1CAN062304, Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation

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Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation
ML23180A292
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 06/29/2023
From: Couture P
Entergy Operations
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23180A291 List:
References
1CAN062304
Download: ML23180A292 (1)
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NOTICE: Enclosure 1 to this letter contains Proprietary Information to be withheld from public disclosure per 10 CFR 2.390. Upon separation from Enclosure 1, this letter is DECONTROLLED.

Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing Tel 601-368-5102 1CAN062304 10 CFR 50.90 June 29, 2023 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation Arkansas Nuclear One, Unit 1 NRC Docket No. 50-313 Renewed Facility Operating License No. DPR-51

Reference:

Entergy letter to the NRC, "Application to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation," (1CAN102202),

ML22304A669, dated October 31, 2022.

By letter dated October 31, 2022 (Reference), Entergy Operations, Inc. (Entergy) requested U.S. Nuclear Regulatory Commission (NRC) approval of a proposed change to the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specifications (TS) that would remove the condition that allows for two reactor coolant pump (RCP) operation while at power with one RCP in operation in each Reactor Coolant System (RCS) loop. The change removes TS 3.4.4 "RCS Loops -

MODES 1 and 2" Condition A, "One RCP not in operation in each loop," Required Action A.1 to "Restore one non-operating RCP to operation," and its Completion Time of "18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />." This change makes ANO-1 TS 3.4.4 consistent with the NRC Standard Technical Specifications for Babcock and Wilcox (B&W) Plants (NUREG-1430 Revision 5).

To ensure that an adjustment to the Reactor Protection System (RPS) setpoint for reactor power with one RCP in service per loop was not required, Framatome developed the proprietary calculation FS1-0061634, "ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint." Since this document was proprietary, it was not submitted with the license amendment request (Reference). The NRC staff has requested that the calculations used to justify the License Amendment Request (LAR) and retain the 55% Rated Thermal Power (RTP) with 1 RCP in service per loop allowable value be provided in a supplement to the Reference letter.

Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213

NOTICE: Enclosure 1 to this letter contains Proprietary Information to be withheld from public disclosure per 10 CFR 2.390. Upon separation from Enclosure 1, this letter is DECONTROLLED.

1CAN062304 Page 2 of 3 Also, during a review of the Reference letter, Entergy discovered that an incorrect value for the maximum hypothetical pump-to-power monitor (PPM) trip setpoint was listed. On Enclosure 1, Page 9 of 16, in the 1st paragraph, the following statement was made:

" the ANO-1 PPM (1/1) trip setpoint could be as high as 62.3% RTP and still provide the required steady-state and transient protection."

This should state:

" the ANO-1 PPM (1/1) trip setpoint could be as high as 62.1% RTP and still provide the required steady-state and transient protection."

This value can be found calculated in Enclosure 1, Section 6.0, in the calculation preceding the last paragraph on the page. The last paragraph correctly states the ANO-1 TS 3.4.4 pump-to-power monitor trip with one RCP in service per loop could be as high as 62.1% and still provide the required steady-state and transient protection. Replacing the incorrect value for PPM provided in the Reference letter does not change Entergy's conclusions that the proposed change meets applicable requirements and does not adversely affect nuclear safety. It has no impact on the no significant hazards consideration provided in the original amendment request (Reference).

The enclosed requested supporting Framatome calculations have no impact on the no significant hazards consideration provided in the original amendment request (Reference).

Some information provided in Enclosure 1 is considered proprietary to Framatome who requests that it to be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commissions regulations. The proprietary information is identified by text enclosed within bolded brackets [Example]. The non-proprietary version is provided in Enclosure 2.

This information is supported by an affidavit, signed by Morris Byram, Manager, Licensing and Regulatory Affairs for Framatome Inc. (2101 Horn Rapids Road, Richland, WA 99354), the owner of the information. The affidavit sets forth the basis by which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. The affidavit is included as Enclosure 3.

There are no new regulatory commitments established in this submittal.

In accordance with 10 CFR 50.91, Entergy is notifying the State of Arkansas of Entergy's supplemental information by transmitting a copy of this letter and enclosure to the designated State Official.

If there are any questions or if additional information is needed, please contact Riley Keele, Manager, Regulatory Assurance, Arkansas Nuclear One, at 479-858-7826.

NOTICE: Enclosure 1 to this letter contains Proprietary Information to be withheld from public disclosure per 10 CFR 2.390. Upon separation from Enclosure 1, this letter is DECONTROLLED.

1CAN062304 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on June 29, 2023.

Respectfully, Philip Digitally sig ned by Philip Co uture Couture Dat e: 2023 .06.29 14:47:1 7 -05'00' Phil Couture PC/mar

Enclosures:

1. Technical Report-ANO-1 TS 3.4.4 LAR Support- RPS Pump-to-Power Monitor Setpoint Summary ANP-4048P, Revision 1 (PROPRIETARY)
2. Technical Report-ANO-1 TS 3.4.4 LAR Support- RPS Pump-to-Power Monitor Setpoint Summary ANP-4048NP, Revision 1 (NON-PROPRIETARY)
3. Affidavit cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Designated Arkansas State Official

ENCLOSURE 2 1CAN062304 Technical Report - ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary ANP-4048NP, Revision 1 (18 Pages)

(NON-PROPRIETARY)

ANO-1 TS 3.4.4 LAR Support - RPS ANP-4048NP Revision 1 Pump-to-Power Monitor Setpoint Summary Technical Report June 2023 (c) 2023 Framatome Inc.

0414-12-F04 (Rev. 004, 04/27/2020)

ANP-4048NP Revision 1 Copyright © 2023 Framatome Inc.

All Rights Reserved 0414-12-F04 (Rev. 004, 04/27/2020)

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page i Nature of Changes Section(s) or Item Page(s) Description and Justification 1 Section 3.0 Corrected instances of 3-to-1 PCD to 3-to-2 PCD and Table 4-1 2 Section 4.0 Added and corrected modifiers for >, <, and = for PPM and Table 4-1 trips 3 Section 6.0 Removed DNBR specific results

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page ii Contents Page

1.0 INTRODUCTION

............................................................................................... 1-1 2.0 ANALYTICAL METHODOLOGY ....................................................................... 2-1 3.0 HISTORICAL BASIS ......................................................................................... 3-1 4.0 TRANSIENT PROTECTION .............................................................................. 4-1 5.0 STEADY-STATE PROTECTION ....................................................................... 5-1 5.1 Maximum Real Power - RPS Flux/Flow Setpoint .................................... 5-1 5.2 Maximum Real Power - RPS PPM (1/1) Setpoint ................................... 5-2 6.0 2 RCP (1/1) STEADY-STATE DNB ANALYSES ............................................... 6-1 7.0

SUMMARY

AND CONCLUSION ....................................................................... 7-1

8.0 REFERENCES

.................................................................................................. 8-1

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page iii List of Tables Table 4-1: ANO-1 LOCF Events and RPS Trip Functions ........................................... 4-2

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page iv Nomenclature Acronym Definition ANO-1 Arkansas Nuclear One Unit 1 AV Allowable Value B&W Babcock and Wilcox CHF Critical Heat Flux COLR Core Operating Limits Report DNB Departure from Nucleate Boiling DNBR Departure from Nucleate Boiling Ratio FP Full Power LAR License Amendment Request LCO Limiting Condition for Operation LOCF Loss of Coolant Flow NRC Nuclear Regulatory Commission PCD Pump Coastdown PPM Pump-to-Power, Power-to-Pump, or Power/Pump Monitor P-T Pressure Temperature RCP Reactor Coolant Pump RCS Reactor Coolant System RPS Reactor Protection System RSS Root Square Sum RTP Rated Thermal Power SCD Statistical Core Design SDL Statistical Design Limit SQRT Square Root TDL Thermal Design Limit TS Technical Specifications

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 1-1

1.0 INTRODUCTION

Entergy is submitting a license amendment request (LAR) for Arkansas Nuclear One Unit 1 (ANO-1) Technical Specification (TS) 3.4.4, RCS Loops, Modes 1 and 2 (Reference 1). ANO-1 TS 3.4.4 Condition A currently allows for one reactor coolant pump (RCP) in operation per loop for 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> before requiring the plant to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. To be in line with NUREG 1430 (Reference 2) as well as the TS for the other operating Babcock & Wilcox (B&W) designed plants, the LAR will remove TS 3.4.4 Condition A. The remaining condition will then require the plant to enter Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if the limiting condition for operation (LCO) is not met.

This document provides analytical support that may be used to justify maintaining the reactor protection system (RPS) RCP-to-Power trip allowable value (AV) at 55 %RTP for 1/1 operation as defined in TS Table 3.3.1-1 (Reference 1).

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 2-1 2.0 ANALYTICAL METHODOLOGY The NRC-approved methods used to establish RPS setpoints and perform departure from nucleate boiling (DNB) calculations for the ANO-1 plant are described in Sections 7 and 6 of Reference 3, respectively.

The B&W plant methodology for DNB response analysis uses the Statistical Core Design (SCD) methodology (Reference 4) to statistically treat uncertainties. This results in a plant specific Statistical Design Limit (SDL). The SDL is higher than the applicable critical heat flux (CHF) correlation because it accounts for uncertainties. Additional margin can be added by arbitrarily increasing the SDL. The increased value is the Thermal Design Limit (TDL) which the DNB analyses then target. This methodology, as applied to B&W fuel reload analyses, is further described in Section 6.2.9 of Reference 3.

The steady-state and transient core thermal-hydraulic DNB response is analyzed with the LYNXT code (Reference 5). The LYNXT code has been approved by the NRC for use in core thermal-hydraulic analyses for the B&W-designed operating plants. The methodology used for the DNB analyses is described further in Sections 6.6 and 6.7 of Reference 3.

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 3-1 3.0 HISTORICAL BASIS The RPS power-to-pump monitor (PPM) overpower trip setpoint for 2 RCP (1/1) operation was originally designed to allow the plant to perform a controlled runback or shutdown following the loss of 1 or 2 RCPs without tripping the plant. This was based on the original Technical Specifications when the flux/flow trip was the primary trip and the power/pump monitor trip was secondary. However, with the transition of the B&W plants to the Standard Technical Specifications (Reference 2), the power/pump monitor became the primary trip and flux/flow the secondary trip. The development of the PPM 2-RCP (1/1) setpoint methodology established the following equations:

The methodology identified that the 4-to-2 and 3-to-2 pump coastdown (PCD) events, which are loss of coolant flow (LOCF) transients evolving to 2-RCP flow conditions, needed to be justified for the PPM (1/1) overpower portion of the setpoint. Both accident scenarios were already analyzed using the flux/flow setpoint, but it was also required to demonstrate that the PPM (1/1) trip provided protection for these events as well.

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 3-2 After determining the maximum allowable power, the PPM (1/1) TS setpoint (SP14) was then established as Historical calculations for several B&W plants demonstrated that the PPM (1/1) TS setpoint could be established at values greater than 65 %FP. However, the final PPM (1/1) AV was ultimately set at a conservative value of 55 %RTP for the Standard TS format for all B&W-designed plants. This approach precluded the need to further demonstrate that the PPM (1/1) trip protects the 4-to-2 PCD and 3-to-2 PCD events on a plant- or cycle-specific basis.

When considering a scenario where the plant may be operating with 2 RCPs during TS 3.4.4 LCO conditions, both the PPM (1/1) trip and the flux/flow trip provide steady-state DNB overpower protection. The following sections discuss the transient and steady-state protection specifically for the ANO-1 plant.

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 4-1 4.0 TRANSIENT PROTECTION As modeled in the accident analyses, the PPM trip is a digital type trip. If the accident analysis assumes a loss of primary flow from a reactor coolant pump trip, the trip condition is based on the initial core power. If the core power is greater than the allowed final pump status power level, a trip condition exists and a reactor trip is initiated. For example, a 4 PCD transient results in a final RCP configuration of 0/0, but the PPM will trip the plant for all idle loop conditions if the power level is greater than 0 %FP.

Consequently, the 4 PCD transient analysis models the PPM trip signal at time zero with the control rods beginning to drop after the PPM trip delay time.

The ANO-1 plant has non-redundant power-pump monitors. A single failure of a monitor would affect all four RPS channels. The primary trip for the 2 PCD event from 4 RCP operation at 100 %FP is an immediate trip on PPM for flux greater than 0 %RTP (0/2, 2/0) OR on PPM for flux greater than 55 %RTP (1/1). In accident analysis space, however, the single failure requirement results in no PPM trip and the accident is protected by the flux/flow trip. Because of the delayed trip on flux/flow, the 4-to-2 PCD event produces the lowest DNBR and sets the basis for the RPS flux/flow setpoint at ANO-1.

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 4-2 Table 4-1 summarizes the ANO-1 LOCF accidents that must be considered and the RPS setpoints that protect each scenario. The table shows that all LOCF events protected by the primary PPM trip will trip immediately regardless of whether the PPM trip is > 0 %RTP or > 55 %RTP since the initial power for 4-pump or 3-pump normal operating conditions is greater than 55 %RTP. For a scenario where the plant is operating at a power level less than or equal to 55 %FP, a 4-to-2 PCD or 3-to-2 PCD event would not initiate a plant trip. This would allow the operator to begin a controlled cooldown to Mode 3 to be in compliance with LCO requirements outlined in the proposed TS 3.4.4 LAR.

Table 4-1: ANO-1 LOCF Events and RPS Trip Functions Potential Plant Initial RPS Trip LOCF Initial Final RCP Potential Plant RPS Trips w/

RCP Used in Event Power Configuration RPS Trips Single Failure Operation Analysis of a Pump Monitor 4-to-3 4 RCP 100 %FP 2/1, 1/2 flux/flow 1.07 flux/flow 1.07 flux/flow PCD 4-to-2 4 RCP 100 %FP 2/0 or 0/2 PPM > 0 %RTP flux/flow 1.07 flux/flow PCD 1/1 PPM flux > 55 %RTP 2/0, 0/2, or 1/1 flux/flow 1.07 4-to-0 4 RCP 100 %FP 0/0 PPM flux > 0 %RTP PPM flux > 0 %RTP PPM PCD flux/flow 1.07 flux/flow 1.07 3-to-2 3 RCP 75 %FP 2/0 or 0/2 PPM flux > 0 %RTP flux/flow 1.07 flux/flow PCD 1/1 PPM flux > 55 %RTP 2/0, 0/2, or 1/1 flux/flow 1.07 Locked 4 RCP 100 %FP 2/1, 1/2 flux/flow 1.07 flux/flow 1.07 flux/flow Rotor

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 5-1 5.0 STEADY-STATE PROTECTION As previously described, the PPM trip does not place any requirement on the allowed power level for 4- or 3-RCP operation, which allows the RPS high flux and flux/flow trips to maintain the required protection. For a scenario where 2-RCP operation may occur for a short period of time, as defined by TS 3.4.4 LCO, both the RPS flux/flow and PPM (1/1) setpoints provide overpower protection.

5.1 Maximum Real Power - RPS Flux/Flow Setpoint The maximum allowable power levels associated with the RPS power/imbalance/flow (P/I/F) trip are calculated as part of the P/I/F Protective Limits provided in the core operating limits report (COLR) each cycle. The maximum power levels are determined using the equation for partial-pump scaling of the protective limits as provided in Reference (3, Section 7.3.3.2).

[

] The current ANO-1 P/I/F maximum allowable power level for 2-RCP operation is then calculated as:

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 5-2 The combination of power and flow in the steady-state DNB analysis bounds the ratio of power to flow that would be calculated for higher best-estimate 2-RCP flows. For example, [ ] produces a real power of [ ] and a corresponding power/flow ratio of [ ] which is bounded by the more conservative power/flow ratio of [ ]

5.2 Maximum Real Power - RPS PPM (1/1) Setpoint The maximum real power associated with the PPM setpoint for 2-RCP (1/1) operation can be calculated similar to the RPS high flux trip (nuclear overpower) as described in Reference (3, Section 7.4.3):

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 5-3

[

]

The ANO-1 PPM maximum real power for 2-RCP (1/1) operation can then be calculated as:

The power of 62.833 %FP represents the maximum real power that could be achieved under 2-RCP (1/1) flow conditions if the RPS PPM (1/1) AV setpoint of 55 %RTP is reached.

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 6-1 6.0 2 RCP (1/1) STEADY-STATE DNB ANALYSES The steady-state DNB analyses protect overpower conditions based on the steady-state minimum thermal design flow for different RCP combinations. ANO-1 steady-state DNB analyses for 2-RCP minimum DNB flow conditions have previously considered a maximum real power level of 64.2 %FP for the current Mk-B-HTP fuel design. This power and flow combination bounds the real power and flow combinations that could exist if either the flux/flow or PPM (1/1) trip setpoints were reached during the TS 3.4.4 LCO time frame.

To provide additional support for the TS PPM (1/1) AV setpoint of 55 %RTP, a 2-RCP steady-state DNB analysis was performed with the LYNXT code (Reference 5) at a real core power level of 70 %FP. The resulting minimum DNBR was calculated to be greater than the applicable DNBR limit for the Mk-BHTP fuel as established using the SCD methodology (Reference 4). The acceptable DNB result for this case demonstrates the steady-state DNB protection as well as the transient DNB protection for the 4-to-2 PCD and 3-to-2 PCD events as discussed in Section 3.0. The maximum allowable power can then be used with Equation 3-3 to show the margin available in the current TS PPM (1/1) AV setpoint.

This result shows that the ANO-1 TS PPM (1/1) AV could be as high as 62.1 %RTP and still provide the required steady-state and transient protection.

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 7-1 7.0

SUMMARY

AND CONCLUSION Entergy is submitting a LAR to remove TS 3.4.4 Condition A, which will then require the plant to shut down within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if only 2 RCPs are operating (1/1). The change to TS 3.4.4 will also allow removal of the 2-RCP Safety Limits, LCO limits, and RPS P/I/F setpoints and protective limits from the COLR. To support these changes, Entergy requested that an evaluation be performed to develop the basis for the current RPS RCP-to-power AV setpoint of 55 %RTP for 1/1 operation and demonstrate that it remains applicable considering the proposed LAR.

The review of the historical basis of the PPM trip showed that the original ANO-1 Technical Specifications were based on the RPS flux/flow setpoint as the primary protection and the PPM setpoint as the secondary protection for the LOCF events. The goal was to allow continued 2-RCP (1/1) operation following a 4-to-2 PCD or a 3-to-2 PCD if the flux/flow setpoint was not reached. However, with the transition to the NUREG-1430 Standard TS, the PPM setpoint became the primary protection and the flux/flow setpoint became the secondary. Consequently, the TS PPM (1/1) AV for all the B&W plants was conservatively set at 55 %RTP. This precluded the need for future plant-specific or cycle-specific PPM setpoint calculations.

To provide additional support for the current TS PPM (1/1) AV of 55 %RTP, a 2-RCP steady-state DNB analysis was performed at a real core power level of 70 %FP. The acceptable DNB result for this case demonstrates both steady-state overpower protection as well as transient protection for the 4-to-2 PCD and 3-to-2 PCD LOCF events. Additionally, a maximum allowable power of 70 %FP can support a PPM (1/1)

AV setpoint as high as 62.1 %RTP, which is conservatively bounded by the current PPM (1/1) AV of 55 %RTP by more than 7 %FP margin. Consequently, it is concluded that the ANO-1 PPM (1/1) AV has sufficient basis and analytical support to remain at 55 %RTP following the proposed TS 3.4.4 LAR changes that will further restrict 2-RCP operation and remove associated 2-RCP limits and setpoints from the COLR.

Framatome Inc. ANP-4048NP Revision 1 ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary Technical Report Page 8-1

8.0 REFERENCES

1. Arkansas Nuclear One, Unit 1, Technical Specifications and Bases, Docket No 50-313, Amendment 274, Bases Revision 76
2. NUREG-1430, Revision 5, Standard Technical Specifications for Babcock

& Wilcox Plants

3. 43-10179PA-009, Safety Criteria and Methodology for Acceptable Cycle Reload Analyses, BAW-10179P-A, Rev. 9, November 2017
4. 43-10187PA-00, Statistical Core Design for B&W Designed 177 FA Plants, BAW-10187P-A, March 1994
5. 43-10156A-01, LYNXT - Core Transient Thermal-Hydraulic Program,,

BAW-10156-A, Rev. 1, March 1991

ENCLOSURE 3 1CAN062304 Affidavit (3 Pages)

AFFIDAVIT

1. My name is Morris Byram. I am Manager, Licensing & Regulatory Affairs for Framatome Inc. (Framatome) and as such I am authorized to execute this Affidavit.
2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
3. I am familiar with the Framatome information contained in Framatome technical report ANP-4048P, entitled ANO-1 TS 3.4.4 LAR Support - RPS Pump-to-Power Monitor Setpoint Summary, and referred to herein as Document. Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.
4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.
6. The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:

(a) The information reveals details of Framatomes research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.

(e) The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.

The information in this Document is considered proprietary for the reasons set forth in paragraph 6(c) and 6(d) above.

7. In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
8. Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

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

Executed on: (6/20/2023)

Digitally signed by BYRAM BYRAM Morris Morris Date: 2023.06.20 14:01:25 -07'00' (NAME) morris.byram@framatome.com

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