ML15092A445
| ML15092A445 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/17/2015 |
| From: | Javorik A Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15092A399 | List: |
| References | |
| GO2-15-035, TAC MF5327 | |
| Download: ML15092A445 (12) | |
Text
F Alex L.. Jeworik Coiwubi Generha" SleOW OWN auPOw4w Pk 61 Wid1.W 90#6294M Propuletry-Withhokl under 10 CFR 23. Ilnea.um t erl 4 conn PROPRtIETARY hnftN-'_on March 17, 2015 G02-1.5-O33 10 CFR 50.90 U.S, Nuclea PAtory Commisslon ATTN: Dmocmn Control Des*
Washington, DC 2o§0555.01
Subject:
COLUUIA GENEANG STATION, DOCKET NO0. 5*
REWONWEE'TO REQUEST FOR ADImONL WO!IIOW FOR UCENSE AUUNDUMtNT REQUW FORt TIOECAL SPC WlC~lqlOW
- CHAN TO AAFME Ui WN E CRIfcA POWER RAIO Refeencm:
- 1) Letter 002-14-139, Dated November 17, 2014, AL Javorik (Energy
), "License Amendment Request for Technical S Change to Safety Umit Minimum i
Power Ratio'
- 2) Email, dated February 27,2015, Andrea George (NRC) to Liua Wiliams (Enerw Norfthwe), "Requ for Additional nformatn: Columbia Geneting Station - LAR to Revive Sft Limit Minimum Crfti Power Ratio (TAC No.
WMF327)
Dear Sir or Madam:
By Reference 1, Energy Northwest submitted for approval a Liese Amendment Request (LAR) for changing the Columbia Generag Station (Columbia) Techncl Specification (TN)
Safety Limit Minimum Critical Power Ratio (SLMCPR).
\\/a Reference 2, the Nucla Regulatory Commission (NRC) submitted Requests for Additional Information (RAts) to Energy Northwt. Enclosure i provides the requested Information. Encosmur I ts considervd proprietary information by Global Nuclear Fuels -
Americes, LLC (GNF). In accordance wfth'10 CFR 2.390(b)(1), an affidavit attesting to the proprietary nature of the enclosed information nd rqueti withholding from public disclosure is included as Enclosure 3. Enclosure 2 is the redacted version of Enclosure 1 provided for public disclosure.
GNF noted a typographical error In the header of their report GNF-001NW6-R3-P, "GNF Additional Informaton Regarding the Requested Changes to the Technical Specifications SLMCPR, Columbia Cycle 23,' submitted as part of Reference 1. Enclosure 4 is the proprietary version of report GNF.001 N866-R3-P, with the typographical error in the header corrected. Enclosure 4 Is considered proprietary wmation by GNF.
RESPONSE TOD MUSS FORA~m AnOITIOw4NOlRmA IQ*
X fOUC MNT R FOR I KHNIS Ill EWES W:NAIM.CfIANGl TO SAFETY Uira IMINO CW1Cft POWER RAT Papgs*2at In aoOoPian66 with 10 CFA ?.390(b)(1), "in miti &ttstng to p p etaty n*re of th enclosedinformatio r
t withholding from public disclosure is included In the fitt few pages of Enclosure 4. Enclosure 5 isth redacted version of Enclosure 4 with the typographical error In the header corroeced for public disclosure.
This letter and Its enclosures contain no regulatory commitments.
If there are any questions or If additional information Is needed, please contact Ms. L.L.
Williams, Licensing Supervisor, at 509-377-8148.
I declare under penaly of perjury that the frgon is true and corect Executed this.~ o i//(6, 11, t NRCNRPrecMaar NRC 8lo Reidn hwpectri6, C Sonoda - BPN139 (smnal) without Enclosures land 4 ESFEC (eml) wthout Enclosures 1 and 4 RFR Cowle-WOH (emal) without Enclosures I1 and 4 WA Horn - Winston & Strown withot Enclosures 1 and 4
RESPONSE TO REQUEST FOR ADDiTIONAL INFORMATION FOR LICENSE AMEN I REQUEST FOR TECHNICAL ICAlTON CHANGE TO SAFEMY LIMT NW" CRI~CAL POWER RATIO fle spa[ iI*,WFN
- foCI18,
VSP-ENW-KKI 015 Nonlropriety Informatim -Cka ! (Public)
Page of 5 By lte dated November 17, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession Package No. ML14336AI00), Energy Northwest (the licensee) submitted a license amendment request to modify the Technical Specifications to revise value, for the Sft, Limit Minimum Critical Power Ratio (SLMCPR, or MCPR) at Columbia Generating Station (CGS). This proposed andment would modify the SLMCPR values in TS 2.0, Sfety Limits (SLs)," due to core loading fuel maagement changes for the upcoming operating cycle at CGS.
Based on the review of the license anmendment request (LAR), the NRC staff has determined that additional information is required to complete its review, as stated below.
VSP-W-KI 5-01
.Proristay fonnatio - Class i (Publc)
Page 2 of 5, Table 3 of GNF.001NB89-R3, Additonal Infornation Regarding the Roquesd Chges to the Technical Specifications SLMCPR, Columbi Cycle 23" (publicly available: portions at ADAMS Accession No. MLt4336A007) shows 9 -significant change in MCPR Importance Parameter (MMP). Pleas describe:
a) Why the cumnmt cycle core design results in a significant flattening of the bundle'by-bundle MCPR distribution; b) How this may affibt selection of the limiting rod pattern ued t evaluate the SLMCPk; c) How these effects may have been considered during the most recent evaluation of the MIP criterion by General Electri-Hitachi Nucleam Energy Americas, LLC (GEH).
d) If these effects were not considered during the most recent evaluation of the MIP criterion, please provide the technical basis for considering that the calculation based on the current core design and plumed opeming strategy is using tly limiting rod pattern(s).
,.S-Am-a) The Global Nuclear Fuel - Americas (GNF) document number on the cover page (page 1) of the document "GNF Additional Information Regarding the Requested Changes to the Technial Specification SLMCPR, Columbia Cycle 23" has the correct document number GNF-001N8896-R3.
However, the document number on the rest of the pages of this document has a typo on the page header. It should have read GNF-001N896-R3 rather than GNF-001N8869-R3.
The current cycle core loading design inherently has a flatter radial power shape than the previous cycle core loading design. This is due to the different fresh bundle designs. The current cycle fresh bundle designs are loaded radially in emrichment (highest enrichment further away from the center) while the previous cycle fresh bundle designs were not. Given a core loading design with a flatter radial power shape, the limiting rod pattern will tend to place more bundles near the target Operating Limit Minimum Critical Power Ratio (OLMCPR). More bundles being placed by the limiting rod pattern near the target OLMCPR will then mathematically result in a larger MIP value (See the equations in Section 4.2 of NEDC-32601P-A). Besides, the limiting case rod pattern for Cycle 23 had all-rods-out, which tends to maximize the radial power flattening effect. The limiting case for Cycle 22 used blades inserted in the outer portion of the core, which tends to produce a less flat distribution than all-rods-out.
b) The selection of the limiting rod pattern is described in Section 4.2 of NEWC-32601P-A.
The selection of the limiting rod pattern is not based on an evaluation of the flatness of the radial power shape. However, an inherent flatter radial power shape will result in a limiting rod pattern (which is consistent with Section 4.2 of NEDC-32601P-A) producing a power
VSP-ENW-KKI-15-018 NoaP ro y W rmaion -Class I (Pubic)
Page 3 of 5 distribution that yields more bundles near the target OLMCPR.
c) GEH does not consider the current cycle core design flatter radial power shape to be outside the basis used to ensure the MIP criteria provides an objective criterion for determining the validity of a cycle specific SLMCPR limiting rod pattemn.:, ý I d) As stited in Section 2.5 of GNF-0N8M896-R3, the Nuclear Reg loory IComission's (NRC's) Safety Evaluation (SE) for NEDC-32694P-A pr*ide four actinsto Iollow (one of which involves review of the MIW criterion'for applicability to fuel design and operating strategies) and were found acceptable by the NRC for the GNF2 fuel design. GEH does not consider the current cycle core design flatter radial power shape to be outside the bases for that aceopteuce. This is because the limiting rod patmern will still place more bundles nearer the target OLMCPRIuan nomina rod patterns and hence will result in a bounding SLMCPR calculation as disdussed in Section 4.2 of NEDC-32601 P-A.
i
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VSP-ENW-KKI 018 Non-Proprietary Information -Class I (Public)
Page 4 of"5 The current cycle will be the first core loading GNF2 fuel at CGS. Section 2.7 of NEDC-32601P-A, "Methodologies and Uncertainties for Safety Limit MCPR Evaluations,"
August 1999 (non-publicly available), indicates that the channel flow area uncertainty` is calculated based on variables that are dependent on the fuel design. Please confirm that the value given in GNF-001NA869.R3, which matches the value calculated in NEC-32601 for GE12 fuel, remains applicable for the newer feel design.
The flow area uncertainty calulation is baed upon the fully rodded zaoe in the lower portion of the bundle. The component dimensions of interest we the fuel rod Outside Diameter (OD1), the water rod OD and the channel box ID. The GEI2, GE14, and GNF2 designs all have 92 fuel rods with the same nominal OD and two water rods with the same nominal OD. The GNF2 channel box nominal Inside Diameter (ID) is slightly larger than the GE12/14 channel box1.
The flow area uncertainty for GNF2 is ((
]I when calculated as described in Section 2.7 of NEDC-32601P-A.
Additionaly, the GE12/14 flow area uncertainty is calculated to be If
)). The increase from GNF2 to GEl2/14 is due to the fuel rod OD tolermce being slightly larger for GNF2 than for GE12/14. The reason that the GEl2/14 flow area uncertainty is larger than the ((
1] value documented in NEDC-32601P-A is that the earlier calculation for GEl2 used a smaller fuel rod OD uncertainty derived from manufacturing data. The current analysis uses a fuel rod uncertainty derived firm the tolerances on the fuel rod, to be consistent with the description in NEDC-32601P-A.
Since the re-calculatwd flow area uncertainties for GE14 and GNF2 both exceed the standard uncertainty of ((
)), the SLMCPR calculation for CGS Cycle 23 was re-analyzed using a bounding value of ((
- 11. No other changes were made. The rounded SLMCPR results (1.10 for Two-Loop Operation (TLO) and 1.13 for Single Loop Operation (SLO)) are unchanged. The TLO and SLO Monte Carlo SLMCPR results increased by only 0.001. This is below the threshold of an effect that is considered potentially significant (0.005). These results are also consistent with earlier sensitivity studies that ((
1] in SLMCPR.
It should be pointed out that the formula for calculating the flow area uncertainty shown in NEDC-32601P-A Equation 2.6 determines the total flow area uncertainty as a sum of the uncertainties of the three types of components (fuel rods, water rods, and channel box). This is a very conservative approach compared to the usual engineering practice of determining the total uncertainty of system components with a Square Root of the Sum of the Squares (SRSS) method, 1 1[
)).
u5 age5of 5 as is used elsewhere in NEDC-32601P-A (e.g., for feedwater flow, feedwater temperature, and reactor pressure in Sections 2.2, 2.3, and 2.4, respectively).
Using the SRSS method, the flow area uncertainty is deternined to be [f 1] for GNF2 and ((
)) for GEl2/14. Note that in this approach (and all those discussed above) GNF has maintiund the very conservative assuption that the total uncerainty mn the area ofthe fuel rods is 92 times the uncertainty of the area of a single rod. Using a standard SRSS technique on the fuel rods would reduce the fuel rod area unet*n by a factor of the square mot of 92 and lead to further reduction In the total flow area uncertairy. For these reaons, GNF concludes that the currently approved flow ara uncertainty of[
remains appopift for GE14 and GNF22.
2 The GE12 product line is no longer m
mufbct urd an is no longer In ervice in the U.S.
RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION FOR LICENSE AMENDMENT REQUEST FOR TECHIC4AL SPECIFICATION CHANGE TO SAFETY LIMIT MINIMUM CRITICAL POWER RATIO Enlourm 3 VimfoNWKK.1m I for ncloureI
Global Nuelcar Fed,- Amern'ca.
AFflDAVIT I, Lakas Trommasda state as follows:
(1) 1 am the Engineering Manage, ReloaO Design andAnalysis, Global NwclearFuel-Americas, LLC (GNF-A), and have bee* delegated the fiaction of reviewing the infamation described i;a paýg (2) which is sought to be wiMthe apd hpq beon autoized toaMl for its withholding.
(2) The nfomiation sought t be witheld is coatained in Enclosurem o
N' etr VSP-ENW-KKI-15-013, Vickie eirry (GNF-A) to Miguel Armenta (Enegy Northweit),
entitled "GNF Response to NRC RAhs for Columbia Cycle 23 SLMCPR Submittal and Corrected SLMCPR Technical Specification Report," dated March 13, 2015.
QNF.-A proprietary informaton in Enclosure 1. which is entitled "Response to NRC RAIs for Columbia Cycle 23 SLMCPR Submittal," is identified by a dotted underline inside double square bucket
[
Figures and some tables containing ONF-A proptiary nformation e identified with double square brackets before and after the object In each case, the smperscript notation ") refers to Pararp (3) of this aflfdavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary infofrpation of which it is the owner or licensee, GNF-A relies upon the exemption from diloso set fomth in the Freedom of0lformatdon Act ("FOIA"), S USC Sec. 552(bX4), and the Trqdi Secrgis Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(aX4), and 2.390(aX4) for trade secw%
(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 rms for purposes of FORA Exemption 4 in, respectively, Crta M Ener Project v. Nuclear Re&jltorv Coytssion. 975 F.2d 871 (DC -Cir.1 1992), sand bUk (Ci~t~Hafht GBOmzuM
- v. FDA. 704 F.2d 1280 (DC Cit. 19133)
(4) Some examples of categories of information which fit into the definition of proprietary information are:
formation that discloses a process, method, or apparatus, including supporting Aata and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advmntage over other companies;,
- b. Information which, if used by a cqmpetitor, would reduciefhis epnitr freore or improve his competitive position ih the desigmanucture shipmenti, isallation, assurance of quality, or licensing of a similar product
- c.
Information which reveals aspects of past, present or future GNF-A customer-finided development plans and programs, resulting In pitential products to GNF-A;
- d.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protectibn.
VSP-ENW-KKI-l5-0l8 Enclosure I Affidavit Page I of 3
The indfrmation sought. to be withheld is considered to be proprietary for the reasons set forth in par*
ps (4) and (4)b. above.
(5) To address 10 CFR 2.390 (b) (4), the informion sought to be withheld is being submitted to AC MM 1hi (iN u
Sofasrt Cid kiyhd uco*fde T
by ONE-A, and is it fa to held. Th iformation sought t *e*withheld a to the 6est of my knowledge gad belief, consistently'been held in cotifidence by GNF-A, no poblic disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittal. to NRC, have been made, or must be made, pursuant to regulatory provisions or, proprietary agrement which provide fof 'Maintenance of the infornmaton in confidene.
Its initial designation as propietr informatio nudth subsequent steps tkn to prevent its unauthorized disclosure, am 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 ifmatio 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 much a document typically requires review by the staff mamager, project manaer, principal scientist or other equivalent authority, by the manager of the cognizant marketing fmction (or his delegate), and by the Legal Operation, for whaical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outse NE,A* are limited to regulatory bodies, customers, and potential customers, and their
- "ts s4piv sanliessndohr with a legitimate need for the Wnonation, a.d then only in w dance with appropriate regulatory provisions or proprietary agreements.
(8) The inf*tmation idente in paagraph (2) is clmified as propriegay because it contains details of GNF-A's fuel design and lcensing methodology.
The development of this methodology, along with the testing "development and approval was achieved at a signficant cost to GNF-A.
1..
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 port 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-ENW-KKl-15-018 Enclosure I Affidavit Page 2 of 3
The precise'valu of the cxpertwis to der~se ad eval in process itd apl ch c(rct analytical meth6dolg is difiult to quantify, but it clearly is substantial.
GNF-A's compatitive adva will be lost if its competitors am 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 undm ling by demomsrating 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 avakb 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 is true and corrt.
Executed on this 13th day of Mach 201S.
Lukas Trosman Engineeing Manager, Reload Design and Analysis Global Nuclear Fuel - Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 Lukas.Trosman@gnf.com VSP-ENW-KKI-15-018 Enclosure 1 Affidavit Page 3 of 3