ML15023A044

Submittal of Confirmatory Calculation for Unit 2, Cycle 22

ML15023A044
Person / Time
Site:	Brunswick
Issue date:	01/13/2015
From:	Pope A Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15023A063	List: BSEP 15-0004, Enclosure 3 - Areva Operability Assessment. (CR 2014-7395) ML15023A044
References
BSEP 15-0004
Download: ML15023A044 (7)

Text

Brunswick Nuclear Plant DUKE Letter Enclosure 1 Contains Proprietary Information P.O. Box 10429

ENERGY, Withhold in Accordance with 10 CFR 2.390(a)(6)

Southport, NC 28461 January 13, 2015 Serial: BSEP 15-0004 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit No. 2 Renewed Facility Operating License No. DPR-62 Docket No. 50-324 Submittal of Confirmatory Calculation for Unit 2, Cycle 22

Reference:

1. Letter from Christopher Gratton (NRC) to Michael J. Annacone (CP&L), "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendments Regarding Addition of Analytical Methodology Topical Reports to Technical Specification 5.6.5 and revision to Minimum Critical Power Ratio Safety Limit (TAC Nos. ME8135 and ME8136)," dated March 1, 2013, ADAMS Accession Number ML13037A551 Ladies and Gentlemen:

On March 1, 2013 (i.e., Reference 1), the U.S. Nuclear Regulatory Commission (NRC) issued Amendment Nos. 262 and 290 to the Renewed Facility Operating Licenses for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2, respectively. These amendments included an update to a license condition in Appendix B, "Additional Conditions," which requires evaluation and confirmation of Safety Limit Minimum Critical Power Ratio (SLMCPR), setpoint, and Qore operating limit values using methods described in an AREVA Operability Assessment. The.

license condition, which is restated below, requires the confirmatory evaluation be submitted at least 60 days prior to startup of each operating cycle.

Safety Limit Minimum Critical Power Ratio (SLMCPR), setpoint, and core operating limit values determined using the ANP-10298PA, ACE/ATRIUM 1OXM Critical Power Correlation (i.e., TS 5.6.5.b.21), shall be evaluated to verify the values determined using the NRC-approved method remain applicable and the core operating limits include margin sufficient to bound the effects of the K-factor calculation issue described in AREVA Operability Assessment CR 2011-2274, Revision 1. SLMCPR shall be evaluated with methods described in AREVA Document ANP-3086(P), Revision 0, Brunswick Unit 1 and Unit 2 SLMCPR Operability Assessment Critical Power Correlation for ATRIUM IOXM Fuel - Improved K-factor Model. Setpoint and core operating limit values shall be evaluated with methods described in AREVA Operability Assessment CR 2011-2274, Revision 1. The results of the evaluation shall be documented and submitted to the NRC, for review, at least 60 days prior to startup of each operating cycle.

A C/

U.S. Nuclear Regulatory Commission Page 2 of 3 The purpose of this letter is to submit the Unit 2 evaluation results for the upcoming BSEP Unit 2 Cycle 22. Based on a currently scheduled startup date of March 15, 2015, for the upcoming BSEP Unit 2 Cycle 22 refueling outage, submittal of the Unit 2 evaluation is required by January 14, 2015.

The evaluation is documented in an AREVA report titled "AREVA Operability Assessment (CR #2014-7395)," a copy of which is provided in Enclosure 1. This Operability Assessment report contains information that AREVA considers proprietary, as defined by 10 CFR 2.390.

AREVA, as the owner of that proprietary information, has executed the affidavit provided in and stated that the identified proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. AREVA requests that the identified proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of the AREVA Operability Assessment (CR #2012-7395) is provided in Enclosure 3.

This document contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

Sincerely, An ette H. Pope Director - Organizational Effectiveness Brunswick Steam Electric Plant WRM/wrm

Enclosures:

1. AREVA Operability Assessment (CR #2014-7395) (Proprietary Information -

Withhold from Public Disclosure in Accordance With 10 CFR 2.390)

2. AREVA Affidavit Regarding Withholding Operability Assessment (CR #2014-7395)

3. Non-Proprietary Version of AREVA Operability Assessment (CR #2014-7395)

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with Enclosures 1, 2, and 3):

U.S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Ms. April Scarbeary, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 cc (with Enclosures 2 and 3):

Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

BSEP 15-0004 AREVA Affidavit Regarding Withholding Operability Assessment (CR #2014-7395)

AFFIDAVIT STATE OF WASHINGTON

)

) ss.

COUNTY OF BENTON

)

1.

My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.

2.

I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.

3.

I am familiar with the AREVA information contained in the Operability Assessment for Condition Report 2014-7395, entitled, "Operability Assessment (CR # 2014-7395)," and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.

4.

This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5.

This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with. 10 CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6.

The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:

(a)

The information reveals details of AREVA's research and development plans and programs or their results.

(b)

Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c)

The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA.

(d)

The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e)

The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.

The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.

7.

In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8.

AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9.

The foregoing statements are true and correct to the best of my knowledge, information, and belief.

k SUBSCRIBED before me this_____

day of 1 2015.

Susan K. McCoy NOTARY PUBLIC, STATE OF WAa1"INGTON MY COMMISSION EXPIRES: 1/14/2016