Q7/23/2Q14 U.S. Nuclear Reeulaforv Co ission ODerations Center Event ReDort P000 I

Part 21 (PAR) Event # 49908

Rep Org: GE HITACHI NUCLEAR ENERGY Notification Date / Time: 03/13/2014 13:05 (EDT)

Supplier: ASCO VALVE, INC. Event Date / Time: 01/16/2014 (EDT)Last Modification: 07/23/2014

Region: 1 Docket #:

City: WILMINGTON Agreement State: YesCounty: License #:

State: NC

NRC Notified by: LISA SCHICHLEIN Notifications: MARC FERDAS R1 DO

HQ Ops Officer: DONG HWA PARK KATHLEEN O'DONOHUE R2DO

Emergency Class: NON EMERGENCY DAVE PASSEHL R3DO

10 CFR Section: THOMAS FARNHOLTZ R4DO

21.21 (a)(2) INTERIM EVAL OF DEVIATION PART 21 GROUP EMAIL

PART 21 - UNSEATING OF VALVE SPRING ON SCRAM SOLENOID PILOT VALVE

"This concerns an evaluation being performed by GE Hitachi Nuclear Energy (GEH) regarding a malfunction of aScram Solenoid Pilot Valve (SSPV), which has been observed to impair control rod scram performance. As statedherein, GEH has not concluded that this is a reportable condition in accordance with the requirements of 10CFR21.21(d). The SSPV manufacturer (ASCO Valve, Inc.) has not yet concluded its own investigation under 1OCFR21, and the results of that investigation are needed as input for the GEH evaluation. The manufacturer has issuedan Interim Report, which provides confidence that this condition is limited to a very small portion of the suspectpopulation.

"A malfunction of a Scram Solenoid Pilot Valve was attributed to the disengagement of the valve spring from thevalve plunger. The effect of the malfunction is to degrade scram performance of an affected control rod. The safetysignificance of this condition cannot be determined at this time, but several mitigating and compensatory functionshave been identified."

This evaluation affects Fermi 2, Columbia, Dresden 2-3, Oyster Creek, Peach Bottom 2-3, Quad Cities 1-2, andBrowns Ferry 1-3.

* * * UPDATE AT 1502 EDT ON 07/23/14 FROM LISA SCHICHLEIN TO S. SANDIN VIA FAX ***

"Subject: Completed Evaluation of Part 21 Potentially Reportable Condition Notification: Unseating of Valve Springon SSPV

"This letter provides information concerning an evaluation now completed by GE Hitachi Nuclear Energy (GEH)regarding the malfunction of Scram Solenoid Pilot Valves (SSPVs), which have been observed to impair control

671231261407/23/2014 I~US'. Nucehar Rogu atnrv Commission, ()nrationn. Ce~nter Event R,-nnrt Pa, e--------------------------

rod scram performance. As stated herein, GEH has concluded this condition is Not Reportable for two of theaffected plants (Enrico Fermi 2 and Columbia Generating Station plants), but GEH does not have sufficientinformation to fully evaluate the safety significance of the condition for the remainder of the potentially affectedplants. Given that, GEH closes this 10 CFR Part 21 evaluation with a Transfer of Information to potentially affectedlicensees, in accordance with the requirements of 10 CFR 21.21(b) and will communicate the determination of NotReportable to the identified plants where sufficient information was available to make that determination.

"Although the Enrico Fermi 2 and Columbia Generating Station plants are included in the attached list of U.S.plants potentially affected, inspections of all suspect SSPVs remaining at those plants indicate that no other SSPVsat those plants exhibit the condition (as informally reported to GEH), and therefore those plants were determined tonot have a reportable condition.

"This letter closes the supplemental 60-Day Interim Report Notification (MFN 14-010 RO), provided on March 13,2014, per 10 CFR 21.21 (a)(2).

"If you have any questions, please call me at (910) 819-4491.

"Sincerely,

"Dale E. Porter"Safety Evaluation Program Manager"GE-Hitachi Nuclear Energy Americas LLC"

Notified R1DO (Gray), R2DO (Musser), R3DO (Orth), R4DO (Miller) and NRR Part 21 Group via email.

HITACHI GE Hitachi Nuclear Energy

Proprietary Notice Dale E. Porter

This letter transmits proprietary information GE-Hitachi Nuclear Energy Americas LLCin accordance with 10CFR2.390. Upon Safety Evaluation Program Manager

removal of Enclosure 1, the balance of this 3901 Castle Hayne Rd.,letter may be considered non-proprietary. Wilmington, NC 28401

USA

July 23, 2014 T 910 819-4491

MFN 14-010 RI Dale.Porter@GE.Com

U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Washington, DC 20555-0001

Subject Completed Evaluation of Part 21 Potentially Reportable Condition Notification:

Unseating of Valve Spring on SSPV

This letter provides information concerning an evaluation now completed by GE Hitachi Nuclear

Energy (GEH) regarding the malfunction of Scram Solenoid Pilot Valves (SSPVs), which have been

observed to impair control rod scram performance. As stated herein, GEH has concluded this

condition is Not Reportable for two of the affected plants (Enrico Fermi 2 and Columbia

Generating Station plants), but GEH does not have sufficient information to fully evaluate the

safety significance of the condition for the remainder of the potentially affected plants. Giventhat, GEH closes this 10 CFR Part 21 evaluation with a Transfer of Information to potentially

affected licensees, in accordance with the requirements of 10 CFR 21.21(b) and will communicate

the determination of Not Reportable to the identified plants where sufficient information was

available to make that determination.

Although the Enrico Fermi 2 and Columbia Generating Station plants are included in the attached

list of U.S. plants potentially affected, inspections of all suspect SSPVs remaining at those plants

indicate that no other SSPVs at those plants exhibit the condition (as informally reported to GEH),

and therefore those plants were determined to not have a reportable condition.

This letter closes the supplemental 60-Day Interim Report Notification (MFN 14-010 RO), provided

on March 13, 2014, per 10 CFR 21.21(a)(2).

If you have any questions, please call me at (910) 819-4491.

Sincerely,

Dale E. Porter

Safety Evaluation Program Manager

GE-Hitachi Nuclear Energy Americas LLC

MFN 14-010 R1 Page 2 of 2

References:1. Letter, Dale E. Porter (GEH) to Document Control Desk (NRC), "Part 21 60-Day Interim

Report Notification: Unseating of Valve Spring on SSPV," MFN 14-010 RO,

March 31, 2014.2. ASCO Valve, Inc., 60-Day Interim Report, March 11, 2014, U.S. NRC ADAMS Accession

Number ML14079A026

3. ASCO Valve, Inc., Final Report, June 16, 2014, U.S. NRC ADAMS Accession Number

ML14169A258

Attachments:

1. U.S. Plants Potentially Affected

Enclosures:1. Description of Closure Evaluation, GEH Proprietary Information - Class II (Internal)2. Description of Closure Evaluation, Non-Proprietary Information - Class I (Public)

3. Affidavit for Enclosure 1

cc: J. Golla, USNRC

S. S. Philpott, USNRC

S. J. Pannier, USNRC

A. Issa, USNRC

D. C. Crawford, GEH

J. F. Harrison, GEH

J. G. Head, GEH

J. Burke, GEH

P. L. Campbell, GEH Washington

PRC File

PLM Spec 000N5377 R1

Document Components:001 MFN 14-010 R1 Cover Letter.pdf002 MFN 14-010 R1 Enclosure 1 Proprietary.pdf003 MFN 14-010 R1 Enclosure 2 Non-Proprietary.pdf004 MFN 14-010 R1 Enclosure 3 Affidavit. pdf

MFN 14-010 R1Attachment

Page 1 of 1

Attachment

U.S. Plants Potentially Affected

U.S. BWR Plants and Associated Facilities

SC only TI Utiiy

Constellation EnergyX Detroit Edison Co.X Energy Northwest

EntergyEntergyEntergyEntergyEntergyExelon

X ExelonExelonExelon

x Exelonx ExelonX Exelon

FirstEnergy Nuclear Operating Co.Florida Power & LightNebraska Public Power DistrictPPL Susquehanna LLCProgress EnergyPSEG Services Corp.Southern Nuclear Operating Co.

x Tennessee Valley AuthorityXcel EnergyNorth East Utilities

TI = Transfer of Information (10CFR 21.21(b))SC = GEH Safety Information Communication

Plant

Nine Mile Point 1-2Fermi 2ColumbiaGrand GulfRiver BendFitzPatrickPilgrimVermont YankeeClintonDresden 2-3LaSalle 1-2Limerick 1-2Oyster CreekPeach Bottom 2-3Quad Cities 1-2Perry 1Duane ArnoldCooperSusquehanna 1-2Brunswick 1-2Hope CreekHatch 1 - 2Browns Ferry 1-3MonticelloMillstone

ENCLOSURE 2

MFN 14-010 R1

Description of Closure Evaluation

Non-Proprietary Information - Class I (Public)

IMPORTANT NOTICE

This is a non-proprietary version of Enclosure 1 to MFN 14-010 R1, from which theproprietary information has been removed. Portions of the enclosure that have beenremoved are indicated by open and closed double square brackets as shown here[[ 1].

Enclosure 2 to MFN 14-010 R1 Non-Proprietary Information - Class I (Public)July 23, 2014 Page 1 of 8

Summary

GE Hitachi Nuclear Energy (GEH) has evaluated the discovery of a Scram Solenoid PilotValve (SSPV) with a disengaged valve spring based on available information anddetermined the condition is not reportable for the Columbia Generating Station (Columbia)and the Enrico Fermi Unit 2 Nuclear Facility (Fermi 2). However, GEH does not havesufficient information to fully evaluate the safety significance of the condition under 10 CFRPart 21 for the remaining potentially affected plants. Therefore, GEH will close this 10 CFRPart 21 evaluation with a Transfer of Information to all potentially affected licensees per 10CFR 21.21(b). In parallel with the GEH evaluation, the SSPV manufacturer has issued anInterim Report and a Final Report, providing information resulting from their evaluation.

Effects of the condition were observed at the Columbia and Fermi 2 plants and attributed toa single affected SSPV at each plant, with extents limited to only those affected SSPVs.Because the cores for those plants were designed to ensure adequate shutdown marginwith the strongest control rod remaining fully withdrawn, the effects of the condition wereaccommodated by design, and there was no impact on the ability to shutdown the reactor.

For the remaining plants, GEH does not know the quantity of any affected SSPVs or theirplant-specific locations, which are necessary to determine impact of the condition on theability to shutdown an affected plant. In some scenarios adequate shutdown margin isassured regardless of postulated control rod behavior, but for other scenarios impact onshutdown margin would depend on the number of affected SSPVs, plant-specific coreconfiguration, and the location and cycle-specific worth of any affected control rods. In allcases, diverse backup functions, which are not safety-related, but are proven to be reliable,would likely activate or be available for manual action to ensure control rod insertion.

The GEH evaluation of potential effects consisting of slow scram insertion of affected controlrods during a full-core scram indicates that compensatory measures and defense in depthprovided by the backup scram function and the alternate rod insertion function, which arenot safety-related but are proven reliable, ensure that affected plants will be able toshutdown in accordance with requirements. A previous GEH evaluation indicates that [[

]] would not lead to violation of the Technical Specifications safety limit forMinimum Critical Power Ratio (MCPR).

Introduction

This communication includes background material provided in MFN 14-010 RO (forcompleteness), but updates the evaluation and conclusions.

On January 15, 2014, GEH was informed of the failure of a control rod to scram (i.e., nocontrol rod motion) during a single rod scram test at a U.S. BWR/5 plant (Plant E in Table 1).Plant personnel conducted an investigation and determined that the 118 SSPVs in theHydraulic Control Unit (HCU) for the affected control rod did not function. They inspectedthe valve and discovered that the spring, normally connected to valve plunger (or core), had

Enclosure 2 to MFN 14-010 R1 Non-Proprietary Information - Class I (Public)July 23, 2014 Page 2 of 8

become detached. Such a condition would not place the valve into its isolated/ventedconfiguration upon deactivation in response to the Reactor Protection System (RPS) scramsignal, and scram performance would be degraded, with a delayed insertion proceedingthrough function of the backup scram valves (or, if necessary, manual activation of theAlternate Rod Insertion (ARI) system or by other manual methods). In the case of a singlerod scram test, the backup scram valves do not open and the condition would leave the.control rod unmoved in the pre-scram position; this was the behavior observed at Plant E.

The valve was returned for inspection to the SSPV manufacturer (ASCO Valve, Inc.), whoinitiated their own 10 CFR Part 21 investigation into the apparent condition of the valve andthe extent of condition. The manufacturer completed their investigation and followed theirInterim Report (March 11, 2014, available on the U.S. NRC website under ADAMSaccession number ML14079A026) with their Final Report, submitted to the U.S. NRC onJune 16, 2014 (ADAMS accession number ML14169A258), and results from theinvestigation have been incorporated into the GEH evaluation of safety significance inaccordance with 10 CFR Part 21. Details provided herein present the information availableto GEH and support the GEH determination that GEH does not have sufficient information tocompletely evaluate the safety significance of the condition, as required by10 CFR Part 21for some potentially affected plants.

Description of Discovery

A review of available industry operating experience and recent GEH experience indicates

that this condition was observed and reported 5 times: 1993, 1994 (two occurrences), 2012,and 2014: The salient information from the review is summarized in Table 1.

Summary of Observed Behaviors

* In observations from 1993, 1994 (2), 2012, and 2014, the condition was discoveredduring normal plant operation within months after valve installation but in only onecase during post-maintenance testing just after installation of the affected valve.

o The 2012 and 2014 occurrences of the condition were evident within

7 months of valve installation, after cycling roughly 60 to 200 times in half-scram tests (during which the condition would not be evident, because onlyone of the pair of SSPVs is cycled at a time).

o Two of the three occurrences from 1993 and 1994 also appear to have beendiscovered within a short time after valve installation (immediately in post-installation testing in one case, and "shortly after" HCU maintenance in

another case).

* When the condition is present:

o During a full-core scram, the rod fully inserts but is delayed, often outside of

the insertion time required by Technical Specifications. This is because thebackup scram valves depressurize the scram air header, which allows thescram valves to open and the rod to insert, but the rate is slower than

Enclosure 2 to MFN 14-010 R1July 23, 2014

Non-Proprietary Information - Class I (Public)Page 3 of 8

insertion triggered with the SSPV function. (If the backup scram function,which is activated by the RPS were to not function for some reason, theoperator could then manually activate the ARI system, which would alsodepressurize the scram air header to insert affected rods, but at a delayedrate and after the duration needed to trigger the system manually. Note thatthe backup scram function and the ARI system are not safety related.)

o During a single-rod scram test, the control rod fails to move upon scramsignal.

Table I - Summary of SSPV Spring Disengagement History

Date Plant ObservationsMarch 1993 Plant A e Slow scram during full-core scram from operation

BWR/3 * Shortly after Control Rod Drive (CRD) HCU maintenanceApril 1994 Plant B o Slow scram during full-core scram from full-power operation

BWR/2 • Had operated successfully on previous occasions after installation(time to failure not provided)

November 1994 Plant C * Failure to scram in low-power Tech Spec testing during post-outageBWR/3 startup

* Immediately after installation/refurbishmentOctober 2012 Plant D • Passed scram-time test during start-up after installation

BWR/4 * Cycled 87 times in half-scram testing over 2 months* Normal insert from notch 12 during full-core scram 2 months after

installation* Cycled 112 additional times in half-scram testing over next 3 months* Slow to scram during full-core scram (2.5-sec delay) 5 months after

installation (scheduled for testing)* Failure to scram during single-rod test 6 months after installation

January 2014 Plant E e Passed two scram-time tests during start-up after installationBWR/5 * Cycled roughly 60 times in half-scram testing over 7 months

* Failed to scram (no movement) in single-rod test 7 months afterinstallation

Extent of Condition

Based on the manufacturer's bounding of the condition, GEH has defined the suspectpopulation as 437 SSPVs assembled during a period extending from 2010, when theassembly operation was moved to a new location, to November 2012, when an assemblyinspection step was added to confirm spring engagement. GEH has correlated internalrecords with those of the manufacturer to identify the serial numbers of SSPVs delivered toplants sites, as provided in Table 2. From the population of 437 SSPVs, a total of 399SSPVs remain at the plant sites, based on the latest information provided to GEH.(Excluded from Table 2 are an additional 38 valves from the suspect population that werereceived by a plant but later returned to the manufacturer.)

Enclosure 2 to MFN 14-010 R1July 23, 2014

Non-Proprietary Information - Class I (Public)Page 4 of 8

Table 2 - Serial Numbers and Receiving Plants for SSPVs from Suspect Population

00073419 140715 A762654 j -001, -002, -003 4-Apr-11 3Browns Fenry __ Plant Total: 3

-008, -012, -021, -027 -028, -031, -034,

337332 A272718 -035, -036, -045, -046, -048, -049, -050, 3-May-13 20

Columbia -052, -053, -057, -060, -062, -065

Plant Total: 20

00000707 13418 A171767 -001,-002 25-Oct-10 2Dresden Ttl- 2Plant Total: 2

Al13888-001 thru -009, -011 thru -014, -016 thru -024,

-026 thru -050, -052 thru -067, -069, -070,-072, -073 thru -081, -083 thru -125

8-Feb-12 118

4700381095

Fermi

-007 thru -009, -014, -025, -031, 31-Jan-12 9

A171767 -034, -037, -045

-030 22-Aug-11 1

A321861 -021 thru -029 22-Aug-11 9

A321861 -005, -006, -010, -012, -030 thru -037, 31-Jan-12 20-041 thru -047,-050

A351454 -001 thru -005 28-Sep- 12

Plant Total:

23-Aug-10

5

162

33Al 71767

-003 thru -006, -010 thru -013, -015, -020, -022, -023, -024, -026, -027 thru -029,-032, -033, -035, -036, -038 thru -044,

-046 thru -05080 0346504 -4-

A321861-001 thru -004, -007 thru -009,

-011, -013, -014, -017, -018, -038,-039, -040, -048, -049

23-Aug-10 17

Oyster Creek80 045972 A276160 -006 thru -011, -013 thru -033 26-Jun-12 27

A272718 -001 thru -006 5-Nov-12 6

80 048306A276160 -002,-004 11-Sep-12 2

80 045972 A272718 -022. -023. -024 6-May-13

Plant Total:

5-Jan-11

3

88

4A171767 -016 thru -01990 258497 427

Peach Bottom A321861 -015,-016,-019,-020 5-Jan-11 4

__ • Plant Total: 8

Quad Cities 00000707 13765 A272718 -066 thru -071 11-Sep-13 6_

PlantTotal: 6

8981120150 A496905 unknown 9-Dec-10 2

8991120188 A793691 -001 thru -108 108

110

399

Enclosure 2 to MFN 14-010 R1 Non-Proprietary Information - Class I (Public)July 23, 2014 Page 5 of 8

Implications for Safety Significance

The limited number of observations of the condition from the current suspect population andthe consistency of time to identify the condition for the five occurrences (recent and 1990s)suggest this condition occurs with low frequency and relatively early identification. However,the possibility of other affected SSPVs from the suspect population is indeterminate andcannot be quantified without full inspection of each suspect SSPV. For that reason, thedegree to which the suspect population is affected by the condition is uncertain, and thesafety significance of the condition, which depends on the number of control rods affectedand their plant-specific locations, cannot be assessed. However, some comments onconditions and potential effects can be made.

For cases of any affected but undetected SSPVs, the ability to safely shutdown the plantand maintain shutdown will depend on whether the functioning control rods maintainsufficient shutdown margin. In the U.S., and in other countries with similar regulations andpractices, reactor cores and fuel cycles are designed to maintain adequate shutdown marginat all times with the highest-worth control rod fully withdrawn. This ensures that a plantunknowingly affected with a single control rod of this condition (typical of the cases observedthus far), or other conditions with similar effects on scram, will meet shutdown requirementsthroughout the operating cycle, during cold shutdown, and during refueling; in such a case asingle control rod affected by a malfunctioning SSPV will not prevent the safe shutdown ofthe reactor. If that provision is not incorporated into the core design or if multiple controlrods are concurrently impacted, shutdown requirements are likely to be met due to thefunction of the backup scram valves. The backup scram function is activated by the RPSand ensures the scram air header is depressurized to allow the scram valves to open andcontrol rods with non-functioning SSPVs to insert. If the backup scram function were to fail,operator action to activate the ARI system would also depressurize the scram air header,allowing affected control rods to insert. Activation of the ARI system must be initiated insufficient time to allow the rods to insert before the scram discharge volume fills. Control rodinsertion by either of these functions is slower than that triggered through the SSPVs, duepartly to the delay in start of motion and also to the slower rate of insertion. Finally, the

operator has the option of using other, longer-term manual insertion methods, such as thenormal control rod positioning function. Although some equipment used for the backup

scram function, the ARI system, and the other insertion methods is not safety-related, thesefunctions are redundant, independent, and/or diverse to the normal RPS scram function.Furthermore, many years of reactor operation have demonstrated these functions to bereliable under normal and encountered off-normal conditions. If those systems were to failwith multiple control rods concurrently affected by this condition, then shutdownrequirements might not be met; this would depend on plant-specific details, including thecore locations of the affected rods.

For cases in which affected control rods are inserted by the function of the backup scramvalves, the scram insertion time could exceed Technical Specifications scram time limits(i.e., > 7 seconds). However, a previous GEH evaluation of control rod performance [[

]] will

Enclosure 2 to MFN 14-010 R1 Non-Proprietary Information - Class I (Public)July 23, 2014 Page 6 of 8

have negligible effect on critical power ratio for the limiting fuel assembly. [[

]] will not pose a concernfor shutdown of the plant and will not lead to violation of the Technical Specifications safetylimit for MCPR.

Synopsis

What is known about the condition can be summarized as follows:

* The effects of the condition result from a latent tendency for an affected SSPV springto disengage from the valve plunger due to an assembly error that escaped detectionby the manufacturer.

* If a misassembled SSPV spring disengages, the affected control rod is observed toinsert slowly during a full-core scram or to not move at all during a single-rod scramtest.

* A number of BWR plants have received GEH-shipped SSPVs from a populationidentified by the manufacturer as being associated with valve spring disengagement.

o Two occurrences of valve spring disengagement have been discovered fromthe identified population of 437 potentially susceptible SSPVs. (At the time ofthe GEH Interim Report notification of this issue in March 2014, 399 of thosesuspect SSPVs remained at plant sites.)

o Industry operating experience indicates three other known or likelyoccurrences of valve spring disengagement in the 1990s, which are notassociated with the currently identified population.

* Of the five known occurrences to date (three in the 1990s and two within the pasttwo years):

o Valve spring disengagement was detected in only one occurrence at each offive plants.

o The frequency at which this defect exists in any of the current suspect.SSPVsis estimated at just under 1%, based on inspection results from 220 suspectSSPVs from the two plant subpopulations that contained the 2 observeddefects. The probability that this defect exists in more than one suspectSSPV in a single plant is also unknown, but is lower than the probability ofthe defect existing in a single suspect SSPV at the same plant. Finally, theprobability of two or more control rods with affected SSPVs concurrentlyfailing to scram is lower yet.

* Discovered occurrences of the disengaged spring were detected within a relativelyshort time after SSPV replacement installation and specifically within 7 months (or 60to 200 valve cycles) for the two recent occurrences.

Enclosure 2 to MFN 14-010 R1 Non-Proprietary Information - Class I (Public)July 23, 2014 Page 7 of 8

o However, the manufacturer's investigation of the failure mechanism was notable to decisively conclude whether the condition would reliably becomeapparent within a short time or a limited number of valve cycles afterinstallation (i.e., it could not consistently replicate behavior consistent with anSSPV spring disengaging within a single plant operating cycle as observed inat least 4 of the 5 occurrences from 1993, 1994, 2012, and 2014).

Safety significance of this condition, if present, depends on the number of affectedcontrol rods and, if multiple control rods in a plant are concurrently affected, on theirlocation. But some general points can be made:

o For U.S. plants, with core loadings designed to maintain adequate shutdownmargin with the strongest rod fully withdrawn, failure of one control rod toinsert, for whatever reason, will not prevent the safe shutdown of the reactor.

o Shutdown margin is otherwise provided reliably by the backup scram functionand the ARI system, which serve to depressurize the scram air header andallow control rods with SSPV failure to insert. Operators might also choose toinsert un-scrammed rods using the normal control positioning function.These alternate methods use equipment that is not safety-related, but hasproven reliable over many years of reactor operation.

o Scram insertion initiated by backup scram function or ARI could exceedTechnical Specification scram times, but in a previous GEH evaluation, acondition [[

]] was shown to have negligible effect on critical power

performance of the limiting fuel assembly.

Because the condition affected only a single control rod each at the Columbia and Fermi 2plants, and because the cores for those plants were designed to ensure adequate shutdownmargin with the strongest control rod remaining fully withdrawn, the effects of the conditionwere accommodated by design and there was no impact on the ability to safely shutdownthe reactor.

GEH is not able to evaluate the safety significance of this condition with the limitedinformation available for the remainder of the potentially affected plants. Specifically, GEHdoes not know the following:

" the number of shipped suspect SSPVs at those plants that are actually affected;

* the time needed for the condition to manifest with an impact on scram performance;and

* the specific core locations and relative worth of control rods and HCUs withpotentially affected SSPVs.

Enclosure 2 to MFN 14-010 R1 Non-Proprietary Information - Class I (Public)July 23, 2014 Page 8 of 8

ABWR and ESBWR Design Certification Documentation Applicability

The issue described herein has been reviewed for applicability to documentation associatedwith 10 CFR 52, and determined to have no effect on the technical information contained ineither the ABWR certified design or the ESBWR design in certification. This is true becausethis condition is not a deficiency in design.

Recommendations

GEH suggests the following:

* Customers who received shipments of the suspect SSPVs but have not inspectedthose SSPVs for spring engagement should consider coordinating with GEH toreturn suspect SSPVs to the manufacturer, ASCO Valve, Inc., for inspection, aspractical and appropriate. Inspections can be performed at the plant site, but thesupplier cautions against that because of the potential for valve nylon thread lockdebris to impact operation of the valve.

* Plant staff can consider whether more-frequent testing of CRDs with suspect SSPVsis beneficial to identify presence of the condition for appropriate action. However,staff should be advised that effects are not gradual to allow early identification beforeSSPV malfunction (i.e., the observable characteristic is scram performance affectedby the malfunction).

GEH assistance on this issue can be obtained by contacting Rich Jones(richard2.jones@ge.com; 910-819-6043, or 910-228-4602).

Corrective/Preventive Actions

The manufacturer, ASCO Valve, Inc. issued an Interim Report, ("Interim Report onHVL26600000010J Valve," March 11, 2014, U.S. NRC ADAMS Accession NumberML14079A026) with stated intention to complete their investigation by the end of June 2014.Their investigation was completed and their final report transmitted to the U.S. NRC and toGEH on June 16, 2014. The final report can be found on the U.S. NRC website underADAMS Accession Number MIL14169A258.

In the supplier's Interim Report, the supplier stated that future occurrence of this conditionwill be prevented by an additional inspection step, incorporated November 9, 2012, toconfirm proper spring engagement during assembly.

ENCLOSURE 3

MFN 14-010 Ri

Affidavit

GE-Hitachi Nuclear Energy Americas LLCAFFIDAVIT

I, Peter M. Yandow, state as follows:

(1) I am Vice President, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi NuclearEnergy Americas LLC ("GEH"), and have been delegated the function of reviewing theinformation described in paragraph (2) which is sought to be withheld, and have beenauthorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure I of GEH letter,MFN 14-010 RI, "Completed Evaluation of Part 21 Potentially Reportable ConditionNotification: Unseating of Valve Spring on SSPV," dated July 23, 2014. The GEHproprietary information in Enclosure 1, which is entitled "Description of Evaluation," isidentified by a dotted underline inside double square brackets. [[This ".s..sentence ".ie. s ".a nexampl.e..13.11]. In each case, the superscript notation 13 refers to Paragraph (3) of thisaffidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is theowner or licensee, GEH relies upon the exemption from disclosure set forth in theFreedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade SecretsAct, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) fortrade secrets (Exemption 4). The material for which exemption from disclosure is heresought also qualifies under the narrower definition of trade secret, within the meaningsassigned to those terms for purposes of FOIA Exemption 4 in, respectively, CriticalMass Energy Project v. Nuclear Regulatory Commission, 975 F2.d 871 (DC Cir. 1992),and Public Citizen Health Research Group v. FDA, 704 F2.d 1280 (DC Cir. 1983).

(4) The information sought to be withheld is considered to be proprietary for the reasons setforth in paragraphs (4)a. and (4)b. Some examples of categories of information that fitinto the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supportingdata and analyses, where prevention of its use by GEH's competitors withoutlicense from GEH constitutes a competitive economic advantage over othercompanies;

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

c. Information which reveals aspects of past, present, or future GEH customer-fundeddevelopment plans and programs, resulting in potential products to GEH;

d. Information which discloses trade secret or potentially patentable subject matterfor which it may be desirable to obtain patent protection.

MFN 14-010 R1 Enclosure 1 Affidavit Page I of 3

(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is beingsubmitted to NRC in confidence. The information is of a sort customarily held inconfidence by GEH, and is in fact so held. The information sought to be withheld has, tothe best of my knowledge and belief, consistently been held in confidence by GEH, nopublic disclosure has been made, and it is not available in public sources. All disclosuresto third parties, including any required transmittals to NRC, have been made, or must bemade, pursuant to regulatory provisions or proprietary agreements which provide formaintenance of the information in confidence. Its initial designation as proprietaryinformation, and the subsequent steps taken to prevent its unauthorized disclosure, areas set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of theoriginating component, the person most likely to be acquainted with the value andsensitivity of the information in relation to industry knowledge, or subject to the termsunder which it was licensed to GEH.

(7) The procedure for approval of external release of such a document typically requiresreview by the staff manager, project manager, principal scientist, or other equivalentauthority for technical content, competitive effect, and determination of the accuracy ofthe proprietary designation. Disclosures outside GEH are limited to regulatory bodies,customers, and potential customers, and their agents, suppliers, and licensees, and otherswith a legitimate need for the information, and then only in accordance with appropriateregulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because itcontains the detailed results, qualification data, and methodology for the determinationof the degree of impairment of the scram solenoid pilot valve. The reporting, evaluationand interpretations of the results, as they relate to the BWR, was achieved at asignificant cost to GEH.

The development of the methodology along with the interpretation and application ofthe analytical results is derived from the extensive experience database that constitutes amajor GEH asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantialharm 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 andtechnology base, and its commercial value extends beyond the original developmentcost. The value of the technology base goes beyond the extensive physical database andanalytical methodology and includes development of the expertise to determine andapply the appropriate evaluation process. In addition, the technology base includes thevalue derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise asubstantial investment of time and money by GEH.

The precise value of the expertise to devise an evaluation process and apply the correctanalytical methodology is difficult to quantify, but it clearly is substantial.

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GEH's competitive advantage will be lost if its competitors are able to use the results ofthe GEH experience to normalize or verify their own process or if they are able to claiman equivalent understanding by demonstrating that they can arrive at the same or similarconclusions.

The value of this information to GEH would be lost if the information were disclosed tothe public. Making such information available to competitors without their having beenrequired to undertake a similar expenditure of resources would unfairly providecompetitors with a windfall, and deprive GEH of the opportunity to exercise itscompetitive advantage to seek an adequate return on its large investment in developingand obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 23rd day of July 2014.

Peter M. YandowVice President, NPP/Services LicensingRegulatory AffairsGE-Hitachi Nuclear Energy Americas LLC3901 Castle Hayne Road, M/C A-65Wilmington, NC 28401Peter.Yandow@ge.com

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