ML20203J003
| ML20203J003 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/24/1998 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19317C921 | List: |
| References | |
| GNRO-98-00019, GNRO-98-19, NUDOCS 9803030396 | |
| Download: ML20203J003 (11) | |
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(v r.)(Aft Ns iew Liegi february 24, 1998 U.S. Nuclear Regulatory Commission Mail Station P137 Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-410 License No. NPF 20 Cycle 10 Reload Response to NRC Request for AdditionalInformation Regarding Safety Limit Minimum Critical Power Ratio
References:
1.
GNRO 97/0087, dated September 18,1997, Proposed Amendment to the Operating License GGNS PCOL 97/003 2.
- !RC Letter GNRI 98/00015 dated February 12,1998 Request for Additionallnformation GNRO 98/00019 Gentlemen
Please find attached Entergy Operations, Inc. responso to the NRC Request for Additional Information regarding proposed changes to the Safety Limit Minimum Critical Power Ratio for Grand Gulf Nuclear Station Cycle 10 opr. ration.
The original amendment request (Reference 1) had been reviewed and eccepted by the Plant Safety Review Committee and the Safety Review Committee. The conclusions of the Sonificant Hazards Considerations for this response remain unchanged.
Based on the guidelines in 10CFR50.92, Entergy Operations has concluded that the response to the NRC request for additionalinformation involves no additional significant hazards considerations, iI
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G9802201
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GNRO 98/00019
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Page 2 of 2 i
General Electric considers portions of the infortnation contained in this submitta!
to be proprietary. The proprietary portior$s have been marked by vertical bars in the left hand margin. In accordance with the requirements to 10CFR2.790(b), an affidavit (Attachment 3)is enclosed to support the withholding of the information in this response from public disclosure. A non proprietary copy of the response (Attachment 4) is also attached for your use.
4 Entergy Operations requests NRC approval and issuance of the Technical specification chareges by April 1,1998 to allow related work activities to be implemented prior to startup from the Grand Gulf Refueling Outage Nine (RF09),
now scheduled to begin April 11,1998.
Yours truly, 7
i JJH/ACG/acg attachments:
1.
Affirmation per 10CFR50.30 2.
EOl Response to NRC Request for AdditionalInformation.
3.
General Electric Company's Affidavit to withhold the proprietary leformation.
4.
Non proprietary copy of the Response, cc:
Ms. J. L. Dixon Herrity, GGNS Senior Resident (w/a)
Mr. N. S. Reynolds (w/a)
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 t
Dr. E. F. Thompson (w/a)
State Health Officer State Board of Health P.O. Box 1700 Jackson, Mississippi 39205 G9802201
Att chm:nt i to GNRO 98/00019
+
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION t
i LICENSE NO. NPF 29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.
i AFFIRMATION I, J. J. Hagan, beir.g duty swom, state that I am Acting Vice President, Operations GGNS of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf "aclear Station; that I signed this application as Acting Vice President, Operations GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best c.f my knowledge, information and belief.
I lagan STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TO before
, a Notary Public, in and for the County and State above named, this 2/ U day of e rwte V g /998 ka over/pr
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Notary Public My commission expires:
dt<Ne E /99/
09802201 c..-.
. to GNRO 98/00019 Page 1 o' 5 Enteray Operations Inc.
General Electric Company's Affidavit to withhold the proprietary information l
Response to the NRC Request for Additional Information (PCOL-97/003) l
L Febr"try 18,1998 Page 1 of 4 GENERAL ELECTRIC COMPANY LQiu i
I, Ralph J. Reda, being duly sworn, depose.id state as follows:
(1)
I am tha Fuel Project Manager, at the GE Nuclear Energy Production facility in Wilmington, N.C., and have been delegated the function of reviewing the information described in paragraph 2 which is sought ta be withheld, and have been authorized to apply for its withnolding.
(2)
The information sought to t>e withheld is contained in portions of the Response to NRC Request for AdditionalInformation Regarding Proposed Changes to the Safety Limit MCPR for Cycle 10 Operation Grand gun Nuclear Station. February 18, 1
1998. Proprietary information is indicated using vertical bars ( l ) in the left margin of j
the response to the NRC's questions.
(3)
In making this application for withholding of proprietary information of which it is the j
owner, GE relies upon the exemption from disclosure set forth in the Freedom of 1
Information act ("FOIA"),5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1906, and NRC regulations 10 CFR 9.17(a)(4) and 2.790(a)(4) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential"(Exemption 4). The material f; which exemption from disclosure is hers 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, respective!y, Critical Mass Enerav Project yJ4uclear Reaulatory Commissiq0,975F2d871 (DC Cir.1992), and Public Citizen tiealth Research Group v. FDA,704F2d1280 (DC Cir.1983).
(4)
Some examples of categories of information which fit into the definition of proprie?ary information are:
a.
Information that discloses a process, method l or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors wi;hout license from General Electric constitutes a cornpetitive economic buvantage over other companies; b
Information which, if used by a competitor, would reduce his expenditure of resources or improve his compatitive position in the design, manufacture, ship. ment, installation, assurance of quality, or licensing of a similar product; 4
February it,1998 Page 2 of 4 c.
Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of Gener
'octric its customers, or its suppliers; 4
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, e.
Information which dis &.,ses patentable subject matter for which it may be desirable to obtain patent protection.
The. 'ormation sought to be withheld is considered to be pioprietary for the r',. ons 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 customalily held in confidence by GE.
and is in fact so held. Its initial deslanation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. 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 ;o third parties including any required transmi,tals to NRC have been made, or tr ust be maue, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
(6)
Initial approval of proprietary treatment of a document is made by the manager of the originatie g component, the person most likely to be acquaint.J with the value and sensitivity of the information in relation to industry knowledge.
Access to s7ch documents within GE is limited on a "need to know" basis.
(7)
The procedure for approval of extemal 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 L egal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.- Disclosures outside GE are ilmited to regulatory bodies, customers, and potenital customers, and their agents, suppliers, and licensees, and others with a legitims.te need for the information, and then only in accordance with appropnate regulatory provit.fons or proprietary agreements.
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February 18,1998 Page 3 of 4 1
(8)
The information identified in paragreph (2) is classifiou as proprietary because it would provide other parties, in':luding competitors, with information related to General Electric fuel designs, analysis methods, analysis results, and potential commercial offerings which were developed at a considerable expense to General Electric.
(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 3
- comprehensive BWR safety and 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, analytical, t.
i NRC review costs comprise a substantialinvestment of tima and money by GE.
GE's competitive advantage will be lost if its competitors are abl3 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 strive 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 similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE 1
of the opportunity to exercise its competitive advantage to seek an adequate retum on its large investment in development these very valuable analytical
- tools,
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i February 18,1998 Page 4 of 4 STATE OF NORTH CAROLINA
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COUNTY OF NEW HANOVER
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Ralph J. Reda, being duly swom, deposes and says:
That he has read the foregoing affidavit and the mattors stated therein are true and correct to the best of his knowledge, information, and belief.
TA Executed at Wilmington, North Carolina, this /8 day of h.chyuG
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Ralph'J. ReTa General Electric Company Subscribed and sworn before this /Ny o 4A
,yq9p Nothry %blic, Siate of rthC na My c mmission expires:
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. to GNRO 98/00019 Page 1 of 3 6
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I Enteray Operations Inc.
Non-properietary copy of the Response to the NRC Request for Additional Information (PCOL-97/003) 4 4
.I
r hfon.Pwprict:ry version Hesponse la NHC Hequest for AdditionalInformation Regarding Proposed Changes to the Safety 1,imit Minimum Critical Poner Ratio for GGNS Cycle 10 Operation (TAC No. M99639)
OllESTION 1:
Describe the bases and assumptions for the GGNS Cycle 10 SLMCPR analysis with respect to those mismnptions for the Cycle 9 SLMCPR analysis and identify the differentes and their effects Ir. the applications to the cycle specific analysis using the approach described in GGNS C)cle 9 Safety Limit MCPR Analysis (Jll 02863St.MCPR, Revision 1 July 1996). Provide justification for the decrement of the proposed SLMCPRs in Cycle 10 for two-loop and single loop operations compared with those used in the Cycle 9 operation.
BESPONSE:
Descr he the bases nd assumpwns for the GGNS Cycle 10 SIAICPlt analysts with respect to those anumptions for the Cycle 9 SIAfCPR analysts and identify the dt[lerences and their effects In the apphcations to the cycle specifle analysts using the approach descrabed in GGNS C)rle 9 Safety 1.tmit MCPR Analysts (JI102863SIAfCPR. Reviston 1 July 1996).
He bases and assumptions for the GONS Cycle 10 SLMCPR analysis are identical to those applied in Cycle 9. ne only change for Cycle 10 was the application of the GONS Cycle 10 core design Since the GGNS Cycle 9 analysis was performed, GE has documented their cycle-specific methodology in a Technical Design Procedure which is based on the methodology developed for the GGNS Cycle 9 St MCPR. His procedure was followed in the development of the GGNS Cycle !0 SLMCPR explicitly modeling the GGNS Cycle 10 mised core. The analysis concluded that the Siemens bundles contributed no rods subject to boiling transition to the limiting SLMCPR. This result is due to the low power levels associated with the thrice burned Siemens bundles at the end of GGNS Cycle 10.
Provide just!ficatwn for the decrement of the proposed SIAfCPRs In Cyrle 10for tu a-loop and smgle-loop operatwns compared with those usedin the Cyrie 9 operation.
The Cycle 4 SLMCPR analysis uas developed in Summer 1996. At that time, GE's safety limit methodology did not include an objective measure of the conservatism in the core radial power distribution as established through the control rod pattern. Consequently, EOl compelled GE to identify and apply the absolute worst case control rod pattern for the Cycle 9 SLMCPR analysis, regardless of the credibility of such a rod pattern. This, in etrect, resulted in excessive conservatism in the GGNS SLMCPR analysis.
GE has since developed an objective measure of the conservatism in the core radial power distribution in response to weaknesses identified by the NRC in inspection Report 99900003/96 01. This measure is 1
flon Proprictny Veision Table I compares the significant parameters for the GGNS Cycle 9 and 10 SLMCPR analyses.
Table 1 Comparison of Significant Parameters impacting St,MCPR QtlANTITY, DESCHIPilON Grand Gulf Grand Gulf Cycle 9 Cycle 10 Number of flundles in Core 800 800 1.imiting Cycle !!xposure Point IIOC lK liOC lK C3cle lixposure at Limiting Point (mwd!STU)
I1325 11960 latest Reload 11atch Fraction 1%]
34 0 %
33.5 %
latest Reload Average llatch Weight % linrichment 3 6H%
3.78 %
Core Average Weight % IInrichment 3.43 %
3 60 %
Core MCPR (for liniiting rod pattern) 1.2748 1.2555
% bundles within 0.05 CPR of Core MCPR 13.0 %
50%
% bundles within 0.10 CPR of Core MCPR 14.0%
12 5%
% bundles witnin 0 20 CPR of Core MCPR 20.0 %
19 0 %
% uncontrolled bundles within 0 20 CPR 20.0 %
16 0 %
Maximum Relative Power
_, 1.57 1 57
% bundles within 0.90 of Max Relative Power 16.0 %
14.5 %
Calculata d Two-l.oop Safety 1.imit MCPN 1.12 1.11 OUESTION 2:
Describe the calculational procedures in the cycle specific analysis for Cycle 10 including new set of coefficients based on GE's GEXLO2 for Siemens 9s9 5, uncertainties, and data used to support Cycle 10 analysis Provide a table to show the impact on the cycle specific analysis between Cycle 10 and current Cycle 9.
HESPONSEt The Cycle 10 SLMCPR analysis applied the same calculational procedures for the Siemens 9x9 5 bundles as applied in the Cycle 9 analysis. The Cycle 10 analysis applied the GEXL coefficients and uncertainties reported in GGNS Cycle 9 Safety Litrit MCPR Analysis (Jll 02863SLMCPR, Resision 1 July 1996) for the Siemens 4x9 5 bundles.
Since the Cycle 9 calculation.i approach was applied for the Siemens bundles. there is no impact on the Cycle 10 SLMCPR analysis due to changes in the CPR modeling of the Siemens bundles. In fact. the Siemens bundles were d;termined to have no impact on the limiting Cycle 10 SLMCPR since no Siemens rals were calculated to be subject to boihng transition.
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