ML17306A356
| ML17306A356 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/20/1991 |
| From: | ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | |
| Shared Package | |
| ML17306A355 | List: |
| References | |
| 161-04352-WFC-G, 161-4352-WFC-G, NUDOCS 9201020064 | |
| Download: ML17306A356 (27) | |
Text
161-'04532-MFC jGAM December 20, 1991 CONTROLLED BY USER OESIGN FEATURES 5.3 REACTOR CORE FUEL ASSEMBLIES 5.3. 1 The reactor core shall contain 241 fuel assemblies with each fuel assembly normally containing 236 fuel rods or burnable poison rods clad with
'nal Zircaloy-4 except that limited substitution of fuel rods by sisting of Zircaloy-4 or stainless steel or by vacancies may be made fied b e filler rods con-if sis. Each fuel rod shall have a nominal active fuel length of 150 inches an contain a maximum total weight of approxi-mately 1950 grams uranium. Each burnable poison rod shall have a nominal justi-active poison length of 136 inches. The initial 'core loading shall have a maximum enrichment of 3. 35 weight percent U-235. Reload fuel shall be similar in physical design '
to .the .initial core loading and shall have a maximum enrich-f4 erc nt U-235.~
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~y ~{~ > ~<< in+~a <~~ ~ >a~>iles for in- te<cfor parAr<o<ee,v'<tua+an purp~ap durity CONTROL 'EL SEMBLIES 5.3.2 The reactor core shall contain 76 .full-length and 13 part-length control element assemblies.
5.4 REACTOR COOLANT SYSTEM DESIGN PRESSURE AND'TEMPERATURE 5.4.1 The Reactor Coolant System is designed and shall be maintained:
.a. In accordance with the code requirements specified in Section 5. 2 of the FSAR with allowance for normal degradation pursuant of the applicable surveillance requirements, b:- For a pressure of '2500 'psia, and C. For a'emperature of 650oF, except for the pressurizer which is 700 F.
VOLUME r
5.4.2 The total water and steam volume. of the Reactor Coolant System is cubic feet at a nominal T avg of 593 F.
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"No fuel with an enrichment greater than 4.0 weight percent U-235 shall be stored in a high density mode in the spent fuel storage facility.
PALO VEROE " UNIT 3 AtlENOt)ENT HO'. 8 920i020064 5'ii220 05000530 PDR ADOC{~
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Table E-1 Distribution of Fuel Rods Using Advanced Cladding in Palo Verde Unit 3 Batch F Demonstration Assemblies ALLOY'.NUMBER"':"..":c:-:::.ALLOY:"DESXGNATION i!i":,:,: i:;:::'-:: DEMO!':ASSEMBLY::;::1'~"::,""'"";i:",':::i:.:-::,'.::,;::::::.",:i,: ;,"';;"':,:;:;":;:;.:.'j;: g:;.:::TOTAL"'N,;:TWO;"'."'-';
i:.Zj.'i,"':.'3 i'.",":,:Pe'riphe'r'al '",;':i?:Inteii'or,:,,"':.':',: ~,::,"Peiiphera1'j:;:; "jInt'e'rio'r";.';:
- g. Ajj.%&(Q(~j."@": ':.
Zircaloy-4 + x l+
Zircaloy-4 + x 2
Zirconium Alloy C 0 Zirconium Alloy D 0 Zircaloy-4 + Y ~ 14 (with two.processing parameters)
TOTAL 80 X ls an clement normally present ln P.rcaloy 4. Ihe subscripts represent different levels of clement X.
Y ls an addltlonal alloylnj clement.
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I 161-04532-l6 C/GAM December 20, 1991 ENCLOSURE B
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Enclosure B, consists of an ABB Combustion Engineering report containing proprietary information, and is being provided to the NRC for review.
This report is available at the APS Nuclear Fuel Management Department.
161-'04532-. WFC/6AM December 20, 1991 AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc. )
'State of Connecticut )
County of Hartford ) SS.:
I, S. A. Toelle, depose and say that I am the Manager, Operating Reactor Licensing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and'ave reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission s regulations in conjunction with Arizona Public Service Company for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-411(V)-P, Revision 2-P, "Safety Evaluation Report for Use of Advanced Zirconium Based Cladding Materials in'PVNGS Unit 3 Batch F Demonstration Fuel Assemblies," .December 1991.
This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret; privileged or as confidential commercial of'inancial information.
Pursuant 'to the provisions, of paragraph:(b) (4) of Section 2.790 t
of the Commission's regulations, the following is furnished for
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I consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
- 1. The information sought to be withheld from public disclosure, which is owned and has been held in confidence by Combustion Engineering, is the composition and testing results for zirconium based alloys that provide superior corrosion resistance compared to standard Zircaloy-4.
- 2. The information consists of test data or other similar data concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.
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- 3. The information is of a type customarily held in confidence by
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Combustion Engineering and not customarily disclosed to the public. Combustion Engineering 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 details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F. M. Stern to Frank Schroeder dated December 2, 1974.
This system was applied in determining that the subject document herein is proprietary.
4 ~ The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the
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Commission.
The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:
- a. A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
- b. Development of this information by C-E required thousands of manhours and hundreds of thousands of dollars. To the best of my knowledge -and belief, a competitor would have to undergo similar expense in generating equivalent.
a information..
In order to acquire such i.nformation, a competitor would I1 c ~
also require considerable time and inconvenience to develop the composition and testing results for zirconium based alloys that provide superior corrosion resistance compared to standard Zircaloy-4.
- d. The information required significant effort and expense to obtain the licensing approvals necessary for application of the information. Avoidance of this expense would decrease a competitor's cost in applying the information and
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marketing the product to which the information is applicable.
The information consists of the composition and testing results for zirconium based alloys that provide superior corrosion resistance compared to- standard Zircaloy,-4 , the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions,to improve their product's position or impair the position of Combustion Engineering s product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
In pricing Combustion Engineering s products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included. The ability of Combustion Engineering's competitors, to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
Use of the information by competitors: in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the- costs associated with their technology development. In addition, disclosure would have an adverse economic impact on Combustion I
Engineering's potential 'o'r obta'ining or mai.'ntaining
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foreign licensees.
Further the deponent sayeth not.
- s. A'.
S. A. Toelle Manager Operating Reactor Licensing to before Sworn this
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~~ me day of 1991 a
No ai;y Pub 'c My commiss"on expires:
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ENCLOSURE C
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A lication for Exem tion From The Provisions of 10 CFR 50 46 10 CFR 50 A endix K and 10 CFR 50 44 that Fuel Claddin is Zircalo Introduction The Code of Federal Regulations, 10 CFR 50.46 and 10 CFR 50, Appendix K contain requirements for emergency core cooling systems (ECCS) at light-water nuclear power plants fueled with uranium oxide pellets within cylindrical zircaloy cladding. Requirements for control of hydrogen gas at light-water reactors fueled with oxide pellets within cylindrical zircaloy are contained in 10 CFR 50.44. The regulations do not define what is considered zircaloy.
Therefore, it is not clear whether the deviations from the composition specifications of Zircaloy-4 of some of the fuel rods in the proposed demonstration program are within the regulatory basis of the zircaloy specified in 50.46, Appendix K, and 50.44. Arizona Public Service Company requests that an exemption be granted to 10 CFR 50.46,. 10 CFR 50, Appendix K,, and 10 CFR 50.44 to permit the use of fuel rods clad 'ith zirconium-based alloys. whose compositions are outside the range of Zircaloy-4.
The criteria of 10 CFR 50.12 are addressed below .to justify this exemption in order to demonstrate the special circumstances whi'ch are required'o be present for the granting of an exemption.
S ecial Circumstances From 10 CFR 50.12:
Special circumstances are present whenever. . .(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.
The underlying purpose of 10 CFR 50.46 and 10 CFR part 50 Appendix K is to establish requirements for calculations of emergency core cooling systems. The safety analysis for the Technical Specification change to allow the use of the advanced alloy cladding in the PVNGS Unit 3 demonstration assemblies identifies that the behavior of the alloys is expected to be essentially the same as that of conventional Zircaloy-4 under all conditions experienced during both normal operation and under the conditions existing during the loss-of-coolant accident (LOCA) transient. Therefore, the 10 CFR 50.46 and 10 CFR 50, Appendix K criteria will be satisfied for the advanced alloys.
The underlying purpose of 10 CFR 50.44 is to ensure that means are provided for the control of hydrogen gas that may be generated following a LOCA. The safety analysis for the Technical Specification change to allow the use of the advanced alloys in the PVNGS Unit 3 demonstration assemblies identifies that the 8 phase oxidation rate of the advanced alloys will be comparable to or lower than that of Zircaloy-4. Therefore, the use of the advanced alloys will have no significant effect on previous assessments of hydrogen gas production.
'0 Im act on the Environment There will be no perceptible impact on the, environment as a result of this exemption. No operational or safety considerations are introduced by this exemption. The advanced cladding alloys are expected to perform at least as well as the Zircaloy-4 cladding. The only credible consequence of this change would be a failure of the demonstration cladding. Even in the case of gross demonstration cladding failure, the number of rods involved (a maximum of 80 rods) is sufficiently small that environmental impact would be minimal, and is bounded by previous assessments.
Foreclosure of Subse uent Alternatives Implementation of the proposed change will not foreclose the implementation of any subsequent alternatives. The only alternative to be considered would be to forgo the demonstration program and revert to using standard cladding. This alternative remains available in the event the demonstration program does not result in improved fuel rod performance.
Effect of Dela There is not a quantifiable effect of delaying the demonstration program. Long range benefits may be expected from this program in terms of reduced incidence of fuel failure, longer operating cycles, and higher fuel burnup.
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ENCLOSURE D A
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t to NRC Staff Comments Concerning the APS
.1 Responses Technical .Specification 'Amendment Request to Allow the Use'of Advanced Alloy Clad in PVNGS Unit 1 NRC Comment 1:
The proposed change to TS 5.3.1 does not indicate which cycles will be affected by the substitution of the 80 fuel rods clad with zirconium-based alloys. The amendment request should clearly specify which cycles will be affected by the proposed TS change.
APS Res onse:
This amendment request for Unit 3 Technical Specification 5.3.1 identifies that the substitution of the up to 80 fuel rods clad with zirconium-based alloys may be made during cycles 4, 5 and 6.
NRC Comment 2:
The amendment request states that "the placement scheme and the similarity to Zirconium-4 assure that the cladding alloys will not be limiting under any operating condition". Clarification is needed on the specific criteria used for the placement of these assemblies in the core and how a "non-limiting" location in the core is determined and defined.
The criteria to be used for the placement of these assemblies in the core is that the assemblies will be positioned in the core such that they will not be subjected to the highest core power density identified in the Unit 3, Cycle 4 reload analysis. This clarification of the fuel assembly placement criteria replaces the discussion regarding a "non-limiting" location in the core in Section D, No Significant Hazards Consideration, Standard 3, and Section E, Safety Analysis for the Proposed Change, Introduction and Evaluation Conclusions.
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