ML20206N183
| ML20206N183 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/28/1999 |
| From: | Hetzel W, Watford G GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20137N757 | List: |
| References | |
| J11-03412SRLR, J11-03412SRLR-R00, J11-3412SRLR, J11-3412SRLR-R, NUDOCS 9905170163 | |
| Download: ML20206N183 (33) | |
Text
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-324 LICENSE NO. DPR-62 TRANSMITTAL OF CORE OPERATING LIMITS REPORT, SUPPLEMENTAL RELOAD LICENSING REPORT, AND LOSS-OF-COOLANT ACCIDENT ANALYSIS REPORT
" SUPPLEMENTAL RELOAD LICENSING REPORT FOR BRUNSWICK STEAM ELECTRIC PLANT UNIT 2 RELOAD 13 CYCLE 14,"
Jl1-03412SRLR, REVISION 0, CLASS I, FEBRUARY 1999 l
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9905170163 990511 PDR ADOCK 05000324 PDR P
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GENuclearEnergy J11-03412SRLR Resision 0 Class I February 1999 Supplemental Reload Licensing Report for BRUNSWICK STEAM ELECTRIC PLANT UNIT 2 Reload 13 Cycle 14 i
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GE NucIsar Encrgy Jil-03412SRLR Revision 0 Class I February 1999 J11-03412SRLR, Rev. O Supplemental Reload Licensing Report for Brunswick Steam Electric Plant Unit 2 Reload 13 Cycle 14
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A-!
Approved Approved
.A. Wat rd, Manager W.H. Hetzel Nuclear Fuel Engineering Fuel Project Manager
BRUNSWICK 2 Jl1-03412SRLR Reload 13 Rev.O Important Notice Regarding Contents of This Report Please Read Carefully This report was prepared by General Electric Company (GE) solely for Carolina Power and Light Company (CP&L) for CP&L's use in defining operating limits for the Brunswick Steam Electric Plant Unit 2. The information contained in this report is be!!eved by GE to be an accurate and true representation of the facts known or obtained or provided to GE at the time this report was prepared.
The only undertakings of GE respecting information in this document are contained in the contract between CP&L and GE for nuclear fuel and related services for the i
nuclear system for Brunswick Steam Electric Plant Unit 2 and nothing contained in this document shall be construed as changing said contract. The use of this information except as defined by said contract, or for any purpose other than that for which it is intended, is not authorized; and with respect to any such unauthorized use, neither GE nor any of the contributors to this document makes any representation or warranty (expressed or implied) as to the completeness, accuracy or usefulness of the information contained in this document or that such use of such information may not infringe privately owned rights; nor do they assume any responsibility for liability or damage of any kind which may result from such use of such information.
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j 4
Page 2
n BRUNSWICK 2 J11-03412SRLR Reload 13 Rev.0 Acknowledgement The engineering and reload licensing analyses, which form the technical basis of this Supplemental Reload Licensing Report, were performed by G.M. Baka, H.M. Schrum and P. Wei. The Supplemental Reload Licensing Report was prepared by G.M. Baka. This document has been verified by D.P. Stier.
Page 3
BRUNSWICK 2 Jl1-03412SRLR l
Reload 13 Rev.0 l
l The basis for this report is General Electric Standard Applicationfor Reactor Fuel, NEDE-24011-P-A-13, August 1996; and the U.S. Supplement, NEDE-240ll-P.A-13-US, August 1996.
1.
Plant-unique Items Appendix A: Analysis Conditions Appendix B: Main Steamline Isolation Valve Out of Service (MSIVOOS)
Appendix C: Decrease in Core Coolant Temperature Events Appendix D: Feedwater Temperature Reduction (FWTR)
Appendix E: Maximum Extended Operation Domain (MEOD)
Appendix F: Turbine Bypass Out of Service (TBPOOS) 2.
Reload Fuel Bundles '
Cycle Fuel Type Loaded Number Irradiated:
j l
GE13-P9DTB363-1 I GZl-100T-146-T (G E13) 12 58 GE13-P9DTB363-l l GZ-100T-146-T (GE13) 12 118 GE13-P9DTB395-12GS.0-100T-146-T (GE13) 13 80 GE13-P9DTB393-4G6.0/9GS.0-100T-146-T (GE13) 13 104 I
New:
GE13-P9DTB403 5G6.0nGS.0-100T-146-T(GE13) 14 64 GE 13-P9DTB403-7G6.0nG S.0- 100T-146-T (GE 13) 14 136 560 Total
' The Cycle 14 core will contain four (4) lead qualification assemblies (LQAs) from Siemens. These were modeled as fresh GE13 bundles. All licensing implications of these LQAs will be hr.ndled by CP&L.
Page 4
n BRUNSWICK 2 J11-03412SRLR Reload 13 Rev.0 i
8 3.
Reference Core Loading Pattern i
Nominal previous cycle core average exposure at end of cycle:
29056 mwd /MT
( 26359 mwd /ST)
Minimum previous cycle core average exposure at end of cycle 28661 mwd /MT from cold shutdown considerations:
( 26001 mwd /ST)
Assumed reload cycle core average exposure at beginning of 15205 mwd /MT cycle:
( 13794 mwd /ST)
Assumed reload cycle core average exposure at end of cycle:
31605 mwd /MT
( 28672 mwd /ST)
Reference core loading pattern:
Figure 1 4.
Calculated Core Effective Multiplication and Control System Worth - No Voids,20*C Beginning of Cycle, keffective Uncontrolled 1.111 Fully controlled 0.958 Strongest control rod out 0.987 R, Maximum increase in cold core reactivity with exposure into cycle, Ak 0.000 l
1 5.
Standby Liquid Control System Shutdown Capability Boron (ppm)
Shutdown Margin (Ak)
(at 20'C)
(at 20 C, Xenon Free) 660 0.031 6.
Reload Unique GETAB Anticipated Operational Occurrences (AOO) Analysis Initial Condition Parameters Exposure: BOC14 to EOC14-2205 mwd /MT (2000 mwd /ST) with ICF Peaking Factors Fuel Bundle Bundle Initial Design Local Radial Axial R-Factor Power Flow MCPR (MWt)
(1000 lb/hr)
GE13 1.45 1.47 1.41 1.020 6.536 112.3 1.34 8 The previous cycle core average exposure at beginning of cycle is 15417 mwd /MT (13986 mwd /ST).
Page 5
l BRUNSWICK 2 J11-03412SRLR l
Reload 13 Rev.0 1
Exposure: EOC14-2205 mwd /MT (2000 mwd /ST) to EOC14 with ICF Peaking Factors Fuel Bundle Bundle Initial Design Local Radial Axial R-Factor Power Flow MCPR (MWt)
(1000 lb/br)
GE13 1.45 1.52 1.19 1.020 6.764 110.2 1.35 Exposure: BOC14 to EOC14 with TBPOOS l
Peaking Factors Fuel Bundle Bundle Initial Design Local Radial Axial R-Factor Power Flow MCPR (MWt)
(1000 lb/hr)
GE13 1.45 1.50 1.19 1.020 6.662 110.8 1.38 7.
Selected Margin Improvement Options Recirculation pump trip:
No Rod withdrawal limiter:
No Thermal power monitor:
Yes improved scram time:
Yes (ODYN Option B) i Measured scram time:
No Exposure dependent limits:
Yes Exposure points analyzed:
2 (EOCl4-2205 mwd /MT and EOCl4) 8.
Operating Flexibility Options Yes Single-loop operation:
Load line limit:
Yes Extended load line limit:
Yes Maximum extended load line limit:
Yes Increased core flow throughout cycle:
Yes 104.5 %
Flow point analyzed:
Page 6
BRUNSWICK 2 J11-03412SRLR Reload 13 Rev.O Increased core flow at EOC:
Yes Feedwater temperature reduction throughout cycle:
Yes Temperature reduction:
I l0.3*F Final feedwater temperature reduction:
Yes ARTS Program:
Yes Maximum extended operating domain:
Yes Moisture separator reheater OOS:
No Turbine bypass system OOS:
Yes Safety / relief valves OOS:
Yes (Additional evaluations are (credit taken for 9 of 11 valves) required to support this option.)
ADS OOS:
Yes (2 valves OOS)
No Main steam isolation valves OOS:
Yes 9.
Core-wide AOO Analysis Results Methods used: GEMINI; GEXI PLUS Exposure range: BOC14 to EOC14-2205 mwd /MT (2000 mwd /ST) with ICF Uncorrected ACPR Event Flux Q/A GE13 Fig.
(%NBR)
(%NBR)
Load Reject w/o Bypass 424 120 0.25 2
Exposure range: EOC14-2205 mwd /MT (2000 mwd /ST) to EOC14 with ICF Uncorrected ACPR Event Flux Q/A GE13 Fig.
(%NBR)
(%NBR)
Load Reject w/o Bypass 338 118 0.27 3
Page 7
l BRUNSWICK 2 Jl1-03412SRLR
- Reload 13 Rev.0 Exposure range: BOC14 to EOC14 with TBPOOS Uncorrected ACPR Event Flux Q/A GE13 Fig.
(%NBR)
(%NBR)
FW Controller Failure 327 123 0.29 4
- 10. Local Rod Withdrawal Error (With Limiting Instrument Failure) AOO Summary he rod withdrawal error (RWE) event in the maximum extended operating domain was originally analyzed in the GE BWR Licensing Report, Maximum Extended Operating Domain Analysis for Brun: wick Steam Electric Plant, NEDC-31654P, February 1989. The MCPR for rod withdrawal error is bounded by the operating limit MCPRs presented in Section 11 of this report for RBM setpoints shown in Table 10-5(a) or 10-5(b) of NEDC-31654P. Additionally, the RBM operability requirements specified in Section 10.5 of NEDC-31654P have been evaluated and shown to be sufficient to ensure that the Safety Limit MCPR and cladding 1% plastic strain criteria will not be exceeded in the event of an unblocked RWE event.
- 11. Cycle MCPR Values '
In agreement with commitments to the NRC (letter from M. A. Smith to the Document Control Desk, 10CFR Part 21, Reportable Condition, Safety Limit MCPR Evaluation, May 24,1996) a cycle-specific Safety Limit MCPR calculation was performed, and has been reported in both the Safety Limit MCPR and the Operating Limit MCPR shown below. The cycle-specific single loop operation Safety Limit was
- calculated to be 0.01 greater than the two loop Safety Limit MCPR as shown below. His cycle specific SLMCPR was determined using the analysis basis documented in GESTAR with the following exceptions:
- 1. The reference core loading was analyzed.
- 2. The actual bundle parameters (e.g., local peaking) were used.
- 3..The full cycle exposure range was analyzed.
Safety limit:
1.09 Single loop operation safety limit:
1.10 The Operating Limit MCPRs for two loop operation (TLO) bound the Openting Limit MCPRs for single loop 8
operation (SLO); therefore, the Operating Limh MCPRs need not be changed for SLO.
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I BRUNSWICK 2 Jl1-03412SRLR l
Reload 13 Rev.0 Non-pressurization events:
Exposure range: BOC14 to EOC14 GE13 Fuel Loading Error (misoriented) 1.29 Fuel Loading Error (mislocated) 1.22 Rod Withdrawal Error (for RBM setpoint of 108%)
1.23 Pressurization events:
Exposure range: BOC14 to EOC14-2205 mwd /MT (2000 mwd /ST) with ICF '
Exposure point: EOC14-2205 mwd /MT (2000 mwd /ST) l Option A Option B GE13 GE13 Load Reject w/o Bypass 1.39 1.34 Exposure range: EOC14-2205 mwd /MT (2000 mwd /ST) to EOC14 with ICF 5
Exposure point: EOC14 Option A Option B GE13 GE13 Load Reject w/o Bypass 1.46 1.38 Exposure range: BOC14 to EOC14 with TBPOOS
- Exposure point: EOC14 Option A Option B GE13 GE13 FW Controller Failure 1.48 1.40
- The ICF Operating Limits for the exposure range of BOCl4 to EOCl4-2205 mwd /MT (2000 mwd /ST) bound i
the Operating Limits for the following domains: MELLL, ICF and FWTR, MSIVOOS and ICF.
51he ICF Operating Limits for the exposure range of EOCl4-2205 mwd /MT (2000 mwd /ST) to EOCl4 bound the operating Limits for the following domains: MELLL, ICF and FWTR, MSIVOOS and ICF.
- The TBPOOS Operating Limits for the exposure range of BOCl4 to EOCl4 bound the Operating Limits for the TBPOOS and FWTR domain.
Page 9
)
BRUNSWICK 2 Jl1-03412SRLR Reload 13 Rev.0
- 12. Overpressurization Analysis Summary Psi Pv Plant Event (psig)
(psig)
Response
MSIV Closure (Flux Scram) 1289 1323 Figure 5
- 13. Loading Error Results Variable water gap misoriented bundle analysis: Yes '
Misoriented Fuel Bundle ACPR GE13 P9DTB395-12GS.0-100T-146-T(GE13) 0.19 G E 13-P9DTB 393 -4 G 6.0/9G S.0- 100T-146-T (G E 13 )
0.20 G E 13-P9DTB403-7G6.0/7G5.0- 100T-146-T (G E 13) 0.10 GE 13-P9DTB403-5G6.0/7G 5.0- 100T-146-T (G E 13 )
0.06 i
Mislocated Fuel Bundle ACPR l
i Fuel Loading Error (mislocated) 0.13
- 14. Control Rod Drop Analysis Results This is a banked position withdrawal sequence plant, therefore, the control rod drop accident analysis is j
not required. NRC approval is documented in NEDE-24011-P-A-US.
l
- 15. Stability Analysis Results Brunswick Unit 2 Cycle 13, Reactor Stability Long-Term Solution Enhanced Opti":: l-A, Stability Region j
Boundary Generation and Validation, GENE-A13-00367-58 documents the Enhanced Option I-A (EIA) stability region boundaries for Brunswick Unit 2 Cycle 13 and the analysis associated with their generation and validation. Reload validation of these stability region boundaries has been performed in accordance with NEDO-32339, Revision 1, Reactor Stability Long Term Solution: Enhanced Option I-A.
The Reload Validation Matrix confirms best-estimate code boundary validation stability criteria. The results are shown in Figure 6.
' Includes a 0.02 penalty due to variable water gap R-factor uncertainty.
Page 10
U BRUNSWICK 2 J11-03412SRLR Reload 13 Rev.0
De GE8x8EB LOCA analysis results, presented in Sections 5 and 6 of Brunswick Steam Electric Plant Units 1 and 2 SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis, NEDC-31624P, Revision 2, l
' July 1990, yielded a licensing basis peak clad temperature of 1537'F, a peak local oxidation fraction of
<031%, and a core-wide metal-water reaction of 0.036%.
l An additional LOCA analysis was performed for the GE13 fuel type. The results, presented in Brunswick Steam Electric Plant Units 1 and 2 SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis:
Application to GE13 Fuel, NEDC-31624P, Supplement 3, Revision 0, January 1996, indicate that the GE13 fuel is bounded by the results from GE8x8EB fuel.
His analysis did not establish new Licensing Basis PCTs for the fuels in BSEP-2. Herefore, the following changes and error effects must be added to the Licensing Basis PCT of 1537'F: 10'F for l
Bottom Head Drain (see Reporting of Changes and Errors in ECCS Evaluation Models, MFN-020-%,
l February 20,1996) and 50*F for sensitivity to small input parameter changes for BWR/4 plants with LPCI injection into the lower plenum (see Reporting of Changes and Errors in ECCS Evaluation i
Models, MFN-090-93, June 30,1993). De corrected Licensing Basis PCT is 1597'F.
A single loop operation (SLO) MAPLHGR multiplier of 0.80 is applicable to GE13 fuel types.
Derefore, the power-and flow-dependent MAPLHGR adjustment factors identified in Figures 4-2 and 4-4 of Maximum Extended Operating Domain Analysisfor the Brunswick Steam Electric Plant, NEDC-31654P, Class III (GE Nuclear Energy Proprietary), February 1989, should be used with the limitation j
that no multiplier greater than 0.80 is used during SLO.
The most and least limiting MAPLHGRs for the new GE13 fuel designs are as follows:
1 l
Page11
h BRUNSWICK 2 Jl1-03412SRLR Reload 13 Rev.O I
- 16. Loss-of-Coolant Accident Results (cont.) ~
l l
l Bundle Type: GE13-P9DTB403-7G6.0/7G5.0 100T-146-T l
Average Planar Exposure MAPLHGR (kw/ft)
(GWd/ST)
(GWd/MT)
Most Limiting Least Limiting 0.00 0.00 10.44 10.44 j
0.20 0.22 10.51-10.51 1.00 1.10 10.61 10.63 2.00 2.20 10.74 10.77 3.00 3.31 10.88 10.93 4.00 4.41 11.02 11.09 5.00 5.51 11.17 11.26 6.00 6.61 1132 11.43 7.00 7.72 11.48 11.59 8.00 8.82 11.62 11.74 9.00 9.92 11.73 11.89 10.00 11.02 11.85 12.04 12.50 13.78 11.86 12.16 15.00 16.53 11.86 12.21 17.50 19.29 11.76 12.06 20.00 22.05 11.54 11.80 25.00-27.56 11.02 11.25 30.00 33.07 10.49 10.70 35.00 38.58 9.85 10.01 40.00 44.09 9.13 9.26 45.00 49.60 8.43 8.52 50.00 55.12 7.73 7.81 55.00 60.63 7.03 7.14 58.33 64.29 6.56 6.61 6.49 59.06 65.11
)
Page 12 l
l
BRUNSWICK 2 Jl 1-03412SRLR Reload 13 Rev.0
- 16. Loss-of-Coolant Accident Results (cont.)
Bundle Type: GE13-P9DTB403 5G6.0/7GS.0-100T-146-T Average Planar Exposure MAPLHGR (kw/ft)
(GWd/ST)
(GWd/MT)
Most Limiting Least Limiting 0.00 0.00 10.65 10.73 0.20 0.22 10.72 10.79 1.00 1.10 10.85 10.88 2.00 2.20 11.00 11.03 3.00 3.31 11.I2 11.21 4.00 4.41 11.25 11.35 5.00 5.51 11.38 11.50 6.00 6.61 11.52 11.66 7.00 7.72 11.66 11.82 8.00 8.82 11.81 11.99 9.00 9.92 11.95 12.12 10.00 11.02 12.05 12.26 12.50 13.78 12.04 12.36 15.00 16.53 11.97 12.29 17.50 19.29 11.79 12.07 20.00 22.05 11.54 11.79 25.00 27.56 11.02 11.23 30.00 33.07 10.44 10.49 35.00 38.58 9.69 9.85 40.00 44.09 8.98 9.14 45.00 49.60 8.30 8.44 50.00 55.12 7.64 7.74 55.00 60.63 7.00 7.05 58.49 64.48 6.54 6.55 59.19 65.25 6.45 l
%ge 13
BRUNSWICK 2 Jl1-03412SRLR Reload 13 Rev.0 eMMMME oHMMMMMMMMo MMMMMMMMMMM
- eMMMMMMMMMEL
{
- MMMMMMMMMMMMM
- M M M M M M M M M M M M M
- MMMMMMMMMMMMM
- MMMMMMMMMMMME l
- M M M M M M M M M M M M M MEMMMMMMMMM MMMMMMMMMMM MMHHHHHHH MMMMM lil IIIIIII 4
1 3 5 7 9 il 15 !$ 17 19 21 25 25 27 29 81 68 85 57 69 41 46 45 47 49 51 Fuel Type A=GE 13-P9DTB363-I I GZ l - 100T-146-T (Cycle 12)
D=GE13-P9DTB403-7G6.0/7GS.0-100T-146-T (Cycle 14)
B=GE13-P9DTB395-12G5.0-100T-146 T (Cycle 13)
E=GE13-P9DTB403-5G6.0'7GS.0-100T-146-T (Cycle 14)
C=GE13 P9DTB393-4G6.0/9G5.0-100T 146-T (Cycle 13)
F=GE13-P9DTB363-llGZ-100T 146-T (Cycle 12)
Figure 1 Reference Core Loading Pattern Page 14
f BRUNSWICK 2 J1103412SRLR Reload 13 Rev.0 1
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Figure 3 Plant Response to Load Reject w/o Bypass (EOC14 2205 mwd /MT (2000 mwd /ST) l to EOC14 with ICF)
Page 16 l
l
BRUNSWICK 2 311-03412SRLR Reload 13 Rev.0
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Page 17
BRUNSWICK 2 J11-03412SIER Reload 13 Rev.0
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Page 18
BRUNSWICK 2 Jl1-03412SRLR Reload 13 Rev.0 1
0.9
- - - i - - - -l- - - - t - - - -l - - - l- - - ' - - - - l- - - - t - - - -l - - - -
ODYSY Stability i
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channel pecay Ratio Figure 6 RVM Results versus ODYSY Stability Criteria Page 19 1
BRUNSWICK 2 Jl1-03412SRLR Reload 13 Rev.0 Appendix A Analysis Conditions To reflect actual plant parameters accurately, the values shown in Table A-1 were used this cycle.
Table A-1 Analysis Value Parameter ICF FWTR Thermal power, MWt 2558.0 2558.0 Core flow, Mlb/hr 80.5 80.5 Reactor pressure, psia 1060.9 1044.9 Inlet enthalpy, BTU /lb 530.7 517.5 Non-fuel power fraction 0.036 0.036 Steam flow, Mlb/hr 11.09 9.66 Dome pressure, psig 1030.0 1015.3 Turbine pressure, psig 985.4 981.2 No. of Safety / Relief Valves 9
9 Relief mode lowest setpoint, psig 1164.0 1164.0 Recirculation pump power source on-site '
ca. site '
Turbine control valve mode of operation Panial arc Partial are
' Bounds operation with off-site power source for reload licensing events for Cycle 14.
Page 20
1 BRUNSWICK 2 Jil-03412SRLR l
Reload 13 Rev.0 l
Appendix B 1
l Main Steamline Isolation Valve Out of Service (MSIVOOS) i i
Reference B-1 provided a basis for operation of the Brunswick Steam Electric Plant (BSEP) with one Main Steamline isolation Valve Out of Service (MSIVOOS)(three steamline operation) and all S/RVs in service. For this mode of operation in BSEP Unit 2 throughout Cycle 14, the ICF operating limit MCPRs presented in Section i1 of this repon are bounding and should be applied when operating in the MSIVCOS mode at any time during the cycle. The peak steamline and peak vessel pressures for the limiting overpressurization event (MSIV closure with flux scram) were not calculated for the MSIVOOS mode of operation, in this mode of operation it is required that all S/RVs be operational versus the assumed two S/RVs OOS for the events evaluated during normal plant operation. Previous cycles analyses have shown that the MSIV closure with flux scram, evaluated in the MSIVOOS mode, has resulted in the peak vessel pressure being reduced by more than 25 psi, when compared to the same case evaluated with all (four) steamlines operational.
Reference B-1, Main Steamline Isolation Valve Out ofServicefor the Brunswick Steam Electric Plant, EAS-117-0987, GE Nuclear Energy, April 1988.
Page 21
BRUNSWICK 2 Jil-03412SRLR Reload 13 Rev.0 Appendir. C Decrease in Core Coolant Temperature Events The Loss of Feedwater Heater (LFWH) event and the inadvertent HPCI start-up event are the only cold water injection AOOs checked on a cycle-by-cycle basis.
The LFWH transient was last analyzed for Brunswick-1 Cycle 11 (a power uprate GE13 reload) and had a resulting ACPR of 0.12. The Brunswick-1 and Brunswick-2 plants are nearly identical and have identical licensing basis heat balance conditions. There is no difference in equipment performance in Brunswick 2 Cycle 14 as compared to Brunswick-1 Cycle 11 which indicates a need for a specific analysis. The results of the AOOs presented in Section 11 of this report sufficiently bound the expected results of the LFWH event. Therefore, the LFWH event is not limiting and analysis is not required.
In addition, the inadvertent HPCI stan-up event was shown to be bounded by the LFWH event in Brunswick-1 Cycle 11. No parameters in Brunswick-2 Cycle 14 differ so as to invahdate the Brunswick-1 Cycle 11 determination. Therefore, the Brunswick-1 Cycle 11 analysis is applicable to Brunswick-2 Cycle 14 and the Inadvertent HPCI transient is bounded by LF%H.
l Page 22
i BRUNSWICK 2 Jl1-03412SRLR Reload 13 Rev.0 l
Appendix D l
Feedwater Temperature Reduction (FWTR)
Reference D-1 provides the basis for operation of the Brunswick Steam Electric Plant (BSEP) with Feedwater Temperature Reduction (FWTR). The MCPR limits presented in Section 11 of this report are bounding and should be applied when operating with FWTR. The MCPR limits apply to operation up to the exposure attainable using increased Core Flow with Final Feedwater Temperature Reduction (which for Cycle 14 is a core average exposure of 32442 mwd /MT). Previous analysis has shown that the FWCF event is most severe at ICF and FWTR. The analyses used to calculate FWTR limits were based on constant turbine pressure which bounds constant dome pressure.
Reference D-1. Feedwater Temperature Reduction with Maximum Extended Load Line Limu and Increased Core Flowfor Brunswick Steam Electric Plant Units 1 and 2, NEDC-32457P, Revision 1, December 1995.
Page 23 l
BRUNSWICK 2 311-03412SRLR Reload 13 Rev.O Appendix E Maximum Extended Operating Domain (MEOD)
Reference E-1 provided a basis for operation of the Brunswick Steam Electric Plant (BSEP) in the Maximum Extended Operating Domain (MEOD). Previous cycles have shown that these low flow conditions are bounded by ICF, therefore this domain was not analyzed for Cycle 14. Application of the GEXL-PLUS correlation to the reload fuel has been confirmed as required in reference E-1. The applicability of GE13 was addressed and found acceptable.
Reference E-1. Maximum Extended Operating Domain Analysis for Brunswick Steam Electric Plant, NEDC-31654P, GE Nuclear Energy (Proprietary), February 1989.
Page 24
BRUNSWICK 2 J11-03412SRLR Reload 13 Rev.0 Appendix F Turbine Bypass Out Of Service (TBPOOS)
Reference F-1 provided a basis for operation of the Brunswick Steam Electric Plant (BSEP) with all Turbine Bypass Valves Out of Service (TBPOOS) and two S/RVs Out of Service (2 SRVOOS).
Reference F-1 has been confirmed applicable to the operation of BSEP Unit 2 for Cycle 14. Section 11 of this report presents the MCPR limits for the modes of operation with TBPOOS.
Reference F-1. Turbine Bypass Out ofService Analysisfor Carolina Power & Light Company's Brunswick Nuclear Plcnts Units 1 and 2, NEDC-32813P, Revision 3, GE Nuclear Energy (Proprietary), June 1998.
l Page 25
5 O
GE Nuclear Energy aman w a n o m con,any P. o. mar res. Innhosan.Ne asser Affidavit I, Glen A. Watford, being duly sworn, depose and stata as follows.
(1) I am "- ;-, Nuclear Fuel Engmeenng, General Electnc Company ("GE") and have been delegated the fuartimi of reviewing the information described in paragraph (2) which is sought to be withhald, and have been authonaed to apply for its withholdmg (2) 'Ihe informatmo sought to be withhald is contained in the report, NEDC-31624P, Supplement 2, Revision 2, Loss-of-Coolant Accident Analysis Reportfor Brunswick Steam Electric Plant Unit 2, Reload 13, Cycle 14.
(3) In making this applicaten for wnhholdmg of proprietary informaten of which it is the owner, GE relies upon the exemptium from diaclaanse set forth in the Freedom ofInformation 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) and 2.790(a)(4) for " trade secrets and cu...,
di.1 or fmancial informatma obtamed from a person and privdeged or naandantial" (Fv=a*6 4). 'Ihe material for wluch exemption from disclosure is here sought is all "naandantial co.-..
dal information," and some portions also quahfy under the narrower dormition of" trade secret," within the meanmas assigned to those terms for purposes of FOIA Fv-neiaa 4 in, respectively, Critial h8mme Fmav Praiant v.
Nuclear Regulatory Commission. 975F2d871 (DC Cir.1992), and Pubhc Citizen Health Research Groun v. FDA. 704F2dl280 (DC Cir.1983).
(4) Some examples of categones of information wiuch fit into the defmition of proprietary informaten are:
a.
Information that disclaman a process, method, or apparatus, including supporting data and analyses, where,,.eA of its use by General Electric's competitors without license from General Electric constitutes a competitive econonuc advantage over other companies;
- b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or heensing of a sindar product; c.
Informatian which reveals cost or price information, production capacities, budget levels, or vu....
dal stratespes of General Electnc, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future General Electric customer-funded dcvdq,.. ; plans and programs, of potential commercial value to General Electnc; Informaten which disclamaa patentable subject matter for winch it may be desirable to c.
obtam patent proractiaa Page1
At& davit
& mformation sought to be mthheld is nanadered to be proprietary for the reasons set forth in both paragraphs (4)a. and (4)b., above (5) The infonnation sought to be withheld is being subnutted to NRC in eaa% The information is of a sort customardy held in nanndanne by GE, and is in fact so held. Its imtal designation as proprietary 1----
%. and the =d=arriait steps taken to prevent its unauthonzed disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and behef, nana stantly 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 transnuttals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements winch provide for maintenance of the information in confidace (6) Initial approval of propnetary treatment of a document is made by the manager of the onginatmg component, the person most likely to be anryi=== tad with the value and sensitivity of the infonnation 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 authonty, by the manager of the cosmzant marketing function (or his delegate), and by the Legal Operation, for technical nantent, competitive effect, and determmation of the accuracy of the proprietary designation Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and hcensees, and others with a legitimate need for the aformation, and then only in accordance with appropriate regulatory provisions or proprietary agrecunents (8) h information idantinad in paragraph (2) is classified as proprietary henner it nantains detads of GE's fuel designs and the w,n-:ei==; results wiuch GE has applied to actual core designs with GE's fuel.
The hd.,,..
- of the n=*hada used in these analyses, along with the testing, development and approval of the supporting methodology was acineved at a significant oost, on the order of several mdhon dollars, to GE.
(9) Public disclaanse of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and forelaae or reduce the avadability of profit-making opportunities.
The fuel design information is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original dcyd
..a.: cost. The value of the technology base goes beyond the extensive physical Caabase and analytical methodology and includes dcvd.,.
of the expertise to determec and apply the appropnate evaluation process In addition, the technology base includes the value derived from provuhng analyses done with NRC-approved methods lhe research, dcvd.,..r.:, enginsenag, analytical, and NRC review costs comprise a substantial investment of time and money by GE.
N 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 if its competitors are able to use the results of the GE experience to nonnahme or venfy their own proones or if they are abic to claim an equivalent A "; by ?
=-w that they can arrive at the same or sumlar conclusions.
CWm - h Page 2
Affid:vit De value of this information to GE would be lost if the informaton were disclosed to the pub!!c.
Making such information avadable to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a wmdfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
State of North Carolina
)
b County ofNew Hanover
)
I Glen A. Watford, being duly sworn, deposes and says:
4 That he has read the foregomg affidavit and the matters stated therein are true and correct to the best of his knowledge,informaton, and belief.
e
,8d [
Executed at Wil-ia-taa. North Carohna, this l.3 day of
. 19
-k alen A. W ord General Electric Company Subscribed and sworn before me this Mday of h.r2A
.19 N, g
t
%j, Notary blic, State ofNorth Caruhna O
My Commission Expires y-RM-O00/
cumu Pageo
4 A F FID A VIT-STATE OF WASHINGTON )
) ss.
COUNTY OF BENTON
)
.1, H.' D. Curet being duly sworn, hereby say and depose:
1.
I am Manager, Product Licensing, for Siemens Power Corporation ("SPC"), and as such I am authorized to execute this Affidavit.
2.'
I am familiar with SPC's detailed document control system and policies which-govern the protection and control of information.
3.
- I am familiar with Report EMF-2168(P) Revision 0, " Brunswick ATRIUM -10 Lead Qualification Safety Analysis" dated March 1999 referred to as " Document".
' 4.
The Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by SPC and'not made available to the public.
Based on my experience, I am aware that other companies regard information of the kind contained in the Document as proprietary and confidential.
5.
The Document has been made available to the Nuclear Regulatory Commission in confidence, with the request that the information contained in the Document will not be l
disclosed or divulged.
6.
The Document contains information which is vital to a competitive advantage of SPC and would be helpful to competitors of SPC when competing with SPC.
i 1
i i
l j
s.a 7.
The information contained in the Document is considered to be proprietary by SPC because it reveals certain distinguishing aspects of SPC licensing methodology which secure competitive advantage to SPC for fuel design optimization and marketability, and includes information utilized by SPC in its business which affords SPC an opportunity to'obtain a competitive advantage over its competitors who do not or may not know or use the information contained in the Document.
8.
The disclosure of the proprietary information contained in the Document to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it valuable insights into SPC licensing methodology and would result in substantial harm to the competitive position of SPC.
9.
The Document contains proprietary information which is held in confidence by SPC and is not available in public sources.
10.
In accordance with SPC's policies governing the protection and control of information, proprietary information contained in the Document has been made available, on a limited basis, to others outside SPC only as required and under suitable agreement providirig for nondisclosure and limited use of the information.
I 11.
SPC policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
12.
Information in this Document provides insight into SPC licensing methodology developed by SPC. SPC has invested significant resources in developing the methodology as well as the strategy for this application. Assuming a competitor had available the same background data and incentives as SPC, the competitor might, at a minimum, develop the information for the same expend:ture of manpower and money as SPC.
y.*'
THAT the statements made hereinabove are, to the best of my knowledge, information, and belief, truthful and complete.
FURTHER AFFIANT SAYETH NOT.
4 SUBSCRIBED before me this M3 day of M
,1999.
y (4
- pTA8j, NeuG Op ggg M
Sue M. Galpin NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 02/27/00 i
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