ML13037A314

Submittal of Confirmatory Evaluation for Unit 2 Cycle 21

ML13037A314
Person / Time
Site:	Brunswick
Issue date:	01/29/2013
From:	Pope A Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 13-0004, TAC ME3856, TAC ME3857
Download: ML13037A314 (18)

Text

Letter Enclosure Contains Proprietary Information Duke Withhold in Accordance with 10 CFR 2.390(a)(6) 6Energy 10 CFR 50.4 JAN 29 2013 Serial: BSEP 13-0004 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Brunswick Steam Electric Plant, Unit No. 2 Docket No. 50-324 Submittal of Confirmatory Evaluation for Unit 2 Cycle 21

References:

1. Letter from Farideh E. Saba (NRC) to Michael J. Annacone (CP&L), "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendments Regarding Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5 (TAC Nos. ME3856 and ME3857)," dated April 8, 2011, ADAMS Accession Number ML111010234

2.

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 ML12076A062 On April 8, 2011 (i.e., Reference 1), the U.S. Nuclear Regulatory Commission (NRC) issued Amendment Nos. 257 and 285 to the Renewed Facility Operating Licenses for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2, respectively. These amendments revised the BSEP, Unit 1 and 2 Technical Specifications (TS) to support transition to ATRIUM 1OXM fuel and associated core design methodologies. In conjunction with issuance of these amendments, the following license condition was included in Appendix B, "Additional Conditions," of the Operating Licenses for BSEP, Units 1 and 2:

Safety Limit Minimum Critical Power Ratio (SLMCPR), setpoint, and core operating limit values determined using the ANP-10298PA, ACE/ATRIUM 1OXM Critical Power Correlation (i.e., TS 5.6.5.b.21), shall be evaluated with methods described in AREVA Operability Assessment CR 2011-2274, Revision 1 to verify the values determined using the NRC-approved method remain applicable and the core operating limits include margin sufficient to bound the effects of the K-factor calculation issue described in AREVA Operability Assessment CR 2011-2274, Revision 1. The results of the evaluation shall be documented and submitted to the NRC, for review, at least 60 days prior to startup of each operating cycle.

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U.S. Nuclear Regulatory Commission Page 2 of 3 Based on a currently scheduled startup date of April 15, 2013, for the upcoming BSEP Unit 2 Cycle 21 refueling outage, submittal of these Unit 2 evaluation results is required by February 14, 2013.

The results of the evaluation are documented in an AREVA report titled "AREVA Operability Assessment (CR #2012-8084 Revision 1)," a copy of which is provided in Enclosure 1. By Reference 2, Carolina Power & Light Company (CP&L) requested license amendments to revise the TS for BSEP, Unit Nos. 1 and 2. These amendments will replace ANF-524(P)(A) 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 methodologies in TS Section 5.6.5.b that may be used for determining core operating limits. The license amendment requests also update the license condition cited above to reflect the change in analytical methodologies. The operability assessment provided in Enclosure 1 presumes, and is dependent upon, NRC approval of the referenced license amendment request and the associated updated license condition.

This Operability Assessment report contains information that AREVA considers proprietary, as defined by 10 CFR 2.390. AREVA, as the owner of that proprietary information, has executed the affidavit provided in Enclosure 2 and stated that the identified 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 identified proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of the AREVA Operability Assessment (CR #2012-8084 Revision 1) is provided in Enclosure 3.

This document contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

Sincerely, Anqne e H. Pope Manager - Organizational Effectiveness Brunswick Steam Electric Plant WRM/wrm

Enclosure:

1. AREVA Operability Assessment (CR #2012-8084 Revision 1) (Proprietary Information

- Withhold from Public Disclosure in Accordance With 10 CFR 2.390)

2. AREVA Affidavit Regarding Withholding Operability Assessment (CR #2012-8084 Revision 1)

3. Non-Proprietary Version of AREVA Operability Assessment (CR #2012-8084 Revision 1)

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with Enclosures 1, 2, and 3):

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 ATTN: Mr. Christopher Gratton (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 cc (with Enclosures 2 and 3):

Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

BSEP 13-0004 AREVA Affidavit Regarding Withholding Operability Assessment (CR #2012-8084 Revision 1)

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 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 Operability Assessment for Condition Report 2012-8084 Revision 1, entitled, "Operability Assessment (CR

1. 2012-8084 Revision 1)," 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 1

day of

,2013.

Susan K. McCoy (h)

NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016

BSEP 13-0004 Non-Proprietary Version of AREVA Operability Assessment (CR #2012-8084 Revision 1)