PLA-8026, Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026)

Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026)

ML22292A009
Person / Time
Site:	Susquehanna
Issue date:	10/19/2022
From:	Cimorelli K Susquehanna, Talen Energy
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML22292A008	List: PLA-8026, Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026)
References
PLA-8026
Download: ML22292A009 (15)

Text

Enclosure 3 Contains Proprietary Information -

Withhold from Public Disclosure Under 10 CFR 2.390 Kevin Cimorelli Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3795 Fax 570.542.1504 Kevin.Cimorelli@TalenEnergy.com October 19, 2022 Attn: Document Control Desk 10 CFR 50.59 U. S. Nuclear Regulatory Commission 10 CFR 72.48 Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION BIENNIAL 10 CFR 50.59 AND 72.48

SUMMARY

REPORT AND CHANGES TO REGULATORY COMMITMENTS Docket Nos. 50-387, PLA-8026 50-388, and 72-28

References:

1) Susquehanna Letter to NRC, Biennial 10 CFR 50.59 and 72.48 Summary Report and Changes to Regulatory Commitments (PLA-7904), dated October 19, 2020 (ADAMS Accession No. ML20293A240)

2) Susquehanna Letter to NRC, Submittal of Updated Final Safety Analysis Report Revision 70 and Fire Protection Review Report Revision 24 (PLA-7935), dated October 12, 2021 (ADAMS Accession No. ML21294A245)

In accordance with 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2), Susquehanna Nuclear, LLC (Susquehanna), hereby submits summary reports for Units 1 and 2 for implemented changes, tests, and experiments for which evaluations were performed in accordance with 10 CFR 50.59(c) and 10 CFR 72.48(c). The summarized evaluations provided in the enclosures were implemented since the submittal of Reference 1, for the period of September 1, 2020, through August 31, 2022.

Since last reported in Reference 2, Susquehanna has not revised any regulatory commitments meeting the criteria specified in NEI 99-04, "Guidelines for Managing NRC Commitment Changes," as endorsed in NRC Regulatory Issue Summary 2000-17. provides a description of implemented changes, tests, and experiments for which evaluations were performed in accordance with 10 CFR 50.59(c). Enclosures 3 and 4 provide a description of implemented changes, tests, and experiments for which evaluations were performed in accordance with 10 CFR 72.48(c).

Information submitted in Enclosure 3 is considered proprietary, as denoted by brackets, to Holtec. As owners of the proprietary information, Holtec has executed an affidavit (Enclosure 2)

Document Control Desk PLA-8026 for the proprietary information, which identifies the information as proprietary, is customarily held in confidence, and should be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosure 4 provides the non-proprietary version of Enclosure 3.

This letter contains no new or revised regulatory commitments.

Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager - Nuclear Regulatory Affairs, at (570) 542-1818.

K. Cimorelli : Description of Changes, Tests, and Experiments under 10 CFR 50.59 : Holtec Affidavit for Holtec Record Number 72.48-1573 : Description of Changes, Tests, and Experiments under 10 CFR 72.48 -

[Proprietary Information - Withhold from Public Disclosure under 10 CFR 2.390] : Description of Changes, Tests, and Experiments Under 10 CFR 72.48 - [Non-Proprietary]

Copy: NRC Region I Mr. C. Highley, NRC Senior Resident Inspector Ms. A. Klett, NRC Project Manager Mr. M. Shields, PA DEP/BRP (w/o Enclosure 3)

Director, Division of Fuel Management

Enclosure 1 to PLA-8026 Description of Changes, Tests, and Experiments under 10 CFR 50.59

Enclosure 1 to PLA-8026 Page 1 of 4 Description of Changes, Tests, and Experiments under 10 CFR 50.59 Introduction Susquehanna Steam Electric Station (SSES) had four changes, tests or experiments approved pursuant to 10 CFR 50.59(c). Below is a summary description of each evaluation.

50.59 SE 00031 Activity Description Framatome's evaluation of the Unit 2 Cycle 21 (U2C21) reload safety analyses utilized newer versions of computer codes than those used to develop the information contained in the ATRIUM 11 Advanced Methods License Amendment Request (LAR) (Reference 1), as supplemented, which was subsequently reviewed and approved by the NRC in Reference 2. The U2C21 analyses results are documented in ANP-3884, using Framatome's NRC approved methodologies, and implemented with the thermal limits developed in the U2C21 Core Operating Limits Report (COLR) (Reference 3).

The computer code versions used in support of ANP-3884 as compared to ATRIUM 11 Advanced Methods LAR were reviewed. Changes associated with MICROBURN-B2 and S-RELAP5 computer codes involve revised elements that impact numerical results of the Susquehanna Updated Final Safety Analysis Report (UFSAR) described evaluation methodologies that are used in safety analyses and, therefore, required evaluation under 10 CFR 50.59. As all code version changes are implemented simultaneously for U2C21, it is appropriate to evaluate them together.

Summary of Evaluation Framatome, under their Software Quality Assurance process, compared the changes in the MICROBURN-B2 and S-RELAP5 codes against the versions used in support of Reference 1, as supplemented. The comparisons demonstrate that the proposed changes to the codes provide results that are essentially the same to those code versions supporting Reference 1, as supplemented.

Therefore, the proposed activity was implemented without prior NRC approval.

50.59 SE 00032 Activity Description Change the technical requirement surveillance testing frequency of the Unit 1 and Unit 2 turbine control, stop, and combined intermediate valves from once per 92 days to once per 122 days with the standard 25% grace period. The testing consists of cycling the turbine valves from the running position and observing closure of the valves. The proposed activity will validate that the turbine missile probability analysis remains within the regulatory requirements and is consistent with the analysis referenced in the Susquehanna UFSAR and that the probability of unacceptable turbine missile damage is less than or equal to 1.0E-7 events per year.

Enclosure 1 to PLA-8026 Page 2 of 4 Summary of Evaluation This activity extended the frequency of the Unit 1 and Unit 2 turbine control, stop, and combined intermediate valves from once per 92 days to once per 122 days. This valve test interval change increased the probability of unacceptable turbine missile damage from a value of 6.0E-8 to a value of 9.416E-8. The probability of unacceptable turbine missile damage at a 122 day turbine valve test interval remains less than the 1.0E-7 per year regulatory limit for unfavorably oriented turbines. The frequency of unacceptable turbine missile damage is not increased by a factor of 2 since the value remains below 1.2E-7 per year [2 x 6.0E-8 (current probability of unacceptable turbine missile damage value)].

The method used to calculate the probability of unacceptable turbine missile damage is in accordance with the approved methodology in the Susquehanna licensing basis.

Therefore, the proposed activity may be implemented without prior NRC approval.

50.59 SE 00033 Activity Description Connect a new 230kV transmission line segment to the output of SSES Unit 1. This electrical connection and new 230kV electrical line segment are part of a larger project that expands the 230kV transmission system to accommodate new electrical loads. There are multiple major components that comprise this project:

• The physical fabrication and installation of new optical ground wires, new fiber optic cable for protective relaying communications, and the physical 230kV tie-in.

• The installation of protective relaying and additional fiber optic communication infrastructure.

The activities associated with extending the transmission line from the physical 230kV connection location to the circuit breaker (SS01) may impact Susquehanna UFSAR described design functions and the safety analysis after the electrical connection (tie-in) is complete. As such, the proposed activity discussed in this evaluation is the 230kV connection to SS01.

Specifically, the change could increase the probability of a generator/turbine trip and subsequent reactor trip due to a load rejection caused by a malfunction and isolation of the existing transmission line and new transmission line connection. Under these conditions, the possibility exists that the frequency of an accident may increase and thus was evaluated further.

A load rejection and turbine trip are initiating transients for two analyzed events: Increase in Reactor Coolant System Pressure and Anticipated Transient Without Scram. A third analyzed event, Station Blackout (SBO), was also considered because a Loss of Offsite Power caused by a disturbance on the transmission system can initiate SBO.

Enclosure 1 to PLA-8026 Page 3 of 4 Summary of Evaluation This evaluation concludes that the proposed activity does not more than minimally increase the frequency of occurrence of an accident previously evaluated in the Susquehanna UFSAR.

The justification for this includes:

• Current codes, standards, and practices will be used for the design, fabrication, installation, and testing of the new transmission line.

• Newer designs, equipment, materials, and test methodologies will be used to improve reliability.

• There will be no changes in Susquehanna UFSAR described system operating methods.

• Failure mode evaluation analysis concluded no new failure modes are created.

This evaluation also concludes that the proposed activity does not more than minimally increase the frequency of occurrence of accidents or malfunctions, has no impact to the previously analyzed consequences of an accident, creates no different accidents or malfunction results, does not alter or challenge fission barrier design basis limits and does not impact any Susquehanna UFSAR described methodologies.

Therefore, the proposed activity may be implemented without prior NRC approval.

50.59 SE 00034 Activity Description The proposed activity connects a new 500kV transmission line segment to the output of SSES Unit 2. This electrical connection and new 500kV electrical line segment are part of a larger project that expands the 500kV transmission system to accommodate new electrical loads. There are multiple major components that comprise this project:

• Installation of three sets of transmission towers for the new connecting lines between the 500kV tap location to new substation circuit breaker (SS02).

• The installation of protective relaying and additional fiber optic communication infrastructure.

The activities associated with extending the transmission line from the physical 500kV connection location downstream of the Unit 2 Main Transformer to SS02 may impact Susquehanna UFSAR described design functions and the safety analysis after the electrical connection (tie-in) is complete. As such, the proposed activity discussed in this evaluation is the transmission line extension from the 500kV connection to SS02. Specifically, the change could increase the probability of a generator/turbine trip and subsequent reactor trip due to a load rejection caused by a malfunction and isolation of the existing transmission line and new transmission line connection. Under these conditions, the possibility exists that the frequency of an accident may increase and thus was evaluated further.

Enclosure 1 to PLA-8026 Page 4 of 4 A load rejection and turbine trip are initiating transients for two analyzed events: Increase in Reactor Coolant System Pressure and Anticipated Transient Without Scram. A third analyzed event, Station Blackout (SBO), was also considered because a Loss of Offsite Power caused by a disturbance on the transmission system can initiate SBO.

Summary of Evaluation This evaluation concludes that the proposed activity does not more than minimally increase the frequency of occurrence of an accident previously evaluated in the Susquehanna UFSAR.

The justification for this includes:

• Current codes, standards, and practices will be used for the design, fabrication, installation, and testing of the new transmission line.

• Newer designs, equipment, materials, and test methodologies will be used to improve reliability.

• There will be no changes in Susquehanna UFSAR described system operating methods.

• Failure mode evaluation analysis concluded no new failure modes are created.

This evaluation also concludes that the proposed activity does not more than minimally increase the frequency of occurrence of accidents or malfunctions, has no impact to the previously analyzed consequences of an accident, creates no different accidents or malfunction results, does not alter or challenge fission barrier design basis limits and does not impact any Susquehanna UFSAR described methodologies.

Therefore, the proposed activity may be implemented without prior NRC approval. References

1) Susquehanna Letter to NRC Proposed Amendment to Licenses NPF-14 and NPF-22:

Application of Advanced Framatome Methodologies and TSTF-535 (PLA-7783), dated July 15, 2019 (ADAMS Accession No. ML19196A270)

2) NRC Letter to Susquehanna, Issuance of Amendment Nos. 278 and 260 to Allow Application of Advanced Framatome ATRIUM 11 Fuel Methodologies (EPID L-2019-LLA-0153), dated January 21, 2021 (ADAMS Accession No. ML20168B004)

3) Susquehanna Letter to NRC Submittal of Unit 2 Cycle 21 Core Operating Limits Report (PLA-7934), dated March 31, 2021 (ADAMS Accession No. ML21090A240)

Enclosure 2 to PLA-8026 Holtec Affidavit for Holtec Record Number 72.48-1573

Enclosure 2 to PLA-8026 Page 1 of 5 U.S. Nuclear Regulatory Commission Affidavit from Holtec International AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Kimberly Manzione, being duly sworn, depose and state as follows:

(1) I have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.

(2) The information sought to be withheld is 72.48 #1573 which contains Holtec Proprietary information.

(3) In making this application for withholding of proprietary information of which it is the owner, Holtec International 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 10CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b )(1) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information",

and some portions 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 Ma s En rgy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).

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Enclosure 2 to PLA-8026 Page 2 of 5 U.S. Nuclear Regulatory Commission Affidavit from Holtec International AFFIDAVIT PURSUANT TO 10 CFR 2.390 (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 Holtec's competitors without license from Holtec International constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

c. Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies of Holtec International, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future Holtec International customer-funded development plans and programs of potential commercial value to Holtec International;

e. 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) The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, 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 Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for 2 of 5

Enclosure 2 to PLA-8026 Page 3 of 5 U.S . Nuclear Regulatory Commission Affidavit from Holtec International AFFIDAVIT PURSUANT TO 10 CFR 2.390 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. Access to such documents within Holtec International is limited on a "need to know" basis.

(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 designee ), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside Holtec International 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 classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed descriptions of analytical approaches and methodologies not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec' s competitor to copy our technology and offer it for sale in competition with our company, causing us financial lllJUry.

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Enclosure 2 to PLA-8026 Page 4 of 5 U.S. Nuclear Regulatory Commission Affidavit from Holtec International AFFIDAVIT PURSUANT TO 10 CFR 2.390 (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International's comprehensive spent fuel storage 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.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.

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.

Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International 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 Holtec International 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 Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

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Enclosure 2 to PLA-8026 Page 5 of 5 U.S. Nuclear Regulatory Commission Affidavit from Holtec International AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY )

) ss:

COUNTY OF CAMDEN )

Kimberly Manzione, being duly sworn, deposes and says:

That she has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.

Executed at Camden, New Jersey, this 16th day of September, 2022.

0(tf&

Kimberly Manzione Licensing Manager Holtec International Erika Grandrimo NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES JANUARY 17, 2027 5 of 5

Enclosure 4 to PLA-8026 Description of Changes, Tests, and Experiments Under 10 CFR 72.48 Non-Proprietary

Enclosure 4 to PLA-8026 Page 1 of 1 Description of Changes, Tests, and Experiments Under 10 CFR 72.48 72.48 SE 00002/ Holtec Record Number 72.48-1573 Activity Description Susquehanna Steam Electric Station (SSES) currently uses NUHOMS Dry Shielded Canisters (DSC) to transfer spent fuel and store it in Horizontal Storage Modules on the site's Independent Spent Fuel Storage Installation (ISFSI). SSES is transitioning future spent fuel storage activities to Holtec's HI-STORM FW System. SSES will continue to operate under a general license for the storage of spent fuel on the current ISFSI.

Eight conditions specific to SSES's transition are not bounded by the generic analyses in the HI-STORM FW Updated Final Safety Analysis Report (UFSAR) and thus, required additional evaluation.

The eight conditions include:

[Proprietary Information - Withhold from Public Disclosure under 10 CFR 2.390]

Summary of Evaluation

[Proprietary Information - Withhold from Public Disclosure under 10 CFR 2.390]

Therefore, the proposed activity may be implemented without prior NRC approval.