ML14064A324

000N2495-R1-NP, Rev. 0, Nine Mile Point Nuclear Station Unit 2 Comparison of Mellla+ Reference Design to Cycle 15 Design Characteristics.

ML14064A324
Person / Time
Site:	Nine Mile Point
Issue date:	02/28/2014
From:	Trosman L Global Nuclear Fuel
To:	Office of Nuclear Reactor Regulation
References
000N2495-R1-NP, Rev. 0
Download: ML14064A324 (17)

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{{#Wiki_filter:ATTACHMENT (3)NINE MILE POINT NUCLEAR STATION UNIT 2, COMPARISON OFMELLLA+ REFERENCE DESIGN TO CYCLE 15 DESIGNCHARACTERISTICS (000N2495-R1-NP) (NON-PROPRIETARY) Nine Mile Point Nuclear Station, LLCFebruary 25, 2014 GNFGlobal Nuclear FuelA Joint Venture of GE. Tohiba,. & HitachiGlobal Nuclear Fuel3901 Castle Hayne RdWilmington, NC 2840100ON2495-R1-NP Revision 0February 2014GNF Proprietary Information -Class I (Public)Nine Mile Point Nuclear Station Unit 2Comparison of MELLLA+ Reference Designto Cycle 15 Design Characteristics Responsible Engineer: L. TrosmanApproving Manager:R. FawcettAuthorizing Document: Verification Status:WA GNFO2 KG 1004 Rev 1Verified 000N2495-Rl-NP Revision 0GNF Proprietary Information -Class I (Public)IMPORTANT NOTICE REGARDING THECONTENTS OF THIS REPORTPlease Read Carefully Disclaimer The only undertakings of Global Nuclear Fuel (GNF) respecting information in this documentare contained in the contract between the company receiving this document and GNF.Nothing contained in this document shall be construed as changing the applicable contract. The use of this information by anyone other than a customer authorized by GNF to have thisdocument, or for any purpose other than that for which it is intended, is not authorized. Withrespect to any unauthorized use, GNF makes no representation or warranty, and assumesno liability as to the completeness, accuracy or usefulness of the information contained inthis document, or that its use may not infringe privately owned rights.Information NoticeThis is a non-proprietary version of the document 000N2495-R1-P, Revision 0, which has theproprietary information removed. Portions of the document that have been removed areindicated by an open and closed bracket as shown here R I].Page ii 000N2495-Rl-NP Revision 0GNF Proprietary In formation -Class I (Public)REVISION SUMMARYRev0 Initial IssueSummary of ChangesIPage iii 000N2495-R1-NP Revision 0GNF Proprietary Information -Class I (Public)TABLE OF CONTENTSSection PaqeREV ISIO N SU M M A RY .................................................................................................................................................... iiiA C RO N Y M S A N D A B B R EV IATIO N S .......................................................................................................................... v1. SC O PE A N D SU M M A RY ...............................................................................................................................

12. C O M PA RISO N S ...............................................................................................................................................

12.2 Energy Req uirem ents .................................................................................................................................. 12.3 Fuel U tilizatio n ................................................................................................................................................ 12.4 Sig nifica nt A na lytica l Inputs ..................................................................................................................... 22.5 Reactivity M a rg ins ........................................................................................................................................ 22.6 Therm a l Lim it M arg ins ................................................................................................................................ 3Page iv 000N2495-R1-NP Revision 0GNF Proprietary Information -Class I (Public)ACRONYMS AND ABBREVIATIONS Item Short Form Description 1 BOC Beginning Of Cycle2 ECCS Emergency Core Coolant System3 MAPLHGR Maximum Average Planar Linear Heat Generation Rate4 MELLLA+ Maximum Extended Load Line Limit Analysis Plus5 MOC Middle Of Cycle6 MWd Energy units MegaWatts-days 7 MWd/ST Exposure units MWd thermal energy per core weight Short Tons8 N/A Not Applicable 9 NRC Nuclear Regulatory Commission 10 OLMCPR Operating Limit for Minimum Critical Power Ratio11 OLTP Original Licensed Thermal Power12 SAR Safety Analysis Report13 SLCS Standby Liquid Control System14 SRO Strongest Rod OutPage v 000N2495-R1-NP Revision 0GNF Proprietary Information -Class I (Public)1. SCOPE AND SUMMARYThe Nine Mile Point Nuclear Station Unit 2 (NMP2) MELLLA+ project consists of theevaluations necessary to support the extensions of the NMP2 operating domain to permitoperation up to 120% (3988 MWt) of OLTP at core flows as low as 85% of rated (RCF). AMELLLA+ SAR was performed with a reference core design designated hereafter asReference Design. The scope of this report is to compare the Reference Design to the Cycle15 design which is anticipated to apply the MELLLA+ domain once approval is obtained. This report supports the commitment made by Nine Mile Point Nuclear Station Unit 2 to theNRC in a MELLLA+ pre-submittal meeting to supplement the MELLLA+ SAR. It should benoted Limitation and Condition 12.4, "Reload analysis submittal", from the final SE for NEDC-33006P, "Maximum Extended Load Line Limit Analysis Plus," requires that "... the SRLR for theinitial MELLLA+ submittal implementation cycle shall be submitted for NRC staffconfirmation." There is no SE requirement to provide a comparison report.The items included in this comparison are as follows:* Energy requirements,

• Fuel Utilization,
• Significant analytical inputs (i.e., design basis)," Reactivity

Margins, and" Thermal limits.2. COMPARISONS 2.1 Energy Requirements Item Parameter Units Reference Design Cycle 151 Total Energy MWd 2,801,012 2,580,225 2 Coastdown Length Days 40 562.2 Fuel Utilization Item Parameter Units Reference Design Cycle 153 Batch Size BundlesBundle Average Wt. % U235Enrichment 5 Fuel Design N/A GE14 GE14Page 1 000N2495-R1-NP Revision 0GNF Proprietary Information

-Class I (Public)2.3 Significant Analytical InputsItem Parameter Units Reference Design Cycle 156 Power MWt 3988 3988% of7 Flow Window Rated85 to 105 87 to 104RatedExp Exp(MWd/ST) Values (MWd/ST) Values8 Hot Target N/AEigenvalues Exp ExpCold Target (MWd/ST) Values (MWd/ST) Values9 Eigenvalues N/A(Distributed) Thermal Mechanical 10 N/A PRIME PRIMEModel2.4 Reactivity MarginsItem Parameter Units Reference Design Cycle 15Cold SRO Minimum11 Shutdown Margin -% AkMinimum occurs at BOCSLCS Minimum12 Shutdown Margin- % AkMinimum occurs at BOCPage 2 000N2495-R1-NP Revision 0GNF Proprietary Information -Class I (Public)2.5 Thermal LimitsItem Parameter Units Reference Design Cycle 1513 OLMCPR N/A [[ [[Exp LHGR Exp LHGR(GWd/MT) (kW/ft) (GWd/MT) (kW/ft)14 U02 Thermal N/AMechanical LimitExp MAPLHGR Exp MAPLHGR(GWd/MT) (kW/ft) (GWd/MT) (kW/ft)0.0 12.8216.00 12.8221.09 12.8215 MAPLHGR Limit* N/A63.50 8.0070.00 5.00*[Page 3 ATTACHMENT (4)AFFIDAVIT FROM GLOBAL NUCLEAR FUEL -AMERICAS, LLC (GNF-A) JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION CONTAINED IN ATTACHMENT (6)Nine Mile Point Nuclear Station, LLCFebruary 25, 2014 Global Nuclear Fuel -AmericasAFFIDAVIT I, Lukas Trosman, state as follows:(1) I am Engineering

Manager, Reload Design and Analysis, Global Nuclear Fuel -Americas, LLC (GNF-A),

and have been delegated the function of reviewing theinformation described in paragraph (2) which is sought to be withheld, and havebeen authorized to apply for its withholding. (2) The information sought to be withheld is contained in GNF-A proprietary report000N0123-FBIR-P, Fuel Bundle Information Report for Nine Mile Point 2Reload 14 Cycle 15, Revision 0, December 2013. GNF-A proprietary information in 000N0123-FBIR-P, Fuel Bundle Information Report for Nine Mile Point 2Reload 14 Cycle 15, Revision 0, December 2013 is identified by a dotted underline inside double square brackets. [[Thi.ssentence is an.example. 131]] Figures and largeequation objects are identified with double square brackets before and after theobject. In each case, the superscript notation (31 refers to Paragraph (3) of thisaffidavit, which provides the basis for the proprietary determination. (3) In making this application for withholding of proprietary information of which it isthe owner or licensee, GNF-A relies upon the exemption from disclosure set forth inthe Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the TradeSecrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "tradesecret", within the meanings assigned to those terms for purposes of FOIAExemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health ResearchGroup v. FDA, 704 F2d 1280 (DC Cir. 1983).(4) Some examples of categories of information which fit into the definition ofproprietary information are:a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A'scompetitors without license from GNF-A constitutes a competitive economicadvantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure ofresources or improve his competitive position in the design, manufacture,

shipment, installation, assurance of quality, or licensing of a similar product;c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products toGNF-A;d. Information which discloses patentable subject matter for which it may bedesirable to obtain patent protection.

00ON0123-FBIR-P Affidavit Page 1 of 3 The information sought to be withheld is considered to be proprietary for the reasonsset forth in paragraphs (4)a. and (4)b. above.(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is beingsubmitted to NRC in confidence. The information is of a sort customarily held inconfidence by GNF-A, and is in fact so held. The information sought to be withheldhas, to the best of my knowledge and belief, consistently been held in confidence byGNF-A, no public disclosure has been made, and it is not available in publicsources. 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. Itsinitial designation as proprietary information, and the subsequent steps taken toprevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7)following. (6) Initial approval of proprietary treatment of a document is made by the manager ofthe originating component, the person most likely to be acquainted with the valueand sensitivity of the information in relation to industry knowledge, or subject to theterms under which it was licensed to GNF-A. Access to such documents withinGNF-A is limited on a "need to know" basis.(7) The procedure for approval of external release of such a document typically requiresreview by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), andby the Legal Operation, for technical

content, competitive effect, and determination of the accuracy of the proprietary designation.

Disclosures outside GNF-A arelimited to regulatory bodies, customers, and potential customers, and their agents,suppliers, and licensees, and others with a legitimate need for the information, andthen only in accordance with appropriate regulatory provisions or proprietary agreements. (8) The information identified in paragraph (2) is classified as proprietary because itcontains details of GNF-A's fuel design and licensing methodology. Thedevelopment of this methodology, along with the testing, development and approvalwas achieved at a significant cost to GNF-A.The development of the fuel design and licensing methodology along with theinterpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNF-A asset.(9) Public disclosure of the information sought to be withheld is likely to causesubstantial harm to GNF-A's competitive position and foreclose or reduce theavailability of profit-making opportunities. The information is part of GNF-A'scomprehensive BWR safety and technology base, and its commercial value extendsbeyond the original development cost. The value of the technology base goesbeyond the extensive physical database and analytical methodology and includesdevelopment of the expertise to determine and apply the appropriate evaluation 00ON0123-FBIR-P Affidavit Page 2 of 3 process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.The research, development, engineering, analytical, and NRC review costs comprisea substantial investment of time and money by GNF-A.The precise value of the expertise to devise an evaluation process and apply thecorrect analytical methodology is difficult to quantify, but it clearly is substantial. GNF-A's competitive advantage will be lost if its competitors are able to use theresults of the GNF-A experience to normalize or verify their own process or if theyare able to claim an equivalent understanding by demonstrating that they can arriveat the same or similar conclusions. The value of this information to GNF-A would be lost if the information weredisclosed to the public. Making such information available to competitors withouttheir having been required to undertake a similar expenditure of resources wouldunfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its largeinvestment in developing and obtaining these very valuable analytical tools.I declare under penalty of perjury that the foregoing affidavit and the matters statedtherein are true and correct to the best of my knowledge, information, and belief.Executed on this 11 th day of December 2013.Lukas TrosmanEngineering

Manager, Reload Design and AnalysisGlobal Nuclear Fuel -Americas, LLC00ON0123-FBIR-P Affidavit Page 3 of 3 ATTACHMENT (5)AFFIDAVIT FROM GLOBAL NUCLEAR FUEL -AMERICAS, LLC (GNF-A) JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION CONTAINED IN ATTACHMENT (7)Nine Mile Point Nuclear Station, LLCFebruary 25, 2014 Global Nuclear Fuel -AmericasAFFIDAVIT I, Lukas Trosman, state as follows:(1) I am Engineering

Manager, Reload Design and Analysis, Global Nuclear Fuel -Americas, LLC (GNF-A),

and have been delegated the function of reviewing theinformation described in paragraph (2) which is sought to be withheld, and havebeen authorized to apply for its withholding. (2) The information sought to be withheld is contained in GNF-A proprietary report000N2495-R1 -P, Nine Mile Point Nuclear Station Unit 2 Comparison of MELLLA +Reference Design to Cycle 15 Design Characteristics, Revision 0, February 2014.GNF-A proprietary information in 000N2495-RI-P, Nine Mile Point NuclearStation Unit 2 Comparison of MELLLA+ Reference Design to Cycle 15 DesignCharacteristics, Revision 0, February 2014 is identified by a dotted underline insidedouble square brackets. This sentence is an exa.mpe..13., In each case, thesuperscript notation 313 refers to Paragraph (3) of this affidavit, which provides thebasis for the proprietary determination. (3) In making this application for withholding of proprietary information of which it isthe owner or licensee, GNF-A relies upon the exemption from disclosure set forth inthe Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the TradeSecrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "tradesecret", within the meanings assigned to those terms for purposes of FOIAExemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health ResearchGroup v. FDA, 704 F2d 1280 (DC Cir. 1983).(4) Some examples of categories of information which fit into the definition ofproprietary information are:a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A'scompetitors without license from GNF-A constitutes a competitive economicadvantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure ofresources or improve his competitive position in the design, manufacture,

shipment, installation, assurance of quality, or licensing of a similar product;c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products toGNF-A;d. Information which discloses patentable subject matter for which it may bedesirable to obtain patent protection.

00ON2495-RI-P Affidavit Page 1 of 3 The information sought to be withheld is considered to be proprietary for the reasonsset forth in paragraphs (4)a. and (4)b. above.(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is beingsubmitted to NRC in confidence. The information is of a sort customarily held inconfidence by GNF-A, and is in fact so held. The information sought to be withheldhas, to the best of my knowledge and belief, consistently been held in confidence byGNF-A, no public disclosure has been made, and it is not available in publicsources. 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. Itsinitial designation as proprietary information, and the subsequent steps taken toprevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7)following. (6) Initial approval of proprietary treatment of a document is made by the manager ofthe originating component, the person most likely to be acquainted with the valueand sensitivity of the information in relation to industry knowledge, or subject to theterms under which it was licensed to GNF-A.(7) The procedure for approval of external release of such a document typically requiresreview by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), andby the Legal Operation, for technical

content, competitive effect, and determination of the accuracy of the proprietary designation.

Disclosures outside GNF-A arelimited to regulatory bodies, customers, and potential customers, and their agents,suppliers, and licensees, and others with a legitimate need for the information, andthen only in accordance with appropriate regulatory provisions or proprietary agreements. (8) The information identified in paragraph (2) is classified as proprietary because itcontains details of GNF-A's fuel design and licensing methodology. Thedevelopment of this methodology, along with the testing, development and approvalwas achieved at a significant cost to GNF-A.The development of the fuel design and licensing methodology along with theinterpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNF-A asset.(9) Public disclosure of the information sought to be withheld is likely to causesubstantial harm to GNF-A's competitive position and foreclose or reduce theavailability of profit-making opportunities. The information is part of GNF-A'scomprehensive BWR safety and technology base, and its commercial value extendsbeyond the original development cost. The value of the technology base goesbeyond the extensive physical database and analytical methodology and includesdevelopment of the expertise to determine and apply the appropriate evaluation 00ON2495-RI-P Affidavit Page 2 of 3 process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.The research, development, engineering, analytical, and NRC review costs comprisea substantial investment of time and money by GNF-A.The precise value of the expertise to devise an evaluation process and apply thecorrect analytical methodology is difficult to quantify, but it clearly is substantial. GNF-A's competitive advantage will be lost if its competitors are able to use theresults of the GNF-A experience to normalize or verify their own process or if theyare able to claim an equivalent understanding by demonstrating that they can arriveat the same or similar conclusions. The value of this information to GNF-A would be lost if the information weredisclosed to the public. Making such information available to competitors withouttheir having been required to undertake a similar expenditure of resources wouldunfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its largeinvestment in developing and obtaining these very valuable analytical tools.I declare under penalty of perjury that the foregoing affidavit and the matters statedtherein are true and correct to the best of my knowledge, information, and belief.Executed on this 7th day of February 2014.uaTrosman Engineering

Manager, Reload Design and AnalysisGlobal Nuclear Fuel -Americas, LLC00ON2495-Rl-P Affidavit Page 3 of 3}}