ML20213F298
| ML20213F298 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/12/1986 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19292G238 | List: |
| References | |
| NUDOCS 8611140139 | |
| Download: ML20213F298 (9) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 2m emooi swirgstoat,tnorr November 12, 1986 ELECTRIC PRODUCTION Docket No. 50-277 Mr. Daniel R. Muller BWR Project Directorate #2 Division of BWR Licensing U.S.
Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Peach Bottom 2 Lead Test Assemblies
REFERENCES:
1.
U.S.
Nuclear Regulatory Commission letter, T.
A.
Ippolito to R.
E.
Engel, " Lead Test Assembly Licensing, dated 9/23/81.
2.
General Electric Company Document NEDE-240ll-P-A-8, " General Electric Standard Application for Reactor Fuel", May, 1986.
3.
"1987 Peach Bottom 2 Lead Test Assembly Description", November 5, 1986.
Dear Mr. Muller:
Philadelphia Electric Company plans to load four (4) Lead Test Assemblies (LTAs) as part of Peach Bottom 2 Reload 7 during the Unit 2 1987 refueling outage.
The assemblies are planned to be in operation for up to four cycles as part of a joint program
..ith General Electric Company to irradiate and test improved fuel design features prior to their use on a production basis.
In accordance with NRC instructions pertaining to Lead Test (g
Assembly licensing (reference 1), this letter is being submitted NNQ to document conformance of the analyses of the Peach Bottom 2 C8' Reload 7 LTAs with the approved methods and criteria given in gg reference 2 as well as to provide additional information requested mo in reference 1.
og 38 A description of the LTAs is given in reference 3 (see Do ) of this letter.
Table 1 lists the major features of the LTAs and Table 2 provides LTA design specifications.
Figures
[g 1 and 2 provide a description of the layout of rods within the jA LTAs including enrichment and gadolinia distributions.
Y Ur (5nCb Qi Ad; U$fY o/ns n/a
Nr. Daniel R. Muller, U.S.
NRC November 12, 1986 Peach Bottom 2 Lead Test Assemblies (50-277)
Page 2 of 3 General Electric Company has designed and analyzed these LTAs utilizing the approved methods given in reference 2.
The LTAs are designed for and meet the same nuclear-thermal-mechanical criteria as standard reload bundles, i.e., analyses show that the LTAs will remain within all approved nuclear-thermal-mechanical limits.
Further, licensing analyses will be performed for the LTAs initial cycle of operation (Cycle 8) wherein the effect of the four LTAs 2
is specifically considered for each of the appropriate licensing events and transients to establish appropriate reactor core thermal limits for operation.
These licensing analyses are described in Attachment 2 of this letter.
Results of Cycle 8 will be submitted in our forthcoming Peach Bottom 2 Reload 7 license j
amendment application.
In summary, the Peach Bottom 2 Reload 7 LTAs have been analyzed using reference 2 approved methods and found to meet all applicable reference 2 approved criteria.
Further, the LTAs will be analyzed for specific operation during Cycle 8 and appropriate thermal limits will be established for operation during Cycle 8, therefore it can be concluded that no unreviewed safety questions will exist for such operation.
I of this letter contains information which the General Electric Company customarily maintains in confidence and j
withholds from public disclosure.
The information has been handled and classified as proprietary to General Electric, as indicated in the attached affidavit, and we hereby request that this attachment be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790.
NRC instructions given in reference 1 also requested that information be provided on the scope of measurements to be conducted on LTAs as well as the schedules for documenting results of these measurements.
As currently envisioned, measurements on the LTAs consist of pre-irradiation characterization of fuel pellets, clad tubing, fuel rods and fuel bundles.
At subsequent refueling outages, the scope of inspections, as currently envisioned, consist of overall bundle visual examinations, bundle and rod let.gth measurements, rod integrity and profilometry i
measurements, and corrosion thickness measurements.
The exten t of such measurement and testing will be governed by the need to minimize the impact of such testing on refueling outage critical path, and by the degree of technical interest in implementing the j
design features demonstrated in the LTA.
Further, as requested in i
reference 1, General Electric Company has advised us that results obtained from this LTA program will be summarized in their fuel experience reports in a timely manner.
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Mr. Daniel R. Muller, U.S.
NRC November 12, 1986 Peach Bottom 2 Lead Test Assemblies (50-277)
Page 3 of 3 We are most anxious to proceed with the irradiation of these LTAs inasmuch as we believe this program will lead to eventual improvements in nuclear fuel economy and reliability.
Should you require any additional information, please do not hesitate to contact us.
Very truly yours, i
/
,y
/
x,
./
~
- - LTA Bundle Descriptions - LTA Unique Inputs and Analyses for Transients and Accidents - Affidavit l
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e ATTACHMENT 3 AFFIDAVIT
(
e GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Rudolph Villa, being duly sworn, depose and state as follows:
1.
I am Manager, Products Licensing, General Electric Company, 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 Tables 1 and 2 and Figures 1 and 2 of the information report entitled "1987 Peach Bottom 2 Lead Test Assembly Description", November 5, 1986.
3.
In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757. This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it....
A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring information.... Some factors to be considered in determining whether given information is one's trade secret are: (1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and
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others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expended by him in developing the information; (6) the ease or difficulty with the which the information could be properly acquired or duplicated by others."
4.
Some examples of categories of information which fit into the definition of proprietary information are:
a.
Information that disclosed a process, method or a,.paratus where prevention of its use by General Electric's c'7petitors without license from General Electric constitutes a competitive economic advantage over other companies;
.A b.
Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus, the application of which provide a competitive economic advantage, e.g., by optimization or improved marketability; Information which if used by a competitor, would reduce his c.
expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product; d.
Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; Information which reveals aspects of past, present or future e.
General Electric customer-funded development plans and programs of potential commercial value to General Electric; f.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection; Information which General Electric must treat as proprietary g.
according to agreements with other parties.
5.
In addition to proprietary treatment given'to material meeting the standards enumerated above, General Electric customarily maintains in confidence preliminary and draft material which has not been subject to complete proprietary, technical and editorial review.
This practice is based on the fact that draft documents often do not appropriately rerlect all aspects of a problem, may contain tentative conclusions and may contain errors that can be corrected during normal review and approval procedures. Also, until the
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final document is complete it may not be possible to make any definitive determination as to its proprietary nature. General Electric is not generally willing to release such a document in such a preliminary form. Such documents are, however, on occasion furnished to the NRC staff on a confidential basis because it is General Electric's belief that it is in the public interest for the staff to be promptly furnished with significant or potentially significant information. Furnishing the document on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documents are technically accurate and correct.
6.
Initial approval of proprietary treatment of a document is typically made by the Subsection Manager of the originating component, who is most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.
Access to such documents within the Company is limited on a "need to know" basis and such documents are clearly identified as proprietary.
7.
The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project Manager, Principal Scientist or other equivalent authority, by the Subsection Manager of the cognizant Marketing function (or delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees and then only with appropriate protection by applicable regulatory provisions or proprietary agreements.
8.
The document mentioned in paragraph 2 above have been evaluated in accordance with the above criteria and procedures and have been found to contain information which is proprietary and which is customarily held in confidence by General Electric.
9.
The Tables and Figures mentioned in paragraph 2 above are classified as proprietary because they contain details of lead test assembly features, specifications, and nuclear design. This information was developed at considerable expense to General Electric and is not available to other parties. Disclosure of this information would provide other parties, including competicors, with valuable design information regarding important features of current and future fuel designs. The information is of a type customarily held in confidence by General Electric since it reveals important features and contains valuaole design information which were obtained at considerable cost to General Electric.
STATE OF CALIFORNIA
) ss:
COUNTY OF SANTA CLARA
)
Rudolph Villa, 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 San Jose, California, this [
day of W
1986.
Rudolph ViH!i General Electric Company Subscribed and sworn before me thi d y of 86 198 OFhlCIAL SEkL to OA,
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NOTARY PUBLIC, STATE OF WALIFORNIA 3Am CUWE COUNTY i
py come, entres WI 13. 1953 )
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ATTACHMENT 2 LTA UNIQUE INPUTS AND ANALYSES FOR TRANSIENTS AND ACCIDENTS
CORE-WIDE TRANSIENTS Current approved methods (Reference 2) are considered appropriate to determine the impact of the core-wide transients on the LTAs.
The GEXL correlation is applicable to the LTAs, as it provides an adequate prediction of test data.
Credit is taken for design improvements in the application of the GEXL correlation to the LTAs.
Appropriate Technical Specification limits will be established to ensure safe operation of the LTAs.
l LOCALIZED TRANSIENTS App;oved methods are considered adequate to evaluate core response to Rod Withdrawal Error and Fuel Loading Error (Rotated Bundle Error), since nuclear inputs are available to represent the LTAs discretely.
The LTAs will be loaded into locations in the core that are not limiting with respect to Rod Withdrawal Error and Puel Loading Error.
CONTROL ROD DROP ACCIDENT (CRDA)
CRDA will be analyzed using current approved methods.
The rod adjacent to the LTAs will be analyzed if it is the limitinq rod, or has worth nearly as large as the limiting rod.
Opr with the LTAs will not result in exceeding CRDA acceptance etit i a.
ECCS l
The LTAs are analyzed by conservatively applying current ECCS models.
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