NL-15-0520, Edwin I. Hatch, Unit 1 - VSP-SNC-GEN-15-002, Cycle 27 Core Operating Limits Report, Version 2, Non-Proprietary, Enclosure 3
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{{#Wiki_filter:Edwin I. Hatch Nuclear Plant Unit 1 Cycle 27 Core Operating Limits Report Version 2 Unit 2 Cycle 23 Core Operating Limits Report Version 2 Unit 2 Cycle 24 Core Operating Limits Report Version 1 Information Letter of NSF Lead Test Assemblies Enclosure 3 HNP Unit 1 Cycle 27 Version 2 Core Operating Limits Report NON-PROPRIETARY INFORMATION ENCLOSURE 2 VSP-SNC-GEN-15-002 Edwin I. Hatch Nuclear Plant Unit 1 Cycle 27 Core Operating Limits Report, Version 2 Non-Proprietary Information INFORMATION NOTICE This is a non-proprietary version of Enclosure 1 of VSP-SNC-GEN-15-002, which has the proprietary information removed. Portions of the document that have been removed are indicated by white space inside open and closed bracket as shown here [[ ]]. SOUTHERN NUCLEAR OPERATING COMPANY EDWIN I. HATCH NUCLEAR PLANT Unit I Cycle 27 CORE OPERATING LIMITS REPORT Version 2 Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201 Non-Proprietary Information Non-Proprietary Information Edwin I. Hatch Nuclear Plant Unit 1 Cycle 27 Core Operating Limits Report TABLE OF CONTENTS Section Title Page 1.0 Introduction 1 2.0 APLHGR Limits 3 3.0 MCPR Operating Limits 6 4.0 LHGR Limits 19 5.0 PBDA Amplitude Setpoint 25 6.0 References 26 Version 2 Plant Hatch Core Operating Unit 1 Cycle 27 Non-Proprietary Information Limits Report TABLES Table No. Title Page 1-1 Main Turbine Bypass System Operability 1 1-2 Equipment-Out-of-Service Limitations 2 3-1 Exposure Definitions 8 3-2 MCPR Operating Flexibility Options 9 4-1 LHGR Operating Flexibility Options 20 4-2 LHGR Limit versus Peak Pellet Exposure 20 5-1 OPRM Setpoint 25 ii Version 2 Plant Hatch Core Operating Unit 1 Cycle 27 Non-Proprietary Information Limits Report FIGURES Figure No. Title Page 2-1 Flow-Dependent APLHGR Multiplier 4 (MAPFACF) versus Core Flow 2-2 APLHGR Limit versus Average Planar 5 Exposure 3-1A Power-Dependent MCPR Limit (MCPRp) 10 versus Core Power from 24% to 45% of Rated Core Power 3-1B Power-Dependent MCPR Limit (MCPRp) 11 versus Core Power from 24% to 45% of Rated Core Power (Main Turbine Bypass System Inoperable) 3-2 Flow-Dependent MCPR Limit (MCPRF) 12 versus Core Flow 3-3A Power-Dependent MCPR Multiplier (Kp) 13 versus Core Power (EOC-RPT System in Service and/or Main Turbine Bypass System operable)3-3B Power-Dependent MCPR Multiplier (Kp) 14 versus Core Power (EOC-RPT System Out of Service and Main Turbine Bypass System Inoperable Simultaneously) 3-3C Power-Dependent MCPR Multiplier (Kp) 15 versus Core Power (Main Turbine Pressure Regulator System in TLCO 3.3.13.c)3-4A MCPR Limits versus Average Scram Time 16 (BOC to MOCI)3-4B MCPR Limits versus Average Scram Time 17 (MOCI to MOC2)iii Version 2 Plant Hatch Core Operating Unit 1 Cycle 27 Non-Proprietary Information Limits Report Figure No. Title 3-4C MCPR Limits versus Average Scram Time 18 (MOC2 to EOC)4-1 Flow-Dependent LHGR Multiplier 21 (LHGRFACF) versus Core Flow 4-2A Power-Dependent LHGR Multiplier 22 (LHGRFACp) versus Core Power (Main Turbine Bypass System Operable or Inoperable) 4-23 Power-Dependent LHGR Multiplier 23 (LHGRFACp) versus Core Power (Main Turbine Bypass System Operable or Inoperable and Main Turbine Pressure Regulator System in TLCO 3.3.13.c)4-3 LHGR versus Peak Pellet Exposure 24 iv Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information
1.0 INTRODUCTION
The Core Operating Limits Report (COLR) for Plant Hatch Unit 1 Cycle 27 is prepared in accordance with the requirements of Technical Specification 5.6.5. The core operating limits presented herein were developed using NRC-approved methods (References 1 through 6). Results from the reload analyses for the fuel in Unit 1 Cycle 27 are documented in References 3 through 5.The following core operating limits are included in this report: a. Average Planar Linear Heat Generation Rate (APLHGR) -Technical Specification 3.2.1 b. Minimum Critical Power Ratio (MCPR) -Technical Specification 3.2.2 c. Linear Heat Generation Rate (LHGR) -Technical Specification 3.2.3 Also included in this report is the maximum allowable scram setpoint for the Period Based Detection Algorithm (PBDA) in the Oscillation Power Range Monitor (OPRM).Based upon the reload analysis for this cycle, the following operability requirement is defined for Unit 1 operation. TABLE 1-1 Main Turbine Bypass System Operability System Main Turbine Bypass System Operable (Technical Specification 3.7.7)Operability Requirement At least two bypass valves must be operable I 1 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information From a fuel thermal limits perspective, the following limitations are placed on Unit 1 Cycle 27 operation. TABLE 1-2 Equipment-Out-of-Service Limitations Equipment / Condition Limitation EOC-RPT Out of Service and Main Turbine Option B scram speeds must be Bypass System Inoperable simultaneously met (in place) at CTP > 45% RTP Main Turbine Pressure Regulator System in Option B scram speeds must be TLCO 3.3.13.c met (in place) at CTP > 45% RTP* CTP must be < 2000 MWth Single-Loop Operation (SLO)
- Core Flow must be 5 56% of Rated NOTE: The power distribution limits in this report apply to plant operation with all equipment in service, unless otherwise specified.
2 Version 2 Plant Hatch Unit 1 Cycle 27 Non-Proprietary Information Core Operating Limits Report 2.0 APLHGR LIMITS (Technical Specification 3.2.1)The APLHGR limit for each six inch axial segment of each fuel assembly in the core is the applicable APLHGR limit taken from Figure 2-2 multiplied by the flow-dependent multiplier, MAPFACF, from Figure 2-1.3 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 1.0 3 L.0.9 0.86 0-0.8 I 0.6"C 0-J 067 0.0 ME 0.5 0.4 I TL TLO SL 30 40 50 6061 70 80 90 100 110 Core Flow (%of Rated)Operating Conditions F SLO / TLO MAPFACF 30 _ F_< 61 TLO 0.86 61 <F TLO 1.00 30< F SLO 0.80 Percent of Rated Core Flow FIGURE 2-1 Flow-Dependent APLHGR Multiplier (MAPFACF) versus Core Flow 4 Version 2 Plant Hatch Unit 1 Cycle 27 Non-Proprietary Information Core Operating Limits Report Average Planar Exposure (GWd/st)0.00 14.51 19.13 57.61 63.50 APLHGR Limit (kW/ft)12.82 12.82 12.82 8.00 5.00 14.0 13.0 12.0 11.0 10.0 E 9.0 8 .0 7.0 6.0 5.0 4.0 0.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0 50.0 55.0 60.0 65.0 70.0 Average Planar Exposure (GWd/st)FIGURE 2-2 APLHGR Limit versus Average Planar Exposure 5 Version 2 Plant Hatch Core Operating Unit 1 Cycle 27 Non-Proprietary Information Limits Report 3.0 MCPR OPERATING LIMITS (Technical Specification 3.2.2)The MCPR operating limit (OLMCPR) is a function of core power, core flow, average scram time, number of operating recirculation loops, EOC-RPT system status, operability of the main turbine bypass system, the status of the main turbine pressure regulator system, and cycle exposure. Cycle exposures are defined in Table 3-1.With both recirculation pumps in operation (TLO), the OLMCPR is determined as follows: a. For 24% _ power < 45%, the power-dependent MCPR limit, MCPRp, as determined by Table 3-2.b. For power > 45%, the OLMCPR is the greater of either: 1) The flow-dependent MCPR limit, MCPRF, from Figure 3-2, or 2) The product of the power-dependent multiplier, Kp, and the rated-power OLMCPR, as determined by Table 3-2.As shown on the figures for absolute MCPR, the OLMCPR with only one recirculation pump in operation (SLO) is equal to the two loop (TLO) OLMCPR plus 0.02.These limits apply to all modes of operation with feedwater temperature reduction, as well as operation with normal feedwater temperatures. In Figures 3-4A, 3-4B, and 3-4C, Option A scram time OLMCPRs correspond to c = 1.0, where c is determined from scram time measurements performed in accordance with Technical Specifications Surveillance Requirements 3.1.4.1 and 3.1.4.2. Option B values correspond to -r = 0.0. For scram times between Option A and Option B, the rated-power OLMCPR corresponds to r. If-c has not been determined, Option A limits must be used.6 Version 2 Plant Hatch Core Operating Unit 1 Cycle 27 Non-Proprietary Information Limits Report The average scram time of the control rods, r, is defined as: Tave -TB T= 0, or whichever is greater.TA -TB where: TA 1.08 sec (Technical Specification 3.1.4, Table 3.1.4-1, scram time limit to notch 36).=B .+ 1.65 -a-?IN where: .= 0.822 sec (mean scram time used in the transient analysis). Y = 0.018 sec (standard deviation of p.).n = number of surveillance tests performed to date in the cycle.N 1 = total number of active rods measured in Technical Specifications Surveillance Requirement 3.1.4.1.Ni = number of active control rods measured in the ith surveillance test.Tave =where: Ti = average scram time to notch 36 of all rods in the ith surveillance test.7 Version 2 Plant Hatch Unit 1 Cycle 27 Non-Proprietary Information Core Operating Limits Report TABLE 3-1 Exposure Definitions Exposure Label Cycle Exposure Definition BOC Beginning of Cycle 0 MWd/st Exposure MOC1 First Middle of Cycle EOR -6062 MWd/st Exposure MOC2 Second Middle of Cycle EOR -1062 MWd/st Exposure Projected end of rated power with all operable control rods EOR End of Rated Exposure out at rated core flow and rated feedwater temperature EOC End of Cycle Exposure Exposure at cycle shutdown 8 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information TABLE 3-2 MCPR Operating Flexibility Options Rated-power OLMCPRs Cycle Exposure BOC to MOC1 Figure 3-4A MOC1 to MOC2 Figure 3-4B MOC2 to EOC Figure 3-4C MCPRP from > 24% to < 45% Power Main Turbine Bypass System Operable* Figure 3-1A Main Turbine Bypass System Inoperable Figure 3-1 B Kp for Power > 45% of Rated EOC-RPT Main Turbine Main Turbine Bypass System Pressure Regulator System In Service Operable* System Status Yes Yes TLCO 3.3.13.a or b Figure 3-3A No Yes TLCO 3.3.13.a or b Figure 3-3A Yes No TLCO 3.3.13.a or b Figure 3-3A No No TLCO 3.3.13.a or b Figure 3-3B**Yes/No Yes/No TLCO 3.3.13.c Figure 3-3C**At least two bypass valves must be operable** Option B scram speeds must be met (in place) at CTP a 45% RTP 9 Version 2 Plant Hatch Unit 1 Cycle 27 Non-Proprietary Information Core Operating Limits Report 3.0 2.8 0.2 2.6 ZJ 2.4" 2.2 CL S2.0 0 a.1.8 1.6 24 27 30 33 36 39 42 45 Core Power(% of Rated)MCPRp(TLO) = A + B*P MCPRp(SLO) = MCPRp(TLO) + 0.02 F P A B< 60 24< P < 28 4.1235 -0.06673> 60 24< P < 28 4.0635 -0.04708< 60 28< P < 45 2.0810 -0.00624>60 28< P < 45 2.4861 -0.01067 P = Percent of Rated Core Power F = Percent of Rated Core Flow FIGURE 3-1A Power-Dependent MCPR Limit (MCPRp) versus Core Power from 24% to 45% of Rated Core Power 10 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 4.0 -3.8 > 60% Flow 3.6 -a .t U 3.4 -.3.2-I W, 3.0 2.8 6 2.6 -="2.4 30 2.2 -. ...... ...2.0 1.8 -96 %Fo 24 27 28 30 33 36 39 42 45 Core Power(% of Rated)MCPRp(TLO) = A + B*P MCPRp(SLO) = MCPRp(TLO) + 0.02 F P A B-60 24 < P < 28 4.3600 -0.07000> 60 24< P < 28 6.5876 -0.1167060 28< P < 45 2.0810 -0.00624> 60 28< P < 45 2.4861 -0.01067 P = Percent of Rated Core Power F = Percent of Rated Core Flow FIGURE 3-1B Power-Dependent MCPR Limit (MCPRp) versus Core Power from 24% to 45% of Rated Core Power (Main Turbine Bypass System Inoperable) 11 Version 2 Plant Hatch Unit 1 Cycle 27 Non-Proprietary Information Core Operating Limits Report 1.6-1.5 L)E_j 1.4 C-, Q3.C 1.3 0 1.2 1.1 30 40 50 60 70 80 90 Core Flow (%of Rated)100 110 MCPRF(TLO) = A + B*F MCPRF(SLO) = MCPRF(TLO) + 0.02 Flow A B 30< F 71.160 1.697 -0.00586 71.160 < F 1.280 0.00000 F = Percent of Rated Core Flow FIGURE 3-2 Flow-Dependent MCPR Limit (MCPRF) versus Core Flow 12 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 1.3 1.2 a-CL 0 C"L 0 a.S1.1 01.1.0 45 50 55 60 65 70 75 80 85 90 95 100 Core Power (% of Rated)KP = A + B*P P A B 45< P < 60 1.6702 -0.00867 605 P 1.3750 -0.00375 P = Percent of Rated Core Power FIGURE 3-3A Power-Dependent MCPR Multiplier (Kp) versus Core Power (EOC-RPT System in Service and/or Main Turbine Bypass System operable)13 Version 2 Plant Hatch Unit 1 Cycle 27 Non-Proprietary Information Core Operating Limits Report 1.3 1.2 0 S1.1 a.0 1.1 45 50 55 60 65 70 75 80 85 90 Core Power(% of Rated)95 100 Kp = A + B*P P I A B 1 45 _< P < 60 1 1.6702 -0.00867 60< P < 90 1.3308 -0.00301 90 < P 1.5961 -0.00596 P = Percent of Rated Core Power FIGURE 3-3B Power-Dependent MCPR Multiplier (Kp) versus Core Power (EOC-RPT System Out of Service and Main Turbine Bypass System Inoperable Simultaneously) 14 Version 2 Plant Hatch Unit 1 Cycle 27 Non-Proprietary Information Core Operating Limits Report 1.5 1.4 Z 1.3 4)CL 1.2 4)0~1.1 1.0 45 50 55 60 65 70 75 Core Power(% of Rated)80 85 90 95 100 Kp = A + B*P P A B 45_ P < 70 1.6268 -0.00451 70 P 2.0367 -0.01037 P = Percent of Rated Core Power FIGURE 3-3C Power-Dependent MCPR Multiplier (Kp) versus Core Power (Main Turbine Pressure Regulator System in TLCO 3.3.13.c)15 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 1.50 I I I..J 0-0 1 .4ts_____EOC-RPT Out of Service 1.46 Plus Turbine Bypass System Inoperable !-1.44 1.42 y 1.40 OutofServicj 1.38 /1.36 -" Turbine Bypass System In operabl 1.32 1.30 1.28 ", All Equipm ent In Service 1.26 -1,24 0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 Tau OLMCPR(sLO) = OLMCPR(TLO) + 0.02 Operating Conditions OLMCPR(TLO) EOC-RPT Bypass Valve System 'r = 0.0 I= 1.0 In Service Operable 1.28 1.30 Out of Service Operable 1.33 1.44 In Service Inoperable 1.32 1.33 Out of Service Inoperable 1.37 1.48 FIGURE 3-4A MCPR Limits versus Average Scram Time (BOC to MOC1)16 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 1.52 1.50 1.48 1.46 1.44.E-j 1.42 1.40 1.38 1.36 1.34 1.32 0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 Tau OLMCPR(sLo) = OLMCPR(TLO) + 0.02 Operating Conditions OLMCPR(TLO) EOC-RPT Bypass Valve System t = 0.0 = 1.0 In Service Operable 1.34 1.37 Out of Service Operable 1.38 1.49 In Service Inoperable 1.36 1.39 Out of Service Inoperable 1.39 1.50 FIGURE 3-4B MCPR Limits versus Average Scram Time (MOCI to MOC2)17 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information E.-1.0 Tau OLMCPR(sLO) = OLMCPR(TLO) + 0.02 Operating Conditions OLMCPR(TLO) EOC-RPT Bypass Valve System 'r = 0.0 r = 1.0 In Service Operable 1.37 1.40 Out of Service Operable 1.42 1.59 In Service Inoperable 1.40 1.43 Out of Service Inoperable 1.45 1.62 FIGURE 3-4C MCPR Limits versus Average Scram Time (MOC2 to EOC)18 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 4.0 LHGR LIMITS (Technical Specification 3.2.3)The LHGR limit for each six inch axial segment of each fuel rod in the core is the applicable rated-power, rated-flow LHGR limit taken from Table 4-2 multiplied by the smaller of either: a. The flow-dependent multiplier, LHGRFACF, from Figure 4-1, or b. The power-dependent multiplier, LHGRFACp, as determined by Table 4-1.Table 4-2 shows the exposure-dependent LHGR limits as a function of initial gadolinium concentrations in a six inch segment of a fuel rod. For exposures between the values shown in Table 4-2, the LHGR limit is based on linear interpolation. For illustration purposes, Figure 4-3 shows the LHGR limits for fuel segments with the lowest (U0 2) and the highest (U0 2+Gd 2 O 3) initial Gd concentration. 19 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information TABLE 4-1 LHGR Operating Flexibility Options LHGRFACp Main Turbine Pressure Regulator System Status TLCO 3.3.13.a or b Figure 4-2A TLCO 3.3.13.c Figure 4-2B** Option B scram speeds must be met (in place) at CTP > 45% RTP TABLE 4-2 LHGR Limit versus Peak Pellet Exposure Initial Pellet Pellet Pellet Pellet Pellet Pellet RodlSection Maximum Exposure Power at Exposure Power at Exposure at Wt-% Gd 2 0 3 Power Knee I Knee 2 Knee 2 EOL EOL (kWlft) (GWdlst) (kWlft) (GWdlst) (kW/ft) (GWdlst)Section = Six inch segment of a fuel rod.EOL = End of Life (maximum licensed pellet exposure)20 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 1.0 Q 0.9-J= 0.8 I=0..0.6 0 LL 0.5 0.4 30 110 Core Flow (%of Rated)LHGRFACF = A + B*F Operating Conditions Values of Variables F SLO / TLO A B 30 _ F < 50.70 SLO / TLO 0.4574 0.006758 50.70 F < 80.29 TLO 0.4574 0.006758 50.70 _ F SLO 0.8000 0.000000 80.29 < F TLO 1.0000 0.000000 F = Percent of Rated Core Flow FIGURE 4-1 Flow-Dependent LHGR Multiplier (LHGRFACF) versus Core Flow 21 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 1.1-1.0 0.9 0.8-J 0.7 CL IN 0.6 0 0.5 0.4 24 44 48 52 56 60 64 68 72 76 80 45 Core Power(%of Rated)LHGRFACP = A + B*P Operating Conditions Values of Variables P F A B 24_ P < 28 F > 60 0.17924 0.009670 24_ P < 28 F 60 0.10366 0.016741 28< P < 45 All 0.52261 0.003617 45 < P All 0.47760 0.005224 P = Percent of Rated Core Power F = Percent of Rated Core Flow FIGURE 4-2A Power-Dependent LHGR Multiplier (LHGRFACp) versus Core Power (Main Turbine Bypass System Operable or Inoperable) 22 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietaty Information 1.1 a 1.0 C.)0.9 0_ 0.8 Cl 0.6.-J 07 0 0.5 0.4 56 60 64 68 72 76 80 84 Core Power(% of Rated)LHGRFACP = A + B*P Operating Conditions Values of Variables P F A B 24_ P < 28 F > 60 0.17924 0.009670 24_ P < 28 F ___ 60 0.10366 0.016741 28 _ P < 70 All 0.52261 0.003617 70 P All 0.25270 0.007473 P = Percent of Rated Core Power F = Percent of Rated Core Flow FIGURE 4-2B Power-Dependent LHGR Multiplier (LHGRFACp) versus Core Power (Main Turbine Bypass System Operable or Inoperable and Main Turbine Pressure Regulator System in TLCO 3.3.13.c)23 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information Lowest Initial Gd Conc.Peak Pellet Exposure LHGR (GWd/st) (kW/ft)lIlJ1 Highest Initial Gd Conc.Peak Pellet Exposure LHGR (GWd/st) (kW/ft)~-FIGURE 4-3 LHGR versus Peak Pellet Exposure 24 Version 2 Plant Hatch Unit 1 Cycle 27 Core Operating Limits Report Non-Proprietary Information 5.0 PBDA AMPLITUDE SETPOINT The amplitude trip setpoint in the Period Based Detection Algorithm in the OPRM system shall not exceed the value reported in the Table below. This applies to instruments 1C51K615 A, B, C, and D.TABLE 5-1 OPRM Setpoint OLMCPR OPRM Setpoint I> 1.28 1.15 25 Version 2 Plant Hatch Core Operating Unit 1 Cycle 27 Non-Proprietary Information Limits Report
6.0 REFERENCES
- 1. "General Electric Standard Application for Reactor Fuel," NEDE-24011-P-A-19, May 2012, and the US Supplement, NEDE-2401 1-P-A-19-US, May 2012.2. GNF letter VSP-SNC-GEN-1 3-101, "Hatch 1 Cycle 27 SRLR/FBIR 000N0481 RO," Vickie S. Perry to S. Hoxie-Key, December 11, 2013.3. Global Nuclear Fuel Document 000N0481-SRLR, "Supplemental Reload Licensing Report for Edwin I. Hatch Nuclear Power Plant Unit 1, Reload 26 Cycle 27," Revision 0, December 2013.4. Global Nuclear Fuel Document 000N0481-FBIR, "Fuel Bundle Information Report for Edwin I. Hatch Nuclear Power Plant Unit 1, Reload 26 Cycle 27," Revision 0, December 2013.5. SNC Nuclear Fuel Document NF-13-171, "Hatch-1 Cycle 27 Reload Licensing Analysis Report," Version 2, December 2014.6. GNF Document NEDC-32868P, "GE14 Compliance with Amendment 22 of NEDE-24011-P-A (GESTAR II)," Rev. 5, May 2013.26 Version 2 Edwin I. Hatch Nuclear Plant Unit 1 Cycle 27 Core Operating Limits Report Version 2 Unit 2 Cycle 23 Core Operating Limits Report Version 2 Unit 2 Cycle 24 Core Operating Limits Report Version 1 Information Letter of NSF Lead Test Assemblies Enclosure 4 Global Nuclear Fuel -Americas Affidavit for Enclosure 5
Global Nuclear Fuel -Americas AFFIDAVIT I, Lukas Trosman, state as follows: (1) 1 am Engineering Manager, Reload Design and Analysis, Global Nuclear Fuel -Americas, LLC ("GNF-A"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding. (2) The information sought to be withheld is contained in Enclosure 4 of GNF's letter, VSP-SNC-GEN-l15-002, Vickie S. Perry to Susan Hoxie-Key (Southern Nuclear Operating Company), entitled "Edwin 1. Hatch Nuclear Plant Unit I Cycle 27 and Unit 2 Cycle 23 Core Operating Limits Reports (COLRs), Version 2," January 14, 2015. GNF proprietary information in Enclosure 4, which is entitled "Edwin I.Hatch Nuclear Plant Unit 2 Cycle 23 Core Operating Limits Report, Version 2," is identified by dotted underlines inside double square brackets. [[This.sentence-is.an. e..mp..e..'] A "" marking at the beginning of a table, figure, or paragraph closed with a "" marking at the end of the table, figure or paragraph is used to indicate that the entire content between the double brackets is proprietary. In each case, the superscript notation 13) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination. (3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption 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), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought 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, 704F2d 1280 (DC Cir. 1983).(4) Some examples of categories of information which fit into the definition of 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;VSP-SNC-GEN-15-002 Enclosure 4 Affidavit Page 1 of 3
- c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. 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. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as 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 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, or subject to the terms under which it was licensed to GNF-A.(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the 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 proprietary agreements. (8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology. The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost to GNF-A or its licensor.(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF-A's VSP-SNC-GEN-15-002 Enclosure 4 Affidavit Page 2 of 3 comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions. The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.I declare under penalty of perjury that the foregoing is true and correct.Executed on this 1 4 th day of January 2015.Lukas Trosman Engineering Manager, Reload Design and Analysis Global Nuclear Fuel -Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 Lukas.Trosman@gnf.com VSP-SNC-GEN-15-002 Enclosure 4 Affidavit Page 3 of 3}}