Text

Application to Revise Technical Specifications for Methodology Report DPC-NE-2005-P, Revision 5, Thermalhydraulic Statistical Core Design Methodology
	ML15075A211
Person / Time
Site:	Harris, Robinson
Issue date:	03/05/2015
From:	Frisco J; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15075A221	List: ML15075A212; ML15075A213; RA-15-000, Attachment 8 - DPC-NE-2005 Appendix H Robinson Plant Specific Data; RA-15-0004, Application to Revise Technical Specifications for Methodology Report DPC-NE-2005-P, Revision 5, Thermalhydraulic Statistical Core Design Methodology;
References
	RA-15-0004
	Download: ML15075A211 (32)
	v • d • e

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,DUKE Joseph Frisco, Jr.

526 South Church Street

ENERGYe ,L Charlotte, NC 28202 Mailing Address

Mail Code EC07H I P.O. Box 1006 Charlotte, NC 28201-1006 704-382-4141 PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENTS 6 AND 7 THIS LETTER IS UNCONTROLLED Serial: RA-15-0004 10 CFR 50.90 March 5, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

SUBJECT:

APPLICATION TO REVISE TECHNICAL SPECIFICATIONS FOR METHODOLOGY REPORT DPC-NE-2005-P, REVISION 5, "THERMAL HYDRAULIC STATISTICAL CORE DESIGN METHODOLOGY"

REFERENCES:

1. NRG letter, Catawba Nuclear Station, Units 1 and 2 and McGuire Nuclear Station Units 1 and 2 RE: Acceptance for Referencing of the Modified Licensing Topical Report DPC-NE-2009P, Revision 2 (TAC Nos. MB4502, MB4503, MB4504, and MB4505),

dated December 18, 2002 (ADAMS Accession No. ML023520616)

2. NRG letter, Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments Regarding Use of AREVA NP Mark-8-HTP Fuel (TAC Nos. MD7050, MD7051, and MD7052), dated October 29, 2008 (ADAMS Accession No. ML082800408)

Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Duke Energy Progress, Inc., referred to henceforth as "Duke Energy", is submitting a request for an amendment to the Technical Specifications (TS) for Shearon Harris Nuclear Power Plant, Unit 1 (SHNPP) and H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP). Specifically, Duke Energy requests NRG review and approval of DPC-NE-2005-P, "Thermal-Hydraulic Statistical Core Design Methodology," Revision 5, and adoption of the methodology into the TS for SHNPP and HBRSEP. This change will allow Duke Energy to perform the subject analysis, as opposed to utilizing contract services.

PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENTS 6 AND 7 THIS LETTER IS UNCONTROLLED

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENTS 6 AND 7 THIS LETTER IS UNCONTROLLED U.S. Nuclear Regulatory Commission RA-15-0004 Page 2 The current Duke Energy Statistical Core Design (SCD) methodology report DPC-NE-2005-P-A, "Thermal-Hydraulic Statistical Core Design Methodology," Revision 4a, contains NRC-approved appendices which currently apply the methodology to McGuire, Catawba, and Oconee nuclear stations. The most recent Appendices F and G were approved by the NRC in References 1 and 2. This proposed change extends applicability of the DPC-NE-2005-P-A methodology to SHNPP and HBRSEP. As a result, Appendices H and I are added to DPC-NE-2005-P-A for HBRSEP and SHNPP, respectively. Duke Energy and NRC staff participated in a pre-submittal meeting on November 12, 2014, regarding these changes.

The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c), and it has been determined that the proposed changes involve no significant hazards consideration. The bases for these determinations are included in . Attachment 3 provides an evaluation of the proposed change. Attachment 4 provides the existing TS pages marked up to show the proposed change. Attachment 5 provides the retyped TS pages.

Attachments 6 and 7 contain the new Appendices H and I, which include information that is proprietary to Duke Energy and AREVA NP. In accordance with 10 CFR 2.390, Duke Energy, on behalf of itself and AREVA NP, requests that Attachments 6 and 7 be withheld from public disclosure. Affidavits are included from each organization (Attachments 1 and 2) attesting to the proprietary nature of the information. Non-proprietary versions of the attachments are included in Attachments 8 and 9.

Approval of the proposed amendment is requested by December 31, 2016 in order to support the core design of SHNPP Cycle 22, which is expected to commence operation Spring 2018.

The requested approval date allows sufficient time to establish the appropriate contract services to perform the analysis, if the amendment is not approved. An implementation period of 120 days is requested to allow for updating the TS and Facility Operating License.

This submittal contains no new regulatory commitments. In accordance with 10 CFR 50.91, Duke Energy is notifying the states of North Carolina and South Carolina of this license amendment request by transmitting a copy of this letter to the designated state officials. Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Manager - Nuclear Fleet Licensing, at 980-373-2062.

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENTS 6 AND 7 THIS LETTER IS UNCONTROLLED

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENTS 6 AND 7 THIS LETTER IS UNCONTROLLED U.S. Nuclear Regulatory Commission RA-15-0004 Page 3 I declare u der penalty of perjury that the foregoing is true and correct. Executed on Sincerely, Joseph Frisco, Jr.

Vice President - Nuclear Engineering JBD/MKL Attachments: 1. Affidavit of Joseph Frisco

2. Affidavit of Gayle Elliott

3. Evaluation of the Proposed Change

4. Proposed Technical Specification Changes (Mark-Up)

5. Retyped Technical Specification Pages

6. DPC-NE-2005-P Appendix H Robinson Plant Specific Data (Proprietary)

7. DPC-NE-2005-P Appendix I Harris Plant Specific Data (Proprietary)

8. DPC-NE-2005 Appendix H Robinson Plant Specific Data (Redacted)

9. DPC-NE-2005 Appendix I Harris Plant Specific Data (Redacted) cc: USNRC Region II USNRC Senior Resident Inspector - SHNPP USNRC Senior Resident Inspector - HBRSEP M. C. Barillas, NRR Project Manager - SHNPP & HBRSEP W. L. Cox, III, Section Chief, NC DHSR (Without Attachments 6 and 7)

S. E. Jenkins, Manager, Radioactive and Infectious Waste Management Section (SC)

(Without Attachments 6 and 7)

Attorney General (SC) (Without Attachments 6 and 7)

A. Gantt, Chief, Bureau of Radiological Health (SC) (without Attachments 6 and 7)

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 UPON REMOVAL OF ATTACHMENTS 6 AND 7 THIS LETTER IS UNCONTROLLED RA- 15-0004 Attachment 1 Affidavit of Joseph Frisco

AFFIDAVIT of Joseph Michael Frisco, Jr.

1. I am Vice President of Nuclear Engineering, Duke Energy Corporation, and as such have the responsibility of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear plant licensing and am authorized to apply for its withholding on behalf of Duke Energy.

2. I am making this affidavit in conformance with the provisions of 10 CFR 2.390 of the regulations of the Nuclear Regulatory Commission (NRC) and in conjunction with Duke Energy's application for withholding which accompanies this affidavit.

3. I have knowledge of the criteria used by Duke Energy in designating information as proprietary or confidential.

4. Pursuant to the provisions of paragraph (b) (4) of 10 CFR 2.390, the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned by Duke Energy and has been held in confidence by Duke Energy and its consultants.

(ii) The information is of a type that would customarily be held in confidence by Duke Energy. The information consists of analysis methodology details, analysis results, supporting data, and aspects of development programs, relative to a method of analysis that provides a competitive.advantage to Duke Energy.

(iii) The infofmaiton was transmitted to the NRC in confidence and under the provisions of 10 CFR 2,390, it is to be received in confidence by the NRC.

(iv) The information sought to be protected is not available in public to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in the submittal is that which is marked in the proprietary versions of Appendix H (dated November 2014) and Appendix I (dated November 2014) of Duke methodology report DPC-NE-2005, Thermal-Hydraulic StatisticalCore Design Methodology. This information enables Duke Energy to:

(a) Support license amendment requests for its Shearon Harris Nuclear Power Plant (SHNPP) and H. B. Robinson Steam Electric Plant (HBRSEP).

(b) Perform transient and accident analysis calculations for SHNPP and HBRSEP.

(vi) The proprietary information sought to be withheld from public disclosure has substantial commercial value to Duke Energy.

(a) Duke Energy uses this information to reduce vendor and consultant expenses associated with supporting the operation and licensing of nuclear power plants.

Page 1 of 2

(b) The subject information could only be duplicated by competitors at similar expense to that incurred by Duke Energy.

5. Public disclosure of this information is likely to cause harm to Duke Energy because it would allow competitors in the nuclear industry to benefit from the results of a significant development program without requiring a commensurate expense or allowing Duke Energy to recoup a portion of its expenditures or benefit from the sale of the information.

Joseph Michael Frisco, Jr. affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

J eph Michael Frisco',Jr.

Subscribed and sworn to me: Offh Date Date

-aw tebab4 TPee5C Notary Public My commission expires: ý.plember( Cpj*"

(.

SEAL Page 2 of 2 RA- 15-0004 Attachment 2 Affidavits of Gayle Elliott (1 each for SHNPP and HBRSEP)

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is Gayle Elliott. I am Manager, Product Licensing, for AREVA Inc.

(AREVA) 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.

3. I am familiar with the AREVA information contained in "DPC-NE-2005-P, Duke Energy Thermal Hydraulic Statistical Core Design Methodology, Appendix H, Robinson Plant Specific Data, Advanced W 15x15 HTP Fuel, Application of HTP CHF Correlation to the Advanced W 15x1 5 HTP Fuel Design," dated November 2014 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 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 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 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 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 AREVA.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(c), 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 has 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 J day of.2fC-.Cvlbe" , 2014.

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is Gayle Elliott. I am Manager, Product Licensing, for AREVA Inc.

(AREVA) 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.

3. I am familiar with the AREVA information contained in "DPC-NE-2005-P, Duke Energy Thermal Hydraulic Statistical Core Design Methodology, Appendix I, Harris Plant Specific Data, Advanced W 17x1 7 HTP Fuel, Application of HTP CHF Correlation to the Advanced W 17x17 HTP Fuel Design," dated November 2014 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 Inc. for the control and protection of proprietary and confidential information.