LR-N07-0215, Supplement to License Amendment Request for Extended Power Uprate

Supplement to License Amendment Request for Extended Power Uprate

ML072480570
Person / Time
Site:	Hope Creek
Issue date:	08/27/2007
From:	Barnes G Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR H05-01, Rev 1, LR-N07-0215
Download: ML072480570 (7)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 OPSEG NuVclear LLC 10 CFR 50.90 LR-N07-0215 LCR H05-01, Rev. 1 August 27, 2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

Supplement to License Amendment Request for Extended Power Uprate

Reference:

1) Letter from George P. Barnes (PSEG Nuclear LLC) to USNRC, September 18, 2006

2) Letter from George P. Barnes (PSEG Nuclear LLC) to USNRC, May 10, 2007 In Reference 1, PSEG Nuclear LLC (PSEG) requested an amendment to Facility Operating License NPF-57 and the Technical Specifications (TS) for the Hope Creek Generating Station (HCGS) to increase the maximum authorized power level to 3840 megawatts thermal (MWt). Reference 1 stated that PSEG intends to implement the provisions of General Electric Company (GE) Licensing Topical Report NEDC-33173P, "Applicability of GE Methods to Expanded Operating Domains," as part of implementation of extended power uprate (EPU) at HCGS.

In Reference 2, PSEG addressed implementation of draft limitations and conditions for NEDC-33173P. Reference 2 stated that HCGS would comply with the condition requiring an adder to the cycle-specific safety limit minimum critical power ratio (SLMCPR) value for EPU operation. to this letter contains a marked up Technical Specification page incorporating the SLMCPR adder. The markup in Attachment 1 replaces the markup of the same page provided in the Reference 1 submittal. Attachment 2 provides additional information regarding the SLMCPR for EPU operation during HCGS Cycle 15. contains information proprietary to Global Nuclear Fuel (GNF). GNF 51ED7 7/99 REV.

95-2168

LR-N07-0215 LCR H05-01, Rev. 1 AUG 2 7 2007 Page 2 requests that the document be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4). An affidavit supporting this request is also contained in Attachment 2. Attachment 3 contains a non-proprietary version of the GNF document.

There are no regulatory commitments contained in this letter.

PSEG has determined that the information contained in this letter and attachments does not alter the conclusions reached in the 10CFR50.92 no significant hazards analysis previously submitted.

Should you have any.questions regarding this submittal, please contact Mr. Paul Duke at 856-339-1466.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on /12717/O7 (date)

Sincerely, George P. Barnes Site Vice President Hope Creek Generating Station Attachments (3)

1. Replacement Markup of Proposed Technical Specification Page Changes

2. GNF Hope Creek C15 SLMCPR - Proprietary Letter

3. GNF Hope Creek C15 SLMCPR - Non-Proprietary Letter cc: S. Collins, Regional Administrator - NRC Region I J. Lamb, Project Manager - Hope Creek, USNRC NRC Senior Resident Inspector - Hope Creek P. Mulligan, Manager IV, NJBNE

ATTACHMENT I Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354 Extended Power Uprate Replacement Markup of Proposed Technical Specification Page Changes TS Page 2-1

2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS 2.1 SAFETY LIMITS THERMAL POWER, Low Pressure or Low Flow 2- "i 2.1.1 THERMAL POWER shall not exceedý of RATED THERMAL POWER with the reactor vessel steam dome pressure less than 785 psig or core flow less than 10% of rated flow.

APPLICABILITY: OPERATIONAL CONDITIONS I and 2.

ACTION:

With THERMAL POWER exceeding RATED THERMAL POWER and the reactor vessel steam dome pressure less than785 psig or core flow less than 10% of rated flow, be in at least HOT SHUTDOWN within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and comply with the requirements of Specification 6.7.1.

THERMAL POWER, High Pressure and High Flow 2.1.2 With reactor steam dome pressure greater than 785 psig and core flow greater than 10% of rated flow: 0 The MINIMUM CRITICAL POWER RATIO (MCPR) shall be ŽQ or two recirculation loop operation and shall be Ž:I for single recirculation loop operation.

APPLICABILITY: OPERATIONAL COIITIONS 1 and 2.

ACTION: . 1-0 With reactor steam dome pressure greater than 785 psig and core flow greater than 10% of rated flow and the MCPR below the values for the fuel stated in LCO 2.1.2, be in at least HOT SHUTDOWN within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> andcomply with the requirements of Specification 6.7.1.

REACTOR COOLANT SYSTEM PRESSURE 2.1.3 The reactor coolant system pressure, as measured in the reactor vessel steam dome, shall not exceed 1325 psig.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3 and 4.

ACTION:

With the reactor coolant system pressure, as measured in the reactor vessel steam dome, above 1325 psig, be in at least HOT SHUTDOWN with reactor coolant system pressure less than or equal to 1325 psig within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and comply with the requirements of Specification 6.7.1.

HOPE CREEK 2--1 Aiencdment No. 158

Affidavit Affidavit I, Jens G. M. Andersen, state as follows:

(1) I am Consulting Engineer, Thermal Hydraulic Methods, Global Nuclear Fuel -

Americas, L.L.C. ("GNF-A") 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 the attachment, "GNF Additional Information Regarding the Requested Changes to the Technical Specification SLMCPR, Hope Creek (KT1) Cycle 15," dated June 15, 2007.

GNF proprietary information is indicated by enclosing it in double brackets. 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, GNF-A 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 and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information," and some portions also qualify 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, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).

(4) Some examples of categories of information which 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 GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, of potential commercial value to GNF-A;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

Affidavit The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b., above.

(5) To address the 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 GNF-A, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on 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, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A 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 agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.

The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GNF-A or its licensor.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A'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 GNF-A or its licensor.

Affidavit 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.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A 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 GNF-A 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 GNF-A 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 at Wilmington, North Carolina, this 15th day of June, 2007.

S647 Jens G. M. Andersen Global Nuclear Fuel - Americas, LLC