RS-14-112, Reports Associated with Results of Post-Irradiation Examination (Pie) of Global Nuclear Fuel (Gnf) GE14i Isotope Test Assembly (ITA)

Reports Associated with Results of Post-Irradiation Examination (Pie) of Global Nuclear Fuel (Gnf) GE14i Isotope Test Assembly (ITA)

ML14086A550
Person / Time
Site:	Clinton
Issue date:	03/27/2014
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-112 NEDO-33845, Rev 0
Download: ML14086A550 (16)

Text

Attachment 1 contains proprietary information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this cover letter is decontrolled.

RS-14-112 March 27, 2014 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Reports Associated with Results of Post-Irradiation Examination (PIE) of Global Nuclear Fuel (GNF) GE14i Isotope Test Assembly (ITA)

Reference:

Letter from C. S. Goodwin (U. S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Clinton Power Station, Unit No.1 -Issuance of Amendment Re: Request to Modify Facility Operating License in Support of the Use of Isotope Test Assemblies (TAC NO. ME1643)," dated January 15,2010 The purpose of this letter is to report the results of portions of the PIE of a GNF GE14i ITA bundle performed by GNF for Facility Operating License No. NPF-62 for Clinton Power Station (CPS). The reporting of this information is specified by Condition 11 of the Conditions and Limitations section of the referenced letter.

This letter provides GNF Report NEDC-33845P, *Clinton EOC14 GE14i (ITA) Fuel Examination October 2013,* Revision 0, dated January 2014, which GNF considers to contain proprietary information. The proprietary information is identified by bracketed text. GNF requests that the proprietary information in Attachment 1 be withheld from public disclosure, in accordance with the requirements of 10 CFR 2.390, "Public inspections, exemptions, requests for withholding,*

paragraph (a)(4). A signed affidavit supporting this request is provided in Attachment 2 to this letter. Attachment 3 to this letter provides a non-proprietary version of the GNF Report (Le.,

NEDO-33845).

Attachment 1 contains proprietary information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this cover letter is decontrolled.

March 27, 2014 U. S. Nuclear Regulatory Commission Page 2 There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2818.

Attachments:

1. NEDC-33845P, "Clinton EOC14 GE14i (ITA) Fuel Examination October 2013," Revision 0, dated January 2014 (Proprietary)

2. Global Nuclear Fuel - Americas Affidavit

3. NEDO-33845, "Clinton EOC14 GE14i (ITA) Fuel Examination October 2013," Revision 0, dated January 2014 (Non-Proprietary)

Attachment 1 contains proprietary information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this cover letter is decontrolled.

ATTACHMENT 2 Global Nuclear Fuel - Americas Affidavit

Global Nuclear Fuel- Americas AFFIDAVIT I, Russell E. Stachowski, state as foHows:

(1) I am Chief Consulting Engineer, Nuclear Physics, Global Nuclear Fuel Americas, LLC (GNF-A), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in GNF-A proprietary repOlt, NEDC-33845P, Clinton EOC14 GENi (ITA) Fuel Examination October 2013, Revision 0, Januaty 2014. GNF-A proprietary infonnation in NEDC-33845P, Clinton EOC14 GENi (ITA) Fuel Examination October 2013, Revision 0, Januaty 2014 is identified by a dotted underline inside double square brackets. (([ht? ..~~m~m:.~.j~ .. .1m.J~?HP.:np.h~~:=.}J] Figures and large equation objects containing GNF proprietary information are identified with double square brackets before and after the object. In all cases, the superscript notation {3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietalY determination.

(3) In making this application for withholding of proprietaty infonnation of which it is the owner or licensee, GNF-A relies upon the exemption £I'om disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the nalTower definition of "trade secret", within the meanings assigned to those tenns for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; C. Infonnation which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;

d. Infonnation which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

Affidavit for NEDC-33845P Revision 0 Affidavit Page] of 3

(5) To address 10 CFR 2.390 (b) (4), the infOimation sought to be withheld is being submitted to NRC in confidence. The infol111ation is of a sort customarily held in confidence by GNF-A, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is 110t available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the infOimation in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set f011h in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the infonnation in relation to industry knowledge, or subject to the terms under which it was licensed to GNr-A. Access to such documents within GNF-A is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the infornlation, and then only in accordance with appropriate regulatOl1' provisions or proprieta11' agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology. The development of this methodology, along with the testing, development and approval, was achieved at a significant cost to GNF-A.

The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GNr -A asset.

(9) Public disclosure of the infOlmation sought to be withheld is likely to cause substantial halm to GNF-A's competitive position and foreclose or reduce the availability of profit-making oPPOItunities. The information is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to detemline and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and hIRC review costs comprise a substantial investment oftime and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

Affidavit for NEDC-33845P Revision 0 Affidavit Page 2 of 3

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can alTive at the same or similar conclusions.

The value of this information to GNF -A would be lost if the information were disclosed to the public. Making such infonllation available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Gl\;'F-A of the 0ppoltunity to exercise its competitive advantage to seek an adequate retum on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of peljury that the foregoing affidavit and the matters stated therein are true and COlTect to the best of my knowledge, information, and belief.

Executed on this 9th day ofJanuruy 2014.

Russell E. Stachowski Chief Consulting Engineer, Nuclear Physics Global Nuclear Fuel- Americas, LLC Affidavit for NEDC-33845P Revision 0 Affidavit Page 3 of 3

ATTACHMENT 3 NEDO-33845 "Clinton EOC14 GE14i (ITA) Fuel Examination October 2013" Revision 0, dated January 2014 (Non-Proprietary)

Global Nuclear Fuel Global Nuclear Fuel NEDO-33845 Revision 0 January 2014 Non-Proprietm:v Information - Class I (Public)

Fuel Exam Services Field Test Report Clinton EOC14 GE14i (ITA)

Fuel Examination October 2013 Copyright 2014 Global Nuclear Fuel- Americas. LLC All Rights Reserved

NEDO-33845 Non-Proprietary Information - Class I (Public)

FUEL EXAM SERVICES FIELD TEST REPORT

(

Reference:

PRI 21-01)

TITLE: Clinton EOC14 GE14i (ITA) Fuel Examination DATE: October 2013, Revision 0 Prepared By:

121412013 James Kersey / Site Date Leader Reviewed By:

Approved By:

Services II

NEDO-33845 Non-Proprietary Infomlation Class I (Public)

INFORMATION NOTICE This is a non-proprietary version of the document NEDC-33845P, Revision 0, which has the proprietary information removed, P0l1ions of the document that have been removed are indicated by an open and closed bracket as shown here (( )),

IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT PLEASE READ CAREFULLY The only undertakings of Global Nuclear Fuel - Americas, LLC (GNF-A) with respect to infonnation in this document are contained in contracts between GNF-A and its customers, and nothing contained in this document shall be construed as changing those contracts, The use of this information by anyone other than those pal1icipating entities and for any purposes other than those for which it is intended is not authorized; and with respect to any unauthorized use, GNF-A makes no representation or wan'anty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.

This document records technical information status at the date of publication and may not represent final disposition or conclusion related to the rep0l1ed study, Changes in test data, analytical models, and evaluations subsequent to publication of this document may supersede the reported work and verification of applicability should be made before results are used in final design work.

III

NEDO-33845 Non-Proprietary Information - Class I (Public) 1.0 Introduction In accordance with an agreement between Exelon and GNF, an irradiated fuel examination of one GE14i isotope (Co-60) test assembly (ITA) was perfonned during the end of cycle 14 (EOC14) refueling outage in October 20 by GNF.

Clinton is aGE BWRJ6 at which the GNF examination team has performed channel exams, measurements, and replacements during the last few outages. This was the second inadiated fuel examination on a GE14i assembly; the first examination occul1'ed two years ago after one cycle of operation was completed. The visual exam will be used to evaluate the performance of one of the eight GE14i ITA bundles operated in Clinton for Cycles 14 and 13 and to evaluate acceptability for continued irradiation.

2.0 Work Scope and Summary The work scope performed is identified in Table 1. Visual characteristics observed for the bundle are listed in Table 2.

The examination work scope included a bundle visual examination on all four sides of the assembly in the unbrushed condition. Also included was a post-brush two-sided visual examination. The bundle side identification convention reflects the GNF designations of Sides 3 and 4 adjacent to the control blade (CB) with Sides 1 and 2 away from the CB. Sides 1 through 4 advance in a clockwise direction looking down from the top of the bundle.

The following sections will provide detailed visual findings that are noteworthy relative to what is normal (from Table 2). In all cases, the findings are not significantly atypical for irradiated fueL That is, some types of debris (crud flakes or clumps or fiber-like) are not hannful, some spacer movement is acceptable (minor raising or cocking) and some variance in rod-to-rod spacing is acceptable (provided rods are not close to touching). No rod gap variation of 50% or more closure was observed.

3.0 GE14i Isotope (Co-60) Test Assembly - JYK693 Results/Observations The assembly was installed in the fuel prep machine (FPM) and the channel fastener and channel were removed. A bundle peripheral. visual examination of the full length of all four sides was completed. Moderate to heavy crud was seen on the fuel rods; however, the crud deposition was much lighter, as expected, on the Co-60 rods. Two sides of the bundle were then brushed (mid-span between spacers) to remove loose, fluffy crud and enable better characterization of the underlying cladding cOlTosion condition. The brushed sides were re-examined, and showed no unusual cOlTosion or oxide spalling, and virtually no crud spalling. No unusual differential rod lengths or rod bow were observed. The visual examinations con filmed that the fuel bundle/rods and Co-60 rods are performing as designed with no atypical results. The customer was informed that this bundle was fully acceptable for reinsertion during the outage.

NEDO-33845 Non-Proprietary Infonnation - Class I (Public)

The channel and channel fastener were installed and proper torque applied; the assembly was confinned acceptable for continued ilTadiation/operational use. The assembly was retumed to the spent fuel racks and was retumed to the core for continued operation.

Photographs summarizing the visual examination are attached including (elevation infonnation in aU photos is in inches from the bottom (lower tie plate (LTP) top surface) of the bundle):

• Figure 1: JYK693 Bundle Observations (Unbrushed)

• Figure 2: JYK693 Bundle Observations (Brushed Two Sides)

Noteworthy observations for JYK693:

• ((

))

4.0 Conclusion The GE14i ITA assembly NK693 is suitable for continued operation. Overall fuel cOlTosion and crud condition and mechanical performance is exce))ent.

5.0 References 5.1 GNP Test Plan and Procedures, "Co-60 Isotope Bundle (GE14i) Fuel Examination & Channel Exchange," Clinton EOC 14, Revision 0, October 2013.

5.2 J. Kersey, Site Exit RepOlt, "Clinton EOC 14 CO-60 Isotope (GE14i) Fuel Exam

& Channel Exchange Site Exit Report," October 16, 2013.

2

NEDO-33845 Non-Proprietary lnfonnation - Class I (Public)

Table 1 - Proposed Examination Plan Comments Bundle Visual (pre- and Brush two sides and post-brushing) re-visual after brush in 3

NEDO-33845 Non-Proprietary InfOimation - Class I (Public)

Table 2 Visual Charactel'istics Obsel'Ved Bundle Periphery*

• Upper tie plate and L TP/component condition

• Expansion spring compression

• Upper and lower end plug weld and heat affected zone appearance

• Peripheral fuel rod and spacer band oxide coverage (if not covered by crud)

• Bar code region corrosion condition where present

• Spacer band weld integrity

• Spacer location

• Presence of obvious foreign material (debris)

• Crud deposition characteristics

• Visible rod-to-rod spacing on aU assemblies

• Partial length rod (PLR) upper spacer contact points

• Any atypical conditions

• If applicable, debris filter LTP visual exam - for trapped debris and crud buildup

• The side identification convention on the photographs reflects the GE designations of Sides 3 and 4 adjacent to the CB with Sides 1 and 2 away from the CB. Sides 1 through 4 advance in a clockwise direction.

4

NEDO-33845 Non-Proprietary Information - Class I (Public)

Figure 1 - JYK693, GE14i, 40.30 GWdfMTU, Bundle Observations (Unbrushed)

(( ((

)) ))

Side 1,161", UEPs, (( )) @ far right Side 3, 100", (( )) @ far left,

(( )) @ far right

(( ((

)) ))

nd Side 2, 85", Mid-tier in unbrushed condition ((( Side 3, 45", Mid-tier between 2 and spacers, ((

)) @ far left) )) @ far left, (( )) @ far right

(( ((

)) ))

st Side 4, 18", 1 spacer ((( )) @ far left Side 4, 6", Transition area ((( )) @ far left

(( )) @ far right; Segment hex connection just

(( )) @ far right) below Spacer 1) 5

NEDO-33845 Non-Proprietary Infonnation Class I (Public)

Figure 2 - JYK693, GE14i, 40.30 GWd/MTU, Bundle Observations (Brushed)

(( ((

)) ))

th th Side 2, 99", Mid-tier between 5 and 6 spacers ((( Side 4, 100", ((( )))

)) @ far left)

(( ((

)) ))

nd Side 2,44",80-100" oxide on fuel rods ((( Side 4, 45", Mid-tier between 2 and 3rd spacers (((

)) @ far left) )))

(( ((

)) ))

Side 2, 23", ((( )), on left) Side 4, 25" less corrosion on ([ )) @ far left, (( )) @ far right) 6