View source for CNL-19-045, Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 9, Additional Information Regarding Anticipate Transient Without Scram with ...

{{Adams
| number = ML19115A099
| issue date = 04/24/2019
| title = Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 9, Additional Information Regarding Anticipate Transient Without Scram with ...
| author name = Henderson E
| author affiliation = Tennessee Valley Authority
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000259, 05000260, 05000296
| license number = DPR-033, DPR-052, DPR-068
| contact person = 
| case reference number = CNL-19-045
| package number = ML19115A097
| document type = Legal-Affidavit, Letter type:CNL
| page count = 12
| project = 
| stage = Supplement
}}

=Text=
{{#Wiki_filter:Proprietary Information Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 1 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-19-045 April 24, 2019 10 CFR 50.90 10 CFR 2.390 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

==Subject:==
Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 9, Additional Information Regarding Anticipate Transient Without Scram with Instability Analyses

==Reference:==
Letter from TVA to NRC, CNL-18-002, "Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus," dated February 23, 2018 (ML18057B276)
By the Reference letter, Tennessee Valley Authority (TVA) submitted a request for a Technical Specification (TS) amendment (TS-510) to Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3, respectively. The proposed amendment allows operation in the expanded Maximum Extended Load Line Limit Analysis Plus (MELLLA+) operating domain and use of the Detect and Suppress Solution - Confirmation Density (DSS-CD) stability solution. During a meeting between Nuclear Regulatory Commission (NRC) and TVA representatives on March 19, 2019, TVA representatives discussed the Anticipated Transient Without Scram with Instability (ATWS-I) analyses performed to support the BFN MELLLA+ License Amendment Request. Enclosure 1 to this letter provides information discussed during the March 19, 2019, meeting.

U.S. Nuclear Regulatory Commission CNL-19-045 Page 2 April 24, 2019 General Electric - Hitachi Nuclear Energy Americas LLC (GEH) considers portions of the information provided in Enclosure 1 to this letter to be proprietary and, therefore, exempt from public disclosure pursuant to 10 CFR 2.390. An affidavit for withholding information, executed by GEH, is provided in Enclosure 3. Enclosure 2 to this letter provides a non-proprietary version of the information provided in Enclosure 1. Therefore, on behalf of GEH, TVA requests that Enclosure 1 be withheld from public disclosure in accordance with the GEH affidavit and the provisions of 10 CFR 2.390.
TVA has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in the Reference letter. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the supplemental information in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed license amendment. Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and the non-proprietary enclosures to the Alabama State Department of Public Health.
There are no new regulatory commitments associated with this submittal. If there are any questions or if additional information is needed, please contact Mr. Michael A. Brown at (423) 751-3275.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of April 2019.
Respectfully, E. K. Henderson Director, Nuclear Regulatory Affairs

==Enclosures:==
: 1.      Additional Information Regarding ATWS-I Analyses (Proprietary)
: 2.      Additional Information Regarding ATWS-I Analyses (Non-proprietary)
: 3.      Affidavit cc:
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama Department of Public Health (w/o Enclosure 1)

ENCLOSURE 1 Additional Information Regarding ATWS-I Analyses (Proprietary)

ENCLOSURE 2 Additional Information Regarding ATWS-I Analyses (Non-proprietary)

ENCLOSURE 2 DOC-0007-4283-140 Response to SRXB-RAI-3A in Support of BFN MELLLA+ LAR Non-Proprietary Information NON-PROPRIETARY NOTICE This is a non-proprietary version of Enclosure 1 of DOC-0007-4283-140 which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here ((       )).
Non-Proprietary Information DOC-0007-4283-140                                                                   Page 1 of 2 SRXB-RAl-3A The two-recirculation pump trip (2RPT) anticipated transient without scram with instability (ATWS-I) peak cladding temperature (PCT) results in the M+SAR and the response to SRXB RAI-3 are ((                                                                                  ))
ATWS-I event results for all sensitivity scenarios analyzed. However, the assumed feedwater temperature at the time of operator actions was significantly lower (more destabilizing) in the TTWBP event compared to the 2RPT event. Additionally, the staff performed TRACE confirmatory calculations of the TTWBP event and the 2RPT event which showed that the TTWBP event was more limiting. Therefore, ((
                                                                              )) To ensure the ATWS-I model is providing realistic results sufficient to meet the ATWS acceptance criteria (i.e., coolable geometry for ATWS-I), please provide a plot of PCT for the ((
                                                             ))
GEH Response The main reason for ((
                    ))
For a demonstration, a comparison is made for two middle of cycle (MOC) regional mode TTWBP cases which are modeled with ((
                                      ))
Non-Proprietary Information DOC-0007-4283-140                                                          Page 2 of 2 Table 3A-1   PCT Results for MOC Regional Mode TTWBP Cases Event     Case      ((
TTWBP-        1 MOC -
Regional      2                                                                   ))
((
                                                                                   ))
Figure 3A-1 PCT Responses for MOC Regional Mode TTWBP Cases

ENCLOSURE 3 Affidavit

ENCLOSURE 3 DOC-0007-4283-140 GEH Affidavit for Enclosure 1

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 Enclosure 1 of GEH letter, DOC-0007-4283-140, GEH Response to MELLLA+ RAI SRXB-RAI-3A, dated April 12, 2019. The GEH proprietary information in Enclosure 1, which is entitled Response to SRXB-RAI-3A in Support of BFN MELLLA+ LAR, is identified by a dotted underline inside double square brackets. ((This sentence is an example.{3})) Figures and large objects containing GEH proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation {3} 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 9.17(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 DOC-0007-4283-140                                                         Page 1 of 3

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 DOC-0007-4283-140                                                       Page 2 of 3

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 10th day of April 2019.
Lisa K. Schichlein Senior Project Manager, NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 Lisa.Schichlein@ge.com Affidavit for DOC-0007-4283-140                                                     Page 3 of 3}}