ML20141G482
| ML20141G482 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/30/1997 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19317C475 | List: |
| References | |
| NUDOCS 9707080344 | |
| Download: ML20141G482 (13) | |
Text
_ _.,
si:n supp.,e o.ptrim A
10 CFR 50.90 PECO NUCLEAR eew om c-965 Chesterbrook Boulevard A Unit of PECO Energy Wayne, PA 19087-5691 L
June 30,1997 Docket No. 50-278 i
License No. DPR-56 U.S. Nucieer Regulatory Commission l
' Attn: Document Control Desk l
Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Unit 3 i
License Change Application ECR 96-03620 l
i
Dear Sir:
i PECO Energy Company (PECO Energy) hereby submits License Change l
' Application ECR 96-03620, in accordance with 10 CFR 50.90, requesting a l
change to the Peach Bottom Atomic Power Station (PBAPS), Unit 3 Facility I
Operating License. This proposed change will revise Technical Specifications (TS) Section 2.0, " Safety Limits." This Section will be revised to incorporate revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the use of the GE13 fuel product line and the cycle-specific analysis performed by l
General Electric Nuclear Energy (GENE) for PBAPS, Unit 3 Cycle 12.
i This LCA supersedes LCA No. 96-01 which was submitted to the U. S. Nuclear Regulatory Commission on March 25,1996 for PBAPS, Units 2 and 3. LCA No.
96-01 was approved for PBAPS, Unit 2 on September 27,1996 (Amendment No.
217).
information supporting this request is contained in Attachment 1 to this letter,
/
and the marked up page showing the proposed changes to the PBAPS, Unit 3
/
TS is contained in Attachment 2. Attachment 3 (letter from R. M. Butrovich (GENE) to H. J. Diamond (PECO Energy), " Peach Bottom Unit 3 Cycle 12 Safety Limit MCPR," dated June 16,1997) specifies the new SLMCPRs for PBAPS, Unit 3. Attachment 3 contains information proprietary to General Electric.
/}9 )
cj General Electric requests that the document be withheld from public disclosure in accordance with 10 CFR 2.790(a)(4). An affidavit supporting this request is contained in Attachment 3.
We request that the amendment to the PBAPS, Unit 3 TS be approved by i
September 26,1997, and be made effective prior to the restart from the upcoming PBAPS, Unit 3 refueling outage.
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If you have any questions, please do not hesitate to contact us.
t Very truly yours,
}). O.
G. A. Hunger, J.,
Director - Licensing
Enclosures:
Affidavit, Attachment 1, Attachment 2, Attachment 3 i
cc:
H. J. Miller, Administrator, Region I, USNRC W. L. Schmidt, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania t
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k COMMONWEALTH OF PENNSYLVANIA:
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COUNTY OF CHESTER l
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i J. B. Cotton, being first duly sworn, deposes and says:
j That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the attached License Change Application ECR 96-03620, for Peach
.i Bottom Facility Operating License DPR-56, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his i
knowledge, information and belief.
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Vice President l
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' Subscribed and sworn to b
before me this.g/a day of 4
1997.
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.-_-.----.m GENuclear Energy I
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Richard M. Burrovich Nuclear fuel. Amencas i
fus: Prze~ b*srager GeneralElectnc Company l
Ca::!e Hayne Raad P 0. Box 780. Mic A33 e
Wimington, NC 29:314783 l
l 910 675 62SS t
l-Ora!Comm; 8*292 6256 l
I ft. 910 675 5684 i
June 16,'1997 cc: J. M. Carmody RMB:97-102 T. R. Loomis 1 l
D. B. Wahermire l
J. L. Embley l
G. A. Watford '
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i Mr. H. J. Diamond, Director l
Fuel & Services Division
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PECO NUCLEAR t
965 Chesterbrook Boulevard Wayne, PA 19087-5691
SUBJECT:
Peach Bottom Unit 3 Cycle 12 Safety Limit MCPR
REFERENCE:
- 1. Attachment dated June 16,1997, D. B. Waltermire to R. M. Butrovich;
Subject:
AdditionalInformation Regarding the 1.11 Cycle Specific I
SLMCPRfor Peach Bottom Unit 3 Cycle 12.
J l
- 2. " Contract between Philadelphia Electric Company and General Electric j
Company for Reload Fuel Supply for Peach Bottom Atomic Power Station Units 2 and 3", September 1,1993 as amended.
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Dear Hugh:
Attached for your information and use is reference I regarding the Peach Bottom 3 Cycle 12 cycle specific SLMCPR. The Cycle 12 SLMCPR is 1.11 and the single loop operation SLMCPR is 1.12.
Please note that reference 1 contains GE Company Proprietary Information contained within the double brackets as indicated in the attachment and should be handled in accordance with the proprietary information provisions. contained in the reference 2 Contract between PECO i
Energy Company and GE.
Very trul yours, j
l
. M. Butrovich Attachment l
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1 General Electric Company AFFIDAVIT I, Ralph J. Reda, being duly sworn, depose and state as follows:
(1) I am Manager, Fuel and Facilities Licensing, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in the letter, G. A. Ilunger, Jr.
(PECO Energy Company) to the U. S. Nuclear Regulatory Commission Document Control Desk, Peach Bottom Atomic Power Station, Unit 3 License Change Application ECR 97-03620 Docket No. 50-278, License No. DPR-56.
(3) In making this application for withholding of proprietary'information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"),5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and 2.790(d)(1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all " confidential commercial information", and some portions also qualify under the narrower definition of " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Groun
(4) Some examples of categories of information which fit into the definition of j
proprietary information are:
a.
Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention ofits use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; b.
Information which, if used by a competitor, would reduce his expenditure of j
resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; 12/13N3RTli Aflidavit Page 1 l
Information which reveals cost or price information, production capacities, c.
budget levels, or commercial strategies of General Electric, its customers, or its suppliers; d.
Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric; Information which discloses patentable subject matter for which it may be e.
desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraph (4)a. and (4)b. above.
(5) The information sought to be withheld is being submitted to NRC in confidence.
The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it would provide other parties, including competitors, with information related to General Electric fuel designs, analysis results and potential commercial
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offerings which were developed at a considerable expense to General Electric.
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i 12/13/93RTil AfTidavit Page 2 I
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i (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process.
The research, development, engineering, and analytical costs comprise a substantial investment of time and money by GE.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GE's competitive advantage will be lost ifits competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a simi'ar expenditure of resources would unfairly provide competitors with a windfall, and deprive 65 of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
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12/13/93RTil Afridavit Page 3
STATE OF NORTH C ROLINA
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SS:
l COUNTY OF NEW HANOVER
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- Ralph J. Reda, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.
Executed at Wilmington, North Carolina, this 16th day of June,1997.
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61phTReda l
General Electric Company i
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Subscribed and sworn before me this 16th day of June,1997.
" }'t' bb<eJ Notaff Public, State ofNorth Carolina My commission expires
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l 12/13/93Rm Affidavit Page 4
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I ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNIT 3 Docket No. 50-278 License No. DPR-56 LICENSE CHANGE APPLICATION ECR 96 03620
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" Revision el SLMCPRs" Supporting infonnation - 4 Pages f
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Docket No. 50-278 License No. DPR-56 Introduction l
PECO Energy Company, Licensee under Facility Operating License DPR-56 for the Peach Bottom Atomic Power Station (PBAPS), Unit 3, requests that the Technical Specifications (TS) contained in Appendix A to the Operating License be amended to i
revise TS 2.1.1.2 to reflect changes in the Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the use of GE13 fuel and the cycle-specific analysis performed by General Electric Nuclear Energy (GENE) for PBAPS, Unit 3 Cycle 12. The TS page showing the proposed changes is contained in Attachment 2. Attachment 3 (Letter j
from R. M. Butrovich (GENE) to H. J. Diamond (PECO Energy), " Peach Bottom Unit 3 1
Cycle 12 Safety Limit MCPR," dated June 16,1997) specifies the new SLMCPRs for PBAPS, Unit 3. This License Change Application provides a discussion and j
description of the proposed TS changes, a safety assessment of the proposed TS changes, information supporting a finding of No Significant Hazards Consideration and l
information supporting an Environmental Assessment.
Discussion and Descriotion of the Proposed Chance The proposed change involves revising the SLMCPRs contained in TS 2.1.1.2 of the PBAPS, Unit 3 TS due to the use of GE13 fuel and the cycle-specific analysis i
performed by General Electric Nuclear Energy (GENE) for PBAPS, Unit 3 Cycle 12.
l The GE13 fuel product line has been developed in order to provide fuel with improved critical power performance and fuel cycle economics. The primary differences between the new GE13 fuel design and the GE11 fuel design are as follows:
L 1)
The part-length fuel rods in the GE13 fuel are twelve inches longer than those of GE11; 2)
- GE13 has one more fuel pin spacer than GE11; and 3)
A GE13 bundle has a mass approximately two kilograms greater than GE11.
l The GE13 fuel product line is compatible with the co-resident fuel in the PBAPS, Unit 3 reactor core, reactor pressure vessel internals, spent fuel pool internals, refueling apparatus, and other plant systems. The thermal-mechanical, nuclear, and thermal-hydraulic behavior of the GE13 fuel design during steady-state, transient, and accident conditions in the reactor core complies with the existing fuel licensing criteria as discussed in NEDE-32198P, "GE13 Compliance With Amendment 22 of NEDE-24011-P-A (GESTAR ll)," dated December 1993.
The calculation of the cycle-specific, two-loop and single-loop operation SLMCPR values for PBAPS, Unit 3, Cycle 12, are based upon USNRC-approved methodology described in " General Electric Standard Application for Reactor Fuel," NEDE-24011-P-A-13, and U.S. Supplement, NEDE-24011-P-A-13-US, August,1996, and the
" Proposed Amendment 25 to GE Licensing Topical Report NEDE-24011-P-A (GESTAR ll) on Cycle Specific Safety Limit MCPR." Proposed Amendment 25 was submitted by GENE to the U. S. Nuclear Regulatory Commission (USNRC) on December 13,1996.
j Revision 13 of GESTAR ll requires that the SLMCPR be reconfirmed each cycle. This l
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l Docket No. 50-278 License No. DPR-56 reconfirmation was performed using the procedures contained in the proposed Amendment 25 to GESTAR which include utilization of cycle-specific parameters such as: 1) the actual core loading, 2) conservative variations of projected control blade patterns, 3) the actual bundle parameters (e.g., local peaking), and 4) the full cycle exposure range.
The SLMCPR is selected such that 99.9% of the rods in the core are expected to avoid transition boiling. The results of the GENE analysis for PBAPS, Unit 3 Cycle 12 show a MCPR Safety Limit of 1.11 for two-loop operation and 1.12 for single-loop operation.
The methodology for determining the conservative variations of projected control blade patterns used to calculate the SLMCPR for PBAPS, Unit 3 is discussed in the letter.
Therefore, we propose that PBAPS, Unit 3 TS 2.1.1.2 be revised to reflect the change in the SLMCPRs.
Safety Assessment i
The proposed TS change will revise TS 2.1.1.2 to reflect the changes in the SLMCPRs due to the use of GE13 fuel and the cycle-specific analysis performed by GENE for PBAPS, Unit 3 Cycle 12. The new SLMCPRs are calculated using USNRC-approved methodology described in " General Electric Standard Application for Reactor Fuel,"
i NEDE-24011-P-A-13, and U.S. Supplement, NEDE-24011-P-A-13-US, August,1996, and the " Proposed Amendment 25 to GE Licensing Topical Report NEDE-24011-P-A l
(GESTAR 11) on Cycle Specific Safety Limit MCPR." Amendment 25 was submitted by j
l GENE to the U. S. Nuclear Regulatory Commission (USNRC) on December 13,1996.
The SLMCPRs are set high enough to ensure that greater than 99.9% of all fuel rods in the core avoid transition boiling if the limit is not violated. The MCPRs are calculated
)
i to include cycle-specific parameters which include: 1) the actual core loading, 2) conservative variations of projected control blade patterns, 3) the actual bundle parameters (e.g., local peaking), and 4) the full cycle exposure range. The new SLMCPRs at PBAPS, Unit 3 Cycle 12 are 1.11 and 1.12 (single-loop operation).
Information Suooortina a Findina of No Sionificant Hazards Consideration We have concluded that the proposed change to the PBAPS, Unit 3 TS, which will revise TS 2.1.1.2 to change the SLMCPRs due to the use of GE13 fuel, does not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards set forth in 10 CFR 50.92 is provided below.
1.
The orooosed TS chances do not involve a sianificant increase in the probability or consecuences of an accident oreviously evaluated.
The derivation of the cycle-specific SLMCPRs for incorporation into the TS, and its use to determine cycle-specific thermal limits, have been performed using the methodology discussed in " General Electric Standard Application for Reactor i-Fuel," NEDE-24011-P-A-13, and U.S. Supplement, NEDE-24011-P-A-13-US, 2
Docket No. 50-278 License No. DPR-56
. August,1996, and the " Proposed Amendment 25 to GE Licensing Topical Report NEDE-24011-P-A (GESTAR ll) on Cycle Specific Safety Limit MCPR."
Amendment 25 was submitted by GENE to the U. S. Nuclear Regulatory Commission (USNRC) on December 13,1996. This change in SLMCPRs cannot increase the probability or severity of an accident.-
The basis of the SLMCPR calculation is to ensure that greater than 99.9% of all fuel rods in the core avoid transition boiling if the limit is not violated. The new SLMCPRs preserve the existing margin to transition boiling and fuel damage in the event of a postulated accident. The fuel licensing acceptance criteria for the SLMCPR calculation app!y to PBAPS, Unit 3, Cycle 12 in the same manner as they have applied previously. The probability of fuel damage is not increased.
Therefore, the proposed TS changes do not involve an increase in the probability or consequences of an accident previously evaluated.
2.
The proposed TS chanoes do not create the possibility of a new or different kind of accident from any accident previousiv evaluated.
The SLMCPR is a TS numerical value, designed to ensure that transition boiling does not occur in 99.9% of all fuel rods in the core during the limiting postulated accident it cannot create the possibility of any new type of accident. The new SLMCPRs are calculated using methodology discussed in " General Electric Standard Application for Reactor Fuel," NEDE-24011-P-A-13, and U.S.
Supplement, NEDE-24011-P-A-13-US, August,1996, and the " Proposed Amendment 25 to GE Licensing Topical Report NEDE-24011-P-A (GESTAR ll) on Cycle Specific Safety Limit MCPR." Amendment 25 was submitted by GENE to the U. S. Nuclear Regulatory Commission (USNRC) on December 13,1996.
Therefore, the proposed TS changes do not create the possibility of a new or different kind of accident, from any accident previously evaluated.
3.
The orooosed TS chances do not involve a sionificant radudion in a marain of
- safety, The margin of safety as defined in the TS Bases will remain the same. The new SLMCPRs are calculated using methodology discussed in " General Electric Standard Application for Reactor Fuel," NEDE-24011-P-A-13, and U.S.
Supplement, NEDE-24011-P-A-13-US, August,1996, and the " Proposed Amendment 25 to GE Licensing Topical Report NEDE-24011-P-A (GESTAR ll) on Cycle Specific Safety Limit MCPR." Amendment 25 was submitted by GENE to the U. S. Nuclear Regulatory Commission (USNRC) on December 13,1996.
The fuel licensing acceptance criteria for the calculation of the SLMCPR apply to PBAPS, Unit 3 Cycle 12 in the same manner as they have applied previously.
The SLMCPRs ensure that greater than 99.9% of all fuel rods in the core will avoid transition boiling if the limit is not violated,- thereby preserving the fuel cladding integrity. Therefore, the proposed TS changes do not involve a reduction in a margin of safety.
3
Docket No. 50-278 License No. DPR-56 Information Suooortina an Environmental Assessment An environmental assessment is not required for the proposed changes since the proposed changes conform to the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The proposed changes will have no impact on the environment. The proposed changes do not involve a significant hazards consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed this proposed change to the PBAPS, Unit 3 TS and have concluded that it does not involve an unreviewed safety question, and will not endanger the health and safety of the public.
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