ML023360238
| ML023360238 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/17/2002 |
| From: | Joseph E Pollock Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:2900-03, TAC MB5498 | |
| Download: ML023360238 (9) | |
Text
Indiana Michigan Power Company 500 Circle Drive Buchanan, MI 49107 1373 INDIANA MICHIGAN POWER October 17, 2002 AEP:NRC:2900-03 10 CFR 50, Appendix K Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units I and 2 SUBMITTAL OF POWER MEASUREMENT UNCERTAINTY CALCULATION IN SUPPORT OF LICENSE AMENDMENT REQUEST FOR APPENDIX K MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE REQUEST (TAC NO. MB5498)
REFERENCES:
- 1) Letter from J. E. Pollock (I&M) to Nuclear Regulatory Commission (NRC) Document Control Desk, "License Amendment Request for Appendix K Measurement Uncertainty Recapture Power Uprate Request,"
AEP:NRC:2900, dated June 28, 2002
- 2) Letter from J. F. Stang (NRC) to A. C. Bakken III (I&M)
"Donald C. Cook Nuclear Plant, Unit 1 - Request for Additional Information Regarding License Amendment
- Request,
'Power Uprate Measurement Uncertainty Recapture,' dated June 28, 2002 (TAC NOS. MB5498),"
dated October 2, 2002
- 3) Letter from J. E. Pollock (I&M) to NRC Document Control
- Desk, "Response to Nuclear Regulatory Commission Request for additional Information Regarding License Amendment Request for Appendix K Measurement Uncertainty Recapture -
Power Uprate Request (TAC No. MB5498)," dated October 15, 2002 This letter submits a proprietary calculation in support of a proposed increase in the Donald C. Cook Nuclear Plant (CNP) Unit 1 licensed reactor core power level.
The attached calculation establishes the thermal power measurement uncertainty for the proposed 1.66 percent power uprate.
U. S. Nuclear Regulatory Commission AEP:NRC:2900-03 Page 2 By Reference 1, Indiana Michigan Power Company (I&M), the licensee for CNP Unit 1, proposed to amend Facility Operating License DPR-58, including Appendix A, Technical Specifications, to allow a 1.66-percent increase in the licensed core power to 3304 MWt.
By Reference 2, the NRC requested additional information regarding the changes proposed in Reference 1. I&M's response to the NRC's questions is provided by Reference 3. In response to Questions 3 and 25 of Reference 2, I&M committed to provide to the NRC a copy of the calculation that describes the methodology used to calculate the thermal power measurement uncertainty presented in Table I-1 of Attachment 3 to Reference 1. to this letter satisfies that commitment by providing I&M's calculation, 1-2-01-03 CALC 2, Revision 1, "Power Calorimetric Accuracy Using the Caldon Check Plus Feedwater Flow Measurement System and a Modified PPC CALM Program,"
dated September 25, 2002 (Proprietary). provides the application and affidavit for withholding Attachment 1 from public disclosure in accordance with 10 CFR 2.790.
It should be noted that the thermal power uncertainty measurement calculation provided in Attachment I to this letter is applicable to both Unit 1 and Unit 2, although Reference 1 only requested a power uprate for CNP Unit 1. I&M plans to use this calculation to justify a measurement uncertainty recapture power uprate request for Unit 2 later this year. There are no new commitments made in this submittal.
Should you have any questions, or require additional information, please contact Mr. Brian A. McIntyre, Manager of Regulatory Affairs, at (269) 697-5806.
Sincerely, J. E. Pollock Site Vice President NiH/jen
Enclosure:
Notarized Oath and Affirmation Statement Attachments:
- 1. Cook Nuclear Plant Calculation No. 1-2-01-03 CALC 2, Revision 1
- 2. Application and Affidavit for Withholding Proprietary Information from Public Disclosure in Accordance with 10 CFR 2.790 to AEP:NRC:2900-03 (b)
Enhance cost-effective plant operation by justifying future operation at an uprated power level.
- 5. Public disclosure of this information is likely to cause harm to I&M because it would allow other companies in the nuclear industry to benefit from the results of a significant analysis program without requiring commensurate expense, or allowing I&M to recoup a portion of its expenditures, or benefit from the sale of the information as described below.
The activity that is the subject of the calculation is not specific to CNP, but rather is an activity that potentially affects the nuclear plants of other utilities.
The calculation and development of the calculation methodology was funded solely by I&M.
The cost to I&M of the calculation and development of the calculation methodology was substantial.
The methodology can easily be adapted to other nuclear plants evaluating Measurement Uncertainty Recapture Power Uprates.
The subject information could only be duplicated by other companies or groups of companies at a similar expense to that incurred by I&M.
I&M may elect to recover a portion of the costs of this methodology development by making the information available to other utilities on a cost-sharing basis.
Public disclosure of the information at this time would prevent implementation of this strategy.
I, Joseph E. Pollock, being duly sworn, state that I am the person who subscribed my name to the foregoing statement, and that the matters and facts set forth in the statement are true to the best of my knowledge, information and belief.
SWORN TO AND SUBSCRIBED BEFORE ME THIS J7DAY OF O73S
,2002 Joseph E. Pollock Notary Site Vice President My commission expires:
Nntary Pub Ic, re" en rCunty, MN My Commission Expires Nov 23, 2005 Page 3
ATTACHMENT 1 to AEP:NRC:2900-03 COOK NUCLEAR PLANT CALCULATION NO. 1-2-01-03 CALC 2, REVISION 1 POWER CALORIMETRIC ACCURACY USING THE CALDON CHECK PLUS FEEDWATER FLOW MEASUREMENT SYSTEM AND A MODIFIED PPC CALM PROGRAM SEPTEMBER 25, 2002 PROPRIETARY THIS ATTACHMENT INCLUDES INFORMATION THAT IS PROPRIETARY TO INDIANA MICHIGAN POWVER COMPANY (I&M).
THIS CALCULATION SHOULD NOT BE RELEASED OUTSIDE I&M OR THE NRC WITHOUT PRIOR PERMISSION FROM I&M.
to AEP:NRC:2900-03 AFFIRMATION 1, Joseph E. Pollock, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.
Indiana Michigan Power Company J. E. Pollock Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF Oý_t0T
.,, 2002 My Commission Expires 1Z/*Z
-/
s MARGARET MARY SUNAGEL Notary Public, Berrien County, MI My Commission Expires Nov 23,2005 Page I
U. S. Nuclear Regulatory Commission AEP:NRC:2900-03 Page 3 c:
K. D. Curry - AEP Ft. Wayne, w/o attachments J. E. Dyer - NRC Region III MDEQ - DW & RPD, w/o attachments NRC Resident Inspector J. F. Stang, Jr. - NRC Washington DC R. Whale - MPSC, w/o attachments
U. S. Nuclear Regulatory Commission Page 4 bc:
Without Enclosure/Attachments G. P. Arent A. C. Bakken, III M. J. Finissi S. A. Greenlee G. J. Hill D. W. Jenkins J. A. Kobyra B. A. McIntyre J. E. Newmiller J. E. Pollock K. W. Riches M. K. Scarpello T. R. Stephens M. G. Williams T. K. Woods AEP:NRC:2900-03
ATTACHMENT 2 TO AEP:NRC:2900-03 INDIANA MICHIGAN POWER COMPANY APPLICATION AND AFFIDAVIT FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.790 Application for Withholding of Proprietary Information from Public Disclosure:
Indiana Michigan Power Company (I&M) requests that the proprietary information described below be withheld from public disclosure.
The proprietary information for which withholding is requested is contained in Attachment 1 to this I&M submittal, AEP:NRC:2900-03, dated October 17, 2002. Attachment 1 is titled, "Cook Nuclear Plant Calculation No. 1-2-01-03 CALC 2, Revision 1 - Power Calorimetric Accuracy Using the Caldon Check Plus Feedwater Flow Measurement System and a Modified PPC CALM Program."
The affidavit provided following this application sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.790 of the Commission's regulations.
Joseph E. Pollock Site Vice President to AEP:NRC:2900-03 Affidavit for Withholding of Proprietary Information from Public Disclosure:
Affidavit of Joseph E. Pollock
- 1. I am Site Vice President for Donald C. Cook Nuclear Plant (CNP), Indiana Michigan Power Company (I&M), and as such, have the responsibility of reviewing the proprietary information sought to be withheld from public disclosure in connection with I&M's submittal AEP:NRC:2900-03, dated October 17, 2002, and am authorized to apply for its withholding on behalf of I&M.
- 2. I am making this affidavit in conformance with the provisions of 10 CFR 2.790 of the regulations of the Nuclear Regulatory Commission (NRC) and in conjunction with I&M's application for withholding, which accompanies this affidavit.
- 3.
I have knowledge of the criteria used by I&M in designating information as proprietary or confidential.
- 4. Pursuant to the provisions of 10 CFR 2.790(b)(4), the following is being furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld.
(i)
The information sought to be withheld from public disclosure is owned by I&M and has been held in confidence by I&M.
(ii)
The information is of a type that would customarily be held in confidence by I&M.
The information consists of analysis methodology details, analysis results, supporting data, and aspects of system design, relative to an analysis that provides a competitive advantage to I&M.
(iii) The information is transmitted to the NRC in confidence, and under the provision of 10 CFR 2.790, it is to be received in confidence by the NRC.
(iv) The information sought to be protected is not available in public sources to the best of my knowledge and belief.
(v)
The proprietary information sought to be withheld is contained in Attachment 1 to this I&M submittal, AEP:NRC:2900-03, dated October 17, 2002. is titled, "Cook Nuclear Plant Calculation No. 1-2-01-03 CALC 2, Revision 1 -
Power Calorimetric Accuracy Using the Caldon Check Plus Feedwater Flow Measurement System and a Modified PPC CALM Program."
This information enables I&M to:
(a)
Justify a proposed license amendment with equipment and system performance, evaluation, and analysis information.
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