ML072070305

Additional Information in Support of Request for License Amendment Regarding Linear Heat Generation Rate and Core Operating Limits Report References for Areva Np Fuel

ML072070305
Person / Time
Site:	Brunswick
Issue date:	07/18/2007
From:	Scarola J Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 07-0067, TAC MD4061, TAC MD4062, TSC-2006-06
Download: ML072070305 (17)

Text

James Scarola& Progress Energy BVrunsick Nre Pant Brunswick Nuclear Plant Progress Energy Carolinas, Inc.JUL 1- 8 2007 10 CFR 50.90 SERIAL: BSEP 07-0067 TSC-2006-06 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Additional Information in Support of Request for License Amendment Regarding Linear Heat Generation Rate and Core Operating Limits Report References for AREVA NP Fuel (NRC TAC Nos. MD4061 and MD4062)

References:

1. Letter from James Scarola to the U.S. Nuclear Regulatory Commission (Serial: BSEP 06-0129), "Request for License Amendment Regarding Linear Heat 'Generation Rate and Core Operating Limits Report References for AREVA NP Fuel," dated January 22, 2007 (ADAMS Accession Number ML070300570)

2. Letter from James Scarola to the U.S. Nuclear Regulatory Commission (Serial: BSEP 07-0053), "Additional Information in Support of Request for License Amendment Regarding Linear Heat Generation Rate and Core Operating Limits Report References for AREVA NP Fuel," dated June 21, 2007 (ADAMS Accession Number ML071840214)

Ladies and Gentlemen:

By letter dated January 22, 2007, as supplemented by letter dated June 21, 2007, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., requested a license amendment to revise the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed changes include: (1) revising TS 5.6.5, "Core Operating Limits Report (COLR)" to add AREVA NP, Inc. (AREVA) topical report references applicable to the use of ATRIUMTM-10 fuel, (2) adding a new definition and TS 3.2.3 for linear heat generation rate (LHGR)requirements, and (3) incorporating the new LHGR requirements into existing TS 3.4.1 and 3.7.6. These changes are being made to support the BSEP transition to AREVA manufactured fuel assemblies.

P.O. Boo 10429 Southport, NC 28461 Aoc(T> 910.457.3698 F> 910.457.2803 Document Control Desk BSEP 07-0067 / Page 2 On May 23, 2007, a meeting was held to review CP&L's plan and schedule for submitting additional information to support the transition to AREVAATRIUMTM-10 fuel. During this meeting, CP&L and AREVA discussed the fuel transition package being developed to document the analyses being performed to support the use of AREVA fuel for the upcoming Brunswick Unit 1 operating cycle.The initial element of the fuel transition package was submitted by CP&L on June 21, 2007, and consisted of a copy of AREVA Topical Report ANP-2637, Revision 1, Boiling Water Reactor Licensing Methodology Compendium.

The remainder of fuel transition package will consist of five reports: (1) the Thermal-Hydraulic Design Report, (2) the LOCA Break Spectrum Analysis Report, (3) the LOCA-ECCS Analysis MAPLHGR Limit Report, (4) the Fuel Cycle Design Report, and (5) the Reload Safety Analysis Report.CP&L is providing, in Enclosure 1, a copy of AREVA Report ANP-2646(P), Revision 0, Brunswick Unit 1 Thermal-Hydraulic Design Report for ATRIUMr M-1O Fuel Assemblies, dated June 2007. This report describes the thermal-hydraulic design characteristics of the ATRIUMTM-10 fuel assembly, and also addresses the thermal-hydraulic compatibility of AREVA fuel with the co-resident fuel. ANP-2646(P), Revision 0, contains information that AREVA considers to be proprietary as defined by 10 CFR 2.390. AREVA, as the owner of the proprietary information, has executed the affidavit provided in Enclosure 2, which identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.

AREVA requests that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of ANP-2646(P), Revision 0, is provided in Enclosure 3.CP&L is providing, in Enclosure 4, a copy of AREVA Report ANP-2625(P), Revision 0, Brunswick Units 1 and 2 LOCA Break Spectrum Analysis for ATRIUMArM-1O Fuel, dated June 2007. This report describes the LOCA break spectrum analyses for the plant and identifies the characteristics of the limiting break (i.e., break size, break location, single failure).

ANP-2625(P), Revision 0, contains information that AREVA considers to be proprietary as defined by 10 CFR 2.390. AREVA, as the owner of the proprietary information, has executed the affidavit provided in Enclosure 5, which identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.

AREVA requests that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of ANP-2625(P), Revision 0, is provided in Enclosure 6.CP&L is providing, in Enclosure 7, a copy of AREVA Report ANP-2624(P), Revision 0, Brunswick Units 1 and 2 LOCA-ECCS Analysis MAPLHGR Limit for ATRIUMrM-1O Fuel, dated June 2007. This report describes the analyses performed to support the exposure dependent MAPLHGR limits, and includes results that demonstrate compliance with the Document Control Desk BSEP 07-0067 / Page 3 10 CFR 50.46 peak cladding temperature and metal water reaction criteria.

ANP-2624(P), Revision 0, contains information that AREVA considers to be proprietary as defined by 10 CFR 2.390. AREVA, as the owner of the proprietary information, has executed the affidavit provided in Enclosure 8, which identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.

AREVA requests that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of ANP-2624(P), Revision 0, is provided in Enclosure 9.Preparation of the Fuel Cycle Design Report and the Reload Safety Analysis Report is continuing.

Preparation of a report describing applicability of AREVA BWR methods to extended power uprate conditions is also in progress.

CP&L anticipates submittal of these remaining reports in accordance with the schedule discussed during the May 23, 2007, meeting.No regulatory commitments are contained in this letter. Please refer any questions regarding this submittal to Mr. Randy C. Ivey, Manager -Support Services, at (910) 457-2447.I declare, under penalty of perjury, that the foregoing is true and correct. Executed on July 18, 2007.Sincerely, James Scarola Document Control Desk BSEP 07-0067 / Page 4 WRM/wrm

Enclosures:

1. AREVA Report ANP-2646(P), Revision 0, Brunswick Unit 1 Thermal-Hydraulic Design Report for ATRIUMTM-1O Fuel Assemblies, dated June 2007 (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)2. AREVA Affidavit Regarding Withholding ANP-2646(P), Revision 0, from Public Disclosure

3. AREVA Report ANP-2646(NP), Revision 0, Brunswick Unit I Thermal-Hydraulic Design Report for ATRIUMAm-I1O Fuel Assemblies, dated June 2007 4. AREVA Report ANP-2625(P), Revision 0, Brunswick Units I and 2 LOCA Break Spectrum Analysis for ATRIUMTm-1O Fuel, dated June 2007 (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)5. AREVA Affidavit Regarding Withholding ANP-2625(P), Revision 0, from Public Disclosure

6. AREVA Report ANP-2625(NP), Revision 0, Brunswick Units 1 and 2 LOCA Break Spectrum Analysis for ATRIUMrM-10 Fuel, dated June 2007 7. AREVA Report ANP-2624(P), Revision 0, Brunswick Units 1 and 2 LOCA-ECCS Analysis MAPLHGR Limit for ATRIUMTM-1O Fuel, dated June 2007 (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)8. AREVA Affidavit Regarding Withholding ANP-2624(P), Revision 0, from Public Disclosure

9. AREVA Report ANP-2624(NP), Revision 0, Brunswick Units 1 and 2 LOCA-ECCS Analysis MAPLHGR Limit for ATRIUMTM-1O Fuel, dated June 2007 Document Control Desk BSEP 07-0067 / Page 5 cc (with Enclosures 1 through 9): U. S. Nuclear Regulatory Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)ATTN: Mr. Stewart N. Bailey (Mail Stop OWFN 8B1)11555 Rockville Pike Rockville, MD 20852-2738 cc (with only Enclosures 2, 3, 5, 6, 8, and 9): Chair -North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221 BSEP 07-0067 Enclosure 2 AREVA Affidavit Regarding Withholding ANP-2646(P), Revision 0, from Public Disclosure AFFIDAVIT STATE OF WASHINGTON

)) ss.COUNTY OF BENTON )1. My name is Jerald S. Holm. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.

I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.3. I am familiar with the AREVA NP information contained in the report ANP-2646P Revision 0, Brunswick Unit I Thermal-Hydraulic Design Report forATRIUMTM-10 Fuel Assemblies, dated June 2007, and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP 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 NP 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 NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 NP.(d) The information reveals'certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(d) above.7. In accordance with AREVA NP'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 NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP 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.I L SUBSCRIBED before me this ___day of _ _ __ 2007.Susan K. McCoy NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/10/2008

'! :,..'.J BSEP 07-0067 Enclosure 5 AREVA Affidavit Regarding Withholding ANP-2625(P), Revision 0, from Public Disclosure AFFIDAVIT STATE OF WASHINGTON

)) ss.COUNTY OF BENTON )1. My name is Jerald S. Holm. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.

I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.3. I am familiar with the AREVA NP information contained in the report ANP-2625(P) Revision 0, Brunswick Units I and 2 LOCA Break Spectrum Analysis for A TRIUMTM-Io Fuel, dated June 2007, and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance.with the policies established by AREVA NP 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 NP 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 NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 NP.(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(d) above.7. In accordance with AREVA NP'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 NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP 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.A A)I &SUBSCRIBED before me this _ -_day of ,2007.Susan K. McCoy NOTARY PUBLIC, STATE OF WASHING MY COMMISSION EXPIRES: 1/10/2008 BSEP 07-0067 Enclosure 8 AREVA Affidavit Regarding Withholding ANP-2624(P), Revision 0, from Public Disclosure AFFIDAVIT STATE OF WASHINGTON

)) ss.COUNTY OF BENTON )1. My name is Jerald S. Holm. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.

I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.3. I am familiar with the AREVA NP information contained in the report ANP-2624(P) Revision 0, Brunswick Units I and 2 LOCA-ECCS Analysis MAPLHGR Limit for ATRIUMTM-IO Fuel, dated June 2007, and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in.accordance with the policies established by AREVA NP 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 NP 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 NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 NP.(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(d) above.7. In accordance with AREVA NP'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 NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP 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 ,-%-day of -. ,2007.\OTA. Susan K. McCoy , NOTARY PUBLIC, STATE OF WASHINGTON O- , MY COMMISSION EXPIRES: 1/10/2008

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