View source for L-13-074, Response to Request for Additional Information Regarding End-of-Life Moderator Temperature Coefficient Testing (TAC Nos. ME9144 and ME9145V)

{{Adams
| number = ML13155A021
| issue date = 06/01/2013
| title = Response to Request for Additional Information Regarding End-of-Life Moderator Temperature Coefficient Testing (TAC Nos. ME9144 and ME9145V)
| author name = Larson E
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000334, 05000412
| license number = DPR-066, NPF-073
| contact person = 
| case reference number = L-13-074, TAC ME9144, TAC ME9145
| document type = Letter type:L
| page count = 15
| project = TAC:ME9144, TAC:ME9145
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:*^I*\S*J                                                                          Beaver Valley Power Station
'nrstEnergyNumerating Compan)M{hhM FrOm PubliC Disclosure Under 10 CFR 2.390          s/j/pp/ngporf ^ f5^
Eric A. Larson                                                                              724-682-5234 Site Vice President                                                                    Fax: 724-643-8069 June 1,2013 L-13-074                                                 10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Response to Request for Additional Information Regarding End-of-Life Moderator Temperature Coefficient Testing (TAC Nos. ME9144 and ME9145V By correspondence dated July 25, 2012 (Accession No. ML12208A309), FirstEnergy Nuclear Operating Company (FENOC) submitted to the Nuclear Regulatory Commission (NRC) a proposed amendment to the Beaver Valley Power Station, Unit Nos. 1 and 2, Technical Specifications (TSs). The proposed amendment would modify TS 3.1.3, "Moderator Temperature Coefficient Measurement (MTC)," to allow the normally required near-end-of-life MTC measurement to not be performed under certain conditions.
By correspondence dated December 28, 2012 (Accession No. ML12340A256), the NRC requested additional information with three questions regarding FENOC's July 25, 2012 correspondence. A February 20, 2013 teleconference was held between the NRC and FENOC to discuss the December 28, 2012 request. By correspondence dated May 9, 2013 (Accession No. ML13084A346), the NRC staff stated that a response to question number 3 of the December 28, 2012 request is not required; Attachment 1 provides a proprietary version of the response to the NRC's December 28, 2012 request. Attachment 2 provides a nonproprietary version of the response. FENQC requests, that the Westinghouse Electric Company LLC proprietary information provided in Attachment 1 be withheld from public disclosure pursuant to 10 CFR 2.390. An affidavit from Westinghouse Electric Company LLC, the owner of the proprietary information, is enclosed. Superscripts correspond to the sections of the Westinghouse Electric Company LLC affidavit and identify the bases for nondisclosure.
Once Attachment 1 has been separated from this letter, the letter can be decontrolled.
Withhold From Public Disclosure Under 10 CFR 2.390 When separated from Attachment 1, this document is decontrolled.

Withhold From Public Disclosure Under 10 CFR 2.390 Beaver Valley Power Station, Unit Nos. 1 and 2 L-13-074 Page 2 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager- FENOC Fleet Licensing, at (330) 315-6810.
I declare under penalty of perjury that the foregoing is true and correct. Executed on June I , 2013.
Sincerely, Eric A. Larson Attachments:
1     Response to December 28, 2012 Request for Additional Information (Proprietary Version) 2     Response to December 28, 2012 Request for Additional Information (Nonproprietary Version)

==Enclosure:==

10 CFR 2.390 Affidavit for Westinghouse Electric Company LLC cc:   NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative Withhold From Public Disclosure Under 10 CFR 2.390 When separated from Attachment 1, this document is decontrolled.

Nonproprietary ATTACHMENT 2 L-13-074 Response to December 28, 2012 Request for Additional Information (Nonproprietary Version)
Page 1 of 6 By letter to the Nuclear Regulatory Commission (NRC) dated July 25, 2012 (Accession No. ML12208A309), FirstEnergy Nuclear Operating Company (FENOC) submitted a proposed amendment to the Beaver Valley Power Station, Units 1 and 2, Technical Specifications (TSs). By correspondence dated December 28, 2012 (Accession No. ML12340A256), the NRC requested additional information with three questions regarding FENOC's July 25, 2012 correspondence. By correspondence dated May 9, 2013 (Accession No. ML13084A346), the NRC staff stated that a response to question number three of the December 28, 2012 request is not required. The NRC staffs requests are presented below in bold type, followed by a nonproprietary version of the response. The Westinghouse Electric Company LLC proprietary information that would have otherwise been contained within the brackets, has been removed from this attachment so that it may be decontrolled.
: 1. In accordance with the second condition in the NRC staff's safety evaluation for WCAP-13749-P-A, the licensee proposed to confirm, on a cycle-specific basis, that core fuel design changes or data from MTC predictions and measurements do not show a significant effect on the predictive correction.
Please clarify the process and criteria for making this determination and justify their adequacy (e.g., statistical testing, engineering judgment, etc).

===Response===
As described in WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement," approved in March 1997, the hot full power (HFP) predictive correction accounts for the observed differences between the measured and predictive (M-P) moderator temperature coefficients (MTCs). The HFP predictive correction
([            ]a>c) was derived by summing the hot zero power (HZP) predictive correction, the xenon sensitivity and the burnup sensitivity. The HZP predictive correction is provided in WCAP-13749-P-A. As long as the beginning of life (BOL)
HZP MTC (M-P) is less negative than the HZP predictive correction, the HFP predictive correction is valid for use during the cycle.
The tables below provide BOL HZP MTC measured values (MTC M), predicted values (MTC P), and the measured minus the predicted values (M-P) for each cycle listed for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 (BVPS-1 and BVPS-2, respectively). The predicted values were calculated using PHOENIX-P/ANC. The MTC M for both BVPS-1 and BVPS-2 are consistently more positive than MTC P, and therefore is conservative for evaluating the continued use of the HFP predictive correction value of [            ]a>c.

Nonproprietary L-13-074 Page 2 of 6 Table 1: BVPS-1 BOL HZP MTC Data (all values In pcm/&deg;F)
Cycle            MTCM                          MTCP       (M-P) 14              -1.11                    I      ]a'C  [     ]a'C 15              -0.56                    I      ]a>C  [     ]a'C 16               0.37                      I    ]a'C  [     ]a'&deg; 17               -1.97                    [      la'C  [     ]a>&deg; 18               -0.06                    I      ]a'&deg;  I     ]a>c 19                1.13
[   ]a'&deg;   [     ia-c 20                0.79                     [    ]a>c   [     la>c 21               0.76                      [    ]a'C  i      ia'c 22               -1.05                    [      ]a>C i      ia'c Table 2: BVPS-2 BOL HZP MTC Data (all values in pcm/&deg;F)
Cycle            MTC (M)                     MTC (P)       (M-P) 9               -0.87                   I       ]a'C [     ]a'c 10                1.58                     I    ]a'&deg;  [     ]W 11               1.12                      [    ]a'&deg;  [     I8'0 12               0.38                     [     ]a'C  I     ]3>C 13               0.38                     [     ]a'C  [     I8'0 14               0.88                     [     ]3>C  I     ]3lC 15              -0.03                    [      ]a>C  [     ]a'C 16               1.57                     [     ]3>C  [     I8'0
[      ]3lC r     , a,c 17               0.26

Nonproprietary L-13-074 Page 3 of 6 WCAP-13749-P-A states, "...the [HFP] predictive correction is reexamined if changes in core fuel designs or continued MTC calculation/measurement data show significant effect on the predictive correction." During the BVPS core design process for each cycle, Westinghouse would provide the HFP predictive correction to FENOC. The following two qualitative assessments will ensure that the predictive correction remains valid for the applicable fuel cycle.
: 1. Prior to each reload, the "Reload Risk Evaluation Checklist" is used to identify and determine the risk of major fuel design changes or core design methodology changes. This checklist would identify whether the reload will use revised or different methodologies and assesses the impact of these changes on the existing analyses. Additionally, prior to accepting the Westinghouse core design calculations, FENOC compares the results generated by Westinghouse computer models to results generated by FENOC using an independent computer model. These evaluations would provide initial indication of a possible change in the BOL HZP MTC (M-P) relationship prior to startup of the fuel cycle.
: 2. In accordance with TS 3.1.3, "Moderator Temperature Coefficient Measurement (MTC)," each cycle during low power physics testing, FENOC measures the BOL HZP MTC. Prior to each conditional exemption of the end of life (EOL) HFP MTC measurement test, FENOC would compare BVPS specific MTC (M-P) data each cycle against previous cycles to determine if there is a change to the measured versus predicted MTC relationship.
If the value of the BOL HZP MTC (M-P) approaches the HZP predictive correction given in WCAP-13749-P-A, then FENOC would evaluate the use of the HFP MTC predictive correction to show that the value of [              ]a>c is conservative or measure the EOL HFP MTC in accordance with the TSs. During use of PHOENIX-P/ANC and after transition to NEXUS/ANC9 (PARAGON), the above tools and assessments would be used each cycle to verify continued consistency and validity of the BOL HZP MTC (M-P) relationship as it pertains to the predictive correction of WCAP-13749-P-A.
: 2. The predictive correction term defined in WCAP-13749-P-A is based, in part, on a tolerance limit that Westinghouse derived from differences between a set of measured and predicted values of the MTC at the beginning of an operating cycle at hot, zero power conditions. Specifically, the predicted MTC values in

Nonproprietary L-13-074 Page 4 of 6 WCAP-13749-P-A were determined from calculations using the PHOENIX-P/ANC code package for a variety of pressurized-water reactor (PWR) core designs prior to 1995. Although the NRC staff has approved the PARAGON lattice physics code as a replacement to PHOENIX-P, it cannot not be concluded that the statistical database, and hence the predictive corrections terms, for the two codes will be equivalent. Therefore, if approval for the use of the predictive correction term for the PHOENIX-P code for calculations with the PARAGON code is sought under this license amendment request, please provide unbiased and statistically significant data analogous to that reported in Table 3-1 of WCAP-13749-P-A for calculations performed with the PARAGON code for contemporary PWR core designs, along with: (1) justification that this data belongs to the same population as the pre-1995 data in WCAP-13749-P-A, generated with the PHOENIX-P code; or (2) a new predictive correction term for the PARAGON code for contemporary cores that is based on a 95/95 tolerance limit appropriate for modifying end-of-cycle MTC predictions made with this code.

===Response===
A database of plants is used for regression testing and continued qualification of core design system code releases. This database consists of multiple cycles of plants chosen to encompass the variety of plant, fuel lattice types, and fuel management strategies that the code will be used to analyze. Comparison of the results for any release with those of previous releases assures continued compliance of the code with its licensing basis.
This set of contemporary PWR cores (including BVPS) has been selected as representative of the statistical database used in WCAP-13749-P-A. These cores have been modeled using both PHOENIX-P/ANC and NEXUS/ANC (the NEXUS cross-section generation system uses PARAGON as the lattice transport code).
Table 1 below lists data analogous to that reported in Table 3-1 of WCAP-13749-P-A for calculations performed with NEXUS/ANC. Benchmarks for both PHOENIX-P/ANC and NEXUS/ANC are listed in the table to show a comparison between the two code sets. Measured end of life (EOL) HFP MTC data is not readily available for most of the benchmark cores, and therefore, for this parameter, measured-minus-predicted (M-P) data was only provided for BVPS for PHOENIX-P/ANC. Additionally, beginning of life (BOL) HZP isothermal temperature coefficient (ITC) data was included instead of BOL HZP MTC data as the measured BOL HZP MTC is the predicted BOL HZP doppler temperature coefficient (DTC) subtracted from the measured BOL HZP ITC.

Nonproprietary L-13-074 Page 5 of 6 The results in Table 1 show that [
                                                                          ]ac Using the M-P values in Table 1, the predictive correction term from WCAP-13749-P-A [
r Using commercial statistics software, the BOL HZP ITC M-P data points in Table 1 have been demonstrated to fall within a normal distribution per the Anderson-Darling and Ryan-Joiner tests, with a M-P mean of [                   ]a>c pcm/&deg;F and a standard deviation of [        ]a'c pcm/&deg;F. From this data, a 95/95 one-sided tolerance limit for the HZP predictive correction of [           ]a'c pcm/&deg;F can be calculated using a K-value of [
                                         ]a,c Applying [
                                    ]ac from WCAP-13749-P-A [
              ]a<<c yields a HFP predictive correction of [            ]a'c pcm/&deg;F. [
ia,c Additionally, the predictive correction term for PHOENIX-P/ANC was recalculated for comparison (for contemporary cores). [
     ]a'c using the K-value of [              ]a>c a HZP predictive correction of
[        ]a*c pcm/&deg;F was calculated. [ Applying the 1.0 pcm/&deg;F and 0.4 pcm/&deg;F xenon concentrati                                     ]a'c yields a HFP predictive correction of
[        r pcm/'F. [
                         ]a'c This shows that: (1) the PHOENIX-P/ANC results in WCAP-13749-P-A are reproducible with the contemporary PWR cores and latest code versions, and (2) the set of cores chosen represents an unbiased sample of the larger data set used in WCAP-13749-P-A.

Nonproprietary L-13-074 Page 6 of 6 Table 1: Summary of Statistics for Measured Minus Predicted Differences of Critical Boron, ITC, MTC, and Rod Worths for Westinghouse Cores PHOENIX-P/ANC       NEXUS/ANC      Number Parameter                  Standard         Standard   of Data a,c Mean Deviation   Mean   Deviation   Points

Enclosure to FENOC Letter L-13-074 10 CFR 2.390 Affidavit for Westinghouse Electric Company LLC (6 Pages Follow)

CAW-13-3703 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
Bradley F. Maurer, Principal Engineer Plant Licensing Sworn to and subscribed before me this 25th day of April 2013 COMMONWEALTH OP PENNSYLVANIA NOTARIAL SEAL Renee Giampole, Notary Public Penn Township, Westmoreland County My Commlstlon Expires September 26,2013

2                                     CAW-13-3703 (1)  I am Principal Engineer, Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2)   I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3)  I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4)  Pursuant to the provisions of paragraph (b)(4) of Section 2.390 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 should be withheld.
(i)      The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii)     The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse 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 application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a)      The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3                                        CAW-13-3703 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b)     It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c)     Its use 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 a similar product.
(d)     It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)     It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f)     It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following:
(a)     The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)     It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)     Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4                                     CAW-13-3703 (d)     Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)      Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)      The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
(iv)  The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v)   The proprietary information sought to be withheld in this submittal is that which is appropriately marked in FirstEnergy Nuclear Operating Company Letter L-13-074, "Response to Request for Additional Information Regarding End-of-Life Moderator Temperature Coefficient Testing (TAC Nos. ME9144 and ME9145)," Attachment 1, "Response to December 28,2012 Request for Additional Information" (Proprietary), for submittal to the Commission, being transmitted by FirstEnergy Nuclear Operating Company Letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as prepared by Westinghouse is that associated with FirstEnergy Nuclear Operating Company's request for NRC approval of L-12-271, Revision 0, "Beaver Valley Power Station, Unit Nos. 1 and 2 License Amendment Request to Modify Technical Specification 3.1.3, 'Moderator

5                                       CAW-13-3703 Temperature Coefficient (MTC),' to Provide an Exemption Under Certain Conditions (ML12208A309)," and may be used only for that purpose.
This information is part of that which will enable Westinghouse to:
(a)     Assist FirstEnergy with obtaining NRC approval of L-12-271, Revision 0, "Beaver Valley Power Station, Unit Nos. 1 and 2 License Amendment Request to Modify Technical Specification 3.1.3, 'Moderator Temperature Coefficient (MTC)/ to Provide an Exemption Under Certain Conditions" (ML12208A309).
(b)      Provide results of customer specific calculations.
(c)      Provide licensing support for customer submittals.
Further this information has substantial commercial value as follows:
(a)      Westinghouse plans to sell the use of the information to its customers for the purpose of meeting NRC requirements for licensing documentation associated with End of Life Moderator Temperature Coefficient Elimination submittals.
(b)      Westinghouse can sell support and defense of the use of the technology to its customer in licensing process.
(c)     The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar fuel design and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

6                                    CAW-13-3703 The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.}}