ML21225A006

Response to Request for Additional Information Regarding License Amendment Request to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev.1 and NSAL-15-1, Rev. 0

ML21225A006
Person / Time
Site:	Byron, Braidwood, Ginna
Issue date:	08/13/2021
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21225A005	List: ML21225A006 RS-21-082, Attachment 2 - Technical Basis for NSAL-09-5 Revision 1 and Applicability to Byron, Braidwood, and R.E. Ginna Non-Proprietary Version for NRC
References
RS-21-082
Download: ML21225A006 (9)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 RS-21-082 10 CFR 50.90 August 13, 2021 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Response to Request for Additional Information Regarding License Amendment Request to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev.1 and NSAL-15-1, Rev. 0

References:

1) Letter from D. Gudger (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Application to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev. 1 and NSAL-15-1, Rev. 0,'" dated April 7, 2021 (ADAMS Accession No. ML21097A226)

2) Email from J. Wiebe (U. S. Nuclear Regulatory Commission) to J. Hodge (Exelon Generation Company, LLC), "Request for Additional Information -

Braidwood, Byron, and Ginna - Amendment to Address the Issues in Westinghouse NSALs," dated July 8, 2021 (ADAMS Accession No. ML21189A160)

In Reference 1, Exelon Generation Company, LLC, (EGC) requested an amendment to the Technical Specifications (TSs) for Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, and R. E. Ginna Nuclear Power Plant (Braidwood 1 and 2, Byron 1 and 2, and Ginna, Attachment 3 contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 3, this document is decontrolled.

August 13, 2021 U. S. Nuclear Regulatory Commission Page 2 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 respectively). The proposed amendment would modify Required Actions and Surveillance Requirements associated with TS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)). These revisions implement a series of more restrictive required actions and more thorough surveillance requirements that are used in instances where the transient heat flux hot channel factor, , is not within its operating limits.

In Reference 2, the U. S. Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the proposed amendment. The RAI request in Reference 2 was discussed during a teleconference between Exelon and NRC representatives on July 21, 2021.

The response to this request is due no later than 45 days from the date of Reference 2 (i.e., by August 23, 2021). Attachments 1 through 4 provide the requested information. to this letter contains information proprietary to Westinghouse Electric Company LLC (Westinghouse) as defined by 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." It is supported by an Affidavit signed by Westinghouse, the owner of the information.

The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the NRCs regulation.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390 of the NRCs regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-21-5210 and should be addressed to Anthony J. Schoedel, Manager, eVinci Licensing & Configuration Management, Westinghouse Electric Company, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066. The Affidavit supporting the proprietary nature of the information in Attachment 3 is provided in .

EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the basis for concluding that the proposed license amendments do not involve a significant hazards consideration.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

a copy of this letter and its attachments are being provided to the designated States of Illinois and New York officials.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this letter, please contact Jessie Hodge at (610) 765-5532.

Attachment 3 contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 3, this document is decontrolled.

August 13, 2021 U. S. Nuclear Regulatory Commission Page 3 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 13th day of August 2021.

Respectfully, David T. Gudger Sr Manager - Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1) Response to Request for Additional Information (Non-Proprietary)

2) Technical Basis for NSAL-09-5 Revision 1 and Applicability to Byron, Braidwood, and R.E.

Ginna Non-Proprietary Version for NRC (Non-Proprietary)

3) Technical Basis for NSAL-09-5 Revision 1 and Applicability to Byron, Braidwood, and R.E.

Ginna Proprietary Version for NRC (PROPRIETARY)

4) Westinghouse Affidavit, CAW-21-5210 (Non-Proprietary) cc: NRC Regional Administrator - NRC Region I w/ attachments NRC Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood NRC Senior Resident Inspector - Byron NRC Senior Resident Inspector - Ginna NRC Project Manager, NRR - Braidwood and Byron NRC Project Manager, NRR - Ginna A. L. Peterson, NYSERDA Illinois Emergency Management Agency - Division of Nuclear Safety Attachment 3 contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 3, this document is decontrolled.

Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 ATTACHMENT 1 Response to Request for Additional Information REQUEST FOR ADDITIONAL INFORMATION

1.0 INTRODUCTION

By application dated April 7, 2021, Exelon Generation (the licensee) requested changes to the Technical Specifications (TSs) for Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, and R. E. Ginna Nuclear Power Plant (Braidwood 1 and 2, Byron 1 and 2, and Ginna, respectively) (Agencywide Document Access and Management System Accession No. ML21097A226). The proposed changes would revise Required Actions and Surveillance Requirements associated with TS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)). These revisions implement a series of more restrictive required actions and more thorough surveillance requirements that are used in instances where the transient heat flux hot channel factor, , is not within its operating limits.

Similar required actions and surveillance requirements had been administratively implemented at each facility under the auspices of NRC Administrative Letter (AL) 89-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety. These actions had been implemented since Westinghouse notified its customers, including the licensee, that the existing required actions and surveillance requirements associated with TS 3.2.1 may not restore adequate operating margin to ensure that the FQ operating limit would prevent any of the facilities from exceeding the linear heat rate assumed in the plants emergency core cooling system (ECCS) evaluations.

2.0 REGULATORY REQUIREMENTS The performance requirements and design criteria applicable to the power distribution assumed in the safety analysis are those that pertain to accident and transient analysis. Primarily these include the requirements contained in 10 CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors, and General Design Criterion (GDC) 10, contained in Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR 50.

The requirements in 10 CFR 50.46 state, in part, that ECCS shall be designed such that an evaluation performed using an acceptable evaluation model demonstrates that acceptance criteria, set forth in 10 CFR 50.46(b), including peak cladding temperature, cladding oxidation, hydrogen generation, maintenance of coolable core geometry, and long-term cooling are met for a variety of hypothetical loss-of-coolant accidents (LOCAs), including the most severe hypothetical LOCA.

GDC 10, Reactor Design, states as follows:

The reactor and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not Page 1 of 2 Attachment 3 contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 3, this document is decontrolled.

Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 ATTACHMENT 1 Response to Request for Additional Information exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.

The requirements for TS are set forth in 10 CFR 50.36, Technical Specifications. Specific categories of TS are provided in 10 CFR 50.36(c). These include limiting conditions for operation (LCOs). If an LCO is not met, the facility must be shut down, or other acceptable remedial action must be taken. The licensee proposed a set of remedial actions, including reductions in the operating space defined by the combination of rated thermal power and axial flux difference (AFD) that would ensure that the margins continue to ensure that the plants continue to be operated in a manner bounded by the initial conditions assumed in the design basis accident and transient analyses. These actions should, therefore, continue to assure compliance with the requirements of 10 CFR 50.46 and GDC 10.

3.0 REQUEST The licensee stated that the required thermal power and axial flux difference (AFD) reductions, which were proposed to be relocated to the Core Operating Limits Report, would initially be those contained in Table 1 of Attachment 1 to the licensees April 7, 2021, submittal. These were based on interim, compensatory measures that had been recommended from Westinghouse when the current required actions and completion times were deemed inadequate. The technical basis for these reductions in thermal power and AFD is not apparent to the NRC staff. Provide information that demonstrates the proposed operating space reductions contained in Table 1 bring about the desired margin improvements, thus assuring compliance with 10 CFR 50.46 and GDC 10 requirements.

EGC Response:

The technical basis for NSAL-09-5, Revision 1, is provided in Attachments 2 and 3. Attachments 2 and 3 also capture the results of Westinghouse analyses to demonstrate that the proposed operating space reductions in thermal power and AFD are sufficient to restore required margin and protect limits at Braidwood 1 and 2, Byron 1 and 2, and Ginna. The Affidavit supporting the proprietary nature of the information in Attachment 3 is provided in Attachment 4.

Page 2 of 2 Attachment 3 contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 3, this document is decontrolled.

ATTACHMENT 4 Westinghouse Affidavit, CAW-21-5210 (NON-PROPRIETARY) 3 pages follow contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 3, this document is decontrolled.

Westinghouse Non-Proprietary Class 3 CAW-21-5210 Page 1 of 3 COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER:

(1) I, Anthony J. Schoedel, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of CE-20-392, Revision 1, Attachment 2 be withheld from public disclosure under 10 CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4) Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable

• • • This record was final approved on 8/6/2021 1:14:16 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CAW-21-5210 Page 2 of 3 others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

(5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use 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 a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

• • • This record was final approved on 8/6/2021 1:14:16 PM. (This statement was added by the PRIME system upon its validation)

Wcstin 'hOlbc Non -l'wpric1a1 1 Cla:;s 3 Ct\ \\'-:.? I - ~ 2 I 0 l'agc 3 11f 3 (6 ) "111c att:'lchcd documents arc bracketed and marked to indicate the bases for withholding. Th1.:

j usri.tication for withhokling is indicated in botl1 versions by mc*m

• of lower-case lcl!as (;.i) thn ugh (I) loc:atcd as a supascript immcdiatdy following the brackets enclosing each item of infom1atilm 1-x:ing idcntifo:d as proprietary or in the margin opposite sud1 infonnation. Tlu.:~c lowcr-G1sc krtcrs retcr to the types of information Wcstinghou *i.: customarily holds in confidcnc\; identified in Sections (5)(a) through (t) of this AtJidavit.

I dcdan: that the avcnncnts of fact ' Ct forth in this Affidavit arc trnc and correct to 1J1c bes! of my kmnvkdgc, infonrn1tion, and belief.

I declare under penalty of perjury that the foregoing is true and com;d.

Execuced on: f / *s/;;OJ_ I tl/fi#. .Id(

Anthony J. Schocdd, Manager eVinci Licensing & Configuration Management

• • • This record was final approved on 8/6/2021 1:14:16 PM. (This statement was added by the PRIME system upon its validation)