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| number = ML16063A033
| number = ML16063A033
| issue date = 02/29/2016
| issue date = 02/29/2016
| title = Monticello Nuclear Generating Plant - License Amendment Request for Areva Extended Flow Window Supplement to Disposition Changes to Non-Limiting Transient Analyses (TAC No. MF5002)
| title = License Amendment Request for Areva Extended Flow Window Supplement to Disposition Changes to Non-Limiting Transient Analyses
| author name = Gardner P A
| author name = Gardner P A
| author affiliation = Northern States Power Co, Xcel Energy
| author affiliation = Northern States Power Co, Xcel Energy
Line 19: Line 19:


=Text=
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{{#Wiki_filter:ENCLOSURE 1 CONTAINS PROPRIETARY INFORMATIONWITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390XceI Energy°Monticello Nuclear Generating Plant2807 W County Rd 75Monticello, MN 55362February 29, 2016L-MT- 16-01010 CFR 50.90U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Monticello Nuclear Generating PlantDocket 50-263Renewed License No. DPR-22License Amendment Request for AREVA Extended Flow WindowSupplement to Disposition Chancqes to Non-Limitinq Transient Analyses(TAC No. MF5002)
{{#Wiki_filter:ENCLOSURE 1 CONTAINS PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 XceI Energy°Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 February 29, 2016 L-MT- 16-010 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22 License Amendment Request for AREVA Extended Flow Window Supplement to Disposition Chancqes to Non-Limitinq Transient Analyses (TAC No. MF5002)


==References:==
==References:==
: 1) Letter from Karen D. Fili (NSPM), to Document Control Desk (NRC),"License Amendment Request for AREVA Extended Flow Window,"L-MT-14-044, dated October 3, 2014 (ADAMS Accession No.ML14283A1 25)2) Letter from Peter A. Gardner (NSPM) to Document Control Desk(NRC), "License Amendment Request for ARE VA Extended FlowWindow Supplement to Respond to NRC Staff Questions (TAC No.MF5002)," L-MT-15-065, dated September 29, 2015 (ADAMSAccession No. ML15274A473)3) Letter from Peter A. Gardner (NSPM) to Document Control Desk(NRC), "License Amendment Request for AREVA Extended FlowWindow Supplement to Provide Revised Analysis of AnticipatedTransient Without Scram Instability (TAC No. MF5002)," L-MT-15-081,dated December 8, 2015 (ADAMS Accession No. ML15345A407)In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM)doing business as Xcel Energy, requested approval of an amendment to the MonticelloNuclear Generating Plant (MNGP) Renewed Operating License (OL) and TechnicalSpecifications (TS). The proposed change would revise the MNGP TS and wouldapprove certain analytical methods that together would support operation in theexpanded power-flow operating domain described as the Extended Flow Window(EFW). The purpose of the requested amendment is to transition from the GeneralElectric -Hitachi methodology called Maximum Extended Load Line Limit Analysis Plus(MELLLA+) to the AREVA methodology called EFW.
: 1) Letter from Karen D. Fili (NSPM), to Document Control Desk (NRC),"License Amendment Request for AREVA Extended Flow Window," L-MT-14-044, dated October 3, 2014 (ADAMS Accession No.ML14283A1 25)2) Letter from Peter A. Gardner (NSPM) to Document Control Desk (NRC), "License Amendment Request for ARE VA Extended Flow Window Supplement to Respond to NRC Staff Questions (TAC No.MF5002)," L-MT-15-065, dated September 29, 2015 (ADAMS Accession No. ML15274A473)
Document Control DeskPage 2In Reference 2, NSPM provided early identification of errors in AREVA's core depletioncode MICROBURN-B2, and the potential effect on the safety analyses under NRCreview. Subsequently, in Reference 3, NSPM described the effect of those errors onthe limitingq transient analyses; providing revised results for the Anticipated TransientWithout Scram -Instability (ATWS-I) analysis. Reference 3 stated that the effect of theMICROBURN-B2 errors on non-limitinq transient analyses would be managed under theAREVA and NSPM corrective action programs. After discussion with NRC Staff onNovember 24, 2015 and February 3, 2016, NSPM is addressing the non-limitingtransient analyses as described below.* Unmitigqated ATWS-I Analysis. While evaluating the MICROBURN-B2 errors undertheir corrective action program, AREVA identified a nominally adverse impact on the"'unmitigated" case that is described in Sections 4 and 5 of ATWS-l Report ANP-3284Revision 0. That report was submitted as Enclosure 9 to the LAR (Reference 1).Rather than revising the analysis of the unmitigated case and reissuing ANP-3284,NSPM is deleting the unmitigated case in its entirety. In effect, the unmitigated case issuperseded by the mitigated case that was submitted with Reference 2 and revised withReference 3. As stated in ANP-3435 Revision 1:"The analysis of Anticipated Transient Without Scram -Instability (ATWVSi)described herein should be recognized as the licensee's analysis of recordsupporting the proposed amendment to allow operation in the EFW domain."Hereby, NSPM considers the unmitigated ATWS-I case described in Sections 4 and 5of ANP-3284 Revision 0 to be superseded by the mitigated ATWS-l case described byANP-3435 Revision 1.* Control Rod Withdrawal Event (CRWE) Transient Analysis and Average PowerRangqe Monitor (APRM) Sigqnal Reduction. While evaluating the MICROBURN-B2 errorsunder their corrective action program, AREVA also identified nominal impacts on theresults for the CRWE transient analysis and the relative value of APRM signal reductionthat were originally provided in Report ANP-3295 Revision 2. ANP-3295 Revision 2was provided as Enclosure 11 to the LAR (Reference 1). The corrected results for theCRWE transient analysis and APRM signal reduction are provided in Revision 3 toAN P-3295.Thus, Enclosure 1 provides AREVA Report ANP-3295P, Revision 3. Enclosure 1 sproprietary to AREVA. Enclosure 2 provides the non-proprietary AREVA Report ANP-3295NP, Revision 3.Enclosure 3 provides an affidavit executed to support withholding Enclosure 1 frompublic disclosure. Enclosure I contains proprietary information as defined by 10 CFR2.390. The affidavit sets forth the basis on which the information may be withheld frompublic disclosure by the NRC and addresses with specificity the considerations listed in10 CFR 2.390(b)(4). Accordingly, NSPM respectfully requests that the AREVAproprietary information in Enclosure 1 be withheld from public disclosure in accordance Document Control DeskPage 3with 10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4. Correspondence withrespect to the copyright or proprietary aspects of the AREVA information in Enclosure 1or the supporting AREVA affidavit in Enclosure 3 should be addressed to Mr. AlanMeginnis, Manager- Product Licensing, AREVA Inc., 2101 Horn Rapids Road,Richiand, Washington 99354.The information offered herein does not affect the conclusions of the No SignificantHazards Consideration and the Environmental Consideration evaluations provided inthe Reference 1 license amendment request.In accordance with 10 CFR 50.91(b), a copy of this application supplement is beingprovided to the designated Minnesota Official without enclosures.If there are any questions or if additional information is needed, please contact GlennAdams at 612-330-6777.Summary of CommitmentsThis letter makes no new commitments and no revisions to existing commitments.I declare under penalty of perjury that the foregoing is true and correct.Executed on: February 29, 2016Peter A.GadeSite Vice PresidentMonticello Nuclear Generating PlantNorthern States Power Company-MinnesotaEnclosures (3)cc: Administrator, Region Ill, USNRCProject Manager, Monticello Nuclear Generating Plant, USNRCResident Inspector, Monticello Nuclear Generating Plant, USNRCMinnesota Department of Commerce (w/o enclosures)
: 3) Letter from Peter A. Gardner (NSPM) to Document Control Desk (NRC), "License Amendment Request for AREVA Extended Flow Window Supplement to Provide Revised Analysis of Anticipated Transient Without Scram Instability (TAC No. MF5002)," L-MT-15-081, dated December 8, 2015 (ADAMS Accession No. ML15345A407)
L-MT-1 6-010Enclosure 3ARE VA Affidavit3 pages follow AFFIDAVITCOMMONWEALTH OF VIRGINIA )) s.,CITY OF LYNCHBURG )1. My name is Morris Byram. I am Manager, Product Licensing, for AREVA Inc.(ARE VA) and as such I am authorized to execute this Affidavit.2. I am familiar with the criteria applied by AREVA to determine whether certainAREVA information is proprietary. I am familiar with the policies established byAREVA to ensure the proper application of these criteria.3. I am familiar with the ARE VA information contained in the topical reportANP-3295P, Revision 3, "Monticello Licensing Analysis For EFW (EPUIMELLLA+)," datedFebruary, 2016, and referred to herein as "Document." Information contained in this Documenthas been classified by AREVA as proprietary in accordance with the policies established byAREVA Inc. for the control and protection of proprietary and confidential information.4. Th~is Document contains information of a proprietary and confidential natureand is of the type customarily held in confidence by AREVA and not made available to thepublic. Based on my experience, I am aware that other companies regard information of thekind contained in this Document as proprietary and confidential.5. This Document has been made available to the U.S. Nuclear RegulatoryCommission in confidence with the request that the information contained in this Document bewithheldl from public disclosure. The request for withholding of proprietary information is made inaccordance 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 financialinformation."6. The following criteria are customarily applied by AREVA to determine whetherinformation should be classified as proprietary:-(a) The information reveals details of ARE VA's research and development plansand programs or their results.(b) Use of the information by a competitor would permit the competitor tosignificantly 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 aprocess, methodology, or component, the application of which results in acompetitive advantage for ARE VA.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitive advantage for ARE VA in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA, would behelpful to competitors to AREVA, and would likely cause substantial harm tothe competitive position of AREVA.The information in this Document is considered proprietary for the reasons set forth inparagraphs 6(b), 6(c), and 6(d) above.7. In accordance with AREVA's policies governing the protection and control ofinformation, proprietary information contained in this Document has been made available, on alimited basis, to others outside AREVA only as required and under suitable agreement providingfor nondisclosure and limited use of the information.8. AREVA policy requires that proprietary information be kept in a secured file orarea and distributed on a need-to-know basis.  
In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM)doing business as Xcel Energy, requested approval of an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS). The proposed change would revise the MNGP TS and would approve certain analytical methods that together would support operation in the expanded power-flow operating domain described as the Extended Flow Window (EFW). The purpose of the requested amendment is to transition from the General Electric -Hitachi methodology called Maximum Extended Load Line Limit Analysis Plus (MELLLA+)
: 9. The foregoing statements are true and correct to the best of my knowledge,information, and belief.SUBSCRIBED before me this ________day of _______ _______ _______ , 2016.Sherry L. McFaden .NOTARY PUBLIC, COMMONWEALTH'oF VIRGINIAMY COMMISSION EXPIRES: 10/31/18Reg. # 7079129~~Notary PMbfcCom, al~Ot 81, 2018 QF021 2, Revision 5 (FP-SC-RSI-04)Pae1oIPage 1 of 1Xcel Energy@SH{IPP1NG DOCUMJENTNORTHERN STATES POWER -MND/B/A Xcel EnergyMonticello Nuclear Plant, 2807 W Hwy. 75, Monticello, MN 55362Date: 2/29/2016Shipping DocumentTracking Number:Ship To:USNRC11555 Rockville PikeRockville, MD 20852-2738Attention Of: Doc ControlCarrier: UPS -Standard Overnight RMA No:Pro I Tracking No: P0 I Contract No:Packaging: Number of Packages: 1 Weight:Dangerous Goodsl UN/NA No: ..Insurance Est. ValueReason for Shipment: Overnight Shipment to USNRCMelody Imholte -Please ensure tracking number is communicated to me -melody.imholte@xenuclear.com-Item° No. Qty. Unit Description Catalog IDIQ1 Env Submittal to NRC L-MT-16-O10By si S p *ng e'o Urecc gto the best of your knowledge, that the mat nal le ng shipped is incornp/i nce with Xce xergy Corporate Policies. Please print and sign your name legibly.SWlP Making Shipment: 3'/I / '4.Received By: .Date:For wi!l-call use only"Use of this form as a procedural aid does not require retention as a quality record.}}
to the AREVA methodology called EFW.
Document Control Desk Page 2 In Reference 2, NSPM provided early identification of errors in AREVA's core depletion code MICROBURN-B2, and the potential effect on the safety analyses under NRC review. Subsequently, in Reference 3, NSPM described the effect of those errors on the limitingq transient analyses; providing revised results for the Anticipated Transient Without Scram -Instability (ATWS-I) analysis.
Reference 3 stated that the effect of the MICROBURN-B2 errors on non-limitinq transient analyses would be managed under the AREVA and NSPM corrective action programs.
After discussion with NRC Staff on November 24, 2015 and February 3, 2016, NSPM is addressing the non-limiting transient analyses as described below.* Unmitigqated ATWS-I Analysis.
While evaluating the MICROBURN-B2 errors under their corrective action program, AREVA identified a nominally adverse impact on the"'unmitigated" case that is described in Sections 4 and 5 of ATWS-l Report ANP-3284 Revision 0. That report was submitted as Enclosure 9 to the LAR (Reference 1).Rather than revising the analysis of the unmitigated case and reissuing ANP-3284, NSPM is deleting the unmitigated case in its entirety.
In effect, the unmitigated case is superseded by the mitigated case that was submitted with Reference 2 and revised with Reference
: 3. As stated in ANP-3435 Revision 1: "The analysis of Anticipated Transient Without Scram -Instability (ATWVSi)described herein should be recognized as the licensee's analysis of record supporting the proposed amendment to allow operation in the EFW domain." Hereby, NSPM considers the unmitigated ATWS-I case described in Sections 4 and 5 of ANP-3284 Revision 0 to be superseded by the mitigated ATWS-l case described by ANP-3435 Revision 1.* Control Rod Withdrawal Event (CRWE) Transient Analysis and Average Power Rangqe Monitor (APRM) Sigqnal Reduction.
While evaluating the MICROBURN-B2 errors under their corrective action program, AREVA also identified nominal impacts on the results for the CRWE transient analysis and the relative value of APRM signal reduction that were originally provided in Report ANP-3295 Revision 2. ANP-3295 Revision 2 was provided as Enclosure 11 to the LAR (Reference 1). The corrected results for the CRWE transient analysis and APRM signal reduction are provided in Revision 3 to AN P-3295.Thus, Enclosure 1 provides AREVA Report ANP-3295P, Revision 3. Enclosure 1 s proprietary to AREVA. Enclosure 2 provides the non-proprietary AREVA Report ANP-3295NP, Revision 3.Enclosure 3 provides an affidavit executed to support withholding Enclosure 1 from public disclosure.
Enclosure I contains proprietary information as defined by 10 CFR 2.390. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4).
Accordingly, NSPM respectfully requests that the AREVA proprietary information in Enclosure 1 be withheld from public disclosure in accordance Document Control Desk Page 3 with 10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4.
Correspondence with respect to the copyright or proprietary aspects of the AREVA information in Enclosure 1 or the supporting AREVA affidavit in Enclosure 3 should be addressed to Mr. Alan Meginnis, Manager- Product Licensing, AREVA Inc., 2101 Horn Rapids Road, Richiand, Washington 99354.The information offered herein does not affect the conclusions of the No Significant Hazards Consideration and the Environmental Consideration evaluations provided in the Reference 1 license amendment request.In accordance with 10 CFR 50.91(b), a copy of this application supplement is being provided to the designated Minnesota Official without enclosures.
If there are any questions or if additional information is needed, please contact Glenn Adams at 612-330-6777.
Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.Executed on: February 29, 2016 Peter A.Gade Site Vice President Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (3)cc: Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC Minnesota Department of Commerce (w/o enclosures)
L-MT-1 6-010 Enclosure 3 ARE VA Affidavit 3 pages follow AFFIDAVIT COMMONWEALTH OF VIRGINIA )) s., CITY OF LYNCHBURG  
)1. My name is Morris Byram. I am Manager, Product Licensing, for AREVA Inc.(ARE VA) 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 ARE VA information contained in the topical report ANP-3295P, Revision 3, "Monticello Licensing Analysis For EFW (EPUIMELLLA+)," dated February, 2016, 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. Th~is 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 withheldl 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 ARE VA'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 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 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 this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c), and 6(d) 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 ________day of _______ _______ _______ , 2016.Sherry L. McFaden .NOTARY PUBLIC, COMMONWEALTH'oF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129~~Notary PMbfcCom, al~Ot 81, 2018 QF021 2, Revision 5 (FP-SC-RSI-04)Pae1oI Page 1 of 1 Xcel Energy@SH{IPP1NG DOCUMJENT NORTHERN STATES POWER -MN D/B/A Xcel Energy Monticello Nuclear Plant, 2807 W Hwy. 75, Monticello, MN 55362 Date: 2/29/2016 Shipping Document Tracking Number: Ship To: USNRC 11555 Rockville Pike Rockville, MD 20852-2738 Attention Of: Doc Control Carrier: UPS -Standard Overnight RMA No: Pro I Tracking No: P0 I Contract No: Packaging:
Number of Packages:
1 Weight: Dangerous Goodsl UN/NA No: ..Insurance Est. Value Reason for Shipment:
Overnight Shipment to USNRC Melody Imholte -Please ensure tracking number is communicated to me -melody.imholte@xenuclear.com-Item° No. Qty. Unit Description Catalog IDIQ 1 Env Submittal to NRC L-MT-16-O10 By si S p *ng e'o Urecc gto the best of your knowledge, that the mat nal le ng shipped is in cornp/i nce with Xce xergy Corporate Policies.
Please print and sign your name legibly.SWlP Making Shipment: 3'/I / '4.Received By: .Date: For wi!l-call use only" Use of this form as a procedural aid does not require retention as a quality record.}}

Latest revision as of 04:36, 3 April 2019

License Amendment Request for Areva Extended Flow Window Supplement to Disposition Changes to Non-Limiting Transient Analyses
ML16063A033
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 02/29/2016
From: Gardner P A
Northern States Power Co, Xcel Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16063A032 List:
References
L-MT-16-010, TAC MF5002
Download: ML16063A033 (8)
v • d • e


Text

ENCLOSURE 1 CONTAINS PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 XceI Energy°Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 February 29, 2016 L-MT- 16-010 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22 License Amendment Request for AREVA Extended Flow Window Supplement to Disposition Chancqes to Non-Limitinq Transient Analyses (TAC No. MF5002)

References:

1) Letter from Karen D. Fili (NSPM), to Document Control Desk (NRC),"License Amendment Request for AREVA Extended Flow Window," L-MT-14-044, dated October 3, 2014 (ADAMS Accession No.ML14283A1 25)2) Letter from Peter A. Gardner (NSPM) to Document Control Desk (NRC), "License Amendment Request for ARE VA Extended Flow Window Supplement to Respond to NRC Staff Questions (TAC No.MF5002)," L-MT-15-065, dated September 29, 2015 (ADAMS Accession No. ML15274A473)
3) Letter from Peter A. Gardner (NSPM) to Document Control Desk (NRC), "License Amendment Request for AREVA Extended Flow Window Supplement to Provide Revised Analysis of Anticipated Transient Without Scram Instability (TAC No. MF5002)," L-MT-15-081, dated December 8, 2015 (ADAMS Accession No. ML15345A407)

In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM)doing business as Xcel Energy, requested approval of an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS). The proposed change would revise the MNGP TS and would approve certain analytical methods that together would support operation in the expanded power-flow operating domain described as the Extended Flow Window (EFW). The purpose of the requested amendment is to transition from the General Electric -Hitachi methodology called Maximum Extended Load Line Limit Analysis Plus (MELLLA+)

to the AREVA methodology called EFW.

Document Control Desk Page 2 In Reference 2, NSPM provided early identification of errors in AREVA's core depletion code MICROBURN-B2, and the potential effect on the safety analyses under NRC review. Subsequently, in Reference 3, NSPM described the effect of those errors on the limitingq transient analyses; providing revised results for the Anticipated Transient Without Scram -Instability (ATWS-I) analysis.

Reference 3 stated that the effect of the MICROBURN-B2 errors on non-limitinq transient analyses would be managed under the AREVA and NSPM corrective action programs.

After discussion with NRC Staff on November 24, 2015 and February 3, 2016, NSPM is addressing the non-limiting transient analyses as described below.* Unmitigqated ATWS-I Analysis.

While evaluating the MICROBURN-B2 errors under their corrective action program, AREVA identified a nominally adverse impact on the"'unmitigated" case that is described in Sections 4 and 5 of ATWS-l Report ANP-3284 Revision 0. That report was submitted as Enclosure 9 to the LAR (Reference 1).Rather than revising the analysis of the unmitigated case and reissuing ANP-3284, NSPM is deleting the unmitigated case in its entirety.

In effect, the unmitigated case is superseded by the mitigated case that was submitted with Reference 2 and revised with Reference

3. As stated in ANP-3435 Revision 1: "The analysis of Anticipated Transient Without Scram -Instability (ATWVSi)described herein should be recognized as the licensee's analysis of record supporting the proposed amendment to allow operation in the EFW domain." Hereby, NSPM considers the unmitigated ATWS-I case described in Sections 4 and 5 of ANP-3284 Revision 0 to be superseded by the mitigated ATWS-l case described by ANP-3435 Revision 1.* Control Rod Withdrawal Event (CRWE) Transient Analysis and Average Power Rangqe Monitor (APRM) Sigqnal Reduction.

While evaluating the MICROBURN-B2 errors under their corrective action program, AREVA also identified nominal impacts on the results for the CRWE transient analysis and the relative value of APRM signal reduction that were originally provided in Report ANP-3295 Revision 2. ANP-3295 Revision 2 was provided as Enclosure 11 to the LAR (Reference 1). The corrected results for the CRWE transient analysis and APRM signal reduction are provided in Revision 3 to AN P-3295.Thus, Enclosure 1 provides AREVA Report ANP-3295P, Revision 3. Enclosure 1 s proprietary to AREVA. Enclosure 2 provides the non-proprietary AREVA Report ANP-3295NP, Revision 3.Enclosure 3 provides an affidavit executed to support withholding Enclosure 1 from public disclosure.

Enclosure I contains proprietary information as defined by 10 CFR 2.390. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4).

Accordingly, NSPM respectfully requests that the AREVA proprietary information in Enclosure 1 be withheld from public disclosure in accordance Document Control Desk Page 3 with 10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4.

Correspondence with respect to the copyright or proprietary aspects of the AREVA information in Enclosure 1 or the supporting AREVA affidavit in Enclosure 3 should be addressed to Mr. Alan Meginnis, Manager- Product Licensing, AREVA Inc., 2101 Horn Rapids Road, Richiand, Washington 99354.The information offered herein does not affect the conclusions of the No Significant Hazards Consideration and the Environmental Consideration evaluations provided in the Reference 1 license amendment request.In accordance with 10 CFR 50.91(b), a copy of this application supplement is being provided to the designated Minnesota Official without enclosures.

If there are any questions or if additional information is needed, please contact Glenn Adams at 612-330-6777.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct.Executed on: February 29, 2016 Peter A.Gade Site Vice President Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (3)cc: Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC Minnesota Department of Commerce (w/o enclosures)

L-MT-1 6-010 Enclosure 3 ARE VA Affidavit 3 pages follow AFFIDAVIT COMMONWEALTH OF VIRGINIA )) s., CITY OF LYNCHBURG

)1. My name is Morris Byram. I am Manager, Product Licensing, for AREVA Inc.(ARE VA) 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 ARE VA information contained in the topical report ANP-3295P, Revision 3, "Monticello Licensing Analysis For EFW (EPUIMELLLA+)," dated February, 2016, 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. Th~is 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 withheldl 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 ARE VA'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 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 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 this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c), and 6(d) 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 ________day of _______ _______ _______ , 2016.Sherry L. McFaden .NOTARY PUBLIC, COMMONWEALTH'oF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129~~Notary PMbfcCom, al~Ot 81, 2018 QF021 2, Revision 5 (FP-SC-RSI-04)Pae1oI Page 1 of 1 Xcel Energy@SH{IPP1NG DOCUMJENT NORTHERN STATES POWER -MN D/B/A Xcel Energy Monticello Nuclear Plant, 2807 W Hwy. 75, Monticello, MN 55362 Date: 2/29/2016 Shipping Document Tracking Number: Ship To: USNRC 11555 Rockville Pike Rockville, MD 20852-2738 Attention Of: Doc Control Carrier: UPS -Standard Overnight RMA No: Pro I Tracking No: P0 I Contract No: Packaging:

Number of Packages:

1 Weight: Dangerous Goodsl UN/NA No: ..Insurance Est. Value Reason for Shipment:

Overnight Shipment to USNRC Melody Imholte -Please ensure tracking number is communicated to me -melody.imholte@xenuclear.com-Item° No. Qty. Unit Description Catalog IDIQ 1 Env Submittal to NRC L-MT-16-O10 By si S p *ng e'o Urecc gto the best of your knowledge, that the mat nal le ng shipped is in cornp/i nce with Xce xergy Corporate Policies.

Please print and sign your name legibly.SWlP Making Shipment: 3'/I / '4.Received By: .Date: For wi!l-call use only" Use of this form as a procedural aid does not require retention as a quality record.

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