ML15023A044

Brunswick Steam Electric Plant, Unit 2 - Submittal of Confirmatory Calculation for Unit 2, Cycle 22

ML15023A044
Person / Time
Site:	Brunswick
Issue date:	01/13/2015
From:	Pope A H 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 PlantDUKE Letter Enclosure 1 Contains Proprietary Information P.O. Box 10429ENERGY, Withhold in Accordance with 10 CFR 2.390(a)(6) Southport, NC 28461January 13, 2015Serial: BSEP 15-0004U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Subject:

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

Reference:

1. Letter from Christopher Gratton (NRC) to Michael J. Annacone (CP&L), "BrunswickSteam Electric Plant, Units 1 and 2 -Issuance of Amendments Regarding Addition ofAnalytical Methodology Topical Reports to Technical Specification 5.6.5 and revision toMinimum Critical Power Ratio Safety Limit (TAC Nos. ME8135 and ME8136)," datedMarch 1, 2013, ADAMS Accession Number ML13037A551Ladies and Gentlemen:On March 1, 2013 (i.e., Reference 1), the U.S. Nuclear Regulatory Commission (NRC) issuedAmendment Nos. 262 and 290 to the Renewed Facility Operating Licenses for the BrunswickSteam Electric Plant (BSEP), Units 1 and 2, respectively. These amendments included anupdate to a license condition in Appendix B, "Additional Conditions," which requires evaluationand confirmation of Safety Limit Minimum Critical Power Ratio (SLMCPR), setpoint, and Qoreoperating limit values using methods described in an AREVA Operability Assessment. The .license condition, which is restated below, requires the confirmatory evaluation be submitted atleast 60 days prior to startup of each operating cycle.Safety Limit Minimum Critical Power Ratio (SLMCPR), setpoint, and core operating limitvalues determined using the ANP-10298PA, ACE/ATRIUM 1OXM Critical PowerCorrelation (i.e., TS 5.6.5.b.21), shall be evaluated to verify the values determined usingthe NRC-approved method remain applicable and the core operating limits includemargin sufficient to bound the effects of the K-factor calculation issue described inAREVA Operability Assessment CR 2011-2274, Revision 1. SLMCPR shall be evaluatedwith methods described in AREVA Document ANP-3086(P), Revision 0, BrunswickUnit 1 and Unit 2 SLMCPR Operability Assessment Critical Power Correlation forATRIUM IOXM Fuel -Improved K-factor Model. Setpoint and core operating limit valuesshall be evaluated with methods described in AREVA Operability AssessmentCR 2011-2274, Revision 1. The results of the evaluation shall be documented andsubmitted to the NRC, for review, at least 60 days prior to startup of each operatingcycle.A C/

U.S. Nuclear Regulatory CommissionPage 2 of 3The purpose of this letter is to submit the Unit 2 evaluation results for the upcoming BSEPUnit 2 Cycle 22. Based on a currently scheduled startup date of March 15, 2015, for theupcoming BSEP Unit 2 Cycle 22 refueling outage, submittal of the Unit 2 evaluation is requiredby 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 Assessmentreport 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 inEnclosure 2 and stated that the identified proprietary information has been handled andclassified as proprietary, is customarily held in confidence, and has been withheld from publicdisclosure. AREVA requests that the identified proprietary information be withheld from publicdisclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of theAREVA 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 -RegulatoryAffairs, at (910) 457-2487.Sincerely,An ette H. PopeDirector -Organizational EffectivenessBrunswick Steam Electric PlantWRM/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 CommissionPage 3 of 3cc (with Enclosures 1, 2, and 3):U.S. Nuclear Regulatory Commission, Region IIATTN: Mr. Victor M. McCree, Regional Administrator245 Peachtree Center Ave, NE, Suite 1200Atlanta, GA 30303-1257U.S. Nuclear Regulatory CommissionATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only)11555 Rockville PikeRockville, MD 20852-2738U.S. Nuclear Regulatory CommissionATTN: Ms. April Scarbeary, NRC Senior Resident Inspector8470 River RoadSouthport, NC 28461-8869cc (with Enclosures 2 and 3):Chair -North Carolina Utilities CommissionP.O. Box 29510Raleigh, NC 27626-0510 BSEP 15-0004Enclosure 2AREVA AffidavitRegarding WithholdingOperability Assessment(CR #2014-7395)

AFFIDAVITSTATE OF WASHINGTON )) ss.COUNTY OF BENTON )1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVAInc. and as such I am authorized to execute this Affidavit.2. I am familiar with the criteria applied by AREVA to determine whether certainAREVA information is proprietary. I am familiar with the policies established byAREVA to ensure the proper application of these criteria.3. I am familiar with the AREVA information contained in the OperabilityAssessment for Condition Report 2014-7395, entitled, "Operability Assessment (CR # 2014-7395)," and referred to herein as "Document." Information contained in this Document has beenclassified by AREVA as proprietary in accordance with the policies established by AREVA forthe control and protection of proprietary and confidential information.4. This Document contains information of a proprietary and confidential natureand is of the type customarily held in confidence by AREVA and not made available to thepublic. Based on my experience, I am aware that other companies regard information of thekind contained in this Document as proprietary and confidential.5. This Document has been made available to the U.S. Nuclear RegulatoryCommission in confidence with the request that the information contained in this Document bewithheld from public disclosure. The request for withholding of proprietary information is madein 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 financialinformation."6. The following criteria are customarily applied by AREVA to determine whetherinformation should be classified as proprietary:(a) The information reveals details of AREVA's research and development plansand programs or their results.(b) Use of the information by a competitor would permit the competitor tosignificantly 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 aprocess, methodology, or component, the application of which results in acompetitive advantage for AREVA.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitive advantage for AREVA in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA, would behelpful to competitors to AREVA, and would likely cause substantial harm tothe competitive position of AREVA.The information in the Document is considered proprietary for the reasons set forth inparagraphs 6(b), 6(d) and 6(e) above.7. In accordance with AREVA's policies governing the protection and control ofinformation, proprietary information contained in this Document have been made available, on alimited basis, to others outside AREVA only as required and under suitable agreement providingfor nondisclosure and limited use of the information.8. AREVA policy requires that proprietary information be kept in a secured file orarea 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.%. kSUBSCRIBED before me this_____day of 1 2015.Susan K. McCoyNOTARY PUBLIC, STATE OF WAa1"INGTONMY COMMISSION EXPIRES: 1/14/2016