L-MT-17-028, Submittal of Areva Cycle 29 Reload Safety Analysis Report

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Submittal of Areva Cycle 29 Reload Safety Analysis Report
ML17102B094
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 04/07/2017
From: Gardner P
Northern States Power Company, Minnesota, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17102B109 List:
References
CAC MF5002, L-MT-17-028
Download: ML17102B094 (6)


Text

ENCLOSURE 1 CONTAINS PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 2807 West County Road 75 Monticello, MN 55362 800.895.4999 xcelenergy.com April 7, 2017 L-MT-17-028 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22 AREVA Extended Flow Window- Submittal of Cycle 29 Reload Safety Analysis Report (CAC No. MF5002)

References:

1) Letter from Karen D. Fili (NSPM), to Document Control Desk (NRG),

"License Amendment Request for AREVA Extended Flow Window,"

L-MT-14-044, dated October 3, 2014 (ADAMS Accession No. ML14283A125)

2) NRG letter to Peter A. Gardner (NSPM), "Monticello Nuclear Generating Plant - Issuance of Amendment RE: Extended Flow Window (CAC NO. MF5002), dated February 23, 2017 (ADAMS Accession No. ML17054C394)
3) Letter from Peter A. Gardner (NSPM) to Document Control Desk (NRG), "License Amendment Request for AREVA Extended Flow Window, Supplement to Revise the Applicability of a Topical Report Limitation (TAC No. MF5002)," L-MT-16-049, dated September 28, 2016 (ADAMS Accession No. ML16272A328)

In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM) doing business as Xcel Energy, requested approval of an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS). The proposed change would revise MNGP TS and would approve certain analytical methods that together would support operation in the expanded

  • power-flow operating domain described as the Extended Flow Window (EFW). The purpose of the requested amendment is to transition from the General Electric - Hitachi (GEH) methodology called Maximum Extended Load Line Limit Analysis Plus (MELLLA+) to the AREVA methodology called EFW. f {) D f

~ tf-.

Document Control Desk Page 2 In Reference 2, NRC issued the amendment requested by Reference 1.

In Reference 3, NSPM stated its intention to submit the Cycle 29 Reload Safety Analysis Report (previously referred to as the "reload licensing report) in satisfaction of Limitation 12.4 of GEH licensing topical report NEDC-33006P-A. The purpose of this letter is to submit the Cycle 29 Reload Safety Analysis Report. provides AREVA Report ANP-3563P, "Monticello Reload Safety Analysis Report for Cycle 29", Revision 2. Enclosure 1 is proprietary to AREVA. Enclosure 2 provides the non-proprietary AREVA Report ANP-3563NP, Revision 2. provides the affidavit executed to support withholding Enclosure 1 from public disclosure. Enclosure 1 contains proprietary information as defined by 10 CFR 2.390. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). Accordingly, NSPM respectfully requests that the AREVA proprietary information in Enclosure 1 be withheld from public disclosure in accordance with 10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4. Correspondence with respect to the copyright or proprietary aspects of the AREVA information in Enclosure 1 or the supporting AREVA affidavit in Enclosure 3 should be addressed to Mr. Alan Meginnis, Manager- Product Licensing, AREVA Inc., 2101 Horn Rapids Road, Richland, Washington 99354.

If there are any questions or if additional information is needed, please contact Glenn Adams at 612-330-6777.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

Peter A.~~

Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (3) cc: Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC

L-MT-17-028 Enclosure 3 AREVA Affidavit 3 pages follow

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 report ANP-3563P, Revision 2 "Monticello Reload Safety Analysis Report for Cycle 29," dated March 2017 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 w.ould 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 fcir 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.

\ \

SUBSCRIBED before me this '.) I ~

day of )v\o...rs.. ~ , 2017.

SUSAN KMCCOY NOTARY PUBLIC *WASHINGTON I ~/' 1 COMMISSION EXPIRES 01-14-2020 Susan K. McCoy NOTARY PUBLIC, STATE OF WASHINGTON

""' 0 MY.COMMISSION EXPIRES: 1/14/2020