), and request for approval of the ANFP correlation was submitted by ANF in May 1989. Carolina Power & Light Company requests your approval of the changes to the Bases to support restart for Cycle 14, currently scheduled for early September 1990.

Further, the Mechanical Design Report references a burnup value of 52.5 GWd/MTU. This does not imply an increase in burnup from the approved value of 44 GWd/MTU, rather the higher value is used in the subject report since it is conservative with respect to the current limit for this application. Carolina Power & Light Company may pursue an increase in the approved burnup limit for subsequent cycles.

During performance of the Cycle 14 analysis a discrepancy was noted in the Cycle 10 Safety Evaluation Report (SER), dated November 7, 1984, regarding the boron dilution event. The SER, page 16, acknowledges that the HBR2 method of determining the time from the initiation of the dilution to the time of loss P

Document Control Desk (NLS-90-010) / Page 2 of shutdown margin differs from the Standard Review Plan "but is consistent with past and current practices." Attachment I to the SER, page 22, however, discusses the criterion for acceptable results in terms of "the time when the alarm announces the dilution is occurring and the time of loss of shutdown margin." The methodology used for the Cycle 14 is consistent with our past practice of analyzing from the time of initiation until the time of loss of shutdown margin.

Please note that CP&L had committed in a letter dated September 8, 1989 to provide the Cycle 14 Safety Analysis Report by December 29, 1989 as part of the normal licensing submittal for Cycle 14. However, due to an extended shutdown in late 1989 and subsequent five month postponement of refueling outage 13, the submittal has been delayed. This delay has been discussed with and agreed to by the NRC Project Manager.

ANF considers the information contained in ANF-89-164(P) to be proprietary.

In accordance with 10CFR2.790(b) the enclosed affidavit executed by Mr. H. F.

Williamson of ANF provides the necessary information to support withholding this topical report from public disclosure.

Questions regarding this matter may be referred to Mr. R. W. Prunty at (919) 546-7318.

Yours very t A. B. Cutter JSK/ecc (582CRS)

Enclosures:

1. ANF-89-160, H. B. Robinson Unit 2, Cycle 14 Safety Analysis Report

2. ANF-89-164(P), Mechanical Licensing Report for H. B. Robinson High Thermal Performance Fuel Assemblies

3. Revised Basis Pages

4. Affidavit cc: Mr. S. D. Ebneter Mr. L. Garner (NRC - HBR)

Mr. R. Lo

AFFIDAVIT STATE OF WASHINGTON )

) ss.

COUNTY OF BENTON )

I, H. E. Williamson being duly sworn, hereby say and depose:

1. I am Manager, Licensing and Safety Engineering, for Advanced Nuclear Fuels Corporation, ("ANF"), and as such I am authorized to execute this Affidavit.

2. I am familiar with ANF's detailed document control system and policies which govern the protection and control of information.

3. I am familiar with the topical report ANF-89-164(P),

entitled "Mechanical Licensing Report for H. B. Robinson High Thermal Performance Fuel Assemblies," referred to as "Document." Information contained in this Document has been classified by ANF as proprietary in accordance with the control system and policies established by ANF for the control and protection of information.

4. The Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by ANF and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in the Document as proprietary and confidential.

5. The Document has been made available to the U.S. Nuclear Regulatory Commission in confidence, with the request that the information contained in the Document will not be disclosed or divulged.

2

6. The Document contains information which is vital to a competitive advantage of ANF and would be helpful to competitors of ANF when competing with ANF.

7. The information contained in the Document is considered to be proprietary by ANF because it reveals certain distinguishing aspects of mechanical design methodology which secure competitive advantage to ANF for fuel design optimization and marketability, and includes information utilized by ANF in its business which affords ANF an opportunity to obtain a competitive advantage over its competitors who do not or may not know or use the information contained in the Document.

8. The disclosure of the proprietary information contained in the Document to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it valuable insights into ANF mechanical design methodology and would result in substantial harm to the competitive position of ANF.

9. The Document contains proprietary information which is held in confidence by ANF and is not available in public sources.

10. In accordance with ANF's policies governing the protection and control of information, proprietary information contained in the Document has been made available, on a limited basis, to others outside ANF only as required and under suitable agreement providing for nondisclosure and limited use of the information.

11. ANF policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

12. Information in this Document provides insight into ANF mechanical design methodology developed by ANF. ANF has invested significant

3 resources in developing the mechanical design methodology as well as the strategy for this application. Assuming a competitor had available the same background data and incentives as ANF, the competitor might, at a minimum, develop the information for the same expenditure of manpower and money as ANF.

THAT the statements made hereinabove are, to the best of my knowledge, information, and belief, truthful and complete.

FURTHER AFFIANT SAYETH NOT.

SUBSCRIBED before me this day of January , 1990.

Susan K. McCoy NOTARY PUBLIC, STATE OF WASHI ON MY COMMISSION EXPIRES: 1/10/9