ML22301A174

Global Nuclear Fuel Americas, LLC (GNF) - Part 21 60-Day Interim Report Notification: GNF3 Raised Water Rod (SC-22-04 Rt)

ML22301A174
Person / Time
Site:	Hatch, Peach Bottom, Nine Mile Point, Fermi, Grand Gulf, Limerick, Clinton, FitzPatrick, LaSalle, 99901376
Issue date:	10/28/2022
From:	Murray S Global Nuclear Fuel
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML22301A173	List: ML22301A174
References
M220124, Rev. 1
Download: ML22301A174 (1)

Text

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Global Nuclear Fuel Proprietary Information Notice This letter transmits proprietary infonnation in accordance with IO CFR 2.390. Upon removal of Enclosure I, the balance of the letter may be considered non-proprietary.

M220124 Revision I October 28, 2022 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Scott P. Murray Safety Evaluation Program Manager Delegate Global Nuclear Fuel

Subject:

Part 21 60-Day Interim Report Notification: GNF3 Raised Water Rod (SC-22-04 Rt)

This letter provides Revision 1 to Global Nuclear Fuel's (GNF) interim report regarding a 10 CFR Part 21 evaluation. The purpose for this revision is to correct an inadvertent redaction of text in the summary in Enclosure 2 regarding the examination's conclusions.

One GNF3 bundle with a raised water rod was found during core verification during the bundle's first cycle of operation. The water rod remained constrained within the envelope of the fuel bundle, which was discharged to the spent fuel pool for examinations. The examinations concluded that no fuel leaks were present, and all hardware was intact with no visible damage. The apparent cause was identified as the water rod not being rotated into its proper orientation during assembly.

The information required for this GNF 60-Day Interim Report Notification per §21.21 (a)(2) is attached as Enclosure 1. Enclosure I contains proprietary information.

GNF will complete the evaluation efforts and provide a determination of reportability in accordance with IO CFR Part 21 no later than December 7, 2022.

Please contact Dr. Brian Moore, General Manager of Core and Fuel Engineering (brian.moore@gnf.com) if there are any questions.

Sincerely,

,,e~ P. ~~

Scott P. Murray Safety Evaluation Program Man er Delegate Global Nuclear Fuel

M220124 Revision I October 28, 2022 Page 2 of2

Enclosures:

t. 60-Day Interim Report Notification Information per §21.21 (a)(2) and Safety Communication-Proprietary

2. 60-Day Interim Report Notification Information per §21.21 (a)(2) and Safety Communication-Non-Proprietary cc:

3. Affidavit E. Lenning, USNRC NRR/DORL/LLPB L. Dudes, USNRC Region II Administrator J. Giessner, USNRC Region Ill Administrator PLM Spec 007NJ317 RI Document Components:

001 M220124 RI Cover Letter.pdf 002 M220124 RI Enclosure I Proprietary. pdf 003 M220124 R 1 Enclosure 2 Non-Proprietary.pdf 004 M220124 RI Enclosure 3 A ffidavit.pdf

ENCLOSURE2 M220124 Revision 1 60-Day Interim Report Notification Information per §21.2l(a)(2) and Safety Communication-Proprietary Non-Proprietary Information IMPORT ANT NOTICE This is a non-proprietary version of Enclosure I to M220124 Revision 1, 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 ((

)).

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10 CFR Part 21 Communication Global Nuclear Fuel SC 22-04 RI October 28, 2022 To:

Affected a11d Pote11tia/ly Affected Pla11ts (Attachme11t I)

Subject:

GNF3 Raised Water Rod-/11terim Notificatio11 Reportable Condition 121.2l(d)]

X 60 Day Interim Report f21.2l(a)(2)]

Transfer of Information 121.2l(b)]

X Safety Information Communication Summary:

One GNF3 bundle with a raised water rod was found during core verification during the bundle's first cycle of operation. The water rod -remained constrained within the envelope of the fuel bundle,. which was discharged to the spent fuel pool for examinations. The examinations concluded that no fuel leaks were present, and all hardware was intact with no visible damage, including the locking clip in the lower tie plate that engages the water rod bayonet end plug. The apparent cause was identified as the water rod not being rotated into its proper orientation during assembly.

The assessment to determine whether this condition is a Substantial Safety Hazard (SSH) requires further evaluation. Also, the extent of condition evaluation to establish the susceptible population of bundles is still underway. A Root Cause Analysis (RCA) is currently in-progress that is expected to inform the susceptible population determination. At this time, GNF has not determined this condition to be an SSH.

GNF has not determined that the subject condition is a reportable condition in accordance with 10 CFR Part 21.2 l(d), and continued evaluation is required to determine reportability under 10 CFR Part 21. Therefore, GNF is issuing this 60-Day Interim Notification in accordance with 10 CFR Part 21.2 l(a)(2).

GNF expects to complete the evaluation by December 7, 2022.

Please contact Dr. Brian Moore, General Manager of Core and Fuel Engineering (brian.moore@gnf.com) if there arc any questions.

Jss11ed by:

Scott P. Murray, Safety Evaluatio Global Nuclear Fuel 3901 Castle Hay_ne Rd., Wilmington NC 28402 NartL't' thu /(} ( F H Purl }I Not!fic:utm,, f>C.'rlUfft_f or,~1, ff* 1l1t'. plcmt!f or fur;t/1114:.,.fp~,ifkul~** mt11'Ulcd a.t h,*m,z uff1tc:fl*tl. Glohul Nucl.:ur f, 14e/ (GNf ) /,u_~ not

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M220124 Revision I Backgrou11d Non-Proprietary Information Page2of7 During a mid-cycle outage at a US-based BWR/6, a first cycle GNF3 bundle (designated "GEX290") was discovered to have a raised water rod during core verification inspection (Figure 1 ).

After the GEX290 discovery, a second GNF3 bundle was found with a water rod not rotated during fabrication oversight with interim additional quality control verification during manufacturing. This GNF3 bundle did not leave GNF's manufacturing facility and the condition was corrected.

An RCA is in-progress to inform the extent of condition that will inform the GNF3 susceptible population to define the affected plants. The section below describes the current state of this evaluation.

Discussio11 The GNF3 fuel design takes advantage of ((

)), to reduce the two-phase pressure drop as the flow approaches and passes through the Upper Tie Plate (UTP). ((

H During bundle assembly, the water rod is locked into place via manual rotation of the water rod, ((

)). Eight spacers are distributed axially. Each spacer is engaged by a set of tabs on the water rod that positively locate each spacer for height and separation.

The primary functions of the spacers are to hold the fuel rods in their proper locations and to improve fuel performance by mixing the water such that the fuel rods maintain the water film responsible for the heat transfer out of the rod and into the coolant: The relevant metric for this thermal-hydraulic behavior and

• associated limit is the critical power of the assembly, which varies throughout operation of the core.

Figure 2 shows a photo taken during the outage at the discovery of the raised water rod and the unengaged water rod tabs.

Figure 1: Water Rod Raised Up to Near UTP Figure 2: Closeup of Spacer 8 Water Rod Tab

M220124 Revision I Non-Proprietary Information Page3of7 After the initial discovery, further inspection of bundle GEX290 indicated that ((

)). The apparent cause was identified as the water rod not being rotated into its proper orientation during bundle assembly.

At this time, the assessment of a SSH is not complete as evaluations are ongoing. Until the suspectable population is determined and the evaluations completed, the potentially affected plants (Attachment I) are conservatively taken as all plants having GNFJ reloads.

While there has not been any indication that another similarly affected bundle has been delivered (besides GEX290 having an unlocked water rod), the full multi-disciplinary RCA, initiated on August 02, 2022, is needed to inform evaluations of the potential for other GNF3 bundles to have an unlocked water rod.

Additional time is needed for GNF to complete the evaluation to determine whether the subject condition is a reportable condition under IO CFR Part 21.

• Recommended Actions GNF has provided supplemental instructions to inspection procedures to be used during new fuel receipt of GNFJ fuel bundles at licensees' facilities. These instructions provide a receipt inspection method for licensees to independently verify that the GNFJ water rod is in the correct orientation prior to insertion of the bundle in the fuel pool. There are no additional recommended actions at this time.

M220124 Revision t X

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X X

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X Non-Proprietary Information Page 4 of7 List of Potentially Affected Plants BWR Plants and Associated Facilities Utility Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Detroit Edison Co.

Energy Northwest Entergy Entergy Entergy FirstEnergy Nuclear Operating Co.

Florida Power & Light Holtec International Nebraska Public Power District NorthStar Group Services Northeast Utilities PPL Susquehanna LLC Progress Energy PSEG Services Corp.

Southern Nuclear Operating Co.

Tennessee Valley Authority Xcel Energy Plant Clinton Dresden 2-3 FitzPatrick LaSalle 1-2 Limerick 1-2 Nine Mile Point 1-2 Peach Bottom 2-3 Quad Cities 1-2

.. Fermi 2 Columbia

.Grand Gulf River Bend Pilgrim Perry I Duane Arnold Oyster Creek Cooper Vermont Yankee Millstone Susquehanna 1-2 Brunswick 1-2 Hope Creek Hatch I

• 2 Browns Ferry 1-3 Monticello

M220124 Revision I Utility BKW-FMB, Ltd Non-Domestic B WR Plants Chubu Electric Power Co.

Chubu Electric Power Co.

Chugoku Electric Power Co.

Chugoku Electric Power Co.

Comision Federal de Electricidad

-Forsmark Kraftgrupp AB Hokuriku Electric Power Co.

Hokuriku Electric Power Co.

Iberdrola SA Japan Atomic Power Co.

Jap~n Atomic Power Co.

Kemkraftwerk Gundremmingen GmbH Kemkraftwerk Brunsbuettel GmbH KemkraftweFk Kruemmel GmbH Kemkraftwerk Philippsburg Kernkraftwerk Leibstadt AG Kraftgrupp AB Kraftgrupp AB Nuclenor SA 0KG Aktiebolag Taiwan Power Company Taiwan Power Company Taiwan Power Company Teollisuuden Voima Oy Tokyo Electric Power Company Tokyo Electric Power Company Tokyo Electric Power Corporation Tokyo Electric Power Corporation Tohoku Electric Power Company Tohoku Electric Power Company Non-Proprietary Information Page 5 of 7 Plant Milhleberg Hamaoka 1-4 Hamaoka 5 Shimane 1-2 Shimane 3 Laguna Verde 1-2 Forsmark 1-3 Shika 1 Shika 2 Cofrentes Tokai 2 Tsuru&a 1..

Gundremmingen B, C Brunsbuettel Kruemmel Philipsburg Leibstadt Forsmark Ringhals I Santa Maria De Garoiia Oskarshamn 1-3 Chinshan 1-2 Kuosheng 1-2 Lungmen 1-2"'

Olkiluoto 1-2 Fukushima Daiichi 1-6 Fukushima Daini 1-4 Kashiwazaki 1-5 Kashiwazaki 6-7 Higashidori I Onagawa 1-3

M220124 Revision I Utility AmerenUE US PWR Plants Arizona Public Service Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Constellation Energy Generation Dominion Dominion Dominion Dominion Dominion Duke Energy Corporation Duke Energy Corporation Duke Energy Corporation Duke Energy Corporation Duke Energy Corporation Duke Energy Corporation Entergy Entergy Enterg)'.

• Entergy FirstEnergy Nuclear Operations Co.

FirstEnergy Nuclear Operating Co.

Fl.orida Power & Light Florida Power & Light Florida Power & Light Florida Power & Light Indiana Michigan Power Corp Northern S_tates Power Pacific Gas & Electric Co.

PSEG Nuclear LLC PSEG Nuclear LLC South Carolina-Electric & Gas Co.

South Texas Project Nuclear Operating Co.

Southern California Edison Co.

Southern Nuclear Operating Co.

Southern Nuclear Operating Co.

Tennessee Valley Authority Tennessee Valley Authority Tennessee Valley Authority TXU Electric Generation Co.

Wolf Creek Nuclear Operating Corp.

Non-Proprietary Information Page 6 of7 Plant Callaway Palo Verde 1-3 Braidwood 1-2 Byron 1-2 Calvert Cliffs 1-2 Fort Calhoun Ginna Three Mile Island I Kewaunee Millstone 2 Millstone 3 North Anna 1-2 Surry 1-2 Catawba 1-2 Crystal River 3 McGuire 1-2 Oconee 1-3 Robinson Shearon Harris Arkansas Nuclear One 1-2 Indian Point 2-3 Palisades Waterford 3 Beaver Valley 1-2 Davis-Besse Seabrook.

• St. Lucie 1-2 Turkey Point 3-4 Point Beach 1-2 DC Cook 1-2 Prairie Island 1-2 Diablo Canyof! 1-2 Salem 1 Salem 2 Summer South Texas Project 1-2 San Onofre 2-3 Farley 1-2 Vogtle 1-2 Sequoyah 1-2 Watts Bar 1 Watts Bar 2 Comanche Peak 1-2 Wolf Creek

M220124 Revision I Non-Proprietary Information Page 7 of 7 - Recent GE Hitachi Nuclear Energy 10 CFR Part 21 Communications The following is a list of recent IO CFR Part 21 communications that GE Hitachi Nuclear Energy (GEH) and Global Nuclear Fuel (GNF) have provided to affected licensees as Reportable Conditions (RC), Transfers of Information (Tl), 60-Day Interim Reports (60 Day) and/or Safety Information Communications (SC).

Number Ref.

SC 22-01 PRC 22-01 SC 22-02 PRC 22-03 SC 22-03 PRC 22-02 SC 22-04 PRC 22-04 SC 22-04 PRC 22-04 Revision I Subject Inadequately sized I rated equipment used to perform dedication testing on a safety related transformer Design Change Implemented by Manufacturer Impacts Qualification Updated Lifetime Limits for Marathon-C+ Control Rods GNF3 Raised Water Rod -. Interim Notification GNF3 Raised Water Rod - Interim Notification Date 5/26/2022 6/8/2022 6/16/2022 9/28/2022 10/27/2022

ENCLOSURE3 Global Nuclear Fuel-Americas, LLC AFFIDAVIT I, Scott P. Murray, state as follows:

(1) I hold the position of Manager, Facility Licensing, for Global Nuclear Fuel-Americas, LLC (4'GNF-A" in this affidavit), have been delegated the responsibility of reviewing the information belonging to GNF-A described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding from public disclosure.

(2) The sensitive security-related information and confidential commercial (hereinafter referred to as "proprietary") information and personally identifiable information requested to be withheld from public disclosure is contained in Enclosure l of GNF-A's letter, Scott P.

Murray to U.S. NRC Document Control Desk, Letter No. M220124 Revision I, "Part 21 60-Day Interim Report Notification: GNF3 Raised Water Rod (SC-22-04 Rl)" dated October 28, 2022. GNF proprietary information in M220124, Revision l is identified by a dotted underline inside double square brackets. ((This sentence is an.example. 131)). GNF proprietary information in figures and large objects is identified by double square brackets before and after the object. In each case, the superscript notation l3J refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of confidential information of which it is the owner, GNF-A relies upon the exemptions 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), 9.17(a)(6), 2.390(a)(4), and 2.390{a)(6) for "trade secrets and commercial or financial information" (Exemption 4) and "personnel and medical files" (Exemption 6) and IO CFR 2.390(d), as well as the guidance in NRC RIS 2005-31, for "security-related information". The material for which exemption from disclosure is here sought is all "confidential commercial or financial information" or "personnel information", and some portions also may 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, 704F2d1280 (DC Cir.

1983).

( 4) Some examples of categories of information which fit into the definition of confidential, trade secret, or 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 organizational structures, cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;

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

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

The information requested to be withheld is considered to be confidential because it reveals confidential commercial and/or financial information regarding the operations of GNF-A and its related joint venture entities or reveals personal information of individuals, and some of the former information is also considered proprietary for the reasons set forth in paragraph (4)c. 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. Notwithstanding the foregoing, in the case of certain summaries, tables, charts, and similar compilations of information, while the overall compilation is deemed proprietary by GNF-A, discrete pieces ofinformation within the larger compilation may not be proprietary and may have been separately publicly disclosed or be 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 confidentiality or proprietary information agreements which provide for maintenance of the information in confidence. Its initial designation as confidential or 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 confidential or 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. Access to such documents within GNF-A is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by, as applicable, the staff manager, project manager, principal scientist or other equivalent authority; the manager of the cognizant marketing function (or his delegate); and the Legal organization, for technical content, competitive effect, and determination of the accuracy of the confidential or 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 confidentiality or proprietary information agreements.

(8) The information identified in paragraph (2), above, is designated as confidential because it reveals: (a) commercial and/or financial information regarding the operations of GNF-A and its related joint venture entities; (b) security-related information; and/or (c) personal privacy information of individuals.

(9) Public disclosure of the infonnation sought to be withheld is inconsistent with the intent of the requirements for submittal and is likely to cause harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities and would reveal personal privacy information and potentially reduce information security.

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, infonnation, and belief.

Executed on this 28th day of October 2022.

&A~

Scott P. Murray Manager, Facility Lice~

Global Nuclear Fuel-Americas, LLC