ML17215A369

Nonproprietary Conservatism of Axial Shape Index DNB Limiting Condition for Operation Below 30% Power.

ML17215A369
Person / Time
Site:	Saint Lucie
Issue date:	04/30/1984
From:	ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:
Shared Package
ML17215A368	List: ML17215A367 ML17215A369
References
CEN-279(L)-NP, NUDOCS 8405070324
Download: ML17215A369 (15)

Text

ST. LUCIE 2 DOCKET 50-389 CEN-279(L) -NP Conservatism of the Axial Sha e Index DNB Limitin Condition for 0 eration Below 305 Power April 1984 COMBUSTION ENGINEERING, INC.

NUCLEAR POWER SYSTEMS POWER SYSTEMS GROUP WINDSOR, CONNECTICUT 06095 8405070324 840430 PDR ADOCK, 05000389 P PDR

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LEGAL NOTICE This report was prepared as an account of work sponsored by Combustion Engineering, Inc. Neither Combustion Engineering nor any person acting on its behalf:

A. Makes any warranty or representation, express or implied including the warranties of fitness for a particular purpose or merchantability, with respect to the accuracy, completeness, or usefullness of the information contained in this report, or that the use of any information, apparatus, method, or process disclosed in this. report may not infringe privately owned rights; or

8. Assumes any liabilities with respect to the use of, or for damages resulting from the use of, any information, apoaratus, method or process disclosed in this report.

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Conservati sm of the Axi al Sha e Index DNB-LCO Below 305 Power On Figure 1, the solid lines drawn in the shape of a tent represent the DNB LCO ASI vs power limits that St. Lucie Unit 2 must operate within during Cycle 1.

This tent is a conservative depiction of the actual calculated values forming the DNB LCO." i These calculated values were generated using computer runs by starting with the DNB SAFDL (which was 1.20 for Cycle 1) and then "backing off" as much as is necessary over each portion (positi ve and negative ASI) to assure that the limiting transient (eg. CEA drop, Loss of Flow) provides sufficient margin to the SAFDL when initiated from anywhere within the LCO space.

As can be seen from Figure 1, as ~ower level drops the axial shape index permitted the DNC LCO becomes Q by In the igure this f This was done for convenience in plotting only; in realty the Superimposed on this Figure is the local power density (LPD) LSSS for St. Lucie 2 Cycle 1. It can be seen from the figure that the installed LSSS for local

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power density becomes more restriciti ve than the DNB LCO, at approximately 77" power i.e.,

that,'onservativ'ely, the Q This fact provides the basis of the position SSS for LPD may be treated as more limiting than the DNB LCO below 3(5 power.

Below are listed selected values of overpower margin for different power levels and axial shape indices.

POWER ASI RODS OVERPOWER MARGIN 12K - 3 12'D IL 12$ ling PDIL 3(5 -.3 30'f. PDIL 3(5 3(5 PDIL 50$ ~ 3 50K PDIL 5(5 ~ 4 5P/. PDIL

110

(-.15,100)

(+.15, 100) 80 g

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LCO~

g 0 CALCULATEDDNB DNB LCO, TECHNICAL SPEC IF I CAT ION FIGURE 3.24 LOCAL POWER DENSITY TRIP SETPOINT, TECHNICAL SPECIFICATION FIGURE 2.2-2

-.6 -,4 -I2 0.0 .2 .4 .6 ASI FIGURE ST. LUCIE 2, CYCLE 1 - DNB LCO AND LOCAL POWER DENSITY TRIP vs ASI 1

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STATE OP PLORIDA COUNTY OP DADE J. W. Williams Jr. , being first duly sworn, deposes and says:

That he is a Vice President of Florida Power R Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

Enclosure 1 is proprietary, and therefore, exempt from public disclosure in accordance with Section 9.5 (4) of the NRC "Rules of Practice", Title 10, Code of Pederal Regulations, per Attachment 1 of the basic letter provided by Combustion Engineering, Inc.

J. W. Williams, Jr.

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Subscribed and sworn to before me this day of , 19~&

'OTARY PUBLIC, in and for the County

<of- Dade, State of Florida.

a ROTARY PUBLIC STATE OF FLORIOA HY COHNISSIOH EXP. FEB lf, IBBB BO!iOEO THRU GEHERAL IHS. UHO.

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AFFIOAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.

State of Connecti cut County of Hartford I, P. L. NcGill, depose and say that I am the Vice President, Commercial, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as I

proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations in conjunction with the application of Florida Power 5

'Light Company for withholding this information.

I The information for which proprietary treatment is sought is contairied in the fol 1 owi n g document:

CEN-279(L)-P, Conservatism of Axial Shape Index DNB Limiting Condition for Operation Below 305 Power, April 1984.

This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by.

Combustion Engineering in designating information as a trade'ecret, privileged or as confidential commercial or financial information.

Pursuant to the provi sions of paragraph (b ) (4) of Section 2.790 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, included in the above referenced document, shoul'd be withheld.

1. The information sought to be withheld from public disclosure are the values of thermal margin calculated for the reactor core and how these values can be translated into plant operational flexibility, which is owned and has been held in confidence by Combustion Engineering.

2. The information consists of test data or other similar data concerning a process, method or component, the application of which results in a substantial competitive advantage to Combustion Engineering.

3. The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to the public. Combustion Engineering 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 details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F.M. Stern to Frank Schroeder dated December 2, 1974. This system was applied in determining that the subject document herein are proprietary.

4. The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission.

5. The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

6. Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:

a. A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.

b. Development of this information by C-E required thousands of manhours and tens of thousands of dollars. To the best of my knowledge and belief a competitor would have to undergo similar expense in generating equi valent information.

c. In order. to acquire such information, a competitor would also require considerable time and inconvenience related to the calculation of similar thermal margin values and the translation of those values into plant operating flexibility.

d. The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.

Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable.

e. The information consists of values of thermal margin calculated for the reactor core and how these values can be translated into plant operational flexibility, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

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f. In pricing Combustion Engineeri'ng's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included.

The ability of Combustion Engineering's competitors to utilize such information without similar expen'diture of resources may enable them to sell at prices reflecting significantly lower costs.

g. Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with thei r technology development. In addition, disclosure would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

P. L. NcGill Yice President Commercial Sworn to before me this ~~" day* of April /9$+

N ary Public

~W, A'. 3MT~T ~0><>y 3 STATE OF CONNECTICUT No. 68542 COMMISSIOII EXPIRES AMRCtf 31,-1939