framatome cog ema fuelsframatome cog ema fuels june 7, 2000 groo-58.doc u. s. nuclear regulatory...

FRAMATOME COG EMA FUELS

June 7, 2000 GROO-58.doc

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject: NRC/FCF Meeting on Bumup Limit Extension for Mark-BW Fuel

Gentlemen:

Enclosed Is the information that was discussed with the NRC staff on June 1, 2000. FCF requests in accordance with 10 CFR 2.790 that this information be considered proprietary and withheld from public disclosure. An affidavit supporting this request is included as Attachment 1. Attachment 2 is the proprietary version of the material. Attachment 3 Is the non-proprietary version.

Very truly yours,

T. A. Coleman, Vice President Government Relations

Enclosures

cc: R. Caruso, NRC M. S. Chatterton, NRC S. L. Wu, NRC S. N. Bailey, NRC M. A. Schoppman 20A13 File/Records Management

FRAMATOME TECH NOLOG IES

Framatome Cogema Fuels 3315 Old Forest Road, P.O. Box 10935, Lynchburg, VA 24506-0935 Telephone: 804-832-3000 Fax: 804-832-3663 -T07

Attachment 1

AFFIDAVIT OF THOMAS A. COLEMAN

A. My name is Thomas A. Coleman. I am Vice President of Government Relations for

Framatome Cogema Fuels (FCF). Therefore, I am authorized to execute this Affidavit.

B. I am familiar with the criteria applied by FCF to determine whether certain information of

FCF-is proprietary and I am familiar with the procedures established within FCF to ensure

the proper application of these criteria.

C. In determining whether an FCF document is to be classified as proprietary information, an

initial determination is made by the Unit Manager, who is responsible for originating the

document, as to whether it falls within the criteria set forth in Paragraph D hereof. If the

information falls within any one of these criteria, it is classified as proprietary by the

originating Unit Manager. This initial determination is reviewed by the cognizant Section

Manager. If the document is designated as proprietary, it is reviewed again by personnel and

other management, within FCF as designated by the Vice President of Government Relations

to assure that the regulatory requirements of 10 CFR Section 2.790 are met.

D. The following information is provided to demonstrate that the provisions of 10 CFR Section

2.790 of the Commission's regulations have been considered:

(i) The information has been held in confidence by FCF. Copies of the document are

clearly identified as proprietary. In addition, whenever FCF transmits the

information to a customer, customer's agent, potential customer or regulatory

agency, the transmittal requests the recipient to hold the information as

proprietary. Also, in order to strictly limit any potential or actual customer's use

of proprietary information, the substance of the following provision is included in

all agreements entered into by FCF, and an equivalent version of the proprietary

provision is included in all of FCF's proposals:

AFFIDAVIT OF THOMAS A. COLEMAN (Cont'd.)

"Any proprietary information concerning Company's or its Supplier's

products or manufacturing processes which is so designated by Company or

its Suppliers and disclosed to Purchaser incident to the performance of such

contract shall remain the property of Company or its Suppliers and is

disclosed in confidence, and Purchaser shall not publish or otherwise

disclose it to others without the written approval of Company, and no

rights, implied or otherwise, are granted to produce or have produced any

products or to practice or cause to be practiced any manufacturing processes

covered thereby.

Notwithstanding the above, Purchaser may provide the NRC or any other

regulatory agency with any such proprietary information as the NRC or

such other agency may require; provided, however, that Purchaser shall

first give Company written notice of such proposed disclosure and

Company shall have the right to amend such proprietary information so as

to make it non-proprietary. In the event that Company cannot amend such

proprietary information, Purchaser shall, prior to disclosing such

information, use its best efforts to obtain a commitment from NRC or such

other agency to have such information withheld from public inspection.

Company shall be given the right to participate in pursuit of such

confidential treatment."

2


(ii) •The following criteria are customarily applied by FCF in a rational decision

process to determine whether the information should be classified as proprietary.

Information may be classified as proprietary if one or more of the following

criteria are met:

a. Information reveals cost or price information, commercial strategies,

production capabilities, or budget levels of FCF, its customers or suppliers.

b. The information reveals data or material concerning FCF research or

development plans or programs of present or potential competitive

advantage to FCF.

c. The use of the information by a competitor would decrease his

expenditures, in time or resources, in designing, producing or marketing a

similar product.

d. The information consists of test data or other similar data concerning a

process, method or component, the application of which results in a

competitive advantage to FCF.

e. The information reveals special aspects of a process, method, component or

the like, the exclusive use of which results in a competitive advantage to

FCF.

f. The information contains ideas for which patent protection may be sought.

3


The document(s) listed on Exhibit "A", which is attached hereto and made a part

hereof, has been evaluated in accordance with normal FCF procedures with respect

to classification and has been found to contain information which falls within one

or more of the criteria enumerated above. Exhibit "B", which is attached hereto

and made a part hereof, specifically identifies the criteria applicable to the

document(s) listed in Exhibit "A".

(iii) The document(s) listed in Exhibit "A", which has been made available to the

United States Nuclear Regulatory Commission was made available in confidence

with a request that the document(s) and the information contained therein be

withheld from public disclosure.

(iv) The information is not available in the open literature and to the best of our

knowledge is not known by Combustion Engineering, Siemens, General Electric,

Westinghouse or other current or potential domestic or foreign competitors of

Framatome Cogema Fuels.

(v) Specific information with regard to whether public disclosure of the information is

likely to cause harm to the competitive position of FCF, taking into account the

value of the information to FCF; the amount of effort or money expended by FCF

developing the information; and the ease or difficulty with which the information

could be properly duplicated by others is given in Exhibit "B".

E. I have personally reviewed the document(s) listed on Exhibit "A" and have found that it is

considered proprietary by FCF because it contains information which falls within one or

more of the criteria enumerated in Paragraph D, and it is information which is customarily

held in confidence and protected as proprietary information by FCF. This report comprises

information utilized by FCF in its business which afford FCF an opportunity to obtain a

4


competitive advantage over those who may wish to know or use the information contained in

the document(s).

THOMAS A. COLEMAN

State of Virginia) SS. Lynchburg

City of Lynchburg)

Thomas A. Coleman, being duly sworn, on his oath deposes and says that he is the person

who subscribed his name to the foregoing statement, and that the matters and facts set forth in the

statement are true.

THOMAS A. COLEMAN

Subscribed and Rom before me this Z.day of C 2000.

Notary Public in aid for the City of Lynchburg, State of Virginia.

My Commission Expires

5

EXHIBITS A & B

EXHIBIT A

Materials handed out at NRC/Framatome Cogema Fuels Meeting on June 1, 2000

EXHIBIT B

The above listed materials contain information which is considered Proprietary in accordance with Criteria b, c, and d of the attached affidavit.

6

Attachment 3

f

NRC/FCF Meeting on Mark-BW Burnup Limit

Rockville, Maryland

C. F. McPhatter

June 1, 2000

cftB O0nr.ppt

Agenda

I Introduction and Background for Increasing Mark BW Burnup Limit

UPresentation of Data

mDiscussion

mConclusion

4 1$cfmh .OOnrc.ppt

.1 4

Obj ectives

EAgree that the proposed burnup limit for the Mark-BW fuel is justified

* Develop plan for providing documentation and obtaining NRC approval

Cfrn8O0nrM.PPt

I Reference Documents

*BAW-10153P, Extended Burnup Evaluation, April 1986

*BAW-10172P, Mark-BW Mechanical Design Report, SER, December 1989

*BAW-10186P-A, Rev. i Extended Burnup Evaluation, April 2000

*BAW-1 0227P-A, Evaluation of Advanced Cladding and Structural Material (M5TM) in-PWR Reactor Fuel, February 2000

dMk.W=-P# Q

4

Background

EThe SER for BAW-10153P-A allows burnups up to 45 GWd/mtU batch average for Mark-B fuel

EThe SER for BAW-10172P allows burnups up to 60 GWd/mtU rod average for Mark-BW fuel

EThe SER for BAW-10186P allows burnups of 60 GWd/mtU and 62 GWd/mtU rod average for MarkBW and for Mark-B fuel respectively

EThe SER for BAW-10227P allows burnups of 60 GWd/mtU and 62 GWd/mtU rod average for MarkBW and for Mark-B fuel respectively

Cft6jJMnr.Ppt

Demonstration Of The Ability For The Mk-BW Fuel Assembly To

Achieve 62 GWd/mtU Pin Burnup

"* Show sufficient data has been obtained to demonstrate accuracy of models to 62 GWd/mtU

"* Show that the data is well behaved so that the models are reliable design tools to 62 GWd/mtU

RoAkMAATO M E T K N N C 3 L I S

Justification For Burnup Limit Of 62 GWd/mtU For Mk-BW

* Data will be presented for both the MK-BW and the Mk-B for comparison

m Mk-B and Mk-BW are very similar designs that perform in a consistent manner

* Key data that justifies the new limit "* Fuel rod oxide " Irradiation experience "* Fuel assembly growth

"* Shoulder Gap "n Guide tube oxide "* Fuel Rod Reliability

1 3F CP. N M0 T 0 M E T R C M M 40 L 40 C tS

Fuel Rod Oxide No Longer Limits Burnup With M5 Cladding

Maximum Oxide Thickness vs Burnup

0 10000 20000 30000 40000 50000 60000

Bumup, MWdImtU

140

E =1

IS

(U

70000

,Y F R ARAMAA.T CM E T E C N 04 0 L 00 0 1 W 6

4 to

5.

. 4

M5 Has Low Sensitivity To Duty

Zy4 - 5 cycles 56 GWdItU - m n

U U

p

mu,.LI

1000

[]

1500 2000 2500

Altitude (mm)

YFTIRC N N LIRAMATOCOM E

100

90

80

ME

70

60

50

40

30-

44

PC

m u m a

n. []

20,

10

0

U,

0 500

0 .W o m= = M 11o o o o o o o O o o ° ° n

a0 MS- :cycleos

63 GWdltU3000 3500 4000

63 GWd/tU

m

Additional Data Obtained Since Topical Representative Of High

Burnup Cyclesw

Mk-BW Data

0 200 400 600 800 1000 1200 1400 1600 1800 2000 2200

In-Core Exposure, EFPD

Y C0RAMoAT •M E T 1I C Hk M O2 LO I II

60

50

40

30

20

C,

IL

*�

� t�'N

� )

--- �----�

A �

'�'.

'P t �

� �< x� �''� �

p

10

0

Additional Data Obtained Since Topical Representative Of High

Burnup Cycles Mk-B And Mk-BW Data

60

50

40

30

20

'V A

10

0 200 400 800 800 - 1000 1200 1400

In-Core Exposure, EFPD

1600 1800 2000 2200

A 8HAMATO M E V B C N N 0 IL O00 I B s

.. 4

E

0

£0 4 IL

0

,�t .9

Fuel Assembly Growth Data Matches Model

Mk-BW Fuel Assembly Growth Zircaloy 4

0 0.1 02 0.3 0.4 0.5 0.6 SFuel Assembly Burnup, GWd/mtU

0.7 0.8 0.9 1

' Ek M AT 40 L0 M E TUCa a N@ OI K S

0.06

0.05

0.04

0.03

0.02

0.01

0

aI

0 go

.1 6

Mk-BW And Mk-B Fuel Assembly Growth Data are Consistent

Mk-BW And Mk-B Fuel Assembly Growth Zircaloy 4

0.00

0.05

, 0.04

0.03

0.02

0.01

0 0.1 0.2 0.3 0.4 0.5 0.6

Fuel Assembly Bumup, GWdImtU

0.7 0.8 0.9 1

1R.5 C A64 T,5RACAO M E I T € H M CO L 0ý 45II

"N..

Shoulder Gap Data Well Behaved With Excess Margin Available

Mk-BW Minimum Shoulder Gap Zircaloy 4

2.500

2.000

CEC

o .500

0.000

0.0 10.0 20.0 3.0 40.0 50.0 60.0

Fuel Assembly Bumup, GWd~mtU

J CR,^hMobT C> M E

T U C H N C L < a I K S

Shoulder Gap Data Well Behaved With Excess Margin Available

Mk-BW And Mk-B Minimum Shoulder Gap

2.500

2.000

1.500 _U

E 01.000

0.5m0

0.000 4 0.0 10.0 20.0 30.0 40.0 50.0

Fuel Assembly Bumup, GWdImtU

60.0

V

k

1FRAMATO M E T 3 C H N C L 3 3 S

Guide Tube Oxide Thickness Data Demonstrates Significant Margin

Guide Tube Oxide Thickness Zircaloy 4

35

30

25

- 20 *

C lO ~15 ,,

10-

0 --

0 10 20 30 40 50 60

Fuel Assembly Bumup, GWd/mtU C L

'-F R A, M AT 0 MO E T R C H N C0 L C-0 1l K S

4 0

Coolant Activity (/,cilgm)

I 0•

0 0

C

0 0D

0•

0 0

0

ANO

CR 3

DB I

Oc I

Oc 2

Oc 3

TMI

Cat I

Cat 2

Mc I

Mc 2

Seq I

Seq 2

*1

0 0

+ 0 0

-o 0

0 03

CD

0M

CDi

0a

0/ 0

0>

0

Om

S

p

I I

1'ý

Failure Rate For Mark-BW Fuel By Year Of Manufacture

Year Of Manufacture

Y TFRAMATO MIE T U C N N 0 L 0 @ I I[ S

10I

U.

8

6

4

2

0

".9

Conclusion

"* Mk-BW fuel assembly has performed well through 53GWd/mtU

"* Sufficient data exists to verify design models are accurate to a fuel rod burnup of greater than 62 GWd/mtU

"* Models provide the tools to design a fuel assembly capable of irradiation to 62 GWd/mtU, rod average

TRACAMATOL M E T KC N INO 0 .0OIIEIm

i.

Conclusion

sOn the basis of the information presented today the proposed burnup limit for Mark-BW fuel is justified

M Define process for obtaining NRC review and approval of the proposed limit

cftn6..oo .p#t