ML19196A109
| ML19196A109 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 07/09/2019 |
| From: | Gerald Bichof Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19196A124 | List: |
| References | |
| 19-083 | |
| Download: ML19196A109 (9) | |
Text
PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 9, 2019 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Serial No.:
NRA/GDM:
Docket Nos.:
10 CFR 50.90 19-083 License Nos.:
R1 50-338/339 50-280/281 NPF-4/7 DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUESTS ADDITION OF ANALYTICAL METHODOLOGY TO THE CORE OPERATING LIMITS
- REPORT FOR A SMALL BREAK LOSS OF COOLANT ACCIDENT (SBLOCA)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION AND ANALYSIS ERROR CORRECTION By letters dated July 12, 2018 and July 31, 2018 [Agencywide Document Access and Management System (ADAMS) Accession Nos. ML18198A118 and ML18218A170, respectively], Virginia Electric and Power Company (Dominion Energy Virginia) submitted license amendment requests (LARs) to revise the Technical Specifications
- (TS) for North Anna and Surry Power Stations (NAPS and SPS) Units 1 arid 2, respectively, to allow each station to implement a fuel vendor-independent evaluation model for analyzing hypothetical small break loss-of-coolant accidents.
As part of its review of the LARs, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an audit at the Dominion Energy Virginia corporate offices in Glen Allen, Virginia, from October 1-4, 2018.
During the course of the audit, the NRC staff presented Dominion Energy Virginia staff with a detailed list of issues requiring further
- information. An audit summary report was issued on October 25, 2018.
The NRC staff completed its initial review of the LARs and of information provided during the audit and has determined that additional information is needed to complete its evaluation. The NRC request for additional information (RAI) and Dominion Energy Virginia's response to the RAI are provided in Attachment 1. In addition, subsequent to the submittal of the NAPS and SPS LARs, an error was identified in Framatome Reports ANP-3467P and ANP-3676P for NAPS and SPS, respectively. A description of
- the error correction is also provided in Attachment 1 immediately following the RAI responses. contains information proprietary to Framatome and is therefore supported by an affidavit signed by the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separati.on from Attachment 1, this page is decontrolled.
Serial No.19-083 Docket Nos.: 50-338/339/280/281 Page 2 of 4 10 CFR 2.390. Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. A redacted, non-proprietary version of the information is provided in Attachment 2.
The affidavit is provided in Attachment 5.
The response to NRC RAI No. 1 required a minor change to the proposed TS pages for the NAPS and SPS TS. The revised marked-up and typed TS pages for NAPS and SPS are provided in* Attachments 3 and 4, respectively. The additional change is indicated by double revision bars in the right hand margin of the typed TS pages provided in Attachment 4.
The information provided in this letter does not affect the conclusions of the significant hazards considerations or the environmental assessments included in the July 12, 2018 and July 31, 2018 LARs.
If there are any questions or if additional information is needed, please contact Mr. Gary D. Miller at (804) 273-2771.
Sincerely, Senior Vice President - Nuclear Operations and Fleet Performance Commitments made in this letter: None COMMONWEAL TH OF VIRGINIA
)
)
COUNTY OF HENRICO
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The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Senior Vice President - Nuclear Operations and Fleet Performance of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this 1-<<, day of bl.(~,
2019.
My Commission Expires: 'Jrlllt1.0b 2>1,21J22 DIANE E. AITKEN NOTARY PUBLIC REG. #7763114 COMMONWEAL TH OF VIRGINIA MV COMMISSION EXPIRES MARCH 31, 2022
~t~
Notary Public
Attachments:
Serial No.19-083 Docket Nos.: 50-338/339/280/281 Page 3 of 4
- 1. Response to NRC Request for Additional Information and Correction of SBLOCA Analysis Error (Proprietary)
- 2. Response To NRC Request for Additional Information and Correction of SBLOCA Analysis Error (Non-proprietary)
cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station Ms. Karen R. Cotton Gross NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. G. Edward Miller NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Marcus Harris Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Blvd.
Gten Allen, Virginia 23060 State Health Commissioner Virginia Department of Health James Madison Building - ih Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Serial No.19-083 Docket Nos.: 50-338/339/280/281 Page 4 of 4
PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390 Serial No.19-083 Docket Nos. 50-338/339/280/281 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION AND CORRECTION OF SBLOCA ANALYSIS ERROR (PROPRIETARY)
Virginia Electric and Power Company (Dominion Energy Virginia)
North Anna and Surry Power Stations Units 1 and 2 contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation from Attachment 1, this page is decontrolled.
Serial No.19-083 Docket Nos. 50-338/339/280/281 FRAMATOME AFFIDAVIT FOR WITHHOLDING PROPRIETARY INFORMATION Virginia Electric and Power Company (Dominion Energy Virginia)
North Anna and Surry Power Stations Units 1 and 2
AFFIDAVIT COMMONWEAL TH OF VIRGINIA
)
) ss.
CITY OF LYNCHBURG
)
- 1.
My name is Nathan E. Hottle. I am Manager, Product Licensing, *for Framatome Inc. (Framatome) 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 following document: Virginia Electric and Power Company Letter Number 19-083, "North Anna and Surry Power Stations Units 1 and 2 Proposed License Amendment Requests - Addition of Analytical Methodology to the Core Operating Limits Report for a Small Break Loss of Coolant Accident (SBLOCA) Response to Request for Additional Information and Error Correction" 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 Inc. 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 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 ~se 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 this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c} and 6(d) above.
- 7.
In accordance with Framatome's policies governing the protection and control of information, proprietary information contained in this Document has 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 rJ5 day of c:, )UJJ&
I 2019.
Heidi Hamilton Elder NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 12/31/2022 Reg. # 7777873