Text

/Quad Cities Nuclear Power Station, Units 1 and 2 - Supplemental Information in Support of Request for License Amendment Regarding Transition to Areva Fuel
	ML15251A381
Person / Time
Site:	Dresden, Quad Cities
Issue date:	09/01/2015
From:	Simpson P; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15251A394	List: ML15251A383; ML15251A384; ML15251A385; ML15251A386; ML15251A387; ML15251A406; RS-15-237, /Quad Cities Nuclear Power Station, Units 1 and 2 - Supplemental Information in Support of Request for License Amendment Regarding Transition to Areva Fuel; RS-15-237, Dresden Nuclear Power Station, Units 2 and 3/Quad Cities Nuclear Power Station, Units 1 and 2 - Supplemental Information in Support of Request for License Amendment Regarding Transition to Areva Fuel;
References
	RS-15-237
	Download: ML15251A381 (22)
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4300 Winfield Road

~Exe Lon Generation Warrenville, IL 60555 630 657 2000 Office PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 RS- 15-237 10 CFR 50.90 September 1, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Supplemental Information in Support of Request for License Amendment Regarding Transition to AREVA Fuel

References:

(1) Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U. S. NRC, "Request for License Amendment Regarding Transition to AREVA Fuel," dated February 6, 2015 (2) Email from Eva Brown (U. S. NRC) to Kenneth Nicely (Exelon Generation Company, LLC), et al, "ACTION: Dresden/Quad Cities - Proprietary Determination - Attachment 8 and 10 to February 6, 2015 Submittal,"

dated July 28, 2015 In Reference 1, Exelon generation Company, LLC (EGC) requested an amendment to Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS) Units 2 and 3, and Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS) Units 1 and 2. The proposed change supports the transition from Westinghouse SVEA-96 Optima2 (Optima2) fuel to AREVA ATRIUM 10XM fuel at DNPS and QCNPS.

In Reference 2, the NRC indicated that their review of Reference 1 identified a number of deficiencies with the proprietary markings in the AREVA proprietary reports provided as Attachments 8 and 10 to Reference 1. The NRC stated in Reference 2, that the noted Attachments 1 through 6 transmitted herewith contain Proprietary Information.

When separated from this attachment, this document is decontrolled.

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September 1, 2015 U. S. Nuclear Regulatory Commission Page 2 of 3 discrepancies are not an all-inclusive list. Therefore, based on the examples of discrepancies provided, AREVA reviewed all the proprietary documents submitted with Reference 1 and has revised the affected proprietary reports to address any deficiencies identified. EGO is supplementing Reference 1 to address the NRC identified proprietary deficiencies by providing the revised reports and affidavits with this letter.

The following attachments are included in support of this proposed change: : Applicability of AREVA Methodology (Proprietary Version) : Mechanical Design Report (Proprietary Version) : Fuel Rod Thermal-Mechanical Design Report (Proprietary Version) : Fuel Cycle Design Report (Proprietary Version) : LOCA Break Spectrum Analysis Report (Proprietary Version) : Nuclear Fuel Design Report (Proprietary Version) : AREVA Affidavits : Applicability of AREVA Methodology (Non-Proprietary Version) : Mechanical Design Report (Non-Proprietary Version) 0: Fuel Rod Thermal-Mechanical Design Report (Non-Proprietary Version) 1: Fuel Cycle Design Report (Non-Proprietary Version) 2: LOCA Break Spectrum Analysis Report (Non-Proprietary Version) 3: Nuclear Fuel Design Report (Non-Proprietary Version)

Attachments 1 through 13 to this letter supersede in full Attachments 7, 8, 10, 11, 13, 15, 16, 17, 18, 20, 21, 23, and 25 of Reference 1, respectively.

EGO has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2818.

Attachments 1 through 6 transmitted herewith contain Proprietary Information.

When separated from this attachment, this document is decontrolled.

September 1, 2015 U. S. Nuclear Regulatory Commission Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1st day of September 2015.

Respectfully, Patrick R. Simpson Manager - Licensing Attachments:

1. Applicability of AREVA Methodology (Proprietary Version)

2. Mechanical Design Report (Proprietary Version)

3. Fuel Rod Thermal-Mechanical Design Report (Proprietary Version)

4. Fuel Cycle Design Report (Proprietary Version)

5. LOCA Break Spectrum Analysis Report (Proprietary Version)

6. Nuclear Fuel Design Report (Proprietary Version)

7. AREVA Affidavits

8. Applicability of AREVA Methodology (Non-Proprietary Version)

9. Mechanical Design Report (Non-Proprietary Version)

10. Fuel Rod Thermal-Mechanical Design Report (Non-Proprietary Version)

11. Fuel Cycle Design Report (Non-Proprietary Version)

12. LOCA Break Spectrum Analysis Report (Non-Proprietary Version)

13. Nuclear Fuel Design Report (Non-Proprietary Version) cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - Dresden Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety Attachments 1 through 6 transmitted herewith contain Proprietary Information.

When separated from this attachment, this document is decontrolled.

Attachment 7 AREVA Affidavits

AFFIDAVIT STATE OF WASHINGTON )

) SS.

COUNTY OF BENTON )

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. 1am familiar with the policies established by AREVA to ensure the proper application of these criteria.

3. 1 am familiar with the AREVA information contained in the report ANP-3338P, Revision 1, "Applicability of AREVA BWR Methods to the Dresden and Quad Cities Reactors Operating at Extended Power Uprate," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by ARE VA as proprietary in accordance with the policies established by AREVA 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 ARE VA 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 to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA'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.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for ARE VA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.

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'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 only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA 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.

C mm SUBSCRIBED before me this JZ*Z..-.

day of ,/* , 2015.

Mary Anne Heilman NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 6/6/2016

AFFIDAVIT STATE OF WASHINGTON )

) ss.

COUNTY OF BENTON )

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by ARE VA to ensure the proper application of these criteria.

3. I am familiar with the AREVA information contained in the report ANP-3305P, Revision 1, "Mechanical Design Report for Quad Cities and Dresden ATRIUM I 0XM Fuel Assemblies Licensing Report," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by ARE VA 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 and not made available to the public. Based on my experience, 1am 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 to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA'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.

(a) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for ARE VA.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of ARE VA.

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'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 only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA 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 jJ* L..rIIil..

day of -a +/- , 2015.

Mary Anne Heilman NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 6/6/2016

AFFIDAVIT STATE OF WASHINGTON )

) SS.

COUNTY OF BENTON )

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.

., I am familiar with the AREVA information contained in the report ANP-3324P, Revision 1, "ATRIUM 10XM Fuel Rod Thermal-Mechanical Design for Quad Cities Unit 2 Cycle 24 Representative fuel Cycle Design," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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