RS-02-145, Supplemental Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit
| ML022410277 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/15/2002 |
| From: | Simpson P Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-02-145 | |
| Download: ML022410277 (15) | |
Text
Exelknd Exelon Generation www exeoncOop Cor Nuclear 4300 Winfield Road Warrenville, IL 60555 10 CFR 50.90 RS-02-145 August 15, 2002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Unit 1 Facility Operating License No. DPR-29 NRC Docket No. 50-254
Subject:
Supplemental Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit
Reference:
Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S.
NRC, "Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit," dated May 30, 2002 In the above referenced letter, Exelon Generation Company, LLC (EGC) submitted a request for a change to the operating license and Technical Specifications (TS) for Quad Cities Nuclear Power Station (QCNPS), Unit 1. The proposed change revises the values of the Safety Limit for the Minimum Critical Power Ratio (SLMCPR) in TS Section 2.1.1, "Reactor Core SLs," for Unit 1 Cycle 18 for both two loop operation and single loop operation to 1. 10 and 1.11, respectively.
On July 24, 2002, Global Nuclear Fuel (GNF) informed EGC of an error in the determination of the SLMCPR limits for QCNPS Unit 1 Cycle 18. Specifically, the bias related to the GEXL14 correlation for top peaked power shapes was not properly applied to all GE14 fuel types.
GNF has re-calculated the SLMCPR values for QCNPS Unit 1 Cycle 18 using the revised safety methodology described in NEDC-32601 P-A, "Methodology and Uncertainties for Safety Limit MCPR Evaluations," and the results are provided in Attachment A. The results do not change the SLMCPR values that were proposed in the above referenced letter.
Some of the information contained in Attachment A is classified as proprietary to our fuel supplier, GNF, and is identified as text contained between opening double brackets (((
and closing double brackets @))). The proprietary information is of the type that GNF maintains in confidence and withholds from public disclosure. It has been handled and classified as proprietary as supported by the affidavit in Attachment C. EGC hereby requests that this information be withheld from public disclosure in accordance with the 9DI
August 15, 2002 U. S. Nuclear Regulatory Commission Page 2 provisions of 10 CFR 2.790, "Public inspections, exemptions, requests for withholding."
Attachment B provides an edited, non-proprietary version of the information in Attachment A.
EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment C of the above referen'ced letter. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed TS change does not involve a significant hazards consideration.
Should you have any questions related to this letter, please contact Mr. Kenneth M.
Nicely at (630) 657-2803.
Respectfully, P. R. Simpson Manager - Licensing Mid-West Regional Operating Group Attachments:
Attachment A: Global Nuclear Fuel Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit 1 Cycle 18 (PROPRIETARY VERSION)
Attachment B: Global Nuclear Fuel Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit I Cycle 18 (NON-PROPRIETARY VERSION)
Attachment C: Global Nuclear Fuel Affidavit cc:
Regional Administrator - NRC Region III NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Office of Nuclear Facility Safety - Illinois Department of Nuclear Safety
STATE OF ILLINOIS COUNTY OF DUPAGE IN THE MATTER OF EXELON GENERATION COMPANY, LLC QUAD CITIES NUCLEAR POWER STATION, UNIT I
)
)
)
) Docket Number
) 50-254
SUBJECT:
Supplement to Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit AFFIDAVIT I affirm that the content of this transmittal is true and correct to the best of my knowledge, information and belief.
P. R. Simpson Manager - Licensing Mid-West Regional Operating Group Subscribed and sworn to before me, a Notary Public in and for the State above named, this __-_"
_ day of
] *",2002 TI*1 MOTHYA. BYAM Noory Pub~ c I.. I,
Attachment B Quad Cities Nuclear Power Station, Unit I Supplement to Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit Global Nuclear Fuel Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit I Cycle 18 (NON-PROPRIETARY VERSION)
Attachment B Quad Cities Nuclear Power Station, Unit 1 Supplement to Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit Global Nuclear Fuel Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit I Cycle 18 (NON-PROPRIETARY VERSION)
Attachment Additional Information Regarding the August 2, 2002 Cycle Specific SLMCPR for Quad Cities Unit 1 Cycle 18 References
[1]
Letter, Frank Akstulewicz (NRC) to Glen A. Watford (GE), "Acceptance for Referencing of Licensing Topical Reports NEDC-32601P, Methodology and Uncertainties for Safety Limit MCPR Evaluations; NEDC-32694P, Power Distribution Uncertainties for Safety Limit MCPR Evaluation; and Amendment 25 to NEDE-2401 1-P-A on Cycle Specific Safety Limit MCPR," (TAC Nos.
M97490, M99069 and M97491), March 11, 1999.
[2]
Letter, Thomas H. Essig (NRC) to Glen A. Watford (GE), "Acceptance for Referencing of Licensing Topical Report NEDC-32505P, Revision 1, R-Factor Calculation Method for GEl1, GEl2 and GEM3 Fuel," (TAC No. M99070 and M95081), January 11, 1999.
[3]
General Electric BWR Thermal.Analysis Basis (GETAB): Data, Correlation and Design Application, NEDO-10958-A, January 1977.
[4]
Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of 10xl0 Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies", FLN-2001-016, September 24,2001.
[5]
Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Confirmation of Applicability of the GEXL14 Correlation and Associated R-Factor Methodology for Calculating SLMCPR Values in Cores Containing GE14 Fuel", FLN-2001-017, October 1, 2001.
[6]
GEXL96 Correlation for ATRIUM-9B Fuel, NEDC-3298 1P, Revision 0, September 2000.
[7]
Letter, Glen A. Watford (GNF-A) to U. S. Nuclear Regulatory Commission Document Control Desk with attention to J. Donoghue (NRC), "Final Presentation Material for GEXL Presentation February 11, 2002", FLN-2002-004, February 12, 2002.
Comparison of Quad Cities Unit 1 SLMCPR Values for Cycles 18 and 17, 17A Table 1 summarizes the relevant input parameters and results of the SLMCPR determination for the Quad Cities Unit 1 Cycle 18 and 17 cores. The SLMCPR evaluations were performed using NRC-approved methods and uncertainties[11, supplemented with Quad Cities Unit 1 specific uncertainties as indicated in Table 2. These calculations use the GEXL14 correlation for GE14 fuel and GEXL96[6] for the SPC fuel.
The GEXL14 bias and uncertainty values used in confirming the DLO and SLO SLMCPR values for Cycle 18 of Quad Cities Unit 1 are the higher values indicated on sheet 35 of the presentation materials attached to Reference [7].
The SLMCPR evaluations for Cycles 17 and 17A were performed by SPC. The quantities that have been shown to have some impact on the determination of the safety limit MCPR (SLMCPR) are provided.
In general, the calculated safety limit is dominated by two key parameters: (1) flatness of the core bundle-by-bundle MCPR distributions and (2) flatness of the bundle pin-by-pin power/R factor distributions. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR.
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page 1 of 6
((1]
Attachment Additional Information Regarding the August 2,2002 Cycle Specific SLMCPR for Quad Cities Unit 1 Cycle 18 Pin-by-pin power distributions are characterized in terms of R-factors using the NRC approved methodology 21. (( ))
Summary
(( )) have been used to compare quantities that impact the calculated SLMCPR value. The calculated 1.10 Monte Carlo SLMCPR for Quad Cities Unit 1 Cycle 18 is consistent with what one would expect (( ))
Based on all of the facts, observations and arguments presented above, it is concluded that the calculated SLMCPR value of 1.10 for the Quad Cities Unit 1 Cycle 18 core is appropriate.
For single loop operations (SLO) the calculated safety limit MCPR for the limiting case is 1. 11 as determined by specific calculations for Quad Cities Unit 1 Cycle 18.
Supporting Information The following information is provided in response to NRC questions on similar submittals regarding changes in Technical Specification values of SLMCPR. NRC questions pertaining to how GE14 applications satisfy the conditions of the NRC SERE'] have been addressed in Reference [4]. Other generically applicable questions related to application of the GEXL14 correlation and the applicable range for the R-factor methodology are addressed in References
[5] and [7]. Only those items that require a plant/cycle specific response are presented below since all the others are contained in the references that have already been provided to the NRC.
The core loading information for Quad Cities Unit 1 Cycles 17A and 18 is provided in Figures 1 and 2, respectively. The impact of the fuel loading pattern differences on the calculated SLMCPR is correlated to the values of (( ))
The power and non-power distribution uncertainties that are used in the analyses are indicated in Table 2. The referenced document numbers have previously been reviewed and approved by the NRC. The SER (Reference [1]) specifically provides that higher uncertainty values be used when necessary as was the case for this SLMCPR evaluation for Quad Cities Unit 1 Cycle 18.
Prepared by:
G. I. Maldonado Technical Program Manager Verified by:
H. Zhang Technical Program Manager
((1]
page 2 of 6
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4
Attachment Additional Information Regarding the August 2, 2002 Cycle Specific SLMCPR for Quad Cities Unit 1 Cycle 18 Table 1 Comparison of the Quad Cities Unit 1 Cycle 18 and Cycle 17, 17A SLMCPR QUANTITY, DESCRIPTION Quad Cities Quad Cities Quad Cities Unit I Cycle Unit I Cycle Unit I Cycle 17 17A 18 Number of Bundles in Core 724 724 724 Limiting Cycle Exposure Point N/A N/A EOR-1.5K Cycle Exposure at Limiting Point [MWd/MTU]
N/A N/A 15500 Reload Fuel Type ATRIUM-9B ATRIUM-9B GE14 Latest Reload Batch Fraction [%]
32.6%
0%
40.9%
Latest Reload Average Batch Weight %
3.82%
0%
4.10%
Enrichment Batch Fraction for GE14 0%
0%
40.9%
Batch Fraction for ATRIUM-9B 60.1%
60.1%
59.1%
Batch Fraction for GElO 39.9%
39.9%
0%
Core Average Weight % Enrichment 3.52%
3.52%
3.85%
Core MCPR (for limiting rod pattern)
N/A N/A 1.49 Power distribution uncertainty N/A N/A See Table 2, Column 2 Non-power distribution uncertainty N/A N/A See Table 2, Column 2 Calculated Safety Limit MCPR 1.111 1.15' 1.102 1 SPC Safety Limit MCPR of 1.11/1.15 includes the effects of channel bow per SPC approved method.
2 GNF Safety Limit MCPR of 1.10 does not include the effects of channel bow per GNF approved method. Such effects are incorporated in the Operating Limit.
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A
Attachment Additional Information Regarding the August 2, 2002 Cycle Specific SLMCPR for Quad Cities Unit 1 Cycle 18 Table 2 Comparison of Quad Cities Unit I Cycle 18 Specific Inputs to NRC-accepted Values COLUMN 1 COLUMN 2 DESCRIPTION Uncertainty Values (%)
Quad Cities Unit previously accepted by 1 Specific NRC Values (%)
Non-power Distribution From Table 2.1 of Uncertainties NEDC-32601P-A Core flow rate (derived from pressure 2.5 TLO 2.5 TLO drop) 6.0 SLO 6.0 SLO Individual channel flow area
(())
(())
Individual channel friction factor 5.0 5.0 Friction factor multiplier
(())
[11))
Reactor pressure
(())
(())
Core inlet temperature 0.2 0.2 Feedwater temperature
(())
(())
Feedwater flow rate
((]1 2.3 Power Distribution Uncertainties GETAB uncertainties as Specific Values consistent with the Revised used to produce values
(%)
Methodology of NEDC-32601P-A shown in Table 4.1 of NEDC-32601P-A GEXL R-factor
(())
(())
Random effective TIP reading 1.2 TLO 1.2 TLO 2.85 SLO 2.85 SLO Systematic effective TIP reading
((1]
(())
Integrated effective TIP reading
(())
((1]
Bundle power
(())
4.156 Effective total bundle power
(())
5.0 uncertainty
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page 4 of 6
(( 1
Attachment Additional Information Regarding the August 2, 2002 Cycle Specific SLMCPR for Quad Cities Unit 1 Cycle 18 Figure I Reference Core Loading Pattern - Cycle 17A 1
2 3
4 5
6 7
8 9
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Bundle Name GEl 0-P8HXB31 1-GZ-1OOT-145-T6-3869 GE1 0-P8HXB312-7GZ-10OT-145-T6-3870 GE1 0-P8HXB332-8G5 0-1 OT-145-T6-3872 D GE10-P8HXB333-4G5 0/6G4 0-IO0T-145-T6-3871 E ATRM9-P9DATB348-11G6.5-SPC100T-9WR-144-T6-2444 F ATRM9-P9DATB36O-1 1G6.5-SPC100T-9WR-144-T6-2445 G ATRM9-P9DATB383-1 1 GZ-SPC1OOT-9WR-144-T6-2446 H ATRM9-P9DATB382-12GZ-SPC100T-9WR-144-T6-2438 Number In Core 4O 17 144 88 152 48 92 143 Total 724
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Attachment Additional Information Regarding the August 2, 2002 Cycle Specific SLMCPR for Quad Cities Unit 1 Cycle 18 Figure 2 Reference Core Loading Pattern - Cycle 18 12 3
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01 03 05 07 09 11 13 15 17 41 43 45 47 49 51 53 55 57 59 Bundle Name A ATRM9-PgDATB348-1 1-6 5-SPC100T-9WR-144-T6-2444 B ATRM9-P9DATB360-1 1G6 5-SPC100T-9WR-144-T6-2445 C GE14-P10DNAB411-14GZ-I(OT-145-T6-2564 D GE 4-PIODNAB409-15GZ-10OT-145-T6-2565 E ATRM19-P9DATB383-1 1GZ-SPC10T-9WR-144-T6-2446 F ATRM9-P9DATB382-12GZ-SPC100T-9WR-144-T6-2438 Number In Core 145 48 152 144 92 143 Total 724 AIAIAIAI BIBIAIAIAIA AIAIFIEIAIAIAIA EIFIAIA AAAI EWAIAIAIAIEIFIAIA AtAI!=
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page 6 of 6
Attachment C Quad Cities Nuclear Power Station, Unit I Supplement to Request for Technical Specifications Change for Minimum Critical Power Ratio Safety Limit Global Nuclear Fuel Affidavit
Global Nuclear Fuel A Joint Venture of GE, Toshiba. & Hitachi Affidavit I, Glen A. Watford, state as follows:
(1) 1 am Manager, Fuel Engineering Services, Global Nuclear Fuel - Americas, L.L.C.
("GNF-A") 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, "Additional Information Regarding the Cycle Specific SLMCPR for Quad Cities Unit I Cycle 18,"
August 2, 2002.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A 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 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 definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A 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 cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future GNF-A customer funded development plans and programs, of potential commercial value to GNF A;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
Page 1
Affidavit The information sought to be withheld is considered to be proprietary for the reasons set forth in 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 GNF-A, 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 GNF-A, 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, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A 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 GNF-A 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 agreements.
(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.
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 GNF-A or its licensor.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit making opportunities. The fuel design and licensing methodology is part of GNF-A'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 GNF-A or its licensor.
C:\\ocuments and Settmgs~ne24383My Document\\Userdata ILICAffidavi qclc 1slmcp* doc Page 2 I
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Affidavit 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.
GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A 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 GNF-A 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 GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed at Wilmington, North Carolina, this 2nd day of August
,2002.
Glen A. Watford Global Nuclear Fuel - Americas, LLC C:"VDcuments and Sett$ngs'nc24383\\hy Documents\\Userdata v
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