ML20058N814

Requests That Proprietary WCAP-11953, Safety Evaluation Supporting More Negative Eol Moderator Temp Coefficient Tech Spec for Joseph M Farley Nuclear Plant Units 1 & 2, Be Withheld Per 10CFR2.790

ML20058N814
Person / Time
Site:	Farley
Issue date:	01/09/1989
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML19298E400	List: ML20058N808 ML20058N811 ML20058N814 ML20058N818
References
CAW-89-003, CAW-89-3, NUDOCS 9008150142
Download: ML20058N814 (13)

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Westinghouse Energy Systems wucw enawinc o Electric Corporation *****

Nrsn Pennsytma 152300355 Janua:y 9, 1989 CAW 89-003-Dr. Thomas Murley, Director Office of Nyclear Reector Regulation U.S. Nuclear Regulc w ? Commission Washington, D.C. fPt APPLICATIONFORWIOOLDING' PROPRIETARY.

INFORMATION FRON ' /BLIC DISCLOSURE

Subject:

. Transmittal of WCAP's-11953/11954 entitled " Safety Evaluation-Sup>orting a More Negative EOL Moderator Temperature Coefficient Tecinical Specification for the Joseph M. Farley Nuclear Plant Units 1 and 2

Dear Dr. Murley:

The propritisry information for which withholding is being requested in.the-enclosed letter by Alabama Power Company is further identified in Affidavit CAW 89 003 signed by the owner of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this-letter, sets forth the basis on which the information^may be . withheld;from public. disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of 10CFR Section 2.790 of the Commission's regulations.

Accordingly, this letter authorizes the. utilization =of the accompanying affidavit by Alabama Power Company.

Correspondence with respect to the proprietary aspects of the-application for withholding or the Westinghouse affidavit should reference this letter, CAW 839-003, and should be addressed to the undersigned.

.Very truly yours, WE TINGHOUSE ELECTRIC CORPORATION Robert A. Wiesemann, Manager

- Regulatory & Legislative Affairs i

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Enclosures cc: E. C. Shomaker, Esq.

Office of the General Counsel, NRC t 9008150142 900713 gDR ADOCK 03000348

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, , CAW 89 0031-AFFIDAVIT-COMMONWEALTH OF PENNSYLVANIA:  !

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COUNTY OF ALLEGHENY:

i Before me, . the undersigned authority, personally appeared '

Robert A. Wiesemann, who, being by me duly sworn according to law, l

deposes and says that he is ~ authorized to-execute this Affidavit on a behalf of WestinghousJ Electric Corporation (" 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:

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-I HYLh1Lanii i

Robert-A'. Wiesemann, Manager  !

Regulatory and' legislative Affairs j,

1 Sworn to and ,- a n6 before me thi.- ._.

of hu A ,1988.

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&&%1. f4 Notary Public NOTARIAL SEAL Lo8lRA!NE M. PiPLCA, NOTARY PUBLIC MONROEVELE ECRO. ALLEGHEHf CoutlTY

- MYCOMM:SSCN EXPIRES DEC 14.1731 Member.Pr.vsyfva aa Am%hc!Nv,yas

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,. CAW-89 003 l -(1) I am Manager, Regulatory and Legislative Affairs, in the- Nuclear and Advanced Technology Division, of the Westinghouse Electric l Corporation and as such, I~have 1.9en-specifically delegated the.

function of reviewleg the proprietary information sought to be l withheld fra pdaic disclosure in connection with nuclear power plant Menden and rulemaking proceedings, and am authorized to apply for its withholding on bad!f of the Westinghouse Energy Systems, Nuclear Fuel, and Power Generation Business Units, i (2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding  !

I accompanying this Affidavit. -

L (3) I have personal knowledge of the criteria.and procedures utilized by the Westinghouse Energy Systems, Nuclear Fuel, and Power Generation -

• Business Units in designating-information as a trade secret, privileged or as confidential commercial or financial-information.

(4) Pursuant to the provisions of paragraph (b)(4) o'f Section-2.790 of the Commission's regulations, the following_is furnished for .

consideration by the Commission in determining wheth'er.the t

information sought to be withheld from public disclosure should.be 1 withheld.

q (i) The information sought to be withheld from public disclosure. is l owned and has been held in confidence by Westinghouse, j l

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3.- CAW-89-003 (ii) The information is of a type customarily held-in confidence hy

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. '

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Under.that system, information is-held in confidence if it falls i in one or more of several types, the release of which might

_j result in the loss of an existing or potential competitive advantage, as follows: 4 1

(a)- The information reveals the. distinguishing aspects-of a process:(or component, structure, tool, method, etc.) where prevention of its'use by any,of Westinghouse's competitors-without license from Westinghouse. constitutes ~ a competitive I economic advantage over other companies.

(b) It consists of' supporting data, including test data, relativetoarprocess:(orcomponent, structure,' tool',

o method, etc.), the-application of.which data' secures a:

competitive economic advantage, e.g., by optimization or

, improved-marketability.

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= CAW-89-003 (c) Its use by a competitor would reduce his expenditure of l resources or improve his' competitive position-in the.

design, manufacture,: shipment, installation, assurance of l

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 futuri Westinghouse-or customer funded development: plans.and programs of' potential commercialvalue to Westinghouse.

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(f) It contains-patentable' ideas, for which patent- protection'  !

may be desirable. l I

(g) It is not the property of Westinghouse, but must be treated.

as proprietary by Westinghouse according'to agreements with-the owner.

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There are sound policy reasons behind the Westinghouse: system: i which include the following- I i

(a) The use of such information by Westinghouse gives::

Westinghouse.a competitive' advantage over its competitors.

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It is, therefore, withheld from disclosureito protect the i Westinghouse competitive position. ',

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c  : CAW-89-003 .

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(b) It is information which is: marketable in many ways.. The. I extent ~to which such information is.available to competitors diminishes thel West.inghouse ability to sell-products and services involving:the use of the information.

I (c) Use-by our competitor would put' Westinghouse ~at a competitive disadvantage'by reducing his expenditure ofl q resources at our expense; (d) Each component.of proprietary information pertinent to a' particular competitive. advantage .is potentially as valuable as the total' competitive advantage. If competitors l acquire:

components of proprietary infomation, any 'one component may be ~the key to the enti_re puzzle, thereby depriving:

Westinghouse of-a competitive advantage. I I

(e) Unrestricted disclosure' would-jeopardize the' position of prominence of Westinghouse in the world market,. and thereby give a market: advantage to theLeompetition of those countries.

l (f) .The Westinghouse capacity to invest: corporate assets in research and development depends upon the success in "

obtaining and maintaining a: competitive advantage.

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6-- CAW 89 003-

'(iii) The information is being transmitted to the Commission in 1 confidence-and,; under the provisions of 10CFR Section '

2.790, it is,to be received in confidence by the- l Commission. I (iv) The information. sought to be protected..is not available inL

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public sources or available information has not been l previously employed inLthe. same original manner or method  !

to' the best of our knowledge and belief. -

(v) The proprietary information sought to be withheld.in this, q submittal is that'which is appropriately marked.in

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" Safety Evaluaiton Supporting a More Negative E0L Moderator Temperature Coefficient Technical Specification' for the Joseph M. Farley Nuclear Plant Units 1 and 2," WCAP-Il953'

.(Proprietary) for J. M. Farley Nuclear Plant, Units 1 and' '

2, being transmitted by the Alabama Power Company (APCo) letter and Application for Withholding Proprietary i Information from Public Disclosure, W. G. Hairston,:III, l' APCo, to the Attention of Thomas Murley (NRC),_ Document Control Desk, January,1989. The proprietary information.

as submitted for use by Alabama Power Company for~the J. .M.

Farley Units 1 and 2 is expected to be applicable in~other' '

licensee submittals..in response to certain NRC requirements

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for , justification of a more: negative End'of Life Moderator

. Temperature Coefficient. '

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This information is part or that which will enable i~ Westinghouse to:

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l (a). Provide documentation of the analyses, methods-and I l conservatisms for reaching a conclusion relative to 'l reducing EOL.MFC Limitin'g Condition for Operation (LCO) and Surveillance Requirements (SR).- U i

(b) Identify benefits for the suspension of the Surveillance-Requirements below 100, ppm Boron

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(c) Establish the effects on the present safety analysis? !i with the More Negative MTC-conditions.-

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p (d) Establish temperature and pressure affects and RCCA' i Insertion. Limits for EOL MTC. '

(e) Assist customer to obtain NRC approval, ui L

Further this information has substantial commercial'value ,

as follows:- 1 t

(a) Westinghouse plans to sell the use of similar_ '!

information to its customers for purposes"of meeting 'I NRC requirements for licensing documentation. .

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1: 1 (b) -Westinghouse can sell support:and defense of the-(

L analyses to its customers in the' licensing process ~ .

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Pub 1tc disclosure;of this; proprietary..information is 'likely to cause+ substantial harm to the' competitive position of Westinghouse because-it would enhance the abi.lity of-competitors to provide similar analytical documentation-and-licensing defense: services for commercial power reactors-without commensurate expenses. Also, public disclosure of the information' would enable 'athers to use' the information to meet NRC requirements!for_ licensing documentation without purchasing the right to.use,the information.

The development of theitechnology described:in part' by the

.information is the result'of applying the results of many years of experience-in antintensive Westinghouse effort and i

the expenditure of a considerable ~ sum'of money.

In order for competitors of Westinghouse to duplicate this information,- similar technical programs would .haveL to be performed and a significant' manpower effort, having the r.9quisite-talent and experience, would have.to-be. expended-for developing the, analytical methods and approach.

Further the deponent sayeth not.

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ATTACBNENT 3 5-SIGNIFICAM HAZARDS CONSIDERATION EVALUATION PURSUAM T0'10 CFR 50.92 POR THE FROPOSED CBANGE TO THE END OF LIFE NODERATOR TENFERATURE COEFFICIENT TECHNICAL SPECIFICATION Proposed Change' The proposed Technical Specification changes vill revise the limit for the end-of-life (EOL) moderator temperature coefficient.(MTC).- Specifically,-

the proposed changes vill:

Change the-3.9 X 10',most delta negative k/k/'F to -4.3 XMTC 10' limitdelta frog k/k/*F (Technical Specification 3.1.1.3.b).

Change 1the'MTC surveillance requirement'from

-3.0 X 10' delta k/k/'F to -3.65 X 10' delta k/k/'F (Technical Specification 4.1.1.3.b)~.

Add a footnote to the MTC surveillance requirement which provides tor-suspension of MTC surveillance when the measured HTC at an equilibrium:

boron concentra} ion of less than or equal to 100 ppm is'less: negative.

than -4.0 X 10' delta k/k/*F (Technical Specification 4.1.1.3.b).

Revise associated Bases Section 3/4.1.1.3 to account for these_ changes.

Background

The use of 18-month cycles at Farley Nuclear Plant Units 1 and 2.has led to higher core average burnups.resulting in more negative end-of-life moderator temperature coefficients. The current Technical Specification.

3.1.1.3.b states "The mo negativethan-3.9X10'peratortemperaturecoefficient_(MTC)shallbe:less delta k/k/'F" (-39 pcm/'F) "for.the all rods withdrawn, end-of-cycle-life (EOL), RATED THERMAL' POWER condition.". The:

corresponding action for exceeding this limiting conditionLfor operation (LCO) is to'"be_in HOT SHUTDOWN vithin 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." In order to ensure that the LCO for the EOL MTC is met, the Technical Specification surveillance-requires that the MTC be measured within seven effective full power days of reaching an equilibrium boron This measurement must be compared to -3.0 X 10'joncentration delta k/k/*Fof(-30

.300pcm/'F) ppm.: at-the all-rods:

-l vithdrawn, rated thermal power condition. -If the measurement indicates that.the HTC is more negative than -30,pcm/*F, the MTC must be measured at least every 14 effective full power days (EFPD) ~ for the -remainder of! the cycle.

Recent Farley core designs have approached the -30 pcm/'F sbrveillance requirement.- It is anticipated that future EOL.MTC measurements may be>

more negative than -30 pcm/'F. When'the surveillance limit is exceeded, measurements must be performed every 14 EFPD. These. additional measurements are undesirable because they require that load svings be  :'

performed, perturbing the normal reactor operation. .In: addition, thousands-of1 gallons of additional water must be processed as.a result of boration-and dilution.

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Atttchmnt 3 P:ga 2 l

l In order to avoid future unnecessary EOL MTC measurements, Alabama Power Company proposes to change the EOL MTC surveillance limit to -36.5 pcm/'F i and to change the LCO to -43 pcm/'F. The proposed changes are made without impacting the safety analysis basis value.

1 The current LCO limit of -39 pcm/'F is based on EOL conditions (specifically with regard to fuel burnup and boron concentration), full power, with rods fully inserted. Most accident analyses use a constant moderator density coefficient (MDC) designed to bound the MDC at this vorst set of initial  !

conditions (as well as at the most limiting set of transient conditions).

This value for MDC forms the licensing basis for the PSAR accident analysis. The new value of -43 pcm/'F is based on calculational methods described in VCAP-11953 which assure that present safety analysis conditions are met while providing additional operating margin.

In addition, a change is proposed to surveillance requirement 4.1.1.3.b to allow for suspension of extended measurement once the equilibrium boron concentration falls below 100 ppm, provided the last measured value is los negative than -40 pcm/*F. This change is proposed-to eliminate unnecessary measurements which perturb reactor operation and generate large volumes of vaste water at low boron concentrations.

The value of -40 pcm/'F, belov which extended measurement may be suspended once the equilibrium boron concentration falls below 100 ppm, is set with  ;

due consideration for MTC behavior with boron concentration reduction and  ;

fuel depletion, to ensure that the proposed E0L (0 ppm) hot full power all rods withdrawn LCO value of -43 pcm/'F vill be met, even if no further measurement is conducted.

The -40 pcm/*F value was chosen such that if the proposed surveillance requirement value of -36.5 pcm/'F vas exceeded, and a subsequent measurement below a boron concentration of 100 ppm yielded a value less negative than -40 pcm/*F, the slope of the MTC versus burnup curve would be conservatively high enough to assure that the LC0 would not be exceeded.  ;

Analysis:

Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to this proposed Technical Specification change and considers the proposed change not to involve a significant hazards consideration. In support of this conclusion the following analysis is provided:

1) Operation of Farley Nuclear Plant Units 1 and 2 in accordance with the proposed license amendment does not involve a significant.

increase in the probability or consequences of an accident previously evaluated. The existing-safety analyses for Farley Nuclear Plant have been evaluated to determine potential impact of the proposed change to the E0L MTC limit. This evaluation demonstrates that the existing safety analyses input parameters conservatively envelop the proposed change to the E0L HTC limit and that the change to both the E0L MTC-'LC0 and the surveillance requirement are acceptable without any changes to the existing safety analyses assumptions.

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Attechnent 3 Pag 3-3' '

.i The effect on the Non-LOCA transients due to'alchange to the MTC

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vas evaluated both for-normal operation and; transient conditions and' n

even the most adverse conditions! vill not result in a reactivity insertion which would invalidate the conclusions presented'in the FSAR analysis. In addition, this change was found to show no effect-to the Large Break LOCA; the Small Break LOCA, and the Steam Generator Tube Rupture (SGTR) analyses.-

Therefore, the proposed license amendment,does not involve a significant' increase in the pro ability or consequences of an accident previously evaluated.

2) The proposed change vill not crea :e the possibility of a nev or different kind of accident from esy. accident previously evaluated' .,

because implementation of this change vill not. alter plant *'

configuration or mode of_ operation.- Implementation.of the' proposed license amendment vill provide continued assurance that_ analysis; assumptions conservatively enve3op operational parameters.-

As identified previously,.the chance to the E0L'MTC would.be bounded, by the present FSAR accident analys h. -(Both normal:and transient conditions were evaluated and the results were shown.to.be bounded by the current FSAR accident analyses.) The core design and '

emergency operating procedures vill assureithat suberiticality is maintained for the conditions encountered:during the recovery,even if an accident would occur.

The current safety analysis remains bounding and' valid-for.the new-conditions. No new accidents have been established with.the-modification of the MTC value and_the present accidents. analyzed can not degrade to a new failure mode. Sufficient margin is still.

present between the current safety analysis-limits'for'MTC and the '

actual operational-limits proposed with this Technical ~ Specification change. In addition, surveillance limits will be' maintained and' only suspended if the first measured HFP MTC measurement-taken after reaching 100 ppm HFP equilibrium: boron concentration is.less negative than -40 pcm/'F as this vill. provide' assurance that the s

ultimate EOL (0 ppm) HFP ARO MTC value vill,notiviolate the LCO limits.

Therefore, this change to the Technical Specifications does not create the possibility of a new or different. kind of accident from any accident previously evaluated.

3) The proposed license amendment does not involve a4significant reduction to a margin of safety because an evalua'tionJof the safety analyses demonstrates that the proposed change vill maintain adequate margin to the current safety analysis vhile achieving improved operability for Farley Nuclear. Plant Units 1 and 2. The

q At tchment 3 >

Pag) 4' D

7 evaluation discussed;in VCAP-11953 shows that'the safety analysis ~

assumption remains conservative with respect to_the proposed LCOs limit value of;-43 pcm/'F.' A11~ accidents are bounded by the present i FSAR and ru) nev' accidents have been created. :Therefore,.the ' ,. .

proposed change in the LCO-technical specification: limit from to -!

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>-43 pem/'F doesinot invalidate the conclusions of the FSAR' safety analyses and ample margin still exists between;the~ actual operating.

L MTC values and those used-in the safety analysis of record'.-' >

There ds no basis in the safety analyses for theisurveillancet a requirement limitivalue.a This limit.merely-provides early '

indication that the.LCOLis being approached.'. Implementation'of the' new surveillance requirement:value vill continue to provide adequate notice prior to reaching the LCO.= i The suspension of theisurveillance requirement below 100 ppm [*

provides additionalioperational flexibility while assuring-'

compliance with the Technical Specifications since exclusion would. ,

only be permitted-if the'first HFP MTC measurement:taken'after'

reaching the 100 ppm hot full power-equilibrium boron concentration

=is less negative than~-40 pcm/'F. Satisfaction of this: caveat ensures that the remainder of any given' cycle vill be operated-within the LCO value.

. . i Finally, prior to each reload all applicable safety limits are

' reviewed and any impact to the operating plant. margin noted.

.l Therefore, thisLehange does-not involve a significant reduction to the margin of: safety.

Conclusion i

Based upon the analysis'provided. herewith,nAlabama' Power-Company has. 1 determined that the proposed Technical Specification changetvill not t

, significantly increase the probability or consequences of.an accident. i h previously evaluatedn createL t he possibility of a nev'or.different kind of accident from any. accident.previously: evaluated, orl involve a"significant- '

reduction in a margin of~ safety. 'Therefore, Alabama' Power, Company has.

determined that the proposed, change meets the requirements of'10 CFR 50.92 j and:does not involve a significant hazards considerations.  !

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