ML20138R498

Application for Amend to License DPR-53,changing Tech Specs to Increase Flexibility for Cycle 8 Re Acceptable Number of Failed in-core Detector Strings.Encl Proprietary CEN-318(B)-P Withheld (Ref 10CFR2.790).Fee Paid

ML20138R498
Person / Time
Site:	Calvert Cliffs
Issue date:	12/17/1985
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Butcher E NRC
Shared Package
ML19276D116	List: ML20138R498 ML20138R502
References
NUDOCS 8512310317
Download: ML20138R498 (8)

Text

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q BALTIM ORE GAS AND ELECTRIC CHARLES CENTER. P. O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNDVALL. JR.

VICE PatsiDEPsT SUPPLY December 17,1985 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC 20555 ATTENTION: Mr. E. J. Butcher, Jr., Acting Chief Operating Reactors Branch #3 Division of Licensing

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit No.1; Docket No. 50-317 Request for Amendment Operability Requirements for Incore Detector Strings

REFERENCES:

(a) CEN-318(B)-P, " Analysis of CECOR Power Peaking Uncertainties for Calvert Cliffs Unit 1 Cycle 8," Combustion Engineering, Inc.,

November 1985 (b) CEN P D-153-P, " INCA /CECOR Power Peaking Uncertainty,"

Combustion Engineering, Inc., May 1980 (c) Mr. C. C. Nelson, (NRC), to Dr. R. E. Uhris, (FP&L), letter dated August 21,1981, Docket No. 50-335 (d) Calvert Cliffs Nuclear Engineering Procedure 1 (NEP-1), "Incore Fuel Management (U-1)"

Gentlemen:

The Baltimore Gas and Electric Company hereby requests an Amendment to its Operating License No. DPR-53 for Calvert Cliffs Unit No. I with the submittal of the proposed changes to the Technical Specifications.

PROPOSED CHANGE (BG&E FCR 85-3004) I l

Remove existing pages 3/4 3-29 and 3/4 3-30 from the Unit 1 Technical Specifications and replace with the attached marked-up pages. g;gg ADDr PWR - 5/BC's TECH 5UPPOR7 (w Jos 70 3"sf=ll no.1 i F08 (N. RECAN) l G512310317 851217 PDR ADCCK 05000317 p PDR l

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Mr. E. J. Butcher, Jr.

December 17,1985 Page 2 DISCUSSION The proposed Technical Specification change provides increased flexibility for Unit 1 Cycle 8 with respect to the acceptable number of failed incore detector strings. An unexpectedly large number of detectors were found failed at startup for Unit 1 Cycle 8 and the number of failed incore detector strings for Unit 1 is approaching the current Technical Specification limit of 3/4 3.3.3.2.

TECHNICAL SPECIFICATION 3/4 3.3.3.2a The current Technical Specification 3/4 3.3.3.2a requires at least eight tilt estimates with a minimum of two estimates of each of the four detector levels. The proposed revision still requires at least eight tilt estimates, but requires that only three levels have at least two estimates each. These changes preserve the statistical validity of the tilt estimate and ensure good core coverage since the requirement that there be at least one operable segment in each quadrant at each level is maintained. This degree of coverage is consistent with the observation that azimuthal tilts do not occur at a single level without being seen at adjacent levels.

TECHNICAL SPECIFICATION 3/4 3.3.3.2b & 3/4 3.3.3.2e The analysis in Reference (a) supports the operation of Calvert Cliffs Unit 1 Cycle 8 with as few as 25% of its incore detectors operable. This analysis is based on extending the present failure patterns to much more than the 25% failure rate allowed by the present Technical Specifications. It is shown that even with 75% of the strings failed, the CECOR uncertainties are still well below those in the INCA /CECOR Topical Report (Reference b). Although the analysis would support operation with up to 75% of the ICIs inoperable, we do not expect to need more relief than the 50% relieflevel requested. A similar relief was granted for a similar C-E plant in Reference (c).

Based upon the analysis of Reference (a), the requested decrease in the number of operable detectors required does not affect the uncertainty applicable to the evaluation of limiting power peaking (Reference b). Even if the measurement uncertainties increase another .2 to .5%, the INCA /CECOR topical uncertainties would still be valid.

With the failure level of incore detector strings above 25%, the Baltimore Gas and Electric Company will, for the remainder of Unit 1 Cycle 8, administratively change its surveillance interval (Reference d) by taking the power distribution mcp on an once per 15 MODE 1 day schedule (twice as often as the Technical Specifications now require).

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Mr. E. J. Butcher, Jr.

December 17,1985 Page 3 DETERMINATION OF SIGNIFICANT HAZARDS CONSIDERATIONS This proposed change to the Technical Specifications has been reviewed against the standards of 10 CFR 50.92 regarding significant hazards considerations. The changes do not constitute a significant hazard, in that operating in accordance with the proposed change would not:

(i) involve a significant increase in the probability or consequences of an accident previously evaluated, or The probability of an accident or malfunction of equipment is unchanged since there are no changes made to plant equipment.

Consequences of accidents are not increased since there is no reduction in margin to fuel design limits.

(ii) create the possibility of a new or different kind of accident from any accident previously evaluated, or A different type of accident or malfunctinn not evaluated in the FSAR is not possible since the uncertainties in the power distribution with up to 75% of the incore strings failed are less than the INCA /CECOR Topical (Reference b) and is analyzed in Reference (a).

(iii) involve a significant reduction in the margin of safety.

The INCAmargin

/CECOR of safety Topical(is not reduced Reference b) issince the uncertainty not violated in the with failures up to 75% and is analyzed in Reference (a).

The proposed change applies a~previously used calculational model or design method.

Results of the change are whhin the acceptable criteria specified by the Standard Review Plan. Therefore, the change is consistent with example (vi) of examples of amendments that are not likely to involve significant hazards considerations, as given in Federal Register Notice page 14870, dated April 6,1983.

SAFETY COMMITTEE REVIEW These proposed changes to the Technical Specifications and our determination of significant hazards have been reviewed by our Plant Operations and Off-Site Safety Review Committees, and they have concluded that implementation of these changes will not result in an undue risk to the health and safety of the public.

m .

Mr. E. J. Butcher, Jr.

December 17,1985 Page 4 FEE DETERMINATION Pursuant to 10 CFR 170.21, we are including BG&E Check Number 1901657 in the amount of $150.00 to the NRC to cover the application fee for this request.

Very truly yours,

)

A. E. Lundvall, Jr.

Vice-President, Supply STATE OF MARYLAND :

TO WIT CfrY OF BALTIMORE  :

Joseph A. Tiernan, being duly sworn states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.

WrrNESS my Hand and Notarial Seal: !z fx_ ,/

( Nofary Public My Commission Expires: / $

AEL/RHB/bsb Attachments: 1. CEN-318(B)-P, " Analysis of CECOR Power Peaking Uncertainties for Calvert Cliffs Unit 1 Cycle 8,"

Copies 000001 through 000010.

2. Proposed Technical Specification Changes, cc: D. A. Brune, Esquire G. F. Trowbridge, Esquire D. H. Jaffe, NRC T. Foley, NRC T. Magette, DNR 1

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ATTACIDIENT 4 AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc. )

State of Connecticut )

County of Hartford ) SS.:

I, A. E. Scherer, depose and say that I am the Director, Nuclear Licensing, of Combustion Engineering Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as 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 and in conjunction with the application of Baltimore Gas and Electric Company for withholding this information.

J The information for which proprietary treatment is sought is contained in the following document:

CEN-318 (B)-P, Analysis of CECOR Power Peaking Uncertainties for Calvert Cliffs Unit 1 Cycle 8, November 1985 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 secret, privileged or as confidential commercial or financial information.

l Pursuant to the provisions 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 documeat, should be withheld.

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N Attachment 4 (cont'd) -

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1. The information sought to be withheld from public disclosure are the methodology related to the determination of power listribution measurement untertainties and the statistical models used to determine the uncertainity j estimate, 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.

f 3. The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to the public. Combustion i 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 l_ confidence. The details of the aforementioned system were provided to the 3

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 j 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 informstion, 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 i- maintenance of the information in confidence.

l 6. Public disclosure of the information is likely to cause substantial i

i harm to the competitive position of Combustion Engineering because:

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Attachment 4 (cont'd)

c. 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 hundreds 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 equivalent information.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of methods and statistical models for determining power dictribution measurement uncertainties.

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 methods and statisical models for the determination of power distribution measurement uncertainities, 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.

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

I The ability of Combustion Engineering's competitors to utilize such information l l

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Attachment 4 (cont'd) l 1

I without similar expenditure 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 their 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.

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__ -f A. E. Scherer Director Nuclear Licensing Sworn to before me this [ day of l

4 50 M.Pd Notary Public

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