LR-N13-0222, Core Operating Limits Report, Reload 17, Cycle 18, Revision 8

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Core Operating Limits Report, Reload 17, Cycle 18, Revision 8
ML13263A119
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Site: Hope Creek PSEG icon.png
Issue date: 09/19/2013
From: Simpson S
Public Service Enterprise Group
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Document Control Desk, Office of Nuclear Reactor Regulation
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LR-N13-0222
Download: ML13263A119 (31)
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PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 SEP 1 9 2013 o I>SEG Nuclear 1.,1.,C LR-N 13-0222 TS 6.9.1.9 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

Core Operating Limits Report, Reload 17, Cycle 18, Revision 8 In accordance with the Hope Creek Technical Specifications, Section 6.9.1.9, PSEG Nuclear LLC submits the Core Operating Limits Report (COLR) for Hope Creek Generating Station (HCGS)

Reload 17, Cycle 18, Revision 8. Revision 8 provides updates to the core operating limits for HCGS Unit 1 Cycle 18 operation. contains information proprietary to Global Nuclear Fuel - Americas, LLC (GNF-A),

specifically, Appendix B of the Core Operating Limit Report for Hope Creek Generating Station Unit 1. GNF-A requests this appendix titled, "Exposure-Dependent Linear Heat Generation Limits,"

be withheld from public disclosure in accordance with 10 CFR 2.390 and 10 CFR 9.17. , which contains the complete Core Operating Limits Report, is marked proprietary in its entirety, and a non-proprietary version of the report is provided in Attachment 2. An affidavit supporting the GNF-A request is provided in Attachment 3.

There are no commitments contained in this letter.

Should you have any questions, please contact Mr. Paul Bonnett at (856) 339-1923.

Sincerely, Susan D. Simpson Manager - Hope Creek Regulatory Assurance - Core Operating Limits Report, Reload 17, Cycle 18, Revision 8 - Proprietary - Core Operating Limits Report, Reload 17, Cycle 18, Revision 8 - Non-Proprietary - Affidavit for Core Operating Limits Report for Hope Creek Generating Station Unit 1 Attachment 1 transmitted herewith contains Proprietary Information.

When separated from Attachment 1, this transmittal document is decontrolled.

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 LR-N13-0222 Page 2 of 2 cc: Mr. W. Dean, Regional Administrator - Region 1 Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. J. Hughey, licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 8B1A Washington, DC 20555 USNRC Senior Resident Inspector - Hope Creek (X24)

Mr. P. Mulligan, Manager IV Bureau of Nuclear Engineering New Jersey Department of Environmental Protection PO Box 420 Trenton, NJ 08625 Corporate Commitment Tracking Coordinator (N21)

Hope Creek Commitment Tracking Coordinator (H02)

Manager - BWR Design & Analysis (N20)

Records Management (N64)

LR-N 13-0222 (Total of 24 pages)

Attachment 2 Core Operating Limits Report, Reload 17, Cycle 18, Revision 8 (Non-Proprietary Version)

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

CORE OPERATING LIMITS REPORT FOR Hope Creek Generating Station Unit 1 RELOAD 17, CYCLE 18 Effective Date: ,,1'/13 Prepared By: __ ._~_-,-~",----",~"",""=",,,~_~ ____ Date: .,/2.",/18 James P Collins Preparer Reviewed By:_...,..,A!-=<..#r."'-II--"o.,L!.)_q E~neth W Buckwheat 1 __- Date: } /;i/l413

....,~"b'L_L~~

I r .

Reviewer Approved By: q~ C(S~ Date:

Francis J Safin Manager - BWR Design & Analysis Page 1 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Table of Contents 1.0 Terms and Definitions 4 2.0 References 5 3.0 General Information 6 4.0 Precautions and Limitations 7 5.0 Technical Specifications that Reference the COLR 8 5.1 Average Planar Linear Heat Generation Rate 9 5.2 Minimum Critical Power Ratio 10 5.3 Linear Heat Generation Rate 13 5.4 OPRM Setpoints 15 Appendix A Method of Core Average Scram Speed Calculation 16 Appendix B Exposure Dependent Linear Heat Generation Rate Limits 18 Appendix C Backup Stability Protection 23 Page 2 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

List of Tables TABLE 5.1-1 APLHGR Data for GE14 and GE14i ITAs 9 TABLE 5.2-1 MCPR Operating Limits Cycle Exposure :5 9983 MWd/MTU (:5 9057 MWd/SiU) 11 TABLE 5.2-2 MCPR Operating Limits Cycle Exposure> 9983 MWd/MTU (> 9057 MWd/STU) 11 TABLE 5.2-3 Power Dependent MCPR Multiplier (Kp) Data 12 TABLE 5.2-4 Flow Dependent MCPR Limit (MCPRf) for GE14 12 TABLE 5.2-5 Flow Dependent MCPR Limit (MCPRf) for GE14i ITAs 12 TABLE 5.3-1 Power Dependent Linear Heat Generation Rate Multiplier (LHGRFAC p) 14 TABLE 5.3-2 Flow Dependent Linear Heat Generation Rate Multiplier (LHGRFACf) 1.4 TABLE B-1 GE14 LHGR Limits - U0 2 Fuel Rods 20 TABLE B-2 GE14 LHGR Limits - Gadolinia Bearing Rods 20 TABLE B-3 GE14 LHGR Limits - U0 2 Fuel Rods 21 TABLE B-4 GE14 LHGR Limits - Gadolinia Bearing Rods 21 TABLE B-5 GE14i ITA LHGR Limits - U0 2 Fuel Rods 22 TABLE B-6 GE:14i ITA LHGR Limits - Gadolinia Bearing Rods 22 TABLE C-1 BSP Region Intercepts for Cycle 18 (Operation Prior to FFWTR) 24 TABLE C-2 BSP Region Intercepts for Cycle 18 (Required for FFWTR) 24 Page 3 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) 1.0 Terms and Definitions APLHGR Average Planar Linear Heat Generation Rate ARTS APRM and RBM Technical Specification Analysis BSP Backup Stability Protection COLR Core Operating Limits Report ECCS Emergency Core Cooling Systems EOC End-of-Cycle EOC-RPT End-ot-Cycle Recirculation Pump Trip FFWTR Final Feedwater Temperature Reduction FWHOOS Feedwater Heaters Out of Service GNF-A Global Nuclear Fuel - Americas, LLC ITA Isotope Test Assembly LCO Limiting Condition for Operation LHGR Linear Heat Generation Rate LHGRFACf ARTS LHGR thermal limit flow dependent adjustments and multipliers LHGRFAC p ARTS LHGR thermal limit power dependent adjustments and multipliers MCPR Minimum Critical Power Ratio MCPRp ARTS MCPR thermal limit power dependent adjustments and multipliers MCPRf ARTS MCPR thermal limit flow dependent adjustments and multipliers OPRM Oscillation Power Range Monitor SLMCPR Safety Limit Minimum Critical Power Ratio SLO Single Recirculation Loop Operation TLO Two_Recirculation Loop Operation Page 4 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) 2.0 References

1. "General Electric Standard Application for Reactor Fuel," NEDE~24011-P~A~18, and the Supplement NEDE~24011 ~P~A~18~US, April 2011.
2. "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications," Global Nuclear Fuel Document NEDO~32465-A, August 1996.
3. Renewed Facility Operating License No. NPF~57, PSEG Nuclear LLC, Hope Creek Generating Station, Docket No. 50~354.
4. "Applicability of GE Methods to Expanded Operating Domains," NEDC~33173P~

A, Revision 1, September 2010.

5. GE14 Compliance with Amendment 22 of NEDE~24011-P~A (GESTAR II),

NEDC~32868P, Revision 3, April 2009.

6. "Supplemental Reload Licensing Report for Hope Creek Reload 17 Cycle 18,"

Global Nuclear Fuel Document No. 0000~0114~2308~SRLR, Revision 0, January 2012.

7. "Fuel Bundle Information Report for Hope Creek Reload 17 Cycle 18," Global Nuclear Fuel Document No. 0000-0114-2308~FBIR, Revision 0, January 2012.
8. "Option B Licensing Basis & Cycle~lndependent Transient Evaluation for Implementation of the Technical Specification Improvement Program (TSIP)

Scram Speed," Global Nuclear Fuel Document No. 0000~0119-7785, Revision 0, October 2010.

9. "Hope Creek Generating Station Cycle 18 BSP Region Update for FFWTR Operation", GE Hitachi Nuclear Energy Document No. 0000~0162~1284, Revision 0, June 2013.

Page 5 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) 3.0 General Information This revision of the Core Operating Limits Report provides the core operating limits for Hope Creek Generating Station Unit 1 Cycle 18 operation. This report provides information relative to OPRM setpoints, OPRM surveillance requirements, and backup stability protection regions, single recirculation loop operation, and core average scram speed. The power distribution limits presented here correspond to the core thermal limits for Average Planar Linear Heat Generation Rate (APLHGR), Minimum Critical Power Ratio (MCPR), and Linear Heat Generation Rate (LHGR). Finally, this report provides references to the most recent revision of the implemented approved methodology.

These operating limit values have been determined using NRC approved methods contained in GESTAR-II .(Reference 1) and NEDO-32465-A Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications (Reference 2). These operating limit values also include limitations where required by the NRC Safety Evaluation Report for Hope Creek License Amendment Number 174, Extended Power Uprate (Reference 3) for the use of GE Licensing Topical Report NEDC-33173P, Applicability of GE Methods to Expanded Operating Domains (Reference 4). In addition, the LHGR limits contained within are based upon the GE Report, GE14 Compliance with Amendment 22 of NEDE-24011-P-A (GESTAR II), NEDC-32868P, Revision 3, April 2009 (Reference 5). Revision 3 of the GE14 Compliance report updates the report to include a specific LHGR limit curve to be used by plants referencing NEDC-33173P.

The following sections contain operating limit values for both the GE14 fuel design and the GE14i Isotope Test Assemblies (GE14i ITAs). The limits for the GE14i ITAs were determined using the methods and limitations described in the NRC Safety Evaluation Report for Hope Creek License Amendment Number 184 (Reference 3). The operating limit values apply to both GE14 and GE14i ITAs, unless specific values are provided for the GE14i ITAs. The limitations and penalties for the GE14 fuel design discussed in the previous paragraph also apply to the GE14i ITAs.

The method of calculating core average scram speed, 1:, is provided in Option B Licensing Basis & Cycle-Independent Transient Evaluation for Implementation of the Technical Specification Improvement Program (TSIP) Scram Speed (Reference 8).

These operating limits are established such that all applicable fuel thermal-mechanical, core thermal-hydraulic, ECCS, and nuclear limits such as shutdown margin, and transient and accident analysis limits are met.

Various sections of the Hope Creek Technical Specifications reference this COLR.

Those sections are listed in Section 5 of this document. Hope Creek Technical Specification 6.9.1.9 also requires that this report, including any mid-cycle revisions, shall be provided upon issuance to the NRC.

Page 6 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) 4.0 Precautions and Limitations This document is specific to Hope Creek Generating Station Unit 1 Cycle 18 and shall not be applicable to any other core or cycle design. This report is applicable for Cycle 18 operating from the date of issuance through the end of cycle including consideration of reduced feedwater temperatures for FWHOOS or FFWTR, and a power coastdown to a core thermal power that shall not go below 40% rated core thermal power. End of full power capability is reached when 100% rated power can no longer be maintained by increasing core flow (up to 105% of rated core flow), at allowable feedwater temperatures, in the all-rods-out configuration. Operation beyond the end of full power capability is defined as power coastdown operation which includes an operating assumption that vessel dome pressure will decrease during the power coastdown period as steam flow decreases (maintaining constant vessel dome pressure during the power coastdown period was not generically considered by GESTAR-II for determining the operating limit LCO values described above).

FWHOOS was evaluated for a final feedwater temperature reduction of up to 60°F from the design rated thermal power final feedwater temperature of 431.6°F (431.6°F - 60°F

=: 371.6°F). Therefore, Cycle 18 FWHOOS operation is limited to feedwater system configurations that result in a final feedwater temperature greater than or equal to 371.6°F at rated thermal power. FWHOOS operation and the associated limitations may be implemented any time during the operating cycle prior to cycle ~xtension utilizing FFWTR.

FFWTR was evaluated for a final feedwater temperature reduction of up to 78°F from the design rated thermal power final feedwater temperature of 431.6°F (431.6°F - 78°F

353.6°F). Therefore, Cycle 18 FFWTR operation is limited to feedwater system configurations that result in a final feedwater temperature greater than or equal to 353.6°F at rated thermal power which is compliant with Renewed Facility Operating License No. NPF-57 License Condition 2.C.(11): The facility shall not be operated with a rated thermal power feedwater temperature less than 329.6°F for the purpose of extending the normal fuel cycle. FFWTR operation and the associated limitations shall only be implemented for the purposes of cycle extension after rated thermal power cannot be maintained at 100% rated total core flow in the all-rods-out configuration.

Page 7 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) 5.0 Technical Specifications that Reference the COLR The following Hope Creek Technical Specifications reference this COLR:

Technical Specification Title 2.1 Safety Limits 3/4.2.1 Average Planar Linear Heat Generation Rate 3/4.2.3 Minimum Critical Power Ratio 3/4.2.4 Linear Heat Generation Rate 3/4.3.11 Oscillation Power Range Monitor 3/4.4.1 Recirculation System Recirculation Loops 6.9.1.9 Administrative Controls, Core Operating Limits Report Page 8 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) 5.1 Average Planar Linear Heat Generation Rate LIMITING CONDITION FOR OPERATION All AVERAGE PLANAR LINEAR HEAT GENERATION RATES (APLHGRs) shall be less than or equal to the limits specified in Table 5.1-1 for two recirculation loop operation (TLO).

When the Technical Specification 3.4.1.1 Action Statement a.1.d is entered from that section's Limiting Condition for Operation, reduce the APLHGR limits to the values specified in Table 5.1-1 for single recirculation loop operation (SLO).

Linear interpolation shall be used to determine APLHGR limits as a function of exposure for intermediate values in Table 5.1-1.

TABLE 5.1*1 APLHGR Data for GE14 and GE14i ITAs APLHGR Limit Average Planar Exposure (kW/ft)

MWd/MTU MWd/STU TLO SLO 0.00 0.000 12.82 10.26 16000 14510 12.82 10.26 21090 19130 12.82 10.26 63500 57610 8.00 6.40 70000 63500 5.00 4.00 Page 9 of 24

COLR HOPE CREEK 1 .Rev 8 (Cycle 18) 5.2 Minimum Critical Power Ratio LIMITING CONDITION FOR OPERATION The MINIMUM CRITICAL POWER RATIO (MCPR) shall be equal to or greater than 'the MCPR limit computed from the following steps: .

1. Determine 1: as defined in Appendix A.

NOTE The SLO operating condition MCPR values in Tables 5.2-1, 5.2-2, 5.2-4, and 5.2-5 implement the increase in the MCPR Safety Limit to meet the requirements of Technical Specification 3.4.1.1 Action Statement a.1.c.

2. Linearly interpolate a MCPR value as a function of 1: from the MCPR value at 1:=0 and MCPR value at 1:=1 as specified in Table 5.2-1 and Table 5.2-2 for the appropriate condition. Repeat for each fuel type.
3. For the power dependent MCPR adjustment, when thermal power is ~ 24% rated core thermal power, determine a Kp value by linearly interpolating a Kp value as a function of core rated thermal power from Table 5.2-3. Multiply the MCPR value obtained from Step 2 by the Kp value to determine the power dependent MCPR limit for each fuel type.

When core thermal power is < 24% rated thermal power, no thermal limits are required.

4. For the flow dependent MCPR adjustment, determine the appropriate flow dependent MCPR limit by linearly interpolating between the MCPR limits as a function of rated core flow using the information in Table 5.2-4 (GE14) and Table 5.2-5 (GE14i ITAs).
5. Choose the most limiting (highest value) of the power and flow dependent MCPR limits determined in Steps 3 and 4 as the value for the MCPR limit for the Limiting Condition for Operation for each fuel type.

Note that the MCPR limit is a function of core average scram speed (1:), cycle exposure, core thermal power, total core flow, EOC-RPT operability, the number of reactor coolant recirculation loops in operation, and main turbine bypass operability.

EOC*RPT system operability is defined by Hope Creek Technical Specification 3.3.4.2.

Reactor coolant recirculation loop operation is defined by Hope Creek Technical Specification 3.4.1.1.

Main Turbine Bypass operability is defined by Hope Creek Technical Specification 3.7.7-.

Page 10 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

TABLE 5.2*1 MCPR Operating Limits Cycle Exposure S 9983 MWd/MTU (S 9057 MWd/STU)

Main Turbine Bypass Operable Scram GE14i Operating Condition Speed GE14 ITAs Option A 1.46 1.63 TLO-EOC-RPT Operable B 1.44 1.61 A 1.49 1.66 TLO-EOC-RPT Inoperable B 1.44 1.61 A 1.48 1.66 SLO-EOC-RPT Operable B 1.46 1.63 A 1.61 1.68 SLO-EOC-RPT Inoperable B 1.46 1.63 Scram Speed Option A '1'=1 , Scram Speed Option B'1'=O

=

TLO Two Recirculation Loop Operation

=

SLO Single Recirculation Loop Operation TABLE 5.2*2 MCPR Operating Limits Cycle Exposure> 9983 MWd/MTU (> 9057 MWd/STU)

Main Turbine Bypass Operable Scram GE14i Operating Condition Speed GE14 ITAs Option A 1.60 1.67 TLO-EOC-RPT Operable B 1.44 1.51 A 1.62 1.69 TLO-EOC-RPT Inoperable B 1.46 1.52 A 1.62 1.69 SLO-EOC-RPT Operable B 1.46 1.53 A 1.64 1.71 SLO-EOC-RPT Inoperable B 1.47 1.64 Scram Speed Option A '1'=1 , Scram Speed Option B'1'=O

=

TLO Two Recirculation Loop Operation SLO = Single Recirculation Loop Operation Page 11 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

TABLE 5.2-3 Power Dependent MCPR Multiplier (Kp) Data Core Thermal Power (% of Rated)

Operating Condition 24 45 60 ~100 MCPR Multiplier Kp TLO 1.561 1.280 1.150 1.000 SLO 1.561 1.280 1.150 1.000 Kp is linearly interpolated between core thermal power entries.

The Kp multiplier is the same for both GE14 and GE14i ITAs.

TLO =Two Recirculation Loop Operation SLO =Single Recirculation Loop Operation TABLE 5.2 ..4 Flow Dependent MCPR Limit {MCPRt} for GE14 Core Flow (% of Rated)

Operating 30 60 89.2 105 Condition TLO 1.55 SLO 1.57 MCPRf is linearly interpolated between core flow entries.

=

TLO Two Recirculation Loop Operation

=

SLO Single Recirculation Loop Operation TABLE 5.2-5 Flow Dependent MCPR Limit (MCPRf ) for GE14i ITAs Core Flow (% of Rated)

Operating 30 60 101 105 Condition MCPR Limit TLO 1.62 SLO 1.64 MCPRf is linearly interpolated between core flow entries.

=

TLO Two Recirculation Loop Operation SLO = Single Recirculation Loop Operation Page 12 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) 5.3 Linear Heat Generation Rate LIMITING CONDITION FOR OPERATION The LINEAR HEAT GENERATION RATE (LHGR) shall not exceed the limit computed from the following steps:

NOTE The steps performed in 1 through 6 below should be repeated for both U0 2 and gadolinia bearing fuel rods in each bundle type.

1. Determine the exposure dependent LHGR limit using linear interpolation between the table values in Appendix B.

NOTE For two recirculation loop operation (TLO) utilize steps 1,2, 3, and 6 to determine the LCO LHGR limits.

When the Technical Specification 3.4.1.1 ACTION statement a.1.e is entered from that section's Limiting Condition for Operation (LCO), utilize steps 1, 4, 5, and 6 to determine the LCO LHGR limits for single recirculation loop operation (SLO).

2. For the power dependent LHGR adjustment for TLO, determine a LHGRFAC p value by linearly interpolating a LHGRFAC p value as a function of rated core thermal power from the TLO entries in Table 5.3~1. Multiply the LHGR values obtained from Step 1 by the LHGRFAC p value to determine the power dependent LHGR limit.
3. For the flow dependent LHGR adjustment for TLO, determine a LHGRFACf value by linearly interpolating a LHGRFACf value as a function of rated core flow from the TLO entries in Table 5.3~2. Multiply the LHGR values obtained from Step 1 by the LHGRFACf value to determine the flow dependent LHGR limit.
4. For the power dependent LHGR adjustment for SLO, determine a LHGRFAC p value by linearly interpolating a LHGRFAC p value as a function of rated core thermal power from the SLO entries in Table 5.3~1. Multiply the LHGR values obtained from Step 1 by the LHGRFAC p value to determine the power dependent LHGR limit.
5. For the flow dependent LHGR adjustment for SLO, determine a LHGRFACf value by linearly interpolating a LHGRFACf value as a function of rated core flow from Page 13 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) the SLO entries in Table 5.3~2. Multiply the LHGR values obtained from Step 1 by the LHGRFACf value to determine the flow dependent LHGR limit.

6. Choose the most limiting (lowest value) of the power and flow dependent LHGR limits determined in Steps 2 and 3 (TLO) or 4 and 5 (SLO) as the value for the LHGR limit for the Limiting Condition for Operation.

TABLE 5.3*1 Power Dependent Linear Heat Generation Rate Multiplier {LHGRFAC p}

Core Thermal Power (% of Rated)

Operating Condition 24 60.86  ;:: 100 LHGRFAC p Multiplier TLO 0.603 SLO 0.603 LHGRFAC p is linearly interpolated between core thermal power entries.

The LHGRFAC p multiplier is the same for both GE14 and GE14i ITAs.

=

TLO Two Recirculation Loop Operation

=

SLO Single Recirculation Loop Operation TABLE 5.3-2 Flow Dependent Linear Heat Generation Rate Multiplier (LHGRFACf)

Core Flow (% of Rated)

Operating Condition 30 50 52.7 60 82.2 105 LHGRFACf Multiplier TLO 0.500 0.782 SLO 0.500 0.782 LHGRFACf is linearly interpolated between core flow entries.

The LHGRFACf multiplier is the same for both GE14 and GE14i ITAs.

TLO = Two Recirculation Loop Operation SLO = Single Recirculation Loop Operation Page 14 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18) 5.4 OPRM Setpoints 5.4.1 1.0 Hz Corner Frequency Setpoints LIMITING CONDITION FOR OPERATION Four channels of the OPRM instrumentation shall be OPERABLE. Each OPRM channel period based algorithm amplitude trip setpoint (Sp) shall be less than or equal to the Allowable Value of 1.11.

Additional Information The NRC Safety Evaluation Report, dated 12/22/04, which was issued for Hope Creek License Amendment Number 159 required that the period based algorithm amplitude trip setpoint and confirmation counts be documented in the COLR (Reference 3).

Confirmation count information applicable to Cycle 18 is documented below.

For Sp ::: 1.11, the required minimum number of successive confirmation counts for OPRM setpoint (N2) ::: 14.

5.4.2 OPRM Enabled Region Core Flow Setpoint SURVEILLANCE REQUIREMENT (4.3.11.5)

Applicable for operation at nominal feedwater temperature, FWHOOS, and FFWTR conditions.

Verify OPRM is enabled when thermal power is :::: 26.1 %, as specified in Technical Specification Surveillance Requirement 4.3.11.5, and recirculation drive flow is :s; the value corresponding to 60% of rated core flow in accordance with the Surveillance Frequency Control Program.

Page 15 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Appendix A: Method of Core Average Scram Speed Calculation Page 16 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Method of Core Average Scram Speed, 't, Calculation

'C is defined as 'f = ('f aVe - 'f B )

'fA-T B 112 n.

IN;'f; where: 'fB =0.672+1.65 --?- (0.016) 'f aVe 1 _

=..!::i=:t..-

II IN; IN;

=1 1=1 TA= 0.86 seconds, control rod scram insertion time limit to notch 39 per Specification 3.1.3.3, n =number of surveillance tests performed to date in cycle, Nt =number of active control rods measured in the ith surveillance test, Tj = average scram time to notch 39 of all rods measured in the ith surveillance test, and Nr =total number of active rods measured in Specification 4.1.3.3.a or 4.1.3.3.d.

If T ave s: 'f B , set 1: =0 to apply Option B OLMCPR.

'C shall be 1.0 (-t =1.0) prior to performance of the initial scram time measurements for the cycle in accordance with Specification 4.1.3.3.

Page 17 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Appendix B: Exposure-Dependent Linear Heat Generation Rate Limits Page 18 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Exposure-Dependent Linear Heat Generation Rate Limits The LHGR limits for all fuel and rod types are considered proprietary information of the vendor. Tables 8-1 through 8-6 contain exposure-dependent LHGR limits. The tables are presented in pairs since the LHGR limits are presented at separate peak pellet exposures for U0 2 and gadolinia bearing fuel rods. Several of the bundle types have the same exposure-dependent LHGR limits, and the applicable bundle types are noted before each set of tables. The gadolinia fuel rod limits provided for each bundle type reflect the bounding gadolinia LHGR limit for all gadolinium concentrations occurring in that bundle type. The proRrietary information is enclosed in double square brackets.

The superscript notation { } within each set of brackets is a reference to Item 3 in the affidavit for withholding of proprietary information; it is not a part of the thermal limits information required to be in the Core Operating Limits Report.

Page 19 of 24

COLR HOPE CREEK 1 Rev 8 (Cycfe 18)

Tables B-1 and 8-2 contain limits applicable to the GE14 bundle types that follow.

  • G E14-P1 OCNAB400-14GZ-1 OOT-150-T6-3006
  • GE14-P10CNAB405-6G6.0/11G4.0-100T-150-T6-3313
  • G E14-P 1OCNAB405-15GZ-1 OOT-150-T6-3009
  • GE14-P10CNAB402-15GZ-100T-150-T6-4057
  • GE14-P1 OCNAB401-14G6.0-1 OOT150-T6-4059 TABLE B*1: GE14 LHGR Limits - U0 2 Fuel Rods Peak Pellet Exposure U0 2 LHGR Limit MWd/MTU MWd/STU kW/ft

((

))

TABLE B*2: GE14 LHGR Limits - Gadolinia Bearing Rods Most Limiting Peak Pellet Exposure Gadolinia LHGR Limit MWd/MTU MWd/STU kWIH

((

))

Page 20 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Tables 8-3 and 8-4 contain limits applicable to the GE14 bundle type that follows.

  • GE14-P1 OCNAB402-13G4.0-1 00T-150-T6-4058 TABLE B*3: GE14 LHGR Limits - U02 Fuel Rods Peak Pellet Exposure U02 LHGR Limit MWd/MTU MWd/STU kW/ft

((

))

TABLE B*4: GE14 LHGR Limits - Gadolinia Bearing Rods Most Limiting Peak Pellet Exposure Gadolinia LHGR Limit MWd/MTU MWd/STU kW/ft

((

))

Page 21 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Tables 8-5 and 8-6 contain limits applicable to the GE14i ITA bundle type that follows.

  • GE141-P1 OCCOB379-13GZ-1 00T-150-T6-3309 TABLE 8*5: GE14i ITA LHGR Limits - U0 2 Fuel Rods Peak Pellet Exposure U0 2 LHGR Limit MWd/MTU MWd/STU kW/ft

((

))

TABLE B .. 6:. GE14i ITA LHGR Limits - Gadolinia Bearing Rods Most Limiting Peak Pellet Exposure Gadolinia LHGR Limit MWd/MTU MWd/STU kW/ft

((

))

Page 22 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Appendix C: Backup Stability Protection Page 23 of 24

COLR HOPE CREEK 1 Rev 8 (Cycle 18)

Backup Stability Protection Region Intercepts Table C-1 values reflect the cycle-specific SSP region intercepts determined for Cycle 18 considering nominal feedwater temperature operation and FWHOOS (Reference 6).

Table C-2 provides SSP region intercepts for Cycle 18 for the implementation of FFWTR operation. (Reference 9)

TABLE C.. 1: BSP Region Intercepts for Cycle 18 (Operation Prior to FFWTR)

Region Boundary Intercept  % Power  % Flow Region 1 High Flow Control Line 65.9 49.4 Region 1 Natural Circulation Line 43.0 35.4 Region 2 High Flow Control Line 72.8 58.1 Region 2 Natural Circulation Line 32.2 36.3 TABLE C..2: BSP Region Intercepts for Cycle 18 (Required for FFWTR)

Region Boundary Intercept  % Power  % Flow Region 1 High Flow Control Line 70.2 54.8 Region 1 Natural Circulation Line 41.9 35.5 Region 2 High Flow Control Line 74.0 59.6 Region 2 Natural Circulation Line 32.2 36.3 Region 1 = SSP Scram Region Region 2 = SSP Controlled Entry Region Page 24 of 24

LR-N13-0222 (Total of 3 pages)

Attachment 3 Affidavit for Core Operating Limits Report for Hope Creek Generating Station Unit 1

Global Nuclear Fuel - Americas Affidavit I, Lukas Trosman, state as follows:

(1) I am Manager, Reload Design and Analysis, 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 the Appendix B of the Core Operating Limits Report for Hope Creek Generating Station Unit 1, titled "Exposure-Dependent Linear Heat Generation Rate Limits." GNF-A proprietary information in Appendix B of the Core Operating Limits Report for Hope Creek Generating Station Unit 1. is identified by a dotted underline inside double square brackets. ((Il1j~U?~Dt.Sl.n9.Sl.. l9.J1rJ.5?)~§m.pJ.Sl...~~~)) A "((" marking at the beginning of a table, figure, or paragraph closed with a "))" marking at the end of the table, figure or paragraph is used to indicate that the entire content between the double brackets is proprietary. In each case, the superscript notation {3) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A 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 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (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. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A; ..

Appendix B, Core Operating Limits Report, Hope Creek Generating Station Unit 1 Page 1 of 3

d. Information 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.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information 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 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. Its initial designation as proprietary information, and the subsequent steps taken to prevent 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 of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-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 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 GNF-A's fuel design and licensing methodology.

The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost to GNF-A or its licensor.

Appendix B, Core Operating Limits Report, Hope Creek Generating Station Unit 1 Page 2 of 3

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. 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 determine 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 NRC review costs comprise a substantial investment of time 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.

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 arrive 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 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 GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on'its large investment in developing and obtaining these very valuable analytical tools.

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

Executed at Wilmington, North Carolina this 29th day of November 2011.

Lukas Trosman Manager, Reload Design and Analysis Global Nuclear Fuel - Americas, LLC Appendix B, Core Operating Limits Report, Hope Creek Generating Station Unit 1 Page 3 of 3

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