ML12348A015

Response to Request for Additional Information Re License Amendment Request for Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, Core Operating Limits Report, and Revision to Technical.

ML12348A015
Person / Time
Site:	Brunswick
Issue date:	11/29/2012
From:	Annacone M J Duke Energy Corp, AREVA NP
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 12-0133
Download: ML12348A015 (7)

Text

Letter Enclosure I Contains Proprietary Information Withhold in Accordance with 10 CFR 2.390 MichaelJ.Annacone Duke Vice President Brunswick Nuclear Plant iff E ergy.P.O.

Box 10429 Southport, NC 28461 910-457-3698 10 CFR 50.4 10 CFR 50.90 November 29, 2012 Serial: BSEP 12-0133 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325, 50-324 Response to Request for Additional Information Regarding License Amendment Request for Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," and Revision to Technical Specification 2.1.1.2 Minimum Critical Power Ratio Safety Limit

References:

1. Letter from Michael J. Annacone to the U.S. Nuclear Regulatory Commission (Serial: BSEP 12-0031), "Request for License Amendments

-Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, 'CORE OPERATING LIMITS REPORT (COLR),' and Revision to Technical Specification 2.1.1.2 Minimum Critical Power Ratio Safety Limit," dated March 6, 2012, ADAMS Accession Number ML1 2076A062 2. Letter from Michael J. Annacone to the U.S. Nuclear Regulatory Commission (Serial: BSEP 12-0098), "Response to Request for Additional Information Regarding License Amendment Request for Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, 'CORE OPERATING LIMITS REPORT (COLR),' and Revision to Technical Specification 2.1.1.2 Minimum Critical Power Ratio Safety Limit," dated August 29, 2012, ADAMS Accession Number ML12251A142 By letter dated March 6, 2012 (i.e., Reference 1), as supplemented by letter dated August 29, 2012 (i.e., Reference 2), Carolina Power & Light Company (CP&L) requested license amendments to revise the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendments:

(1) revise TS 5.6.5.b by replacing AREVA Topical Report ANF-524(P)(A), ANF Critical Power Methodology for Boiling Water Reactors with AREVA Topical Report ANP-1 0307PA, Revision 0, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors, June 2011, in the list of analytical methods that have been reviewed and approved by the NRC for determining core operating limits, (2) revise TS 2.1.1, Reactor Core SLs, by incorporating revised Safety Limit Minimum Critical Power Ratio (SLMCPR) values, and (3) revise the license condition in Appendix B, "Additional Conditions," of the operating licenses regarding an alternate method for evaluating SLMCPR values.

U.S. Nuclear Regulatory Commission Page 2 of 3 Subsequently, on October 25, 2012, by electronic mail, the NRC provided the following request regarding CP&L's August 29, 2012 (i.e., Reference 2), response to NRC questions concerning the referenced license amendment requests: A small number of predicted fuel channel fluence gradient values exceed the empirical database for the damage model that is used to predict channel bow and associated uncertainty.

The Request for Additional Information (RAI) response (RAI 3, Page 5 of Enclosure 1, August 29 letter) indicates why these values were predicted to exceed the empirical database, but did not justify the analytic treatment of these values in light of the fact that the empirical database does not bound their predicted fluence gradients, other than to indicate that these constitute a small portion of the overall analyzed population of fuel channels.

Please provide this justification.

The response to the latest NRC request is contained in AREVA Document Number 51-9150440-000, AREVA Input to Progress Energy: Follow-Up to SAFLIM3D LAR Request for Additional Information (RAI) 3 (Proprietary Version), a copy of which is provided in Enclosure 1.This AREVA document contains information considered proprietary to AREVA; therefore, an affidavit supporting withholding the report from public disclosure is provided in Enclosure 2.A non-proprietary version of the document (i.e., AREVA Document Number 51-9195058-000, AREVA Input to Progress Energy: Follow-Up to SAFLIM3D LAR Request for Additional Information (RAI) 3 (Non-Proprietary Version) is provided in Enclosure 3.This letter contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager -Regulatory Affairs, at (910) 457-2487.I declare, under penalty of perjury, that the foregoing is true and correct. Executed on November 29, 2012.Sincerely, Michael J. Annacone WRM/wrm U.S. Nuclear Regulatory Commission Page 3 of 3

Enclosures:

1.2.3.AREVA Document Number 51-9150440-000, AREVA Input to Progress Energy: Follow-Up to SAFLIM3D LAR Request for Additional Information (RAI) 3 (Proprietary Version) (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)AREVA Affidavit Regarding Withholding Information from Public Disclosure AREVA Document Number 51-9195058-000, AREVA Input to Progress Energy: Follow-Up to SAFLIM3D LAR Request for Additional Information (RAI) 3 (Non-Proprietary Version)cc (with all Enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A)11555 Rockville Pike Rockville, MD 20852-2738 cc (with Enclosures 2 and 3 only): Chair -North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. W. Lee Cox, Ill, Section Chief Radiation Protection Section North Carolina Department of Environment and Natural Resources 1645 Mail Service Center Raleigh, NC 27699-1645 BSEP 12-0133 Enclosure 2 AREVA Affidavit Regarding Withholding Information from Public Disclosure AFFIDAVIT STATE OF WASHINGTON

)) ss.COUNTY OF BENTON )1. My name is Alan B. Meginnis.

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 determin6 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 51-9150440-000, "AREVA Input to Progress Energy: Follow-Up to SAFLIM3D LAR Request for Additional Information (RAI) 3 (Proprietary Version)," dated November 2012 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), 6(d) and 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.SUBSCRIBED before me this ;L-7 day of LJf ,s,2012. Ke is,, TA!ly'4" NO Ry P U 8 LL'opgajS NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016