ML20209G163
| ML20209G163 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/12/1999 |
| From: | Wanczyk R VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20137X301 | List: |
| References | |
| BVY-99-91, NUDOCS 9907190062 | |
| Download: ML20209G163 (10) | |
Text
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- VERMONT YANKEE
.-y NUCLEAR POWER CORPORATION 185 Old Ferry Road, Brattleboro, VT 05301 7002 (802) 257 5271 July 12,1999 BW 99-91 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271) Technical Specification Proposed Change No. 221 Safety Limit - Minimum Critical Power Ratio Pursuant to 10CFR50.90, Vermont Yankee (W) hereby proposes to amend its Facility Operating License, DPR-28, by incorporating the attached proposed change into the Technical . Specifications (TS) of Vermont Yankee Nuclear Power Station. This proposed change provides a revised value for the Safety Limit Minimum Critical Power Ratio (SLMCPR) and deletion of the wording specifying these as Cycle 20 values. to this letter contains supporting information and the safety assessment of the proposed change. Attachrnent '2 contains the determination of no significant hazards consideration. provides the marked-up version of the current Technical Specification pages. contains the retyped Technical Specification pages. of the enclosed information is a summary of the technical bases for the SLMCPR values and is considered proprietary information by General Electric Nuclear Energy (GENE). In accordance with 10CFR2.790(b)(1), an affidavit attesting to the proprietary nature of the enclosed information is attached, requesting tvithholding from public disclosure. Attachment 6 is the same GENE summary with the proprietary information removed, and is provided for public disclosure. W has reviewed the proposed Technical Specification change in accordance with 10CFR50.92 - and concludes that the proposed change does not involve a significant hazards consideration. l W-has ~ evaluated the proposed amendment against the criteria of 10CFR51.22 for environmental considerations and concludes that the proposed change will not increase the types and amounts of effluents that may be released offsite. Thus, W believes that the proposed change is eligible for categorical exclusion from the requirements for an environments' impact statement in accordance with 10CFR51.22(c)(9). l P I Regarding our proposed schedule for this amendment, we request your review and approval to implement the revised SLMCPR by October 1999 to coincide with our refueling outage, i s 9907190062 990712 PDR ADOCK 05000271 - f P PDR /8 (M j' )
vamost YAsus Nrca.An Pown u Cmmon. mon . BV 99-91/ Page 2 11 you have any questions concerning this transmittal, please contact Mr. Jeffrey T. Meyer at (802) 258-4105. I Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION l / Robert J. Wa czy Vf Director of Sa and Regulatory Affairs i STATE OF VERMONT ) )ss WINDHAM COUNTY ) Then personally appeared before me, Robert J. Wa sczyk, who, being duly sworn, did state that he is Director of Safety and Regulatory Affairs of Vermont Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoing document in the name and on the behaliof Vermont Yankee Nuclear Power Corporation, and that the statements therein are true to the best of his knowledge and j belief. lU 0. YMM b Jupith A. Harris, Notary Public My Commission Expires February 10,2003 /g y Attachments NOTARY cc: USNRC Region 1 Administrator USNRC Resident inspector-VYNPS S PUBUC x USNRC Project Manager-VYNPS q Vermont Department of Public Service p NT4.
voimm nsum Necuan rowni co u ouxuos Docket No. 50-271 BW 99-91 Attachment i Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 221 Safety Limit - Minimum Critical Power Ratio Supporting information and Safety Assessment of Proposed Change l I
r r vrunom vma: Necu:.ut Powrn com onmos BW 99-91/ Attachment 1/ Paga 1 of 1 Description of the Proposed Change Pursuant to 10CFR50.90,' Vermont Yankee proposes to amend Appendix A, Technical i Specification (TS)~ Section 1.1.A.1 of Facility Operating License DPR-28. The proposed changes are as follows: Page 6, Specification 1.1.A.1 - Delete reference to Cycle 20 and replace the listed SLMCPR values of 1.11 (1.13 for single loop operation) with new values of 1.10 (1.12 for single loop operation). Purpose of the Proposed Change j Calculations for Vermont Yankee by General Electric Nuclear Energy (GENE) summarized in have determined that the current SLMCPR values for single and dual loop operation contained in the Technical Specifications (1.11 and 1.13) are not applicable for the upcoming fuel cycle due to core loading design and fuel type changes. This change revises the SLMCPR values to (1.10 and 1.12) for the upcoming fuel cycle. Additionally, by specifying a cycle number for this parameter in current Technical Specifications, Vermont Yankee is - required to submit a change even if the SLMCPR numbers remain conservative for the next operating cycle. Thus, this change will remove reference to a specific cycle number and will only require submittal of a future change if cycle specific SLMCPR analysis determines these . values are not bounding. i Safety Assessment of Proposed Change ' The purpose of the SLMCPR is to provide high statistical probability (L '.9%) that fuel rods in the operating core would not experience transition boiling (clad dryout) during the most limiting Abnormal Operational Transient (AOT). The criteria of transition boiling for determination of the SLMCPR is a conservative approach since this phenomena by itself does not signal the onset ) of fuel cladding failure. The revised SLMCPR for Vermont Yankee was determined using plant and cycle-specific fuel and core parameters as discussed in Attachment 5. Analysis of the limiting AOT provides the allowed operating conditions, in terms of MCPR, of the core during the fuel cycle such that if the event were to occur, the transient MCPR would not be less than the SLMCPR. No plant hardware or operational changes are required with this proposed change. i i
c-vamou nsun: Nrcuan powni cmu int.mos Docket No. 50-271 BW 99-91 j i Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 221 Safety Limit - Minimum Critical Power Ratio Determination of No Significant Hazards Consideration
VuotoNT hm: Nt cuan Powtn Colwon.uioN . BVY 99-91/ Attachment 2 / Page 1 of 2 No Significant Hazard Determination i ~ Pursuant to 10CFR50.92, Vermont Yankee Nuclear Power Corporation has reviewed the proposed change and concludes that the change does not involve a significant hazards consideration since the proposed change satisfies the criteria in 10CFR50.92(c). 1. The operation of Vermont Yankee Nuclear Power Station in accordance with the proposed amendment. will not involve a sianificant increase in the orobability or conseauences of an accident previously evaluated. The basis of the SLMCPR is to ensure no mechanistic fuel damage is calculated to occur if the limit is not violated. The new SLMCPR values preserve the existing margin to transition boiling and probability of fuel damage is not increased. The derivation of l the revised SLMCPR for Vermont Yankee for incorporation into the Technical Specifications, and its use to determine plant and cycle-specific thermal limits, have been performed using NRC approved methods. These plant-specific calculations are performed each operating cycle and if necessary, will require future changes to these values based upon revised core designs. The revised SLMCPR values do not change the method of operating the plant and have no effect on the probability of an accident initiating event or transient. Based on the above, Vermont Yankee has concluded that the proposed change will not I result in a significant increase in the probability or consequences of an accident previously evaluated. 2.- The operation of Vermont Yankee Nuclear Power Station in accordance with the I p.r. goosed amendment. will not create the possibility of a new or different kind of accident from any accident oreviously evaluated. The proposed changes result only from a specific analysis for the Vermont Yankee core reload design and deletion of a cycle specific reference for the values. These changes do not involve any new or different method for operating the facility and do not involve any facility modifications. No new initiating events or transients result from these changes. Based on the above, Vermont Yankee has concluded that the proposed change will not create the possibility of a new or different kind of accident from those previously evaluated. 3. The operation of Vermont Yankee Nuclear Power Station in accordance with the proposed amendment. will not involve a sianificant reduction in a marain of safety. l The new SLMCPR is calculated using NRC approved methods with plant and cycle specific parameters for the current core design. The SLMCPR value remains high enough to 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. The L 1
vennost Ymu: Necuan Powni coneonmos . BW 99-91/ Attachment 2 / Pag)2 of 2 operating MCPR limit is set appropriately above the safety limit value to ensure adequate margin when the cycle specific transients are evaluated. As a result, Vermont Yankee has determined that the proposed change will not result in a significant reduction in a margin of safety. On the basis of the above, VY has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10CFR50.92(c), in that it: (1)_does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) does not involve a significant reduction in a margin of safety. F
o o GE Nuclear Energy came esce conway P. O. Box 700, %Nmington, NC 20402 Affidavit I, Glen A. Watford, being duly sworn, depose and state as follows: (1) I am Manager, Nuclear Fuel Engineering, 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 attachment, AdditionalInformation ~ Regarding the Cycle Specific SLMCPRfor Vermont Yankee Cycle 21, datedJune 14,1999. (3) In making this application for withholding of proprietary information of which it is the owner, GE relics 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) 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 for which exemption from disclosure is here sought is all " confidential commercial information," and some portions also qualify under the narrower dermition of" trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Enerav Proiect v. Nuclear Regulatory Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Grouo v. FDA. 704F2dl280 (DC Cir.1983). (4) Some examples of categories of information which fit into the definition of giroprietary information are: a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its 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 resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;.
c. Information which reveals coit or price information, production capacities, budget levels, or commercial strategics 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;
- e.. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withhcid is considered to be proprietary for the reasons set forth in both paragraphs (4)a. and (4)b., above. Page1
e Affid1vit (5) %c information sought to be withheld is being submitted to NRC in confidence. He information i:. of a sort customarily held in confidence by GE, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. He 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. (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) He 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 designatioa. 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 wLh appropriate regulatory provisions or proprietary agreements. (8) He information identified in paragraph (2) is classified as proprietary because it contains details of GE's Safety Limit methodology and the corresponding results which GE has applied to actual core designs with GE's fuel. The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GE. (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. He Safety Limit analysis is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. He 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. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods. He research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GE. De precise value of th; expertise to devise an evaluation process and apply the correct analytical methodology is difYicult 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 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. He 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 cmucwu,mu,w Page 2
~ s. Affid:vit 1 L a similar expenditure of raources would unfairly provide competitors with a windfall, and depnve GE of the opportunity to exercise its cornpetitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools. State ofNorth Carolina ) b County of New Hanover ) ,p 6:en A. Watford, being duly sworn, deposes and says: 'Ihat he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief, d Executed at Wilmington, North Carolina, this b day of dune ,_,19 N sL a !cn A. ord General Electric Company Subscribed and sworn before me this o7tA day of /M . 19 8 u Att - Cerxw Notary Public, State of North Carolina My Commission Expires - Y/#/86CO CMLIGAIMmbatWava.dne Page 3 =}}