Text

GE-NE-0000-0024-6517-R0, Safer/Gestr Loss-of-Coolant Accident Analysis for GE14 Fuel.
	ML100190077
Person / Time
Site:	Nine Mile Point
Issue date:	03/31/2004
From:	Stott J; General Electric Co
To:	; Office of Nuclear Reactor Regulation
References
	DRF 0000-0016-8320, TAC ME1476 GE-NE-0000-0024-6517NP-R0
	Download: ML100190077 (99)
	v • d • e

ATTACHMENT 6 GE-NE-0000-0024-6517-RO (NON-PROPRIETARY), SAFER/GESTER LOSS-OF-COOLANT ACCIDENT ANALYSIS FOR GE14 FUEL Certain information, considered proprietary by GEH, has been deleted from this Attachment. The deletions are identified by double square brackets.

Nine Mile Point Nuclear Station, LLC December 23, 2009

ENCLOSURE 2 GE-PPO-1GYEF-KG1-498 GE-NE-0000-0024-6517-RO, non-proprietary version NON-PROPRIETARY NOTICE This is a non-proprietary version of the Enclosure I of GE-PPO- IGYEF-KG 1-498 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 (( I].

0 GE-NE-0000-0024-6517NP-RO DRF 0000-0016-8320 Class I March 2004 Non-Proprietary Information Project Task Report Constellation Energy Nine Mile Point-2 SAFER/GESTR Loss-of-Coolant Accident Analysis for GE14 Fuel 0 Copyright 2003 GeneralElectric Company Principal Contributor: J.J. Stott Principal Verifier: Davood Abdollahian

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION INFORMATION NOTICE This is a non-proprietary version of the document GE-NE 0000-0024-6517, Revision 0, 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 only undertakings of GE Hitachi Nuclear Energy Americas LLC ("GEH") with respect to information in this document are contained in contracts between GEH and its customers, and nothing contained in this document shall be construed as changing those contracts. The use of this information by anyone other than those participating entities and for any purposes other than those for which it is intended is not authorized; and with respect to any unauthorized use, GEH makes no representation or warranty, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document.

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GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION TABLE OF CONTENTS Page

1.0 INTRODUCTION

1

2.0 DESCRIPTION

OF MODELS 1 3.0 ANALYSIS PROCEDURE 1 3.1. Licensing Criteria 1 3.2. SAFER/GESTR-LOCA Licensing Methodology 1 3.3. Generic Analysis 1 3.4. Nine Mile Point-2 Specific Analysis 1 4.0 INPUT TO ANALYSIS 2 5.0 RESULTS 4 5.1. Large Recirculation Line Breaks 4 5.2. Small Recirculation Line Breaks 5 5.3. Non-Recirculation Line Breaks 5 5.4. Alternate Operating Modes 6

6.0 CONCLUSION

S 12

7.0 REFERENCES

14 Appendix A Operating Plant Licensing Parameters (OPL4/5) 35 0

iii

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION LIST OF TABLES Table Title Page TABLE 1 PLANT OPERATIONAL PARAMETERS 2 TABLE 2 GE14 FUEL PARAMETERS 3 TABLE 3 SINGLE FAILURE SENSITIVITY STUDY FOR LARGE RECIRCULATION LINE BREAKS 10 TABLE 4 BREAK AREA SENSITIVITY STUDY FOR SMALL RECIRCULATION LINE BREAKS WITH HPCS-D/G WITH 6ADS AVAILABLE 10 TABLE 5 BREAK AREA SENSITIVITY STUDY FOR SMALL RECIRCULATION LINE BREAKS WITH HPCS-D/G WITH 5ADS AVAILABLE 11 TABLE 6 BREAK AREA SENSITIVITY STUDY FOR SMALL RECIRCULATION LINE BREAKS WITH HPCS-D/G WITH 7ADS AVAILABLE 11 TABLE 7 ECCS-LOCA ANALYSIS RESULTS FOR GE14 12 TABLE 8 THERMAL LIMITS FOR GE14 13 0

0 iv

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION LIST OF FIGURES Title Page Figure 1-a Water Level in Hot and Average Channels. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 15 Figure 1-b Reactor Vessel Pressure. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 16 Figure 1-c Peak Cladding Temperature. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 17 Figure 1-d Heat Transfer Coefficients. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 18 Figure 1-e ECCS Flows. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 19 Figure 2-a Water Level in Hot and Average Channels. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions] 20 Figure 2-b Reactor Vessel Pressure. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions] 21 Figure 2-c Peak Cladding Temperature. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions]

22 Figure 2-d Heat Transfer Coefficients. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions]

23 Figure 2-e ECCS Flows. Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions] 24 Figure 3-a Water Level in Hot and Average Channels. Limiting Small Recirculation Line Break (0.08ft2), HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 25 Figure 3-b Reactor Vessel Pressure. Limiting Small Recirculation Line Break (0.08ft2),

HPCS-D/G Failure (1 LPCS +3 LPCI + ADS Available) [Nominal Assumptions] 26 v

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION Figure 3-c Peak Cladding Temperature. Limiting Small Recirculation Line Break 2

(0.08ft ), HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 27 Figure 3-d Heat Transfer Coefficients. Limiting Small Recirculation Line Break (0.08ftw),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 28 Figure 3-e ECCS Flows. Limiting Small Recirculation Line Break (0.08ft2), HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Nominal Assumptions] 29 Figure 4-a Water Level in Hot and Average Channels. Limiting Small Recirculation Line Break (0.07ft2 ), HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions] 30 Figure 4-b Reactor Vessel Pressure. Limiting Small Recirculation Line Break (0.07fte),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions]

31 Figure 4-c Peak Cladding Temperature. Limiting Small Recirculation Line Break (0.07ft2 ), HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions] 32 0 Figure 4-d Heat Transfer Coefficients. Limiting Small Recirculation Line Break (0.07ft2 ),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions]

33 Figure 4-e ECCS Flows. Limiting Small Recirculation Line Break (0.07ft2), HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available) [Appendix K Assumptions] 34 0

vi

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION

1.0 INTRODUCTION

The purpose of this document is to supplement the ECCS-LOCA evaluation results for Nine Mile Point-2 documented in the Reference 1 analysis. Specifically, using the limiting cases as defined in Reference 1, results are provided for GE14 fuel. The plant ECCS parameters and analysis methodology are consistent with those defined in Reference 1.

2.0 DESCRIPTION

OF MODELS Consistent with Reference 1, the ECCS-LOCA results are generated using the standard four GE-NE computer models. These models are LAMB, TASC, SAFER and GESTR-LOCA.

See Reference 1 for further details.

3.0 ANALYSIS PROCEDURE 3.1. LICENSING CRITERIA Consistent with Reference 1, the acceptance criteria for the ECCS-LOCA results are based on the Code of Federal Regulations, 10 CFR 50.46 (Reference 2). See Reference 1 for further details.

3.2. SAFER/GESTR-LOCA LICENSING METHODOLOGY Consistent with Reference 1, the ECCS-LOCA analysis was generated using the SAFER/GESTR-LOCA licensing methodology (References 3 and 4) as approved by the NRC (References 5 and 6).

3.3. GENERIC ANALYSIS The generic ECCS-LOCA analysis for the BWR/5-6 product line is described in Reference 3.

3.4. NINE MILE POINT-2 SPECIFIC ANALYSIS The Nine Mile Point-2 specific analysis in Reference 1 demonstrated that the nominal and Appendix K PCT trends as a function of break size were consistent with one another and with the generic BWR/5-6 results. In the current GE14 large break analysis, the DBA recirculation suction break with ((

0]

1

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION 4.0 INPUT TO ANALYSIS The Operating Parameters List 4/5 (OPL4/5) parameters used in this analysis are given in Appendix A. The plant heat balance conditions utilized in this analysis are presented in Table 1. The GE14 fuel parameters are given in Table 2.

Table 1 Plant Operational Parameters Plant Parameters Nominal Appendix K Core Thermal Power (MWt) 3467 3536 Core Thermal Power 100.0 102.0

(% of Licensed Thermal Power)

Core Flow (Mlb/hr) 108.5 108.5 Core Flow (% rated) 100.0 100.0 Vessel Steam Dome Pressure (psia) 1055 1055 0

2

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION Table 2 GE14 Fuel Parameters Fuel Parameter Analysis Value PLHGR (kW/ft) -LOCA Analysis Limit ((

-Appendix K

-Nominal MAPLHGR (kW/ft) -LOCA Analysis Limit

-Appendix K

-Nominal Radial Peaking Factor' Worst Case Pellet Exposure for ECCS Evaluation (MWd/MTU)

LHGR - Exposure Limit2 Curve S (kW/ft vs. MWd/MTU)

Initial Operating MCPR -LOCA Analysis Limit

-Appendix K

-Nominal Axial Peaking Factor' Number of Fuel Rods per Bundle 1Peaking Factors used in the rated Appendix K case.

2 The curve shown corresponds to the U0 2 rod.

3

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION

5.0 RESULTS 5.1. LARGE RECIRCULATION LINE BREAKS

((

)) Several large recirculation suction line breaks were analyzed for GE14 with Nominal and Appendix K assumptions to confirm the limiting break and single failure combination. These analyses include dryout times from LAMB/TASC calculations that determined early boiling transition occurs in the top four axial fuel nodes. For all two-loop large break cases, a more conservative assumption of early boiling transition at the hot node (early dryout of the top 5 axial fuel nodes) was used. This resulted in a nominal PCT for the limiting two-loop case that was higher than the nominal SLO PCT (with an acceptable SLO MAPLHGR / PLHGR multiplier). The limiting nominal two-loop PCT must exceed the nominal SLO PCT in order to ensure that the SLO condition is bounded by the two-loop condition. The results of these analyses are given in Table 4 and Figures 1 and 2. ((

1]

For the maximum recirculation suction line break with HPCS-D/G failure and nominal assumptions, there is a rapid vessel depressurization due to vessel inventory loss through the break (Figure lb). This mass loss causes core uncovery beginning at approximately 26 seconds into the event (Figure la). Before core uncovery there is an early bundle heatup due to the stored energy in the bundle (Figure 1c) caused by early dryout of the upper axial nodes in the bundle (Figure 1d) which is a result of the rapid core flow coastdown. As the saturation pressure drops due to vessel depressurization the nodes rewet (Figure 1d) causing a temperature decrease. The LPCS begins injection after the pressure permissive is reached and the injection valve opens. This occurs at approximately 68 seconds into the event (Figure le).

The LPCI begins injection after the pressure permissive is reached and the discharge valve closes. This occurs at approximately 73 seconds into the event (Figure le). When the core uncovers, there is a second bundle heatup until the level in the core fully recovers at approximately 100 seconds (Figure la).

The system response to a maximum recirculation suction line break with HPCS-D/G failure and Appendix K assumptions is similar to the case with nominal assumptions. There is a rapid vessel depressurization due to vessel inventory loss through the break (Figure 2b) but is slightly faster due to higher break flow from the Appendix K Moody Slip Flow Model. This higher mass loss also causes an earlier core uncovery beginning at approximately 20 seconds into the event (Figure 2a). Before core uncovery there is an early bundle heatup due to the stored energy in the bundle (Figure 2c) caused by early dryout of the upper axial nodes in the bundle that is a result of the rapid core flow coastdown. The rods remain in film boiling for a longer time than the nominal case because of the more restrictive Appendix K assumptions, which do not allow the bundle to change from film boiling to transition boiling until the cladding superheat falls below 300'F. The LPCS and LPCI begin injection following the same timing as for that with nominal conditions. The temperature decreases as the saturation 4

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION pressure drops due to vessel depressurization until the core uncovers. Then there is a second bundle heatup, which lasts until the heat transfer regime in the hot rod fully recovers at approximately 140 seconds into the event (Figure 2d). Overall the bundle heatup for the Appendix K case is higher than the nominal case due to higher bundle power and decay heat.

5.2. SMALL RECIRCULATION LINE BREAKS The most limiting single failure for small recirculation line breaks is the HPCS-D/G. The small break cases were reanalyzed for GE14 with Nominal and Appendix K assumptions assuming 6 ADS valves available in addition to the postulated single failure to determine the small break with the highest PCT. The results of these analyses are given in Table 4 and Figures 3 and 4. ((

)) The Appendix K small recirculation break is less limiting than the large recirculation line breaks. Although the nominal small break is more limiting than the large recirculation line break, the large break Licensing Basis PCT bounds the small break Licensing Basis PCT.

For the 0.08 ft2 recirculation line break case with HPCS-D/G failure and nominal assumptions, scram is assumed to occur at the start of the event on high drywell pressure and the vessel pressure falls to the pressure regulator setpoint (Figure 3b). When the main steamline isolation valves close on low water level, the vessel pressure begins to rise until the Automatic Depressurization System (ADS) actuation occurs (Figure 3b) at 342 seconds, 120 seconds after the low water level signal. Continued vessel inventory loss through the break and the ADS cause core uncovery (Figure 3a) and bundle heatup (Figure 3c). Once the vessel pressure has dropped below the injection valve permissive pressure and the -injection valve opens, the LPCS starts to inject, followed by LPCI injection (Figure 3e). The level is rapidly recovered in the bundle and terminates the bundle heatup (Figure 3c).

The accident progression for the 0.07 ft2 recirculation line break case with HPCS-D/G failure and Appendix K assumptions is similar to the nominal case. Due to higher bundle power and decay heat the pressurization is faster following MSIV closure and the Safety/Relief Valves (SRV) setpoint is reached. Pressure is maintained at the SRV setpoints until the ADS system actuates at 232 seconds (Figure 4b). Continued vessel inventory loss through the break and the ADS cause core uncovery and bundle heatup (Figures 4a and 4c). Once the vessel pressure has dropped below the injection valve permissive pressure and the injection valve opens, the LPCS begins injection, followed by LPCI injection (Figure 4e). After ECCS injection the level is rapidly recovered in the bundle and terminates the bundle heatup.

5.3. NON-RECIRCULATION LINE BREAKS The analysis in Reference 1 demonstrated that the non-recirculation line break cases are clearly non-limiting. With the introduction of GE14 fuel, non-recirculation line break cases will not become limiting. Non-recirculation line breaks cases have not been re-analyzed for 5

5

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION GE14 fuel.

5.4. ALTERNATE OPERATING MODES The limiting large break, the maximum recirculation suction line break, was reanalyzed for the ELLLA, FFWTR, Increased Core Flow (ICF) and Single-Loop Operation (SLO) operating modes.

For the ELLLA condition (100% of rated power and 87% of rated flow), the LAMB/TASC calculations have determined that early boiling transition (EBT) occurs in the top four axial fuel nodes. The same conservative assumption regarding the early boiling transition at the hot node was made for ELLLA and the early transition, boiling was imposed on the top five nodes. ((

For the FFWTR condition (120'F reduction in initial feedwater temperature from the rated feedwater temperature of 425'F), the LAMB/TASC calculations have determined that early boiling transition (EBT) also occurs in the top four axial fuel nodes. The same conservative assumption regarding the early boiling transition at the hot node, was made for FFWTR and the early transition boiling was imposed on the top five nodes. ((

)) Again, as expected, these results are similar to the rated case that also has EBT occurring in the top five axial fuel nodes.

The analysis in Reference 1 demonstrated that the effect on the LOCA results of ICF operation up to 105% of rated core flow is negligible. The LOCA results at ICF conditions are bounded by the LOCA results at rated conditions for all fuel types. Therefore the PCTs for the limiting large break cases given in Section 5.1 are applicable to the ICF condition.

The SLO analysis conservatively assumes the simultaneous dryout of all axial fuel nodes almost immediately following the initiation of the event. The SLO analysis results are shown in Table 7. ((

)) The SLO condition with Appendix K assumptions results in a PCT of 1093 IF, which is well below the 22007F licensing limit.

A separate analysis has been performed with 5 ADS valves available. The additional valve out-of-service does not impact the large . break cases because significant vessel depressurization is realized through the break. The impact on small breaks of 5 ADS valves available is shown in Table 5. These results compared to Table 4 show that the impact on one ADS out-of-service increases the calculated PCT for small breaks by 196 °F with 6

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION Nominal assumptions and by 194 'F with Appendix K assumptions. However, the Appendix K PCTs with 5 ADS valves available remain well below licensing limits.

A separate analysis has been performed with all 7 ADS valves available. The results are shown in Table 6.

Since the ECCS-LOCA analysis does not specifically model the individual steamlines, one Main Steam Isolation Valve (MSIV) out-of-service has no impact on the LOCA response.

This has previously been demonstrated in Reference 9.

COMPLIANCE EVALUATIONS 5.4.1. Licensing Basis PCT Evaluation The Appendix K results confirm that the limiting break is the maximum recirculation suction line break (DBA). This is consistent with the BWR-5 generic conclusion. ((

)) The Licensing Basis PCT for Nine Mile Point-2 is calculated for GE14 fuel based on the above Appendix K PCT and the use of SAFER/GESTR-LOCA licensing methodology approved by NRC (Reference 5). Nine Mile Point-2 unique variable uncertainties, including backflow leakage, ECCS signal, stored energy, gap pressure, and ADS time delay, were evaluated specifically for GE14 fuel to determine plant-specific adders. ((

))

The licensing basis PCT was estimated for ELLLA and FFWTR. This evaluation was performed to assure conformance with 10 CFR50.46 acceptance criteria and NRC SER requirements for SAFER/GESTR methodology for all the operating points. All 10 CFR50.46 acceptance criteria and NRC requirements were met.

5.4.2. Removal of the Current Requirement for Evaluation of Upper Bound PCT 7

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRJETARY INFORMATION 0

O8

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION 0

9

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION 0 Table 3 Single Failure Sensitivity Study for Large Recirculation Line Breaks Nominal Appendix K Peak Cladding Peak Cladding Break Size and Location Failure Temperature Tem erature First Second First Second Peak Peak Peak Peak (AF) (St) (OF) ([F)

DBA, Suction HPCS-D/G DBA, Suction LPCI-D/G DBA, Suction LPCS-D/G 80% DBA, Suction HPCS-D/G 60% DBA, Suction HPCS-D/G DBA, Suction (ELLLA) HPCS-D/G DBA, Suction (SLO) HPCS-D/G DBA, Suction (FFWTR) HPCS-D/G ]

Table 4 Break Area Sensitivity Study for Small Recirculation Line Breaks with HPCS-D/G with 6ADS Available Nominal Appendix K Break Area Peak Cladding Peak Cladding (ft2) Temperature ('F) Temperature (°F) 0.06 ((

0.07 0.08 0.09 0.10 ))

0 10

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION Table 5 Break Area Sensitivity Study for Small Recirculation Line Breaks with HPCS-D/G with 5ADS Available Nominal Appendix K Break Area Peak Cladding Peak Cladding (ft2) Temperature (°F) Temperature (°F) 0.06 ((

0.07 0.08 0.09 0.10 ))

Table 6 Break Area Sensitivity Study for Small Recirculation Line Breaks with HPCS-D/G with 7ADS Available Nominal Appendix K Break Area Peak Cladding Peak Cladding 0 (ft) Temperature (OF) Temperature (OF) 0.06 ((

0.07 0.08 0.09 0.10 11 Table 7 SLO Analysis - HPCS-D/G Failure Analysis Basis SLO PCT (OF)

Multiplier Nominal Two-Loop ((

Single-Loop ))

Appendix K Two-Loop ((

Single-Loop ]

0 11

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION

6.0 CONCLUSION

S The analysis contained in this report demonstrates that for GE14 fuel, the limiting break and single failure combination is the maximum recirculation suction line break with HPCS-D/G failure for both Nominal and Appendix K assumptions.

Based on the limiting large and small breaks and applying the SAFER/GESTR ECCS-LOCA methodology, the Nine Mile Point-2 ECCS-LOCA analysis was performed for the limiting LOCA event for GE14 fuel with an analytical PLGHR of 13.40 kW/ft. ((

)) The analyses demonstrate that the limiting Licensing Basis PCT occurs for the maximum recirculation suction line break. As shown in Table 8 below, these results meet all licensing and SAFER/GESTR methodology analysis limits. The ECCS-LOCA analysis results for all alternate modes (ELLLA, ICF, SLO, and FFWTR) also meet all licensing limits.

The thermal limits applied to the GE14 fuel in the ECCS-LOCA evaluation are summarized in Table 9.

Table 8 ECCS-LOCA Analysis Results for GE14 0 Parameter

____________________________ Analysis Result

________________________Acceptance 10CFR50.46 Criteria Criteri

1. Licensing PCT 1370 OF <2200 OF*

2. Maximum Local Oxidation < 1.0 % < 17 %*

3. Core-Wide Metal-Water <0.1 % < 1.0 %*

Reaction

4. Coolable Geometry See results from Items 1 and 2 Maintain coolable geometry above which is satisfied by meeting PCT *2200 OF and Maximum Local Oxidation _<17 %.

5. Core Long-Term Cooling Satisfied by either: Core Temperature acceptably (1) core reflooded above TAF or low and long-term decay heat removed (2) core reflooded to elevation of jet pump suction and one core spray system in operation

10 CFR 50.46 ECCS-LOCA Analysis Acceptance Criteria 12

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION Table 9 Thermal Limits for GEl4 PARAMETER ANALYSIS LIMIT PLHGR - Exposure Limit Curve GWd/MTU kW/ft 0.0 13.40 16.0 13.40 63.5 8.00 70.0 5.00 GWd/MTU kW/ft MAPLHGR- Exposure Limit Curve 0.0 12.82 16.0 12.82 21.09 12.82 63.5 8.00 70.0 5.00 0 Initial Operating MCPR 1.25 R-factor 0.954 Off-rated Thermal Limits:

Core Power, % of Rated (ELLLA) 100 Core Flow, % of Rated 87 K(f) (Note 1)

Power Peaking Limit (Note 1)

SLO Multiplier on PLHGR and 0.78 MAPLHGR (1) In the ELLLA LOCA evaluation, the rated power condition is bounding due to the off-rated restrictions applied by the K(f) curve (Reference 11) and the excessive power peaking limit (Reference 12, Section 3.2.4).

0 13

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION OREFERENCES

1. NEDC-31830P, "Nine Mile Point Nuclear Power Station Unit 2 SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis," Revision 1, November 1990.

2. 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors."

3. NEDC-23785PA, "The GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident, Volume III, SAFER/GESTR Application Methodology,"

Revision 1, General Electric Company, October 1984.

4. NEDE-23785P-A, Vol. III, Supplement 1, Revision 1, "GESTR-LOCA and SAFER Models for Evaluation of Loss-of Coolant Accident Volume III, Supplement 1, Additional Information or Upper Bound PCT Calculation," March 2002.

5. Letter, C.O. Thomas (NRC) to J.F. Quirk (GE), Acceptancefor Referencing of Licensing Topical Report NEDE-23785P, Revision 1, Volume III (P), "The GESTR-LOCA and SAFER Modelsfor the Evaluationof the Loss-of-CoolantAccident, " June 1, 1984.

6. Letter, S.A. Richards (NRC) to J.F. Klapproth (GENE), Review of NEDE-23785P, Vol.

III, Supplement 1, Revision 1, "GESTR-LOCA and SAFER Models for Evaluation of Loss-of Coolant Accident Volume II, Supplement 1, Additional Information for Upper Bound PCTCalculation," (TAC No. MB2774), February 1, 2002.

7. Letter, S.A. Richards (NRC) to J.F. Klapproth (GE), "Review of NEDC-32084P, 'TASC-03A, A Computer Program for Transient Analysis of a Single Fuel Channel' (TAC No.

MB0564)," March 13, 2002.

8. NEDC-32084P, "TASC-03A, A Computer Program for Transient Analysis of a Single Fuel Channel," Revision 2, General Electric Company, October 2000.

9. MDE-287-1285, "One Main Steamline Isolation Valve Out of Service for Nine Mile Point Nuclear Power Station Unit 2," General Electric Company, January 1986.

10. GE-NE-JI 103938-07-02P, "Nine Mile Point Unit 2 ECCS-LOCA Evaluation Update for GEl 1," January 2002.

11. JI 1-03938-ER, "Engineering Report for Nine Mile Point Nuclear Station Unit 2 Reload 8, Cycle 9," Revision 0, March 2002.

12. Nine Mile Point Unit 2 Improved Technical Specifications.

S 14

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION NINE MILE POI 'TJ 2 HOT CHANNEL AVERAGE CHANNEL DRA SLCT - NOM RATE[ TOP OF ACTIVE FU HPCSDG FAILURE

60. 4 I. -I +

5- 2 -

l--

0 tI

__1 2 ).

.,:w wK o I -, I I I I I 0.

60. 120. 180. 210 .

20001212, 1112.0 TIME (SECOND$E)

Figure 1-a Water Level in Hot and Average Channels.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

15 0

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION ZC.

Ln 0.

Cr' rý'

w) 0.

0. 60. 120. 180. 210.

L11 fI81A (16C*C 2006121L81112.0 TIME (c;EECONDFB )

Figure 1-b Reactor Vessel Pressure.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

16 0

GE-NE 0000-0024-65 17NP-RO GEH NON-PROPRIETARY INFORMATION NINE MILE POI 'T 2 I PEAK CLAD TEMPERýTURE DIUASUCT - NOM RA1E HPCSDG FAILURE

&i0 2.

U.1 P

I .

CLJ r -~ ____ N 0.1 - I I i ______________________________________________________________________________ ______________________________

0 60. 120. 180. 210 .

67I1, 03Oma P003121FF III;-.0 TIME (SECONDS)

Figure 1-c Peak Cladding Temperature.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

17

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION 5.

6.

CD CD (xi I-CD CD CD 0 m I.

ID CD

-j ID CD

0. 60. 120. 180. 210o.

UTIKA 0 LUC 200612 18 1112.0 TIME (;ECONOD)

Figure 1-d Heat Transfer Coefficients.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

18 S

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION NINE MILE POI 2 2 I

HPCS (prcs DRA SUCT - NOMRATEI LPCI #l HPCSDG FAILURE LPCI #2 1 PCT #T?5 I I C-)

rcn Co 0.b I I I __________________________ _______________________________________________

0. 180. 2 10 .

60. 120.

(1 2T0312L 01112. TIME (3ýECGND,;)

Figure 1-e ECCS Flows.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

19

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION 60.

so, U-

-J U- PD.

-j I-.

0.

0. 60, 120. 180. 2',0.

MHrn 0ge TIME (SECONDS)

Figure 2-a Water Level in Hot and Average Channels.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

20 0

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION 1.2 -

0.8;

0. 60. 120. 18O. 21,0.

CT rr.A osýRl 2003Ž1M 0820.3 TIME (SECONDS)

Figure 2-b Reactor Vessel Pressure.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

21 0

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION 2.

C-EL.

C3; 0.

tU-I 3.-

2U-

0. -

0. 60. 120. 180. 2'10.

GTHUA 09atH 20031231 0820.3 TIME (SECONDS)

Figure 2-c Peak Cladding Temperature.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

22 0

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION S.

6.

U.--

m

-_J

0. 60. 120. 180. 2'iO MiH -A 09A

ýOM03123 0820.3 TIME (SECONDS)

Figure 2-d Heat Transfer Coefficients.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

23 0

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION NINE MILE POI NT 2 Iircs3 DBA SUCT - APPK RAT

_0 L[I' #1 HPCSDG FAILURE LPC I*B I I -I -- '--,~-'"-.-' .4-.

'I0' I

0 C-)

wj rn

0. S (4

I I I I I r

0. 120. 180. 2'10 60.

owAn

.1. IYA 2O031231 0820.3 TIME (SECONDS)

Figure 2-e ECCS Flows.

Maximum Recirculation Line Suction Break, HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

24

0 GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION H-0 U--

0.

Soo.

0.10 TTME (SECONDS)

Figure 3-a Water Level in Hot and Average Channels.

Limiting Small Recirculation Line Break (0.08ft2),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptionsi 25

0 GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION 0.

0 0.

L;3 w

1,00. 0o00. 800.

GTHW*IA I2CFE TIME (SECONDS)

Figure 3-b Reactor Vessel Pressure.

Limiting Small Recirculation Line Break (0.08ft2),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

26

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION NINE MILE POI 'T 2 I PEAK CLAD TEMPERAVIURE 0.08 FT2 SUCT - NOM RATED HPCSWG -AILUHL 2.

w w

0 U F-I.

/

U I I I 0~.

U F-0 1 I I _____________________________________

0. 200. 400. 600. 800.

GICMA IPCI*

TIME (SECONDS)

Figure 3-c Peak Cladding Temperature.

Limiting Small Recirculation Line Break (0.08ft2),

IPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

27

GE-NE 0000-0024-651 7NP-RO GEH NON-PROPRIETARY INFORMATION NINE MILE POINT 2 CONV HTC HOT #5 CONV HTC HOT /16 0.08 FT2 SUCT - NOM RATED RAD HTC H07 #5 HPCS0LWT-ALURL RAD HI 1C201 #6 TnTA{ I ITi, .IIT -R TOTAL HTC HOT #6 I~

(\J LI_

ill III I

I .

CD

._J 7

F--

- II

0. 200. #00. 600. 800.

TIME (SECONDS)

Figure 3-d Heat Transfer Coefficients.

Limiting Small Recirculation Line Break (0.08ft2),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

28 0

0 GE-NE 0000-0024-651 7NP-RO GER NON-PROPRIETARY INFORMATION NINE MILE POI NT 2 H-PCS LF'CS 0.08 FT2 SUCT - NM RATED LI-LI 91 HPCSm]GFATI LJRF IPCI 91 1 PrT ?fA l 51 I- i-

'I0, I

LI U-)

Z-J

0. S ______________

I--

-jz U-,

0 I I I

0. 200., "000. 300 .

n0=,04; OCF TUME (SECONDS)

Figure 3-e ECCS Flows.

Limiting Small Recirculation Line Break (0.08ft2),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Nominal Assumptions]

29

GE-NE 0000-0024-651 7NP-RO GEH NON-PROPRIETARY INFORMATION NINE MILE POI NT 2 IIOT CI ANNCL AVERAGE CHANNEL 0.07 FT2 SUCT - APP RATEO UOPUF ACI"IVE FL HPCSOG FAILURE 60.

U---

0 -_J 20.

w~_

0. - I I I ______________________________________________________________________

0 200. 100. 600. 3000.

.9 TIME (SECONDS)

Figure 4-a Water Level in Hot and Average Channels.

Limiting Small Recirculation Line Break (0.07ft),

HiPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

30 0

0 GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION I.-

-10' Q.

0 r~n I I CL

0. L-

0. 200. o100. 600. 800.

20040*15 O TIME (SECONDS)

Figure 4-b Reactor Vessel Pressure.

Limiting Small Recirculation Line Break (0.07ft),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

31

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION xl0*

UD 0 wI I.

wL

0. 200 . 1100. 600. R00.

GT A'q 12A07 1'00101I9 1'181.9 -IIME (SECONDS)

Figure 4-c Peak Cladding Temperature.

Limiting Small Recirculation Line Break (0.07ft),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

32 S

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION NINE MILE POI NT 2 J CONV ITC IIOT #5 CONV HTC HOT #6 0.07 FT2 SUCT - APP RATED HAD HIC HOI #5 HPCSDG FAILURE RAD HTC HOT #6 TnTAl -TI IJT f-

5. TOTAL HTC HOT #G, 6.

U-oJ H-2:

02 U)

-J C)

H-2:

- ll 1

0. 200. 1100. 600. 00.

CTHrrA 12o07 20040115 1418.9 TIME (SECONDS)

Figure 4-d Heat Transfer Coefficients.

Limiting Small Recirculation Line Break (0.07fe),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

33 0

GE-NE 0000-0024-6517NP-R0 GEH NON-PROPRIETARY INFORMATION NINE MILE POI 'T 2 I Ircs RATED LPC9 0.07 FT2 SUCT - APP LPCI #1 HPCSDG FAILURE LPCI #2 LPCI #3 1I.5

-to 1

0 co 0.5

-LJ 0

0. 200. '100. 600. 800.

12A07 OT WA2 n00A015 1' 18.9 TIME (SECONDS)

Figure 4-e ECCS Flows.

Limiting Small Recirculation Line Break (0.07ft2),

HPCS-D/G Failure (1 LPCS + 3 LPCI + ADS Available)

[Appendix K Assumptions]

34

GE-NE 0000-0024-6517NP-RO GEH NON-PROPRIETARY INFORMATION Appendix A Operating Plant Licensing Parameters (OPL-4/5)

OPL-4/5 FORMS FOR NINE MILE POINT UNIT 2 (SEE NOTES C, D, E, F) 0 35

General Electric Company Non-Proprietary Information Class I

GE Nuclear Energy NMP2 Sheet No 36" I Rev. 0 OPL-4 for Cycle 9

1. Plant Operational Parameters Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References (2)

A. Operational Parameters-Rated conditions

1. Core thermal power-Nominal MWt 3467 V/ 3467

2. Core thermal power- MWt 3536 V 3536 Appendix K

3. Vessel steam dome pressure- psia 1055 1055 Nominal

4. Vessel steam dome pressure- psia 1055 __ 1055 Appendix K

5. Vessel steam output-Nominal Mlbm/hr 15.00 15.00

6. Vessel steam output- Mlbm/hr 15.35 " 15.35 Appendix K

7. Core flow Mlbm/hr 108.5 ,/ 108.5

8. Recirculation drive flow- Mlbm/hr 16.25 " 16.25 Loop A

9. Recirculation drive flow- Mlbm/hr 16.25 V/ 16.25 Loop B

10. Feedwater temperature- OF 425.1 423 403 Nominal

11. Feedwater temperature- OF 426.6 425 405 Appendix K 36 0

0 General Electric Company Non-Proprietary Information Class I 0 NMP2 SheetNo 37[

GE Nuclear Energy Rev. S OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References (2)

B. Alternate Operation Mode Parameters-[Single Loop]

1. Core thermal power-Nominal MWt 2842.9 2843 2843

2. Core thermal power- MWt 2899.8 2900 2900 Appendix K

3. Vessel steam dome pressure- psia 1055 V 1055 Nominal

4. Vessel steam dome pressure- psia 1055 1055 0 Appendix K

5. Vessel steam output-Nominal Mlbm/hr 11.949 11.949

6. Vessel steam output- Mlbmihr 12.222 12.222 Appendix K V,

7. Core flow Mlbm/hr 65.10 V/ 65.10

8. Recirculation drive flow- Mlbm/hr 19.5 19.5 Loop A

9. Recirculation drive flow-Loop B Mlbm/hr 0 0

10. Feedwater temperature- OF 403.6 403 383 Nominal

11. Feedwater temperature- 405.7 405 385 Appendix K 37 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 38

GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References C. Alternate Operation Mode Parameters-[ELLLAI

1. Core thermal power-Nominal MWt 3467 3467

2. Core thermal power- MWt 3536 3 53__.66 Appendix K

3. Vessel steam dome pressure- psia 1055 1055 Nominal

4. Vessel steam dome pressure- psia 1055 1055 Appendix K

5. Vessel steam output-Nominal Mlbm/hr 15.00 15.00

6. Vessel steam output- Mlbm/hr 15.35 15.35 Appendix K

7. Core flow Mlbm/hr 94.4 94.4

8. Recirculation drive flow- Mlbm/hr 14.1 14.1 Loop A

9. Recirculation drive flow-Loop B Mlbm/hr 14.1 14.1

10. Feedwater temperature- OF 423 403 Nominal

11. Feedwater temperature- OF 425 405 Appendix K 38

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 39

GE NuclearEnergy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References D. Alternate Operation Mode Parameters-[ICF]

1. Core thermal power-Nominal MWt 3467 3467

2. Core thermal power- MWt 3536 3536 Appendix K

3. Vessel steam dome pressure- psia 1055 1055 Nominal

4. Vessel steam dome pressure- psia 1055 1055 Appendix K

5. Vessel steam output-Nominal Mlbm/hr 15.00 15.00

6. Vessel steam output- Mlbm/hr 15.35 15.35 Appendix K

7. Core flow - 105% of Rated - Mlbm/hr 113.9 113.9 AL

8. Recirculation drive flow- Mlbm/hr 17.05 17.05 Loop A

9. Recirculation drive flow-Loop B Mlbmlhr 17.05 17.05 0

10. Feedwater temperature- F 423 403 Nominal

11. Feedwater temperature- °F 425 405 Appendix K 39

General Electric Company Non-Proprietary Information Class I

. GE NuclearEnergy. NMP2 Sheet No 40 Rev. 0 OPL-4 for Cycle 9

2. LPCI & LPCS Emergency Diesel Generators (EDGs)

Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References A. Initiating signals

1. Low water level Level # 1

2. High drywell pressure Yes/No Yes 3/ Yes seconds 1.0 1.0 B. Delay time to process initiation signal (TsPo on Fig. 1, 2) seconds 30.0 30.0 C. Maximum delay time from EDG 0 start signal until bus is at rated voltage (TDG on Fig. 1, 2) 40

0 General Electric Company Non-Proprietary Information Class I GEGENcerEnergy Nuclear NMP2 Rev. 0 Sheet No 41 OPL-4 for Cycle 9

2. HPCS Emergency Diesel Generator (EDG)

Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References A. Initiating signals

1. Low water level Level # 1 2 2

2. High drywell pressure Yes/No Yes Yes B. Delay time to process initiation seconds 1.0 1.0 signal (TsPD on Fig. 1, 2)

C. Maximum delay time from EDG seconds 30.0 30.0 start signal until bus is at rated voltage (TDG on Fig. 1, 2) 41 0

General Electric Company Non-Proprietary Information Class I o GE NuclearEnergy OPL-4 for Cycle 9 NMP2 Rev. 0 Sheet No 42

3. Low Pressure Coolant Injection (LPCI) System Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References A. Initiating signals

1. Low water level Level # 1 $

2. High drywell pressure Yes/No Yes $ Yes

3. Low vessel pressure psig ~1 N/A permissive

4. Timer delay for sustained low minutes I/ N/A water level (TsLL on Fig. 1)

B. Delay time to process initiation seconds 1.0 1.0 signal (TsPD on Fig. 1)

C. Maximum vessel pressure at psid 225 See Table 1 See Table 1 which pumps can inject flow (vessel to (See Table 1)

(pressure associated with TCIPH on drywell)

Fig. 1)

D. Minimum flow delivered to vessel

1. Vessel pressure at which flow psid 20 See Table I See Table 1 rates listed below are quoted (vessel to (See Table 1) drywell)

2. One LPCI pump into shroud gpm 6280 See Table 1 See Table 1 (See Table 1)

E. Minimum flow at 0 psid (vessel- See Table I See Table 1 to-drywell) 42

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 43 0 GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References

1. One LPCI pump into shroud gpm 6576 See Table 1 See Table I (See Table 1)

F. Maximum delay time from bus at seconds 7.3 7.3 rated voltage until power available for pump start. (TCIPA on Fig. 1)

G. Maximum delay time from pump seconds 3.0 3.0 start until pump is at rated speed (TCIPR on Fig. 1)

H. LPCI Injection Valves

1. Maximum delay time from bus seconds 0 0 at rated voltage until power available at injection valve (Tcrpv on Fig. 1)

2. Pressure at which injection psig 225 225 A valve may open (pressure (vessel) permissive associated with Tc1 ppon Fig. 1)

3. Maximum injection valve seconds 25 _ 25 stroke time - opening (Tcuv on Fig. 1) 43

General Electric Company Non-Proprietary Information Class I NMIP2 Sheet No 44

GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Res olved Variable Units Value Value V alue Notes References

4. Minimum differential pressure psid 8 8 at which injection valve may (across open (corresponding to the injection RPV pressure in variable valve) 3.H.2)

I. Minimum flow bypass (MFB) valve

1. Normal position of MFB valve Open/ O en at system startup Closed

2. System flow at which MFB gpm _ 1050 1_050 valve is signaled to close

3. MFB valve stroke time seconds _ 12 12

4. MFB flow rate gpm _ 1100 100 44

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 45

0 GE Nuclear Energy Rev. 0 1 OPL-4 for Cycle 9

4. Core Spray (CS)/Low Pressure Core Spray (LPCS) System Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References A. Initiating signals

1. Low water level Level # Y I

2. High drywell pressure Yes/No Ye...s Yes

3. Low vessel pressure psig NA NA permissive

4. Timer delay for sustained low minutes NA NA water level (TsLL on Fig. 2) 0 B. Delay time to process initiation signal (TsPD on Fig. 2) seconds 1.0 1.0 C. Maximum vessel pressure at psid 289 See Table 2 See Table 2 which pumps can inject flow (vessel to (See Table 2)

(pressure associated with TcSPH on drywell)

Fig. 2)

D. Minimum flow delivered to vessel

1. Vessel pressure at which flow psid 30 See Table 2 See Table 2 rate listed below is quoted (vessel to (See Table 2) drywell)

2. Minimum flow at vessel gpm 6150 See Table 2 See Table 2 pressure (See Table 2)

E. Minimum flow at 0 psid (vessel to gpm 6494 See Table 2 See Table 2 drywell) (See Table 2) 45 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 46

GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References F. Maximum delay time from bus at seconds 7.3 7.3 rated voltage until power available for pump start (TcsPA on Fig. 2)

G. Maximum delay time from pump seconds 4.5 4.5 start until pump is at rated speed (TcsPR on Fig. 2)

H. CS/LPCS Injection Valve(s)

1. Maximum delay time from bus seconds 0 0 at rated voltage until power available at injection valve (Tcspv on Fig. 2)

2. Pressure at which injection psig 305_5 305 B valve may open (pressure (vessel) permissive associated with Tcspp on Fig. 2)

3. Maximum injection valve seconds 25 _" 25 stroke time - opening (Tcsv on Fig. 2)

4. Minimum differential pressure psid 0 0 at which injection valve may (across open (corresponding to the injection RPV pressure in variable valve) 4.H.2) 46

General Electric Company Non-Proprietary Information Class I

GE NuclearEnergy NMP2 Rev. 0 SheetNo 47 I 1

OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References I. Minimum flow bypass (MFB) valve

1. Normal position of MFB valve Open/ Open Open

at system startup Closed

2. System flow at which MFB gpm 1550 1550 valve is signaled to close

3. MFB valve stroke time seconds 6 6

4. MFB flow rate gpm 1208 1208 0

47 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 48

GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9

5. High Pressure Core Spray (HPCS) System Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References A. Initiating signals

1. Low water level Level # 2 ,/ 2

2. High drywell pressure Yes/No Yes Yes B. Delay time to process initiation seconds I I signal (TspD)

. C. Maximum vessel pressure at which pumps can inject flow psid (vessel to 1175 (See Table 3)

See Table 3 See Table 3 (pressure associated with TCSPH) source)

D. Minimum flow delivered to vessel

1. Vessel pressures at which flow psid 1175.3 rates listed below are quoted (vessel to 1175 source) 1030 See Table 3 See Table 3 100 (See Table 3)

2. Minimum flows at vessel gpm 0 pressure 509 1525 See Table 3 See Table 3 6150 (See Table 3)

E. Minimum flow at 0 psid (vessel to gpm 6250 See Table 3 See Table 3 source) (See Table 3) 48 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 49I

GE Nuclear Energy Rev. 0 J OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References F. Maximum delay time from bus at seconds 0 0 rated voltage until power available for pump start (TcsPA)

G. Maximum delay time from pump seconds 12 12 start until pump is at rated speed (TcspR)

H. HPCS Injection Valve

1. Maximum delay time from bus seconds 0 at rated voltage until power available at injection valve (Tcspv)

2. Maximum injection valve seconds 22 22 stroke time - opening (Tcsiv)

1. Minimum flow bypass (MFB) valve

1. Normal position of MFB valve Open/ Close Close at system startup Closed

2. System flow at which MFB gpm 900 900 valve is signaled to close

3. MFB valve stroke time seconds 10 10

4. MFB flow rate gpm 1000 1000 49 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 50

GE NuclearEnergy Rev. 0 OPL-4 for Cycle 9

7. Automatic Depressurization System (ADS)

Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References A. Initiating signals

1. Low water level Level # I

2. High drywell pressure Yes/No No V No

3. High drywell pressure bypass minutes N/A V N/A timer delay for sustained low water level (TBT on Fig. 3)

4. ECCS ready permissive Yes/No Yes Yes O B Delay time to process initiating seconds _

signal (Tspi on Fig. 3)

C. Total number of relief valves with 7/ 7 ADS function D. Total number of relief valves with 5 5 ADS function assumed in analysis E. Pressure at which flow capacity psig 1080 1080 listed below is quoted (vessel)

F. Minimum flow rate for one valve Ibm/hr 8.162x10 5 816000 816000 open at above listed pressure 50 S

S General Electric Company Non-Proprietary Information Class I GE Nuclear gy NMP2 Sheet No 511 E

frEnerg Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References G. ADS timer delay from initiating seconds 120 I/ 120 signal completed to the time valves are opened (TsT on Fig. 3) 51

General Electric Company Non-Proprietary Information Class I

GE Nuclear Energy NMP2 Rev. 0 Sheet No 52 I1 OPL-4 for Cycle 9

8. In-Vessel Leakage Rates Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References A. LPCI leakage (One Pump)

1. Leakage flow gpm 80 " 80

2. Pressure at which leakage flow psid 20 20 is defined B. CS leakage (principally through

. vent hole of T-joint)

1. Leakage flow

2. Pressure at which leakage flow gpm psid 1000 122 30 100 30__

is defined (CS/LPCS)

3. Pressure at which leakage flow psid 200 100 100 is defined (HPCS)

C. Leakage allowance for shroud cracks

1. Leakage flow gpm _ 150 150

2. Core flow at which leakage % of rated _ 105 105 flow is defined

3. Elevation of core shroud inches 294 294 cracks AVZ D. Leakage allowance for access hole cover cracks

1. Leakage flow gpm 80 80 52 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 53

GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References

2. Core flow at which leakage % of rated 105 105 flow is defined E. Leakage allowance for LPCI- N/A N/A related cracks

1. Leakage flow gpm _ 0

2. Pressure at which leakage flow psid _

is defined F. Leakage allowance for CS header N/A N/A and riser cracks

1. Leakage flow gpm "/

V 0

2. Pressure at which leakage flow psid -

is defined G. Leakage allowance for internal modifications and shroud repairs

1. Leakage flow gpm _ 350 350

2. Core flow at which leakage % of rated _ 105 105 flow is defined

3. Elevation of leakage path inches 294 294 AVZ H. Leakage allowance for access hole N/A N/A cover repairs

1. Leakage flow gpm - 0 53

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 54 I

GE NuclearEnergy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References

2. Core flow at which leakage % of rated __

flow is defined

1. Leakage allowance for LPCI- N/A N/A related repairs

1. Leakage flow gpm - " 0

2. Pressure at which leakage flow psid _

is defined

J. Leakage allowance CS repairs N/A N/A

1. Leakage flow gpm - " 0

2. Pressure at which leakage flow psid _

is defined 54

0 General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 55

GE Nuclear Energy Rev. 01 OPL-4 for Cycle 9

9. Miscellaneous Inputs Utility GE Proposed Proposed Res olved Variable Units Value Value V alue Notes References A. Normal water level at rated power inches 563.5 5 63.5 (indicated level) AVZ B. Water level setpoints

1. Level 8-High Level inches 587.6 588.4 5188.4 AVZ

2. Level 7-High Level Alarm inches _ 568 5;68 (indicated level) AVZ

3. Level 4-Low Level Alarm inches 559.0 5 59.0 (indicated level) AVZ

4. Level 3-Low Level inches 535.0 511 5 (indicated level) AVZ

5. Level 2-Low Low Level inches 453.5 457.5 4 57.5 AVZ

6. Level 1-Low Low Low Level inches 366.3 366.5 3 66.5 AVZ C. Steam dryer pressure drop psid 0.374 $ 0. 374 D. MSIV isolation-initiation signal

1. Low water level Level # I " I

2. Low steam line pressure psig 720 7720

3. High steam line flow % of rated 140 130-140 13( 0-140 55

0 General Electric Company Non-Proprietary Information Class I 0 [NMP2 Sheet No 56 GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References E. MSIV signal delay (from initiating seconds 0.5 $ 0.5 event to start of valve motion)

F. MSIV closure time

1. Minimum closing time seconds 3 3

2. Maximum closing time seconds 5 5 G. Feedwater pump coastdown (from seconds 5 .001 .00_

initial value to zero flow)

H. Time constant for recirculation seconds 4 4 pump coastdown

1. Number of pilot-actuated Safety/Relief Valves (SRVs) in group

1. Group A 2__ 2 _

2. Group B 4 __4

3. Group C 4__ 4

4. GroupD 4 __ 4

5. Group E 4 4 J. Opening/closing setpoints of pilot-actuated SRVs

1. Group A psig 1103/1003 " 1103/1003

2. Group B psig 1113/1013 " 1113/1013 56 0

0 General Electric Company Non-Proprietary Information Class I SheetNo 57 GE NuclearEnergy Ener _foRev.

NMP2 0

OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References

3. Group C psig 1123/1023 1123/1023

4. Group D psig 1133/1033 1133/1033

5. Group E psig 1143/1043 1143/1043 K. Low-low set logic Yes/No NA NA L. Number of low-low set SRVs in Group

1. Group A NA NA 2 Group B NA NA

3. Group C NA NA M. Opening/closing pressure setpoints NA of low-low set SRVs NA

1. Group A ,/

psig N/A

2. Group B psig V, N/A

3. Group C psig N/A N. Pilot-actuated SRV capacity

1. SRV capacity at (100+ACC)% Ibm/hr 800000 800000 of reference pressure

2. Reference pressure psig 1145 1080 1080

3. Overpressure Accumulation 3 0 0 Factor (ACC) 57 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 58 0 GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References

0. Additional Pilot-actuated SRV opening/closing parameters

1. Time delay before opening of seconds 0.3 ', 0.3 pilot-actuated SRVs

2. Time constant of SRV seconds 0.3 0.3 opening/closing P. Number of Spring Safety Valves (SSVs) 1 Group A 2 2

2. Group B 4 4

3. Group C 4 4

4. Group D 4 4

5. Group E 4 4 Q. Opening/closing setpoint of SSVs

1. Group A psig 1165/1065 1165/1089 1165/1089

2. Group B psig 1175/1075 1175/1099 1175/1099

3. Group C psig 1185/1085 1185/1108 1185/1108

4. Group D psig 1195/1095 1195/1117 1195/1117

5. Group E psig 1205/1105 1205/1127 1205/1127 R. SSV capacity at opening setpoint

1. Group A lbm/hr 905,726 905000 905000

2. Group B lbmihr 913,~40 913000 913000

3. Group C lbm/hr 921,081 921000 921000 58

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 59

GE NuclearEnergy Rev. 0 OPL-4 for Cycle 9 Utility GE Proposed Proposed Resolved Variable Units Value Value Value Notes References

4. Group D Ibm/hr 9280759 928000 928000

5. Group E Ibm/hr 936,437 936000 936000 S. ECCS make-up water temperature OF 12__00 120 T. Operator action time seconds 600 600 U. High drywell pressure setpoint psig 2.0 2.0 0

59 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 60 W GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9

10. Notes A. The LPCI injection valve open permissive will not be granted (even when the vessel pressure falls below 225 psig) prior to 41.3 seconds into the LOCA. The LPCI pumps will be at rated speed (operating on min flow) at 41.3 seconds due to various time delays (EDG start time delay, motor loading time delay, motor acceleration time). GE is to provide validation of this assumption.

B. The LPCS injection valve open permissive will not be granted (even when the vessel pressure falls below 305 psig) prior to 42.8 seconds into the LOCA. The LPCS pump will be at rated speed (operating on min flow) at 42.8 seconds due to various time delay (EDG start time delay, motor loading time delay, motor acceleration time). GE is to provide validation of this assumption.

C. The LOCA analysis is done in such a manner that it is reflective of the ECCS equipment out-of-service option presently allowed by the Technical Specifications:

Out-of- LPCS LPCI A LPCI B LPCI C HPCS 1 Req'd Service ADS LPCS 7 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Not 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Allowed LPCI A 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 7 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LPCI B 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 7 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LPCI C 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 7 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months HPCS Not 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 14 days Not Allowed with RCIC Allowed operable 1 Req'd 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Not 14 days ADS Allowed D. The LOCA analysis for off-normal conditions (one MSIV out-of-service) is bounded by the LOCA analyses that corresponds to the plant operation at the rated power, extended load line limit point, increased core flow point, or single loop operation point. GE is to provide validation of this assumption.

E. The LOCA analysis for main steam line break and other smaller breaks (LPCI, HPCS, feedwater, etc) is bounded by the recirculation pump suction line break LOCA analysis. GE is to provide validation of this assumption.

F. The input parameters (e.g., ECCS injection flow rates, vessel initial pressure, core flow rate, etc.) other than those associated with automatic trips or corrective actions, labeled as Analytical Limit (AL) in the OPL 4/5 Design Guide do not include measurement uncertainties even though the OPL 4/5 Design Guide seems to require the uncertainties to be included. This deviation is acceptable based on the conclusion of the BWROG report, Safety Analysis Evaluations Relative to Measurement 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 61 W GE Nuclear Energy Rev. 0 W OPL-4 for Cycle 9 Uncertainties for the BWR/4 In nproved Standard Technical Specification. The BWROG in the report concluded that this is acceptable because "of the substantial amount of conservatism in the safety analysisprocess".

11. References

1. not used

2. References for OPL are contai ied in Nine Mile Point Nuclear Station Unit 2 Calculation #A1O.1-AE-002 R ev. 0.

0 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 62 W GE Nuclear Energy Rev. 0 0 OPL-4 for Cycle 9 MAXIMUM BREAK AREAS FOR LOCA EVALUATION Break Location Break Area (ft2 )

Recirculation Suction Line 3.131 The maximum break area for each break location is calculated using the minimum flow (cross-sectional) area in each possible flow path from the point of the break to inside the vessel. The maximum design tolerances are used in the calculation of the minimum flow area in order to ensure conservative values.

0 The recirculation suction line break area is comprised of the minimum flow areas of the recirculation suction line nozzle/safe end, the jet pump nozzles, the bottom head drain line, and the recirculation cross-tie drain line.

0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 63 W GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Table 1. LPCI Pump Characteristics Used in LOCA Analysis (One Pump)

Vessel to Drywell Pressure Pump Flow into Vessel*

(psid) (gpm) 0 6660 20 6360 45 5960 67 5570 90 5160 112 4710 135 4210 150 3600 0 190 2200 190.1 1000 210 0

For leakage into the downcomer region see OPL-4 Item 8 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 64 WGE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 Table 2. LPCS Pump Characteristics Used in LOCA Analysis (One Pump)

Vessel to Drywell Pressure Pump Flow into Vessel*

(psid) (gpm) 0 6600 30 6250 58 5900 87 5520 116 5110 144 4660 173 4170 202 3610 0 231 2950 260 2080 289 0

For leakage into the downcomer region see OPL-4 Item 8 0

General Electric Company Non-Proprietary Information Class I NMP2 Shetoo65 GE Nuclear Energy Rev. 0 0 OPL-4 for Cycle 9 Table 3. HPCS Pump Characteristics Used in LOCA Analysis Vessel to Drywell Pressure Pump Flow into Vessel*

(psid) (gpm) 0 6250 100 6250 980 1800 1080 0 j _____________________________________________________________________________

For leakage into the downcomer region see OPL-4 Item 8 0

General Electric Company Non-Proprietary Information Class I Sheet No 66 GE NuclearEnergy Rev. 0 OPL-4 for Cycle 9 To = 0.0 TSPD

'ANP I

1II 'I1 I-- I1

-I Powe I IDischai SI IInject Timer Starts Valv TSLL ANP Timer Elapsed I II OR.y . J IV Starts to Open L __I TDV

___NI IDV FullL

. .Closed I Time Of LPCI Injection Note: Delay times refer to solid lines between events. Dotted lines show logic without time delay.

Figure 1. Initiation Logic Diagram for Low Pressure Coolant Injection (LPCI) System 0

General Electric Company Non-Proprietary Information Class I SNMP2 Sheet No 67 GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 LOCA Initiation, To = 0.0 THDW TLWL TCSPP High Drywell Low Reactor i Low Vessel Pressure Water Level Pressure Permissive TSPD TSPO ----------- TSPD I _(

_ OR "-

r -.-..

I QI-R ------- AND

.- TCSPH Starts DG Start TDG TSLL PoweratBus Timer Elapsed Cs Injection TCSPA AND Shutoff Head TCSPV Pump Start AND Power at IV --

TCSPR Iv Starts Pump at to Open Rated Speed TCSIV IAND IV Full J- - - - Open I Time of CS Injection Note: Delay times refer to solid lines between events. Dotted lines show logic without time delay.

Figure 2. Initiation Logic Diagram for Low Pressure Core Spray (LPCS) System 0

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 68 GE Nuclear Energy Rev. 0 OPL-4 for Cycle 9 LOCA Initiation, To = 0.0 TSPD TECCS S

Note: Delay times refer to solid lines between events.

Dotted lines show logic without time delay. L--------

OpenADS Valves Figure 3. Initiation Logic Diagram for Automatic Depressurization System (ADS) 0

General Electric Company Non-Proprietary Information Class I 0

W GE Nuclear Energy OPL-5 for Cycle 9 F NMP2 Rev. 0 VERIFICATION OF EMERGENCY CORE COOLING SYSTEM SINGLE FAILURE EVALUATION FOR SAFER/GESTR ANALYSIS(')

The table below shows the various combinations of Automatic Depressurization System (ADS),

High Pressure Core Spray (HPCS) System, Low Pressure Core Spray (LPCS) System, and Low Pressure Coolant Injection (LPCI) System which might be operable in an assumed design basis accident situation.

The following single, active failures will be considered in the ECCS performance evaluation:

Assumed Failure Recirculation Line Break Systems Remaining 2)

HPCS Diesel Generator ADS"3 ', LPCS, 3 LPCI LPCS Diesel Generator ADS 3 ), HPCS, 2 LPCI LPCI Diesel Generator ADSP 3 T,HPCS, LPCS, 1 LPCI Notes for OPL-5 (1) Other postulated failures are not specifically considered because they all result in at least 0 (2) as much ECCS capacity as one of the above assumed failures.

Systems remaining, as identified in this table, are applicable to all non-ECCS line breaks.

For a LOCA from an ECCS line break, the systems remaining are those listed, less the ECCS system in which the break is assumed.

(3) The ECCS-LOCA analysis conservatively assumes only 5 ADS valves available

General Electric Company Non-Proprietary Information Class I NMP2 Sheet No 70

GE Nuclear Energy Rev. 0 OPL-5 for Cycle 9 NMP2 SAFER/GESTR-LOCA Analysis Operating Plant Licensing (OPL) 4/5 Forms-Resolution of Emergency Core Cooling System Parameters as Inputs to the SAFER/GESTR Analysis The OPL-4/5 forms represent a confirmation by NMP2 of the Emergency Core Cooling System parameters which are to be used as inputs to the SAFER/GESTR computer code in the NMP2 SAFER/GESTR-L OCA analysis.

Prepared by: _ Date:

Carl Lepine Fuels / NMP O Verified by: _ Date:

Jeff Winklebleck Fuels / NMP

ATTACHMENT 7 REPLACEMENT PAGES FOR NEDO-33351, REVISION 0, "SAFETY ANALYSIS REPORT FOR NINE MILE POINT NUCLEAR STATION UNIT 2 CONSTANT PRESSURE POWER UPRATE" (LAR ATTACHMENT 3)

Nine Mile Point Nuclear Station, LLC December 23, 2009

NEDO-33351 - REVISION 0 - CORRECTED PAGE NON-PROPRIETARY INFORMATION 0 Table 1-1 Computer Codes Used For EPU Task Computer Version or NRC Comments Code* Revision -Approved Comments Nominal Reactor Heat ISCOR 09 Y(2) NEDE-2401 1-P Rev. 0 SER Balance Reactor Core and Fuel TGBLA 06 Y NEDE-30130-P-A (4)

Performance PANACEA 11 Y NEDE-30130-P-A (4)

ISCOR 09 Y(2) NEDE-2401 IP Rev. 0 SER Thermal Hydraulic ISCOR 09 Y(2) NEDE-2401 1-P Rev. 0 SER Stability PANACEA ODYSY05 11 Y Y NEDE-30130-P-A (4)

ODYSY 05 Y OPRM 01 Y(15) NEDC-32992P-A, Class III, July 2001 TRACG 04 Y(16) NEDO-32465-A RPV Fluence TGBLA 06 Y See note 14 DORTGO1V 01 N See notes 12 and 13 RPV Internals Structural SAP4GO7V 01 NA NEDO-10909 (1)

Integrity Evaluation Reactor Internal Pressure ISCOR 09 Y(2) NEDE-2401 IP Rev. 0 SER Differences LAMB 07 (3) NEDE-20566-P-A TRACG 02 Y NEDE-32176P Rev. 2 NEDC-32177P Rev. 2 NRC TAC No. M90270 Transient Analysis PANACEA 11 Y NEDE-30130-P-A (4)

ISCOR 09 Y(2) NEDE-2401 1-P Rev. 0 SER ODYN 09 Y NEDO-24154-A SAFER 04 (5) NEDC-32424P-A, NEDC-32523P-A (8) (9) (10)

Anticipated Transient ODYN 09 Y NEDE-24154P-A Supp. 1, Vol. 4 Without Scram STEMP 04 (6)

PANACEA 11 Y NEDE-30130-P-A ISCOR 09 Y(2) NEDE-2401 1-P Rev. 0 SER Containment System SHEX 05 Y (7)

Response M3CPT 05 y NEDO-10320, Apr. 1971 LAMB 08 (3) NEDE-20566-P-A September 1986 Appendix R Fire GESTR 08 (5) NEDE-23785-1-PA Rev. 1 Protection SAFER 04 (5) (8) (9) (10)

SHEX 04 Y (7)

Reactor Recirculation BILBO 04V NA NEDE-23504, February 1977 System (1) 1-7

NEDO-33351 - REVISION 0 - CORRECTED PAGE NON-PROPRIETARY INFORMATION (GE), "Review of NEDE-23785-1 (P), "GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident, Volumes I and II," August 29, 1983.) In addition, the use of SAFER in the analysis of long term Loss-of-Feedwater (LOFW) events is specified in the approved LTRs for power uprate: "Generic Guidelines for General Electric Boiling Water Reactor Extended Power Uprate," NEDC-32424P-A, February 1999 and "Generic Evaluations of General Electric Boiling Water Reactor Extended Power Uprate," NEDC-32523P-A, February 2000. The Appendix R events are similar to the loss of FW and small break LOCA events.

(6) The STEMP code uses fundamental mass and energy conservation laws to calculate the suppression pool heatup. The use of STEMP was noted in NEDE-24222, "Assessment of BWR Mitigation of ATWS, Volume I & II (NUREG-0460 Alternate No. 3) December 1, 1979." The code has been used in ATWS applications since that time. There is no formal NRC review and approval of STEMP.

(7) The application of the methodology in the SHEX code to the containment response is approved by NRC in the letter to G. L. Sozzi (GE) from A. Thadani (NRC), "Use of the SHEX Computer Program and ANSI/ANS 5.1-1979 Decay Heat Source Term for Containment Long-Term Pressure and Temperature Analysis," July 13, 1993 (Reference 7).

(8) Letter, J.F. Klapproth (GE) to NRC, Transmittal of GE Proprietary Report NEDC-32950P "Compilation of Improvements to GENE's SAFER ECCS-LOCA Evaluation Model," dated January 2000 by letter dated January 27, 2000.

(9) Letter, S.A. Richards (NRC) to J.F. Klapproth, "General Electric Nuclear Energy (GENE) Topical Reports GENE (NEDC)-32950P and GENE (NEDC)-32084P Acceptability Review," May 24, 2000.

(10) "SAFER Model for Evaluation of Loss-of-Coolant Accidents for Jet Pump and Non-Jet Pump Plants," NEDE-30996P-A, General Electric Company, October 1987.

(11) The NRC approved the TASC-03A code by letter from S. A. Richards, NRC, to J. F.

Klapproth, GE Nuclear Energy,

Subject:

"Review of NEDC-32084P, TASC-03A, A Computer Code for Transient Analysis of a Single Fuel Channel," TAC NO. MB0564, March 13, 2002. The acceptance version has not yet been published.

(12) CCC-543, "TORT-DORT Two-and Three-Dimensional Discrete Ordinates Transport Version 2.8.14," Radiation Shielding Information Center (RSIC), January 1994.

(13) Letter, H. N. Berkow (NRC) to G. B. Stramback (GE), "Final Safety Evaluation Regarding Removal of Methodology Limitations for NEDC-32983P-A, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations (TAC No.

MC3788)," November 17, 2005.

(14) Letter, S.A. Richards (NRC) to G. A. Watford (GE), "Amendment 26 to GE Licensing Topical Report NEDE-2401 1-P-A, GESTAR II - Implementing Improved GE Steady-State Methods (TAC No. MA6481)," November 10, 1999.

(15) The OPRM code is not Level 2. However, the methodology as implemented in the OPRM code has been approved by the NRC.

(16) TRACG02 has been approved in NEDO-32465-A by the US NRC for the stability DIVOM analysis. The CLTP stability analysis is based on TRACG04, which has been shown to provide essentially the same or more conservative results in DIVOM applications as the previous version, TRACG02.

0 1-9

0 NEDO-33351 - REVISION 0 - CORRECTED PAGE NON-PROPRIETARY INFORMATION Limitation Limitation Title Limitation, Description Disposition Section of NMIP2 PUSAR Number from which addresses the NRC SER Limitation 9.16 Void Reactivity 2 A supplement to TRACG /PANAC 1I for Not The limitation is not applicable AOO is under NRC staff review (Reference A- Applicable to NMP2 EPU application 4). TRACG internally models the response because it is not based on surface for the void coefficient biases and Supplement 3 to NEDE-uncertainties for known dependencies due to 32906P.

the relative moderator density and exposure on nodal basis. Therefore, the void history bias determined through the methods review can be incorporated into the response surface "known" bias or through changes in lattice physics/core simulator methods for establishing the instantaneous cross-sections.

Including the bias in the calculations negates the need for ensuring that plant-specific applications show sufficient margin. For application of TRACG to EPU and MELLLA+

applications, the TRACG methodology must incorporate the void history bias. The manner in which this void history bias is accounted for will be established by the NRC staff SE approving NEDE-32906P, Supplement 3, "Migration to TRACG04/PANAC1 1 from TRACG02/PANAC1O," May 2006 (Reference A-4). This limitation applies until the new TRACG/PANAC methodology is approved by the NRC staff.

A-10

0 NEDO-33351 - REVISION 0 - CORRECTED PAGE NON-PROPRIETARY INFORMATION Limitation Limitation Title Limitation, Description Disposition.' Section of NMP2 PUSARý

ý,.Number fromn. which, addresses.the NRCSER "..,Limitation 9.19 Void-Quality For applications involving Comply Section 2.8.5.8 and Section Correlation 1 PANACEA/ODYN/ISCOR/TASC for 2.8.3.1 operation at EPU and MELLLA+, an additional 0.01 will be added to the OLMCPR, until such time that GE expands the experimental database supporting the Findlay-Dix void-quality correlation to demonstrate the accuracy and performance of the void-quality correlation based on experimental data representative of the current fuel designs and operating conditions during steady-state, transient, and accident conditions.

9.20 Void-Quality The NRC staff is currently reviewing Not The limitation is not applicable Correlation 2 Supplement 3 to NEDE-32906P, "Migration to Applicable to NMP2 EPU application TRACG04/PANAC 1I from because it is not based on TRACG02/PANAC 10," dated May 2006 Supplement 3 to NEDE-(Reference A-4). The adequacy of the 32906P.

TRACG interfacial shear model qualification for application to EPU and MELLLA+ will be addressed under this review. Any conclusions specified in the NRC staff SE approving Supplement 3 to LTR NEDC-32906P (Reference A-4) will be applicable as approved.

A-12

ATTACHMENT 8 REPLACEMENT PAGES FOR NEDO-33351P, REVISION 0, "SAFETY ANALYSIS REPORT FOR NINE MILE POINT NUCLEAR STATION UNIT 2 CONSTANT PRESSURE POWER UPRATE" (LAR ATTACHMENT 11)

Nine Mile Point Nuclear Station, LLC December 23, 2009

NEDC-33351P - REVISION 0- CORRECTED PAGE GEH PROPRIETARY INFORMATION Table 1-1 Computer Codes Used For EPU

'r TakiTask Co p uter Version or NRC Comments Commients, .

-Code* Revision Approved _ __.....___

Nominal Reactor Heat ISCOR 09 Y(2) NEDE-2401 1-P Rev. 0 SER Balance Reactor Core and Fuel TGBLA 06 Y NEDE-30130-P-A (4)

Performance PANACEA 11 Y NEDE-30130-P-A (4)

ISCOR 09 Y(2) NEDE-2401 IP Rev. 0 SER Thermal Hydraulic ISCOR 09 Y(2) NEDE-2401 1-P Rev. 0 SER Stability PANACEA 11 Y ODYSY ODYSY05 05 Y Y NEDE-30130-P-A (4)

OPRM 01 Y(15) NEDC-32992P-A, Class III, July 2001 TRACG 04 Y(16) NEDO-32465-A RPV Fluence TGBLA 06 Y See note 14 DORTG01V 01 N See notes 12 and 13 RPV Internals Structural SAP4GO7V 01 NA NEDO-10909 (1)

Integrity Evaluation Reactor Internal Pressure ISCOR 09 Y(2) NEDE-2401 1P Rev. 0 SER Differences LAMB 07 (3) NEDE-20566-P-A TRACG 02 Y NEDE-32176P Rev. 2 0 NEDC-32177P Rev. 2 NRC TAC No. M90270 Transient Analysis PANACEA 11 Y NEDE-30130-P-A (4)

ISCOR 09 Y(2) NEDE-2401 1-P Rev. 0 SER ODYN 09 Y NEDO-24154-A SAFER 04 (5) NEDC-32424P-A, NEDC-32523P-A (8) (9) (10)

Anticipated Transient ODYN 09 Y NEDE-24154P-A Supp. 1, Vol. 4 Without Scram STEMP 04 (6)

PANACEA 11 Y NEDE-30130-P-A ISCOR 09 Y(2) NEDE-2401 1-P Rev. 0 SER Containment System SHEX 05 Y (7)

Response M3CPT 05 y NEDO-10320, Apr. 1971 LAMB 08 (3) NEDE-20566-P-A September 1986 Appendix R Fire GESTR 08 (5) NEDE-23785-1-PA Rev. 1 Protection SAFER 04 (5) (8) (9) (10)

SHEX 04 Y (7)

Reactor Recirculation BILBO 04V NA NEDE-23504, February 1977 System (1) 0 1-7

NEDC-33351P - REVISION 0- CORRECTED PAGE GEH PROPRIETARY INFORMATION (GE), "Review of NEDE-23785-1 (P), "GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident, Volumes I and II," August 29, 1983.) In addition, the use of SAFER in the analysis of long term Loss-of-Feedwater (LOFW) events is specified in the approved LTRs for power uprate: "Generic Guidelines for General Electric Boiling Water Reactor Extended Power Uprate," NEDC-32424P-A, February 1999 and "Generic Evaluations of General Electric Boiling Water Reactor Extended Power Uprate," NEDC-32523P-A, February 2000. The Appendix R events are similar to the loss of FW and small break LOCA events.

(6) The STEMP code uses fundamental mass and energy conservation laws to calculate the suppression pool heatup. The use of STEMP was noted in NEDE-24222, "Assessment of BWR Mitigation of ATWS, Volume I & II (NUREG-0460 Alternate No. 3) December 1, 1979." The code has been used in ATWS applications since that time. There is no formal NRC review and approval of STEMP.

(7) The application of the methodology in the SHEX code to the containment response is approved by NRC in the letter to G. L. Sozzi (GE) from A. Thadani (NRC), "Use of the SHEX Computer Program and ANSI/ANS 5.1-1979 Decay Heat Source Term for Containment Long-Term Pressure and Temperature Analysis," July 13, 1993 (Reference 7).

(8) Letter, J.F. Klapproth (GE) to NRC, Transmittal of GE Proprietary Report NEDC-32950P "Compilation of Improvements to GENE's SAFER ECCS-LOCA Evaluation Model," dated January 2000 by letter dated January 27, 2000.

(9) Letter, S.A. Richards (NRC) to J.F. Klapproth, "General Electric Nuclear Energy (GENE) Topical Reports GENE (NEDC)-32950P and GENE (NEDC)-32084P Acceptability Review," May 24, 2000.

(10) "SAFER Model for Evaluation of Loss-of-Coolant Accidents for Jet Pump and Non-Jet Pump Plants," NEDE-30996P-A, General Electric Company, October 1987.

(11) The NRC approved the TASC-03A code by letter from S. A. Richards, NRC, to J. F.

Klapproth, GE Nuclear Energy,

Subject:

"Review of NEDC-32084P, TASC-03A, A Computer Code for Transient Analysis of a Single Fuel Channel," TAC NO. MB0564, March 13, 2002. The acceptance version has not yet been published.

(12) CCC-543, "TORT-DORT Two-and Three-Dimensional Discrete Ordinates Transport Version 2.8.14," Radiation Shielding Information Center (RSIC), January 1994.

(13) Letter, H. N. Berkow (NRC) to G. B. Stramback (GE), "Final Safety Evaluation Regarding Removal of Methodology Limitations for NEDC-32983P-A, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations (TAC No.

MC3788)," November 17, 2005.

(14) Letter, S.A. Richards (NRC) to G. A. Watford (GE), "Amendment 26 to GE Licensing Topical Report NEDE-24011-P-A, GESTAR II - Implementing Improved GE Steady-State Methods (TAC No. MA6481)," November 10, 1999.

(15) The OPRM code is not Level 2. However, the methodology as implemented in the OPRM code has been approved by the NRC.

(16) TRACG02 has been approved in NEDO-32465-A by the US NRC for the stability DIVOM analysis. The CLTP stability analysis is based on TRACG04, which has been shown to provide essentially the same or more conservative results in DIVOM applications as the previous version, TRACG02.

0 1-9

S NEDC-3335 IP - REVISION 0 - CORRECTED PAGE GEH PROPRIETARY INFORMATION Limitation Limitation Title Limitation Description Disposition Section of NMP2' PUSAR Number from which addresses the NRC SER Limitation 9.16 Void Reactivity 2 A supplement to TRACG /PANAC 1I for Not The limitation is not applicable AOO is under NRC staff review (Reference A- Applicable to NMP2 EPU application 4). TRACG internally models the response because it is not based on surface for the void coefficient biases and Supplement 3 to NEDE-uncertainties for known dependencies due to 32906P.

the relative moderator density and exposure on nodal basis. Therefore, the void history bias determined through the methods review can be incorporated into the response surface "known" bias or through changes in lattice physics/core simulator methods for establishing the instantaneous cross-sections.

Including the bias in the calculations negates the need for ensuring that plant-specific applications show sufficient margin. For application of TRACG to EPU and MELLLA+

applications, the TRACG methodology must incorporate the void history bias. The manner in which this void history bias is accounted for will be established by the NRC staff SE approving NEDE-32906P, Supplement 3, "Migration to TRACG04/PANAC 1I from TRACG02/PANAC 10," May 2006 (Reference A-4). This limitation applies until the new TRACG/PANAC methodology is approved by the NRC staff.

A-10

0 0 0 NEDC-3335 IP - REVISION 0- CORRECTED PAGE GEH PROPRIETARY INFORMATION Limitation Limitation Title Limitation Description Disposition Section of NMP2 PUSAR Number from which addresses the NRC SER Limitation 9.19 Void-Quality For applications involving Comply Section 2.8.5.8 and Section Correlation 1 PANACEA/ODYN/ISCOR/TASC for 2.8.3.1 operation at EPU and MELLLA+, an additional 0.01 will be added to the OLMCPR, until such time that GE expands the experimental database supporting the Findlay-Dix void-quality correlation to demonstrate the accuracy and performance of the void-quality correlation based on experimental data representative of the current fuel designs and operating conditions during steady-state, transient, and accident conditions.

9.20 Void-Quality The NRC staff is currently reviewing Not The limitation is not applicable Correlation 2 Supplement 3 to NEDE-32906P, "Migration to Applicable to NMP2 EPU application TRACG04/PANAC1 1 from because it is not based on TRACG02/PANAC 10," dated May 2006 Supplement 3 to NEDE-(Reference A-4). The adequacy of the 32906P.

TRACG interfacial shear model qualification for application to EPU and MELLLA+ will be addressed under this review. Any conclusions specified in the NRC staff SE approving Supplement 3 to LTR NEDC-32906P (Reference A-4) will be applicable as approved.

A-12

ATTACHMENT 9 AFFIDAVIT JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION IN GE-HITACHI NUCLEAR ENERGY AMERICAS LLC DOCUMENT GE-NE-0000-0024-6517-RO, SAFER/GESTER LOSS-OF-COOLANT ACCIDENT ANALYSIS FOR GE14 FUEL Nine Mile Point Nuclear Station, LLC December 23, 2009

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Edward D. Schrull, state as follows:

(1) I am Vice President, Regulatory Affairs, Services Licensing, GE Hitachi Nuclear Energy Americas LLC ("GEH"), 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 GEH letter, GE-PPO-1GYEF-KG1-498, G. Carlisle, GEH, to M. Gorski, Constellation Energy Nuclear Group, "Transmittal of GE-NE-0000-0024-6517-R0," dated December 9, 2009. The proprietary information contained in Enclosure 1, which is entitled "Project Task Report, Constellation Energy, Nine Mile Point 2, SAFER/GESTR Loss-of-Coolant Accident Analysis for GE14 Fuel," is identified by a double underline inside double square brackets, ((This sentence is an example. 3 1]. In each case, the superscript notation {3l 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, GEH 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, 704F2dl280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH 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 GEH customer-funded development plans and programs, resulting in potential products to GEH;

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

Affidavit for GE-PPO- 1GYEF-KG 1-498 Affidavit Page I of 3

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 GEH, 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 GEH, 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 GEH. Access to such documents within GEH 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 for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH 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) above is classified as proprietary because it contains the GEH analysis methodology for an analysis performed in support of the Nine Mile Point-2 Extended Power Uprate (EPU) license application. Development of the EPU methodology and the supporting analysis techniques and information, and their application to the design, modification, and processes were achieved at a significant cost to GEH.

The development of the evaluation methodology along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.

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

Affidavit for GE-PPO- 1GYEF-KG 1-498 Affidavit Page 2 of 3

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

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.

GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH 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 GEH 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 on this 11 th day of December 200 Edward D. Schrull Vice President, Regulatory Affairs Services Licensing GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.

Wilmington, NC 28401 edward.schrull@ge.com Affidavit for GE-PPO- 1GYEF-KG 1-498 Affidavit Page 3 of 3

ATTACHMENT 10 AFFIDAVIT JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION IN GE-HITACHI NUCLEAR ENERGY AMERICAS LLC DOCUMENT RAI RESPONSES B2, El, F1 THROUGH F9, AND SNPB-1 Nine Mile Point Nuclear Station, LLC December 23, 2009

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Edward D. Schrull, state as follows:

(1) I am Vice President, Regulatory Affairs, Services Licensing, GE-Hitachi Nuclear Energy Americas LLC ("GEH"), 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 GEH letter, GE-PPO-lGYEF-KG1-499, G. Carlisle, GEH to M. Gorski, Constellation Energy Nuclear Group, "NMP2 EPU Round 1 RAI Responses," dated December 10, 2009. The proprietary information contained in Enclosure 1, which is entitled " RAI Responses to B2, El, F1 through F9 Proprietary, and Enclosure 3, which is entitled "RAI Response to SNPB-1 Proprietary," is identified by a dark red font and dotted underline placed within double square brackets,

((This sentence is an exam.p.e.. 3.)). 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, GEH 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, 704F2dl280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH 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 GEH customer-funded development plans and programs, resulting in potential products to GEH;

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

Affidavit for GE-PPO- 1GYEF-KG 1-499 Affidavit Page I of 3

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 GEH, 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 GEH, 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 GEH. Access to such documents within GEH 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 for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH 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) above is classified as proprietary because it contains results of an analysis performed by GEH to support Nine Mile Point-2 Extended Power Uprate (EPU) license application. This analysis is part of the GEH EPU methodology. Development of the extended power uprate methodology and the supporting analysis techniques and information, and their application to the design, modification, and processes were achieved at a significant cost to GEH.

The development of the evaluation methodology along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH'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 Affidavit. for GE-PPO-1GYEF-KGI -499 Affidavit Page 2 of 3

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 GEH.

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.

GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH 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 GEH 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 on this 11th day of December 2009.

Edward D. Schrull Vice President, Regulatory Affairs Services Licensing GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.

Wilmington, NC 28401 edward.schrull@ge.com Affidavit for GE-PPO-1GYEF-KG1-499 Affidavit Page 3 of 3

ATTACHMENT 11 AFFIDAVIT JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION IN RAI RESPONSE A2, CDI TECHNICAL NOTE NO.09-17P, REV. 0, CDI REPORT 08-08P, REV. 3, AND CDI REPORT 08-24P, REV. 2 Nine Mile Point Nuclear Station, LLC December 23, 2009

< z iLD Continuum Dynamics, Inc.

(609) 538-0444 (609) 538-0464 fax 34 Lexington Avenue Ewing, NJ 08618-2302 AFFIDAVIT Re: C.D.I. Report 08-08P "Acoustic and Low Frequency Hydrodynamic Loads at CLTP Power Level on Nine Mile Point Unit 2 Steam Dryer to 250 Hz," Revision 3; C.D.I.

Technical Note 09-17P "Limit Curve Analysis with ACM Rev. 4 for Power Ascension at Nine Mile Point Unit 2," Revision 0; C.D.I. Report 09-26P "Stress Assessment of Nine Mile Point Unit 2 Steam Dryer at CLTP and EPU Conditions," Revision 1; and Nine Mile Point Mechanical and Civil Engineering Steam Dryer Evaluation Question No. A2 I, Barbara A. Agans, being duly sworn, depose and state as follows:

1. I hold the position of Director, Business Administration of Continuum Dynamics, Inc. (hereinafter referred to as C.D.I.), and I am authorized to make the request for withholding from Public Record the Information contained in the documents described in Paragraph 2. This Affidavit is submitted to the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 2.390(a)(4) based on the fact that the attached information consists of trade secret(s) of C.D.I. and that the NRC will receive the information from C.D.I. under privilege and in confidence.

2. The Information sought to be withheld, as transmitted to Constellation Energy Group as attachments to C.D.I. Letter No. 09184 dated 10 December 2009, C.D.I.

Report 08-08P "Acoustic and Low Frequency Hydrodynamic Loads at CLTP Power Level on Nine Mile Point Unit 2 Steam Dryer to 250 Hz," Revision 3; C.D.I. Technical Note 09-17P "Limit Curve Analysis with ACM Rev. 4 for Power Ascension at Nine Mile Point Unit 2," Revision 0; C.D.I. Report 09-26P "Stress Assessment of Nine Mile Point Unit 2 Steam Dryer at CLTP and EPU Conditions," Revision 1; and Nine Mile Point Mechanical and Civil Engineering Steam Dryer Evaluation Question No. A2.

3. The Information summarizes:

(a) a process or method, including supporting data and analysis, where prevention of its use by C.D.I.'s competitors without license from C.D.I. constitutes a competitive 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 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 3(a), 3(b) and 3(c) above.

4. The Information has been held in confidence by C.D.I., its owner. The Information has consistently been held in confidence by C.D.I. and no public disclosure has been made and it is not available to the public. All disclosures toý third parties, which have been limited, have been made pursuant to the terms and conditions contained in C.D.I.'s Nondisclosure Secrecy Agreement which must be fully executed prior to disclosure.

5. The Information is a type customarily held in confidence by C.D.I. and there is a rational basis therefore. The Information is a type, which C.D.I. considers trade secret and is held in confidence by C.D.I. because it constitutes a source of competitive advantage in the competition and performance of such work in the industry. Public disclosure of the Information is likely to cause substantial harm to C.D.I.'s competitive position and foreclose or reduce the availability of profit-making opportunities.

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

Executed on this day of L4*! 2009.

16arbara A. Agans Continuum Dynamics, Inc.

Subscribed and sworn before me this day: % 7 Ei urmeýiste otr Public EILEEN P. BURMEISTER NOTARY PUBLIC OF NEW JERSEY

MY COMM. EXPIRES MAY 6, 2012

v t e Letter Sequence Other
TAC:ME1476, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance Meeting Questions 29 March 2011 8 October 2009 13 November 2009 18 November 2009 23 December 2009 10 March 2010 10 March 2010 10 March 2010 11 May 2010 10 May 2010 8 June 2010 14 July 2010 15 June 2010 18 September 2009 12 January 2010 27 January 2010 1 February 2010 6 October 2010 12 November 2010 9 February 2011 8 April 2011 14 April 2011 12 May 2011 5 April 2011 Answers 23 December 2009 19 February 2010 16 April 2010 7 May 2010 3 June 2010 30 June 2010 9 July 2010 30 July 2010 5 November 2010 13 December 2010 10 December 2010 19 January 2011 23 March 2011 9 May 2011 13 June 2011 15 July 2011 5 August 2011 19 August 2011 8 October 2015 Results Approval, Approval, Approval, Approval Other: ML092460553, ML092460595, ML092460596, ML100190073, ML100190074, ML100190075, ML100190076, ML100190077, ML101300006, ML101900448, ML101900449, ML101900450, ML101950497, ML101950498, ML103050187, ML110460160, ML110880302, ML11171A060, ML111920326, ML111950133, ML112031112, ML112081701, ML112160736, ML11221A013, ML112450479, ML112460008, ML112460009, ML113340186, ML120050150, ML120250137, ML12313A203, ML12313A204, ML12313A206, NRC-2010-0117, Final Environmental Assessment and Finding of No Significant Impact - Federal Register Notice - Related to the Proposed License Amendment to Increase the Maximum Reactor Power Level
MONTHYEAR2010-02-01 [Table View]

ML100190077

Text

1.0 INTRODUCTION

2.0 DESCRIPTION

6.0 CONCLUSION

7.0 REFERENCES

1.0 INTRODUCTION

2.0 DESCRIPTION

6.0 CONCLUSION

Subject:

Subject:

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