ML19345B185

Nonproprietary Version of Response to Request for Addl Info on Calvert Cliffs 1 Cycle 5 Licensing Submittal. Notarized Affidavit Included

ML19345B185
Person / Time
Site:	Calvert Cliffs
Issue date:	11/19/1980
From:	ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:
Shared Package
ML19262F305	List: ML19345B185
References
CEN-144(B)-NP, NUDOCS 8011260270
Download: ML19345B185 (23)

Text

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c, AFFIDAVIT PURSUANT T0.10 CFR 2.790 Combustion Engineering, Inc. )

State of Connecticut )

- County of Hartford ) SS.:

I, A. E. Scherer, depose and say that I am the Director, Nuclear Licensing of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph imediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Baltimore Gas and Electric Company, for withholding this information.

The information for which proprietary treatment is sought is contained in the following document:

CEN-144(B)-P, Response to Request for Additional' Information on Calvert Cliffs 1, Cycle 5 Licensing Submittal, November 19, 1980.

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 or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is .arnished for consideration by the Comission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, -

should be withheld.

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1. The information sought to be withheld from public disclosure are fuel rod and poison rod design innovations and the supporting data which are owned and have been held in confidence by Combustion Engineering.

2. The information consists of test data or other similar data concerning a process, method or component, the application of which results in a substantial competitive advantage to Combustion Engineering.

3. The information is of a _ type customarily held in confidence by 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 Comission via letter DP-537 from F.M. Stern to Frank Schroeder dated December 2, 1974. This system was applied in determining that the subject documents herein are 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 Comission.

5. 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.

6. 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 end sold by major pressurized water reactors competitors of Combustion Engineering.

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b. Development of this infonnation by C-E required thousands of i man-hours of effort and tens of- thousands of dollars. To the best of my knowledge and belief a competitor would have to undergo similar expense in generating equivalent information.

! c. In order to acquire such information, a competitor would i

j also require considerable time and inconvenience related to obtaining data from post irradiation examinations, an extensive materials development program and analytical work to support fuel rod and poison rod design i developments, 4

d. The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.

4 Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable. i

e. The information consists of fuel rod and poison rod design innovations and the supporting experimental and analytical data, 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,

f. 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

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reflecting significantly lower costs.

9 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 Combustien Engineering's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

, A:w A. E. Srp 6er_

Director Nuclear Licensing Sworn ta before me this O/N day of /(Ct O N% I3b b cLd.Sw M }b1CL Notary Public /

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I Combustion Engineering, Inc.

c; Response to Requpst for Additional Information on Calvert Cliffs 1 Cycle 5 Licensing Subnittal

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LEGAL NOTICE Tills ITEPORT "!AS PREPARED AS Aff ACCOUNT OF V!ORK SPO??SORED BY COMCUSTION Et;GINEERING, INC. NEITHER CCI.13USTIOi! ENGINEERING IJOlt ANY ltRSON ACTING ON ITS DEllALF:

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MAKES ANY V!ARRAfJTY OR REPRESENTATIOTJ, EXPRESS OR IMPLIED INCLUDING THE V!ARRATJTIES OF FITNESS FOR A PARTICULAR PURPOSE OR f,1E R CHAN TABI LI TY, V/ITH RESPECT TO THE ACCURACY, COMPLETENESS, OR USEFULNESS OF THE INFORI.1ATION CONTAlf ED IN THIS REPORT, OR THAT THE USE OF ANY INFORMATIO:J, AFPARATUS, fl.ETHOD, OR PROCESS O'.';fJEU RIGHTS; ORD!SCLOSED IN THIS REPORT MAY NOT INFR!NGE FRIVATELY D. ASSU.*ES ANY LIA3tLITIES VitTH RESPECT TO THE USE OF, OR FOR DAMAGES RESULT!fJG FROT.1 THE USE OF, ANY INFORMATIOfJ, APPARATUS, METilOD OR I'ROCESS DISCLOSED IN THIS REPORT.

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. Question Dl Enclosure and 2 makes Ecad Prototype. a distinction between Experimental Test Assen.blics Assemblies.

a.

Are the 4 so-called PROTOTYPE ar;emblies in Cycle 5 Experimental Test Assemblies or Lead Prototype Assemblies according to the definition in Enclosure 2?

b.

If these 4 assenblics are Lead i'rototype Assemblies adequate surveil-lance that must fuel be perf ormed at EOC-5 to support following core reloads of type.

lance that is planned for EOC-5 and how the resu.ts will to the NRC.

than that performed for r'ature cores or first cores, but p techniques may suffice, c.

If these 4 assemblies are Experimental Test Assemblies, surveillance at E0C-5 is not required but results from any post-irradiation examination (PIE) would be of interest to the HRC.

indicate what PIE results would be made available to the NRC.In this case, plea

Response

The four PROTOTYPE Assemblies are categorized as Experimental Tes per the definitions of Enclosure,2.

ment program These assenblies form part of a develop-whose purpose is to provide [ _

design innovations is included in response to question].Adescriptionofthese D5.

determined,[Since the true life limits of the standard fuel design have ye licensing submittal will be[]. At that time, the technical suppart for th 3-Plans for a poolside examination af ter Cycle 5 include [

a bearing on safety-rel]ated issues will be reported to the N

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Question 04 Would through aone of cycle, fourth the three identical or t:ould PROTOTYPE noe assen.bly with[ assemblies b

.jbethecandidate?

Resy_onse of being irradiated a fnurth cycle.All four of the PROTOTYPE a examinations of I'It0 TOT'fPE and its predecessor,[ Data obtained from the

. the evaluation of the[

]will assist in number and cycle will be combination of assemblies to remain in the cor specified at the time when the assen:bly loadings for Cyc 3

8 are selected.

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Quest _lon D5_

Appendix D provides a description of the PRO 10lVPL fuel desi< ins. Please provide additional detail inf oroution including drawings wilii din >ensions.

has beenidentify Please the inodified design fecture and detrimental ef fects which considered, M ponse The PROTOTYPE program incorporates [

innovations are[

3 The n: ore basic design lable 1 lists the specific number of fuel rods of each type in each of]the fou. PROTOIYPE assemblies, and Figure 1 i ~

illustrates the features as they differ froa the standard design.

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3 PCCI A L l'UEL ROC CE5IGNS  !

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TABLE 1 D1511t10U110!! Oi fi005 it: Pi!OT 01'(I'E 6

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i pugst_ ion 010 From batch B of Cycle 4 there are 15 C-E/EpRI test rods that will be loaded  !

into fuel assembly 0047 for Cycle 5 operation.

evaluation for 12 of these rods was based on an ihe creep collapse insrection performed during a previous spection outage rather than on the standard analysis. The in-did not reveal L

cluded that no collapse during Cycle 5 would be Since expected.large these clad e test rods will be inspected during this outage, please confirm this con- '

clusion based on current observation.

. Response An inspection of the test rods to be loaded into Assembly 0047 for an extended irradiation was conducted af ter their third cycle. Detailed diameter profilometry verified the absence of any gaps ir the fuel column which could lead to collapse of the cladding [

, Since pellet i densification is essentially complete in the first cycle of] operation, and sinc ([ .

previousexamprovideshig]hconfidencethatcollapsewillnotocc subsequent cycles. .

Plans for the poolside examination of these rods,which is currently under-Way, include further profilometry.

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, completed, the results will be reported to the lWC.Should time permit, and the p These fourth-cycle measure' rents, however, are not considered necessary for the verification of pellet column integrity for the reasons stated above.

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OUESTIOil 011 cycles, the 52 Batch G fuel asscn blics to be loaded f are to each etcploy 8 burnable poison pins.

poison pins the sarae as that used in the initial core loading?Was If so, were the de the revised C-E design modifications and manufacturing process changes--to

'~ preclude the earlier type of hydride.. induced failures-employed? If these poison pins for Cycle 5 operations are of a different design, please provide appropriate design drawings and descriptions. It would also be helpful to describe the results of any other licensee's operating experience with any new type of poison pin design that would be used in Cycle 5.

_RESPO!!SE__

The Batch original G BPR design differs in several respects from that used in the core.

The design changes are directed toward both the moisture retention problem and a pellet-cladding interaction (PCI) concern, To deal with the tendency of the A1203-04C to retain moisture, a combination

, of materials controls and manufacturing process controls has been instituted. .

L The PCI concern arose as a result of measured length changes of poison rod which indicated that a definite PCI component was present in axial elongation.

The design changes directed toward PCI are listed below.

Original Core _ Batch G m

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There is no post-irradiation data available on the revised design, lhe attached sketch shows the designs in schematic.

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POIS0!! ROD DESIGil C0liPARIS0:1 4

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Question D14, a

f The licensee has previnusly submitted information (1,2) to show that an tiRC-supplied correction ( 3,4) of the fission gas release model in the Calvert Cliffs Unit i fuel performance analysis sould not result in rod

' internal pressure e>.ceeding no:ainal prirary systen pressure nor would it result in and adverse ef fect on LOCA or other safety analysis. .The burnup and peak linear heat generatino rate useil in that analysis do not reflect

' the values anticipated for Cycle 5 operation. provide results of an analysis for these conditions shading continued acceptability of these 4

results for Cycle 5 operation.

! The calculations of fuel rod internal pressure for Cycle 5 were performed

' using tne same methods as those used for Cycle 4. The development of improved methods for ,redicting fission gas release is, however, an active and ongoing prograu at C-E. Da ta are _eing collected and included the evaluation of any enhancement due to burnup.

The most directly applicable data have been obtained from the destructive examination of full-length fuel rods. operated in Calvert Cliffs-1. As part of an EPRl/C-E program, fuel rods containing a variety of UO 2 fuels have operated to rod average.burnups up to J7,000 tr..'D/ !TU. lhe initial

' enrichment of selected rods was higher than com;:arision rods, so as to in- .

crease the linear beat ratings above the standard rods in tne core. The results of this program, to date, are presented in Table 1 which includes the fuel type gas release.[, the oper5 ting parcmeters and the racasured values of fission 1

Despite the absence of a measured effect due to burnup from the data above, C-E has calculated the internal pressure of the various fuel rods in Calvert Cliffs 1 and 2 for the upcoming cycle in each plant. As agreed at our meeting of f;avember 12, these results are being reported as the re-sponse to Question 014. Table 2 tabulates the results for the various groups of fuel rods by the standard methods along with the results obtained by usinq the FATES model with the liRC's enhancement factor.[

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! . 1. Letter from A. E. Lundvall, Jr., BGSE, to D. L. Zicnann, fiRC, j dated December 31, 1976.  ;

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i 2. Letter from A. E. Lundvall, Jr. , BG5E, to D. L. Ziemann, !!RC,  !

j dated February 23, 1977. l 1  !

i 3. Letter from D. L. Ziemann, flRC, to A. E. Lundvall, Jr., BG&E, t j dated flovember 23, 1976 [

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4. R. O. Meyer, .C.E. Beyer, and J. C. Hglewede, " Fission Gas Release from

!j fuel at High Burnup," liRC Report tiUREG-0418, March 1978.

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Question 017 lhe reload safety analysis (1) piovides .4 in .uf ficiviit discussin i on f uel i od bowin.) and its e f f ec t on IM"' m n.:i n . Th. tuo '.coler.ces that are poivided do nut it%: i fy tho !vi-t.'w i tude and red'Etion-in-ICR r nrrelations un d f er the Calvert Lli f f s tini t I analysis.

fleither is there any inforte. tina given on the input paremtcrs used for the calculations, f urthermare, the (c'.fi. di'.cussion of f uel ecd hcuing ref erences t h Coubu51ien ingin.,cring generic topical report Cl.!lPD-??b", l uel I.1%isen Pod I..r.iing" th.u h is not been approved

• for licensing applications.

Please identify the correlations that w re used cnd cite their liRC appiovnl. Provide the input that .ih used for the Cycle 5 i

analysis. Describe cny ceneric or plant-spe<:i fic DMCR taargins i that were required to of f set it.el rod ho' ing effects.

Response: (1) The bou nagnitude correlation th.'t uas used is as given in Reference 1 settien C.2.1.F. It is:

o Ac/co I"14 b(M f I ch DB I" DOS

. Co where :

o n standard deviation of gap closure due to fuel rod nc/co -

bowing a g

= sample standard deviation of the as fabricated cl.annel width ceasurement for C-E 14x14 fuel;

[ ] as sho..n in Table G-5 of Referente 1.

b = Burnup coefficient;

[ ]assho.eninTable c. fl o f Reference 1.

n = Exponent cn burnup; value of n=.5 verified in section G.2.1.1 and in Tab 1 C-3 of Rc rerence 1.

f g

= cold-to-hat c orreciioa f actor; value of f ch I' derived in Reference 2.

rgg e Catc!-in-bet.ch variation correct icn factor; value of

[ ] derived in section G.P.l.1 and in Table G-8 of Re ference 1.

Co  : nominal chonnel width between fuel rods; Co = .140" for

. Calve.rt Cli f f s plants.

The form of thi: correlation and the factor <. occounted for follo.s liRC quid. nce ip ven in !'eicante; 3.

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t (2) The ieductien-in-D m correlation um! is that given by tiie !!P.C in References 3 and 4. The tom of the c'orrelation is embodied in " calculational st eps" 2 ,through 'i anil 7 t hrough 11 in Table G-1 of I:.:ference 1. These :.teps follce the f orm given by the flRC.

(3) The calculation of D:mR penalty for Calvert Clif fs I cycle 5

. was perforn.cd by entering curve 1 of figure G-2 in Reference 1 at a buinup value of 45000 !!!D/MTU, a value whic'. envelopes the rnaximum expected batch average burnup for this cycle. The ,

i penalty of this burnup is given as.46", resulting in t'Dl!BR =

1,0046x1.19=1.195. The burnup value of 45000 f tlD/MTU was the only " input" used speci fically for the cycle 5 analysis, i'

Input used iri prodring curvc 1 of figuru G-2 is given in Tables G-2 and G-3 o~f Reference 1, in the columns labelled i

"14x14 feel Design" and "CE-1 CPF Correlation" respectively.

l This input is generic to C-E .14x14 plants using TCP,C/CE-1 rmtho-dology.

(4) As required by Reference 3 fuel rod bouing penalty was applied directly to the value of the MDIGR SAFDL used for Safety analyses and setpoints. fio additional generic or plant specific margins were applied as offsets to the fuel rod bowing effects, since the co!:puted thennal margin of the reactor is auf omtically reduced by the procedure used.

(5) The use of Reference 1 in this response and of Reference 2 in the original Calvert Cliffs licensing submittal is not intended to imply approval by the liRC. Rather, these documents are referenced as available sources of information pertinent ta ;;RC's review of the cycle 5 licensing submittal.

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1. Supplement 3-P to CUiPD-2P5-P, " fuel and Poison ! od Coding",

June, 1979.

2. CEl(PD-225-P, " fuel and Poison Rod Dmtir.g", Octo!;ce,1976.

3. Letter, D. B. Vassello to A. E. Scherer, June 12, 1978.

4. Letter, D. B. Vassello to A. E. Scherer, Sept. 15, 1078.

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