ML18075A330

Response to Request for Additional Information SNPB-RAI-2 Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865)

ML18075A330
Person / Time
Site:	Brunswick
Issue date:	03/01/2018
From:	Gideon W R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 18-0027, CAC MF8864, CAC MF8865
Download: ML18075A330 (7)

Text

March 1, 2018 W.lllifl~

~' Gide.on \,(ice President Brunswick Nuclear Plant P .o. eox 10429 ,Soutliport,.Nc 28461 .ci; g~ o:a~2:f3698 Serial: BSEP 18-0027 10 CFR 50.90 U.S. N1;1clear Regµlatory Commission ATTN: Document.Control Desk Washington, DC 20555-0001

References:

Brunswick S~earn !=lectric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 arid 50.;324 Response to Request for Additional Information SNPB-RAl-2 Regarding Request for License Amendm.el)t Regarding Core Flow Operating Range Expansion (CAC Nos. MF8864 and MF8865) 1. !-etter f~om William R, Giqeo_n (Dµke Energy) to the U.S. Nuqlear Regulatory Commission Document Control Desk, Request for License Amendment Regarding Core Flow Operating Range Expansiqn, dated September 6, 2016, ADAMS Acces~ion Number riAL16257A41 o 2. NRC E-..-nail.Capture, Brunswick Unit 1 and Unit2-Request for Additional Information Related to the MELLLA+ LAH(CACs MFBB64 and MFB865) (Nonproprietary), dated J,:muary 5, 2018, ADAMS Accession NtJrilber ML 1801 OA051 3. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Com miss.ion pqcumenJ Control 'Desi<, Respons({J to fleqµest for Aqditio11al .Jnformatioh Regarding Request for License Amendment Regarding Core Flow Operating Range {=xpansion (GAG Nos. MF8864 and MFBB65)~ dc1.ted February 5, 201 a, ADAMS Accession Number ML 1 B036A665 Ladies and Gentlemen:

By letter dated September 6, 2016 (i.e., Reference 1 ), Duke Energy Progress, LLC (Duke Energy), submitted a license amendment req1,1est (LAR) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 .. The proposed amendment revises Technical Specifications (TSs) 3.1.7; 3.3.1.1, 3.4.1, 5:6.5, adds a newTS 5;6.7,.andadds a new license condition to Appendix a of the operating license (OL), to sµpport an expansion of the core power-flow operating range (i.e., Maximum Extended Load Line. Limit Analysis Plus (MELLLA+)).

On January 5, 2018, by electronic mail (i.e., Reference 2), the NRC provided a request for additional information (RAJ) regarding the LAA. Duke Energy's response to the RAJ questions, except for NRC Question SNPB-RAl-2, was submitted by letter dated February 5, 2018 (i.e., Reference 3). As discussed vviJh and agreed to by the NRC licensing project manager, Mr. Andrew Hon, NRG Question SNPB-RAl-2 required additional time to develop a response and would be provided no later than March 1, 2018.

~i~*e?2 4B}e:r Fle9lJ!~t9ry 60,mrnissi9il . Duk!3. EnemY'l3 re,sponse tq NRC RAj_Question SNPEH~Ai-t is provJ~~d in :Fr~rn_~tpn,e*

Report . ANP;.3S55P, Revisiod q, 13runsyvick MELLL.t\+

CRPA Assesstnentwf(hpratt .Crfteria, a copy bf* wl}iph :is *p:rovided in. Enc;lqsµre.

f of this .1~.tt~r.

Frctmat!:>m~

Report ANP-~Sspp, Revi$ion .Q, provid.es

ir,fbrmat1CH'l considered proprietary tq Framaforne Jnc. (i:.e., formeriy known *as AREVA). A non-proprietary version, of Framatome Report ANP.,3655P, Revision *Q, .is provided in En<;;lois1.tre2, * * * * . . . .FramaJ9me, as o~ilefr of.the proprietary:infc:>tmation, has executed th~ affidavit proyided fn Enclosure

.3, Which identifies the informatidn as proprietary; is customarily held Jn confidence, and_ shquJq be withhElld from p1.1.b1ic c:tisc!osure.

the pr<:,prtetary inf qrro~tlori was proviQec:l t<;> Duke .Energy in a Framatome transrnitt~i

'that is referenced by the affidavit.

• No regulatory commitments are c:ohtained in :this letter, Please refer any questions regarding thi.s submittal to Mr. Lee Grzeck, Manager -Regul!;ltory Affairs. at :(91 O) 832-2487 .. I declare, under p~tialtY of perju,ry, th~tthe foregoing ls true *and corr~ct. Executed .on March 1, 2018~ * * * * * * ** * ** William H. '3ic:ieon

Enclosures:

. . :1:. Ftama:ton,e Report ANP~3655P, Revision O; Brunsl/lick MELLLA+ CRO!t Assessment*

with Dr1;1tt Critf:Jrla

(Propriet~ry lrifc;,rmaficm

.;.. Whhhoid frc;>i:n Pul:>lic Disc;h;.>$ure in Accordance With to CFR 2.390) * ** *

• 2, Frarnatofne, Rep9rt ANP-3655N.P, R~visiqi, .Q, {3f'l,mSwiqk.

M~l,,LLA+

<;RDA Assesstneiit with Draft Criteria. (Non-Proprietary)

• * * **

• 3. Framatome Affidavit Regarding*Withhbiding

'Ffama:tome Rep6rt ANP-3655P, Hevision o, BrunswiGk MELLLA+ CRDA Assessment with Pratt Crit~ria, !'.lf:lted February 22, 201 .8 U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with all enclosures):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257.

U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 84 70 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 cc (with enclosures 2 and 3): Chair -North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. W. Lee Cox, Ill, Section Chief (Electronic Copy Only) Radiation Protection Section North Carolina Department of Health and Human Services 1645 Mail Service Center Raleigh, NC 27699-1645 lee.cox@dhhs.nc.gov BSEP 18-0027 Enclosure 3 Framatome Affidavit Regarding Withholding Fram a tome Report ANP-3655P, Revision 0, Brunswick MELLLA+ CRDA Assessment with Draft Criteria, dated February 22, 2018 AFFIDAVIT STATE OF WASHINGTON ) ) ss. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.

I am Manager, Product Licensing, for Framatome Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary.

I am familiar with the policies established by Framatome to ensure the proper application of these criteria.

3. I am familiar with the Framatome information contained in the report ANP-3655P, Revision O, "Brunswick MELLLA+ CRDA Assessment with Draft Criteria," dated February 2018 and referred to herein as "Document." Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies *established by Framatome for the control and protection of proprietary and confidential information.

4. This Document contains information of a prnprietary and confidential nature and is of the type customarily held in confidence by Framatome 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 Framatome to determine whether information should be classified as proprietary: (a) The information reveals details of Framatome'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 Framatome. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability. (e) The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.

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

8. Framatome 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 d .;) day of "r.9---1 --u* 2018. Susan K. McCoy "-0 NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2020 SUSANK MCCOY NOTARY PUBLIC* WASHINGTON MY COMMISSION EXPIRES 01-14-2020