ML14051A138
| ML14051A138 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/14/2014 |
| From: | Costanzo C Constellation Energy Nuclear Group, EDF Group, Nine Mile Point |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML14051A138 (12) | |
Text
This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment (3).
Christopher R. Costanzo Office: 315-349-5200 Vice President-Nine Mile Point Fax: 315-349-1321 E-mail: Christopher.Costanzo@cengllc.com CENG.
a joint venture of
'e'F Enau' NINE MILE POINT NUCLEAR STATION February 14, 2014 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk
SUBJECT:
Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 Docket No. 50-410 License Amendment Request Pursuant to 10 CFR 50.90: Maximum Extended Load Line Limit Analysis Plus - Response to Request for Supplemental Information
REFERENCE:
(a) Letter from P. Swift (NMPNS) to Document Control Desk (NRC), dated November 1, 2013, License Amendment Request Pursuant to 10 CFR 50.90:
Maximum Extended Load Line Limit Analysis Plus (b) Email from B. Vaidya (NRC) to E. Perkins (NMPNS), dated January 2, 2014, Unacceptable Application With Opportunity To Supplement - Nine Mile Point Nuclear Station, Unit 2 - License Amendment Request - Maximum Extended Load Line Limit Analysis Plus (c) Letter from C. Costanzo (NMPNS) to Document Control Desk (NRC), dated January 21, 2014, License Amendment Request Pursuant to 10 CFR 50.90:
Maximum Extended Load Line Limit Analysis Plus - Commitment Date to Provide Supplemental Information (d) Letter from B. Hagemeier (GEH) to D. Goodney (NMPNS), dated January 28, 2014, GE-PPO-1GYEF-KG1-725, GEH Response to NRC Request for Supplement Information to Complete NMP2 MELLLA+ LAR Acceptance Review Information Nine Mile Point Nuclear Station, LLC (NMPNS) hereby provides supplemental information to the Nine Mile Point Unit 2 (NMP2) License Amendment Request for Maximum Extended Load Line Limit Analysis Plus, Reference (a), as requested by the NRC staff in an email, Reference (b). A Nine Mile Point Nuclear Station P.O. Box 63, Lycoming, NY 13093 r
This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment (3).
Document Control Desk February 14, 2014 Page 2 This supplemental information provides the diversity information requested, and the associated analysis, as clarified in the conference call with the NRC staff on January 15, 2014 and satisfies the commitment made in Reference (c).
The supplemental information was prepared by General Electric Hitachi Nuclear Energy Americas LLC (GEH) and provided to NMPNS as GEH letter GE-PPO-1GYEF-KGI-725, Reference (d). The NRC request is repeated (in italics), followed by the NMPNS response and is provided in Attachment (1) (non-proprietary) and Attachment (3) (proprietary). The affidavit from GEH detailing the reasons for the request to withhold the proprietary information is provided in Attachment (2). Attachment (3) is considered to contain proprietary information exempt from disclosure pursuant to 10 CFR 2.390.
Therefore, on behalf of GEH, NMPNS hereby makes application to withhold this attachment from public disclosure in accordance with 10 CFR 2.390(b)(1).
Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this supplemental letter to the appropriate state representative. This supplemental letter does not change the initial determination of "no significant hazards consideration" justified in the original amendment request, Reference (a).
Should you have any questions regarding the information in this submittal, please contact Everett (Chip)
Perkins, Director Licensing, at (315) 349-5219.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February 14, 2014.
Sincerely, CRC/KJK Attachments (1) Response to NRC Request for Supplement Information in Support of NMP2 MELLLA+ LAR Acceptance Review (Non-Proprietary)
(2) Affidavit from GE-Hitachi Nuclear Energy Americas LLC (GEH) Justifying Withholding Proprietary Information Contained in Attachment 3 (3) Response to NRC Request for Supplement Information in Support of NMP2 MIELLLA+ LAR Acceptance Review (Proprietary) cc: Regional Administrator, Region I, NRC Project Manager, NRC Resident Inspector, NRC A. L. Peterson, NYSERDA (without Attachment 3)
ATTACHMENT (2)
AFFIDAVIT FROM GE-HITACHI NUCLEAR ENERGY AMERICAS LLC (GEH) JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION CONTAINED IN ATTACHMENT (3)
Nine Mile Point Nuclear Station, LLC February 14, 2014
GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, James F. Harrison, state as follows:
(1) I am the Vice President, Fuel Licensing, Regulatory Affairs, of 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 Enclosure 1 of GEH letter, GE-PPO-IGYEF-KG1-725, "GEH Response to NRC Request for Supplement Information to Complete NMP2 MELLLA+ LAR Acceptance Review," dated January 28, 2014. The GEH proprietary information in Enclosure 1, which is entitled "Response to NRC Request for Supplement Information in Support of NMP2 MELLLA+ LAR Acceptance Review," is identified by a dotted underline inside double square brackets. ((T .his..sentence..is..an example.:.13)) In each case, the superscript notation t31 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 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.
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 qualifies 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 Proiect v. Nuclear Regulatory Commission, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that 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 that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
- c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
- d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.
Affidavit for GE-PPO- 1GYEF-KG 1-725 Page]1 of 3
GE-Hitachi Nuclear Energy Americas LLC (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, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH.
(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 or confidentiality agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains the detailed GEH methodology for maximum extended load line limit analysis and for the GEH Boiling Water Reactor (BWR). These methods, techniques, and data along with their application to the design, modification, and analyses associated with stability were achieved at a significant cost to GEH.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute 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.
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 Affidavit for GE-PPO- 1GYEF-KG 1-725 Page 2 of 3
GE-Hitachi Nuclear Energy Americas LLC 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 2 8th day of January 2014.
James F. Harrison Vice President, Fuels Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC Affidavit for GE-PPO- 1GYEF-KG 1-725 Page 3 of 3
ATTACHMENT (1)
RESPONSE TO NRC REQUEST FOR SUPPLEMENT INFORMATION IN SUPPORT OF NMP2 MELLLA+ LAR ACCEPTANCE REVIEW (NON-PROPRIETARY)
Nine Mile Point Nuclear Station, LLC February 14, 2014
ENCLOSURE 2 GE-PPO- 1GYEF-KG 1-725 Response to NRC Request for Supplement Information in Support of NMP2 MELLLA+ LAR Acceptance Review Non-Proprietary Information- Class I (Public)
NON-PROPRIETARY NOTICE This is a non-proprietary version of Enclosure 1 of GE-PPO-IGYEF-KG1-725 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].
of Non-Proprietary Information-Class I (Public)
GE-PPO- 1GYEF-KG 1-725 Page 1 of 4 EICB RSI 1 By letter dated November 1, 2013, ConstellationEnergy, the licensee, submitted a license amendment request (LAR) (Agencywide Document Access and Management System Accession No. ML13316B.107) to revise Nine Mile Point Nuclear Station, Unit 2 OperatingLicense and Technical Specifications allowing the plant operationto expand in the Maximum Extended Load Line Analysis Plus domain. On September 17, 2007, the MELLLA + Topic Report (TR)
(ML072330599) was approved by US. Nuclear Regulatory Commission (NRC) with the proviso that licensees must provide NRC-approvedplant specific automaticbackup stability protection for MELLLA + operation.
Upon completion of the proposedLAR, the Detect andSuppress Solution - ConfirmationDensity (DSS-CD) reactortripfinction will be credited as a requiredmitigationfunction to provide protectionagainst violation of the safety limit minimum criticalpower ratio (SLMCPR) for anticipatedoscillations. The DSS-CD solution involves incorporationof a new reactorscram function that is intendedto terminatepower oscillationsprior to significantamplitude growth. Because this new safetyfunction is being performed by the digitalNuclear Measurement Analysis and Control OscillationPower Range Monitor (NUMA C OPRM) system, and because each of the redundantdivisions of the NUMAC system use the same digital equipment programmedin the same way, the potentialfor software related common cause failures of the system must be taken into consideration.
The NRC Staff Requirements Memorandum (SRM) on SECY 93 087, dated July 21, 1993, describes the position of NRC regardingDiversity andDefense-In-Depth (D3). This SRM states that applicantsusing digital or computer based technology shall assess the defense-in-depth and diversity of the proposed instrumentationand control system to demonstrate that vulnerabilities to common mode failures have been adequately addressed The SRM also states; "in performing the assessment, the vendor or applicantshall analyze each postulatedcommon-mode failurefor each event that is evaluatedin the accident analysissection of the safety analysis report (SAR) using best estimate methods. The vendor or applicantshall demonstrate adequate diversity within the designfor each of these events. "
It is apparentthat a postulatedsoftware common-causefailure (SWCCF)of the NUMA C OPRM could disable the safety tripfunction performedby the DSS-CD algorithms. Therefore, a diverse means of performing either the same function (Reactor Trip) or a differentfunction is required Please identify what this diverse means is andprovide a documented basis that the diverse means is unlikely to be subject to the same common-mode failure that would disable the DSS-CD safety function. It is requested that the licensee provide a detailedanalysis that meets the guidance contained in BTP 7-19.
References:
- 1. US. Nuclear Regulatory Commission, NUREG-0800, "StandardReview Planfor the Review of Safety Analysis Reportsfor Nuclear Power Plants: L WR [Light- Water Reactor] Edition,"
(SRP) Branch Technical Position (BTP) 7-19. "Guidancefor Evaluation of Diversity and Defense-in-Depth in Digital Computer Based Instrumentation and Control Systems,"
Revision 5, March 2007 (ADAMS Accession No. ML070550072).
of Non-Proprietary Information-Class I (Public)
GE-PPO-1GYEF-KG 1-725 Page 2 of 4
Response
The diverse means for the safety trip function performed by the DSS-CD algorithms at the Nine Mile Point Nuclear Station Unit 2 (NMP2) for a postulated common-mode failure of the NUMAC OPRM is Manual Operator Action. The basis that the diverse means is unlikely to be subject to the same common-mode failure that would disable the DSS-CD safety function is documented below.
The OPRM system (supporting either DSS-CD or the Option III solution) is designed to automatically detect and suppress anticipated power oscillations. The postulated Common Cause Failure (CCF), assumed to result in comprehensive loss of Power Range Neutron Monitor (PRNM) system functionality, would also disable the OPRM system (i.e., Confirmation Density Algorithm (CDA) for DSS-CD and Period Based Detection Algorithm (PBDA) for Option III).
The loss of PRNM system functionality would also disable the Automatic Backup Stability Protection (ABSP) function of DSS-CD because the Average Power Range Monitor system would no longer be available.
As described in Section 7 and in the Technical Specification (TS) changes documented in the approved DSS-CD Licensing Topical Report (LTR) NEDC-33075P-A, Revision 8 (Reference 1),
if both the OPRM system is inoperable and the ABSP function cannot be implemented or is inoperable, the licensed stability solution becomes the Manual Backup Stability Protection (BSP)
Regions with the BSP Boundary, which is manually implemented through administrative actions.
This is essentially the same backup approach utilized in Option III for the PBDA algorithm. In the Option III solution there is only one BSP Option, which is provided by the Manual BSP Regions and associated operator actions.
The postulated CCF in the PRNM system results in the system providing valid indications of plant conditions until the stability transient occurs, at which time they become anomalous. In the case of power oscillations, PRNM system indications of power and flow would track consistently with other plant indicators as they change to a statepoint where the potential exists for high growth-rate power oscillations (i.e., the upper left comer of the power/flow map), but fail to provide any protection when large amplitude oscillations begin to occur.
((I In the event of a two recirculation pump trip, NMP2 operators are procedurally required to insert a manual scram as an immediate action. This immediate action is uncomplicated and completed by rotating the reactor mode switch to the shutdown position at Panel 603 in the main control room. In the event that the mode switch did not result in an immediate actuation of a reactor scram, operators would simultaneously depress the two reactor scram push buttons at Panel 603.
of Non-Proprietary Information-Class I (Public)
GE-PPO- 1GYEF-KG 1-725 Page 3 of 4 Confirmation that the manual scram is successful is unambiguous and provided within a few seconds by multiple indications including the main control rod display on Panel 603. These manual actions can be completed well ((
)) Given timely completion of the manual scram action, the SLMCPR is not exceeded throughout this event, and the acceptance criteria provided in BTP 7-19 are met.
Manipulation of either the mode switch or manual pushbuttons results in an immediate actuation of a reactor scram via the failsafe Reactor Protection System (RPS). This portion of the RPS is fully independent of a digital or software-based CCF of the PRNM system.
There are multiple diverse control room indications of a dual recirculation pump trip that are fully independent from the effects of the postulated PRNM system CCF described above. All of these affirming indications are immediately available to the control room operators at Panels 603 and 602, located adjacent to one another at the front of the NMP2 main control room. The control room indications include the following:
Recirculation System Flow Status
" Recirculation Pump differential pressure (DP) indicators on Panel 602
" Control Room Annunciators due to Recirculation Drive Motor Trips (various initiating conditions) on Panel 602
- Recirculation pump speed reducing as indicated by the Recirculation Speed Meter on Panel 602
- Other pump status control room indications available to the control room operator (depending on the pump trip failure mode) are the breaker position indication lights to Recirculation pumps and MG sets on the bench of Panel 602 and pump motor amperage on Panel 602
" Jet pump loop drive flow on Panel 602 Core Flow Status
" Total Core Flow Recorder on Panel 603
" Loops A and B Sum Jet Pump Flow Indication on Panel 602
" Calibrated jet pump flows on Panel 602 of Non-Proprietary Information-Class I (Public)
GE-PPO- 1GYEF-KG 1-725 Page 4 of 4 The ABSP is an alternative stability solution in the event that CDA becomes inoperable.
However, ABSP is designed to prevent the core from operating in regions with high potential for THI. Therefore, a postulated CCF of the ABSP would mean that the automatic scram would not occur when the reactor is operating in the BSP Scram region. The procedures for immediate action to scram the reactor as discussed above would apply. The immediate actions provide a diverse and independent method to assure reactor protection in the event of a postulated stability event with an ABSP (or PRNM system) CCF.
In summary, the NMP2 evaluation of the CCF for the PRNM system with DSS-CD was performed to disposition undetected power oscillations using the acceptance criteria provided in BTP 7-19. It was determined that sufficient redundancy and diversity exists so that the plant has the ability to cope with any CCF in the PRNM system with Option III or DSS-CD.
References:
- 1) GE Hitachi Nuclear Energy, "GE Hitachi Boiling Water Reactor Detect and Suppress Solution - Confirmation Density," NEDC-33075P-A, Revision 8, November 2013.
- 2) USNRC Standard Review Plan, "Guidance for Evaluation of Diversity and Defense-In-Depth in Digital Computer-Based Instrumentation and Controls Systems," BTP 7-19 (NUREG-0800), Revision 6, July 2012.
- 3) GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-3241OP-A, Supplement 1, November 1997.