ML15051A464

Response to Fifth Request for Additional Information Concerning License Amendment Request for Maximum Extended Load Line Limit Analysis Plus

ML15051A464
Person / Time
Site:	Nine Mile Point
Issue date:	02/18/2015
From:	Orphanos P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15051A479	List: ML15051A464
References
NMP2L 2572, TAC MF3056
Download: ML15051A464 (16)

Text

This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 3.

~ Exelon Generation NMP2L 2572 10 CFR 50.90 February 18, 2015 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410

Subject:

Response to Fifth Request for Additional Information Concerning Nine Mile Point Nuclear Station License Amendment Request for Maximum Extended Load Line Limit Analysis Plus

References:

1. Letter from P. Swift (NMPNS) to Document Control Desk (NRC), License Amendment Request Pursuant to 10 CFR 50.90: Maximum Extended Load Line Limit Analysis Plus, dated November 1, 2013 (ML13316B1307)

2. Letter from C. Costanzo (NMPNS) to Document Control Desk (NRC),

License Amendment Request Pursuant to 10 CFR 50.90: Maximum Extended Load Line Limit Analysis Plus- Revision 1, dated June 13, 2014 (ML14169A034)

3. Email from B. Vaidya (NRC) to K. Kristensen (NMPNS), Request for Additional Information Nine Mile Point Nuclear Station Unit 2 License Amendment Request Pursuant to 10 CFR 50.90: Maximum Extended Load Line Limit Analysis Plus Nine Mile Point Nuclear Station, LLC Docket No.

50-401 TAC N. MF3056 dated February 2, 2015 (ML15033A002)

Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information in support of a previous request for amendment to the Nine Mile Point Unit 2 (NMP2) Renewed Facility Operating License NPF-69. The initial request, dated November 1, 2013 (Reference 1),

included a proposed expansion of the operating boundary to allow operation in the Maximum Extended Load Line Limit Analysis Plus (MELLLA+) domain and the use of the General Electric Hitachi Nuclear Energy (GEH) analysis code TRACG04. The November 1, 2013 request (Reference 1) was revised on June 13, 2014 (Reference 2).

This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 3.

U. S. Nuclear Regulatory Commission February 18, 2015 Page 2 The supplemental information, provided in Attachment 1 (non-proprietary) and Attachment 3 (proprietary) to this letter, responds to the request for additional information that was provided in an email from the NRC Staff to NMPNS on February 2, 2015 (Reference 3). of this letter contains information considered to be proprietary as defined by 10 CFR 2.390. GE Hitachi Nuclear Energy (GEH), as the owner of the proprietary information in , has executed the affidavit provided in Attachment 2 detailing the reasons for withholding the proprietary information. The GEH proprietary information was provided in GEH letter GE-PPO-1GYEF-KG1-744, "GEH Response to NRC SRXB-Fluence-RAI1 in support of the NMP2 MELLLA+ LAR," dated February 13, 2015. On behalf of GEH, NMPNS hereby requests that proprietary information in Attachment 3 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390.

This supplemental information does not change the determination of "no significant hazards consideration" justified in the original amendment request, Reference 1, and as revised in Reference 2. Pursuant to 10 CFR 50.91 (b)(1), NMPNS has provided a copy of this supplemental information to the appropriate state representative.

This letter contains no new regulatory commitments.

Should you have any questions regarding the information contained in this submittal, please contact Mr. Terry Syrell, Acting Regulatory Assurance Manager, at (315) 349-5245.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of February, 2015.

Respectfully, Peter M. Orphanos Site Vice President - Nine Mile Point Exelon Generation Company, LLC PMO/KJK Attachments: 1. Response to SRXB-Fluence-RAI1 (Non-Proprietary)

2. General Electric - Hitachi Affidavit Justifying Withholding Proprietary Information

3. Response to SRXB-Fluence-RAI1 (Proprietary) cc: Regional Administrator, Region I, USNRC Project Manager, USNRC Resident Inspector, USNRC A. L. Peterson, NYSERDA (without Attachment 3)

ATTACHMENT 1 RESPONSE TO SRXB-FLUENCE-RAI1 (NON-PROPRIETARY)

This Attachment provides supplemental information that responds to the NRC's request for additional information that was provided in an email to NMPNS dated February 2, 2015. The NRC question is repeated (in italics), followed by the response. The response addresses the alternative comparison of flux. contains the non-proprietary version of Enclosure 1 of GE-PPO-1GYEF-KG1-744 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 (( I].

Nine Mile Point Nuclear Station, LLC February 18, 2015 Non-Proprietary Information - Class I (Public)

GE-PPO- 1GYEF-KG 1-744 Page 1 of 9 SRXB - Fluence RAI 1 By application dated November 21, 2012, NMPNS requested changes to the facility Technical Specifications as necessary to implement a Pressure Temperature Limits Report (PTLR) using a plant-specific method performed by MPM Technologies, Inc. (MPM). This application was approved by the NRC staff in its safety evaluation, "Nine Mile Point Nuclear Station, Unit No. 2

- Issuance of Amendment Regarding Relocation of Pressure and Temperature Limit Curves to the Pressureand Temperature Limits Report," dated May 29, 2014 (ML14057A554).

Fluence is identified in the MELLLA+ topical report as an item to be dispositioned.

NEDC-33576NP, Safety Analysis Report for Nine Mile Point Unit 2 Maximum Extended Load Line Limit Analysis Plus (ML13316B109) attached with the application states that MELLLA+

flux is calculated using the GEH flux evaluation methodology contained in NEDO-32983-A, Revision 2, "General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations," (ML072480121).

A clarificationcall on Tuesday, December 16, 2014, took place to discuss the NMP2 MELLLA+

GEH method for fluence evaluation. The licensee stated, in part, that the PTLR approved by the NRC staff uses the MPM plant-specific calculation and that the fluence evaluation for MELLLA+ conditions was performed using the GEH method contained in NEDO-32983-A, Revision 2. The final outcome of this call was for the licensee to submit the neutron fluence calculationnotes and data for MELLLA+ conditionsfor audit.

The NRC staff audited the provided materialfrom the licensee for neutronfluence calculations using the GEH method. While auditing the provided calculations, the NRC staff observed that the fluence estimation and flux/fluence data documented in the plant-specific MPM method are used as the basis for all pre-EPU cycles. The NRC staff also observed that the fluence estimation is based on a combination of (1) End-of-Cycle (EOC) 10 fluence at 14.08 Effective Full Power Years (EFPY) documented in the plant-specific MPM method, (2) Cycle 10 flux derived from 22-EFPY fluence and EOC 10 fluence in the plant-specific MPM method, and (3) M+ flux calculatedin this task.

The combination of multiple fluence methods is not in accordance with Regulatory Guide (RG) 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence." Nor is it, in the staff's view, accordant with NEDO-32983-A, Revision 2, since the NEDO document is limited only to GEH's calculationalapproach, and it does not provide for fluence inputsfrom other methods. Furthermore,the NRC did not identify any information in the M+SAR justifying the combination of multiplefluence methods.

The NRC staff requests the licensee to provide a RG 1.190 compliant disposition of fluence calculations that is in accordance with the MELLLA+ topical report. Alternatively, provide a comparison of EPUflux and MELLLA+ flux to show that the effects of MELLLA+ operation are appropriatelyaddressed. Provide information to show that (1) the comparativeflux evaluation is conservative relative to recent plant operation, (2) the comparativeflux evaluation is based on RG 1.190-adherent transport methods, and (3) the comparativeflux evaluation accountsfor the increasedcoolant void conditions associatedwith MELLLA+ operation.

Non-Proprietary Information - Class I (Public)

GE-PPO- 1GYEF-KG1-744 Page 2 of 9 GEH Response This response demonstrates that the effects of Maximum Extended Load Line Limit Analysis Plus (MELLLA+) operation on Reactor Pressure Vessel (RPV) fast neutron fluence as it impacts Pressure-Temperature Limits are appropriately addressed by providing a relative comparison of the Extended Power Uprate (EPU) and MELLLA+ flux.

The comparative flux evaluation accounts for the increased coolant void conditions associated with MELLLA+ operation. The assessment of the relative impact of the MELLLA+ operation on the neutron flux as a result of the expected decreased water density resulting from MELLLA+

operation was performed in accordance with MELLLA+ Licensing Topical Report (LTR) Safety Evaluation Report (SER) Limitation and Condition 12.8 using the GE Hitachi Nuclear Energy (GEH) flux evaluation methodology contained in Reference 1. The flux evaluation was performed by comparing the MELLLA+ equilibrium cycle design to the EPU equilibrium cycle design using GEH RG 1.190 adherent transport methods. The EPU and MELLLA+ equilibrium cores assume the same batch size and new fuel loading of (( )) bundles. Both the MELLLA+ and EPU equilibrium cycle design parameters used in the GEH flux models account for the((

)) The variation in the neutron flux is depicted in Table 1 and in Figures 1 through 5. While it is expected that there is an increase in coolant voids (and decrease in average water density) within the core due to decreased flow for MELLLA+ operation, there is also ((

The MELLLA+ decreased water density in the upper portion of the core results in a 1% increase for the core shroud fast neutron flux and a 7% increase in the fast neutron flux at the top guide vessel internal component. The 1% shift in core shroud flux and 7% shift in top guide flux are not considered significant as these internal components already have fluence levels well above the 5E20 n/cm 2 Irradiation-Assisted Stress Corrosion Cracking (IASCC) threshold. The small increase in flux due to MELLLA+ does not significantly change the material's susceptibility.

Additionally, the requirement for stress to be present as a conjoint factor for Stress Corrosion Cracking (SCC) continues to restrict the areas of concern for crack initiation to those regions in the vicinity of the welds. Based on this assessment, the inspections documented in the Boiling Water Reactor Vessel and Internals Program (BWRVIP) continue to be adequate to assess the effects of IASCC at current levels as well as those associated with MELLLA+. Similarly, MELLLA+ has no impact on Intergranular Stress Corrosion Cracking (IGSCC) of the reactor coolant pressure boundary.

Non-Proprietary Information - Class I (Public)

GE-PPO- 1GYEF-KG 1-744 Page 3 of 9 The reduced fast flux on the RPV based on the equilibrium cycle relative comparison demonstrated that the vessel fluence calculation used to set the pressure-temperature limits based on a RG 1.190 adherent method remain conservative for fracture toughness.

The relative flux comparison is conservative relative to recent plant operation. The NMP2 RG 1.190 vessel fluence basis using MPM methods is described in the NMP2 USAR. The NMP2 vessel transport results for the first EPU operating cycle, Cycle 14, indicate that the peak flux is approximately 21% less than the equilibrium cycle estimated neutron flux and resulting fluence used to define the reactor vessel material fracture toughness and operating pressure temperature curves. Several core design and operating factors contribute to this result with the primary factor being a core design achieving a significantly reduced batch size of (( )) for Cycle 14 compared to (( )) for the equilibrium cycle, which reduces the number of high power fuel bundles located near the periphery. For Cycle 15, the batch size is ((

Cycle 15 is the current cycle and the initial implementation of MELLLA+ will occur during the end of cycle operation. The results for NMP2 Cycle 14, using a RG 1.190 adherent fluence method, tracks the as-designed core parameters and operating conditions, and the next update is planned for the end of Cycle 15 to maintain accurate vessel fluence accounting. The NMP2 RG 1.190 methods used to track cycle-specific vessel fluence demonstrate that use of the EPU equilibrium core design fluence values in fracture toughness calculations is conservative.

Based on the MELLLA+ / EPU equilibrium cycle relative flux comparison, using the GEH RG 1.190 flux methods confirming that ((

)) and the NMP2 RG 1.190 fluence basis used to develop the pressure-temperature limits that is conservative relative to recent and projected plant operation, the impact of RPV fast neutron fluence is appropriately addressed for MELLLA+ operation.

References:

1. GE Nuclear Energy, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations," NEDC-32983P-A, Revision 2, January 2006.

2. GE Nuclear Energy, "General Electric Boiling Water Reactor Maximum Extended Load Line Limit Analysis Plus," NEDC-33006P-A, Revision 3, June 2009.

Non-Proprietary Information - Class I (Public)

GE-PPO- 1GYEF-KG 1-744 Page 4 of 9 Table 1 MELLLA+ vs EPU Equilibrium Cycle Neutron Flux Comparison Based on GEH RG 1.190 Neutron Transport Flux Methods Parameter EPU MELLLA+ Notes RPV Azimuthal Inner Radius Figure 1 Figure 1 Ratio of Neutron Flux 1.12E9 at 1.10E9 at M+/EPU is 0.98 (E>1.0 MeV n/cm 2-s) 260 and 64' 26' and 640 RPV Axial Inner Radius Flux Figure 2 Figure 2 No significant Distribution peak elevation is peak elevation is change (E>1.0 MeV n/cm 2-s) 71" above Bottom 71" above BAF of Active Fuel (BAF)

Core Shroud Azimuthal Inner Figure 3 Figure 3 Ratio of Radius Neutron Flux peak 2.99E12 at peak 3.02E12 at M+/EPU is 1.01 (E>1.0 MeV n/cm 2-s) 24.50 and 65.50 24.5' and 65.50 azimuth azimuth Core Shroud Axial Inner Radius Figure 4 Figure 4 No significant Neutron Flux elevation is 75" elevation is 75" change (E>1.0 MeV n/cm 2 -s) above BAF above BAF Peak Neutron Flux at Top Guide Figure 5 Figure 5 Ratio of (E>1.0 MeV n/cm 2 -s) 2.37E13 2.54E13 M+/EPU is 1.07 Peak Neutron Flux at Core Plate 3.88E 1I 3.65E1 1 Ratio of (E>1.0 MeV n/cm 2 -s) M+/EPU is 0.94 Peak Neutron Flux at Bio Shield 6.18E7 6.18E7 No significant (E>1.0 MeV n/cm 2-s) change Peak Neutron Flux at N6 Nozzle 3.60E8 3.42E8 Ratio of (E>1.0 MeV n/cm 2 -s) M+/EPU is 0.95 Peak Neutron Flux at N 12 2.51 E8 2.41E8 Ratio of Nozzle (E>1.0 MeV n/cm2-s) M+/EPU is 0.96 Non-Proprietary Information - Class I (Public)

GE-PPO- 1GYEF-KG 1-744 Page 5 of 9 1]

Figure 1. Azimuthal Distribution of Fast Neutron Flux at RPV Inner Surface at Peak Elevation Non-Proprietary Information - Class I (Public)

GE-PPO- 1GYEF-KG 1-744 Page 6 of 9 11 Figure 2. Axial Distribution of Fast Neutron Flux at RPV Inner Surface at Peak Azimuth Non-Proprietary Information - Class I (Public)

GE-PPO- 1GYEF-KG 1-744 Page 7 of 9 Figure 3. Azimuthal Distribution of Fast Neutron Flux at Shroud Inner Surface at Peak Elevation Non-Proprietary Information - Class I (Public)

GE-PPO- 1GYEF-KG 1-744 Page 8 of 9 Figure 4. Axial Distribution of Fast Neutron Flux at Shroud Inner Surface at Peak Azimuth Non-Proprietary Information - Class I (Public)

GE-PPO-1GYEF-KG1-744 Page 9 of 9 11 Figure 5. Axial Distribution of Fast Neutron Flux at Peak Top Guide Location

ATTACHMENT 2 GENERAL ELECTRIC - HITACHI AFFIDAVIT JUSTIFYING WITHHOLDING PROPRIETARY INFORMATION Nine Mile Point Nuclear Station, LLC February 18, 2015

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, GE-PPO-1GYEF-KG1-744, "GEH Response to NRC SRXB - Fluence - RAI 1 in Support of the NMP2 MELLLA+ LAR," dated February 13, 2015. The GEH proprietary information in Enclosure 1, which is entitled "Response to SRXB - Fluence - RAI 1 in Support of the NMP2 MELLLA+ LAR," is identified by a dotted underline inside double square brackets.

((This sentence is an example... 31.)) Figures and large objects are identified with double square brackets before and after the object. 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, GEH relies upon the exemption from disclosure set forth in the Freedom of Infonnation 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 GE-PPO- I GYEF-KG 1-744 Page I 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 GE-PPO- 1GYEF-KG 1-744 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 13th day of February 2015.

Lisa K. Schichlein Senior Project Manager, NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road, M/C A-65 Wilmington, NC 28401 Lisa.Schichlein@ge.com Affidavit for GE-PPO- 1GYEF-KG 1-744 Page 3 of 3