ML090910265

License Amendment Request on Measurement Uncertainty Recapture Power Uprate

ML090910265
Person / Time
Site:	North Anna
Issue date:	03/26/2009
From:	Price J Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
09-033A
Download: ML090910265 (11)

Text

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 26, 2009 U.S. Nuclear Regulatory Commission Serial No. 09-033A Attention: Document Control Desk NLOS/RPC RO Washington, D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2 LICENSE AMENDMENT REQUEST MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE PROPRIETARY SUPPORTING DOCUMENTS Pursuant to 10 CFR 50.90, under separate cover (Letter Serial No.09-033 dated March 27, 2009) Dominion is requesting amendments to Operating Licenses NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. This measurement uncertainty recapture (MUR) power uprate License Amendment Request (LAR) would increase each unit's authorized core power level from 2893 megawatts thermal (MWt) to 2940 MWt, and make changes to Technical Specifications as necessary to support operation at the uprated power level. The proposed change is an increase in maximum power level (Rated Thermal Power) of 1.64% from the current reactor output.

The MUR LAR is supported by Cameron reports which are proprietary in nature and should be withheld from public disclosure in accordance with 10 CFR 2.390. Information provided in the attachments to this letter is summarized below:

• Attachment 1 provides the Cameron affidavit concerning the 10 CFR 2.390 information to be withheld from public disclosure.

• Attachment 2 provides Cameron Bounding Uncertainty Analysis Report for Unit 1 with Affidavit (Proprietary).

" Attachment 3 provides Cameron Bounding Uncertainty Analysis Report for Unit 2 with Affidavit (Proprietary).

• Attachment 4 provides Cameron Meter Factor Report for Unit 1 with Affidavit (Proprietary)

" Attachment 5 provides Camer6n Meter Factor Report for Unit 2 with Affidavit (Proprietary)

NOTE: THE ATTACHMENTS TO THIS LETTER CONTAIN "PROPRIETARY INFORMATION -

WITHHOLD UNDER 10 CFR 2.390" AND MUST BE PROTECTED ACCORDINGLY. UPON SEPARATION OF THE ATTACHMENTS, THIS LETTER IS "DECONTROLLED."

Serial No. 09-033A Docket Nos. 50-338/339 Page 2 of 3 If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.

Sincerely, A'rn$}ice SPresident - Nuclear Engineering Commitments made in this letter: None Attachments:

1. Cameron 10 CFR 2.390 Affidavit

2. Cameron Uncertainty Analysis Report Unit 1 (Proprietary)

3. Cameron Uncertainty Analysis Report Unit 2 (Proprietary)

4. Cameron Meter Factor Report Unit 1 (Proprietary)

5. Cameron Meter Factor Report Unit 2 (Proprietary)

COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. Alan Price, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 4o rday of '2009.

My Commission Expires: _

ICKI L. HULL S tary VCKIL.NHULL Notary Public Publicc 054 Notary Commonwealth of Virginia L 140542 MyCommission Expires May 31, 2010 I

Serial No. 09-033A Docket Nos. 50-338/339 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region II Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060 State Health Commissioner Virginia Department of Health James Madison Building - 7th Floor 109 Governor Street Suite 730 Richmond, Virginia 23219 NRC Senior Resident Inspector North Anna Power Station Ms. D. N. Wright NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 H4A 11555 Rockville Pike Rockville, Maryland 20852 Mr. J. F. Stang, Jr.

NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 G9A 11555 Rockville Pike Rockville, Maryland 20852

Serial No. 09-033A Docket Nos. 50-338/339 Attachment 1, Page 1 Attachment I (Serial No. 09-033A)

Cameron 10 CFR 2.390 Affidavit North Anna Power Station Units 1 & 2 Virginia Electric and Power Company (Dominion)

Measurement Systems Caldono Ultrasonics Technology Center 1000 McClaren Woods Drive Coraopolis, PA 15108 Tel 724-273-9300' CAMERON Fax 724-273-9301 www.c-a-m.com February 18, 2009 CAW 09-01 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

1. Caldon Ultrasonics Engineering Report ER-646 Rev. 2 "Bounding Uncertainty Analysis for Thermal Power Determination at North Anna Unit 1 Using the LEFM/ + System"

2. Caldon Ultrasonics Engineering Report No. 689 Rev. 2 "LEFM/ + Meter Factor Calculation and Accuracy Assessment for North Anna Unit 1"

3. Caldon Ultrasonics Engineering Report ER-637 Rev. 3 "Bounding Uncertainty Analysis for Thermal Power Determination at North Anna Unit 2 Using the LEFMI + System"

4. Caldon Ultrasonics Engineering Report No. 675 Rev. 2 "LEFMI/+ Meter Factor Calculation and Accuracy Assessment for North Anna Unit 2" Gentlemen:

This application for withholding is submitted by Cameron International Corporation, a Delaware Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, pursuant to the provisions of paragraph (b)(1) of Section 2.390 of the Commission's regulations. It contains trade secrets and/or commercial information proprietary to Cameron and customarily held in confidence.

The proprietary information for which withholding is being requested is identified in the subject submittal. In conformance with 10 CFR Section 2.390, Affidavit CAW 09-01 accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.

February 18, 2009 Page 2 Accordingly, it is respectfully requested that the subject information, which is proprietary to Cameron, be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW 09-01 and should be addressed to the undersigned.

Very truly yours, Calvin R. Hastings General Manager Enclosures (Only upon separation of the enclosed confidential material should this letter and affidavit be released.)

February 18, 2009 CAW 09-01 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Calvin R. Hastings, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Cameron International Corporation, a Delaware Corporation (herein called "Cameron")) on behalf of its operating unit, Caldon Ultrasonics Technology Center, and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

Calvin R. Hastil~s General Manager Sworn to and subscribed before me this _________day of 2009 Nqýr Public COMMONWEALTH OF PENNSYLVANIA Notadal Seal Joann B. Thomas, Notary Public Findlay Twp., Allegheny County My Commission Expires July 28, 2011 Member, Pennsvivinip Assodition of Notaries

February 18, 2009 CAW 09-01

1. I am the General Manager of Caldon Ultrasonics Technology Center, and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of Cameron.

2. I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Cameron application for withholding accompanying this Affidavit.

3. I have personal knowledge of the criteria and procedures utilized by Cameron in designating information as a trade secret, privileged or as confidential commercial or financial information.

The material and information provided herewith is so designated by Cameron, in accordance with those criteria and procedures, for the reasons set forth below.

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 withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Cameron.

(ii) The information is of a type customarily held in confidence by Cameron and not customarily disclosed to the public. Cameron has a rational basis for determining the types of information customarily held in confidence by it and, in that connection utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Cameron policy and provides the rational basis required. Furthermore, the information is submitted voluntarily and need not rely on the evaluation of any rational basis.

February 18, 2009 CAW 09-01 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 advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Cameron's competitors without license from Cameron constitutes a competitive 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 would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, and assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Cameron, its customer or suppliers.

(e) It reveals aspects of past, present or future Cameron or customer funded development plans and programs of potential customer value to Cameron.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Cameron system, which include the following:

(a) The use of such information by Cameron gives Cameron a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Cameron competitive position.

February 18, 2009 CAW 09-01 (b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Cameron ability to sell products or services involving the use of the information.

(c) Use by our competitor would put Cameron at a competitive disadvantage by reducing his expenditure of resources at our expense.

(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 may be the key to the entire puzzle, thereby depriving Cameron of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Cameron in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Cameron 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 §§ 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 manner or method to the best of our knowledge and belief (v) The proprietary information sought to be withheld are the submittals titled:

Caldon Ultrasonics Engineering Report ER-646 Rev. 2 "Bounding Uncertainty Analysis for Thermal Power Determination at North Anna Unit 1 Using the LEFM,/ + System"

February 18, 2009 CAW 09-01

• Caldono Ultrasonics Engineering Report No. 689 Rev. 2 "LEFM,/ + Meter Factor Calculation and Accuracy Assessment for North Anna Unit 1"

• Caldon Ultrasonics Engineering Report ER-637 Rev. 3 "Bounding Uncertainty Analysis for Thermal Power Determination at North Anna Unit 2 Using the LEFMI + System"

• Caldon Ultrasonics Engineering Report No. 675 Rev. 2 "LEFM,/ + Meter Factor Calculation and Accuracy Assessment for North Anna Unit 2".

It is designated therein in accordance with 10 CFR §§ 2.390(b)(1)(i)(A,B), with the reason(s) for confidential treatment noted in the submittal and further described in this affidavit. This information is voluntarily submitted for use by the NRC Staff in their review of the accuracy assessment of the proposed methodology for LEFM CheckPlus Systems used by North Anna Power Station 1 and 2 for an MUR UPRATE.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Cameron because it would enhance the ability of competitors to provide similar flow and temperature measurement systems and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the informationto meet NRC requirements for licensing documentation without the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Cameron effort and the expenditure of a considerable sum of money.

In order for competitors of Cameron to duplicate this information, similar products would have to be developed, similar technical programs would have to be performed, and a significant manpower effort, having the requisite talent and experience; would have to be expended for developing analytical methods and receiving NRC approval for those methods.

Further the deponent sayeth not.