W3F1-2005-0025, Licensing Report Errors

Licensing Report Errors

ML051100168
Person / Time
Site:	Waterford
Issue date:	04/15/2005
From:	Murillo R Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC M98325, W3F1-2005-0025 HI-971628
Download: ML051100168 (12)

Text

Entergy Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-739-715 Fax 504-739-6698 rmurill@entergy.com Robert J. Murillo Licensing Manager, Acting Waterford 3 W3FI-2005-0025 April 15, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Holtec Licensing Report Errors Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. NRC letter dated July 10, 1998, Issuance of Amendment No. 144 to Facility Operating License NPF Waterford Steam Electric Station, Unit 3 (TAC No. M98325)"

2. Entergy letter dated March 27, 1997, "Waterford 3 SES Docket No.

50-382 License No. NPF-38 Technical Specification Change Request NPF-38-193" (W3Fl 0061)

Gentlemen:

License Amendment 144 (Reference 1) was issued to the Waterford Steam Electric Station, Unit 3 (Waterford 3) to increase the spent fuel pool storage capacity from 1088 to 2398 fuel assemblies and to increase the maximum fuel enrichment from 4.9 w/o (weight percent) to 5.0 w/o U-235. As documented in Entergy Operations, Inc. (Entergy's) 10 CFR 50 Appendix B corrective action program and discussed below, minor non-safety significant errors were recently identified in the information submitted to the NRC via Reference 2 in support of this amendment.

The purpose of this letter is to inform the NRC staff, for information only, of two minor errors that were discovered in Holtec Licensing Report for Re-racking of Waterford 3 Spent Fuel Pool. The Holtec report was provided to the NRC staff as Attachment IlIl to Reference 2.

The errors were as follows:

1. The Boral panel was modeled off-center for the Region 1 storage racks when it should have been modeled on center.

2. The minimum, Region 1, flux trap water-gap dimension was modeled at 1.26 inches when it should have been modeled at 1.22 inches for consistency with the water-gap tolerance.

The impact of these errors is as follows:

1. A case was run to determine the effect on reactivity of the positioning of the Boral 4 4 0

W3F1-2005-0025 Page 2 of 3 panel. The results show that centering the Boral panel on the cell wall reduces the reactivity. Therefore, the information previously submitted in Reference 2 is conservative.

2. An additional calculation was run to determine the reactivity effect of the smaller water gap. Results show that the smaller water gap results in a larger reactivity, 0.0087 delta k rather than 0.0041 delta k as reported in Table 4.5.1 of the Holtec report. Combining this larger reactivity effect with the other previously calculated tolerance effects (see Table 4.5.1), the total reactivity effect of manufacturing tolerances is 0.0102 delta k rather than 0.0068 delta k as reported in Section 4.5.2, Table 4.2.1, and Table 4.5.1 of the Holtec report. When statistically combined with calculational uncertainties, the overall uncertainty is 0.0103 delta k rather than 0.0069 delta k as reported in Section 4.5.2 and Table 4.2.1 of the Holtec report.

This results in a slightly larger maximum k-eff (0.931 8 rather than 0.9284) and a slightly larger MCNP4a maximum reactivity (0.9306 rather than 0.9272) then previously reported in Table 4.2.1 of the Holtec report. However, the corrected maximum k-eff remains below the regulatory limit of 0.95. The corrected Holtec report pages are provided in Attachment 1. contains proprietary information. The redacted version of the corrected pages is provided in Attachment 2 and the Holtec International application for withholding of proprietary information from public disclosure in accordance with 10 CFR 2.390 is provided in Attachment 3.

Entergy reviewed this condition in accordance with 10 CFR 50.9 and the condition was found to have no significant implication for public health and safety or common defense and security and therefore is not reportable per 10 CFR 50.9. This conclusion is based on

1) the first error was conservative and 2) the maximum k-eff, when corrected for the second error, continues to be less than the applicable regulatory limit (i.e., 0.95) (reference Waterford 3 Technical Specification 5.6).

This submittal contains no commitments. If you have any questions or require additional information, please contact D. Bryan Miller at 504-739-6692.

Sincerely, Robe il Licensing Manager, Acting Waterford 3 RJM/dbm Attachments:

1. Marked-up Holtec Report Pages (Proprietary)

2. Redacted Version of Marked-up Holtec Report Pages (Non-proprietary)

3. Holtec Intemational Application for Withholding Proprietary Information from Public Disclosure

W3Fl-2005-0025 Page 3 of 3 cc:

Dr. Bruce S. Malleti Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop 0-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K. Street, NW Washington, DC 20006-3817 W3FI-2005-0025 Holtec International Application for Withholding Proprietary Information from Public Disclosure

AFFIDAVIT PURSUANT TO IOCFR2.390 1, Stefan Anton, being duly sworn, depose and state as follows:

(1)

I am the Licensing Manager for Holtec International and have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.

(2)

The information sought to be withheld is contained in the document entitled "Licensing Report for Reracking of Waterford Spent Fuel Pools," Holtec Report HI-971628, revision 5. The proprietary material in this document is delineated by proprietary designation (i.e., shaded text) on page 4-24.

(3)

In making this application for withholding of proprietary information of which it is the owner, Holtec International 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 1 OCFR Part 9.17(a)(4),

2.390(a)(4), and 2.390(b)(1) 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 Project

v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), 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 information are:

a.

Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by Holtec's competitors without license from Holtec International 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.

I

AFFIDAVIT PURSUANT TO IOCFR2390

c.

Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies of Holtec International, its customers, or its suppliers;

d.

Information which reveals aspects of past, present, or future Holtec International customer-funded development plans and programs of potential commercial value to Holtec International;

e.

Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

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 the NRC in confidence. The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, and is in fact so held.

The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(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 Holtec International 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 designee), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside Holtec International are limited to regulatory bodies, customers, and 2

AFFIDAVIT PURSUANT TO 10CFR2390 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 classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed historical data and analytical results not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed using codes developed by Holtec International. Release of this information would improve a competitor's position without the competitor having to expend similar resources for the development of the database. A substantial effort has been expended by Holtec International to develop this information.

(9)

Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International's comprehensive spent fuel storage 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.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.

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.

Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International 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 Holtec International would be lost if the information were disclosed to the public. Making such information available to 3

AFFIDAVIT PURSUANT TO IOCFR2390 competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Holtec International 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 NEW JERSEY)

)

ss:

COUNTY OF BURLINGTON)

Stefan Anton, 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 Marlton, New Jersey, this 14th day of April, 2005.

Mr. Stefan Anton Holtec International Subscribed and sworn before me this day of 4

, 2004' t, i;C Z 2 ?.

!tO)TA'Y PUBLIC OF NEW JERSEY My Cormrn;S9jon Exp!r= April 2 62005 4

W3FI -20054025 Redacted Version of Marked-up Holtec Report Pages (Non-proprietary)

(5.0 +/- 0.05%). Independent calculations with the MCNP4a code provides confirmation of the validity of the reference KENOSa calculations.

4.5.2 Uncertainties Due to Tolerances The reactivity effects of manufacturing tolerances are tabulated in Table 4.5.1. The net effect of these tolerances is an uncertainty of

• 0.0102 Ak which, when statistically combined with calculational uncertainties (Table 4.2.1), results in an overall uncertainty of +/- 0.0103 Ak.

The effect of the 0.05% tolerance in enrichment is included in the overall value listed above.

Fuel density was assumed to be the maximum (10.47 gms UO2 cm3) and is therefore conservatively included in the reference criticality calculation.

4.5.3 Eccentric Fuel Positioning The fuel assembly is assumed to be normally located in the center of the storage rack cell.

Calculations were also made with the fuel assemblies assumed to be in the corner of the storage rack cell (four-assembly cluster at closest approach).

These calculations indicated that the reactivity decreases slightly (-0.0009 Ak) as determined by differential KENO-Sa calculations.

The highest reactivity, therefore, occurs for the reference design with the assemblies nominally centered in the cells.

4.6 Region 2 Criticality Analyses 4.6.1 Nominal Design Case CASMO3 was used for dejletion analyses in Region 2 and the restart option was then used to analytically transfer the spent fuel into the storage rack configuration at a reference temperature of 40C.

Calculations were also made for fuel of several different initial enrichments and Holtec Report HI-971628 4-11 1

ffiffi, I'M 1

M. A, a

o

Shaded Areas denote Proprietary Information Table 4.5.1 REACTIVITY EFFECTS OF MANUFACTURING TOLERANCES Ak Condition Tolerance Region 1 Region 2 Boron areal density

+/- 0.0026

+/- 0.0035 Absorber width

+/- 0.0011

+/- 0.0009 Absorber length Negligible Negligible Box I.D

+/- 0.0028

+/- 0.0013 Water Gap Spacing

+/- 0.0087 NA SS thickness

+/- 0.0008

+/- 0.0001 Fuel Pin Pitch

+/- 0.0008

+/- 0.0009 Fuel Enrichment

+/- 0.0017

+/- 0.0021(t)

Fuel Density NA NA Pellet Diameter

+/- 0.0003

+/- 0.0001 Sheath Thickness l

0.0001 NA Clad O.D.

+/- 0.0027

+/- 0.0016 Clad I.D.

+/- 0.0001

+/- 0.0002 Guide Tube Thickness

+/- 0.0012

+/- 0.0007 Statistical Sum

+/- 0.0102

+/- 0.0047 (root-mean square) t) The reactivity effect of the tolerance on enrichment in Region 2 is enrichment-dependent and is separately evaluated for each enrichment. The value shown here is for 5.0 % fuel.

Holtec Report HI-971628 4-24