L-2011-342, St. Lucie, Unit 1 - Response to Nuclear Performance and Code Review Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request

St. Lucie, Unit 1 - Response to Nuclear Performance and Code Review Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request

ML11242A142
Person / Time
Site:	Saint Lucie
Issue date:	08/25/2011
From:	Anderson R L Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2011-342
Download: ML11242A142 (6)

Text

Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 Proprietary Information

-Withhold From Public Disclosure Under 10 CFR 2.390 FPL August 25, 2011 L-2011-342 10 CFR 50.90 10 CFR 2.390 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Re: St. Lucie Plant Unit 1 Docket No. 50-335 Renewed Facility Operating License No. DPR-67 Response to Nuclear Performance and Code Review Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request

References:

(1) R. L. Anderson (FPL) to U.S. Nuclear Regulatory Commission (L-2010-259),"License Amendment Request (LAR) for Extended Power Uprate," November 22, 2010, Accession No. ML103560419.

(2) Email from T. Orf (NRC) to C. Wasik (FPL), "St. Lucie Unit 1 EPU -draft RAIs -Nuclear Performance

& Code (SNPB)," July 26, 2011.By letter L-2010-259 dated November 22, 2010 [Reference 1], Florida Power & Light Company (FPL) requested to amend Renewed Facility Operating License No. DPR-67 and revise the St. Lucie Unit 1 Technical Specifications (TS). The proposed amendment will increase the unit's licensed core thermal power level from 2700 megawatts thermal (MWt) to 3020 MWt and revise the Renewed Facility Operating License and TS to support operation at this increased core thermal power level. This represents an approximate increase of 11.85% and is therefore considered an Extended Power Uprate (EPU).By email from the NRC Project Manager dated July 26, 2011 [Reference 2], additional information related to fuel performance was requested by the NRC staff in the Nuclear Performance and Code Branch (SNPB) to support their review of the EPU LAR. The request for additional information (RAI) identified seven questions.

The response to these RAIs is provided in Attachments 1 to this letter. Attachment 1 contains AREVA Proprietary information; Attachment 2 is the fully non-proprietary version of Attachment 1.an FPL Group company L-2011-342 Page 2 of 2 Attachment 3 contains the AREVA Proprietary Information affidavit.

The purpose of this attachment is to withhold the proprietary information contained in Attachment 1 from public disclosure.

The Affidavit signed by AREVA as the owner of the information sets forth the basis for which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4)of § 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to AREVA in Attachment 1 be withheld from public disclosure in accordance with 10 CFR 2.390.In accordance with 10 CFR 50.91 (b)(1), a copy of this letter is being forwarded to the designated State of Florida official.This submittal does not alter the significant hazards consideration or environmental assessment previously submitted by FPL letter L-2010-259

[Reference 1].This submittal contains no new commitments and no revisions to existing commitments.

Should you have any questions regarding this submittal, please contact Mr. Christopher Wasik, St. Lucie Extended Power Uprate LAR Project Manager, at 772-467-7138.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Executed on At o44 49' ;i13 Very truly urs, d .nderson c P sident St. Lucie lant Attachments (3)cc: Mr. William Passetti, Florida Department of Health St. Lucie Unit 1 Docket No. 50-335 L-2011-342 Attachment 3 ATTACHMENT 3 Response to NRC Nuclear Performance and Code Review Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request AREVA NP Application for Withholding Proprietary Information from Public Disclosure (Cover Page Plus 3 Pages)

AFFIDAVIT COMMONWEALTH OF VIRGINIA )) ss.CITY OF LYNCHBURG

)1. My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVA NP Inc. (AREVA NP) 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-3028(P), Revision 0, entitled "St. Lucie Plant Unit 1 EPU RAIs -Nuclear Performance

&Code (SNPB)," dated August 2011 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 secret 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(c) 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-A1 2011.Dorothy H. Hughes NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 07/31/14 Reg. # 7036892