ML20236X804

Proposed Tech Specs Section 1.1.A Re SLMCPR to Be Applicable During Cycle 14

ML20236X804
Person / Time
Site:	FitzPatrick
Issue date:	08/03/1998
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20138K589	List: JPN-98-036, Forwards Application for Amend to DPR-59,revising Note Which Will Allow TS Section 1.1.A Re SLMCPR to Be Applicable During Cycle 14.Proprietary GE Addl Info Encl.Proprietary Info Withheld (Ref 10CFR2.790(b)(1)) ML20236X781 ML20236X804
References
NUDOCS 9808100269
Download: ML20236X804 (12)

Text

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Att chmsnt lll to JPN-98-036 MARKED-UP TECHNICAL SPECIFICATION PAGES SAFETY LIMIT MINIMUM CRITICAL POWER RATIO (JPTS-98-002)

NOTE 1:

Deletions are shown in 5ti;keout, and additions are in bold.

NOTE 2:

Previous amendment revision bars are shown and will be deleted.

New York Power Authority l

JAMES A. FITZPATRICK NUCLEAR POWER oLANT Docket No. 50-333 DPR-59 9808100269 980803 PDR ADOCK 05000333 P

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o Attachment V to JPN-98-036 -

EVALUATION REGARDING SAFETY LIMIT MCPR NON-PROPRIETARY (JPTS-98-002)

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59

4 Attachment AdditionalInformation Regarding the 1.09 July 13,1998 Cycle Specific SLMCPR for FitzPatrick Cycle 14 References U1 General Electric BWR Thermal Analysis Basis (GETAB): Data, Correlation and Design Application, NEDO-10958-A, January 1977.

(*)

General Electric Standard Applicationfor Reactor Fuel (GESTAR 11), NEDE-2401 1 -P-A-1 1, November 1995.

131 Smith, M.A. (GE) letter to NRC Document Control Desk,10CRF Part 21, Reportable

^

Condition, Safety Limit MCPR, letter # 96-04NRC. DOC (MFN 074-96), May 24,1996.

HI General Electric Standard Applicationfor Reactor Fuel (GESTAR 11), NEDE-2401 1-P-A-12, June 1996.

I'l Matthews, David B. (NRC) letter to Ralph J. Reda (GE), Proposed GeneralElectric Revision 12 to GESTAR11, August 5,1996.

I'l General Electric Standard Applicationfor Reactor Fuel (GESTAR 11), NEDE-2401 1 -P-A-13, August 1996.

173 Reda, R.J. (GE) letter to NRC Document Control Desk with attention to T.E. Collins, Acting k Branch Chicf af Reactor Systems Branch: Proposed Amendment 25 to GE Licensing Topical Report NEDE-24011-P-A (GESTAR 11) on Cycle-Specific Safety Limit MCPR; December 13,1996.

I'l Reda, R.J. (GE) letter to NRC Document Control Desk with attention to T.E. Collins, Acting Branch Chief of Reactor Systems Branch; GESTAR Amendment 25 Supporting Information; December 13,1996.

I'1 GeneralElectric FuelBundle Designs, NEDE-31152-P, Revision 6, April 1997.

U *l Methodology and Uncertaintiesfor Safety Limit MCPR Evaluations, NEDC-32601 P, Class 1II, December 1996. (Submitted for NRC review by letter from R.J. Reda (GE) to NRC Document Control Desk dated December 13,1996.)

I"3 R-Factor Calculation Methodfor GE11, GE12 and GE13 Fuel, NEDC-32505P, Revision 1, June 5,1997.

Background

The AEC-approved (1974) methodology for calculating the Safety Limit Minimum Critical Power Ratio (SLMCPR) is documented in GETABUI which is specifically referenced by GESTAR II.

Prior to 1996, GESTAR IIr2) stipulated that the SLMCPR analysis for a new fuel design be performed I

I for a large high power density plant assuming a bouncing equilibrium core. The Gell product line l

genenc SLMCPR value of 1.07 was determined according to this specification.

In March 1996 it was discovered that the SLMCPR calculated on a generic basis with the GE methodology may be non-conservative when applied to some actual core and fuel designs. A 10CFR Part 21, Reportable ConditionDI documenting the problem and the earlier communications and meetings with the NRC as well as the NRC inspection No. 99900003/96-01 in Wilmington May 6-10 was filed on May 24,1996. The NRC found in their inspection that GE " failed to recalculate or

(( GENE Proprietary Information))

page 1 of 4

(( enclosed by double brackets ))

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• Attachment AdditionalInformation Regarding the 1.09 July 13,1998 Cycle Specific SLMCPR for FitzPatrick Cycle 14 reconfirm the applicability of the generically determined SLMCPR to new fuel bundle designs".

Revision 12 to GESTAR Il'1 was submitted in response to this finding in order to clarify how the l

calculated SLMCPR would be reconfirmed on a plant / cycle specific basis. The NRC staff requestedl8 "that General Electric withdraw this revision and submit an amendment incorporating full information on the SLMCPR analysis processes". In the same letter!'l the NRC staff stated that SLMCPR values "should be confirmed for each plant / core-specific application". In response to this NRC request, GE issued Revision 13 to GESTAR II'l without the description of how the plant / cycle I

specific SLMCPR methodology would be applied to reconfirm the safety limit. Instead this information was submitted'1 as requested by the NRC as the " Proposed Amendment 25...".

Pending NRC approval of the proposed Amendment 25 to GESTARII, the NRC staff has been reviewing plant / cycle specific Safety Limits individually for each cycle of each plant. The purpose of this document is to provide the NRC with additional information to support their review of how plant / cycle specific SLMCPR analyses using the uncertainties defined in Reference [9] were used to confirm the calculated SLMCPR value for FitzPatrick Cycle 14.

Comparison of FitzPatrick Cycle 14 SLMCPR versus the Cycle 13 SLMCPR value Table I summarizes the relevant input parameters and results of the SLMCPR determination for both the FitzPatrick Cycle 14 core and the Cycle 13 core. The plant / cycle specific evaluations are performed using the methods described in GETAB 'I.

The evaluations yield different calculated l

I SLMCPR values because the inputs that are used are different. The quantities that have been shown to have some impact on the determination of the safety limit MCPR (SLMCPR) are provided. Much of this information is redundant but is provided in this case because it has been provided previously to the NRC to assist them in understanding the differences between plant / cycle specific SLMCPR evaluations and previous cycle values calculated by fuel product line. (())

The FitzPatrick Cycle 14 is a mixed coru with GE12 and Gell fuel. The latest reload consists of GE12 fuel making up (( )) of the total bundles in the core. The fresh GE12 has a batch average bundle enrichment of (( )) and a core average enrichment of (( )), as shown in Table 1. By way of comparison, the FitzPatrick Cycle 13 core has a fresh GE12 batch average bundle enrichment of(( ))

and a core average enrichment of(()). Higher enrichment in the fresh fuel for the FitzPatrick Cycle 14 core (compared to the rest of the core) produces higher power in the fresh bundles relative to the rest of the core. These enrichment differences result in the GE12 fresh fuel producing a higher relative share of the number of fuel rods calculated to be susceptible to boiling transition (NRSBT).

((1]

(()) The FitzPatrick Cycle 14 core has a somewhat flatter core MCPR distribution than the FitzPatrick Cycle 13 core, but the bundle R-factor distribution is slightly less flat.

(())

(())

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(()) one is led to the conclusion that the core MCPR distribution for FitzPatrick Cycle 14 is slightly flatter than the distribution evaluated for the FitzPatrick Cycle 13 case.

I

(( GENE Proprietary Information ))

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I Attachment Additional Information Regarding the 1.09 July 13,1998 Cycle Specific SLMCPR for FitzPatrick Cycle 14

(())

The uncontrolled bundle pin-by-pin power distributions were compared between the FitzPatrick Cycle 14 GE12 bundles and the GE12 bundles used in the FitzPatrick Cycle 13 analysis. Pin-by-pin power distributions are characterized in terms of R-factors using the methodology defined in Reference [Il]. For. the FitzPatrick Cycle 14 bundles, there is a more peaked distribution of uncontrolled R-factors. (())

The flatness of the pin R-factor distribution within a panicular bundle is characterized (())

1

(( )) This supports the conclusion that the higher calculated SLMCPR value for FitzPatrick Cycle 14 is entirely due to the flatter core MCPR distribution relative to that used for the FitzPatrick Cycle 13 evaluation.

Table 1 Comparison of FitzPatrick Cycle 13 and Cycle 14 Core and Bundle Quantities that impact the SLMCPR (())

f Summary The calculated nominal 1.09 Monte Carlo SLMCPR for FitzPatrick Cycle 14 is consistent with what one would expect (( )) the 1.09 SLMCPR value is appropriate.

Various quantities (( )) have been used over the last year to compare quantities that impact the calculated SLMCPR value. These other quantities have been provided to the NRC previously for other plant / cycle specific analyses using a format such as that given in Table 1. These other quantities have also been compared for this core / cycle. (()) The key parameters in Table I support j

the conclusions that the FitzPatrick Cycle 14 core / cycle has a slightly flatter core MCPR distribution (significant enough to more than compensate for the slightly more peaked bundle R-factor distribution) which contributes to the higher calculated SLMCPR relative to the FitzPatrick Cycle 13 evaluation.

1 Based on all of the facts, observations and arguments presented above, it concluded that the j

calculated SLMCPR value of 1.09 for the FitzPatrick Cycle 14 core is appropriate. It is reasonable I

that this value is 0.01 higher than the 1.08 value calculated for the FitzPatrick Cycle 13 core.

For single loop operations (SLO) the safety limit MCPR is 0.01 greater than the two-loop value. (( ))

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~~"Kftachm'ent " AdditionalInformation RegardL g the 1.09 July 13,1998

. Cycle Specific SLMCPR for FitzPatrick Cycle 14 Prepared by:

Verified by:

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S. J. Peters -

J.Su Technical Program Manager Technical Program Manager Nuclear Fuel Engineering Nuclear Fuel Engineering

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(( GENE Proprietary Information ))

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,s Attachment IV to JPN-98-036 l

EVALUATION REGARDING SAFETY LIMIT MCPR INFORMATION IN THIS ATTACHMENT IS CONSIDERED GE PROPRIETARY AND SHOULD BE WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE I

WITH 10 CFR 9.17(a)(4) AND 10 CFR 2.790(a)(4)

(JPTS-98-002) l l

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59

GENuclearEnergy John A. Baumgartner NucinarFuel Senior FuelProject Manager GeneralEkctic Company Product Management P.O. Box 780. htC A33 Henington NC 28401-0780 (910) 675 5821 Fax (910) 6755684 July 17,' 1998 JAB-N8043 cc: G. L Rorke Mr. PaulIzmberg Manager of Nudear FuelSupply New York Power Authority 123 Main Street,11-F White Plains, NY 10601

Subject:

Cyde Specific SLMCPR for FitzPatrick Cycle 14

References:

1. Attachment "AdditionalInformation Regarding the 1.09 Cyde Specific SLMCPR for FitzPatrick Cycle 14", GE COMPANY PROPRIETARY INFORMATION, July 13,1998.

2. Attachment "AdditionalInformation Regarding the 1.09 Cyde Specific SLMCPR for FitzPatrick Cycle 14", July 13,1998. (Non-Proprietary) i

3. Affidavit signed by Glen A. Watford, datedJuly 17,1998.

i

Dear Paul,

Enclosed are the reference documents supporting the Safety Limit MCPR for FitzPatrick Cycle 14. Please let us know if you have any questions regarding this information.

Yours very truly, s

NEW YORK POWWI AUTHORITY DOCUM~NT REVIEW STATUS p

John A. Baumgartner m,g a Senior Fuel Project Manager i K AccenuD 2 O Accamap AS NOTED neousaNTTAL NOT neQupWD ec: S. Peters

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t GE Nuclear Energy GeneralEkctnc Company P. o, Box 780, Wilmington. NC 26402 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 letter, J. Knubel (New York Power Authority) to the U. S. Nuclear Regulatory Commission Document Control Desk, James A.

FitzPatrick Nuclear Power Plant, Proposed Change to the Technical Specifications Regarding Minimum CriticalPower Ratio Safety Limit (JPTS-98-002), Docket No. 50-333, DPR-59.

. (3) In making this application for withholding of proprietary information of which it is the owner, GE relies 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 inforraation 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 definition of" trade secret,"

within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, l

Critical Mass Energy Project v. Nuclear Regulatory Commission. 975F2d871 (DC Cir.1992),

j and Public Citizen Health Research Group v. FDA,704F2dl280 (DC Cir.1983).

(4) Some examples of categories of information which fit into the definition of proprietary l

1 information are:

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Information that discloses a process, method, or apparatus, including supporting data a.

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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, l

assurance of quality, or licensing of a similar product; L

c.

Information which reveals cost or price information, production capacities, budget I

levels, or commercial strategies of General Electric, its customers, or its suppliers;

d. Information whkh 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.

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Affidavit

/'N The information sought to be withheld is considered to be proprietary for the reasons set V

forth in both paragraphs (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 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. 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 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) 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 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 designation, 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 with appropriate regulatory provisions or proprietary 7

agreements.

[O (8) The information identified in paragraph (2) is classified as proprietary because it contains details of GE's Safety Limit MCPR analysis and the corresponding results which GE has applied to this specific plant and cycle's actual core design with GE's fuel.

The development of the methods used in these analysis, along with the testing, development and approval of the supporting critical power correlation 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. The stability analysis is part of GE's 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. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GE.

The 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.

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GE's competitive advantage will be lost ifits 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.

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 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

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County of New11anover )

Glen A, Watford, 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.

!b Executed at Wilmington, North Carolina, this / 7 day of Tulta

,1998 I

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Glen A. W d

General ctric Company Subscribed and sworn before me this l'1M;!ay of b1[u_

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Nota Public, ' tate of North Carolina M d (20d/

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My Com lission Expires Ji-2 4 -

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