View source for BSEP 18-0046, Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion

{{Adams
| number = ML18100A230
| issue date = 04/10/2018
| title = Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion
| author name = Gideon W
| author affiliation = Duke Energy Progress, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071
| contact person = 
| case reference number = BSEP 18-0046
| package number = ML18102A044
| document type = Letter type:BSEP, Response to Request for Additional Information (RAI)
| page count = 9
| project = 
| stage = Supplement
}}

=Text=
{{#Wiki_filter:William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 April 10, 2018 Serial: BSEP 18-0046                                                              10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Supplement to Response to Request for Additional Information SRXB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion

==References:==
: 1. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, Request for License Amendment Regarding Core Flow Operating Range Expansion, dated September 6, 2016, ADAMS Accession Number ML16257A410
: 2. NRC E-mail Capture, Brunswick Unit 1 and Unit 2 - Request for Additional Information Related to the MELLLA+ LAR (CACs MF8864 and MF8865)
(Nonproprietary), dated January 5, 2018, ADAMS Accession Number ML18010A051
: 3. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865), dated February 5, 2018, ADAMS Accession Number ML18036A665
: 4. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, Response to Request for Additional Information SNPB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865), dated March 1, 2018, ADAMS Accession Number ML18075A330 Ladies and Gentlemen:
By letter dated September 6, 2016 (i.e., Reference 1), Duke Energy Progress, LLC (Duke Energy), submitted a license amendment request (LAR) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment would expand the core power-flow operating range (i.e., Maximum Extended Load Line Limit Analysis Plus (MELLLA+)). On January 5, 2018, by electronic mail (i.e., Reference 2), the NRC provided a request for additional information (RAI) regarding the LAR.

U.S. Nuclear Regulatory Commission Page 2 of 3 Duke Energy's response to the RAI questions was submitted by letters dated February 5, 2018 and March 1, 2018 (i.e., References 3 and 4, respectively). After further review and discussion with the NRC regarding Duke Energy's SRXB-RAl-2 response provided in Reference 3, it was determined that a supplement to that response was necessary.
The supplement to Duke Energy's response to NRC RAI Question SRXB-RAl-2 is provided in . This response involves information considered proprietary to General Electric Hitachi (GEH).
GEH, as owner of the proprietary information, has executed the affidavit provided in , which identifies the proprietary information that has been handled and is classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.
The proprietary information was provided to Duke Energy in a GEH transmittal referenced by the affidavit. The proprietary information has been faithfully reproduced in Enclosure 1 such that the affidavit remains applicable.
A non-proprietary version of the supplement is provided in Enclosure 2.
No regulatory commitments are contained in this letter.
Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.
I declare, under penalty of perjury, that the foregoing is true and correct. Executed on April 10, 2018.
William R. Gideon SBY/sby

==Enclosures:==
: 1. Supplement to the SRXB-RAl-2 Response (Proprietary Information - Withhold from Public Disclosure in Accordance With 10 CFR 2.390)
: 2. Supplement to the SRXB-RAl-2 Response (Non-Proprietary)
: 3. GEH Affidavit Regarding Withholding GEH Information Contained in Attachment 1 of GEH Letter GEH-PGN-MPLUS-152, Clarification of GEH Response to NRG MELLLA+
Request for Additional Information SRXB-RAl-2, dated April 4, 2018

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with all Enclosures):
U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 cc (with Enclosures 2 and 3):
Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, III, Section Chief (Electronic Copy Only)
Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov

BSEP 18-0046 Enclosure 2 Page 1 of 2 Supplement to the SRXB-RAI-2 Response To provide additional margin to the expected range of oscillation periods, ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
` ` ` ` ` ` )) Tmin to 1.0 seconds is proposed for Brunswick Steam Electric Plant (BSEP) Units 1 and 2. Safety Communication (SC) 02-21 (Reference 1), as communicated to the Nuclear Regulatory Commission (NRC) via Reference 2, indicates that a Tmin=1.0 seconds provides increased margin to the expected range of oscillation periods, ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
```````````````````````````````                                                   ` ` ` ` )) (Figure SRXB-2-4 from the response to SRXB-RAI-2 (Reference 3)). As described in the response to Item b of SRXB-RAI-2 (Reference 3), ((`
````````````````````````````````````````````````````````````````````````````````````````````````
` ` ` ` ` ` ` ` ))
The oscillation period assessment of Reference 1 is based on an assessment of period variation versus percent rated core flow using the ODYSY code. Per References 4 and 5, ODYSY and TRACG are approved for Boiling Water Reactor (BWR) stability calculations up to and including the Maximum Extended Load Line Limit Analysis Plus (MELLLA+) domain.
Additionally, Section 2.6.2.3 of the Interim Methods Licensing Topical Report (IMLTR)
(Reference 5) states, The existing GE thermal-hydraulic stability models reasonably and adequately model the magnitude and period of industry thermal-hydraulic instability events.
Both the GE stability codes (frequency domain code ODYSY and time-domain code TRACG) model past events relatively well, including the recent thermal-hydraulic instability events at two domestic BWRs.
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
`````````````````````````````````````````````````````````                                                                   `````````````````````````````````
` ` ` ` ` )) (Figure SRXB-2-4 from the response to SRXB-RAI-2 (Reference 3)), this supports a Tmin=1.0 seconds as providing acceptable margin to the expected minimum oscillation period for BSEP with Detect and Suppress Solution - Confirmation Density (DSS-CD) at MELLLA+
conditions.
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
````````````````````````````````````````````````````````````````````````````````````````````````
````````````````````````````````````````````````````````````````````````````````````````````````
````````````````````````````````````````````````````````````````````````````````````````````````
````````````````````````````````````````````````````````````````````````````````````````````````
``````````````````````````````````````````````````````````
````````````````````````````````````````````````````````````````````````````````````````````````
````````````````````````````````````````````````````````````````````````````````````````````````
````````````````````````````````````````````````````````````````````````````````````````````````

BSEP 18-0046 Enclosure 2 Page 2 of 2
````````````````````````````````````````````````````````````````````````````````````````````````
````````````````````````````````````````````````````````````````````````````````````````````````
````````````````````````````````````````````````````````````````                                                                                            `
` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
In conclusion, a Tmin=1.0 seconds provides increased margin to the range of expected oscillation periods, as supported by Figure SRXB-2-4 from the response to SRXB-RAI-2 (Reference 3).
This setting of Tmin=1.0 seconds, ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
````````````````````````````````````                     ` ` ` ` ` ` ` ` )) is therefore recommended for use by BSEP with DSS-CD.
References
: 1.         GE Nuclear Energy Safety Communication, Stability Option III: OPRM Tmin Specification, SC 02-21, November 22, 2002.
: 2.         Letter, Jason S. Post (GEH) to NRC Document Control Desk, Reportable Condition Stability Option III: Period Based Algorithm Tmin Specification, MFN 02-091, November 22, 2002.
: 3.         Letter, William R. Gideon (Duke Energy) to NRC Document Control Desk, Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865), BSEP 18-0021, February 5, 2018.
: 4.         GE Hitachi Nuclear Energy, GE Hitachi Boiling Water Reactor Detect and Suppress Solution - Confirmation Density, NEDC-33075P-A, Revision 8, November 2013.
: 5.         GE Hitachi Nuclear Energy, Applicability of GE Methods to Expanded Operating Domains, NEDC-33173P-A, Revision 4, November 2012.

BSEP 18-0046 Enclosure 3 GEH Affidavit Regarding Withholding GEH Information Contained in Attachment 1 of GEH Letter GEH-PGN-MPLUS-152, Clarification of GEH Response to NRC MELLLA+ Request for Additional Information SRXB-RAI-2, dated April 4, 2018

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Lisa K. Schichlein, state as follows:
(1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC ("GEH"), 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 Attachment 1 of GEH letter, GEH-PGN-MPLUS-152, "Clarification of GEH Response to NRC MELLLA+ Request for Additional Information SRXB-RAI-2," dated April 4, 2018. The GEH proprietary information in Attachment 1, which is entitled "Clarification of SRXB-RAI-2 Response in Support of Brunswick Steam Electric Plant MELLLA+ LAR," is identified by a dotted underline inside double square brackets. ((This sentence is an .example./3 l)) In each case, the superscript notation Pl 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, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.
Sec. 1905, and NRC regulations 10 CFR 9.l 7(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies 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, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4 )a. and (4 )b. Some examples of categories of information that 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 GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;
: b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
: c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
: d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.
Affidavit for GEH-PGN-MPLUS-152                                                           Page I of3

GE-Hitachi Nuclear Energy Americas LLC (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 GEH, 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 GEH, not been disclosed publicly, and not been made 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 or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH.
(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 for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH 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 or confidentiality agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed results and conclusions regarding supporting evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability of the Maximum Extended Load Line Limit Analysis Plus analysis for a GEH Boiling Water Reactor
("BWR"). The analysis utilized analytical models and methods, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of Maximum Extended Load Line Limit Analysis Plus for a GEH BWR.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience and information databases that constitute a major GEH asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's 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.
Affidavit for GEH-PGN-J\.1PLUS-152                                                      Page 2 of3

GE-Hitachi Nuclear Energy Americas LLC The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. 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. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH 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 GEH 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 4th day of April 2018.
Lisa K. Schichlein Senior Project Manager, NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 2840 I Lisa.Schichlein@ge.com Affidavit for GEH-PGN-MPLUS-152                                                        Page 3 of3}}