ML20217E037

Application for Amend to License NPF-57,supporting Use of ABB-CE Fuel & Reload Analyses Beginning with Upcoming Cycle 10.Proprietary & non-proprietary Info Re Subject Amend,Encl. Proprietary Info Withheld,Per 10CFR2.790(a)(4)

ML20217E037
Person / Time
Site:	Hope Creek
Issue date:	09/30/1999
From:	Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20138G239	List: ML20217E037 ML20217E045
References
LCR-H99-09, LR-N99429, NUDOCS 9910190056
Download: ML20217E037 (14)

Text

O PSEG Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuc! car Business Unit MP 301999  !

l LR-N99429  !

LCR H99-09 I I

United States Nuclear Regulatory Commission  !

Document Control Desk l Washington, DC 20555 1

Gentlemen:

REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS FUEL VENDOR CHANGE HOPE CREEK GENERATING STATION I FACILITY OPERATING LICENSE NPF-57 l DOCKET NO. 50-354 in accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Technical Specifications (TS) for the Hope Creek Generating Station (HC). In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey.

The proposed revision supports the use of Asea Brown Bovien/ Combustion Engineering (ABB/CE) fuel and reload analyses beginning with the upcoming Cycle 10.

The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1),

using the criteria in 10CFR50.92(c), and a determination has been made that this i request involves no significant hazards considerations. The basis for the requested change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a determination of no significant hazards consideration, is provided in Attachment 2. The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 3.

1 ABB/CE considers the material in Attachment 1 enclosed in double brackets to be {

proprietary and requests that it be withheld from public disclosure in accordance with j 10CFR2.?90(a)(4). Attachment 4 contains an affidavit executed by ABB/CE in support i of this request. A non-proprietary version of Attachment 1 is provided in Attachment 5 of this letter.

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f ATTACHMENT 1 OF THIS LETTER CONTAINS PROPRIETARY INFORMATION

- NOT FOR PUBLIC DISCLOSURE -

9910190056 DR 99o93o i ADOCK 0500o354 PDR 'y _f gb Thqwerisin your hands.

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SEP 301999 i Document Control Desk l LR-N99429 Upon NRC approval of this proposed change, PSE&G requests that the amendment be made effective on the date of issuance, but allow an implementation period of sixty days after the completion of Cyc'e 9 to provide sufficient time for associated administrative activities.

Should you have any questions regarding this request, please contact Paul Duke at (856) 339-1466.

Sincerely, l Affidavit I Attachments (5) i I

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i ATTACHMENT 1 OF THIS LETTER CONTAINS PROPRIETARY INFORMATION

- NOT FOR PUBLIC DISCLOSURE -  ;

Si 3 ; 19991 Document Control Desk LR-N99429 C Mr. H. Miller, Administrator - Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 8B1 11555 Rockville Pike Rockville, MD 20852 USNRC Senior Resident inspector - HC (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625 ATTACHMENT 1 OF THIS LETTF81 CONTAINS PROPRIETARY INFORMATION

- NOT FOR PUBLIC DISCLOSURE -

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i REF: LR-N99429 LCR H99-09 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

M. Bezilla, being duly sworn according to law deposes and says:

I am Vice President - Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief. I

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Subscribed and Sworn to before me this 3o day of ScLla ,1999 0

Rw tm b- / W 4 /t N[ary Pub!b of New Jersey JENNIFER M. TURNER My Commission expires on .N0TARY PUBLIC OF NEW JERSEY my uunin nu.uu up,, o umy to, tuvv I

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Docum:nt C:ntrol De k - LR-N99429 Atta*hm:nt 4 LCR H99-09 AFFIDAVIT AND BASIS FOR WITHHOLDING INFORMATION CONTAINED IN ATTACHMENT 1 TO LCR H99-09 FROM PUBLIC DISCLOSURE i

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AFFIDAVIT PURSUANT  !

l TO 10 CFR 2.790 1

1, T. Rodack depose and say that I am the Director, Mechanical Design and Advanced l

Projects (Nuclear Fuels), of ABB Combustion Engineering Nuclear Power, Inc. (ABB )

CENP), duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10

CFR 2.790 of the Commission's regulations and in conjunction with the application of Public Service Enterprise Group for withholding this information. l The information for which proprietary treatment is sought is contained in the following I document:

LR-N99429, LCR H99-09, " Request for Change to Technical Specifications, Fuel Vendor Change, Hope Creek Generating Station, Facility Operating License NPF-57, Docket No. 50-354," September 30,1999.

This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by ABB CENP in designating information as a trade secret, privileged or as confidential commercial or financialinformation.

Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining

. whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

1. The information sought to be withheld from public disclosure, is owned and has been held in confidence by ABB CENP. It consists of information regarding Safety Limits and analysis methodology of ABB CENP fuel.

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' 2. The information is suppoded by test data or other similar data conceming a process, method or component, the application of which results in substantial

! con.petitive advantage to ABB CENP.

L 3. The information is of a type customarily held in confidence by ABB CENP l and not customarily disclosed to the public. ABB CENP has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The details of the ,

i aforementioned system were provided to the Nuclear Regulatory

. Commission via letter DP-537 from F. M. Stem to Frank Schroeder dated

. December 2,1974. This system was applied in determining that the subject document herein is proprietary.

4. The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission.

5. The information, to the best of my knowledge and belief, is not available in i public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

6. Public disclosure of the information is likely to cause substantial harm to the competitive position of ABB CENP because:

a.- A similar product is manufactured and sold by major competitors of ABB CENP.

b. Development of this information by ABB CENP required tens i i of thousands of dollars and hundreds of manhours of effort. A competitor would have to undergo similar expense in generating equivalent information.

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c. In order to acquire such information, a competitor would also require considerable time and inconvenience to develop j

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information regarding Safety Limits and analysis i

methodology of ABB CENP fuel.

d. The information consists of Safety Limits and analysis methodology, the application of which provides a competitive i economic advantage. The availability of such information to t competitors would enable them to modify their product to better compete with ABB CENP, take marketing or other actions to improve their product's position or impair the position of ABB CENP's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

e. In pricing ABB CENP's products and services, significant research, development, engineering, analytical, manufacturing,  !

licensing, quality assurance and other costs and expenses must be included. The ability of ABB CENP's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting signe c.tly lower costs,

f. Use of the information by competitors in the intemational marketplace would increase their ability to market nuclear steam supply systems, nuclear fuel, analyses or other support services by reducing the costs associated with technology '

development. In addition, disclosure would have an adverse economic impact on ABB CENP's potential for obtaining or maintaining foreign licensees.

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• Further the deponent sayeth not.

I J T. Rodack.. Director Mechanical Design and Advanced Projects (Nuclear Fuels)

Swom to before me this A ffM day of ' dI

.1999 J - A

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Notary Public My commission expires: P3/oY j

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, . l DocumInt Central Drk LR-N99429 AttachmInt 2 LCR H99-09

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HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 SAFETY LIMIT MINIMUM CRITICAL POWER RATIO (SLMCPR) CHANGES i

l 10CFR50.92 EVALUATION l l Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the I Hope Creek Generating Station (HC) Technical Specifications do not involve a l l significant hazards consideration. In support of this determination, an evaluaticn of each of the three standards set forth in 10CFR50.92 is provided below.

REQUESTED CHANGE t

l The proposed changes to the Hope Creek Technical Specifications contained in this l

submittal are being made to: 1) replace the 1.09 MCPR limit for dual recirculation loop operation for GE9B fuel with a 1.10 SLMCPR for Hope Creek Cycle 1J and to add a 1.10 dual recirculation loop operation SLMCPR applicable to the ABB/CE fuel; 2) replace the 1.11.MCPR limit for single recirculation loop operation for GE9B fuel with a 1.12 SLMCPR for Hope Creek Cycle 10 and to add a 1.13 single recirculation loop operation SLMCPR applicable to the ABB/CE fuel; and 3) to remove the cycle specific footnote for the Safety Limit applicability. The Bases for TS 2.1, " Safety Limits," will be revised to reflect the new MCPR limits for dual and single recirculation loop operation and to include the ABB/CE bases. Administrative changes are being made to TSs 3/4.2.1,3/4.2.3 and 3/4.4.1 and their associated Bases, and TS 6.9.1.9 to reflect the use of approved ABB/CE methodologies for calculating core operating limits for Cycle 10 and subsequent cycles.

BASIS 1

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The derivation of the revised SLMCPRs for Hope Creek for incorporation into the Technical Specifications, and its use to determine cycle-specific thermal limits, have been performed using NRC approved methods. These calculations do not change the method of operating the plant and have no effect on the probability of an accident initiating event or transient.

I There are no significant increases in the consequences of an accident previously evaluated. The basis of the MCPR Safety Limit is to ensure that no mechanistic fuel n

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Docum:nt C:ntral Der;k LR-N99429 l . Attachmsnt 2 LCR H99-09 l t

damage due to clad overheating is calculated to occur if the limit is not violated. The new SLMCPRs preserve the existing margin to transition boiling and the probability of fuel damage is not increased. 1 l Removal of the cycle specific footnote for the Safety Limit applicability will not l involve a significant increase in the probability or consequences of an accident previously evaluated since the change is administrative and does not affect the plant or fuel design or operation.

Likewise, the proposed changes to the Average Planar Heat Generation Rate i (APLHGR), Minimum Critical Power Ratio (MCPR), Recirculation Loop Limiting Condition for Operation (LCO) Action Statements, and references to fuel vendor analyses and reports do not involve a significant increase in the probability or consequences of an accident previously evaluated. The changes to the APLHGR, MCPR and Recirculation Loop LCOs are considered to be administrative in nature since the Core Operating Limits Report (COLR) will continue to be used to appropriately control and limit the bounds of plant operation with slow control rods or during single recirculation loop operation, and the COLR will still be developed in accordance with NRC approved methods. Similarly, the revised references to the fuel vendor throughout the Technical Specifications are also considered to be administrative in nature since they reflect the current status of NRC approval of methodologies utilized by PSE&G and the fuel vendor to develop operating and safety limits for the fuel and core designs. These proposed changes do not alter the method of operating the plant and have no effect on the probability of an accident initiating event or transient.

There are no significant increases in the consequences of an accident previously j evaluated. The basis of the COLR and the PSE&G and fuel vendor methodologies )

is to ensure that no mechanistic fuel damage is calculated to occur if the limits on -

plant operation are not violated. The COLR will continue to preserve the existing I margin to fuel damage and the probability of fuel damage is not increased. l l

Therefore, the proposed change does not involve an increase in the probability or l consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or differerd kind of accident from any accident previously evaluated.

I The proposed changes contained in this submittal result from an analysis of the reload core using the same fuel types as previous cycles and an ABB/CE fuel design  !

with extensive operating experience. These changes do not involve any new

method for operating the facility and do not involve any facility modifications for the L reload core operation. No new initiating events or transients result from these 1

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Document C:ntrol Desk LR-N99429

. Atta:hment 2 LCK H99-09 changes. Therefore, the proposed Technical Specification changes do not create the possiNiity of a new or different kind of accident, from any accident previously evaluatea.

Removal of the cycle specific footnote for the Saiety Limit applicability does not create the possibility of a new or different kind of accident from any accident previously evaluated since the change is administrative and does not affect the plant or fuel design or operation.

~ The changes to the APLHGR, MCPR and Recirculation Loop LCOs are considered to be administrative ..; nature since the Core Operating Limits Report (COLR) will continue to be usN to appropriately control and limit the bounds of plant operation with slow coreiroi rods or during single recirculation loop operation, and the COLR will still be developed in accordance with NRC approved methods. These changes do not involve' any new method for operating the facility and do not involve any facility modifications in addition to the new fuel design. No new initiating events or transients result from these changes. Therefore, the proposed Technical Specification changes do not create the possibility of a new or different kind of accident.-

The revised references to the fuel vendor throughout the Technical Specifications are also considered to be administrative in nature since they reflect the current status of NRC approval of methodologies utilized by PSE&G and the fuel vendor to develop operating and safety limits for the fuel and core designs. These changes do not involve any new method for operating the facility and do not involve any facility modifications in addition to the new fuel design. No new initiating events or transients result from these changes. Therefore, the proposed Technical Specification changes do not create the possibility of a new or different kind of accident.

3. The proposed change does not involve a significant reduction in a margin of safety.

The margin of safety as defined in the Technical Specification bases will remain the

. same. The new SLMCPRs are calculated using NRC approved methods, which are in accordance with the current fuel designs, and licensing criteria. The MCPR Safety Limit 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.' Therefore, the proposed Technical Specification changes do not involve a significant reduction in a margin of safety.

Removal of the cycle specific footnote for the Safety Limit applicability does not create the possibility of a new or different kind of accident from any accident 3-L

Docum:nt COntral De;k LR-N99429

' Attachm:nt 2 LCR H99-09 previously evaluated since the SLMCPR will continue to be evaluated on a cycle-specific basis.

The margin of safety as defined in the Technical Specification bases will likewise remain unaffected by the proposed changes to APLHGR, MCPR and Recircule'.hn Loop LCOs, and the revised references to the fuel vendor throughout the Techr.; cal Specifications. These changes establish controls for plant operation and establish bases for fuel analyses that reflec' NRC approved methods, and are in accordance with the current fuel design and licensing criteria. These changes will continue to ensure that the plant is operated within specified acceptable fuel design limits.

Therefore, the proposed Technical Specification changes do not involve a significant reduction in a margin of sa'ety.

CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

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Docum:nt C:ntr:I D;ck LR-N99429 Attachment 3 LCR H99-09 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)

TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Facility Operating License No. NPF-57 are ,

affected by this change request: l Technical Specification Page 2.1.2 2-1 Bases 2.0 B 2-1 Bases 2.1.1 B 2-1 Bases 2.1.2 B 2-2 4 B 2-3  ;

3.2.1 3/4 2-1 3.2.3 3/4 2-3 4.2.3 3/4 2-4 3.4.1.1 3/4 4-1 l

Bases 3/4.1.4 B 3/4 1-3 B 3/4 1-5 Bases 3/4.2 B 3/4 2-1  :

Bases 3/4.2.1 B 3/4 2-1 B 3/4 2-2 l

Bases 3/4.2.3 B 3/4 2-3 8 3/4 2-4 l Bases 3/4.4.1 B 3/4 4-1 l B 3/4 4-2 6.9.1.9 6-21 References 6-25