ML072180370

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

ML072180370
Person / Time
Site:	Brunswick
Issue date:	07/31/2007
From:	Scarola J Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 07-0075, TAC MD4061, TAC MD4062, TSC-2006-06
Download: ML072180370 (12)

Text

James Scarola SProgress Energy Vice President Brunswick Nuclear Plant Progress Energy Carolinas.

Inc.July 31, 2007 10 CFR 50.90 SERIAL: BSEP 07-0075 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)

3. Letter from Ben Waldrep to the U.S. Nuclear Regulatory Commission (Serial: BSEP 07-0067), "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 July 18, 2007 Ladies and Gentlemen:

By letter dated January 22, 2007, as supplemented by letters dated June 21, 2007, and July 18, 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 ATRIUTMTM-10 fuel, (2) adding a new definition and TS 3.2.3 for linear heat generation PO. Box 10429 Southport, NC 28461 T> 910.457.3698 F > 910.457.2803 Document Control Desk BSEP 07-0075 / Page 2 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.

During a meeting held on May 23, 2007, CP&L, AREVA, and the NRC discussed CP&L's plan and schedule for submitting additional information to support the ATRIUMTM-10 fuel transition.

Consistent with those discussions, CP&L is providing the information described below.In Enclosure 1, CP&L is providing a copy of AREVA Report ANP-2658(P), Revision 0, Brunswick Unit I Cycle 17 Fuel Cycle Design, dated July 2007. This report describes the fuel cycle design, including the core loading pattern and projected control rod patterns for operation through end-of-cycle.

The neutronic analyses have been performed to determine the power distribution and reactivity characteristics of the reactor, as well as provide the basis for cycle-specific licensing analyses.

ANP-2658(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-2658(P), Revision 0, is provided in Enclosure 3.In Enclosure 4, CP&L is providing a copy of AREVA Report ANP-2638(P), Revision 0, Applicability of AREVA NP BWR Methods to Extended Power Uprate Conditions, dated July 2007. This report describes the applicability of AREVA's analysis methods for demonstrating acceptable operation of BSEP, Units 1 and 2 at extended power uprate conditions.

ANP-2638(P), Revision 0, also 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-2638(P), Revision 0, is provided in Enclosure 6.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.

Document Control Desk BSEP 07-0075 / Page 3 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on July 31, 2007.Sincerely, WR~lwnnJames Scarola WRM/wrm

Enclosures:

1. AREVA Report ANP-2658(P), Revision 0, Brunswvick Unit 1 Cycle 17 Fuel Cycle Design, dated July 2007 (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)2. AREVA Affidavit Regarding Withholding ANP-2658(P), Revision 0, from Public Disclosure

3. AREVA Report ANP-2658(NP), Revision 0, Bninswick Unit I Cycle 17 Fuel Cycle Design, dated July 2007 4. AREVA Report ANP-2638(P), Revision 0, Applicability ofAREVA NP BWR Methods to Extended Power Uprate Conditions, dated July 2007 (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)5. AREVA Affidavit Regarding Withholding ANP-2638(P), Revision 0, from Public Disclosure

6. AREVA Report ANP-2638(NP), Revision 0, Applicability ofAREVA NP BWR Methods to Extended Power Uprate Conditions, dated July 2007 Document Control Desk BSEP 07-0075 / Page 4 cc (with Enclosures 1 through 6): 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, and 6): 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 07-0075 Enclosure 2 AREVA Affidavit Regarding Withholding ANP-2658(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-2658(P) Revision 0, Brunswick Unit I Cycle 17 Fuel Cycle Design, dated July 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(e) 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.n 6/SUBSCRIBED before me this [_____day of , 2007.Susan K. McCoy L NOTARY PUBLIC, STATE OFWASHINGTON MY COMMISSION EXPIRES: 1/10/2008 BSEP 07-0075 Enclosure 5 AREVA Affidavit Regarding Withholding ANP-2638(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. 1 am familiar with the AREVA NP information contained in the report ANP-2638P Revision 0, Applicability of AREVA NP BWR Methods to Extended Power Uprate Conditions, dated July 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(c) 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~~~SUBSCRIBED before me this ____-__day of -L A. ,2007.7 Susan K. McCoy NOTARY PUBLIC, STATE OF HINGTON MY COMMISSION EXPIRES: 1/10/2008