GNRO-2011/00082, Supplemental Information Extended Power Uprate
| ML112690148 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/26/2011 |
| From: | Krupa M Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML112690143 | List: |
| References | |
| GNRO-2011/00082 | |
| Download: ML112690148 (15) | |
Text
When Attachment 1 is removed, the entire letter is non-proprietary.
contains Proprietary Information.
GNRO-2011/00082 September 26, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Supplemental Information Extended Power Uprate Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCES:
- 1.
License Amendment Request, Extended Power Uprate, dated September 8, 2010 (GNRO-2010/00056, Accession Number ML102660403)
- 2.
Entergy letter to the NRC, Supplemental Information, Extended Power Uprate, dated September 2, 2011 (NRC ADAMS Accession No. ML112490050)
Dear Sir or Madam:
Per teleconference on September 14, 2011 with the Nuclear Regulatory Commission (NRC),
additional information was requested regarding certain aspects of the Grand Gulf Nuclear Station, Unit 1 (GGNS) Extended Power Uprate (EPU) License Amendment Request (LAR)
(Reference 1). Attachment 1 provides additional supplemental information regarding considerations in the small break loss-of-coolant accident (SBLOCA) spectrum. Entergy previously provided information regarding the SBLOCA spectrum by letter dated September 2, 2011 (Reference 2).
GE-Hitachi Nuclear Energy Americas, LLC (GEH) considers portions of the information provided in Attachment 1 to be proprietary and therefore exempt from public disclosure pursuant to 10 CFR 2.390. An affidavit for withholding information, executed by GEH, is provided in. The proprietary information was provided to Entergy in a GEH transmittal that is referenced in the affidavit. Therefore, on behalf of GEH, Entergy requests to withhold from public disclosure in accordance with 10 CFR 2.390(b)(1). A non-proprietary version of the RAI responses is provided in Attachment 2.
Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel. (601) 437-6684
GNRO-2011/00082 Page 2 of 2 contains Proprietary Information.
When Attachment 1 is removed, the entire letter is non-proprietary.
No change is needed to the no significant hazards consideration included in the initial LAR (Reference 1) as a result of the additional information provided. There are no new commitments included in this letter.
If you have any questions or require additional information, please contact Jerry Burford at 601-368-5755.
I declare under penalty of perjury that the foregoing is true and correct. Executed on September 26, 2011.
Sincerely, MAK/FGB/dm Attachments:
- 1.
Supplemental Information - Proprietary
- 2.
Supplemental Information - Non-Proprietary
- 3.
GEH Affidavit for Withholding Information from Public Disclosure 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. A. B. Wang, NRR/DORL (w/2)
ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P. O. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
GNRO-2011/00082 Grand Gulf Nuclear Station Extended Power Uprate Supplemental Information Non-Proprietary This is a non-proprietary version of Attachment 1 from which the proprietary information has been removed. The proprietary portions that have been removed are indicated by double square brackets as shown here: (( )).
to GNRO-2011/ 00082 Page 1 of 8 Non-Proprietary Non-Proprietary Grand Gulf Nuclear Station Extended Power Uprate Supplemental Information By letter dated September 8, 2010, Entergy Operations, Inc. (Entergy) submitted a license amendment request (LAR) for an Extended Power Uprate (EPU) for Grand Gulf Nuclear Station, Unit 1 (GGNS). By teleconference on August 16, 2011, the Nuclear Performance and Code Review Branch requested additional information regarding considerations in the small break loss-of-coolant accident (SBLOCA) spectrum (see Entergy response in its letter to the NRC dated September 2, 2011 (NRC ADAMS Accession No. ML112490050)). By teleconference on September 14, 2011, additional information beyond that provided in Entergys September 2, 2011 response was requested by the Nuclear Performance and Code Review Branch.
Entergys response is provided below.
RESPONSE
In response to an additional request from the NRC, an explicit calculation of the bottom head drain line break has been performed for GGNS which demonstrates the adequacy of the methodology described in Entergys letter to the NRC dated September 2, 2011 (NRC ADAMS Accession No. ML112490050). The limiting small break (0.08 ft2) Appendix K PCT was
(( )) as reported in the GGNS EPU Safety Analysis Report (NEDC-33477P). This case is re-analyzed, removing the recirculation line breaks modeled at the recirculation outlet nozzle and jet pump nozzle elevations, modeling only a bottom head drain line flow path break at the bottom of the vessel. The resulting PCT for break of the full area of the bottom head drain line was (( )). Plots and tables appended to this response convey the details of this calculation. This result affirms the trend of the bottom head drain line to be considered a special case small break, and inherently accommodated in the small break spectrum, according to GEH ECCS-LOCA methodology.
to GNRO-2011/ 00082 Page 2 of 8 Non-Proprietary Non-Proprietary
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Figure 1: Peak Cladding Temperature - Bottom Head Drain Line Break to GNRO-2011/ 00082 Page 3 of 8 Non-Proprietary Non-Proprietary
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Figure 2: RCS Pressure - Bottom Head Drain Line Break to GNRO-2011/ 00082 Page 4 of 8 Non-Proprietary Non-Proprietary
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Figure 3: Break Mass Flow Rate - Bottom Head Drain Line Break to GNRO-2011/ 00082 Page 5 of 8 Non-Proprietary Non-Proprietary
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Figure 4: ECC Injection Mass Flow Rates - Bottom Head Drain Line Break to GNRO-2011/ 00082 Page 6 of 8 Non-Proprietary Non-Proprietary
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Figure 5: Core Two-Phase Level - Bottom Head Drain Line Break to GNRO-2011/ 00082 Page 7 of 8 Non-Proprietary Non-Proprietary
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Figure 6: Downcomer Level - Bottom Head Drain Line Break to GNRO-2011/ 00082 Page 8 of 8 Non-Proprietary Non-Proprietary Bottom Head Drain Line Break - Analysis Details Table 1: Key Input Parameters
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Table 2: Sequence of Events
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GNRO-2011/00082 Grand Gulf Nuclear Station Extended Power Uprate GEH Affidavit for Withholding Information from Public Disclosure
GE-Hitachi Nuclear Energy Americas LLC Affidavit for GEH-GGNS-AEP-489 Affidavit Page 1 of 3 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), 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, GEH-GGNS-AEP-489, Follow-up NRC Question on Bottom Head Drain Line Break, dated September 22, 2011. The GEH proprietary information in Enclosure 1, which is entitled GEH Response to NRC Question on Bottom Head Drain Line Break is identified by a dotted underline inside double square brackets. ((This sentence is an example.{3}))
Figures containing GEH proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation {3} 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 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 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;
GE-Hitachi Nuclear Energy Americas LLC Affidavit for GEH-GGNS-AEP-489 Affidavit Page 2 of 3
- d.
Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.
(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 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 detailed GEH design information of the methodology used in the design and analysis of the reactor systems for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GEH.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute a major GEH asset.
GE-Hitachi Nuclear Energy Americas LLC Affidavit for GEH-GGNS-AEP-489 Affidavit Page 3 of 3 (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 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 22nd day of September 2011.
James F. Harrison Vice President, Fuel Licensing, Regulatory Affairs GE Hitachi Nuclear Energy Americas LLC