LR-N18-0011, Supplement to License Amendment Request- Safety Limit Minimum Critical Power Ratio Change. Includes GNF-004N5379-R1-NP, Gnf Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR

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Supplement to License Amendment Request- Safety Limit Minimum Critical Power Ratio Change. Includes GNF-004N5379-R1-NP, Gnf Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR
ML18022A374
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 01/22/2018
From: Carr E
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18023B541 List:
References
LAR H17-07, LR-N18-0011 GNF-004N5379-R1-NP
Download: ML18022A374 (21)
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Text

Enclosure 1 Contains Proprietary Information to be Withheld from Public Disclosure Pursuant to 10 CFR 2.390 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 10 CFR 50.90 LR-N18-0011 LAR H17-07 JAN 22 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

Supplement to License Amendment Request- Safety Limit Minimum Critical Power Ratio Change

References:

1. LR-N 17-0163, "License Amendment Request- Safety Limit Minimum Critical Power Ratio Change", dated November 9, 2017 (ADAMS Accession Nos. ML173178320 and ML173178294)
2. GE Hitachi Nuclear Energy (GEH) Safety Information Communication SC 18-02 RO, dated January 10, 2018 In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request for Hope Creek Generating Station (HCGS). The proposed amendment modifies Technical Specifications (TS) Section 2.1 ("Safety Limits"). Specifically, this change incorporates a revised Safety Limit Minimum Critical Power Ratio (SLMCPR) for two recirculation loop operation (TLO) and single recirculation loop operation (SLO) due to the cycle specific analysis performed by Global Nuclear Fuel (GNF) for HCGS Cycle 22.

GE Hitachi Nuclear Energy (GEH) has determined that the GESAM02 engineering computer program (ECP), which is used in the calculation of the SLMCPR, contained an error in its pseudo-random number generator. No change to the proposed Hope Creek Cycle 22 SLMCPR values found in LAR H17-07 is required due to this error. GEH has documented its evaluation in Safety Information Communication SC 18-02 RO (Reference 2) which stated in its conclusion that the reported SLMCPR TS values for HCGS Cycle 22 remain adequate. However, for completeness and accuracy of information, PSEG is providing in enclosures 1 and 2, the revised versions of the GNF SLMCPR TS Change letter as a supplement to LAR H17-07.

Enclosure 1 transmitted herewith contains proprietary information. When separated from enclosure 1, this transmittal document is decontrolled.

JAN *22 2018 Page 2 LR-N18-0011 LAR H17-07 Enclosure 1, GNF Report 004N5379-R1-P, specifies the required SLMCPRs for HCGS Cycle

22. Enclosure 1 contains information proprietary to GNF. GNF requests that the document be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4 ). Enclosure 2 contains a non-proprietary version of the GNF Report, 004N5379-R1-NP. An affidavit supporting this request is contained in Enclosure 3.

PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50. 92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91 (b)(1 ), a copy of this supplement to license amendment request LAR H17-07 has been sent to the State of New Jersey.

There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please contact Mr. Lee Marabella at (856) 339-1208.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on -+-(/;?,-'- __;)-;--'-__;::_ ;7_- 7_-

(Date)

Respectfully,

./

Eric Carr Site Vice President Hope Creek Generating Station

Enclosures:

1. Proprietary Version of GNF Report 004N5379-R1-P
2. Non-Proprietary Version of GNF Report 004N5379-R1-NP
3. GNF Affidavit in Support of Request to Withhold Information cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. MacEwen, Hope Creek Commitment Tracking Coordinator

LR-N18-0011 Enclosure 2 Non- Proprietary Version of GNF Report 004N5379-R1-NP

I .

December 2017 l

GNF-004N5379- Rl-NP Non-Proprietary Information- Class I (Public)

GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Hope Creek Cycle 22 Copyright 2017 Global Nuclear Fuel- Americas, LLC All Rights Reserved

GNF -004N 5379-Rl-NP Non-Proprietary Information- Class I (Public)

Information Notice This is a non-proprietary version of the document GNF-004N5379-Rl-P, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here (( )).

Important Notice Regarding Contents of this Report Please Read Carefully The design, engineering, and other information contained in this document is furnished for the purpose of providing information regarding the requested changes to the Technical Specification SLMCPR for PSEG Hope Creek. The only undertakings of GNF-A with respect to information in this document are contained in the contract between GNF-A and PSEG, and nothing contained in this document shall be construed as changing that contract. The use of this information by anyone other than PSEG, or for purposes other than those for which it is intended is not authorized; and with respect to any unauthorized use, GNF-A makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.

Information Notice Page 2 of 14

GNF-004N5379-Rl-NP Non-Proprietary Information - Class I (Public)

Revision History 0 October 20 17 Initial issue Table 1: Revised the calculated Monte Carlo SLO and TLO SLMCPR values for the previous and current cycle limiting 1 December 201 7 cases at rated power rated core flow and rated power minimum core flow.

Revision History Page 3 of 14

GNF-004N5379-R1-NP Non-Proprietary Information - Class I (Public)

Table of Contents 1.0 Summary ...................................... ................................................................. ...................... 5 2.0 Regulatory Basis ...................................................................................... ....................... ..... 5 3.0 Methodology ........................................................................................................................ 5 3.1. Methodology Restrictions ................................................................................................. 6 4.0 Discussion............................................................................................................................. 7 4.1. Major Contributors to SLMCPR Change .......................................................................... 7 4.2. Deviations from Standard Uncertainties............................................................................ 8 4.2. 1. R-Factor ......... ............ .............................................. ............ ...... . ...................... 8 4.2.2. Core Flow Rate and Random Effective TIP Reading .......................... ................. ... 8 . ..

4.2.3. Flow Area Uncertainty................................................................................................ 9 4.2.4. Fuel Axial Power Shape Penalty................................................................................. 9 4.3. Additional SLMCPR Licensing Conditions ...................................................................... 9 5.0 References ........................ fl ************************************************************************************************* 10 List of Tables Table 1. Monte Carlo SLMCPR .................................................................................................. 12 Table 2. Description of Core ........................................................................................................ 13 Table 3. Deviations from Standard Uncertainties ........................................................................ 14 Page 4 of 14

GNF-004N 53 79-R 1-NP Non-Proprietary Information - Class I (Public) 1.0 Summary The requested changes to the Technical Specification (TS) Safety Limit Minimum Critical Power Ratio (SLMCPR) values are 1.09 for Two Recirculation Loop Operation (TLO) and 1.12 for Single Recirculation Loop Operation (SLO) for Hope Creek Cycle 22. This SLMCPR change is applicable to the power level proposed in the Thermal Power Optimization (TPO) license amendment (Reference 1) currently under review as well as to the current power level.

Additional details are provided in Table 1.

A main contributor to the change in the limiting case for Cycle 22 is the bundle pin-by-pin power/R-Factor distribution which produces a flatter core power distribution than that of the limiting case in the previous cycle.

2.0 Regulatory Basis 10 Code of Federal Regulations (CFR) 50.36(c)( 1), "Technical Specifications," requires that power reactor facility TS include safety limits for process variables that protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity. The fuel cladding is one of the physical barriers that separate the radioactive materials from the environment. The purpose of the SLMCPR is to ensure that Specified Acceptable Fuel Design Limits (SAFDLs) are not exceeded during steady state operation and analyzed transients.

General Design Criterion (GDC) 10, "Reactor Design," of Appendix A to 10 CFR 50 states that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that the SAFDLs are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.

Guidance on the acceptability of the reactivity control systems, the reactor core, and fuel system design is provided in NUREG-0800, " Standard Review Plan [ SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants." Specifically, SRP Section 4.2, "Fuel System Design," specifies all fuel damage criteria for evaluation of whether fuel designs meet the SAFDLs. SRP Section 4.4, "Thermal Hydraulic Design," provides guidance on the review of thermal-hydraulic design in meeting the requirement of GDC 10 and the fuel design criteria established in SRP Section 4.2.

3.0 Methodology GNF performs SLMCPR calculations in accordance with NEDE-240 1 1-P-A "General Electric Standard Application for Reactor Fuel ( GE STAR II)" (Reference 2) for plants such as Hope Creek that are equipped with the GNF ACUMEN core monitoring system by using the following Nuclear Regulatory Commission (NRC) approved methodologies and uncertainties:

Summary Page 5 of 14

GNF-004N5379-R 1-NP Non-Proprietary Information - Class I (Public)

  • NEDC-3260 1P-A, "Methodology and Uncertainties for Safety Limit MCPR Evaluations," (Reference 3).
  • NEDC-32694P-A, "Power Distribution Uncertainties for Safety Limit MCPR Evaluations," (Reference 4).

(Reference 5).

These methodologies were used for the Hope Creek Cycle 2 1 and Cycle 22 SLMCPR calculations.

3.1. Methodology Restrictions Four restrictions were identified on page 3 of NRC's Safety Evaluation (SE) relating to the General Electric (GE) Licensing Topical Reports (LTRs) NEDC-3260 1P, NEDC-32694P, and in Amendment 25 to NEDE-240 1 1-P-A (Reference 6).

The four restrictions were addressed for GE 14 in FLN-200 1-0 16 "Confirmation of 10x 10 Fuel Design Applicability to Improved SLMCPR" (Reference 7) and FLN-200 1- 17 "Power Distribution and R-Factor Methodologies" (Reference 8).

The following statement was extracted from the generic compliance report for the GNF2 fuel assembly design (Reference 9) that GNP sent to the NRC in March of 2007:

"The NRC Safety Evaluation (SE) for NEDC-32694P-A provides four actions to follow whenever a new fuel design is introduced. These four conditions are listed in Section 3 of the SE. In the last paragraph of Section 3.2.2 of the Technical Evaluation Report included in the SE are the statements "GE has evaluated this effect for the 8x8, 9x9, and 1 Ox 10 lattices and has indicated that the R-Factor uncertainty will be increased ... to account for the correlation of rod power uncertainties" and "it is noted that the effect of the rod-to-rod correlation has a significant dependence on the fuel lattice (e.g., 9x9 versus 1 Ox 10).

Therefore, in order to insure the adequacy of the R-Factor uncertainty, the effect of the correlation of rod power calculation uncertainties should be reevaluated when the NEDC-3260 1P methodology is applied to a new fuel lattice."

Therefore, the definition of a new fuel design is based on the lattice array dimensions (e.g., NxN). Because GNF2 is a 10x 10, and the evaluations in NEDC-32694P-A include 10x 10, then these four actions are not applicable to GNF2."

In an NRC audit report (Reference 10) for this document, Section 3.4. 1 page 59 states:

Methodology Page 6 of 14

GNF-004N5379-R 1-NP Non-Proprietary Information - Class I (Public)

"The NRC staffs SE of NEDC-32694P-A (Reference 19 of NEDC-33270P) provides four actions to follow whenever a new fuel design is introduced. These four conditions are listed in Section 3.0 of the SE. The analysis and evaluation of the GNF2 fuel design was evaluated in accordance with the limitations and conditions stated in the NRC staffs SE, and is acceptable."

Another methodology restriction is identified on page 4 of the NRC's SE relating to the GE LTR NEDC-32505P (Reference 1 1). Specifically, it states that "if new fuel is introduced, GENE must confirm that the revised R-factor method is still valid based on new test data."

NEDC-32505P addressed the GE 12 10x 10 lattice design (i.e., how the R-Factor for a rod is calculated based upon its immediate surroundings (fuel rods, water rods or channel wall)).

Validation is provided by the fact that the methodology generates accurate predictions of Critical Power Ratio (CPR) with reasonable bias and uncertainty. The applicability of the R-Factor method is coupled and documented (along with fuel specific additive constants) with the GEXL correlation development (References 12 and 13), which is submitted as a part of GESTAR II compliance for each new fuel product line.

4.0 Discussion In this discussion, the TLO nomenclature is used for two recirculation loops in operation, and the SLO nomenclature is used for one recirculation loop in operation.

Table 2 provides the description of the current cycle and previous cycle for the reference loading pattern as defined by NEDE-240 1 1-P-A (Reference 2).

4.1. Major Contributors to SLMCPR Change In general, for a given power-flow statepoint, the calculated safety limit is dominated by two key parameters: ( 1) flatness of the core bundle-by-bundle Minimum Critical Power Ratio (MCPR) distribution, and (2) flatness of the bundle pin-by-pin power/R-Factor distribution. Greater flatness in either parameter yields more rods susceptible to boiling transition and thus a higher calculated SLMCPR. Therefore, the calculated SLMCPR may change whenever there are changes to the core configuration or to the fresh fuel designs. The plant-cycle specific SLMCPR methodology accounts for these factors.

The current cycle core design has produced similar results to the previous cycle core design, that is, the SLMCPR values are within 0.005 for the TLO limiting case. The change in the calculated SLMCPR can be attributed to cycle-to-cycle variation. A key component of this variation is both the bundle-by-bundle MCPR distribution as well as the pin-by-pin power/R-Factor distribution.

The only effect the increase in power level has is a difference in the flow uncertainty, which decreases due to the increase in the minimum core flow.

Discussion Page 7 of 14

GNF-004N5379-R1-NP Non-Proprietary Information - Class I (Public)

For the limiting TLO case, the current fresh fuel pin-by-pin power/R-Factor distribution is flatter than the previous cycle fresh fuel pin-by-pin power/R-Factor distribution while the core bundle bybundle MCPR distribution is slightly more peaked than the previous cycle. While the current cycle core bundle-by-bundle MCPR distribution is slightly more peaked, the change in the fresh fuel pin-by-pin power/R-Factor is more significant, thus the combination of the two distributions produces a flatter core power distribution. The overall core power distribution flatness along with the cycle-to-cycle variation in the core loading tends to produce an increase in the calculated SLMCPR.

The current cycle's change in the Monte Carlo SLO SLMCPR from the previous cycle is consistent with the Monte Carlo TLO SLMCPR change between the two cycles. The SLO values are greater than the TLO values as expected due to the increase in uncertainties used for the SLO case.

4.2. Deviations from Standard Uncertainties Table 3 provides a list of deviations from NRC-approved uncertainties (References 3 and 4). A discussion of deviations from these NRC-approved values follows, all of which are conservative relative to NRC-approved values.

4.2.1. R-Factor GNF has generically increased the GEXL R-Factor uncertainty from (( )) to account for an increase in channel bow due to the phenomena called control blade shadow corrosion-induced channel bow, which is not accounted for in the channel bow uncertainty component of the approved R-Factor uncertainty. Reference 14 technically justifies that a GEXL R-Factor uncertainty of (( )) accounts for a channel bow uncertainty of up to

(( )). The Hope Creek Cycle 22 analysis shows an expected channel bow uncertainty of

(( )), which is bounded by a GEXL R-Factor uncertainty of (( )). Thus, the use of a GEXL R-Factor uncertainty of (( )) adequately accounts for the expected control blade shadow corrosion-induced channel bow. The effect of this change is considered not significant (i.e., < 0.005 increase on SLMCPR).

4.2.2. Core Flow Rate and Random Effective TIP Reading In Reference 15, GNF committed to the expansion of the state points used in the determination of the SLMCPR. Consistent with the Reference 15 commitments, GNF performs analyses at the rated core power and minimum licensed core flow point in addition to analyses at the rated core power and rated core flow point. The approved SLMCPR methodology is applied at each state point that is analyzed.

Discussion Page 8 of 14

GNF-004N5379-R 1-NP Non-Proprietary Information - Class I (Public)

For the TLO calculations performed at 97. 1% core flow, the approved uncertainty values for the core flow rate (2.5%) and the random effective Traversing In-Core Probe (TIP) reading ( 1.2%)

are conservatively adjusted by dividing them by 97. 11 100.

The core flow and random TIP reading uncertainties used in the SLO minimum core flow SLMCPR analysis remain the same as in the rated core flow SLO SLMCPR analysis because these uncertainties (which are substantially larger than used in the TLO analysis) already account for the effects of operating at reduced core flow.

4.2.3. Flow Area Uncertainty GNF has calculated the flow area uncertainty for GNF2 and GE 14 using the process described in Section 2.7 of Reference 3. It was determined that the flow area uncertainty for GNF2 and GE 14 is conservatively bounded by a value of (( )). Because this is larger than the Reference 3 value of (( )) the bounding value was used in the SLMCPR calculations. The effect of this change is considered not significant (i.e., < 0.005 increase on SLMCPR).

4.2.4. Fuel Axial Power Shape Penalty The GEXL correlation critical power uncertainty and bias are established for each fuel product line according to a process described in NEDE-240 1 1-P-A (Reference 2).

GNF determined that higher uncertainties and non-conservative biases in the GEXL correlations for certain types of axial power shapes could exist relative to the NRC-approved methodology values (References 16, 17, 18, and 19). The GE 14 and GNF2 product lines are potentially affected in this manner only by Double-Hump (D-H) axial power shapes.

The D-H axial power shape did not occur on any of the limiting bundles (i.e., those contributing to the 0. 1% of rods susceptible to transition boiling) in the current and/or prior cycle limiting cases. Therefore, D-H power shape penalties were not applied to the GEXL critical power uncertainty or bias.

4.3. Additional SLMCPR Licensing Conditions As shown in Table 1, there are no added penalties applied to the calculated SLMCPR. Cycle 22 will be the second cycle in which Hope Creek does not apply an added penalty to the calculated SLMCPR. This is permitted by the approvals presented in Reference 20.

Discussion Page 9 of 14

GNF-004N5379-R 1-NP Non-Proprietary Information - Class I (Public) 5.0 References

1. Letter, Eric Carr (PSEG) to NRC Document Control Desk, "License Amendment Request for Measurement Uncertainty Recapture (MUR) Power Uprate, " LR-N 17-0044, LAR H 17-03, July 7, 20 17.
2. Global Nuclear Fuel, " General Electric Standard Application for Reactor Fuel, "

NEDE-240 1 1-P-A, Revision 24, March 20 17.

3. GE Nuclear Energy, "Methodology and Uncertainties for Safety Limit MCPR Evaluations, " NEDC-3260 IP-A, August 1999.
4. GE Nuclear Energy, "Power Distribution Uncertainties for Safety Limit MCPR Evaluations, " NEDC-32694P-A, August 1999.
5. GE Nuclear Energy, "R-Factor Calculation Method for GEll, GE 12 and GE 13 Fuel, "

NEDC-32505P-A, Revision 1, July 1999.

6. Letter, Frank Akstulewicz (NRC) to Glen A. Watford (GNF-A), "Acceptance for Referencing of Licensing Topical Reports NEDC-3260 1P, Methodology and Uncertainties for Safety Limit MCPR Evaluations; NEDC-32694P, Power Distribution Uncertainties for Safety Limit MCPR Evaluation; and Amendment 25 to NEDE-240 1 1-P-A on Cycle-Specific Safety Limit MCPR (TAC Nos. M97490, M99069 and M9749 1), " MFN-003-099, March 1 1, 1999.
7. Letter, Glen A. Watford (GNF-A) to NRC Document Control Desk with attention to R. Pulsifer (NRC), "Confirmation of 1 Ox 10 Fuel Design Applicability to Improved SLMCPR, Power Distribution and R-Factor Methodologies, " FLN-200 1-0 16, September 24, 200 1.
8. Letter, Glen A. Watford (GNF-A) to NRC Document Control Desk with attention to J. Donoghue (NRC), "Confirmation of the Applicability of the GEXL 14 Correlation and Associated R-Factor Methodology for Calculating SLMCPR Values in Cores Containing GE 14 Fuel, " FLN-200 1-0 17, October 1, 200 1.
9. Letter, Andrew A. Lingenfelter (GNF-A) to NRC Document Control Desk with cc to MC Honcharik (NRC), "GNF2 Advantage Generic Compliance with NEDE-240 1 1P-A (GESTAR II), NEDC-33270P, March 2007, and GEXL17 Correlation for GNF2 Fuel, NEDC-33292P, March 2007, " FLN-2007-0 1 1, March 14, 2007.
10. Memorandum, Michelle C. Honcharik (NRC) to Stacy L. Rosenberg (NRC), "Audit Report for Global Nuclear Fuels GNF2 Advantage Fuel Assembly Design GESTAR II Compliance Audit, " September 25, 2008. (ADAMS Accession Number ML081630579)

References Page 10 of 14

GNF-004N5379-R 1-NP Non-Proprietary Information - Class I (Public) 1 1. Letter, Thomas H. Essig (NRC) to Glen A. Watford ( GNF-A), "Acceptance for Referencing of Licensing Topical Report NEDC-32505P, Revision 1, 'R-factor Calculation Method for GE 1 1, GE 12 and GE 13 Fuel, "' (TAC Nos. M99070 and M9508 1), " MFN-046-98, January 1 1, 1999.

12. Global Nuclear Fuel, "GEXL 14 Correlation for GE 14 Fuel, " NEDC-3285 1P-A, Revision 5, April 20 1 1.
13. Global Nuclear Fuel, " GEXL 17 Correlation for GNF2 Fuel, " NEDC-33292P, Revision 3, April 2009.
14. Letter, John F. Schardt ( GNF-A) to NRC Document Control Desk with attention to Mel B. Fields (NRC), "Shadow Corrosion Effects on SLMCPR Channel Bow Uncertainty, "

FLN-2004-030, November 10, 2004.

15. Letter, Jason S. Post (GENE) to NRC Document Control Desk with attention to Chief, Information Management Branch, et al. (NRC), "Part 2 1 Final Report: Non-Conservative SLMCPR, " MFN 04- 108, September 29, 2004.
16. Letter, Glen A. Watford ( GNF-A) to NRC Document Control Desk with attention to Joseph E. Donoghue (NRC), "Final Presentation Material for GEXL Presentation -

February 1 1, 2002, " FLN-2002-004, February 12, 2002.

17. Letter, Glen A. Watford (GNF-A) to NRC Document Control Desk with attention to Alan Wang (NRC), "NRC Technology Update -Proprietary Slides -July 3 1 - August 1, 2002, " FLN-2002-0 15, October 3 1, 2002.
18. Letter, Jens G. Munthe Andersen ( GNF-A) to NRC Document Control Desk with attention to Alan Wang (NRC), " GEXL Correlation for 10X 10 Fuel, " FLN-2003-005, May 3 1, 2003.
19. Letter, Andrew A. Lingenfelter ( GNF-A) to NRC Document Control Desk with cc to MC Honcharik (NRC), "Removal of Penalty Being Applied to GE 14 Critical Power Correlation for Outlet Peaked Axial Power Shapes, " FLN-2007-03 1, September 18, 2007.
20. GE Hitachi Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains, " NEDC-33 173P-A, Revision 4, November 20 12.

References Page 1 1 of 14

GNF-004N5379-Rl-NP Non-Proprietary Information - Class I (Public)

Table 1. Monte Carlo SLMCPR Limiting Cycle Exposure Point Beginning of Cycle (BOC) I EOC EOC EOC EOC Middle of Cycle (MOC) I End of Cvcle (EOC Cycle Exposure at Limiting 10,000 10,000 9,600 9,600 Point (MWdiST

((

))

Requested Change to the TS NIA 1.09 (TLO) 1 1. 12 (SLO)

SLMCPR Table 1. Monte Carlo SLMCPR Page 12 of 14

GNF-004N 5379-Rl-NP Non-Proprietary Information - Class I (Public)

Table 2. Description of Core Core Rated Power (MWt) I 3,840 I 3,902 Minimum Flow at Rated Power 94.8 97. 1

(% rated core flow)

Number of Bundles in the Core 764 764 Batch Sizes and Types:

(Number of Bundles in the Core)

Fresh 2 12 GNF2 200 GNF2 Once-Burnt 220 GE 14 2 12 GNF2 Twice-Burnt 224 GE 14 220 GE 14 Thrice-Burnt or more 108 GE 14 132 GE 14 Fresh Fuel Batch Average Enrichment I 3.82 I 3.82 (Weight%)

Core Monitoring System I 3DMonicore and ACUMEN I ACUMEN Table 2. Description of Core Page 13 of 14

GNF-004N5379-Rl-NP Non-Proprietary Information - Class I (Public)

Table 3. Deviations from Standard Uncertainties GEXL R-Factor (( )) (( )) (( ))

Random Effective TIP Reading All TLO Cases at Rated Power and Minimum Flow (Non-Maximum 1.2 1.27 1.24 Extended Load Line Limit Analysis Plus (MELLLA+))

Reactor Pressure Measurement (( )) (( )) (( ))

Channel Flow Area Variation (( )) (( )) (( ))

Total Core Flow Measurement All TLO Cases at Rated Power and I 2.5 I 2.64 I 2.57 Minimum Flow (Non-MELLLA+)

Table 3. Deviations from Standard Uncertainties Page 14 of 14

LR-N18-0011 Enclosure 3 GNF Affidavit in Support of Request to Withhold Information

Global Nuclear Fuel- Americas AFFIDAVIT I, Charles F. Lamb, state as follows:

( 1) I am the Engineering 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 GNF proprietary report GNF-004N5379-R 1-P, "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR Hope Creek Cycle 22, " dated December 20 17. GNF proprietary information in GNF-004N5379-R 1-P is identified by a dotted underline inside double square brackets. ((.T.b)--nt!W.YjUlJ..l__y__g].].p_l_,_{_ )) GNF proprietary information in some tables is identified with double square brackets before and after the object. In each case, the superscript notation {J} 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 oflnformation 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, 975 F2d 87 1 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (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;
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.

GNF-004N5379-R 1-P Affidavit Page 1 of 3

(5) To address 10 CPR 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 GNP-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 GNP-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 GNP-A.

(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 GNP-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 GNP-A's fuel design and licensing methodology. The development of this methodology, along with the testing, development and approval was achieved at a significant cost to GNP-A.

The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from an extensive experience database that constitutes a major GNP-A asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNP-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNP-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 GNP-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.

GNP-004N5379-Rl-P Affidavit Page 2 of 3

GNFA'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 GNFA 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 is true and correct.

Executed on this 18th day of December 20 17.

Charles F. Lamb Engineering Manager, Reload Design and Analysis Global Nuclear Fuel- Americas, LLC 390 1 Castle Hayne Road Wilmington, NC 2840 1 CharlesF.Lamb@ge.com GNF004N5379-Rl-P Affidavit Page 3 of 3

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