ML16189A104
| ML16189A104 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/30/2016 |
| From: | Mark D. Sartain Dominion Nuclear Connecticut |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 16-242 | |
| Download: ML16189A104 (25) | |
Text
Dominion Nuclear Coooecticut, Inc.
5000 Dominion Boulevard, Glen Al len. VA 23060 Web Address: www.dom.com PROPRIETARY INFORMATION WITHHOLD UNDER 10 CFR 2.390 June 30 , 2016 U.S. Nuclear Regulatory Commission Serial No.16-242 Attention : Document Control Desk NRANVDC RO Washington , DC 20555 Docket No. 50-423 License No. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNIT 3 PROPOSED EXEMPTION REQUEST FOR THE USE OF AXIOM CLADDING MATERIAL IN LEAD TEST ASSEMBLIES Pursuant to 10 CFR 50.12, Dominion Nuclear Connecticut, Inc. (DNC) requests an exemption from certain requirements of 10 CFR 50.46 , "Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors," and Appendix K of 10 CFR 50, "ECCS Evaluation Models" for Millstone Power Station (MPS) Unit 3 (MPS3). The exemption requested relates solely to the specific types of cladding material specified in these regulations for use in li~ht water reactors. As written , the regulations presume the use of Zircaloy or ZIRLO M fuel rod cladding . In order to use AXIOM cladding for lead test assemblies (LTAs), a limited exemption to these regulations is needed.
DNC requests an exemption from these requirements to allow up to eight (8) LTAs containing fuel rods fabricated with AXIOM cladding . The exemption request is required since the metallurgical content of the AXIOM material is outside the metallurgical content of cladding types approved for use at MPS3 (i.e., Zirc-4, ZIRLO, or Optimized ZIRLO'). The exemption request is provided as Attachment 1. contains information proprietary to Westinghouse Electric Company LLC.
An Affidavit signed by Westinghouse, the owner of the information, is provided in . 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 in Attachment 1, which is proprietary to Westinghouse, be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commission's regulations. The non-proprietary version of the exemption request is provided in Attachment 2.
The LTAs are planned to be initially inserted into MP3 Cycle 19 core (M3C 19) in non-limiting core locations during the next refueling outage. The refueling outage is currently scheduled for fall 2017 . DNC requests approval of the proposed exemption request by June 30, 2017 to support the core design for the M3C 19 core reload .
Attachment 1 contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation from Attachment 1, this letter is decontrolled.
Serial No.16-242 Docket No. 50-423 Page 2 of 3 If you have any questions regarding this request, please contact Ms. Wanda Craft at (804) 273-4687.
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D.
Sartain, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.
- Acknowledged before me this 3Ji1day of cJ/:Lo (, , 2016.
5 -3 I - I R .
My Commission Expires:
(/,~k i. J(uu_
Notary Public Attachments:
- 1. Request for Exemption From the Provisions of 10 CFR 50.46 and 10 CFR 50 Appendix K to Allow Use of AXIOM High Performance Fuel Cladding Material in Eight Lead Test Assemblies) (Proprietary)
- 2. Request for Exemption From the Provisions of 10 CFR 50.46 and 10 CFR 50 Appendix K to Allow Use of AXIOM High Performance Fuel Cladding Material in Eight Lead Test Assemblies) (Non-Proprietary)
- 3. Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-16-4431, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
Commitments made in this letter: None
Serial No.16-242 Docket No. 50-423 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 R. V. Guzman Senior Project Manager - Millstone Power Station U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 C2 Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director, Radiation Division Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 1 of 13 Attachment 2 Request for Exemption From the Provisions of 10 CFR 50.46 and 10 CFR 50 Appendix K to Allow Use of AXIOM High Performance Fuel Cladding Material in Eight Lead Test Assemblies (LTAs)
(NON-PROPRIETARY)
DOMINION NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNIT 3
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 2 of 13 Purpose Dominion Nuclear Connecticut, Inc (DNC) requests an exemption from the provisions of 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems (ECCS) for Light-water Nuclear Power Reactors," and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models," to allow the use of AXIOM' High Performance Fuel Cladding Material in lead test assembly (LTA) applications for Millstone Power Station Unit 3 (MPS3). The regulations in 10 CFR 50.46 contain acceptance criteria for the ECCS for reactors that have fuel rods fabricated only with Zircaloy or ZIRLO High Performance Cladding Material. Concurrently, Appendix K to 10 CFR Part 50, paragraph l.A.5, requires that the Baker-Just equation be used to predict rates of energy release, hydrogen generation, and cladding oxidation from the metal-water reaction in the core. -
The Baker-Just equation assumes the use of a zirconium alloy different than the AXIOM material. Therefore, an exemption is required from both 10 CFR 50.46, and 10 CFR Part 50, Appendix K to support the use of AXIOM fuel rod cladding at MPS3. This exemption request relates solely to the specific cladding material identified in these regulations (i.e., fuel rods with Zircaloy or ZIRLO cladding) and will provide for the application of 10 CFR 50.46 and 10 CFR Part 50, Appendix K acceptance criteria to fuel assembly designs using AXIOM fuel rod cladding at MPS3. This document requests exemption from 10 CFR 50.46 and 10 CFR Part 50, Appendix K. Insertion of the LTAs in the MPS3 reactor will be evaluated following the 10 CFR 50.59 process.
Background
As the nuclear industry pursues longer operating cycles, with increased fuel discharge burnup and fuel duty, the corrosion performance requirements for nuclear fuel cladding become more demanding. AXIOM material is being developed to be more resistant to accelerated corrosion than ZIRLO or Optimized ZIRLO' cladding, while meeting all fuel design criteria. In addition, fuel rod internal pressures (resulting from the increased fuel duty, use of integral fuel burnable absorbers, and corrosion/temperature feedback effects) have become more limiting with respect to fuel rod design criteria. Reducing the associated corrosion buildup, and thus, minimizing the temperature feedback effects, provides additional margin to the fuel rod internal pressure design limit.
AXIOM cladding variants have been included in past Lead Test Rod (LTR) programs for Virgil C. Summer Nuclear Station (References 1 and 2) and Byron/Braidwood Nuclear Power Plants (References 3 and 4) that included lead rod average burnups up to 75,000 MWD/MTU. A final AXIOM alloy composition was selected based on the results observed in these LTR programs. From this point forward, reference to AXIOM cladding refers to the final selected material composition. To improve the experience base for the AXIOM cladding material and gain additional material performance data, the reloads for MPS3 starting with Cycle 19 would contain LTAs with 264 fuel rods in each assembly AXIOM, Optimized ZIRLO, and ZIRLO are trademarks or registered trademarks of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademarks or registered trademarks of their respective owners.
- Serial No.16-242 Docket No. 50-423 Attachment 2, Page 3 of 13 comprised of the AXIOM cladding material. There is sufficient flexibility within the Technical Specification (TS) for MPS3 to allow the use of AXIOM fuel rod cladding for LTA applications provided a limited number of LTAs are inserted and are in non-limiting locations. The LTAs are planned to be operated for up to three cycles and would remain within the fuel rod cladding methodology and plant licensed burnup limit.
Technical Justification of Acceptability The chemical composition of the AXIOM alloy is provided in Table 1 with comparisons to ZIRLO, which is processed to be stress relief annealed (SRA), and Optimized ZIRLO alloy. AXIOM alloy is a niobium-bearing zirconium alloy like ZIRLO alloy with reduced tin content to further reduce corrosion. Similar to Optimized ZIRLO cladding, AXIOM alloy is processed to be in the partially-recrystallized annealed (pRXA) condition to provide creep resistance superior to that of ZIRLO and Optimized ZIRLO cladding while allowing for the further reduction in tin content. In addition to the major alloying elements of niobium and tin, copper and vanadium are added to AXIOM alloy to improve specific properties such as reduced hydrogen pickup.
Table 1: Nominal Chemical Composition and Microstructure of AXIOM, ZIRLO and Optimized ZIRLO Alloys Alloy Micro- Nb Sn Fe Cu v Zr Structure (wt%) (wt%) (wt%) (wt%) (wt%) (wt%)
Optimized ZIRLO pRXA 1 0.67 0.1 Bal.
AXIOM pRXA 0.7 0.35 0.1 0.12 0.25 Bal.
The LTAs will be typical production fuel assemblies with the exception of the cladding material. The fuel skeleton design and structural materials will be identical to those of the resident fuel in the core. A maximum of eight AXIOM cladding LTAs will be inserted.
Setting the number of LTAs with AXIOM rods to this level allows for a variety of loading patterns and power histories to be obtained for prototypical fuel patterns while restricting the total number of test assemblies to a small percentage of the core.
Westinghouse and DNC will perform evaluations of the lead test assemblies during the program development phase as part of the operating cycle design process. These evaluations will include the pertinent testing and analysis necessary to address safety, including mechanical, neutronic, thermal-hydraulic, transient and loss-of-coolant accident, as well as the design of the lead test assemblies.
The DNC method for demonstrating compliance with the MPS3 TS 5.3.1 requirement of non-limiting locations is the maintenance of F~H margin between the AXIOM LTAs and the limiting resident fuel product in the reload core designs to ensure a reduction in total peaking factor (Fa). Maintaining approximately 2-3% F~H margin between the AXIOM LTAs and the resident fuel product is expected to be sufficient to ensure non-limiting performance for the AXIOM LTAs. The exact amount of F~H margin to be retained to
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 4 of 13 ensure non-limiting performance for the AXIOM LTAs will be determined as part of the cycle specific reload calculations. DNC will comply with the MPS3 TS 5.3.1 requirement of non-limiting core regions by confirming the F~H margin as part of the cycle-specific reload calculations.
Prior to each cycle, the LTAs will be evaluated to ensure that current design criteria are met for the projected burnup. Current NRG-approved models will be conservatively applied to bound AXIOM cladding material properties and expected behavior. If any current design criteria are not met, the AXIOM cladding LTAs will not be inserted into the core.
The current licensed fuel performance code predictions will be compared to post-irradiation examination data collected for the AXIOM cladding. If significant deviations exist between the code predictions and the observations, the affected assemblies will not be reinserted, and a replacement assembly will be inserted until the deviations are understood. Since the AXIOM material is similar to currently licensed materials (e.g.,
Optimized ZIRLO cladding), the actual performance is expected to be bounded by the predictions obtained from the licensed fuel performance codes.
The lead test assemblies will be evaluated mechanically with respect to existing design criteria governing the design of the fuel assembly. The same methods used for the current fuel assemblies will be applied to the lead test assemblies. A fuel rod design evaluation will be performed for the lead test assemblies. This evaluation will show that the fuel rod design criteria and applicable fuel rod design limits will be met. No new or altered design limits for purposes of 10 CFR 50, Appendix A, General Design Criterion 10, "Reactor Design" are required for this program.
For the mechanical evaluations, the three primary areas impacted by the use of AXIOM fuel cladding are the basic material properties, corrosion, and irradiation creep and growth.
Basic Material Properties An out-reactor characterization program has been conducted on AXIOM alloys, with material properties tested over multiple lots.
Density The density of AXIOM cladding material has been measured directly and shown to be comparable to ZIRLO cladding and Optimized ZIRLO cladding. Existing models for density which are applied to ZIRLO cladding may also be applied to AXIOM cladding.
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 5 of 13 Thermal Expansion Thermal expansion measurements on AXIOM cladding material have demonstrated that the thermal expansion behavior of AXIOM cladding is consistent with that of ZIRLO cladding. Existing models for thermal expansion of
- ZIRLO cladding may also be applied to AXIOM cladding.
Thermal Conductivity Thermal conductivity of zirconium alloys *is weakly affected by the alloy composition. Therefore, the existing models for ZIRLO cladding are applied to model the behavior of AXIOM cladding material.
Specific Heat The specific heat of AXIOM cladding has been measured and shown to be comparable to ZIRLO and Optimized ZIRLO cladding. As expected for all zirconium materials, the occurrence of the a-phase to 13-phase produces a discontinuity. (peak) in the curve of specific heat versus temperature. The a-phase to 13-phase transition peak sizes and locations are comparable between ZIRLO, Optimized ZIRLO and AXIOM cladding.
Elastic (Young's) Modulus and Poisson's Ratio The elastic modulus of zirconium alloys is a fundamental property of the interatomic forces which exist between the zirconium atoms that make up the bulk of the material. The presence of dilute amounts and varying concentrations and types of alloying elements do not readily affect the elastic properties of the material. Similarly, the Poisson's Ratio is also effectively the same for all dilute zirconium alloys.
Phase Transition Temperature The occurrence of the a-phase to 13-phase produces a discontinuity in the*
specific heat which is expected for all zirconium materials. The temperature ranges where the phase transition occurs are similar for AXIOM cladding, ZIRLO and Optimized ZIRLO cladding.
Tensile Strength AXIOM cladding material is made with a partially re-crystallized microstructure which consists largely of [
]a,c Tin serves. as a solid solution strengthening alloying addition; however, its concentration has been reduced relative to the Optimized ZIRLO alloy to further improve corrosion performance. As such, AXIOM cladding material has different tensile (yield and ultimate) strength properties.
The processing of AXIOM cladding material includes a final anneal that is designed to improve the cladding creep resistance. This annealing also removes some of the cold-work from the manufacturing process, [
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 6 of 13 Corrosion Irradiation experience has been obtained for over one hundred AXIOM alloy lead test rods (LTRs) in a variety of reactors worldwide, including five commercial reactors and two test reactors. High burnup experience (over 70 GWd/MTU) has been obtained from most of the LTR campaigns. Pool side post-irradiation exams (PIEs) have been conducted after each cycle (including both 12-month cycle and 18-month cycle). In-reactor performance data including corrosion, creep, and growth are available for AXIOM alloy rods in a range of burnup from about 10 GWd/MTU to over 70 GWd/MTU.
Comprehensive hotcell examinations have been conducted on AXIOM alloy high burnup rods over 70 GWd/MTU.
The composition of AXIOM cladding has been designed to improve corrosion performance and reduce the resulting pickup of hydrogen within the cladding material.
The improved corrosion performance has been successfully demonstrated by
- an extensive lead test rod campaign. The oxide data in Figures 1 and 2 indicate that AXIOM and Optimized ZIRLO rods are similar in corrosion performance to those for ZIRLO rods at low burnups of about 20-30 GWd/MTU. At higher burnups, the advantage of the AXIOM alloy over Optimized ZIRLO and ZIRLO cladding becomes significant. The oxide levels for AXIOM alloys remain relatively flat over the entire burnup ranges. The oxide thickness of the AXIOM alloys are less than 50 µm for a Modified Fuel Duty Index (MFDI) of over 1000 and burnup of about 70 GWd/MTU. The MFDI is a way of expressing the corrosion duty as a function of the time-averaged rod surface temperature, the total irradiation time and the total boiling mass evaporated.
Therefore, corrosion data as a function of MFDI more accurately captures the corrosion performance difference of the rods experiencing different fuel duties at diverse plant operating conditions (Reference 5).
Figure 3 gives the calculated hydrogen content in the metal for AXIOM cladding, ZIRLO and Optimized ZIRLO cladding. The results from hotcell tests confirmed the very low hydrogen pickup for AXIOM alloy due to the combination of low maximum oxide thickness and low hydrogen pick up ratio. [
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 7of13 CD CD E
0 120 100
<> Optimized ZIRLO u
- -E
- en en 80
- AXIOM
~ 60
~
u
- -.r:. 40
~
Cl>
"C 20 0
0 10 20 30 40 50 60 70 80 Burnup (GWd/MTU)
Figure 1: Rod Peak Oxide Thickness as a Function of Burnup
-,_ 140
-Cl>
Cl>
E 0
120
<> Optimized ZIRLO u 100
- AXIOM
-E en en 80 Cl>
c
~ 60 u
.r:.
~ 40 Cl>
"C
")( 20 0
0 0 200 400 600 800 1000 1200 Modified Fuel Duty Index (MFDI)
Figure 2: Rod Peak Oxide Thickness as a Function of Modified Fuel Duty Index (MFDI)
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 8of13 E 1200 Q.
Q. ZIRLO Data
~
...c.. 1000
- Optimized ZIRLO * *
...c G> 800
- AXIOM 0 *
- 0 600
- c
- G>
C) 0
~
400
- c
-... 200
~
G> 0 0.0
- 20.0 40.0 60.0 80.0 100.0 Oxide Thickness, um Figure 3: Hydrogen Content AXIOM, Optimized ZIRLO and ZIRLO Alloys as a Function of Oxide Thickness.
Irradiation Creep and Growth The creep resistance of AXIOM cladding material has been improved through optimization of the final heat treatment to produce a partially recrystallized microstructure, as well as alloy chemistry modification. Overall , AXIOM cladding has a steady-state creep rate that is less than 80% of the rate that is observed for Optimized ZIRLO and ZIRLO cladding . This has been validated through in-pile experimental results as part of the Westinghouse Vogtle Creep and Growth Program where AXIOM cladding samples were operated to burnup equivalents over [
]a,c For the LTA design , a conservative model will be used in the fuel rod design evaluation .
Table 2 below compares the creep and growth behaviors of AXIOM alloy, Optimized ZIRLO alloy and ZIRLO alloy at the same hoop stress level of approximately -66 MPa.
These samples were irradiated in the same assembly for one cycle.
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 9 of 13 Table 2: Irradiation Creep and Growth Results after 1 cycle of Operation at Hoop Stress of Approximately -66 MPa AD/Do irradiation creep AL/Lo irradiation growth Alloy diameter strain normalized axial strain normalized to to ZIRLO Cladding ZIRLO Cladding ZIRLO 1.00 1.00 Optimized ZIRLO 0.92 0.71 AXIOM 0.59 0.40 Lead test rod data in Figure 4 has shown that AXIOM cladding material offers comparable growth to both ZIRLO and Optimized ZIRLO clad fuel rods for burnups up to 55 GWD/MTU. AXIOM cladding continues to show stable growth behavior for burnups beyond 70 GWd/MTU with no indications of instability in growth trends.
1.0 ~-----------------------~
0.9 4 ZIRLO 0.8 + Optimized ZIRLO 0.1
- AXIOM
-'i
~
0
.c 0.6 0.5 0.4 e
(!) 0.3 0.2 0.1 0.0 +-----~L----..----..---.....---.....---.....---~------1 0 2 4 6 8 10 12 14 16 Neutron Fluence (10 21 n/cm2)
Figure 4: AXIOM, Optimized ZIRLO and ZIRLO Fuel Rod Growth as a Function of Fast Neutron Fluence
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 1O of 13 Nuclear Design Evaluations The impact of the lead test assemblies on nuclear design will be evaluated. The standard reload methodologies can be used to model the lead test assemblies. The features of the lead test assemblies do not challenge the validity of the standard reload methodologies. The LTAs will be placed in non-limiting locations. Standard reload methodologies will be used for reloads containing the lead test assemblies.
The AXIOM cladding and Optimized ZIRLO cladding have very similar neutronic characteristics since over 98% of the cladding is zirconium. The small changes in the alloying elements between AXIOM and Optimized ZIRLO alloys have a negligible impact on the neutronic characteristics of the cladding when analyzed during the nuclear design evaluation.
Thermal-Hydraulic and Safety Analysis Evaluations For the AXIOM LTA program at MPS3, the only change to the resident fuel product is the use of the AXIOM fuel rod cladding material instead of Optimized ZIRLO. There are no other changes to the structural materials, grid design, or overall design of the resident Westinghouse RFA-2 fuel design utilized at MPS3. The small changes in the alloying elements between the AXIOM and Optimized ZIRLO alloys are expected to have a negligible impact on the thermal-hydraulic characteristics of the cladding when analyzed during the thermal-hydraulic and safety analysis evaluations.
Thermal-hydra1,.11ic and safety analysis evaluations of loss-of-coolant accident (LOCA) and non-LOCA transients will be performed for the lead test assemblies as part of the normal reload process. Standard thermal-hydraulic and safety analysis methodologies will be used for reloads containing the lead test assemblies. These evaluations will confirm that the lead test assemblies are bounded by the current analyses of record.
Westinghouse has performed preliminary high temperature steam oxidation tests on AXIOM cladding and confirmed that AXIOM cladding exhibits a ductile response to ring compression tests for equivalent cladding reacted (ECR) values up to and beyond
[ re. Figure 5 below shows the offset strain versus the calculated Cathcart-Pawel equivalent clad reacted (CP-ECR) for as-fabricated AXIOM cladding oxidized at target peak clad temperature (PCT) of 1200°C. The offset strain is averaged over the data with the same CPECR values.
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 11 of 13 a,c Figure 5: Average Offset Strain vs Calculated CP-ECR for As-Fabricated AXIOM Cladding Oxidized at Target PCT of 1200°C Justification of Exemption 10 CFR 50.12, "Specific exemptions," states that the NRC may grant exemptions from the requirements of the regulations of this part provided two conditions are met. They are: 1) the exemption is authorized by law; the exemption will not present an undue risk to the health and safety of the public; and the exemption is consistent with the common defense and security; and 2) the Commission will not consider granting an exemption unless special circumstances are present.
The requested exemption to allow the use of AXIOM fuel rod cladding material for LTA applications at MPS3 in addition to Zircaloy or ZIRLO material as specified in the listed regulations satisfies these criteria as described below.
Condition 1:
- 1. This exemption is authorized by law As required by 10 CFR 50.12 (a)(1),* this requested exemption is "authorized by law." The selection of a specified cladding material (i.e., fuel rods with Zircaloy or ZIRLO cladding) in 10 CFR 50.46 and implied in 10 CFR Part 50, Appendix K, was adopted at the discretion of the Commission consistent with its statutory
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 12 of 13 authority. No statute required the NRC to adopt this specification. Additionally, the NRC has the authority under Section 50.12 to grant exemptions from the requirements of Part 50 upon showing proper justification. Note that MPS3 is not seeking an exemption from the acceptance and analytical criteria of 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The intent of this request is solely to allow use of the criteria set forth in these regulations for application to the AXIOM fuel rod cladding material.
- 2. This exemption will not present an undue risk to public health and safety The reload evaluations will ensure that acceptance criteria are met for the insertion of LTAs with fuel rods clad with AXIOM material. Due to similarities in the composition of the AXIOM alloy and the Optimized ZIRLO and standard ZIRLO alloys, fuel assemblies using AXIOM fuel rod cladding will be evaluated using plant-specific models to address the changes in the cladding material properties. The safety analyses for MPS3 are supported by the applicable site specific TS. Reload cores are required to be operated in accordance with the operating limits specified in the TS. Thus, the granting of this exemption request will not pose an undue risk to public health and safety.
- 3. This exemption is consistent with common defense and security As noted above, this exemption request is only to allow the application of 10 CFR 50.46 and 10 CFR Part 50, Appendix K to allow testing of an improved fuel rod cladding material. All
- the requirements and acceptance criteria will be maintained. The special nuclear material in these assemblies is required to be handled and controlled in accordance with approved procedures. Use of LTAs with AXIOM fuel rod cladding in the MPS3 core will not affect plant operations and is consistent with common defense and security.
Condition 2 Special circumstances support the issuance of an exemption 10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption to the regulations unless special circumstances are present. This exemption request meets the special circumstance criteria of 10 CFR 50.12(a)(2)(ii), "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." For MPS3, application of the subject regulations is not necessary to achieve the underlying purpose of the rule.
10 CFR 50.46 identifies acceptance criteria for ECCS performance at nuclear power plants. Westinghouse will perform an evaluation of the MPS3 core using Loss of Coolant Accident (LOCA) methods approved for the site to ensure that assemblies with AXIOM fuel rod cladding material meet all LOCA safety criteria.
The intent of 10 CFR Part 50, Appendix K, paragraph l.A.5 is to apply an equation that conservatively bounds for rates of energy release, hydrogen generation, and cladding oxidation from a metal-water reaction (i.e., the Baker-Just equation). Due to the similarities in the composition of the AXIOM alloy and the Optimized ZIRLO and
Serial No.16-242 Docket No. 50-423 Attachment 2, Page 13 of 13 standard ZIRLO fuel rod cladding materials, application of the Baker-Just equation is anticipated to be applicable for the AXIOM alloy.
Conclusion The acceptance criteria and requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K are currently limited in applicability to the use of fuel rods with Zircaloy or ZIRLO cladding. 10 CFR 50.46 and 10 CFR Part 50, Appendix K do not apply to the proposed use of AXIOM fuel rod cladding since AXIOM material has a slightly different composition than Zircaloy or ZIRLO material. With the approval of this exemption request, these regulations will be applied to AXIOM fuel rod cladding at MPS3.
In order to support the use of AXIOM fuel rod cladding material at MPS3, an exemption from the requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K is requested.
As required by 10 CFR 50.12, the requested exemption is authorized by law, does not present undue risk to public health and safety, and is consistent with common defense and security. Approval of this exemption request does not violate the underlying purpose of the rule. In addition, special circumstances do exist to justify the approval of an exemption from the subject requirements.
References
- 1. Letter to Jeffery B. Archie (SCE&G) from Karen R. Cotton (NRC), "V. C. Summer Nuclear Station - Exemption from the Requirements of 10 CFR part 50, Sections 50.44, 50.46, and Appendix K (TAC No. MC4462)," January 14, 2005.
(Accession Number: ML05004029)
- 2. Letter to Jeffrey B. Archie (SCE&G) from Timothy J. McGinty (NRC), "Virgil C.
Summer Nuclear Station, Unit 1 - Correction to Exemptions Issued on March 13, 2008, from the Requirements of 10 CFR Part 50, Sections 50.44, 50.46, and Appendix K (TAC No. MD5699)," May 23, 2008. (Accession Number:
- 3. Letter to Christopher M. Crane (Exelon) from Robert F. Kuntz (NRC), "Byron Station, Unit Nos. 1 and 2 - Exemption from the Requirements of 10 CFR 50.44, 10 CFR 50.46, and 10 CFR Part 50, Appendix K (TAC Nos. MC8517 and MC8518)," June 30, 2006. (Accession Number: ML061380518)
- 4. Letter to Charles G. Pardee (Exelon) from Marshall J. David (NRC), "Byron Station, Unit No. 2 - Exemption from the Requirements of 10 CFR Part 50, Section 50.46 (TAC No. MD8455)," April 30, 2009. (Accession Number:
- 5. W. J. Leech and K. Yueh, 'The Fuel Duty Index, a Method to Assess Fuel Performance," Top Fuel Conference, Paper P2-16 (2001).
Serial No.16-242 Docket No. 50-423 Attachment 3 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-16-4431, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
DOMINION NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNIT 3
Westinghouse Non-Proprietary Class 3
@Westinghouse Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 l 1555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-16-4431 June 7, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Dominion Nuclear Connecticut, Inc., Millstone Power Station Unit 3, Proposed Exemption Request for the Use of Axiom Cladding Material in Lead Test Assemblies (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proplietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-16-4431 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 Dominion Nuclear Connecticut, Inc.
Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-16-4431, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.
James A. Gresham, Manager Regulatory Compliance
© 2016 Westinghouse Electric Company LLC. All Rights Reserved.
CAW-16-4431 June 7, 2016 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
SS COUNTY OF BUTLER:
I, Henry A. Sepp, am 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 my knowledge, information, and belief.
CRE-Systems and Components Engineering
2 CAW-16-4431 (I) I am Director, CRE-Systems and Components Engineering, Westinghouse Electric Corppany 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 trad~ 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 constitute Westinghouse policy and provide the rational basis required.
Under that system, information is held in confidence 1f 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-16-4431 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b) It consists of suppo1ting 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, assur~nce 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 Westingbouse 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.
(iii) 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-16-4431 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If .
competitofs acquire components of proprietary infonnation, 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.
(iv) The information is being transmitted to the Commission in confidence and, under the provisions of I 0 CFR Section 2.390, is to be received in confidence by the Commission.
(v) 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.
(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Dominion Letter 16-242> "Dominion Nuclear Connecticut, Inc.,
Millstone Power Station Unit 3, Proposed Exemption Request for the Use of Axiom Cladding Material in Lead Test Assemblies" (Proprietary), for submitta,l to the Commission, being transmitted by Dominion Nuclear Connecticut, Inc. letter and Application for Withholding Proprietary Infonnation from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with development of and data collection for the AXIOM' fuel rod cladding material, and may be used only for that purpose.
AXIOM is a trademark or registered trademark of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademarks or registered trademarks of their respective owners.
5 CAW-16-4431 (a) This information is part of that which will enable Westinghouse to develop and license the AXIOM fuel rod cladding material.
(b) Further, this information has substantial commercial value as follows:
(i) Westinghouse plans to sell the use of similar information to its customers for the purpose of implementing advanced fuel rod cladding materials at operating power plants.
(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.
(iii) The information requested to be withheld reveals the distinguishing aspects of a technology 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 documenta~ion 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 non-proprietary versions of a document, furnished to the NRC in connection with requests for plant-specific review and approval of the AXIOM fuel rod cladding lead test assembly program and may be used only for that purpose.
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.
Dominion Nuclear Connecticut, Inc.
Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk:
Enclosed are:
- 1. "Dominion Nuclear Connecticut, Inc., Millstone Power Station Unit 3, Proposed Exemption Request for the Use of Axiom Cladding Material in Lead Test Assemblies" (Proprietary)
- 2. "Dominion Nuclear Connecticut, Inc., Millstone Power Station Unit 3, Proposed.Exemption Request for the Use of Axiom Cladding Material in Lead Test Assemblies" (Non-Proprietary)
Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-16-4431, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an 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-16-4431 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.