ML12275A418

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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  Southern California Edison icon.png
Issue date: 09/27/2012
From: St.Onge R
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)
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{{#Wiki_filter:Richard 1. St. Onge SOUTHERN CALIFORNIA 

                                &   DDirector,                                              Nuclear Regulatory Affairs and
       . ED ISO N An EDISON INTERNATIONAL Company Emergency Planning Request to Withhold from Public Disclosure Under 10 CFR 2.390(a)(4) and (6)

September 27, 2012 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket Nos. 50-361 and 50-362 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 (TAC Nos. ME6820, ME6821, ME6822, AND ME6823) San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

Letter from N. Kalyanam (NRC) to P. T. Dietrich (SCE) dated August 1, 2012;

Subject:

San Onofre Nuclear Generating Station, Units 2 and 3 License 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 Request for Additional Information (RAI) regarding use of unrestricted usage of AREVA fuel and permanent exemption to use M5 cladding. The RAI letter requested a response within 30 days of receipt of the letter. NRC staff agreed by phone on September 4, 2012, that SCE may submit the response by September 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 in accordance with 10 CFR 2.390(a)(4). Enclosure 1 provides notarized affidavits from SCE and AREVA which set forth the basis on which the information in Enclosure 2 may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed by paragraph (b)(4) of 10 CFR 2.390. Enclosure 3 provides the non-proprietary version of Enclosure 2. Notice: This document is decontrolled when separated from Enclosure 2 P.O. Box 128 San Clemente, CA 92672 Pýo 00L

Document Control Desk September 27, 2012 Request 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 any questions or require additional information, please contact Ms. Linda T. Conklin, Licensing Manager, at (949) 368-9443. Sincerely, f41K

Enclosures:

1. Notarized Affidavits Proprietary Enclosures
2. Response to Request for Additional Information (RAI) Question 11 regarding use of unrestricted usage of AREVA fuel and permanent exemption to use M5 cladding Non-Proprietary Enclosures
3. Response to Request for Additional Information (RAI) Question 11 regarding use of unrestricted usage of AREVA fuel and permanent exemption to use M5 cladding cc: E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 Notice: This document is decontrolled when separated from Enclosure-2.

ENCLOSURE 1 NOTARIZED AFFIDAVITS

AFFIDAVIT STATE OF CALIFORNIA ) 

                        ) SS.

CITY OF SAN CLEMENTE)

1. My name is Owen J. Thomsen. I am employed by Southern California Edison Company ("SCE"). My present capacity is Manager, Nuclear Fuel Management, for the San Onofre Nuclear Generating Station ("SONGS"), and in that capacity I am authorized to execute this Affidavit.
2. SCE is the operating agent for SONGS. I am familiar with the policies established by SCE to determine whether certain SCE information is proprietary and confidential, and to ensure the proper application of these policies.
3. I am familiar with SCE information in the document entitled "San Onofre Nuclear Generating Station, Units 2 and 3, Proposed Permanent Exemption Request and Proposed Change Number (PCN) 600, Amendment Application Numbers 261 and 247, Request for Unrestricted Use of AREVA Fuel," (referred to herein as "Document") submitted to the NRC in July 2011.
4. SCE has classified the information contained in the Document as proprietary and confidential in accordance with SCE's policies.
5. Specifically, SCE applied the following criteria to determine that the information 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 AREVA have provided to SCE certain proprietary and confidential information contained in the Document.

(b) The information reveals details of Westinghouse's, SCE's, and/or AREVA's research and development plans and programs, or the results of these plans and programs. (c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive commercial 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 competitive commercial advantage for Westinghouse, SCE, and/or AREVA on product optimization 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 significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service. (f) The information contained in the Document is vital to a competitive commercial advantage held by Westinghouse, SCE, and/or AREVA, would be helpful to their competitors, and would likely cause substantial harm to the competitive position of Westinghouse, SCE, and AREVA.

6. The information contained in the Document is considered proprietary and confidential for the reasons set forth in Paragraph 5. In addition, the information contained in the Document 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 am aware that other companies also regard the type of information contained in the Document as proprietary and confidential.
7. In accordance with the Westinghouse-AREVA-SCE NDA, the Document has been made available to the NRC in confidence, with the request that the information contained in this Document be withheld from public disclosure. The request for withholding the information from public disclosure is made in accordance with 10 CFR 2.390. The information qualifies for withholding from public disclosure under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
8. In accordance with SCE's policies governing the protection and control of proprietary and confidential information, the information contained in the Document has been made available, on a limited basis, to others outside Westinghouse, SCE and AREVA only as required in accordance with the Westinghouse-AREVA-SCE NDA.
9. SCE's policies require that proprietary and confidential information be kept in a secured file or area and distributed on a need-to-know basis. The information contained in the Document 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 declare under penalty of perjury under the laws of the State of California that the above is true and correct.

ow/en'j. 1Thomsen lbebact aNdN wa (Or O*UW4 SUBSCRIBED before me this day of 2011. pwedte me onofZu..eIk tobedsm" ftw6 fiý NOTARY PUBLIC, STATE OF CALIFORNIA MY COMMISSION EXPIRES: TRUPTI TRIVEDI Reg. #: Commission # 1936996 

                                                                     -Notary          Public - California Orange County My Comm. EKpires Jun 14, 2015

AFFIDAVIT COMMONWEALTH OF VIRGINIA ) 

                                               ) ss.

COUNTY OF CAMPBELL )

1. My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVA NP 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 whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
3. I am familiar with the AREVA NP information contained in a letter from Rick Williamson (AREVA NP) to Owen Thomsen (Southern California Edison) with subject "Proposed Response 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 this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.
4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld 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 is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA NP's research and development plans and programs or their results. (b) Use of the information by a competitor would permit the competitor to significantly 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 a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(c) above.

7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
8. AREVA NP policy requires that proprietary information be kept in a secured file 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 this day of 2. Kathleen A. Bennett NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 8/31/2015 Reg. #110864 KATHLEEN ANN BENNETT Notuy Public Commanwealth of Virgifla My COmmMs8oln Expires Aug 31, 2015

ENCLOSURE 3 Response to Request for Additional Information (RAI) Question 11 regarding use of unrestricted usage of AREVA fuel and permanent exemption to use M5 cladding (Non-Proprietary)

RAI #11 The NRC staff intends to run FRAPCON-3.4 (Reference 2) benchmark calculations of 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 and 3. A. Rod Power History, KW/ft as a function of GWd/MTU

1. Bounding thermal-mechanical operating envelope (e.g., radial falloff curve)
2. Discuss any application of rod power uncertainties
3. 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 Tolerances

1. Outer diameter
2. Inside diameter
3. Pellet diameter
4. Stack length
5. Plenum length
6. Pellet height
7. Dish radius
8. Dish depth
9. Spring outside diameter
10. Spring wire diameter
11. Number of spring turns
12. 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 factor
26. Cladding Hydrogen content (ppm)
27. Fill gas pressure
28. Fill gas composition
29. Rate of CRUD accumulation factor (mils/hr)
30. CRUD thermal conductivity D. Coolant conditions
1. Coolant inlet temperature (OF)
2. Coolant mass flux (Ibm/hr-ft 2 )
3. System pressure (psia)

RESPONSE

A Rod Power History, KW/ft as a function of GWd/MTU

1. Bounding thermal-mechanical operating envelope (e.g., radial falloff curve)

[

2. Discuss any application of rod power uncertainties The rod power uncertainties are applied directly in the FATES3B analysis. No additional uncertainties are applied to the values presented here.
3. Include power histories for different pellet designs (U0 2 , Gadolinium).

As discussed above Table 1 contains a bounding power history for a standard U0 2 rod, and Table 2 contains a bounding power history for a Gadolinia rod. Table 1: Composite U0 2 Fuel Rod Burnup Steady-State Steady-State Transient Transient GWd/MTU Radial Fall-off Rod Average Radial Fall-off Power, kW/ft Power, kW/ft [[________________________ ________________________ ________________________ ________________________ 

                +                   i                           i                        i 1-                                              4                        t 4                  I.                         4                         4 I-                 4                          4                         +

I 4 4 4 I 4 4 + 4 + 4 4 4 + *1 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 1 1

Table 1: Composite U0 2 Fuel Rod Burnup Steady-State teady-State Transient Transient GWd/MTU Radial Fall-off Rod Average Radial Fall-off Power, kW/ft Power, kW/ft 

                  +                      +                         +                        +
                  +/-                      4-                        4-                        F 4-                     +                         4-                        F
                  +                      4-                        -F                        F
                  -I-                     F                         F                        F 4-                      F                         F                        F 4-                      F                         F                        F F                      +                         F                        F F                      t                         F                        F F                      F                         F                        F F                      F                         F                        F Table 2: Composite Gadolinia Fuel Rod

[Burnup Steady-State Steady-State Transient Transient Gwd/MTU Radial Fall-off Rod Average Radial Fall-off Power, kW/ft wd/MURadalFal-o_ Power, kW/ft [[_____________________ _____________________ _____________________ _____________________ _____ I _____ I _____ I _____ I _____

Table 2: Composite Gadolinia Fuel Rod [Burnup Steady-State Steady-State Transient Transient Gwd/MTU Radial Fall-off Rod Average Power, Radial Fall-off Power, kW/ft kW/ft 

                 +                   4                                    4
                 +                   4                 4                  4
                 -I-                 F                 4                  4
                 +                   4                 4                  4
                 -I-                 4                 4                  4 I.                 4                 +                  4 I.                 +                 4                  4 4*                 +                 +                  +

4 4 4 -4 t .4 4 4 4 4 4 4 4 4 4 4 4 4 4 .4 4 4 4 .4 I B Axial Power Distribution (Fz at each axial node)

1. Include axial power distributions (AXPDs) for different axial blanket configurations.

[

I Table 3: Steady-State Power Distribution % Core% Height CoreHeight Normalized Axial Shape (Fz) i i i I

Table 4: Transient Power Distribution Heght 

   % Coe          Normalized Axial

% Core Height Shape (Fz) [I________________________ i i i i i I

C Fuel Rod Design Specifications and Manufacturing Tolerances Table 5: Fuel Rod Design Specifications and Manufacturing Tolerances Fuel Rod Design Parameter CE 16X16 AREVA HTP Specification and Specification and Manufacturing Manufacturing Tolerance Tolerance

1. Outer Diameter, in
2. Inside Diameter, in
3. Pellet Diameter, in
4. Stack Height, in
5. Plenum Length, in
6. Pellet Height, in
7. Dish Radius, in
8. Dish Depth, in
9. Spring Outside Diameter, in
10. Spring Wire Diameter, in
11. Number of Spring Turns
12. 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, micro-inches (arithmetic average)
20. Expected density increase, gms/cc
21. Sintering temperature, 'F

Table 5: Fuel Rod Design Specifications and Manufacturing Tolerances Fuel Rod Design Parameter CE 16X16 AREVA HTP Specification and Specification and Manufacturing Manufacturing Tolerance Tolerance

22. Cladding Alloy
23. Final thermal treatment
24. Cladding surface roughness, micro-inches (arithmetic-average)
25. Cladding texture factor
26. Cladding Hydrogen content, ppm
27. Fill gas pressure, psig
28. Fill gas composition*
29. Rate of CRUD Accumulation factor, mils/hr
30. CRUD thermal conductivity
31. Fuel rod pitch, inT
  1. -[

I

  • _[
          ] For the purposes of producing the plots in Figures 1 and 2, FRAPCON code default values 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 input for running FRAPCON 3.4.

D Coolant conditions Table 6: Coolant Conditions Coolant Parameter Value Coolant Inlet Temperature, 'F 550 Coolant Mass Flux, Ibm/hr-ft2 2.6333E+06 System Pressure, psia 2250 Additional Discussion As discussed throughout NUREG/CR-7022, Vol. 1 (FRAPCON-3.4: A Computer Code for the Calculation 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 and boundary condition changes are sufficiently slow for the term "steady-state" to apply. This includes situations such as long periods at constant power and slow power ramps that are typical 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 through points 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 is intended for long-term, steady-state operation and not recommended for rapid power maneuvers or transients. Therefore, to obtain results consistent with long-term operation of a fuel rod, no rapid power changes should be performed and the fuel rod should be modeled as it is 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 CE 16x16 standard design and the proposed AREVA HTP 16x16 design and made comparisons to data present in PCN-600, Section 4.3. Figure 1 is a modified version of PCN-600 Figure 4.3.6 showing fuel average temperatures I

I Similarly, Figure 2 is a modified version of PCN-600 Figure 4.3.8 showing rod internal pressure comparisons. 1.

Figure 1 Fuel Average Temperature Comparison I

Figure 2 Rod Internal Pressure Comparison I}}

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