ML14027A707

Comanche Peak, Units 1 & 2, Response to Requests for Additional Information Round 2, on License Amendment Request (LAR) 13-01 Spent Fuel Pool Criticality Analysis, (TAC Nos. MF1365 and MF1366)

ML14027A707
Person / Time
Site:	Comanche Peak
Issue date:	12/17/2013
From:	McCool T P Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14028A551	List: CP-201301411, Response to Requests for Additional Information Round 2, on License Amendment Request (LAR) 13-01 Spent Fuel Pool Criticality Analysis, ML14027A705
References
CAW-13-3866, CP-201301411, LAR 13-01, TAC MF1365, TAC MF1366, TXX-13182
Download: ML14027A707 (12)

Text

Rafael Flores Luminant PowerSenior Vice President P 0 Box 1002& Chief Nuclear Officer 6322 North FM 56rafael.flores@Luminant.com Glen Rose, TX 76043LuminantT 254 897 5590C 817 559 0403F 254 897 6652REF: 10CFR50.90CP-201301411TXX-13182December 17, 2013U. S. Nuclear Regulatory Conm-issionATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)DOCKET NOS. 50-445 AND 50-446LICENSE AMENDMENT REQUEST (LAR) 13-01 SPENT FUEL POOL CRITICALITYANALYSIS, RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION ROUND 2(TAC NOS. MF1365 AND MF1366)REFERENCE: 1. Letter logged TXX-13045, dated March 28, 2013, License Amendment Request(LAR) 13-01, Revision to Technical Specifications 3.7.16, "FUEL STORAGE POOLBORON CONCENTRATION," 3.7.17, "SPENT FUEL ASSEMBLY STORAGE," 4.3,"FUEL STORAGE," and 5.5 "PROGRAMS AND MANUALS" (ML 13095A023)2. Letter logged TXX-13109, dated July 16, 2013, "Supplemental Informationsupporting LAR 13-01, Spent Fuel Pool Criticality Analysis" (ML 13205A056)3. Letter logged TXX-13169, dated November 26, 2013, "Supplemental Informationsupporting LAR 13-01, Spent Fuel Pool Criticality Analysis" (ML 13317B703)4. Letter dated November 19, 2013, from Balwant Singal of the NRC to Rafael Flores ofLuminant Power, RE: Request for Additional Information Round 2 (ML 13317B703)

Dear Sir or Madam:

In March 2013, Luminant Generation Company LLC (Luminant Power) submitted a License AmendmentRequest (LAR) 13-01 (Reference 1, as supplemented by Reference 2 and the response to Requests forAdditional Information in Reference 3) to the NRC for Facility Operating License Nos. NPF-87 and NPF-89 for Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2, respectively. This LAR proposes achange to the CPNPP, Units 1 and 2, Technical Specifications based on an updated criticality analysismethodology for the spent fuel pools.A member of the STARS AllianceCallaway

• Comanche Peak -Diablo Canyon .Palo Verde

• South Texas Project

• Wolf CreekSpAv ~ aA U. S. Nuclear Regulatory CommissionTXX-13182Page 2 of 412/17/2013Per Reference 4, the U.S. Nuclear Regulatory Commission (NRC) staff has requested additionalinformation (RAI), regarding the LAR, be submitted in order to complete its review. Attachment 1 to thisletter is the proprietary version of Luminant Power's response to the RAIs. Attachment 2 provides a non-proprietary version of Lumninant Power's response to the RAIs.Also enclosed is the Westinghouse Application for Withholding Proprietary Information fromPublic Disclosure CAW-13-3866, accompanying Affidavit, Proprietary Information Notice, andCopyright Notice.As Attachment I contains information proprietary to Westinghouse Electric Company LLC, it issupported by an affidavit signed by Westinghouse, the owner of the information. The affidavitsets forth the basis on which the information may be withheld from public disclosure by theCommission and addresses with specificity the considerations listed in paragraph (b)(4) ofSection 2.390 of the Commission's regulations.Accordingly, it is respectfully requested that the information which is proprietary toWestinghouse be withheld from public disclosure in accordance with 10CFR Section 2.390 of theCommission's regulations.Correspondence with respect to the copyright or proprietary aspects of the items listed above orthe supporting Westinghouse affidavit should reference CAW-13-3866 and should be addressedto James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite310, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.In accordance with 10CFR50.91(b), Luminant Power is providing the State of Texas with a copyof this proposed amendment.Attachment 1 of Reference 1, Description and Assessment, which addresses the nosignificance hazards consideration standards set forth in 10CFR50.92, remains valid and doesnot require change.This communication contains the following new commitments regarding Comanche Peak Units 1 and 2.Commitment No. Description4760732 Current and future fuel assemblies will use a Wet Annular Burnable Absorber(WABA) which is no more than 120 inches in length and 95/95 Upper Bound fueltheoretical density (%TD) will be < 96.5%. Future fuel cycles will utilize a MaximumInlet Temperature of _< 561.7 degrees F. If these parameters are not met, the fuelassemblies will be treated as fresh fuel for storage in the Spent Fuel Pools.4760737 CPNPP will review the calculated B-10 concentration in the RCS each refuelingoutage (after borating to >2400 ppm, but not including the fill of the RefuelingCavity). If the calculated value is below 0.194 atom fraction, a B-10 measurement willbe performed on the Spent Fuel Pool after adequate mixing time has occurred, butprior to the next refueling outage to ensure the B-10 value in the SFP has notsignificantly changed.

U. S. Nuclear Regulatory CommissionTXX-13182Page 3 of 412/17/20134760738 CPNPP will review the SFP Boron Measurement history each refueling outage. If theSFP boron values have experienced any increase of more than 100 ppm, a review of B-10 values for Boric Acid purchased at CPNPP will be performed. If this reviewdemonstrates that boric acid has been purchased which has a B-10 atom fractionbelow 0.194, a B-10 measurement will be performed on the Spent Fuel Pool prior tothe next refueling outage to ensure the B-10 value in the SFP has not significantlychanged.4760741 For fuel assemblies which are classified as outlier assemblies solely due to Hot FullPower (HFP) Rodded Operation, burnup which is accrued during lITFP roddedconditions will not be credited in the Technical Specification Surveillance, but allother burnup accrued during the cycle will be credited. The administrative controlsand Configuration Confirmation Software tools described in Enclosure 1 of LAR 13-01will incorporate limitations to ensure that the appropriate burnup is credited for fuelassemblies which have experienced HFP Rodded Operation beyond the lowthreshold required by the area of applicability.Should you have any questions, please contact Mr. J. D. Seawright at (254) 897-0140.I state under penalty of perjury that the foregoing is true and correct.Executed on December 17, 2013.Sincerely,Luminant Generation Company LLCRafael FloresBy:Thomas P. McCoolVice President, Station Support U. S. Nuclear Regulatory CommissionTXX-1 3182Page 4 of 412/17/2013Attachments: 1. Comanche Peak Responses to LAR 13-01 Request for Additional Information (RAI) -Round 2 (Proprietary)2. Comanche Peak Responses to LAR 13-01 Request for Additional Information (RAI) -Round 2 (Non-Proprietary)

Enclosure:

Westinghouse Application for Withholding Proprietary Information from Public DisclosureCAW- 13-3866, accompanying Affidavit, Proprietary Information Notice, and CopyrightNoticec -Marc L. Dapas, Region IV (w/o Attachment 1)Balwant K. Singal, NRRBartlett, Mathew NRRResident Inspectors, Comanche Peak (w/o Attachment 1)Mr. Robert Free (w/o Attachment 1)Environmental Monitoring & Emergency Response ManagerTexas Department of State Health ServicesMail Code 1986P. 0. Box 149347Austin, Texas 78714-9347 Enclosure to TXX- 13182

( Westinghouse Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 720-075411555 Rockville Pike e-mail: greshaja@westinghouse.comRockville, MD 20852 Proj letter: NF-TB-13-119CAW-13-3866December 10, 2013APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject:

CE- 13-809, Attachment 1, "Westinghouse Suggested Responses to the NRC Requests forAdditional Information (RAI) on the Comanche Peak Nuclear Power Plant Units I and 2 SpentFuel Pool License Amendment Request." (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-13-3866 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Luminant GenerationCompany LLC.Correspondence with respect to the proprietary aspects of the application for withholding or theWestinghouse Affidavit should reference CAW-] 3-3866, and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,arraes A.Gresham, ManagerRegulatory ComplianceEnclosures CAW-13-3866AFFIDAVITCOMMONWEALTtt OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared James A. Gresham, who, being by meduly sworn according to law, deposes and says that lie is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief.James A. Gresham, ManagerRegulatory ComplianceSworn to and subscribed before methis 10th day of December 2013Notary Public14ýCOMMONWEALTH OF PENNSYLVANIANotarial SealAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commission Expires Aug. 7, 2016MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2 CAW-1 3-3866(1) 1 am Manager, Regulatory Compliance, in Engineering, Equipment and Major Projects,Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specificallydelegated the function of reviewing the proprietary information sought to be withheld from publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amnauthorized 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 theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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 theinformation sought to be withheld firom public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been heldin confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe 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 inconfidence. The application of that system and the substance of that system constitutesWestinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 ofWestinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.

3CAW- 13-3866(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(c) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one component 4CAW-1 3-3866may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2.390, it is to be received in confidence by theCommission.(v) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in CE- 13-809, Attachment 1, "Westinghouse Suggested Responsesto the NRC Requests for Additional Information (RAI) on the Comanche Peak NuclearPower Plant Units I and 2 Spent Fuel Pool License Amendment Request." (Proprietary),for submittal to the Commission, being transmitted by Luminant Generation CompanyLLC letter and Application for Withholding Proprietary Information from PublicDisclosure, to the Document Control Desk. The proprietary information as submitted byWestinghouse is that associated with Westinghouse's request for NRC approval ofWCAP-1 7728, Revision 1, and may be used only for that purpose.

55CAW-l 3-3866(a) This information is part of that which will enable Westinghouse to:(i) Obtain NRC approval of WCAP- I 7728-P, Revision 1, "Comanche PeakNuclear Power Plant Units I and 2 Spent Fuel Pool Criticality SafetyAnalysis."(ii) Demonstrate the sub-criticality of the Comanche Peak spent fuel pools.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of the information to its customers forthe purpose of demonstrating the sub-criticality of the spent fuel pool.(ii) Westinghouse can sell support and defense of spent fuel pool criticalityanalysis.(iii) The information requested to be withheld reveals the distinguishingaspects of a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary informnation has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).COPYRIGHT NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal use in connection with generic and plant-specific reviews and approvals as well as the issuance,denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license,permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.