ML12275A418

San Onofre Nuclear Generating Station, Units 2 and 3 - Response to Request for Additional Information Question 11 Regarding License Amendment Request for Permanent Use of Areva Fuel and for Permanent Exemption to Use M5 Cladding

ML12275A418
Person / Time
Site:	San Onofre
Issue date:	09/27/2012
From:	St.Onge R J Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME6820, TAC ME6821, TAC ME6822, TAC ME6823
Download: ML12275A418 (24)

Text

{{#Wiki_filter:SOUTHERN CALIFORNIA Richard 1. St. Onge& DDirector, Nuclear Regulatory Affairs and.ED ISO N Emergency PlanningAn EDISON INTERNATIONAL CompanyRequest to Withhold from Public Disclosure Under 10 CFR 2.390(a)(4) and (6)September 27, 201210 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Subject:Reference:Docket Nos. 50-361 and 50-362Response to Request for Additional Information Question 11Regarding License Amendment Request for Permanent Use ofAREVA Fuel and for Permanent Exemption to Use M5 Cladding(TAC Nos. ME6820, ME6821, ME6822, AND ME6823)San Onofre Nuclear Generating Station, Units 2 and 3Letter from N. Kalyanam (NRC) to P. T. Dietrich (SCE) dated August 1,2012; Subject: San Onofre Nuclear Generating Station, Units 2 and 3License Amendment Request RE: Use of AREVA Fuel (TAC Nos.ME6820, ME6821, ME6822, AND ME6823)Dear Sir or Madam:By letter dated August 1, 2012, the Nuclear Regulatory Commission issued a Requestfor Additional Information (RAI) regarding use of unrestricted usage of AREVA fuel andpermanent exemption to use M5 cladding.The RAI letter requested a response within 30 days of receipt of the letter. NRC staffagreed by phone on September 4, 2012, that SCE may submit the response bySeptember 14, 2012 and September 30, 2012 specifically for RAI Question 11.Enclosure 2 of this submittal contains information that is proprietary to SCE or AREVA.SCE requests that this proprietary enclosure be withheld from public disclosure inaccordance with 10 CFR 2.390(a)(4). Enclosure 1 provides notarized affidavits fromSCE and AREVA which set forth the basis on which the information in Enclosure 2 maybe withheld from public disclosure by the Commission and addresses with specificity theconsiderations listed by paragraph (b)(4) of 10 CFR 2.390. Enclosure 3 provides thenon-proprietary version of Enclosure 2.Notice: This document is decontrolled when separated from Enclosure 2P.O. Box 128San Clemente, CA 92672Pýo00L Document Control Desk-2-September 27, 2012Request to Withhold from Public Disclosure Under 10 CFR 2.390(a)(4) and (6)There are no new regulatory commitments contained in this letter. If you have anyquestions or require additional information, please contact Ms. Linda T. Conklin,Licensing Manager, at (949) 368-9443.Sincerely,f41KEnclosures:1. Notarized AffidavitsProprietary Enclosures2. Response to Request for Additional Information (RAI) Question 11 regarding useof unrestricted usage of AREVA fuel and permanent exemption to use M5claddingNon-Proprietary Enclosures3. Response to Request for Additional Information (RAI) Question 11 regarding useof unrestricted usage of AREVA fuel and permanent exemption to use M5claddingcc: E. E. Collins, Regional Administrator, NRC Region IVR. Hall, NRC Project Manager, San Onofre Units 2 and 3G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3Notice: This document is decontrolled when separated from Enclosure-2. ENCLOSURE 1NOTARIZED AFFIDAVITS AFFIDAVITSTATE OF CALIFORNIA )) SS.CITY OF SAN CLEMENTE)1. My name is Owen J. Thomsen. I am employed by Southern California EdisonCompany ("SCE"). My present capacity is Manager, Nuclear Fuel Management, for the SanOnofre Nuclear Generating Station ("SONGS"), and in that capacity I am authorized to executethis Affidavit.2. SCE is the operating agent for SONGS. I am familiar with the policiesestablished by SCE to determine whether certain SCE information is proprietary andconfidential, and to ensure the proper application of these policies.3. I am familiar with SCE information in the document entitled "San Onofre NuclearGenerating Station, Units 2 and 3, Proposed Permanent Exemption Request and ProposedChange Number (PCN) 600, Amendment Application Numbers 261 and 247, Request forUnrestricted Use of AREVA Fuel," (referred to herein as "Document") submitted to the NRC inJuly 2011.4. SCE has classified the information contained in the Document as proprietaryand confidential in accordance with SCE's policies.5. Specifically, SCE applied the following criteria to determine that theinformation contained in the Document should be classified as proprietary and confidential:(a) SCE has a Non-Disclosure Agreement (NDA) with Westinghouse Electric LLC("Westinghouse") and AREVA NP ("AREVA") (the NDA is referred to as the'Westinghouse-AREVA-SCE NDA"), under which Westinghouse and AREVAhave provided to SCE certain proprietary and confidential information containedin the Document. (b) The information reveals details of Westinghouse's, SCE's, and/or AREVA'sresearch and development plans and programs, or the results of these plans andprograms.(c) The information includes test data or analytical techniques concerning a process,methodology, or component, the application of which results in a competitivecommercial advantage for Westinghouse, SCE, and/or AREVA.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides a competitivecommercial advantage for Westinghouse, SCE, and/or AREVA on productoptimization or marketability.(e) The unauthorized use of the information by one of Westinghouse's, SCE's,and/or AREVA's competitors would permit the offending party to significantlyreduce its expenditures, in time or resources, to design, produce, or market asimilar product or service.(f) The information contained in the Document is vital to a competitive commercialadvantage held by Westinghouse, SCE, and/or AREVA, would be helpful to theircompetitors, and would likely cause substantial harm to the competitive positionof Westinghouse, SCE, and AREVA.6. The information contained in the Document is considered proprietary andconfidential for the reasons set forth in Paragraph 5. In addition, the information contained in theDocument is of the type customarily held in confidence by AREVA, Westinghouse, and SCE,and not made available to the public. Based on my experience in the nuclear industry, I amaware that other companies also regard the type of information contained in the Document asproprietary and confidential.

7. In accordance with the Westinghouse-AREVA-SCE NDA, the Document hasbeen made available to the NRC in confidence, with the request that the information containedin this Document be withheld from public disclosure. The request for withholding the informationfrom public disclosure is made in accordance with 10 CFR 2.390. The information qualifies forwithholding from public disclosure under 10 CFR 2.390(a)(4) "Trade secrets and commercial orfinancial information."8. In accordance with SCE's policies governing the protection and control ofproprietary and confidential information, the information contained in the Document has beenmade available, on a limited basis, to others outside Westinghouse, SCE and AREVA only asrequired in accordance with the Westinghouse-AREVA-SCE NDA.9. SCE's policies require that proprietary and confidential information be kept ina secured file or area and distributed on a need-to-know basis. The information contained in theDocument has been kept in accordance with these policies.10. The foregoing statements are true and correct to the best of my knowledge,information, and belief, and if called as a witness I would competently testify thereto. I declareunder penalty of perjury under the laws of the State of California that the above is true andcorrect.SUBSCRIBED before me thisday of 2011.ow/en'j. 1Thomsenlbebact aNd wa N (Or O*UW4pwedte me on ofZu.. eIktobed sm" ftw6 fiýNOTARY PUBLIC, STATE OF CALIFORNIAMY COMMISSION EXPIRES:Reg. #:TRUPTI TRIVEDICommission # 1936996-Notary Public -CaliforniaOrange CountyMy Comm. EKpires Jun 14, 2015 AFFIDAVITCOMMONWEALTH OF VIRGINIA )) ss.COUNTY OF CAMPBELL )1. My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVANP Inc. (AREVA NP) and as such I am authorized to execute this Affidavit.2. I am familiar with the criteria applied by AREVA NP to determine whethercertain AREVA NP information is proprietary. I am familiar with the policies established byAREVA NP to ensure the proper application of these criteria.3. I am familiar with the AREVA NP information contained in a letter from RickWilliamson (AREVA NP) to Owen Thomsen (Southern California Edison) with subject "ProposedResponse to RAI on License Amendment Request for Use of AREVA VQP Fuel," FAB1 2-439,dated September 5, 2012 and referred to herein as "Document." Information contained in thisDocument has been classified by AREVA NP as proprietary in accordance with the policiesestablished by AREVA NP for the control and protection of proprietary and confidentialinformation.4. This Document contains information of a proprietary and confidential natureand is of the type customarily held in confidence by AREVA NP and not made available to thepublic. Based on my experience, I am aware that other companies regard information of thekind contained in this Document as proprietary and confidential.5. This Document has been made available to the U.S. Nuclear RegulatoryCommission in confidence with the request that the information contained in this Document bewithheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure isrequested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financialinformation."6. The following criteria are customarily applied by AREVA NP to determinewhether information should be classified as proprietary:(a) The information reveals details of AREVA NP's research and developmentplans and programs or their results.(b) Use of the information by a competitor would permit the competitor tosignificantly reduce its expenditures, in time or resources, to design, produce,or market a similar product or service.(c) The information includes test data or analytical techniques concerning aprocess, methodology, or component, the application of which results in acompetitive advantage for AREVA NP.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitive advantage for AREVA NP in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA NP, wouldbe helpful to competitors to AREVA NP, and would likely cause substantialharm to the competitive position of AREVA NP.The information in the Document is considered proprietary for the reasons set forth inparagraphs 6(b) and 6(c) above.7. In accordance with AREVA NP's policies governing the protection and controlof information, proprietary information contained in this Document has been made available, ona limited basis, to others outside AREVA NP only as required and under suitable agreementproviding for nondisclosure and limited use of the information.

8. AREVA NP policy requires that proprietary information be kept in a securedfile or area and distributed on a need-to-know basis.9. The foregoing statements are true and correct to the best of my knowledge,information, and belief.SUBSCRIBED before me thisday of 2.Kathleen A. BennettNOTARY PUBLIC, COMMONWEALTH OF VIRGINIAMY COMMISSION EXPIRES: 8/31/2015Reg. #110864KATHLEEN ANN BENNETTNotuy PublicCommanwealth of VirgiflaMy COmmMs8oln Expires Aug 31, 2015 ENCLOSURE 3Response to Request for AdditionalInformation (RAI) Question 11 regardinguse of unrestricted usage of AREVA fueland permanent exemption to useM5 cladding (Non-Proprietary)

RAI #11The NRC staff intends to run FRAPCON-3.4 (Reference 2) benchmark calculationsof the resident CE 16x16 fuel rod design and the new AREVA HTP fuel rod design.Please provide the following input for both co-resident fuels at SONGS, Units 2 and3.A. Rod Power History, KW/ft as a function of GWd/MTU1. Bounding thermal-mechanical operating envelope (e.g., radial falloff curve)2. Discuss any application of rod power uncertainties3. Include power histories for different pellet designs (UO2, Gadolinium).B. Axial Power Distribution (Fz at each axial node)1. Include axial power distributions (AXPDs) for different axial blanket configurations.C. Fuel Rod Design Specifications and Manufacturing Tolerances1. Outer diameter2. Inside diameter3. Pellet diameter4. Stack length5. Plenum length6. Pellet height7. Dish radius8. Dish depth9. Spring outside diameter10. Spring wire diameter11. Number of spring turns12. Maximum U-235 enrichment (%)13. Average U-235 enrichment (%)14. Maximum gadolinia content (%)15. Water in pellet (ppm)16. Nitrogen in pellet (ppm)17. Pellet density (%TD)18. Open porosity (%)19. Pellet surface roughness (microns)20. Expected density increase (gms/cc)21. Sintering temperature (OF)22. Cladding Alloy = (Material name)23. Final thermal treatment = (RXA or ?)24. Cladding surface roughness (microns)25. Cladding texture factor26. Cladding Hydrogen content (ppm)27. Fill gas pressure28. Fill gas composition

29. Rate of CRUD accumulation factor (mils/hr)30. CRUD thermal conductivityD. Coolant conditions1. Coolant inlet temperature (OF)2. Coolant mass flux (Ibm/hr-ft2)3. System pressure (psia)RESPONSE:A Rod Power History, KW/ft as a function of GWd/MTU1. Bounding thermal-mechanical operating envelope (e.g., radial falloff curve)[2. Discuss any application of rod power uncertaintiesThe rod power uncertainties are applied directly in the FATES3B analysis. No additionaluncertainties are applied to the values presented here.

3. Include power histories for different pellet designs (U02, Gadolinium).As discussed above Table 1 contains a bounding power history for a standard U02 rod,and Table 2 contains a bounding power history for a Gadolinia rod.Table 1: Composite U02Fuel RodBurnup Steady-State Steady-State Transient TransientGWd/MTU Radial Fall-off Rod Average Radial Fall-off Power, kW/ftPower, kW/ft[[________________________ ________________________ ________________________ ________________________+ i i i1- 4 t4 I. 4 4I- 4 4 +I 4 4 4I 4 4 +4 + 4 44 + *14 4 4 44 4 4 44 4 4 44 4 4 41 1 Table 1: Composite U02 Fuel RodBurnup Steady-State teady-State Transient TransientGWd/MTU Radial Fall-off Rod Average Radial Fall-off Power, kW/ftPower, kW/ft+ + + ++/- 4- 4- F4- + 4- F+ 4- -F F-I- F F F4- F F F4- F F FF + F FF t F FF F F FF F F FTable 2: Composite Gadolinia Fuel Rod[Burnup Steady-State Steady-State Transient TransientGwd/MTU Radial Fall-off Rod Average Radial Fall-off Power, kW/ftwd/MURadalFal-o_ Power, kW/ft[[_____________________ _____________________ _____________________ __________________________ I _____ I _____ I _____ I _____

Table 2: Composite Gadolinia Fuel Rod[Burnup Steady-State Steady-State Transient TransientGwd/MTU Radial Fall-off Rod Average Radial Fall-off Power, kW/ftPower, kW/ft+ 4 4+ 4 4 4-I- F 4 4+ 4 4 4-I- 4 4 4I. 4 + 4I. + 4 44* + + +4 4 4 -4t .4 4 44 4 4 44 4 4 44 4 4 .44 4 4 .4IB Axial Power Distribution (Fz at each axial node)1. Include axial power distributions (AXPDs) for different axial blanket configurations.[ I Table 3: Steady-State PowerDistribution% Core Height Normalized Axial% CoreHeight Shape (Fz)iiiI Table 4: Transient PowerDistribution% Coe Heght Normalized Axial% Core Height Shape (Fz)[I________________________iiiiiI C Fuel Rod Design Specifications and Manufacturing TolerancesTable 5: Fuel Rod Design Specifications and ManufacturingTolerancesFuel Rod Design Parameter CE 16X16 AREVA HTPSpecification and Specification andManufacturing ManufacturingTolerance Tolerance1. Outer Diameter, in2. Inside Diameter, in3. Pellet Diameter, in4. Stack Height, in5. Plenum Length, in6. Pellet Height, in7. Dish Radius, in8. Dish Depth, in9. Spring Outside Diameter, in10. Spring Wire Diameter, in11. Number of Spring Turns12. Maximum U-235enrichment, %13. Average U-235enrichment, %14. Maximum gadoliniacontent, %15. Water in pellet, ppm16. Nitrogen in pellet, ppm17. Pellet Density, %TD18. Open Porosity, %19. Pellet Surface roughness,micro-inches (arithmeticaverage)20. Expected density increase,gms/cc21. Sintering temperature, 'F Table 5: Fuel Rod Design Specifications and ManufacturingTolerancesFuel Rod Design Parameter CE 16X16 AREVA HTPSpecification and Specification andManufacturing ManufacturingTolerance Tolerance22. Cladding Alloy23. Final thermal treatment24. Cladding surfaceroughness, micro-inches(arithmetic-average)25. Cladding texture factor26. Cladding Hydrogencontent, ppm27. Fill gas pressure, psig28. Fill gas 29. Rate of CRUDAccumulation factor, mils/hr30. CRUD thermal conductivity31. Fuel rod pitch, inT#-[I*_[] For the purposes of producing the plots in Figures 1 and 2, FRAPCON code defaultvalues were used (see NUREG/CR-7022, Vol. 1).-Fuel rod pitch is being included in the list of provided parameters because it is a required inputfor running FRAPCON 3.4. D Coolant conditionsTable 6: Coolant ConditionsCoolant Parameter ValueCoolant Inlet Temperature, 'F 550Coolant Mass Flux, Ibm/hr-ft2 2.6333E+06System Pressure, psia 2250Additional DiscussionAs discussed throughout NUREG/CR-7022, Vol. 1 (FRAPCON-3.4: A Computer Code for theCalculation of Steady-State Thermal-Mechanical Behavior of Oxide Fuel Rods for High Burnup),"FRAPCON-3 is an analytical tool that calculates LWR fuel rod behavior when power andboundary condition changes are sufficiently slow for the term "steady-state" to apply. Thisincludes situations such as long periods at constant power and slow power ramps that aretypical of normal power reactor operations." FRAPCON-3 itself is described in Section 3.3.3 as"a best-estimate fuel performance code." To that end, several modules (e.g., conduction throughpoints of contact, fuel relocation, and fuel rod gas release) are described in detail as "best-estimate." It should be noted in Section 1.2, Limitations of FRAPCON-3, that the code isintended for long-term, steady-state operation and not recommended for rapid powermaneuvers or transients. Therefore, to obtain results consistent with long-term operation of afuel rod, no rapid power changes should be performed and the fuel rod should be modeled as itis expected to be operated (e.g., at a representative long-term power level).SCE has generated FRAPCON 3.4 runs to model fuel rod behavior of both the existing CE16x16 standard design and the proposed AREVA HTP 16x16 design and made comparisons todata present in PCN-600, Section 4.3.Figure 1 is a modified version of PCN-600 Figure 4.3.6 showing fuel average temperaturesI ISimilarly, Figure 2 is a modified version of PCN-600 Figure 4.3.8 showing rod internal pressurecomparisons.1. Figure 1Fuel Average Temperature ComparisonI Figure 2Rod Internal Pressure ComparisonI }}