ML20151S430

Application for Amend to License NPF-57,implementing Appropriately Conservative SLMCPR for Upcoming Cycle 9 Plant Core & Fuel Designs.Proprietary & non-proprietary Description of Revs to TS Encl.Proprietary Info Withheld

ML20151S430
Person / Time
Site:	Hope Creek
Issue date:	08/25/1998
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20138K839	List: ML20151S430 ML20151S433
References
LCR-H98-06, LCR-H98-6, LR-N98404, NUDOCS 9809080119
Download: ML20151S430 (9)

Text

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,. 4 ,- Company Louis F. storz Public Service Electnc and Gas Cor P.O. Box 236, Hancocks Bridge. NJ 08038 609-339-5700 l Senior Vice President Nuclear Operatons I

LR-N98404 l LCR H98-06 United States Nuclear Regulatory Commicsion  ;

Document Control Desk j Washington, DC 20555 l

l Gentlemen:

REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS l SAFETY LIMIT MINIMUM CRITICAL POWER RATIO (SLMCPR)

HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 i

in accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Tech,iical Specifications (TS) for the Hope Creek Generating Station (HC). In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey. /

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The proposed revision represents changes to TS 2.1.2, " THERMAL POWER, High l Pressure and High Flow", and the Bases for TS 2.1, " Safety Limits". These changes are being made to implement an appropriately conservative Safety Limit Minimum Critical Power Ratio (SLMCPR) for the upcoming Cyc!c 9 Hope Creek core and fuel i designs. Justification for these proposed changes was developed from General Electric l SLMCPR analyses performed to address SLMCPR issues identified in a 10CFR21 notification made by General Electric on May 24,1996. c 4

The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1), '

using the criteria in 10CFR50.92(c), and a determination has been made that this request involves no significant hazards considerations. The basis for the requested change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a determination of no significant hazards consideration, is provided in Attachment 2. The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 3. Pursuant to Attachment 4 of this letter, this submittal contains proprietary information in Attachment 1, which is indicated by use of double ATTACHMENT 1 OF THIS LETTER CONTAINS PROPRIETARY INFORMATION D 54 C MSGOSM -

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AUG 251998 i Document Control Desk l LR-N98404 l

brackets. Since the information contained in Attachment 1 should be withheld from public disclosure, a non-proprietary version of Attachment 1 is provided in Attachment 5 of this letter.

Upon NRC approval of this proposed change, PSE&G requests that the amendment be ,

made effective on the date of issuance, but allow an implementation period of sixty {

days after the completion of Cycle 8 to provide sufficient time for associated l administrative activities.

I Should you have any questions regarding this request, please contact James Priest at (609) 339-5434, 1 Sincerely, .

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Affidavit Attachments (5) 1 C Mr. H. Miller, Administrator - Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr. S. Pindale (X24)

USNRC Senior Resident inspector- HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625 ATTACHMENT 1 OF THIS LETTER CONTAINS PROPRIETARY INFORMATION

- NOT FOR PUBLIC DISCLOSURE -

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REF: LR-N98404 LCR H98-06 STATE OF NEW JERSEY ) i

) SS. i COUNTY OF SALEM ) l E. C. Simpson, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.

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i Subscribed and Swopor before me this d6M d ofMuq// AL 1998 i ,

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Nhary Public obehrsdy My Commission expires Ar a . //fA 03 '

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D:cument C:ntrel Derk LR-N98404

• Attachment 4 LCR H98-06

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I AFFIDAVIT AND BASIS FOR WITHHOLDING INFORMATION CONTAINED IN )

ATTACHMENT 1 TO LCR H98-06 FROM PUBLIC DISCLOSURE 1

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GE Nuclear Energy

, ,. GeneralDoctnc Company P. O. Box 780. VWmington, NC 28402 Affidavit I, Glen A. Watford, being duly sworn, depose and state as follows:

(1) I am Manager, Fuels and Facility Licensing, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withhe8d, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is centained in Attachment 1 of transmittal letter LR-N98404 as indicated by the brackets in the text.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from 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 2.790(a)(4) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all " confidential commercial information," and some portions also qualify under the narrower definition of" trade secret," ,

within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively,  ;

Critical Mass Enerav Proiect v. Nuclear Reculatory Commission. 975F2d871 (DC Cir.1992),

and Public Citi7en Health Research Group v. FDA. 704F2dl280 (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 General Electric's competitors without license from General Electric 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. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

o The information sought to be withheld is conside-ed to be proprietary for the reasons set forth in both paragraphs (4)a. and (4)b., above.

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I Affid:vit l (5) The information sought to be withheld is being submitted to NRC in confidence. The

'information is of a sort customarily held in conHdence by GE, and is in fact so held. Its initial i

' designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not 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 information in confidence.

(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 information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis. J (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 l technical content, competitive effect, and determination of the accuracy of the proprietary l designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential  ;

customers, and their agents, suppliers, and licensees, and others with a legitimate need for the I

information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GE's Safety Limit MCPR analysis and the corresponding results which GE has  ;

applied to Hope Creek's actual core design with GE's fuel.

The development of the methods used in these analysis, along with the testing, development and I l approval of the supporting critical power correlation was achieved at a signi6 cant cost, on the order of several million dollars, to GE.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design is part of GE'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 determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses l done with NRC-approved methods.

I The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GE.

l The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is dif6 cult to quantify, but it clearly is substantial.  !

1 GE's competitive advantage will be lost if its competitors are able to use the results of the GE j experience to normalize or verify their own process or if they are able to ciaim an equivalent understanding by demonstrating that they can irrive at the same or similar conclusions.

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., ;AfRd vit The value of this information to GE would be lost if the information were disclosed to the

, public. Making such information available to competitors without their having been required to .

' undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

State of North Carolina )

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. County of New Hanover )

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Glen A. Watford, being duly sworn, deposes and says: I i

That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

<j Executed at Wilmington, North Carolina, this [ day of Alge ,19 N v i I

/1 l b ASA l len A. Wa d i General Electric Company 1

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Subscribed and sworn before me this A / day of /2mr M ,19 78'

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• ~ }lf. hAA Nothry Public, State of North Carolina l

My Commission Expires /#/e //J W I.

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Dacument Crntrol Deck LR-N98404 Attcchment 2 LCR H98-06

, . HOPE CREEK GENERATING STATION '

FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 SAFETY LIMIT MINIMUM CRITICAL-POWER RATIO (SLMCPR) CHANGES 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Hope Creek Generating Station (HC)

Technical Specifications do not. involve a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.

REQUESTED CHANGE The proposed changes to the Hope Creek Technical Specifications contained in this submittal are being made to: 1) replace the 1.10 MCPR limit for two recirculation loop operation with a 1.09 MCPR limit for Hope Creek Cycle 9; and 2) replace the 1.12 MCPR limit for single recirculation loop operation with a 1.11 MCPR I limit'for Hope Creek Cycle 9. l l

, BASIS

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The derivation of the revised SLMCPRs for Hope Creek for incorporation into the Technical Specifications, and its use to determine cycle-specific thermal limits, have been performed using NRC approved methods. These calculations do not change the method of operating the plant and have no effect on the probability of an accident initiating event or transient.

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There are no significant increases in the consequences of an accident previously evaluated. The basis of the MCPR Safety Limit is to ensure that no mechanistic fuel damage is calculated to occur if the limit is not violated. The new SLMCPRs preserve l the existing margin to transition boiling and the probability of l fuel damage is not increased. Therefore, the proposed change does not involve an increase in the probability or consequences of an accident previously evaluated.

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Dccument,Cantrol DOok LR-N98404  !

Attachment 2 LCR H98-06 2.

The proposed change does not create the possibility of a new or different kind of accident from any accident previously  ;

evaluated. e The proposed changes contained in this submittal result from an i analysis of the Cycle 9 core reload using the same fuel types as ,

previous cycles. These, changes do not involve any new method for .

operating the facility and do not involve any facility t modifications. No new initiating events or transients result ,

from these changes. Therefore, the proposed Technical l Specification changes do not create the possibility of a new or i different kind of accident, from any accident previously evaluated. 1

3. The proposed change does not involve a significant reduction in a margin of safety.

The margin of safety as defined in the Technical Specification bases will remain the same. The new SLMCPRs are calculated using

NRC approved methods, which are in accordance with the current

[ fuel design, and licensing criteria. The MCPR Safety Limit  !

remains high enough to ensure'that greater than 99.9% of all fuel '

rods in the core will avoid transition boiling if the limit is l not violated, thereby preserving the fuel cladding integrity.

Therefore, the proposed Technical Specification changes do not involve a significant reduction in a margin of safety.

CONCLUSION Based on the above, PSE&G has determined that the proposed

- changes do not involve a significant hazards consideration.

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