ML041620508
| ML041620508 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/03/2004 |
| From: | Dacimo F Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-04-069 | |
| Download: ML041620508 (14) | |
Text
Entergy Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway. GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Fred Dacimo Site Vice President Administration June 3, 2004 Re:
Indian Point Unit No. 3 Docket No. 50-286 NL-04-069 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Proposed Changes to Technical Specifications:
Stretch Power Uprate (4.85%) and Adoption of TSTF-339
References:
- 1. Technical Specification Task Force Traveler TSTF-339, Rev 2; "Relocate Technical Specification Parameters to the COLR", dated June 13, 2000.
- 2. NRC Regulatory Issue Summary (RIS) 2002-03, "Guidance on the Content of Measurement Uncertainty Recapture Power Uprate Applications", dated January 31, 2002.
- 3. Westinghouse WCAP -10263, 'A Review Plan for Uprating the Licensed Power of a Pressurized Water Reactor Power Plant,"
dated January 1993.
- 4. NRC Review Standard (RS)-001, "Draft Review Standard for Extended Power Uprates".
- 5. Entergy letter to NRC, NL-04-068, "Proposed Changes to Technical Specifications Regarding Adoption of Alternate Source Term", dated June 2, 2004
Dear Sir:
Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc, (Entergy) hereby requests an amendment to the Operating License for Indian Point Nuclear Generating Unit No. 3 (IP3), to increase the maximum authorized reactor core power level from 3067.4 MWt to 3216 MWt.
The proposed nominal increase of 4.85% in rated thermal power is based on analyses contained in Attachment IlIl (WCAP-16212-P). Six copies of the proprietary version and two copies of the nonproprietary version of the WCAP are being provided.
NL-04-069 Docket No. 50-286 Page 2 of 3 This amendment request also proposes to adopt TSTF-339 (Reference 1) regarding relocation of certain cycle-specific parameters from the Technical Specifications to the Core Operating Limits Report. The values for some of these parameters are changing as a result of the proposed power increase. The methodology used and the resulting new parameter values are described in Attachment ll. In addition, Entergy is proposing changes to several Reactor Protection System and Engineered Safeguards Features System allowable values that are not affected by the proposed power increase. These allowable value changes are described in Attachment I.
The proposed changes regarding a power increase, adoption of TSTF-339, and several allowable values, have been evaluated in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92 (c) and Entergy has determined that this proposed change involves no significant hazards considerations (Attachment I). The proposed change to the Facility Operating License and changes to the current Technical Specification and Bases pages are provided in Attachment II.
In accordance with 10CFR50.91, a copy of this application and the associated attachments are being submitted to the designated New York State official.
The evaluation of the proposed increase in rated thermal power has been performed following the guidance of References 2 and 3. Although Reference 4 addresses power uprate requests greater than that being requested for IP3, Entergy has reviewed the guidance of Reference 4 to identify additional information that is being provided in selected areas to support NRC evaluation and approval of this request. Safety analyses that assess hypothetical accident dose consequences at the proposed higher power level use the alternate source term (AST) methodology in accordance with 10 CFR 50.67. Therefore, NRC approval of Entergy's proposed adoption of AST (Reference
- 5) is required to support the proposed power increase.
Also provided, as Enclosure A, is Westinghouse authorization letter dated June 1, 2004 (CAW 1841), with the accompanying affidavit, Proprietary Information Notice, and Copyright Notice. As Attachment IlIl contains information proprietary to Westinghouse Electric Company, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information that is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commission's regulations. The non-proprietary version of the WCAP is provided as Enclosure B.
Correspondence with respect to the copyright on proprietary aspects of the items listed above or the supporting affidavit should reference CAW-04-1841 and should be addressed to J. A.
Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P. 0. Box 355, Pittsburgh, Pennsylvania 15230-0355.
Entergy requests approval of the proposed amendment by March 2005 to support implementation activities and operation at the new power level following completion of the 3R13 Spring 2005
NL-04-069 Docket No. 50-286 Page 3 of 3 refueling outage. There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. Kevin Kingsley at 914-734-6695.
I declare under penalty of perjury that the foregoing is true and correct. Executed on
- Reely, Fred R. Dacimo Site Vice President Indian Point Energy Center Attachments:
I. Analysis of Proposed Technical Specification Changes II. Proposed Technical Specification and Bases Changes (markup)
Ill. Indian Point Nuclear Generating Unit No. 3 Stretch Power Uprate NSSS and BOP Licensing Report, WCAP-16212-P, dated June 1, 2004 cc:
Mr. Patrick D. Milano, Senior Project Manager Project Directorate I, Division of Reactor Projects I/li U.S. Nuclear Regulatory Commission Mail Stop 0 8 C2 Washington, DC 20555 Mr. Hubert J. Miller (w/o prop. end)
Regional Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector's Office (w/o prop. end)
Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511 Mr. Peter R. Smith (w/o prop. end)
President, NYSERDA 17 Columbia Circle Albany, NY 12203 Mr. Paul Eddy (w/o prop. end)
New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223
e Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Direct tel:
Direct fax:
e-mail:
(412) 3744643 (412) 3744011 gresliaja@vestingliouse.com Ourref: CAW-04-1841 June 1, 2004 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-16212-P, "Indian Point Nuclear Generating Unit No. 3 Stretch Power Uprate NSSS and BOP Licensing Report" (Proprietary')
The proprietary information for which withholding is being requested in the above-referenced report is filrther identified in Affidavit CAW-04-1841 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. TIle affidavit, which accompanies this letter, sets forth the basis on wvhich the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Entergy Nuclear Operations.
Correspondence wvith respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-04-184 1, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
Very truly yours,
- 07.
A. Gresham, Manager Regulatory' Compliance and Plant Licensing Enclosures cc:
W. Macon E. Peyton A BNFL Group company
CAW-04-1841 bcc:
J. A. Gresham (ECE 4-7A) IL R. Bastien, IL, IA (Nivelles, Belgium)
C. Brinkman, I L, IA (Westinghouse Electric Co., 12300 Twinbrook Parklvay, Suite 330, Rockville, MD 20852)
RCPL Administrative Aide (ECE 4-7A) IL, IA (letter and affidavit only)
S. Ira (WM F2D7) IL, IA R. Laubham (ECE 419F) IL, IA T. Timmons (ECE 406F) IL, IA T. Gerlowski (ECE 413C) IL, IA J. Stukus (ECE 419G) IL, IA D. Morris (ENN) IL, IA C. Jackson (ENN IL, IA K. Kingsley (ENN) IL, IA W. Wittich (ENN) IL, IA J. Curry (ENN) IL, IA J. Jawor (ENN) IL, IA A BNFL Group company
Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 BroadwaN Buchanan, NY 10511-0249 Attn: Mr. David Morris Direct tel:
Direct fax:
e-mail:
(412) 374-2347 (412) 374-4011 stukusjr@a cstingbouse.con Your Ref. Entergy Purchase Order 4500521762 Our Ref INT-04-149 PU3-W-04-12 I1 June 1, 2004 Entergy Nuclear Northeast Indian Point Nuclear Generating Unit No. 3 Transmittal of Stretch Power Uprate NSSS and BOP Licensing Report
Dear Mr. Morris:
This letter transmits 6 copies of proprietary (WCAP-16212-P) and 6 copies of nonproprietary (NNWCAP-16212-NP) versions of Indian Point Nuclear Generating Unit No. 3 Stretch Power Uprate NSSS and BOP Licensing Report," dated June 2004, for %'our submittal to the NRC for review and approval, and to other New York state agencies.
In addition to the proprietary and nonproprietary WCAPs, there are four other enclosures for your use:
- 1.
Information which should be included in your NRC transmittal letter.
- 2.
Proprietary Information Notice to be attached to your NRC transmittal letter.
- 3.
Copyright Notice to be attached to y'our NRC transmittal letter.
- 4.
Westinghouse letter, "Application for Withholding Proprietary Information from Public Disclosure" (CAW-04-1841) with Affidavit CAW-04-1841.
Please transmit the original of Item 4 to the NRC in your transmittal.
If you have any questions, please do not hesitate to contact us.
Very tly y ours dian Point Unit No. 3 Stretch Power Uprate Licensing Project Manager Enclosures A BNFL Group company
CAW-04-1 841 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared J. A. Gresham, wvho, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit arc truc and correct to the best of his knowvledge, information, and belief:
J. A. Gresham, Manager Regulator) Compliance and Plant Licensing Swvorn to and subscribed before me this
/
day of
.2004 Notary Public Notarial Seal Patricia L Crown, Notary Public Monroeville Boro, Allegheny County My Conmnssion Expires Feb. 7, 2005 M, rlrPennsytvanilaAssociat onot N)tnrip-
2 CAW.-04-1841 (1)
I am Manager, Regulatory Compliancc and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically, delegated the function of rcviewing the proprietary information sought to be withhield from public disclosure in connection xvith nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding oln behalf of Westinghouse.
(2) 1 am making this Affidavit in conformance vith the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with tile Westinghouse 'Application for Withholding" accompanying this Affidavit.
(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4)
Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be wvithheld from public disclosure should be vithlileld.
(i)
The inforniation sought to be vithheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii)
Thc information is of a type customnarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a sy stem to determine wvhen and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a)
Thc informiation reveals the distinguishing aspects of a process (or component, stnicture, tooJ, method, etc.) wvhere prevention of its use by an), of
3 CAW-04-1841 Westinghouse's compctitors without license from Westinghouse constitutes a competitiv c economic advantage over other companies.
(b)
It consists of supporting data, including test data, relative to a process (or component. structure. tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(C)
Its use by a competitor wvould reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following:
(a)
The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, wvithiheld from disclosure to protect the \\Westinghouse competitive position.
(b)
It is information that is marketable in manly ways. The extent to wviicih such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)
Use by our competitor wvould put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
4 CAW-04-184 I (d)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component ma! be tile key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)
Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(0 The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to tile best of our knowledge and belief.
(v) Thle proprietary informiation sought to be wvithheld in this submittal is that which is appropriately marked in WCAP-16212-P. "Indian Point Nuclear Generating Unit No. 3 Stretch Power Uprate NSSS and BOP Licensing Report" (Proprietary) dated June 2004, being transmitted by the Entergy Nuclear Northeast letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted for use by Westinghouse for the Indian Point Nuclear Generating Unit No. 3 is expected to be applicable for other licensee submittals in response to certain NRC requirements for justification of Stretch Power Uprate License Amendment Request.
This information is part of that which will enable Westinghouse to:
5 CAW-04-184I (a) Provide information in support of plant power uprate licensing submittals.
(b) Provide plant specific calculations.
(c) Provide licensing documentation support for customer submittals.
Further this information has substantial commcrcial value as followvs:
(a)
Westinghouse plans to sell the usc of similar information to its customers for purposes of mecting NRC requircments for licensing documentation associated Avith powcr uprate liccnsing submittals.
(b)
Westinghouse can sell support and defense of the technology to its customers in the licensing process.
(c)
The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar calculations. evaltuations, analyses and licensing defense sen'ices for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the techlology described in part by the information is the result of applying the results of man)y years of experience in an intensive Westinghouse effort and the expenditure of a considerable sumi of money,.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent saveth not.
PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprictary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requiremcnts of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (tile information that Divas contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
COPYRIGHT NOTICE The reports transmitted herewith each bear a Wcstinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which arc necessary for its internal use in conncction with generic and plant-specific reviews and approvals as weil as the issuance, denial, amendment. transfer, renewal. modification, suspension, revocation, or violation ofa license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to tile non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy, available for public viewing in the appropriate docket files in the public document room in WVashington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by tile NRC must include the copyright notice in all instances and the proprietary notice if the original vas identified as proprietary.
Entergy Nuclear Northeast Lctter for Transmittal to the NRC Thc following paragraphs should be included in V'our letter to the NRC:
Enclosed are:
- 1. 6 copies of WCAP-16212-P, Indian Point Nuclear Generating Unit No. 3 Stretch Power Uprate NSSS and BOP Liccnsing Report" (Proprietary)
- 2.
2 copies of WCAP-16212-P, Indian Point Nuclear Gencrating Unit No.3 Stretch Power Uprate NSSS and BOP Licensing Report" (Proprietary)
Also enclosed is Westinghouse authorization letter CAW-04-184 1, accompanying affidavit, Proprietary Information Notice, and Copyright Notice.
As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis onl which the information ma! be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of Section 2.390 of the Commission's' regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-04-1841 and should be addressed to J. A. Gresham, Manager, Rcgulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Penrnsvlvania 15230-0355.