LR-N25-0076, Pre-Submittal Meeting Slides for License Amendment Request to Add Data Validation and Reconciliation (DVR) Methodology to Existing Measurement Uncertainty Recapture Power Uprate

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Pre-Submittal Meeting Slides for License Amendment Request to Add Data Validation and Reconciliation (DVR) Methodology to Existing Measurement Uncertainty Recapture Power Uprate
ML25252A315
Person / Time
Site: Salem  PSEG icon.png
Issue date: 09/09/2025
From: Jurek S
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML25252A316 List:
References
LR-N25-0076
Download: ML25252A315 (1)
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Text

Enclosure 1 Contains Proprietary Information.

Withhold from Public Disclosure Under 10 CFR 2.390(a)(4).

Shane Jurek Regulatory Programs Manager - Licensing, PSEG Nuclear PO Box 236 Hancocks Bridge, New Jersey 08038-0221 Shane.Jurek@pseg.com 10 CFR 2.390 10 CFR 50.90 LR-N25-0076 September 9, 2025 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Pre-Submittal Meeting Slides for License Amendment Request to Add Data Validation and Reconciliation (DVR) Methodology to Existing Measurement Uncertainty Recapture Power Uprate

References:

1.

Letter from EPRI to NRC, Use of Data Validation and Reconciliation Methods for Measurement Uncertainty Recapture, TR 3002018337, dated November 2020 (ADAMS Accession Nos. ML21053A031 (Proprietary Version, Non-Publicly Available) and ML21053A030 (Nonproprietary Version, Publicly Available))

2.

Letter from NRC to PSEG, Salem Nuclear Generating Station, Unit Nos.

1 and 2, Issuance of Amendment Re: Increase Licensed Power Levels from 3,411 MWt to 3,459 MWt (TAC Nos MB05221 and MB0522), dated May 25, 2001 (ADAMS Accession No. ML011350051)

In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is planning a license amendment request (LAR) for Salem Generating Station Unit 1 and Unit 2. The purpose of this LAR will be to add the recently approved Data Validation and Reconciliation (DVR) methodology using EPRI Topical Report 3002018337, Use of Data Validation and Reconciliation Methods for Measurement Uncertainty Recapture, Reference 1, to the methodology for the existing Measurement Uncertainty Recapture (MUR) power uprate. In Reference 2, the NRC approved a 1.4% MUR uprate for Salem Units 1 and 2 that changed rated thermal power from 3,411 megawatts thermal (MWt) to 3,459 MWt. This previous request was based on the installation of the CE Nuclear Power LLC Crossflow ultrasonic flow measurement system with its ability to achieve increased accuracy in measuring steam generator feedwater flow. The proposed change is a methodology change and will not request a change in power.

Contains Proprietary Information.

Withhold from Public Disclosure Under 10 CFR 2.390(a)(4).

LR-N25-0076 10 CFR 2.390 Page 2 10 CFR 50.90 PSEG has requested a pre-submittal meeting scheduled for September 23, 2025. To support this meeting, PSEG is providing as enclosures to this letter, its presentation for this meeting.

provides the proprietary presentation material for the meeting. Enclosure 3 provides a non-proprietary redacted version of the presentation material for the meeting. Enclosure 2 provides an affidavit related to the proprietary material in Enclosure 1.

contains proprietary information as defined by 10 CFR 2.390. GSE Performance Solutions LLC (GSE), as the owner of the proprietary information, has executed the Enclosure 2 affidavit identifying that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.

GSE requests that the proprietary information in Enclosure 1 be withheld from public disclosure, in accordance with the requirements of 10 CFR 2.390 (a)(4), Public inspections, exemptions, requests for withholding.

This letter contains no new regulatory commitments.

Should you have questions concerning this submittal, please contact Peter Gohdes at Peter.Gohdes@pseg.com.

Respectfully, Shane Jurek Regulatory Programs Manager - Licensing PSEG Nuclear

Pre-Submittal Meeting Slides (Proprietary)
Affidavit Supporting Withholding Proprietary Information from Public Disclosure
Pre-Submittal Meeting Slides (Non-Proprietary) cc:

Administrator, Region I, NRC NRC Project Manager, Salem NRC Senior Resident Inspector, Salem Manager, NJBNE PSEG Commitment Tracking Coordinator

LR-N25-0076 Affidavit Supporting Withholding Proprietary Information from Public Disclosure

GSE Solutions September 8th, 2025 1

AFFIDAVIT

1. My name is Greg Kanuckel. I am the Manager of Thermal Performance at GSE Performance Solutions LLC (hereafter referred to as GSE) and as such I am authorized to

Ž

2. I am familiar with the criteria applied by GSE to determine whether certain GSE information is proprietary. I am familiar with the policies established by GSE to ensure the proper application of these criteria.
3. I am familiar with the GSE information contained in the presentation package submitted as Enclosure 1 to PSEG letter LR-N25-0076 for the PSEG Salem DVR for MUR Pre-Submittal Meeting and referred to herein as "Document." Information contained in this Document has been GSE as proprietary in accordance with the policies established by GSE GSE Ž public. Based on my experience, I am aware that other companies regard information of the

"Žb



Document be information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is >

information."

6. The following criteria are customarily applied by GSE to determine

ŽGSEŽ plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to

Ž process, methodology, or component, the application of which results in a

ŽŽGSE.

GSE Solutions September 8th, 2025 2

Ž

ŽŽ

ŽŽGSE in product optimization or marketability.

ŽŽŽGSE, would be helpful to competitors to GSE, and would likely cause substantial

ŽGSE.

The information in this Document is considered proprietary for the reasons set forth in

Ž

7. In accordance with GSEŽ of information, proprietary information contained in this Document has been made

Ž a limited basis, to others outside GSE agreement Ž

8. GSE

-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.

(September 8th, 2025 Greg Kanuckel Manager of Thermal Performance GSE Solutions Digitally signed by Greg Kanuckel Date: 2025.09.08 14:09:20

-05'00'

LR-N25-0076 Pre-Submittal Meeting Slides (Non-Proprietary)

1 Salem Generating Station - Update MUR Methodology to Include Data Validation and Reconciliation (DVR)

Nuclear Regulatory Commission License Amendment Request Pre-submittal Meeting September 23, 2025 Salem Generating

2 Agenda Part 1 - Open Meeting Meeting Purpose Salem Plant Overview Current Licensing Basis Proposed Change Reason for Change Technical Specification Changes Precedent Impact on Future Submittals Schedule Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

3 Describe License Amendment Request (LAR) to update the methodology for the existing Salem Units 1 and 2 Measurement Uncertainty Recapture (MUR) uprate Establish common understanding of proposed change Establish common understanding of DVR methodology Establish common understanding of MUR methodologies relative to planned future power uprate LAR Establish a common understanding of the schedule Obtain NRC feedback Meeting Purpose Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

4

  • Feedwater Flow Measurement System Description Venturi nozzles in steam generator (SG) feedwater (FW) lines measure FW mass flow Provide input to Control Room Indication and Recording and to FW control system CE Nuclear LLC Crossflow Ultrasonic Flow Meter (UFM) installed on SG FW lines Measures FW mass flow which is periodically compared to venturi nozzle mass flow to determine the correction factor Correction factor applied to mass flow from venturi nozzles to determine corrected mass flow signal used to determine power Salem Plant Overview Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

5 Current Licensing Basis

  • Existing MUR Uprate Based Upon Crossflow UFM Issued May 2001 (ML011350051)

Stated uncertainty of 0.5% on FW flow resulting in core thermal power uncertainty of

+/-0.6% justifying 1.4% MUR Reduced 10 CFR 50 Appendix K required 2% uncertainty to 0.6% uncertainty 102% analytical power level - 3479 MWt Allowed for uprate of both units from 3411 MWt to Current Licensed Thermal Power (CLTP) of 3,459 MWt Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

6 Proposed Change

DVR models do not use Crossflow as measurement inputs Proposed change is a methodology change for existing MUR; not a power uprate Will not request change in CLTP Analytically bounded by existing MUR LAR to address RIS 2002-03, Attachment 1, relevant information regarding change of FW flow measurement instrumentation basis for MUR

  • Retain Crossflow as a Backup to DVR at CLTP Crossflow retained as an option to utilize if DVR non-functional until SPU
  • Remove MUR Methodology from TS 6.9.1.9, Core Operating Limits Report MUR methodology not used in determination of core operating limits Consistent with most recently approved MURs Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

7 Reason for Change

  • Replacing Crossflow with DVR allows for MUR to be used in combination with SPU and allow for further potential uncertainty reduction in SPU submittal
  • Crossflow is intended to be phased out due to parts obsolescence and cost of maintenance
  • First of a kind DVR for MUR submittal for the industry developed as part of PWROG pilot initiative Salem DVR System and Methodology developed by GSE Solutions using Belsim software compliant with NRC-approved EPRI Methodology Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

8 Technical Specification Changes

Remove TS 6.9.1.9.b.6 reference to CENPD-397-P-A, Improved Flow Measurement Accuracy Using Crossflow Ultrasonic Flow Measurement Technology with no replacement Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

9 Precedent

  • Use of DVR in Nuclear Power Plants DVR is utilized in many US plants as a method for power recovery Power recovery process similar to how DVR is expected to be implemented for MUR
  • Existing MUR Methodology Change Update MUR FW flow measurement methodology not involving change in power level similar to amendment issued to South Texas Project for Crossflow to LEFM (ML15049A129)

Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

10 10 Impact on Future Submittals

  • Stretch Power Uprate Anticipated to be submitted in 2Q2027 SPU will include revalidation of DVR-MUR at the higher SPU power level DVR MUR portion of SPU likely to request further reduction in uncertainty

DVR model will continue to be developed and refined in the interim

Additional instrumentation will be identified and included to further lower uncertainty, which will be incorporated into proposed change for SPU Crossflow will be phased out as an MUR methodology in SPU LAR Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

11 11 Schedule

Projected submittal December 2025 Requested approval of January 2027

  • Project Schedule:

DVR Model currently undergoing site testing (Unit 1 complete)

DVR System and servers installed in 3Q2026 under 50.59 Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

12 Agenda Part 2 - Closed Meeting DVR Methodology DVR System Architecture DVR Uncertainties Unit 1 Site Acceptance Testing Unit 1 DVR FW Verification (C&L #9)

DVR Measurement Uncertainties Unit 1 DVR FW Uncertainty Contributions DVR Correction Factor Implementation Allowed Outage Time Included Attachments/Enclosures Questions / Discussion Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

13 13 DVR Methodology

  • Reduction in Uncertainties The DVR calculation utilizes measurement uncertainty and first-principles (mass and energy balances) to identify and correct measurement errors in process systems A typical nuclear plant DVR model will include measurement inputs from up to approximately 300 instruments in the plant The contribution of these instruments to the reconciled output from the DVR model will be dependent upon the type and location of instrumentation, as well as the measurement uncertainties that are assigned to the instrument.

DVR models also employ non-measurement inputs (and associated uncertainties for these inputs) to establish additional redundancy between independent measurements, as well as to make the system of equations solvable Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

14 14 DVR Methodology

  • Reduction in Uncertainties - Continued Uncertainties for parameters that have multiple redundancies associated with them are reduced through the reduction in sensitivity that these parameters have to any single measurement Final FW flow rate has, in general, significant redundancy in nuclear DVR models, and therefore is subject to significant uncertainty reduction The reduced uncertainty for final FW flow rate in the DVR output can be used as the basis for MUR uprates, in the same principle as ultrasonic flow meters (LEFMs)

Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

15 15 DVR System Architecture

  • DVR models developed using VALI DVR models developed using VALI software (compliant with VDI-2048 methodology)
  • 251 instruments (tags) selected for use in each Salem units model
  • Models will be configured on dedicated server Receive hourly averaged data input from Plant Process Computer once per hour Run data input through model for DVR calculation Output stored in MS-SQL database Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

16 16 DVR System Architecture Instruments Plant Process Computer Data Historian DVR Server DVR model (VALI) performs reconciliation calculations Stores model input and output files in SQL database Individual workstations view DVR output via web-based displays (ValiStudio) and/or direct access to SQL database DVR output reviewed for determining correction factor to manually apply to FW flow measurement inputs for CTP calculation Manual FWF CF Update Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

17 17 DVR Uncertainties

  • To maintain current 1.4% MUR power level, it is necessary to demonstrate a total calculated core thermal power uncertainty of 0.6%.
  • Based on current Salem CTP calorimetric uncertainty calculation, total measured FW flow rate uncertainty contributes ~93% of the calculated CTP uncertainty
  • To maintain CTP uncertainty 0.6%, the total FW flow rate uncertainty must be 0.56%
  • Final DVR models at Salem are expected to have nominal reconciled total FW flow rate uncertainties of 0.54%

Unit 2 expected to have lower nominal uncertainty than Unit 1, primarily due to increased measurement uncertainty for the Unit 1 FW flow rate measurements due to more significant fouling bias Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

18 18 Unit 1 Site Acceptance Testing Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

19 19 Unit 1 DVR FW Verification (C&L #9)

Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

  • Venturi flow element correction factors from Crossflow to DVR:

20 20 Unit 1 DVR FW Verification (C&L #9)

Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

21 21

  • Measurement Uncertainties (C&L #1)

Measurement uncertainty is an important input for DVR; all tags providing input into the model (plant instrument or otherwise) can have measurement uncertainties assigned to them SE Condition and Limitation #1 requires that the DVR input measurement uncertainties be demonstrated to bound the expected error sources (process, instrument, channel, etc.)

The contribution of a tags settings to the reconciled total FW flow rate uncertainty can be quantified and ranked. Therefore, it is expected that higher ranking (or more significantly contributing) tags will require increased justification for their measurement uncertainty settings as compared to lower contributing tags.

DVR Measurement Uncertainties Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

22 22

  • Measurement Uncertainties (C&L #1) - Continued A dedicated appendix to the Functional Design Specification includes the measurement uncertainty settings for all tags, as well as references/justification for the values (uncertainty calculations, calibration records, bounding estimates, etc.)

DVR Measurement Uncertainties Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting Proprietary information withheld in accordance with 10 CFR 2.390

23 23 Unit 1 DVR FW Uncertainty Contributions Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

  • Main contributors to FW uncertainty Proprietary information withheld in accordance with 10 CFR 2.390

24 24 Unit 1 DVR FW Uncertainty Contributions Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

  • Main contributors to FW uncertainty Proprietary information withheld in accordance with 10 CFR 2.390

25 25 Unit 1 DVR FW Uncertainty Contributions

  • Uncertainty contribution from plant instrumentation:
  • Uncertainty contribution from non-plant instrumentation:
  • More contributors to uncertainty means the determination of total FW flow rate (and calculated CTP) is less susceptible to errors in any single instrument Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting Proprietary information withheld in accordance with 10 CFR 2.390

26 26

  • DVR output will be periodically reviewed to determine a valid feedwater flow rate correction factor to be implemented into the plant CTP calorimetric calculation (proposed 3-month periodicity)

Review of plant history for feedwater venturi measurement stability shows minimal risk of defouling or other sudden non-conservative bias 3-month periodicity aligns with quarterly surveillance periods for more safety-significant surveillances Current plants using DVR for power recovery (fouling bias correction) have a 3-month periodicity for reviewing/updating the correction factor Minimize operator burden without corresponding reduction in risk

  • Independent plant measurements that have a high correlation with actual plant CTP will be used to ensure implemented correction factor is valid and that any sudden non-conservative shift in flow element performance is detected DVR Correction Factor Implementation Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

27 27

  • If implemented correction factor is declared non-functional, the allowed outage time before downpower is planned to be 72-hours Aligns with recent MUR submittals using the LEFM technology Minimal risk for non-conservative shift during this time-period Allows sufficient time for investigation and troubleshooting
  • Deviation between independent measurements and implemented correction factor will result in overhead annunciator alarm in control room initiating AOT through alarm response procedures Prior to allowed outage time being exceeded, the correction factors will be set to 1.0000 (uncorrected venturi measurements) and unit will downpower to 3411 MWt (pre-MUR power level)

Or manually swap over to Crossflow to maintain CLTP Allowed Outage Time Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

28 28 Included Attachments/Enclosures

  • Proprietary and non-proprietary versions of the following are anticipated to be provided as LAR attachments:

Functional Design Specifications Functional Acceptance Tests Site Acceptance Tests Calorimetric Uncertainty Calculations Evaluations of Limitation and Conditions 7 and 9 Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

29 29 Questions / Discussion Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

30 30 Thank You Salem Update MUR Methodology to Include DVR LAR Pre-submittal Meeting

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