ML20137H714

Provides Proprietary Supplemental Response to Request for Addl Info Re TS Change Request 96-01 on Conversion to Framatome Cogema Fuel.Encl Withheld,Per 10CFR2.790

ML20137H714
Person / Time
Site:	Sequoyah
Issue date:	03/25/1997
From:	Shell R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20007F874	List: ML20137H714
References
TAC-M95144, TAC-M95145, NUDOCS 9704030031
Download: ML20137H714 (17)

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Tennessee Valley Authority, Post Omce Box 2000, Soddy-Daisy, Tennessee 37379-2000 March 25,1997 U.S. Nuclear Regulatory Commission .

ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 l

SEQUOYAH NUCLEAR PLANT (SON)- SUPPLEMENTAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION - TECHNICAL SPECIFICATION (TS) CHANGE REQUEST 96-01 ON CONVERSION TO FRAMATOME COGEMA FUEL (TAC i NOS. M95144 AND M95145)

Reference:

1. TVA letter to NRC dated February 7,1997, on the above subject i l

2. TVA letter to NRC dated March 17,1997, on the above subject ]

l The purpose of this letter is to provide supplementalinformation to NRC for the TVA J

responses to NRC's request for additional information in the referenced letters.

Reference 1 provided responses to 36 NRC questions. NRC determined that no j

. additional information to these responses was necessary with the exception of the responses to Questions 1,2,7,8,11,12,15,20,23,25,27,28,30,31,32,and

33. Reference 2 provided revised responses to each of the above questions with the exception of Question 1. Enclosure 1 provides the proprietary version of the revised responses to Questions 32 and 33 as requested by NRC during a telephone call on March 21,1997. Enclosure 2 contains the non-proprietary version of the revised responses. ,

Since Enclosure 1 provides information which is proprietary to Framatome Cogema Fuels (FCF), Enclosure 3 contains the application for withholding and affidavit signed by FCF, the owner of the information. The application for withholding and the g,I I affidavit set forth the basis on which the information may be withheld from public i 9704030031 970325 ADOCK 05000327 PDR P PDR g$hg ,

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.a U.S. Nuclear Regulatory Commission Page 2 March 25,1997 disclosure by NRC and address with specificity the considerations listed in Section  :

. 2.790, Paragraph (b)(4) of the NRC regulations. ....,

Accordingly, it is respectfully requested that information which is proprietary to FCF be withheld from public disclosure in accordance with 10 CFR, Section 2.790, of the NRC regulations, i r

Correspondence with respect to the proprietary aspects of Enclosure 1 or the supporting FCF affidavit should be addressed to J. H. Taylor, Manager of Licensing i Services, Framatome Cogema Fuels, P. O. Box 10935, Lynchburg,  ;

Virginia 24506-0935 l Please direct questions concerning this issue to Keith Weller at (423) 843-7527. ,

Sincerely, 2 N. A&A(

R. H. Shell Site Licensing and Industry Affairs Manager  ;

Enclosures cc: See page 3 6

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O.S. Nuclear Regulatory Page 3 s on Commis i March 25,1997 cc (Enclosures):

Nuclear Regulatory One White Flint, North ger CommissionMr. R. W. Hern 11555 Rockville Pike Rockville, Maryland 20852 2739 NRC Resident inspector

{ Sequoyah Nuclear Plant i

i 2600 Igou Ferry Road

( Soddy-Daisy, Tennessee - 624 37379 3 j

Regional Administrator U.S. Nuclear Regulatory Region 11 ss on Commi i Atlanta, Georgia ,

e 2900 30323-2711101 Marietta Street, NW 1

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.4' U.S. NuElear Regulatory Commission Page 3 March 25,1997 cc (Enclosures): . _

Mr. R. W. Hernan, Project Manager .  ;

Nuclear Regulatory Commission l One White Flint, North  !

11555 Rockville Pike -

Rockville, Maryland 20852-2739

. I NRC Resident inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road {

i. Soddy-Daisy, Tennessee 37379-3624 .

Regional Administrator U.S. Nuclear Regulatory Commission ,

Region il 101 Marietta Street, NW, Suite 2900

- Atlanta, Georgia 30323-2711 l

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ENCLOSURE 3 APPLICABILTlY FOR WITHHOLDING AND AFFIDAVIT

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s AFFIDAVIT OF IAMFR H. TAYLOR A. My name is James H. Taylor. I am Manager of Licensing Services for Framatome Technologies, Inc. (FTI). Framatome Cogema Fuels is administratively responsible to Framatome Technologies, Inc. Therefore, I am authorized to execute this Affidavit.

4 B. I am familiar with the criteria applied by FTI to determine whether certain information of FTI is proprietary and I am familiar with the procedures established within FTI to ensure the proper application of these criteria.

C. In determining whether an FTI document is to be classified as proprietary information, an initial determination is made by the Unit Manager, who is responsible for originating the document, as to whether it falls within the criteria set forth in Paragraph D hereof. If the information falls within any one of these criteria, it is classified as proprietary by the originating Unit Manager.

This initial determination is reviewed by the cognizant Section Manager. If the document is designated as proprietary, it is reviewed again by Licensing personnel and other management within FTI as d6;pa:a! by the Manager of Licensing Services to assure that the regulatory requirements of 10 CFR Section 2.790 are met.

D. The following information is provided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:

(i) The information has been held in confidence by FTL Copies of the document are clearly identified as proprietary. In addition, whenever FTI transmits the information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requests the recipient to hold the informa' ion as proprietary. Also, in order to strictly limit any potential or actual customer's use of proprietary information, the substance of the following provision is included in all agreements entered into by Frl, and an equivalent version of the proprietary provision is included in all of FTI's proposals:

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AFFIDAVrr OF J AMFR H. TAYLOR '(Cont'd.)  !

"Any proprietary information concerning Company's or its Supplier's products or manufacturing processes which is so designated by Company or its l Suppliers and disclosed to Purchaser incident to the performance of such contract shall remain the property of Company or its Suppliers and is disclosed .

in confidence, and Purchaser shall not publish or otherwise disclose it to others without the written approval of Company, and no rights, implied or otherwise, [

are granted to produce or have produced any products or to practice or cause to be practiced any manufacturing processes covered thereby.

Notwithstanding the above, Purchaser may provide the NRC or any other l regulatory agency with any such proprietary information as the NRC or such other agency may require; provided, however, that Purchaser shall first give Company written notice of such proposed disclosure and /;oinpany shall have the right to amend such proprietary information so as to make it non-proprietary. In the event that Company cannot amend such proprietary information, Purchaser shall, prior to disclosing such information, use its best efforts to obtain a commitment from NRC or such other agency to have such information withheld from public inspection.

j Company shall be given the right to participate in pursuit of such confidential treatment."

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AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)

'(ii) The following criteria are customarily applied by FTI in a rational decision process to determine whether the information should be classified as proprietary. Information may be classified as proprietary if one or more of the following criteria are met:

a. Information reveals cost or price information, commercial strategies, production capabilities, or budget levels of FTI, its customers or suppliers.

b. The information reveals data or material concerning FTI research or development plans or programs of present or potential competitive advantage to FTI.

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c. The use of the information by a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing a similar product.

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

e. The information reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage to FTI.

f. The information contains ideas for which patent protection may be sought.

The document (s) listed on Exhibit "A", which is attached hereto and made a part hemof, has been evaluated in accordance with normal FTI procedures with respect to classification and has been found to contain information which falls within one or 3

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AFFIDAVIT OF JAMFIH. TAYLOR (Cont'd.) - .

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.' s more of the' criteria enumerated above. Exhibit "B", which is attached hereto and l made a part hereof, specifically identifies the criteria applicable to the document (s) l listed in Exhibit "A".

i The document (s) listed in Exhibit "A", which has been made available to the Unt:ed (iii) f .

States Nuclear Regulatory Commission was made available in confidence with a j .

request that the document (s) and the information contained therein be withheld from l public disclosure.

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(iv) The information is not available in the open literature and to the best of our  !

knowledge is not known by Combustion Engineering, EXXON, General Electric, Westinghouse or other current or potential domestic or foreign competitors of Framatome Technologies, Inc.

i (v) ~ Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of FTI, taking into account the value of the information to FTI; the amount of effort or money expended by FTI developing the information; and the ease or difficulty with which the information could be properly duplicated by others is given in Exhibit "B".

E. I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is considered proprietary by FTI because it contains information which falls within one or more of thecriteria enumerated in Paragraph D, and it is information which is customarily held in confidence and protected as pmprietary information by FTI. This repor: comprises information 4

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s AFFIDAVIT OF JAMFS H. TAYLOR (Cont'd.)  ;

utilized by FTI in its business which afford FTI an opportunity to obtain a competitive advantage over those who may wish to know or use the information contained in the document (s).

fh+ /e AMES H. TAY R 1

State of Virginia)

) SS. Lynchburg City of Lynchburg)

James H. Taylor, being duly sworn, on his oath deposes and says that he is the person who 1 subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement l are true.

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JAMES H. TAYLOR ff i

Subscrip and sworn before me this81 day ofIbrch 1997.

I mD~b,bmO-Notary Public in and for the City of Lynchburg, State of Virginia.

My Commission Expires 1Iy 30491 5

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. EXHIBITS A & B l l

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EXHIBIT A 1 i

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! - Revised Responses to Questions 32 and 33 of Request for AdditionalInformation on BAW- .l

- 10220P," MARK-BW Fuel Assembly Application for Sequoyah Nuclear Units 1 and 2," March i 1996.-

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i-EXIIIBIT B v

i The above listed document contains information which is considered Proprietary in accordance i with Criteria b, c, and d of the attached affidavit.

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ENCLOSURE 2 REVISED RESPONSES TO NRC QUESTIONS NON-PROPRIETARY VERSION

,32.- The horizontal seismic and LOCA loads were calculated for the mixed core for Mark-BW fuel and Westinghouse Standard fuel. Why was Westinghouse V-5H not used?

Additionally, explain how the mixed core calculation was performed to assure conservative results.

Responss Framatome Cogema Fuels (FCF) has calculated the horizontal seismic and LOCA loads for the mixed core for Mark-BW and Westinghouse Vantage 5H fuel assemblies as described on page 8-6 of BAW-10220P, Rev. O. The results of the calculations were compared with the seismic and LOCA loads results of the full Mark-BW core configuration. The resulting changes in spacer grid impact loads are minor [ ] as stated on page 8-6 of BAW-10220P, Rev 0. The spacer grid impact loads for all the faulted conditions are within the elastic load limit. Therefore, the requirement of ,

a core coolable geometry is met.

The core configurations as indicated below and shown in Figure 32-1 were analyzed for a 5-assembly model. These configurations are based on providing combinations of E Vantage 5H and FCF Mark-BW fuel assemblies in mixed cores. The configurations are identical to those analyzed for the E Standard and FCF Mark-BW mixed core analysis (Figure 32-2).

V5H V5H V5H V5H V5H - Base Case V5H V5H BW V5H V5H - Core ConfI BW V5H V5H V5H BW - Core ConfII V5H BW V5H BW V5H - Core ConflII The all-V5H case is given because that establishes a base line loading for V5H assemblies. A goal of the mixed core analysis is to demonstrate the adequacy of the FCF fuel assemblies when mixed with E resident fuel assemblies. It is also shown that the loads on E V5H and W Standard in a mixed core are equal or less than the all V5H or Standard baseline.

Based on previous calculations as discussed in Section 4.2 of BAW-10133P, Rev.1 (NRC approved topical), the five fuel assembly model gave the highest impact load, and as the number of FAs increased beyond five, the load decreased. For the Sequoyah plant, five FAs do not exist in any row of the core. The minimum number of fuel assemblies that exist in one row is seven.

However, for additional conservatism, the five-FA row was selected for the Sequoyah plant. As reported in Figure 5 of Enclosure 2 of B AW-10133P, Rev. I by using the five-fuel assembly core model, instead of the seven-fuel assembly model, resulted in the peak impact load higher by approximately [ ]%.

As additional conservatism to achieve a maximum load on Mark-BW fuel assembly, the core FCF Non-Proprietary

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- configuration consisting ofE Vantage 5H, E standard, and Mark-BW fuel assemblies as shown in Figure 32-3 was analyzed. This configuration is conservative because the Mark-BW fuel assemblies are placed on the periphery as this location which has been shown in the previous cases to experience the maximum impact loads. Also, E Standard assemblies, which have Inconel intermediate spacer grids with a higher grid stiffness than the Zirca!ay grids of the Mark-BW, are l placed next to Mark-BW fuel assemblies, which increases the impact loading on the Mark-BW ,

assemblies. The results of this analysis are discussed in the last paragraph of the response to  ;

Question 33. , i I

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Figure 32-1  :

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Vantage 5H/ Mark-BW Mixed Core Configuration ,

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E Standard / Mark-BW Mixed Core Configuration .j

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E Standard / Vantage SH/ Mark-BW Mixed Core Configuration  !

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. 33. - Is a full core analysis performed for the combined LOCA/ Safe Shutdown Earthquake (SSE) loads for mixed core applications? Compare the critical loads (crushing loads) for the three types of fuel that will be in the reactor and describe how the results are effected by the differences.

Resoonse An analysis described in the response to above Question 32 demonstrates the adequacy of the FCF Mark-BW fuel assemblies when mixed with E Vantage 5H fuel assemblies. For E Standard fuel assemblies, a mixed core bounding analysis as discussed on page 8-6 of B AW- 10220P, Rev.

O was performed for a mixed E and FCF fueled core. The resulting changes in spacer grid impact loads as discussed on page 8-7 of BAW 10220P, Rev. O are minor [ ] and well within the spacer grid clastic load limit (crushing load). Hence, the requirement of a core coolable geometry is met for all combinations of Westinghouse (Vantage 5H and Standard) and FCF Mark-BW fuel assemblies.

0 The elastic load limit for the Mark-BW zircaloy intermediate spacer grid at 600 F is [ ] lbs. This value was determined through testing. The buckling strength (crushing strength) of the Westinghouse Vantage 5H and Standard spacer grids were determined through a comparison of basic grid geometry and the use of test data. The calculated crushing strength of the ,

Westinghouse Vantage 5H and Standard spacer grids at 600'F are.

Pvm = [ ] lbs. l l

i I'st,,a,,, = [ ] lbs.

An analysis described in Section 4.2.1.3.2 of Sequoyah FSAR demonstrates the adequacy of the E Vantage 5H and E Standard fuel assemblies under seismic and LOCA loadings. For Mark-BW fuel assemblies, a seismic and LOCA analysis of a mixed core bounding configuration (Mark-BW, W Standard, and E Vantage 5H) was performed, which showed that the Mark-BW fuel assembly loads are within the clastic load limit. The grid maximum impact force for the seismic plus LOCA for this worst case configuration is [ ] lbs. Hence, the requirement of a core coolable geometry is met. l A base core configuration of all Mark-BW fuel assemblies was analyzed. The maximum impact force experienced by this full Mark-BW core was [ ] Ibs. In comparison, the maximum grid impact force in the three assembly core configuration, shown in Figure 32-3 and described in the last paragraph of the response to question 32, is [ ] lbs. The presence of the Westinghouse fuel assemblies increased the maximum grid impact forces on the Mark-BW by [ ]%.

FCF Non-Proprietary