ML14351A428
| ML14351A428 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/11/2014 |
| From: | GE-Hitachi Nuclear Energy Americas, Nine Mile Point |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GE-PPO-1GYEF-KG1-742, NMP2L 2568 | |
| Download: ML14351A428 (20) | |
Text
ATTACHMENT 3 GEH RESPONSE TO THE NRC REQUEST FOR AN UPDATE OF THE TIP COMPARISONS FOR CURRENT OPERATING CONDITIONS, GE-PPO-1GYEF-KG1-742, ENCLOSURE 2 (NON-PROPRIETARY)
Nine Mile Point Nuclear Station, LLC December 11, 2014
ENCLOSURE 2 GE-PPO- 1GYEF-KG 1-742 Updated TIP Comparisons for Current Operating Conditions Non-Proprietary Information - Class I (Public)
NON-PROPRIETARY NOTICE This is a non-proprietary version of Enclosure I of GE-PPO-lGYEF-KGl-742 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 (( I].
GE-PPO-1GYEF-KG1-742 Non-Proprietary Information - Class I (Public) Page 1 of 14
- 1. Request for Additional Information Via an e-mail sent on Monday, November 10, 2014, Exelon Corporation (Exelon) requested an update of the Nine Mile Point 2 (NMP2) Traversing In-Core Probe (TIP) comparisons for current operating conditions to support potential Nuclear Regulatory Commission (NRC) questions.
- 2. General The question pertains to Limitation and Condition 9.3 of Methods Licensing Topical Report (LTR) NEDC-33173P-A (Reference 1), which states:
"Plant-specific EPU and expanded operating domain applications will confirm that the core thermal power to total core flow ratio will not exceed 50 MWt/Mlbmlhr at any statepoint in the allowed operating domain. For plants that exceed the power-to-flow value of 50 MWt/Mlbmlhr, the application will provide power distribution assessment to establish that neutronic methods axial and nodal power distribution uncertainties have not increased."
Note that the current operating conditions do not include Maximum Extended Load Line Limit Analysis Plus (MELLLA+) conditions, only Extended Power Uprate (EPU) conditions. In responding to this request, it was necessary to gather specific off-line information in order to perform a proper comparison. The off-line core tracking is done using non-adapted thermal margins, as compared to the plant usage of 3DMonicore with shape adaption for the thermal margins. For this response, comparisons of the thermal margins will not be provided. Only the TIP statistical comparisons will be provided, as the purpose is to provide additional information for an assessment that the neutronic methods radial, axial, and nodal power distribution uncertainties have not increased with EPU conditions. Plant operating data at MELLLA+
conditions will be obtained in the future.
The NMP2 plant uses neutron TIP detectors. These detectors have a larger variability in the agreement with off-line calculations than gamma TIP detectors. A full discussion comparing these two detector types is provided in Reference 2. This document shows that for the same actual power distribution, the TIP radial Root Mean Square (RMS) for a neutron TIP detector system will be larger by a significant amount as compared to a gamma TIP detector system.
The. larger values observed in neutron TIP plants are not a safety concern, but rather an operational concern to the utility, as the observed thermal margins will show a larger variability with a neutron TIP system as compared to a gamma TIP system.
- 3. Approach While this question is specific to NMP2, it is also informative to look at the NMP2 TIP data collectively with data from some other plants. After the NMP2 data is presented, additional data is provided for Plants A, C, and D. The general characteristics for NMP2 and Plants A, C, and D are presented in Table 1. Data for NMP2 is available from 2010 to 2014, for Plant A for the same range of dates, while for Plants C and D, the data is available over a wider range, from 2005 to 2014. Figure 1 characterizes the available TIP comparison data, showing the range of
GE-PPO- 1GYEF-KG1-742 Non-Proprietary Information - Class I (Public) Page 2 of 14 the parameter Power/Core Flow (P/F) (MWt/Mlbm/hr) vs. time, while Figure 2 characterizes the TIP data points showing reactor power vs. time. Note that NMP2 uses neutron TIPs, as does Plant A, while plants C and D use gamma TIPs.
Table 1 Plant Characteristics Current Rated TIP Licensed Power Rated MWt/Mlbm/hr Rated Plant System Thermal %EPU Density Core Flow Original Licensed MWt/Mlbml Power (kwll) Mlbm/hr Thermal Power hr CLTP (CLTP) (OLTP)
A Neutron NMP2 Neutron 3988 120.0% 58.99 108.5 30.63 36.76 C Gamma D Gamma
((I Figure 1 Power / Flow vs. Date for NMP2 and Plants A, C, and D
GE-PPO-1GYEF-KG1-742 Non-Proprietary Information - Class I (Public) Page 3 of 14
[1 Figure 2 Power vs. Date for NMP2 and Plants A, C, and D
- 4. Available NMP2 TIP Data The available NMP2 TIP measurements are summarized in Table 2. These data points are shown in the power flow map in Figure 3. An increase to EPU conditions is seen in the later parts of Cycle 14.
GE-PPO- 1GYEF-KG 1-742 Non-Proprietary Information - Class I (Public) Page 4 of 14 Table 2 NMP2 TIP Measurements Cycle "Date Cycle Exposure Core E Powermw/c Core Flow KwlL C Dt MWd/ST MW(t) Mlbm/hr mwtlwct (MWtlvcore) 13 5/5/2010 28.4 37.96 13 6/8/2010 806.7 51.25 13 7/24/2010 1858.0 51.25 13 9/3/2010 2795.0 51.28 13 10/13/2010 3703.1 51.30 13 12/1/2010 4828.5 51.20 13 1/7/2011 5676.2 51.21 13 3/26/2011 7458.0 51.24 13 5/5/2011 8375.9 51.27 13 6/16/2011 9336.3 51.25 13 7/29/2011 10323.4 51.18 13 9/7/2011 11087.6 51.27 13 10/18/2011 12028.8 51.34 13 11/30/2011 13014.5 51.20 13 1/13/2012 13846.9 51.23 13 2/23/2012 14785.5 51.25 14 6/13/2012 71.0 37.64 14 7/25/2012 952.0 58.85 14 9/6/2012 2085.1 59.03 14 10/22/2012 3298.5 58.92 14 12/10/2012 4391.1 59.03 14 1/24/2013 5579.2 58.98 14 3/7/2013 6684.3 58.93 14 4/10/2013 7580.8 58.91 14 5/29/2013 8865.4 37.66 14 7/12/2013 10024.2 58.97 14 8/21/2013 11076.5 59.00 14 10/2/2013 12182.3 58.96 14 11/13/2013 13285.5 58.91 14 12/17/2013 13936.6 58.89 14 1/30/2014 15082.3 58.86 15 6/2/2014 857.2 58.92 15 7/18/2014 2069.8 59.02
GE-PPO-1GYEF-KG1-742 Non-Proprietary Information - Class I (Public) Page 5 of 14 1[
Figure 3 NMP2 Power Flow Map Showing TIP Measurement Cases
- 5. Results of NMP2 TIP Comparisons To provide a basis for trending of the NMP2 TIP statistics, Table 3 provides a comparison of the ratio of the case specific TIP RMS to the average TIP RMS for all NMP2 cases, with values for the bundle (radial), axial, and nodal TIP RMS. This data is displayed as a function of P/F flow in Figures 5, 6, and 7 for the radial, axial, and nodal RMS statistics, respectively. The ratio to the average TIP RMS value is used so as to focus on the trending; however, no specific trending can be established as a function of P/F ratio.
GE-PPO- 1GYEF-KG 1-742 Non-Proprietary Information - Class I (Public) Page 6 of 14 Table 3 NMP2 TIP RMS Statistics Ratio to Ratio to Ratio to Core Core Flow Average Average Average MWd/ST MwerMlbm/hr Bundle TIP Axial TIP Nodal TIP MW(t) RMS RMS RMS 5/5/2010 28.4 6/8/2010 806.7 7/24/2010 1858.0 9/3/2010 2795.0 10/13/2010 3703.1 12/1/2010 4828.5 1/7/2011 5676.2 3/26/2011 7458.0 5/5/2011 8375.9 6/16/2011 9336.3 7/29/2011 10323.4 9/7/2011 11087.6 10/18/2011 12028.8 11/30/2011 13014.5 1/13/2012 13846.9 2/23/2012 14785.5 6/13/2012 71.0 7/25/2012 952.0 9/6/2012 2085.1 10/22/2012 3298.5 12/10/2012 4391.1 1/24/2013 5579.2 3/7/2013 6684.3 4/10/2013 7580.8 5/29/2013 8865.4 7/12/2013 10024.2 8/21/2013 11076.5 10/2/2013 12182.3 11/13/2013 13285.5 12/17/2013 13936.6 1/30/2014 15082.3 6/2/2014 857.2 7/18/2014 2069.8 ]
GE-PPO- 1GYEF-KG 1-742 Non-Proprietary Information - Class I (Public) Page 7 of 14 Figure 4 Trending of Radial TIP RMS vs. Reactor Power / Core Flow
GE-PPO-IGYEF-KG1-742 Non-Proprietary Information - Class I (Public) Page 8 of 14 Figure 5 Trending of Axial TIP RMS vs. Reactor Power / Core Flow
GE-PPO- IGYEF-KG 1-742 Non-Proprietary Information - Class I (Public) Page 9 of 14
[1 Figure 6 Trending of Nodal TIP RMS vs. Reactor Power / Core Flow
GE-PPO-1GYEF-KGI-742 Non-Proprietary Information - Class I (Public) Page 10 of 14 As can be seen from Figures 4, 5, and 6, there is no significant trending with respect to the absolute P/F parameter. The observed TIP variations depend on a variety of factors including plant heat balance and flow calibration uncertainties, uncertainties in the basic cross sections that feed the lattice physics calculations, statistical variations in fuel dimensions and as-built isotopics.
The scatter for the recent operating cycles of NMP2 is similar to that observed in Figure 25-20 of MFN 05-029 (Reference 3). In this MFN letter, Figure 25-19 plots TIP RMS differences vs. P/F ratio for gamma TIP cycles, while Figure 25-20 provides the same information for neutron TIP cycles. As can be seen in Figure 25-20, the radial (bundle) RMS is comparable to the NMP2 value. The NMP2 axial RMS is better than that illustrated in Figure 25-20.
The TIP statistical comparisons for recent cycles of NMP2 are consistent with the information provided to the NRC in 2005 in Reference 3.
- 6. Comparisons Including Plants A, C and D To further augment the NMP2 discussion, TIP comparisons for three additional plants are also included. Table 4 summarizes the TIP RMS statistics for the four plants, in terms of absolute RMS. The plots will continue to use the P/F ratio to the ratio values for the comparative ease of evaluating the trend. As expected, the TIP radial RMS statistics for the neutron TIP based plants are larger than for the gamma TIP based plants.
Figure 7 provides the TIP radial RMS trending as a function of P/F, while Figures 8 and 9 provide the TIP axial RMS and TIP nodal RMS trending. In all cases, there is no apparent trending in the TIP comparisons between measured and calculated results as a function of the P/F metric, and the ranges of values are within the ranges of values previously communicated to the NRC. The TIP radial RMS comparisons are useful as one of the components of the Safety Limit Minimum Critical Power Ratio (SLMCPR) uncertainties. The TIP nodal RMS comparisons provide some hints regarding Linear Heat Generation Rate (LHGR) modeling uncertainties. The TIP axial comparisons, however, are not used in any evaluation of uncertainty components in any safety evaluations, but rather provide hints regarding the agreement of the off-line calculated core average axial power distribution with the measured core average axial power distribution. It should be remembered that any disagreements of the off-line axial core power distributions are removed in the on-line 3DMonicore shape adaption process. If a comparison such as Figure 8 were to be provided for the on-line monitoring system, the TIP axial RMS values would be seen to be near zero, and only a flat line would be seen as a function of P/F.
GE-PPO-1GYEF-KG1-742 Non-Proprietary Information - Class I (Public) Page 11 of 14 Table 4 TIP RMS Statistics for Plants A, B, C, and D (Averaged Over All Cycles)
Radial TIP Type RMSTIP Axial RMSTIP Nodal RMSTIP Plant A Neutron NMP2 Neutron Plant C Gamma Plant D Gamma
((
Figure 7 TIP Radial RMS Trending as a Function of Reactor Power over Reactor Flow
GE-PPO- IGYEF-KG1-742 Non-Proprietary Information - Class I (Public) Page 12 of 14
[1 Figure 8 TIP Axial RMS Trending as a Function of Reactor Power over Reactor Flow
GE-PPO-1GYEF-KG1-742 Non-Proprietary Information - Class I (Public) Page 13 of 14 Figure 9 TIP Nodal RMS Trending as a Function of Reactor Power over Reactor Flow
GE-PPO- 1GYEF-KG 1-742 Non-Proprietary Information - Class I (Public) Page 14 of 14
- 7. Regression Analysis for Trending From the plots, visually it seems clear that there is no trending of the TIP RMS with the P/F ratio. As a very simple statistical confirmation, each of the TIP RMS values was fit as a linear function of the P/F ratio, and the R-squared (R2 ) and R 2 (Adjusted) values are tabulated. R2 can take on any value between 0 and 1, with a value closer to 1 indicating that a greater proportion of variance is accounted for by the model. Table 5 presents the results of this regression analysis.
As is clear, the values of both R 2 and R2 (Adjusted) indicate no statistically significant correlation of the TIP RMS values with increasing values of the P/F ratio.
Table 5 Regression Analysis for Relationship of TIP RMS vs P/F Ratio Linear Fit in the form TIPRMS = Constant + Linear Term
- P/F Ratio Category Constant Term Linear R2 R R(A)
R2 (Adj)
NMP2 Radial vs. P/F NMP2 Axial vs. P/F NMP2 Nodal vs. P/F Four Plants Radial vs. P/F Four Plants Axial vs. P/F Four Plants Nodal vs. P/F ]
In conclusion, with respect to the data and uncertainties presented in this document, there is no significant trending of TIP uncertainty with respect to P/F ratio.
- 8. References 1 GE Hitachi Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains," NEDC-33173P-A, Revision 4, November 2012.
2 "BWR TIP Detector Operational Impacts for Thermal vs. Gamma TIP Detectors" by John P. Rea and John C. Hannah, ANS 2013 LWR Fuel Performance / TOP Fuel, September 15-19, 2013.
3 Letter from Louis M. Quintana (GE Energy) to Herbert Berkow (NRC),
Subject:
Responses to RAIs - Methods Interim Process (TAC No. MC5780), MFN 05-029, April 8, 2005.
ATTACHMENT 4 GENERAL ELECTRIC - HITACHI AFFIDAVIT JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION IN GE-PPO-1GYEF-KG1-742, ENCLOSURE 1 Nine Mile Point Nuclear Station, LLC December 11, 2014
GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Lisa K. Schichlein, state as follows:
(1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), 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 1 of GEH letter, GE-PPO-1GYEF-KGI-742, "GEH Response to the NRC Request for an Update of the TIP Comparisons for Current Operating Conditions," dated December 2, 2014. The GEH proprietary information in Enclosure 1, which is entitled "Updated TIP Comparisons for Current Operating Conditions," is identified by a dotted underline inside double square brackets. ((T.his sentence is anexample....)) Figures and large objects are identified with double square brackets before and after the object. In each case, the superscript notation (3) 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, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.
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 qualifies 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 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that 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 GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;
- b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
- c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
- d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.
Affidavit for GE-PPO- IGYEF-KG 1-742 Pagae I of 3
GE-Hitachi Nuclear Energy Americas LLC (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 GEH, 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 GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH.
(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 for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH 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 or confidentiality agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains details of GEH methodology. These methods, techniques, and data along with their application to the design, modification, and analyses were achieved at a significant cost to GEH.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute a major GEH asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH'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 GEH. 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. GEH's competitive advantage will be lost if its Affidavit for GE-PPO- 1GYEF-KG 1-742 Page 2 of 3
a GE-Hitachi Nuclear Energy Americas LLC competitors are able to use the results of the GEH 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 GEH 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 GEH 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 it true and correct.
Executed on this 2nd day of December 2014.
Lisa K. Schichlein Senior Project Manager, NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road, M/C A-65 Wilmington, NC 28401 Lisa.Schichlein @ge.com Affidavit for GE-PPO- 1GYEF-KG 1-742 Page 3 of 3