PLA-6203, Proposed License Amendment Extended Power Uprate Application Containment and Ventilation Technical Review Request for Additional Information Responses, PLA-6203

Proposed License Amendment Extended Power Uprate Application Containment and Ventilation Technical Review Request for Additional Information Responses, PLA-6203

ML071700096
Person / Time
Site:	Susquehanna
Issue date:	06/04/2007
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6203
Download: ML071700096 (6)

Text

Brltt T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 pp Tel. 570.542.3149 Fax 570.542.1504 042007 btmckinney@pplweb.com 1

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP 1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED LICENSE AMENDMENT NO. 285 FOR UNIT 1 OPERATING LICENSE NO. NPF-14 AND PROPOSED LICENSE AMENDMENT NO. 253 FOR UNIT 2 OPERATING LICENSE NO. NPF-22 EXTENDED POWER UPRATE APPLICATION RE:

CONTAINMENT AND VENTILATION TECHNICAL REVIEW REQUEST FOR ADDITIONAL INFORMATION RESPONSES Docket Nos. 50-387 PLA-6203 and 50-388 References. 1) PPL Letter PLA-6076, B. T McKinney (PPL)to USNRC, "ProposedLicense Amendment Numbers 285for Unit ] Operating License No. NPF-14 and 253 for Unit 2 OperatingLicense No. NPF-22 Constant PressurePower Uprate,"dated October 11, 2006.

2) Letter, R. V. Guzman (NRC) to B. T McKinney (PPL),

"Requestfor Additional Information (RAI) -

Susquehanna Steam ElectricStation, Units 1 and 2 (SSES 1 and 2) -

Extended Power Uprate Application Re. Containment and Ventilation Technical Review (TA C Nos. MD3309 and MD3310), " datedApril 27, 2007.

3) Letter, R. V. Guzman (NRC) to B. L. Shriver (PPL),

"SusquehannaSteam Electric Station Unit 1 & 2 Generic Letter 96-06 Assurance of Equipment Operability& Containment Integrity DuringDesign Basis Accidents (TAC NOS. MB96875 and MB96876), "August 12, 2003.

Pursuant to 10 CFR 50.90, PPL Susquehanna LLC (PPL) requested in Reference 1 approval of amendments to the Susquehanna Steam Electric Station (SSES) Unit 1 and Unit 2 Operating Licenses (OLs) and Technical Specifications (TS) to increase the maximum power level authorized from 3489 Megawatts Thermal (MWt) to 3952 MWt, an approximate 13% increase in thermal power. The proposed Constant Pressure Power Uprate (CPPU) represents an increase of approximately 20% above the Original Licensed Thermal Power (OLTP).

The purpose of this letter is to provide responses to the "Request for Additional Information" transmitted to PPL in Reference 2. A01i wa~x -s-I

Document Control Desk PLA-6203 The Attachments contain the PPL responses.

The PPL responses in Attachment 1 contain information that General Electric Company considers proprietary. General Electric Company requests that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390 (a) 4 and 9.17 (a) 4. The Affidavit supporting this request is provided in Attachment 3.

A non-proprietary version of Attachment 1 is provided in Attachment 2.

There are no new regulatory commitments associated with this submittal.

PPL has reviewed the "No Significant Hazards Consideration" and the "Environmental Consideration" submitted with Reference 1 relative to the Enclosure. We have determined that there are no changes required to either of these documents.

If you have any questions or require additional information, please contact Mr. Michael H. Crowthers at (610) 774-7766.

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

Executed on: -e- q 9 4d7

.M B . TM : Proprietary Version of the Request for Additional Information Responses : Non-Proprietary Version of the Request for Additional Information Responses : General Electric Company Affidavit Copy: NRC Region I Mr. A. J. Blarney, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Sr. Project Manager Mr. R. R. Janati, DEP/BRP

Attachment 3 to PLA-6203..

General Electric Company Affidavit

General Electric Company AFFIDAVIT I, Bradley J. Erbes, state as follows:

(1) I am Manager Services Engineering, General Electric Company ("GE") 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 the GE-SSES-AEP-322, Larry King (GE) to Mike Gorski (PPL), GE Responses to BWR Systems RAIs 10, 12, 14, 33 and 40; Mechanical and Civil RAIs 1, 3, 7, 12, 20 and 21; Containment and Venting RAIs 1; 3,5, 9 and 14, GE Proprietary Information, dated May 21, 2007. The Enclosure 1 (GE Responses to BWR Systems RAIs 10, 12, 14, 33 and 40; Mechanical and Civil RAIs 1, 3, 7, 12, 20 and 21; Containment and Venting RAIs 1, 3, 5, 9 and 14) proprietary information is delineated by a dotted underline inside double square 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, GE 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 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, 704F2d1280 (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 General Electric's competitors without license from General Electric 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;*

BJS-07-05-af GE-SSES-AEP-322 EPU RAls 5-18-07.doc Affidavit Page I

c. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric;

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

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 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The infor*mation is of a sort customarily held in confidence by GE, and is in fact so held. Thý information sought. to be withheld has, to the best of my knowledge and belief, con'istently been held in confidence by. GE,.

no public disclosure has been made, and it is not available in public, sources. All disclosures to third parties including any iequired 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. ,'Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(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. Access to such documents within GE 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 GE 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), above, is classified as proprietary because it contains detailed results and conclusions from evaluations,. utlizing analytical models and methods, including computer codes, which GE has developed, obtained NRC approval of, and applied to perform evaluations of transient and accident events in the GE Boiling Water Reactor ("BWR"). The development and approval of these system, component, and thermal hydraulic modes and computer codes. were achieved at a significant cost to GE, on the order of several million dollars.

BJS-07-05-af GE-SSES-AEP-322 EPU RAIs 5-18-07.doc Affidavit Page 2

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE'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 inrludes the value derived from providing analyses done with NRC-approved methodsJ The research, development, engineering, aipalytical and NRC review costs comprise a substantial investment of time and money:by GE.

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.

GE's competitive advantage will be lost if its competitors are able to use the results of the GE 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 GE 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 GE of.the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing 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 ___"_ day of May 2007 Bradley J. Erbes General Electric Company BJS-07-05-af GE-SSES-AEP-322 EPU RAIs 5-18-07.doc Affidavit Page 3