LR-N21-0018, Response to Requests for Additional Information SNSB-RAI 2 and SNSB-RAI 3 License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communication

Response to Requests for Additional Information SNSB-RAI 2 and SNSB-RAI 3 License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communication

ML21119A367
Person / Time
Site:	Hope Creek
Issue date:	04/29/2021
From:	Duke P Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21119A366	List: LR-N21-0018, Response to Requests for Additional Information SNSB-RAI 2 and SNSB-RAI 3 License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communication
References
(EPID L-2020-LLA-0210, EPID L-2020-LLA-0210, LAR H20-04, LR-N21-0018
Download: ML21119A367 (11)

Text

Enclosure 3 Contains Proprietary Information to be Withheld from Public Disclosure Pursuant to 10 CFR 2.390 10 CFR 50.90 LR-N21-0018 LAR H20-04 April 29, 2021 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

Response to Requests for Additional Information SNSB-RAI 2 and SNSB-RAI 3 Re: License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communication (EPID L-2020-LLA-0210)

References:

1. PSEG letter to NRC, License Amendment Request: Revise Hope Creek Generating Station Low Pressure Safety Limit to Address General Electric Nuclear Energy Part-21 Safety Communication SC05-03, dated September 24, 2020 (ADAMS Accession No. ML20272A063)

2. NRC letter to PSEG, Hope Creek Generating Station - Request for Additional Information RE: License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communications (EPID L-2020-LLA-0210), dated February 18, 2021, (ADAMS Accession No. ML21041A397)

In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) for Hope Creek Generating Station (HCGS). The proposed amendment would revise HCGS Technical Specifications (TS) 2.1.1 to lower the Low Pressure Safety Limit to address General Electric (GE) Nuclear Energy Part 21 Safety Communication SC05-03.

In the Reference 2 letter, the U.S. Nuclear Regulatory Commission staff provided PSEG a Request for Additional Information (RAI) to support the NRC staffs detailed technical review of Reference 1. The enclosures to this letter contain responses to questions RAI 2 and RAI 3 contained in the Reference 2 letter. As discussed with NRC staff, the response to question RAI 1 in the Reference 2 letter will be transmitted in a separate letter by May 31, 2021. The non-

LR-N21-0018 10 CFR 50.90 Page 2 Enclosure 3 Contains Proprietary Information to be Withheld from Public Disclosure Pursuant to 10 CFR 2.390 proprietary version of the responses to questions RAI 2 and RAI 3 are provided in Enclosure 1. contains an affidavit for withholding information executed by GE-Hitachi. The proprietary version of the responses to questions RAI 2 and RAI 3 are provided in Enclosure 3.

PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please contact Mr. Michael Wiwel at 856-339-7907.

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

q Executed on ___ _;_.pA=r ..;..;. il-=2=9_,_, =2=02=-1 (Date) c Paul R. Duke, Jr.

Manager - Licensing PSEG Nuclear LLC Non-Proprietary Response to Request for Additional Information (EPID L-2020-LLA-0210) Affidavit for withholding information executed by GE-Hitachi Proprietary Response to Request for Additional Information (EPID L-2020-LLA-0210) cc: Administrator, Region I, NRC NRC Project Manager NRC Senior Resident Inspector, Hope Creek Ms. A. Pfaff, Manager, NJBNE PSEG Corporate Commitment Tracking Coordinator Station Commitment Tracking Coordinator

Enclosure 1 Response to Questions RAI 2 and RAI 3 in Request for Additional Information by Nuclear Systems Performance Branch on Changes in Technical Specification 2.1.1 Due to General Electric Safety Communication SC05-03 for Hope Creek Generating Station L-2020-LLA-0210 (Non-Proprietary Version)

SNSB-RAI 2:

Regulatory Basis:

Criterion 10 - Reactor Design: The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.

RAI:

For the analysis to evaluate the performance of the GEXL14 and GEXL17 correlations against the GNF3 test data, Reference 2, Section 3.0 states:

((An adjustment of the R-factor additive constants is selected in this evaluation to shift the critical power prediction to GNF3 data at the reference condition. Here reference condition refers to a set of data for a given flow, inlet subcooling and rod peaking where data exist for a wide range of pressures. Aligning GEXL at the reference condition enables the assessment of GEXL17 and GEXL14 correlations pressure trends by excluding the effect of GNF3 specific effects in critical power data. GNF3 fuel has shown improved critical power performance for higher flow while similar performance for low flow compared to GNF2 and GE14. In addition, GNF3 critical power performance improvement is different between axial power shapes. Therefore, the adjustment of additive constants is necessary for each flow condition and axial power shape to better characterize GEXL pressure trend against GNF3 data. {3}))

(a) Explain why the ((adjustment of R-factor additive constants is selected to shift the critical power prediction by the GEXL14 and GEXL17 correlations to the GNF3 data. {3}))

(b) Explain what is meant by ((Aligning GEXL at the reference condition enables the assessment of GEXL17 and GEXL14 correlations pressure trends by excluding the effect of GNF3 specific effects in critical power data. {3}))

(c) Confirm that the ((adjustment was made in the additive constants provided in Reference 3, Table 5-1, and Reference 4, Table 5-2 for the GEXL14 and GEXL17 correlations {3} ))

respectively. If not, provide the source of the ((additive constants that were adjusted. {3}))

(d) Based on the statement in Reference 5, Section 5.2.5, the additive constant applied to each fuel rod location ((is dependent on the fuel assembly spacer and channel geometry. {3}))

Explain how this ((dependency was considered in the adjustment of the R-factor additive constants. {3}))

order to better evaluate the correlation trend with pressure, the GEXL correlation needs an adjustment to capture the critical power characteristic of GNF3 fuel at the reference condition.

For this evaluation, reference condition refers to a set of data for a given flow, inlet cooling and Response to SNSB-RAI 2:

(a) The purpose of this evaluation is to show the adequacy of the GEXL17 (or GEXL14) correlation in predicting the critical power trends of GNF2 (or GE14) fuel down to 600 psia.

Due to the lack of critical power data for GNF2 (or GE14) fuel down to 600 psia, the critical power data for GNF3 fuel are used in this evaluation. While the pressure trends between fuel product lines are expected to be similar, the GEXL17 (or GEXL14) correlation is not expected to accurately predict the absolute value of GNF3 critical power data due to the difference in critical power performance between fuel designs (e.g. different geometry and different spacer designs). ((In order to better evaluate the correlation trend with pressure, the GEXL correlation needs an adjustment to capture the critical power characteristic of GNF3 fuel at the reference condition. For this evaluation, reference condition refers to a set of data for a given flow, inlet subcooling and rod peaking where data exists for a range of pressures from 600 psia to 1400 psia. An R-factor additive constant for the GEXL17 (or GEXL14) correlation was determined such that the GEXL17 (or GEXL14) correlation aligned with the GNF3 data. A more detailed description of the process of the adjustment is provided in the response to RAI 2-(b). {3}))

(b) The GEXL correlation is a best-estimate correlation based on experimental data. The GEXL correlation coefficients and R-factor additive constants are determined such that the GEXL correlation has a mean ECPR (Experimental Critical Power Ratio, where Pr edicted Critical Power ECPR ) close to 1.0 and a minimized standard deviation. For Measured Critical Power example, the GEXL17 correlation coefficients and R-factor additive constants are determined to accurately predict GNF2 critical power data. ((In this evaluation, the GEXL17 (or GEXL14) correlation was applied to GNF3 data without changing the GEXL17 (or GEXL14) correlation coefficients. R-factor is an input to the GEXL correlation, which is determined by the addition of an R-factor additive constant to the raw R-factor based on rod-by-rod power distribution. To develop the GEXL correlation [RAI References 3, 4, 5]

the additive constant is determined as the difference between the R-factor needed to match the measured critical power and the raw R-factor based on the rod-by-rod power distribution.

Because this evaluation uses GNF3 critical power data, the GEXL17 (or GEXL14) R-factor that match the GNF3 data must be determined. If the GEXL21 R-factor was used with the GEXL17 coefficients, as an example, then predicted critical power would be significantly different compared to GNF3 data, thereby impacting the ability to evaluate the pressure trend. To evaluate the pressure trend of GEXL17 (or GEXL14) down to 600 psia using GNF3 data, an R-factor additive constant was determined for this specific application to the GNF3 data to shift the critical power prediction such that the mean ECPR of GEXL17 (or GEXL14) with the GNF3 data at the reference condition was close to 1.01400

a. The R-factor additive constant for the GEXL17 (or GEXL14) correlation is determined such that the GEXL17 (or GEXL14) correlation align to the GNF3 data. A more detailed It is

noted that the determination of the R-factor additive constant in this evaluation is conceptually identical to the process used to determine the R-factor additive constant at each rod location of a specific GEXL correlation [RAI References 3, 4, and 5]. However, there is no direct connection between the R-factor additive constant determined as part of this evaluation and the fuel rod additive constants for a specific GEXL correlation. The R-factor additive constant determined in this evaluation can be considered as a normalization factor for the set of GNF3 data at the reference condition. {3}))

(c) ((The additive constants defined in Table 5-2 of RAI Reference 4 for GEXL17 and in Table 5-1 of RAI Reference 3 for GEXL14 were not adjusted as part of this evaluation. An additive constant specific for the analysis of the GNF3 data with GEXL17 (or GEXL14) was determined. {3})) See response to RAI 2-(b) above for more details.

(d) The fuel rod specific R-factor additive constants are determined as part of the normal development of the GEXL correlation and ((are dependent on the fuel assembly spacer and channel geometry in general (RAI References 3, 4 and 5). However, such considerations were not necessary for the R-factor additive constant determined in this specific evaluation. {3})) See response to RAI 2-(b) above.

SNSB-RAI 3:

Regulatory Basis:

Criterion 10 - Reactor Design: The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.

RAI:

Reference 2, Section 3.1, states ((a total of 27 GNF3 test points are selected for the analysis.{3}))

Explain what is the significance and/or basis of ((27 test points. {3}))

Response to SNSB- RAI 3:

Critical power test data are collected for each unique rod position for a fuel bundle. A wide range of mass flux and inlet subcooling conditions are tested at a typical BWR operating pressure of 1000 psia. ((Because the pressure trend of critical power data can be easily captured with the GEXL correlation, off-pressure data (other than 1000 psia) are typically only collected for limited rod positions. Therefore, the amount of critical power data at very low pressure, 600 psia in this case, is limited. Within the GNF3 critical power database, all data at 600 psia were identified. Then

In summary, all 27 data points available from the GNF3 database suitable for this evaluation were used. It covers a wide range of flow and pressure conditions with two axial power shapes and two limiting rod positions. Therefore, the 27 data points are considered adequate to show the GEXL pressure trend. {3}))

he data were further searched for corresponding test points with the same peaking pattern (or target rod) at different pressures. As a result, a total of 27 GNF3 test points were identified as suitable for this analysis.

Enclosure 2 Affidavit from GEH Supporting the Withholding of Information in Enclosure 3 From Public Disclosure

Global Nuclear Fuel - Americas AFFIDAVIT I, Brian R. Moore, state as follows:

(1) I am General Manager, Core & Fuel Engineering, Global Nuclear Fuel - Americas, LLC (GNF-A), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in the GNF-A report, 006N6017 Revision 0, GNF Responses to NRC RAI 2 and RAI 3 for the Hope Creek Generating Station License Amendment Request to Revise the Low Pressure Safety Limit GNF Responses to Hope Creek Generating Station dated April 2021. The GNF-A proprietary information is identified by a dotted underline inside double square brackets. ((This sentence is an example {3})). Figures and large objects containing GNF-A proprietary information are identified with double square brackets before and after the object. In all cases, the notation {3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

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

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;

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

006N6017 Revision 0 Affidavit Page 1 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 GNF-A, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains detailed data and results including the process and methodology for the analysis to evaluate the performance of the GEXL14 and GEXL17 correlations against the GNF3 test data. The development, evaluation, and design details of the GEXL Correlations and their application to GNF fuel was achieved at a significant cost to GNF-A and are derived from an extensive experience database that constitutes a major GNF-A asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

006N6017 Revision 0 Affidavit Page 2 of 3

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

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

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

Executed on this 28th day of April 2021.

Brian R. Moore General Manager, Core & Fuel Engineering Global Nuclear Fuel - Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 Brian.Moore@ge.com 006N6017 Revision 0 Affidavit Page 3 of 3