ML23208A092
| ML23208A092 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Surry, North Anna  |
| Issue date: | 07/26/2023 |
| From: | James Holloway Dominion Energy Nuclear Connecticut, Virginia Electric & Power Co (VEPCO) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML23208A090 | List: |
| References | |
| 22-362D(O) | |
| Download: ML23208A092 (1) | |
Text
PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 Dominion Energy Services, Inc.
5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion Energy.com U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 July 26, 2023 Serial No.
22-362D(O)
NRA/SS RO Docket Nos.
50-336/423 50-338/339 50-280/281 License Nos. DPR-65/NPF-49 NPF-4/7 DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)
NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)
MILLSTONE POWER STATION UNITS 2 AND 3 REQUEST FOR APPROVAL OF APPENDIX F OF FLEET REPORT DOM-NAF-2-P QUALIFICATION OF THE FRAMATOME ORFEO-GAIA AND ORFEO-NMGRID CHF CORRELATIONS IN THE DOMINION ENERGY VIPRE-D COMPUTER CODE RESPONSE TO SECOND REQUEST FOR ADDITIONAL INFORMATION By letter dated December 19, 2022 [Serial No.22-362 (ADAMS Package No.
ML22353A618)], Dominion Energy Virginia and DENG (collectively, Dominion Energy) submitted Appendix F, "Qualification of the Framatome ORFEO-GAIA and ORFEO NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code" to Fleet Report DOM-NAF-2-P for review and approval by the Nuclear Regulatory Commission (NRG). The request for review was supplemented by letter dated April 6, 2023 (ADAMS Accession No. ML23096A297 (Proprietary, Non-Public, ML23096A298 (Public)).
By email dated June 20, 2023 [ADAMS Accession No. ML23171B052], the NRC requested additional information (RAI) to facilitate their review. Dominion Energy agreed to respond to the RAI within 45 days of issuance, or no later than August 4, 2023. The proprietary and non-proprietary versions of Dominion Energy's response to the RAI are provided in and 2, respectively. contains information proprietary to Framatome Inc. and is supported by an affidavit (Attachment 3) signed by Framatome, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. A redacted, non-proprietary response to the NRG request for additional information is provided in Attachment 2. contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation from Attachment 1, this letter is decontrolled.
~
Dominion
- iii" Energy
Serial No. 22-362D Docket Nos. 50-336/423/338/339/280/281 Page 2 of 3 If you have questions or require additional information, please contact Mr. Shayan Sinha at (804) 273-4687.
Respectfully, r James E. Holloway Vice President - Nuclear Engineering and Fleet Support Commitments made in this letter: None Attachments:
- 1. Response to Second NRC Request for Additional Information Related to Appendix F to Fleet Report DOM-NAF-2-P, "Qualification of the Framatome ORFEO-GAIA and ORFEO-NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code" (Proprietary)
- 2. Response to Second NRC Request for Additional Information Related to Appendix F to Fleet Report DOM-NAF-2-P, "Qualification of the Framatome ORFEO-GAIA and ORFEO-NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code" (Non-Proprietary)
Serial No. 22-362D Docket Nos. 50-336/423/338/339/280/281 Page 3 of 3 cc:
U.S. Nuclear Regulatory Commission - Region I 475 Allendale Road, Suite 105 King of Prussia, PA 19406-1415 U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 Mr. R. V. Guzman NRC Senior Project Manager - Millstone Units 2 and 3 U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 9 E3 11555 Rockville Pike Rockville, MD 20852-2738 Mr. G. Edward Miller NRC Senior Project Manager - North Anna Units 1 and 2 U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 9 E3 11555 Rockville Pike Rockville, MD 20852-2738 Mr. L. John Klos NRC Project Manager-Surry Units 1 and 2 U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 9 E3 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station
Serial Number 22-362D Docket Nos. 50-336/423/338/339/280/281 RESPONSE TO SECOND NRC REQUEST FOR INFORMATION RELATED TO APPENDIX F TO FLEET REPORT DOM-NAF-2-NP, QUALIFICATION OF THE FRAMATOME ORFEO-GAIA AND ORFEO-NMGRID CHF CORRELATIONS IN THE DOMINION ENERGY VIPRE-D COMPUTER CODE (NON-PROPRIETARY)
Virginia Electric and Power Company (Dominion Energy)
North Anna and Surry Power Stations Units 1 and 2 Dominion Energy Nuclear Connecticut, Inc. (DENC)
Millstone Power Station Units 2 and 3
Serial Number 22-362D Docket Nos. 50-336/423/338/339/280/281, Page 1 of 30 By letter dated December 19, 2022 [Serial No.22-362 (ADAMS Package No.
ML22353A618)], Dominion Energy Virginia and Dominion Energy Nuclear Connecticut, Inc.,
(collectively, Dominion Energy) submitted Appendix F, Qualification of the Framatome ORFEO-GAIA and ORFEO-NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code to Fleet Report DOM-NAF-2-P for review and approval by the Nuclear Regulatory Commission (NRC). The request for review was supplemented by letter dated April 6, 2023 (ADAMS Accession No. ML23096A297 (Proprietary, Non-Public, ML23096A298 (Public)).
By email dated June 20, 2023 [ADAMS Accession No. ML23171B052], the NRC requested additional information (RAI) to facilitate their review. Dominion Energy agreed to respond to the RAI within 45 days of issuance, or no later than August 4, 2023. The non-proprietary version of Dominion Energys response to the RAI is provided in this attachment.
NRC Question 1 Upon review of the licensee request and the subsequent validation data provided by the licensee April 6, 2023 (ADAMS Accession No. ML23096A298), the NRC has determined that the following additional information is necessary to complete its review and make a regulatory decision:
- 1. A plot of pressure versus M/P for ORFEO-GAIA and ORFEO-NMGRID data revealed ((
)). Further investigation of the validation data provided by the licensee revealed the following potential ((
)):
For ORFEO-GAIA - ((
))
For ORFEO-NMGRID - ((
))
Serial Number 22-362D Docket Nos. 50-336/423/338/339/280/281, Page 2 of 30 Dominion Energy Response to NRC Question 1 VIPRE-D/ORFEO-GAIA The submitted data was generated using a version of VIPRE-D that calculated the Critical Heat Flux (CHF) correlation input parameter for burnout length (BoL) by ((
)). Following submittal of the dataset to the NRC, Dominion Energy identified that the dataset submitted in ANP-10341-A calculated the BoL by ((
)) structure was adopted within a new modification of the VIPRE-D code to ensure alignment with the vendor dataset.
Use of this new modification of VIPRE-D ((
)) resulted in a slight modification to the VIPRE-D/ORFEO-GAIA dataset and an overall calculated Deterministic Design Limit (DDL) of 1.12. Dominion Energy investigated this new dataset with the 1.12 DDL using the method described in NUREG/KM-0013, "A Generic Safety Case to Determine the Credibility of Critical Heat Flux and Critical Power Models". Specifically, Section G3.3.2 of NUREG/KM-0013 discusses identification of non-conservative subregions using a method similar to the one proposed by Kaizer, 2015 (Reference 1). Dominion Energy identified the existence of a similar potential non-conservative subregion with the same bounds as documented in the NRC RAI.
Dominion Energy also investigated the new dataset with the submitted DDL of 1.13 using the same method outlined in the NUREG/KM-0013 document and its cited paper. With the use of the submitted DDL, there are ((
)) in the identified subregion that lie below the 1.13 DDL. This meets the allowed number of points for this subregion.
Therefore, Dominion Energy concludes that the submitted DDL of 1.13 and its accompanying statistics based on the previous dataset remain conservative for the use of the VIPRE-D/ORFEO-GAIA code/correlation pair. The new dataset described in this response is provided in Table 1.
VIPRE-D/ORFEO-NMGRID Upon further investigation of the NRC-identified subregion, Dominion Energy determined that ((
)). The submitted dataset exhibits predictable behavior and ((
)) the DDL. This provides high confidence that the submitted DDL is conservative and provides at least 95/95 protection against departure from nucleate boiling (DNB).
In addition, the subregion identified by the NRC in the RAI is a ((
)). This type of subregion has been addressed in a submitted limitation for use of the VIPRE D/ORFEO-NMGRID code/correlation pair, which states: It should be confirmed that any DNB analyses performed using ORFEO-NMGRID are far removed from the ((
)). If calculations are not far removed from this region, then an appropriate additional uncertainty of the region should be quantified and applied in the analysis.
Serial Number 22-362D Docket Nos. 50-336/423/338/339/280/281, Page 3 of 30 To provide additional basis for the acceptability of the submitted statistics, Dominion Energy evaluated deterministic events applicable to the reload analyses, including accidents and setpoints for which the ORFEO-NMGRID CHF correlation would be applied. ((
)) which ensures that relevant analyses are not evaluated within this subregion.
In summary, the dataset exhibits predictable behavior, there are a ((
)), and the relevant deterministic analyses are performed outside of the NRC-identified subregion. Therefore, the submitted restriction remains appropriate to ensure the submitted DDL and statistics are adequate to preserve the safety of the nuclear fuel. If calculations are not far removed from this region, then an appropriate additional uncertainty of the region should be quantified and applied in the analysis.
NOTE: A VIPRE-D/ORFEO-NMGRID dataset was also calculated with the modification of VIPRE-D described in the VIPRE-D/ORFEO-GAIA portion of the response. Like the new VIPRE-D/ORFEO-GAIA dataset, the VIPRE-D/ORFEO-NMGRID DDL and accompanying statistics improved for the new dataset calculated with the modification of VIPRE-D, such that the submitted VIPRE-D/ORFEO-NMGRID DDL and accompanying statistics are conservative. Specific to the NRC-identified subregion, there is a decrease in the number of data points below the submitted VIPRE-D/ORFEO-NMGRID DDL for the new dataset ((
)).
Reference 1
Joshua Kaizer, Identification of Nonconservative Subregions in Empirical Models Demonstrated Using Critical Heat Flux Models, 2015.
NRC Question 2 Upon review of the licensee request and the subsequent validation data provided by the licensee April 6, 2023 (ADAMS Accession No. ML23096A298), the NRC has determined that the following additional information is necessary to complete its review and make a regulatory decision:
- 2. Confirm that the numerical solution methods and the empirical correlations used in the VIPRE-D model for the validation performed for ORFEO-GAIA and ORFEO-NMGRID data are consistent with the approved values in the topical report for the VIPRE-D code.
Serial Number 22-362D Docket Nos. 50-336/423/338/339/280/281, Page 4 of 30 Dominion Energy Response to NRC Question 2 Each test section for ORFEO-GAIA and ORFEO-NMGRID was modeled for analysis with the VIPRE-D thermal-hydraulic computer code as a full assembly model following the modeling methodology discussed in Section 4 in the main body of DOM-NAF-2-A.
5 of 30 Table 1: ORFEO-GAIA CHF Test Data Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
6 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
7 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
8 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
9 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
10 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
11 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
12 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
13 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
14 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
q Serial Number 22-362D
15 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
16 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
17 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
18 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
19 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
20 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
21 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
22 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
23 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
24 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
25 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
26 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
27 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
28 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
29 of 30 Total No. of Points Test File Test Points Axial Location
[in]
System Pressure
[psia]
Mass Flux
[Mlbm/hr-ft2]
Critical (predicted)
Heat Flux
[Mbtu/hr-ft2]
Measured Heat Flux
[Mbtu/hr-ft2]
Quality M/P Ratio Burnout length
[in]
Tong Factor Type Axial Power Profile IGM Rod OD/
GT OD [in]
Heated Length
[in]
Grid Spacing
[in]
Serial Number 22-362D
30 of 30 Notes:
1.
For ((
)), grid spacing accounts for the presence of IGM.
2.
The spacing between an IGM and the upstream GAIA grid is [
)). The spacing between an IGM and the downstream GAIA grid is ((
)).
3.
This table includes ((
)) points excluded from App. F due to a burnout length greater than ((
)).
Serial Number 22-362D
Serial Number 22-362D Docket Nos. 50-336/423/338/339/280/281 FRAMATOME AFFIDAVIT FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE Virginia Electric and Power Company (Dominion Energy)
North Anna and Surry Power Stations Units 1 and 2 Dominion Energy Nuclear Connecticut, Inc. (DENC)
Millstone Power Station Units 2 and 3
- 1.
My name is Morris Byram. I am Product 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 Attachment 1 to Dominion Energy letter Serial No. 22-362D(O), entitled "Response to Second NRC Request for Additional Information Related to Appendix F to Fleet Report DOM-NAF-2-P, 'Qualification of the Framatome ORFEO-GAIA and ORFEO-NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code'," 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 Framatome's 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 Framatome's 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: (7/25/2023)
BYRAM MO rr
- I S\\Digitally signed by BYRAM Morris
, -_ Date: 2023.07.25 14:01 :07 -07'00' (NAME) morris. byram@framatome.com