GNRO-2010/00064, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System

Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System

ML102810306
Person / Time
Site:	Grand Gulf
Issue date:	09/29/2010
From:	Krupa M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2010/00064, TAC ME2531
Download: ML102810306 (17)

Text

Entergy Entergy Operations, Inc.

P. 0. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel. (601) 437-6684 Attachment I contains PROPRIETARY information.

GNRO-2010/00064 September 29, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. Entergy Operations, Inc. letter to the NRC (GNRO-2009/00054),

License Amendment Request - Power Range Neutron Monitoring System Upgrade, November 3, 2009 (ADAMS Accession No. ML093140463)

2. NRC letter to Entergy Operations, Inc. (GNRI-2010/00067),

Request for Additional Information Re: Power Range Neutron Monitoring System, May 4, 2010 (ADAMS Accession No. ML101190125)

3. Entergy Operations, Inc. letter to the NRC (GNRO-2010/00040),

Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System, June 3, 2010 (ADAMS Accession No. ML101790436)

Dear Sir or Madam:

In Reference 1, Entergy Operations, Inc. (Entergy) submitted to the NRC a license amendment request (LAR), which proposes to revise the Grand Gulf Nuclear Station (GGNS)

Technical Specifications to reflect installation of the digital General Electric-Hitachi (GEH)

Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring System.

In Reference 2, the NRC staff transmitted to Entergy requests for additional information (RAIs) needed to support their review and approval of the LAR. Entergy submitted responses When Attachment I is removed from this letter, the entire document is NON-PROPRIETARY. Auoý OLL

GNRO-2010/00064 Page 2 of 3 to several of the RAls via Reference 3; however, failure rate data for the PRNM System specific to the GE BWR/6 design, as requested in RAI No.. 8, was not provided at that time.

Entergy committed to provide this information on or before. September 30, 2010. A revised response to RAI No.8, which includes the failure rate data, is. provided in Attachment I.

GEH considers certain information contained in Attachment 1 to be proprietary and, therefore, requests it be withheld from public disclosure in accordance-with 10 CFR 2.390. GEH', as the owner of the proprietary information, has executed the affidavit contained in Attachment 2.

This affidavit identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from ,public disclosure. The proprietary information was provided to Entergy in a GEH transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in such that the, affidavit remains applicable. GEH hereby. requests that the' attached proprietary information be withheld from public disclosure in accordance With the provisions of 10 CFR 2.390 and 9,17. Attachment 3 provides a non-proprietary version of .

The No Significance Hazards Determination and the Environmental Consideration provided. in Reference 1 are not impacted by this information.

This letter contains no new commitments.

If you have any questions or require additional information, please contact Mr., Guy Davant at (601) 368-5756.

I declare under penalty of perjury that the fOregoing is true and correct; executed on September 29, 2010.

Sincerely, MAK/ghd Attachments: 1. Response to RAI No. 8 (Proprietary Version)

2. Affidavit Supporting- Request to Withhoid Information from Public Disclosure

3. Response to RAI No. 8 (Non-Proprietary. Version),

GNRO-2010/00064 Page 3 of 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission ATTN: Mr. C. F. Lyon, NRR/DORL Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

ATTACHMENT 2 GNRO-2010/00064 AFFIDAVIT SUPPORTING REQUEST TO WITHHOLD INFORMATION FROM PUBLIC DISCLOSURE PROVIDED BY GE-HITACHI NUCLEAR ENERGY AMERICAS, LLC 3901 CASTLE HAYNE ROAD WILMINGTON, NC 28401

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, James F. Harrison, state as follows:

(1) I am the Vice President, Fuel Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH). I 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, GG-PRNM-168777-ECO81, Edward Cooper (GEH) to Jon Langberg (Entergy), "GEH Response to Request for Additional Information #8," dated September 28, 2010. The GEH proprietary information in Enclosure 1, which is entitled "Response to Request for Additional Information #8," is enclosed by double square brackets. ((Th..isentence is an

.e...mp.le. ]. Figures containing GEH proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation 131 refers to Paragraph (3) of this affidavit that 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 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC 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 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC 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 GEH and/or 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, that may include potential products of GEH.

d. Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.

GG-PRNM-168777-ECO81, 9/28/2010 Affidavit Page I of 3

(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to the 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 and/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. Access to such documents within GEH is limited to a "need to know" basis.

(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 and/or confidentiality agreements.

(8) The information identified in paragraph (2) above is classified as proprietary because it contains details regarding the Nuclear Measurement Analysis and Control Power Range Neutron (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function. Development of the NUMAC PRNM, and information related to the design, modification, analyses methodologies and processes related to the NUMAC PRNM was achieved at a significant cost to GEH. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes 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.

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 GG-PRNM- 168777-ECO81, 9/28/2010 Affidavit Page 2 of 3

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 affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 2 8 th day of September 2010.

r James F. Harrison Vice President, Fuel Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC GG-PRNM- 168777-ECO81, 9/28/2010 Affidavit Page 3 of 3

ATTACHMENT 3 GNRO-2010/00064 REVISED RESPONSE TO RAI No. 8 (NON-PROPRIETARY VERSION)

This is a non-proprietary version from which the proprietary information has been removed.

Portions of the attachment that have been removed are indicated by an open and closed bracket set as shown here: (( I to GNRO-2010/00064 Page 1 of 9 REVISED RESPONSE TO RAI No. 8 NRC RAI No. 8 Please identify how the failure rate data for the identified hardware items, as provided in NEDC-3241 OP-A Table F.2, is affected by the Grand Gulf Nuclear Station (GGNS) BWR/6 equipment configuration.

Response

to GNRO-2010/00064 Page 2 of 9

((

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to GNRO-2010/00064 Page 3 of 9

References:

1. Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function Licensing Topical Report, NEDC-3241 OP-A Supplement 1, dated November 1997.

2. NRC letter (GNRI-2010100067) to Grand Gulf Nuclear Station dated May 4 2010, "Grand Gulf Nuclear Station, Unit 1 - Request for Additional Information RE: Power Range Neutron Monitoring System," including attachments.

to GNRO-2010/00064 Page 4 of 9 Table F.1 Equipment Required for Each Main Function (per channel)

Table F.1 Notes:

((I to GNRO-2010/00064 Page 5 of 9 to GNRO-2010/00064 Page 6 of 9 Table F.2 Failure Rate Data for the GGNS PRNM Hardware to GNRO-2010/00064 Page 7 of 9 Table F.2 Notes:

1. Typical maximum quantities of modules used in the chassis or assembly are shown for information.

2. MTBF from field data is included where there has been sufficient field experience. In some cases (marked with "v"), this is vendor-supplied data. In other cases, the field experience is with a similar module (marked with an "s").

3. Mil-217 calculations use either Mil-Hdbk-217F (current calculations) or Mil-Hdbk-217D, for continuous operation at 40°C.

))

to GNRO-2010/00064 Page 8 of 9 Table 1 Failure Rate Data for the GGNS PCI Hardware I-I I 1L1 II 4

__________ 1.

4-I

• 1>

4 41 + 4- I 4 II + 4- I 4 II I- 4-

• 4 II V 4. 1 4 41 4 4- I 4 II 4- 4-

• 4 Table 1 Notes:

I_

1. Typical maximum quantities of modules used in the chassis or assembly are shown for information.

2. MTBF from field data is included where there has been sufficient field experience. In some cases (marked with "v"), this is vendor-supplied data. In other cases, the field experience is with a similar module (marked with an "s").

3. Mil-217 calculations use either Mil-Hdbk-217F (current calculations) or Mil-Hdbk-217D, for continuous operation at 40 0 C.

4. ((

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