ML14036A100

Submittal of Confirmatory Evaluation for Unit 1 Cycle 20

ML14036A100
Person / Time
Site:	Brunswick
Issue date:	01/27/2014
From:	Pope A H Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 14-0007
Download: ML14036A100 (7)

Text

I Letter Enclosure Contains Proprietary Information Brunswick Nuclear Plant DUKE Withhold in Accordance with 10 CFR 2.390(a)(6)

P.O. Box 10429 ENERGY. Southport, NC 28461 January 27, 2014 Serial: BSEP 14-0007 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit No. 1 Renewed Facility Operating License No. DPR-71 Docket No. 50-325 Submittal of Confirmatory Evaluation for Unit 1 Cycle 20

References:

1. Letter from Christopher Gratton (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 and Revision to Minimum Critical Power Ratio Safety Limit (TAC Nos. ME8135 and ME8136)," dated March 1, 2013, ADAMS Accession Number ML13037A551 Ladies and Gentlemen:

On March 1, 2013 (i.e., Reference 1), the U.S. Nuclear Regulatory Commission (NRC) issued Amendment Nos. 262 and 290 to the Renewed Facility Operating Licenses for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2, respectively.

These amendments included a license condition in Appendix B, "Additional Conditions," to require Safety Limit Minimum Critical Power Ratio (SLMCPR), setpoint, and core operating limit values be evaluated with methods described in an AREVA Operability Assessment 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 a K-factor calculation issue described in AREVA Operability Assessment CR 2011-2274, Revision 1.The results of the evaluation are required to be submitted to the NRC, for review, at least 60 days prior to startup of each operating cycle. Based on planned return-to-service date of March 30, 2014, for the upcoming BSEP Unit 1 Cycle 20 refueling outage, submittal of these Unit 1 evaluation results is required by January 29, 2014.The evaluation results are documented in an AREVA report titled "Operability Assessment (CR #2013-8241)," a copy of which is provided in Enclosure

1. 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 U.S. Nuclear Regulatory Commission Page 2 of 3 disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of the Operability Assessment (CR #2013-8241) 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, Anne te H. Pope Manager -Organizational Effectiveness Brunswick Steam Electric Plant WRM/wrm

Enclosure:

1. Operability Assessment (CR #2013-8241) (Proprietary Information

-Withhold from Public Disclosure in Accordance With 10 CFR 2.390)2. AREVA Affidavit Regarding Withholding Operability Assessment (CR #2013-8241)

3. Non-Proprietary Version of Operability Assessment (CR #2013-8241)

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: Mr. Siva P. Lingam (Mail Stop OWFN 8G9A)11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 cc (with Enclosures 2 and 3): Chair -North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 BSEP 14-0007 Enclosure 2 AREVA Affidavit Regarding Withholding Operability Assessment (CR #2013-8241)

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 2013-8241, entitled, "Operability Assessment (CR #2013-8241)," 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 day of 0-9-ý , 2013, MY COMMISSION EXPIRES: 1/14/2016