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| {{#Wiki_filter:ENCLOSURES 1 AND 3 CONTAIN PROPRIETARY INFORMATIONWITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390XcelEnergy Monticello Nuclear Generating Plant2807 W County Rd 75Monticello, MN 55362October 4, 2013 L-MT-1 3-09610 CFR 50.90U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Monticello Nuclear Generating PlantDocket 50-263Renewed License No. DPR-22 | | {{#Wiki_filter:ENCLOSURES 1 AND 3 CONTAIN PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390XcelEnergy Monticello Nuclear Generating Plant2807 W County Rd 75Monticello, MN 55362October 4, 2013 L-MT-1 3-09610 CFR 50.90U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Monticello Nuclear Generating PlantDocket 50-263Renewed License No. DPR-22 |
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| Maximum Extended Load Line Limit Analysis Plus License AmendmentRequest -Request for Additional Information Responses (TAC ME3145) | | |
| | Maximum Extended Load Line Limit Analysis Plus License Amendment Request -Request for Additional Information Responses (TAC ME3145) |
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| ==References:== | | ==References:== |
| 1) Letter from T J O'Connor (NSPM), to Document Control Desk (NRC),"License Amendment Request: Maximum Extended Load Line LimitAnalysis Plus," L-MT-10-003, dated January 21, 2010. (ADAMSAccession No. ML100280558)2) Email from K. Feintuch for T. Beltz (NRC) to J. Fields (NSPM),"Monticello Nuclear Generating Plant -Revised Draft Request forAdditional Information Associated with NRC Staff Review of theMELLLA+ License Amendment Request (TAC No. ME3145)," datedSeptember 11,2013.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 allow operation in the expandedMaximum Extended Load Line Limit Analysis Plus (MELLLA+) domain.In Reference 2 the NRC provided Requests for Additional Information (RAIs) pertainingto information needed to support MELLLA+ and analysis revisions. The purpose of thisletter is to provide NSPM's responses to the Reference 2 RAIs.Enclosure 1 provides a report from General Electric -Hitachi (GEH) letter,GE-MNGP-AEP-3304R1, "GEH Response to MELLLA+ RAI 2." Enclosure 1 containsproprietary information. | | : 1) Letter from T J O'Connor (NSPM), to Document Control Desk (NRC),"License Amendment Request: |
| Document Control DeskPage 2Enclosure 2 provides a non-proprietary copy of the Enclosure 1 RAI responses. Thenon-proprietary copy of the RAI responses is being provided based on the NRC'sexpectation that the submitter of the proprietary information should provide, if possible,a non-proprietary version of the document with brackets showing where the proprietaryinformation has been deleted.Enclosure 3 provides page changes to the MELLLA+ Safety Analysis Report (NEDC-33435P). These page changes are based on corrections and changes in the analysispresented in Enclosure 1. Enclosure 3 contains proprietary information.Enclosure 4 provides a non-proprietary version of Enclosure 3.Enclosure 5 provides an affidavit executed to support withholding Enclosures 1 and 3from public disclosure. Information in Enclosures 1 and 3 contain proprietaryinformation as defined by 10 CFR 2.390. The affidavit sets forth the basis on which theinformation may be withheld from public disclosure by the NRC and addresses withspecificity the considerations listed in 10 CFR 2.390(b)(4). Accordingly, NSPMrespectfully requests that the proprietary information in Enclosures 1 and 3 be withheldfrom public disclosure in accordance with 10 CFR 2.390(a)4, as authorized by10 CFR 9.17(a)4.Correspondence with respect to the copyright or proprietary aspects of GEH informationor the supporting GEH affidavit in Enclosure 5 should be addressed to Peter M.Yandow, Vice President, Nuclear Plant Projects/Services Licensing, Regulatory Affairs,GE-Hitachi Nuclear Energy Americas LLC, 3901 Castle Hayne Road, Wilmington, NC28401.Enclosure 6 contains a response to RAI 1 from Reference 2 and a commitmentassociated with the MELLLA+ analysis implementation.The supplemental information provided herein does not change the conclusions of theNo Significant Hazards Consideration and the Environmental Consideration evaluationsprovided in Reference 1 for the MELLLA+ license amendment request.In accordance with 10 CFR 50.91(b), a copy of this application supplement, withoutenclosures is being provided to the designated Minnesota Official.Summary of CommitmentsThis letter makes the following new commitment:NSPM commits to train and test licensed reactor operators to initiate MonticelloNuclear Generating Plant feedwater flow reduction in less than or equal to 90seconds to support the MELLLA+ Anticipated Transient without Scram Instabilityanalysis. | | Maximum Extended Load Line LimitAnalysis Plus," L-MT-10-003, dated January 21, 2010. (ADAMSAccession No. ML100280558) |
| Document Control DeskPage 3I declare under penalty of perjury that the foregoing is true and correct.Executed on: October 2013KarenbD FiliSite Vice-PresidentMonticello Nuclear Generating PlantNorthern States Power Company-MinnesotaEnclosures (6)cc: Regional Administrator, Region III, USNRC (w/o enclosures)Project Manager, Monticello Nuclear Generating Plant, USNRCResident Inspector, Monticello Nuclear Generating Plant, USNRC (w/oenclosures)Minnesota Department of Commerce (w/o enclosures) | | : 2) Email from K. Feintuch for T. Beltz (NRC) to J. Fields (NSPM),"Monticello Nuclear Generating Plant -Revised Draft Request forAdditional Information Associated with NRC Staff Review of theMELLLA+ License Amendment Request (TAC No. ME3145)," |
| L-MT-1 3-096ENCLOSURE 5GENERAL ELECTRIC -HITACHI AFFIDAVIT FORWITHHOLDING PROPRIETARY INFORMATION3 pages follow GE-Hitachi Nuclear Energy Americas LLCAFFIDAVITI, Peter M. Yandow, state as follows:(1) I am the Vice President, Nuclear Plant Projects/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function ofreviewing the information described in paragraph (2) which is sought to be withheld, andhave been authorized to apply for its withholding.(2) The information sought to be withheld is contained in Enclosures I and 3 of GEH letter,GE-MNGP-AEP-3304R1, "GEH Response to MELLLA Plus Requests for AdditionalInformation," dated October 3, 2013. The GEH proprietary information in Enclosure 1,which is entitled "GEH Response to MELLLA+ RAI 2," and Enclosure 3 which is entitled"NEDC-33435P Corrected Pages," is identified by a dark red dotted underline inside doublesquare brackets. [[This ..sentence -.i*s...an. examp l'e...131]] .Figures containing GEH proprietaryinformation are identified with double square brackets before and after the object. In eachcase, the superscript notation 131 refers to Paragraph (3) of this affidavit that provides thebasis for the proprietary determination.(3) In making this application for withholding of proprietary information of which it is theowner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedomof Information Act (FOIA), 5 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.See. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets(Exemption 4). The material for which exemption from disclosure is here sought alsoqualifies under the narrower definition of trade secret, within the meanings assigned tothose terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass EnergyProiect v. Nuclear Regulatory Commission, 975 F.2.d 871 (D.C. Cir. 1992), and PublicCitizen Health Research Group v. FDA, 704 F.2.d 1280 (D.C. Cir. 1983).(4) The information sought to be withheld is considered to be proprietary for the reasons setforth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit intothe definition of proprietary information are:a. Information that discloses a process, method, or apparatus, including supporting dataand analyses, where prevention of its use by GEH's competitors without license fromGEH constitutes a competitive economic advantage over GEH or other companies.b. Information that, if used by a competitor, would reduce their expenditure of resourcesor improve their competitive position in the design, manufacture, shipment,installation, assurance of quality, or licensing of a similar product.c. Information that reveals aspects of past, present, or future GEH customer-fundeddevelopment plans and programs, that may include potential products of GEH.Affidavit for GE-MNGP-AEP-3304R1Page I of 3 GE-Hitachi Nuclear Energy Americas LLCd. Information that discloses trade secret or potentially patentable subject matter forwhich it may be desirable to obtain patent protection.(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted tothe NRC in confidence. The information is of a sort customarily held in confidence byGEH, and is in fact so held. The information sought to be withheld has, to the best of myknowledge and belief, consistently been held in confidence by GEH, not been disclosedpublicly, and not been made available in public sources. All disclosures to third parties,including any required transmittals to the NRC, have been made, or must be made, pursuantto regulatory provisions or proprietary or confidentiality agreements that provide formaintaining the information in confidence. The initial designation of this information asproprietary information, and the subsequent steps taken to prevent its unauthorizeddisclosure are as set forth in the following paragraphs (6) and (7).(6) Initial approval of proprietary treatment of a document is made by the manager of theoriginating component, who is the person most likely to be acquainted with the value andsensitivity of the information in relation to industry knowledge, or who is the person mostlikely to be subject to the terms under which it was licensed to GEH. Access to suchdocuments within GEH is limited to a "need to know" basis.(7) The procedure for approval of external release of such a document typically requires reviewby the staff manager, project manager, principal scientist, or other equivalent authority fortechnical content, competitive effect, and determination of the accuracy of the proprietarydesignation. Disclosures outside GEH are limited to regulatory bodies, customers, andpotential customers, and their agents, suppliers, and licensees, and others with a legitimateneed for the information, and then only in accordance with appropriate regulatoryprovisions or proprietary or confidentiality agreements.(8) The information identified in paragraph (2) above is classified as proprietary because itcontains results of an analysis performed by GEH to support the Monticello MaximumExtended Load Line Limit Analysis Plus (MELLLA+) license application. This analysis ispart of the GEH MELLLA+ methodology. Development of the MELLLA+ methodologyand the supporting analysis techniques and information, and their application to the design,modification, and processes were achieved at a significant cost to GEH.The development of the evaluation methodology along with the interpretation andapplication of the analytical results is derived from the extensive experience database thatconstitutes a major GEH asset.(9) Public disclosure of the information sought to be withheld is likely to cause substantialharm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety andtechnology base, and its commercial value extends beyond the original development cost.The value of the technology base goes beyond the extensive physical database andAffidavit for GE-MNGP-AEP-3304R1Page 2 of 3 GE-Hitachi Nuclear Energy Americas LLCanalytical methodology and includes development of the expertise to determine and applythe appropriate evaluation process. In addition, the technology base includes the valuederived from providing analyses done with NRC-approved methods.The research, development, engineering, analytical and NRC review costs comprise asubstantial investment of time and money by GEH. The precise value of the expertise todevise an evaluation process and apply the correct analytical methodology is difficult toquantify, but it clearly is substantial. GEH's competitive advantage will be lost if itscompetitors are able to use the results of the GEH experience to normalize or verify theirown process or if they are able to claim an equivalent understanding by demonstrating thatthey can arrive at the same or similar conclusions.The value of this information to GEH would be lost if the information were disclosed to thepublic. Making such information available to competitors without their having beenrequired to undertake a similar expenditure of resources would unfairly provide competitorswith a windfall, and deprive GEH of the opportunity to exercise its competitive advantageto seek an adequate return on its large investment in developing and obtaining these veryvaluable analytical tools.I declare under penalty of perjury that the foregoing affidavit and the matters stated therein aretrue and correct to the best of my knowledge, information, and belief.Executed on this 3rd day of October, 2013.Peter M. YandowVice President, Nuclear Plant Projects/Services LicensingRegulatory AffairsGE-Hitachi Nuclear Energy Americas LLC3901 Castle Hayne RdWilmington, NC 28401Peter.Yandow@ge.comAffidavit for GE-MNGP-AEP-3304R1Page 3 of 3 L-MT-1 3-096ENCLOSURE 6MAXIMUM EXTENDED LOAD LINE LIMIT PLUS (MELLLA+)REQUEST FOR ADDITIONAL INFORMATIONThis enclosure provides a response from the Northern States Power Company, aMinnesota corporation (NSPM), doing business as Xcel Energy, to a request foradditional information (RAI) provided by the Nuclear Regulatory Commission (NRC) inReference 1.NRC RequestThe failure of the reactor to shut down during certain transient can lead to unacceptablereactor coolant system pressure, fuel conditions, and/or containment conditions.Provide a training schedule and tracking method to train operators on the importance oftaking action within 90 seconds to mitigate an A TWS event.NSPM ResponseThe current MELLLA+ Anticipated Transient Without Scram (ATWS) Instability (ATWSI)analysis demonstrates acceptable performance and resulting fuel protection whenoperators initiate actions to reduce feedwater flow to the reactor vessel in less than orequal to 90 seconds of the onset of an ATWS event initiation.The Monticello Nuclear Generating Plant (MNGP) Time Critical Operator Actions(TCOA) procedures identify tasks contained in the plant's operating procedures that arecredited by the design and licensing basis to be accomplished in a specified time. Forthe ATWS event at MNGP, operators are currently required to reduce feedwater flow in78 seconds. Training for operators, validation of satisfactory performance of the TCOAby operators and periodic validation of the equipment necessary to perform TCOAs areall required and controlled by the TCOA procedures.Currently, operator training on MELLLA+ revisions to the design and licensing basis arescheduled to be completed by October 4, 2013. The Simulator Exercise Guide (SEG),used for training and verification of operator compliance with the TCOA, requires thatthe feedwater reduction step be completed in less than or equal to 90 seconds of theonset of an ATWS event.To ensure continued future compliance of the performance of the ATWS feedwater flowreduction TCOA, NSPM is providing the following commitment:Page 1 of 2 L-MT-1 3-096NSPM commits to train and test licensed reactor operators to initiate MonticelloNuclear Generating Plant feedwater flow reduction in less than or equal to 90seconds to support the MELLLA+ Anticipated Transient without Scram Instabilityanalysis.References1 -Email from K. Feintuch for T. Beltz (NRC) to J. Fields (NSPM), "Monticello NuclearGenerating Plant -Revised Draft Request for Additional Information Associated withNRC Staff Review of the MELLLA+ License Amendment Request (TAC No.ME3145)," dated September 11, 2013.Page 2 of 2 | | datedSeptember 11,2013.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 allow operation in the expandedMaximum Extended Load Line Limit Analysis Plus (MELLLA+) |
| }} | | domain.In Reference 2 the NRC provided Requests for Additional Information (RAIs) pertaining to information needed to support MELLLA+ and analysis revisions. |
| | The purpose of thisletter is to provide NSPM's responses to the Reference 2 RAIs.Enclosure 1 provides a report from General Electric |
| | -Hitachi (GEH) letter,GE-MNGP-AEP-3304R1, "GEH Response to MELLLA+ RAI 2." Enclosure 1 containsproprietary information. |
| | Document Control DeskPage 2Enclosure 2 provides a non-proprietary copy of the Enclosure 1 RAI responses. |
| | Thenon-proprietary copy of the RAI responses is being provided based on the NRC'sexpectation that the submitter of the proprietary information should provide, if possible, a non-proprietary version of the document with brackets showing where the proprietary information has been deleted.Enclosure 3 provides page changes to the MELLLA+ Safety Analysis Report (NEDC-33435P). |
| | These page changes are based on corrections and changes in the analysispresented in Enclosure |
| | : 1. Enclosure 3 contains proprietary information. |
| | Enclosure 4 provides a non-proprietary version of Enclosure 3.Enclosure 5 provides an affidavit executed to support withholding Enclosures 1 and 3from public disclosure. |
| | Information in Enclosures 1 and 3 contain proprietary information as defined by 10 CFR 2.390. The affidavit sets forth the basis on which theinformation may be withheld from public disclosure by the NRC and addresses withspecificity the considerations listed in 10 CFR 2.390(b)(4). |
| | Accordingly, NSPMrespectfully requests that the proprietary information in Enclosures 1 and 3 be withheldfrom public disclosure in accordance with 10 CFR 2.390(a)4, as authorized by10 CFR 9.17(a)4. |
| | Correspondence with respect to the copyright or proprietary aspects of GEH information or the supporting GEH affidavit in Enclosure 5 should be addressed to Peter M.Yandow, Vice President, Nuclear Plant Projects/Services Licensing, Regulatory Affairs,GE-Hitachi Nuclear Energy Americas LLC, 3901 Castle Hayne Road, Wilmington, NC28401.Enclosure 6 contains a response to RAI 1 from Reference 2 and a commitment associated with the MELLLA+ analysis implementation. |
| | The supplemental information provided herein does not change the conclusions of theNo Significant Hazards Consideration and the Environmental Consideration evaluations provided in Reference 1 for the MELLLA+ license amendment request.In accordance with 10 CFR 50.91(b), |
| | a copy of this application supplement, withoutenclosures is being provided to the designated Minnesota Official. |
| | Summary of Commitments This letter makes the following new commitment: |
| | NSPM commits to train and test licensed reactor operators to initiate Monticello Nuclear Generating Plant feedwater flow reduction in less than or equal to 90seconds to support the MELLLA+ Anticipated Transient without Scram Instability analysis. |
| | Document Control DeskPage 3I declare under penalty of perjury that the foregoing is true and correct.Executed on: October 2013KarenbD FiliSite Vice-President Monticello Nuclear Generating PlantNorthern States Power Company-Minnesota Enclosures (6)cc: Regional Administrator, Region III, USNRC (w/o enclosures) |
| | Project Manager, Monticello Nuclear Generating Plant, USNRCResident Inspector, Monticello Nuclear Generating Plant, USNRC (w/oenclosures) |
| | Minnesota Department of Commerce (w/o enclosures) |
| | L-MT-1 3-096ENCLOSURE 5GENERAL ELECTRIC |
| | -HITACHI AFFIDAVIT FORWITHHOLDING PROPRIETARY INFORMATION 3 pages follow GE-Hitachi Nuclear Energy Americas LLCAFFIDAVIT I, Peter M. Yandow, state as follows:(1) I am the Vice President, Nuclear Plant Projects/Services Licensing, Regulatory |
| | : Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function ofreviewing the information described in paragraph (2) which is sought to be withheld, andhave been authorized to apply for its withholding. |
| | (2) The information sought to be withheld is contained in Enclosures I and 3 of GEH letter,GE-MNGP-AEP-3304R1, "GEH Response to MELLLA Plus Requests for Additional Information," |
| | dated October 3, 2013. The GEH proprietary information in Enclosure 1,which is entitled "GEH Response to MELLLA+ RAI 2," and Enclosure 3 which is entitled"NEDC-33435P Corrected Pages," is identified by a dark red dotted underline inside doublesquare brackets. |
| | [[This ..sentence |
| | -.i*s...an. |
| | examp l'e...131]] |
| | .Figures containing GEH proprietary information are identified with double square brackets before and after the object. In eachcase, the superscript notation 131 refers to Paragraph (3) of this affidavit that provides thebasis for the proprietary determination. |
| | (3) In making this application for withholding of proprietary information of which it is theowner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedomof Information Act (FOIA), 5 U.S.C. Sec. 552(b)(4), |
| | and the Trade Secrets Act, 18 U.S.C.See. 1905, and NRC regulations 10 CFR 9.17(a)(4), |
| | and 2.390(a)(4) for trade secrets(Exemption 4). The material for which exemption from disclosure is here sought alsoqualifies under the narrower definition of trade secret, within the meanings assigned tothose terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass EnergyProiect v. Nuclear Regulatory Commission, 975 F.2.d 871 (D.C. Cir. 1992), and PublicCitizen Health Research Group v. FDA, 704 F.2.d 1280 (D.C. Cir. 1983).(4) The information sought to be withheld is considered to be proprietary for the reasons setforth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit intothe definition of proprietary information are:a. Information that discloses a process, method, or apparatus, including supporting dataand analyses, where prevention of its use by GEH's competitors without license fromGEH constitutes a competitive economic advantage over GEH or other companies. |
| | : b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, |
| | : shipment, installation, assurance of quality, or licensing of a similar product.c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, that may include potential products of GEH.Affidavit for GE-MNGP-AEP-3304R1 Page I of 3 GE-Hitachi Nuclear Energy Americas LLCd. Information that discloses trade secret or potentially patentable subject matter forwhich it may be desirable to obtain patent protection. |
| | (5) To address 10 CFR 2.390(b)(4), |
| | the information sought to be withheld is being submitted tothe NRC in confidence. |
| | The information is of a sort customarily held in confidence byGEH, and is in fact so held. The information sought to be withheld has, to the best of myknowledge and belief, consistently been held in confidence by GEH, not been disclosed |
| | : publicly, and not been made available in public sources. |
| | All disclosures to third parties,including any required transmittals to the NRC, have been made, or must be made, pursuantto regulatory provisions or proprietary or confidentiality agreements that provide formaintaining the information in confidence. |
| | The initial designation of this information asproprietary information, and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in the following paragraphs (6) and (7).(6) Initial approval of proprietary treatment of a document is made by the manager of theoriginating component, who is the person most likely to be acquainted with the value andsensitivity of the information in relation to industry knowledge, or who is the person mostlikely to be subject to the terms under which it was licensed to GEH. Access to suchdocuments within GEH is limited to a "need to know" basis.(7) The procedure for approval of external release of such a document typically requires reviewby the staff manager, project manager, principal scientist, or other equivalent authority fortechnical |
| | : content, competitive effect, and determination of the accuracy of the proprietary designation. |
| | Disclosures outside GEH are limited to regulatory bodies, customers, andpotential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary or confidentiality agreements. |
| | (8) The information identified in paragraph (2) above is classified as proprietary because itcontains results of an analysis performed by GEH to support the Monticello MaximumExtended Load Line Limit Analysis Plus (MELLLA+) |
| | license application. |
| | This analysis ispart of the GEH MELLLA+ methodology. |
| | Development of the MELLLA+ methodology and the supporting analysis techniques and information, and their application to the design,modification, and processes were achieved at a significant cost to GEH.The development of the evaluation methodology along with the interpretation andapplication of the analytical results is derived from the extensive experience database thatconstitutes a major GEH asset.(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. |
| | The information is part of GEH's comprehensive BWR safety andtechnology base, and its commercial value extends beyond the original development cost.The value of the technology base goes beyond the extensive physical database andAffidavit for GE-MNGP-AEP-3304R1 Page 2 of 3 GE-Hitachi Nuclear Energy Americas LLCanalytical methodology and includes development of the expertise to determine and applythe appropriate evaluation process. |
| | In addition, the technology base includes the valuederived from providing analyses done with NRC-approved methods.The research, development, engineering, analytical and NRC review costs comprise asubstantial investment of time and money by GEH. The precise value of the expertise todevise an evaluation process and apply the correct analytical methodology is difficult toquantify, but it clearly is substantial. |
| | GEH's competitive advantage will be lost if itscompetitors are able to use the results of the GEH experience to normalize or verify theirown process or if they are able to claim an equivalent understanding by demonstrating thatthey can arrive at the same or similar conclusions. |
| | The value of this information to GEH would be lost if the information were disclosed to thepublic. Making such information available to competitors without their having beenrequired to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these veryvaluable analytical tools.I declare under penalty of perjury that the foregoing affidavit and the matters stated therein aretrue and correct to the best of my knowledge, information, and belief.Executed on this 3rd day of October, 2013.Peter M. YandowVice President, Nuclear Plant Projects/Services Licensing Regulatory AffairsGE-Hitachi Nuclear Energy Americas LLC3901 Castle Hayne RdWilmington, NC 28401Peter.Yandow@ge.com Affidavit for GE-MNGP-AEP-3304R1 Page 3 of 3 L-MT-1 3-096ENCLOSURE 6MAXIMUM EXTENDED LOAD LINE LIMIT PLUS (MELLLA+) |
| | REQUEST FOR ADDITIONAL INFORMATION This enclosure provides a response from the Northern States Power Company, aMinnesota corporation (NSPM), doing business as Xcel Energy, to a request foradditional information (RAI) provided by the Nuclear Regulatory Commission (NRC) inReference 1.NRC RequestThe failure of the reactor to shut down during certain transient can lead to unacceptable reactor coolant system pressure, fuel conditions, and/or containment conditions. |
| | Provide a training schedule and tracking method to train operators on the importance oftaking action within 90 seconds to mitigate an A TWS event.NSPM ResponseThe current MELLLA+ Anticipated Transient Without Scram (ATWS) Instability (ATWSI)analysis demonstrates acceptable performance and resulting fuel protection whenoperators initiate actions to reduce feedwater flow to the reactor vessel in less than orequal to 90 seconds of the onset of an ATWS event initiation. |
| | The Monticello Nuclear Generating Plant (MNGP) Time Critical Operator Actions(TCOA) procedures identify tasks contained in the plant's operating procedures that arecredited by the design and licensing basis to be accomplished in a specified time. Forthe ATWS event at MNGP, operators are currently required to reduce feedwater flow in78 seconds. |
| | Training for operators, validation of satisfactory performance of the TCOAby operators and periodic validation of the equipment necessary to perform TCOAs areall required and controlled by the TCOA procedures. |
| | Currently, operator training on MELLLA+ revisions to the design and licensing basis arescheduled to be completed by October 4, 2013. The Simulator Exercise Guide (SEG),used for training and verification of operator compliance with the TCOA, requires thatthe feedwater reduction step be completed in less than or equal to 90 seconds of theonset of an ATWS event.To ensure continued future compliance of the performance of the ATWS feedwater flowreduction TCOA, NSPM is providing the following commitment: |
| | Page 1 of 2 L-MT-1 3-096NSPM commits to train and test licensed reactor operators to initiate Monticello Nuclear Generating Plant feedwater flow reduction in less than or equal to 90seconds to support the MELLLA+ Anticipated Transient without Scram Instability analysis. |
| | References 1 -Email from K. Feintuch for T. Beltz (NRC) to J. Fields (NSPM), "Monticello NuclearGenerating Plant -Revised Draft Request for Additional Information Associated withNRC Staff Review of the MELLLA+ License Amendment Request (TAC No.ME3145)," |
| | dated September 11, 2013.Page 2 of 2}} |
Letter Sequence Request |
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TAC:ME3145, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance
- Meeting, Meeting, Meeting, Meeting, Meeting, Meeting
Results
Other: L-MT-08-091, Calculation 0801040.301, Steam Dryer Outer Hood Submodel Analysis., L-MT-09-002, Response to NRC Probabilistic Risk Assessment (PRA) Branch Requests for Additional Information (Rais) Dated December 5, 2008, L-MT-09-003, Response to NRC Environmental Branch Requests for Additional Information (Rais) Dated December 18, 2008, L-MT-09-004, Enclosure 1 (Continued) to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 2, Copy of MNGP Appr T0406 Data Transmittal Pages 1 of 538 Through Pages 538 of 538, L-MT-09-026, Calculation 0000-0081-6958 MNGP-PRNMS-APRM Calc-2008-NP, Rev. 1, Average Power Range Monitor Selected Prnm Licensing Setpoints - EPU Operation (Numac), L-MT-09-027, Extended Power Uprate: Response to Instrumentation and Controls Branch RAI No. 3 Dated April 6, 2009, L-MT-09-044, Extended Power Uprate: Response to NRC Mechanical and Civil Engineering Review Branch (Emcb) Requests for Additional Information (Rais) Dated March 28, 2009, L-MT-09-049, Drawing C.5-2007, Revision 15, Failure to Scram, L-MT-09-073, Extended Power Uprate: Response to NRC Containment and Ventilation Review Branch (Scvb) Requests for Additional Information (Rais) Dated July 2, 2009 and July 14, 2009, L-MT-09-083, Extended Power Uprate: Limit Curves Requested by the Mechanical and Civil Review Branch (Emcb) Associated with Requests for Additional Information (Rais) Dated March 20, 2009, L-MT-09-088, Extended Power Uprate: Revision to Clarify Text in Enclosures 5 and 7 of L-MT-08-052, L-MT-09-097, Extended Power Uprate: Acknowledgement of NRC Review Delay, L-MT-10-025, Extended Power Uprate (Epu): Response to NRC-NSPM February 25, 2010 Conference Call, L-MT-10-072, Extended Power Uprate: Updates to Docketed Information, L-MT-11-044, Uprate (Epu): Update on EPU Commitments, L-MT-12-056, WCAP-17549-NP, Rev. 0, Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE, L-MT-12-090, Westinghouse, LTR-A&SA-12-8, Rev. 1, Attachment B, Recommendations for Inspections of the Monticello Replacement Steam Dryer., L-MT-12-114, Drawing C.5-2007, Rev. 17, Failure to Scram, L-MT-13-020, Enclosure 1 - Responses to the Gap Analysis, L-MT-13-029, Enclosure 14 to L-MT-13-029 - WCAP-17716-NP, Revision 0, Benchmarking of the Acoustic Circuit Enhanced Revision 2.0 for the Monticello Steam Dryer Replacement Project., L-MT-13-091, WCAP-17716-NP, Revision 1 - Benchmarking of the Acoustic Circuit Enhanced Revision 2.0 for the Monticello Steam Dryer Replacement Project, Enclosure 14, L-MT-13-092, Extended Power Uprate (Epu): Completion of EPU Commitments, Proposed License Conditions and Revised Power Ascension Test Plan, L-MT-13-096, GE-MNGP-AEP-3304R1, Enclosure 4, NEDC-33435 Corrected Pages, L-MT-13-126, Enclosure 3, GE-MNGP-AEP-3306, Enclosure 2 GEH Response to Mella+ Eicb RAI and Affidavit, L-MT-14-023, Maximum Extended Load Line Limit Analysis Plus: Technical Specification Clarifications, L-MT-15-074, Enclosure 7, WCAP-18604-NP, Revision 0, Monticello EPU Main Steam Line Strain Data Evaluation Report., L-MT-16-017, Revised Commitment to Reconcile Analysis of Bypass Voiding for Transition to Areva Analysis Methodology, L-MT-16-071, Submittal of 2016 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46, ML083230111, ML083400402, ML083500575, ML083570610, ML083590127, ML090710680, ML090710683, ML090710684, ML091120578, ML091140470, ML091410121, ML091410122, ML091410123, ML091410124, ML091760769, ML092290250, ML092810554, ML093160816, ML093220925, ML093220964, ML093620024, ML100280558... further results
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MONTHYEARML0907106832008-02-17017 February 2008 Enclosure 1 (Continued) to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 2, Attachment 1-1g Through End of Encl. 1 Project stage: Other ML13064A4352008-03-20020 March 2008 CA-95-075, Main Steam Line High Flow Setpoint, Attachment 4 Project stage: Other ML0914101242008-08-11011 August 2008 Monticello - Calculation CA-08-050, Rev. 0, Instrument Setpoint Calculation - Average Power Range Monitor (APRM) Non-Flow Eiased Prnm Setpoints for Cl Tp and EPU Project stage: Other L-MT-08-091, Calculation 0801040.301, Steam Dryer Outer Hood Submodel Analysis.2008-10-31031 October 2008 Calculation 0801040.301, Steam Dryer Outer Hood Submodel Analysis. Project stage: Other ML0832301122008-10-31031 October 2008 NEDC-33322-NP, Revision 3, Monticello Nuclear Generating Plant, Safety Analysis Report, Constant Pressure Power Uprate. Project stage: Request ML0832301112008-11-0505 November 2008 Monticello Nuclear Generating Plant, License Amendment Request: Extended Power Uprate Project stage: Other ML0832301142008-11-0505 November 2008 Monticello Nuclear Generating Plant, Steam Dryer Dynamic Stress Evaluation. Project stage: Request ML0834003662008-12-0202 December 2008 Extended Power Uprate Acceptance Review Questions on Probabilistic Risk Assessment Issues Project stage: Acceptance Review ML0834004022008-12-0505 December 2008 Extended Power Uprate - Monticello - Request to Supplement the Application in the Probabilistic Risk Assessment Area Project stage: Other ML0835000992008-12-11011 December 2008 Monticello Extended Power Uprate (Usnrc TAC MD9990): Acceptance Review Supplement Regarding Steam Dryer Outer Hood Submodel Analysis Project stage: Supplement ML0835303022008-12-16016 December 2008 Draft Request for Additional Information, Environmental Issues of EPU Application Project stage: Draft RAI ML0936200242008-12-18018 December 2008 Report 0800760.401, Rev. 1, Flaw Evaluation and Vibration Assessment of Existing Monticello Steam Dryer Flaws for Extended Power Uprate. Project stage: Other ML0835005752008-12-18018 December 2008 Letter Finding 11/5/08 Application for Amendment Acceptable for Review Project stage: Other ML0835309982008-12-18018 December 2008 EPU Application - Additional RAI Question Regarding an Environmental Issue Project stage: RAI ML0835310022008-12-18018 December 2008 Proposed Eou Amendment - Revised RAI Re. Containment Analysis Project stage: RAI ML0914101222008-12-18018 December 2008 Monticello - Calculation CA-95-075, Revision 1, Main Steam Line High Flow Setpoint Project stage: Other ML0914101212008-12-19019 December 2008 Monticello - Calculation CA-95-073, Revision 4, Reactor Low Water Level SCRAM Setpoint Project stage: Other ML0835901272009-01-14014 January 2009 Letter Conveying Determination That Enclosure 5 of 11/5/08 Application for EPU Amendment Contains Proprietary Information and Withheld from Public Disclosure Project stage: Other ML0835706102009-01-26026 January 2009 Letter Conveying Determination That Enclosure 11 of 11/5/08 Application for EPU Amendment Contains Proprietary Information and Is Withheld from Public Disclosure Project stage: Other L-MT-09-003, Response to NRC Environmental Branch Requests for Additional Information (Rais) Dated December 18, 20082009-01-29029 January 2009 Response to NRC Environmental Branch Requests for Additional Information (Rais) Dated December 18, 2008 Project stage: Other L-MT-09-005, Revision to Attachment 1 of Enclosure 17 of MNGP License Amendment Request for Extended Power Uprate2009-02-0404 February 2009 Revision to Attachment 1 of Enclosure 17 of MNGP License Amendment Request for Extended Power Uprate Project stage: Request L-MT-09-002, Response to NRC Probabilistic Risk Assessment (PRA) Branch Requests for Additional Information (Rais) Dated December 5, 20082009-02-0404 February 2009 Response to NRC Probabilistic Risk Assessment (PRA) Branch Requests for Additional Information (Rais) Dated December 5, 2008 Project stage: Other ML0904204852009-02-11011 February 2009 Draft RAI from Materials Engineering Re. Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907106792009-02-17017 February 2009 Monticello, Response to NRC Containment & Ventilation Branch Request for Additional Information (Rals) Dated December 18, 2008 Project stage: Request ML0907106802009-02-17017 February 2009 Monticello, Enclosure 1 to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 1 Dated December 18, 2008, Cover Through Copy of MNGP Appr T0406 Data Transmittal Page 424 of 424 Project stage: Other L-MT-09-004, Enclosure 1 (Continued) to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 2, Copy of MNGP Appr T0406 Data Transmittal Pages 1 of 538 Through Pages 538 of 5382009-02-17017 February 2009 Enclosure 1 (Continued) to L-MT-09-004, NSPM Response to Containment & Ventilation Branch RAI Number 2, Copy of MNGP Appr T0406 Data Transmittal Pages 1 of 538 Through Pages 538 of 538 Project stage: Other ML0907106842009-02-17017 February 2009 Enclosures 2 - 4: NSPM Response to Containment & Ventilation Branch RAI Numbers 2, 3 and 4 Dated December 18, 2008 Project stage: Other L-MT-09-018, Response to NRC Steam Generator Tube Integrity & Chemical Engineering Branch Request for Additional Information (RAI) Dated February 11, 20092009-02-24024 February 2009 Response to NRC Steam Generator Tube Integrity & Chemical Engineering Branch Request for Additional Information (RAI) Dated February 11, 2009 Project stage: Request ML0907100912009-03-11011 March 2009 Conveying Draft RAI Questions from the Instrumentation and Controls Branch Regarding the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907200572009-03-12012 March 2009 Conveys Draft RAI Regarding Fire Protection for the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907800062009-03-18018 March 2009 Draft RAI from Probabilistic Risk Assessment Licensing Branch on the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907800042009-03-18018 March 2009 Conveys Draft RAI by the PRA Licensing Branch on the Proposed EPU Amendment Project stage: Draft RAI ML0907809032009-03-19019 March 2009 Conveys Draft RAI Provided by the Containment and Ventilation Branch on the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0907809092009-03-19019 March 2009 RAI from the Containment and Ventilation Branch the Proposed Extended Power Uprate Amendment Project stage: RAI L-MT-09-017, Extended Power Uprate: Response to NRC Reactor Systems Branch & Nuclear Performance & Code Review Branch Request for Additional Information (RAI) Dated January 16, 20092009-03-19019 March 2009 Extended Power Uprate: Response to NRC Reactor Systems Branch & Nuclear Performance & Code Review Branch Request for Additional Information (RAI) Dated January 16, 2009 Project stage: Request ML0908200312009-03-20020 March 2009 Draft RAI Re. Health Physics Issues for the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0908200992009-03-23023 March 2009 Draft RAI from the Balance of Plant Branch Re the Proposed Amendment on Extended Power Uprate Project stage: Draft RAI ML0908800022009-03-28028 March 2009 Second Portion of Draft RAI from the Mechanical and Civil Engineering Branch Regarding the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0908800032009-03-28028 March 2009 Draft RAI from the Electrical Engineering Branch Re. the Proposed Extended Power Uprate Amendment for Monticello Project stage: Draft RAI ML0908800012009-03-29029 March 2009 Additional Draft RAI Questions from the Containment and Ventilation Branch Proposed EPU Amendment for Monticello Project stage: Draft RAI ML0910300212009-04-0606 April 2009 Draft RAI Question from Instrumentation and Controls Branch Re. Proposed EPU Amendment Project stage: Draft RAI ML0910300172009-04-0606 April 2009 Conveys an Additional EPU Draft RAI Question from Instrumentation and Controls Branch Project stage: Draft RAI L-MT-09-025, Extended Power Uprate: Response to NRC Reactor Systems Branch and Nuclear Performance & Code Review Branch Request for Additional Information (RAI) Dated February 23, 20092009-04-22022 April 2009 Extended Power Uprate: Response to NRC Reactor Systems Branch and Nuclear Performance & Code Review Branch Request for Additional Information (RAI) Dated February 23, 2009 Project stage: Request ML0911205782009-04-22022 April 2009 Request for Audit of Implementation of Long-Term Stability Solution Project stage: Other ML0911902092009-04-29029 April 2009 Transmit Revised Draft RAI from the Probabilistic Risk Assessment Licensing Branch on the Proposed Extended Power Uprate Amendment Project stage: Draft RAI ML0914101232009-05-0606 May 2009 Monticello - Calculation 96-054, Rev 5, Turbine Stop Valve Closure/Generator Load Reject Scram Bypass Project stage: Other ML0911404702009-05-0707 May 2009 Determination That Submitted Information Can Be Withheld from Public Disclosure Project stage: Other ML0914101202009-05-13013 May 2009 Monticello - Extended Power Uprate: Response to NRC Instrumentation & Controls Branch Request for Additional Information Dated March 11, 2009, and April 6, 2009, and Fire Protection Branch RAIs Dated March 12, 2009 Project stage: Request L-MT-09-045, Extended Power Uprate: Response to NRC Electrical Engineering Review Branch (Eeeb) Request for Additional Information (RAI) Dated March 28, 20092009-05-26026 May 2009 Extended Power Uprate: Response to NRC Electrical Engineering Review Branch (Eeeb) Request for Additional Information (RAI) Dated March 28, 2009 Project stage: Request L-MT-09-029, Extended Power Uprate: Response to NRC Probabilistic Risk Assessment (PRA) Licensing Branch Request for Additional Information (RAI) Dated April 29, 20092009-05-29029 May 2009 Extended Power Uprate: Response to NRC Probabilistic Risk Assessment (PRA) Licensing Branch Request for Additional Information (RAI) Dated April 29, 2009 Project stage: Request 2009-02-24
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Category:Legal-Affidavit
MONTHYEARL-MT-23-030, Subsequent License Renewal Application Supplement 32023-07-0404 July 2023 Subsequent License Renewal Application Supplement 3 L-MT-23-013, Core Operating Limits Report (COLR) for Cycle 31, Revision 32023-03-28028 March 2023 Core Operating Limits Report (COLR) for Cycle 31, Revision 3 ML21211A5962021-06-30030 June 2021 Attachments 9a, B, 10a, B, 11a, 12a and 13a and 13b, Including ANP-3933NP, Revision 0, Monticello ATWS-I Evaluation for Atrium 11 Fuel, Affidavit L-MT-21-034, Affidavit for Cycle 31 Core Operating Limits Report - NAD-MN-047P2021-05-13013 May 2021 Affidavit for Cycle 31 Core Operating Limits Report - NAD-MN-047P L-MT-16-028, Transmittal of Extended Power Uprate, Extended Steam Dryer - Response to Requests for Additional Information2016-05-18018 May 2016 Transmittal of Extended Power Uprate, Extended Steam Dryer - Response to Requests for Additional Information ML15289A0732015-10-12012 October 2015 Submittal of Power Ascension Testing Results for Replacement Steam Dryer L-MT-15-065, Enclosure 8, Areva Report ANP-3424NP, Revision 1 to Areva Responses to RAI from Scvb on MNGP EFW LAR (Non-Proprietary) and Enclosure 9, Areva Affidavits2015-09-29029 September 2015 Enclosure 8, Areva Report ANP-3424NP, Revision 1 to Areva Responses to RAI from Scvb on MNGP EFW LAR (Non-Proprietary) and Enclosure 9, Areva Affidavits ML15348A2202015-08-26026 August 2015 Enclosure 9, Areva Affidavits ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow L-MT-14-060, Extended Power Uprate: Replacement Steam Dryer - Response to NRC Requests for Additional Information, Revised Limit Curves and Supporting Information2014-07-22022 July 2014 Extended Power Uprate: Replacement Steam Dryer - Response to NRC Requests for Additional Information, Revised Limit Curves and Supporting Information L-MT-14-016, Calculation 11042-0204, Revision 2, Structural and Allowable Flaw Size Evaluation of the Spent Fuel Storage Canisters with Nonconforming Closure Welds at Monticello Nuclear Generating Plant2014-07-0707 July 2014 Calculation 11042-0204, Revision 2, Structural and Allowable Flaw Size Evaluation of the Spent Fuel Storage Canisters with Nonconforming Closure Welds at Monticello Nuclear Generating Plant ML15348A2152014-07-0707 July 2014 Enclosure 4, General Electric Hitachi (GEH)- Affidavit L-MT-13-126, Enclosure 3, GE-MNGP-AEP-3306, Enclosure 2 GEH Response to Mella+ Eicb RAI and Affidavit2013-12-20020 December 2013 Enclosure 3, GE-MNGP-AEP-3306, Enclosure 2 GEH Response to Mella+ Eicb RAI and Affidavit ML13282A1412013-10-0404 October 2013 Maximum Extended Load Line Limit Analysis Plus License Amendment Request - Request for Additional Information Responses L-MT-13-070, Maximum Extended Load Line Limit Analysis Plus License Amendment Request - Request for Additional Information Responses2013-07-31031 July 2013 Maximum Extended Load Line Limit Analysis Plus License Amendment Request - Request for Additional Information Responses L-MT-13-059, Extended Power Uprate and Maximum Extended Load Line Limit Analysis Plus License Amendment Requests: Response to Request for Additional Information Reactor Systems Branch and Vessel & Internals Integrity Branch and Supplemental Informati2013-06-26026 June 2013 Extended Power Uprate and Maximum Extended Load Line Limit Analysis Plus License Amendment Requests: Response to Request for Additional Information Reactor Systems Branch and Vessel & Internals Integrity Branch and Supplemental Information L-MT-13-033, Extended Power Uprate: Secy 11-0014 Use of Containment Accident Pressure - Responses to Requests for Additional Information2013-03-21021 March 2013 Extended Power Uprate: Secy 11-0014 Use of Containment Accident Pressure - Responses to Requests for Additional Information ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit ML0923903232009-08-10010 August 2009 Enclosure 2 - Continuum Dynamics Affidavit ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference ML0413101222004-04-30030 April 2004 Request for Closed Meeting with USNRC to Discuss NMC Refueling Plans 2023-07-04
[Table view] Category:Letter
MONTHYEARML24025A9362024-01-31031 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0055 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) IR 05000263/20230042024-01-31031 January 2024 Integrated Inspection Report 05000263/2023004 ML24024A0722024-01-24024 January 2024 Independent Spent Fuel Storage Installation, Onticello, Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000263/20244012024-01-22022 January 2024 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000263/2024401 L-MT-23-054, Subsequent License Renewal Application Supplement 82024-01-11011 January 2024 Subsequent License Renewal Application Supplement 8 L-MT-23-047, License Amendment Request: Revision to the MNGP Pressure Temperature Limits Report to Change the Neutron Fluence Methodology and Incorporate New Surveillance Capsule Data2023-12-29029 December 2023 License Amendment Request: Revision to the MNGP Pressure Temperature Limits Report to Change the Neutron Fluence Methodology and Incorporate New Surveillance Capsule Data L-MT-23-056, Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 Part 22023-12-18018 December 2023 Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 Part 2 ML23349A0572023-12-15015 December 2023 and Independent Spent Fuel Storage Installation, Revision to Correspondence Service List for Northern States Power - Minnesota IR 05000263/20234022023-12-13013 December 2023 Security Baseline Inspection Report 05000263/2023402 L-MT-23-042, 2023 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.462023-12-11011 December 2023 2023 Annual Report of Changes in Emergency Core Cooling System Evaluation Models Pursuant to 10 CFR 50.46 L-MT-23-052, Subsequent License Renewal Application Supplement 72023-11-30030 November 2023 Subsequent License Renewal Application Supplement 7 L-MT-23-051, Update to the Technical Specification Bases2023-11-28028 November 2023 Update to the Technical Specification Bases L-MT-23-049, Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 12023-11-21021 November 2023 Subsequent License Renewal Application Response to Request for Additional Information and Request for Confirmation of Information - Set 1 ML23319A3182023-11-15015 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000263/20230032023-11-13013 November 2023 Integrated Inspection Report 05000263/2023003 and 07200058/2023001 L-MT-23-043, 10 CFR 50.55a(z)(1) Request Regarding OMN-17, Revision 1. VR-092023-11-13013 November 2023 10 CFR 50.55a(z)(1) Request Regarding OMN-17, Revision 1. VR-09 L-MT-23-038, License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.62023-11-10010 November 2023 License Amendment Request to Revise Monticello Technical Specification Surveillance Requirement 3.8.6.6 L-MT-23-046, Subsequent License Renewal Application Response to Request for Additional Information Round 2 - Set 12023-11-0909 November 2023 Subsequent License Renewal Application Response to Request for Additional Information Round 2 - Set 1 ML23291A1102023-10-23023 October 2023 Environmental Audit Summary and RCIs and RAIs ML23285A3062023-10-12012 October 2023 Implementation of the Fleet Standard Emergency Plan for the Monticello Nuclear Generating Plant and the Prairie Island Nuclear Generating Plant L-MT-23-041, Subsequent License Renewal Application Response to Request for Confirmation of Information Set 22023-10-0303 October 2023 Subsequent License Renewal Application Response to Request for Confirmation of Information Set 2 L-MT-23-037, Subsequent License Renewal Application Response to Request for Additional Information Set 32023-09-22022 September 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 3 ML23262B0372023-09-19019 September 2023 Response to NRC Request for Additional Information Regarding the 2023 Monticello and Prairie Island Plant Decommissioning Funding Status Reports ML23248A2092023-09-18018 September 2023 Proposed Alternative VR-11 to the Requirements of the ASME OM Code Associated with Periodic Verification Testing of MO-2397, Reactor Water Cleanup Inboard Isolation Valve ML23256A1682023-09-13013 September 2023 Independent Spent Fuel Storage Installation and Monticello Nuclear Generating Plant - Voluntary Security Clearance Program 2023 Insider Threat Program Self-Inspection IR 05000263/20230102023-09-0707 September 2023 Commercial Grade Dedication Inspection Report 05000263/2023010 L-MT-23-036, Subsequent License Renewal Application Response to Request for Additional Information Set 2 and Supplement 62023-09-0505 September 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 2 and Supplement 6 ML23214A2412023-08-31031 August 2023 Letter: Aging Management Audit - Monticello Unit 1 - Subsequent License Renewal Application IR 05000263/20230052023-08-30030 August 2023 Updated Inspection Plan for Monticello Nuclear Generating Plant (Report 05000263/2023005) L-MT-23-035, Subsequent License Renewal Application Supplement 52023-08-28028 August 2023 Subsequent License Renewal Application Supplement 5 ML23241A9732023-08-21021 August 2023 Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1, Subsequent License Renewal Application (Docket No. 50-263) L-MT-23-034, Subsequent License Renewal Application Response to Request for Additional Information Set 12023-08-15015 August 2023 Subsequent License Renewal Application Response to Request for Additional Information Set 1 ML23222A0122023-08-10010 August 2023 Independent Spent Fuel Storage Installation and Monticello Nuclear Generating Plant - Changes in Foreign Ownership, Control or Influence ML23215A1312023-08-0909 August 2023 License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application IR 05000263/20230022023-08-0707 August 2023 Plantintegrated Inspection Report 05000263/2023002 L-MT-23-028, 2023 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report2023-07-31031 July 2023 2023 Refueling Outage 90-Day Inservice Inspection (ISI) Summary Report L-MT-23-032, 10 CFR 50.55a(z)(2) Request Regarding MO-2397, VR-112023-07-31031 July 2023 10 CFR 50.55a(z)(2) Request Regarding MO-2397, VR-11 ML23198A0412023-07-28028 July 2023 LRA Availability Letter ML23206A2342023-07-25025 July 2023 Independent Spent Fuel Storage Installation, and Monticello Nuclear Generating Plant, Changes in Foreign Ownership, Control or Influence ML23201A0352023-07-24024 July 2023 Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information ML23202A0032023-07-21021 July 2023 Independent Spent Fuel and Independent Spent Fuel Storage Installation, Monticello Nuclear Generating Plant, Submittal of Quality Assurance Topical Report (NSPM-1) L-MT-23-031, Subsequent License Renewal Application Supplement 4 and Responses to Request for Confirmation of Information - Set 12023-07-18018 July 2023 Subsequent License Renewal Application Supplement 4 and Responses to Request for Confirmation of Information - Set 1 ML23195A1732023-07-14014 July 2023 Revision of Standard Practice Procedures Plan IR 05000263/20235012023-07-13013 July 2023 Emergency Preparedness Inspection Report 05000263/2023501 2024-01-31
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Text
ENCLOSURES 1 AND 3 CONTAIN PROPRIETARY INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390XcelEnergy Monticello Nuclear Generating Plant2807 W County Rd 75Monticello, MN 55362October 4, 2013 L-MT-1 3-09610 CFR 50.90U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Monticello Nuclear Generating PlantDocket 50-263Renewed License No. DPR-22
Subject:
Maximum Extended Load Line Limit Analysis Plus License Amendment Request -Request for Additional Information Responses (TAC ME3145)
References:
- 1) Letter from T J O'Connor (NSPM), to Document Control Desk (NRC),"License Amendment Request:
Maximum Extended Load Line LimitAnalysis Plus," L-MT-10-003, dated January 21, 2010. (ADAMSAccession No. ML100280558)
- 2) Email from K. Feintuch for T. Beltz (NRC) to J. Fields (NSPM),"Monticello Nuclear Generating Plant -Revised Draft Request forAdditional Information Associated with NRC Staff Review of theMELLLA+ License Amendment Request (TAC No. ME3145),"
datedSeptember 11,2013.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 allow operation in the expandedMaximum Extended Load Line Limit Analysis Plus (MELLLA+)
domain.In Reference 2 the NRC provided Requests for Additional Information (RAIs) pertaining to information needed to support MELLLA+ and analysis revisions.
The purpose of thisletter is to provide NSPM's responses to the Reference 2 RAIs.Enclosure 1 provides a report from General Electric
-Hitachi (GEH) letter,GE-MNGP-AEP-3304R1, "GEH Response to MELLLA+ RAI 2." Enclosure 1 containsproprietary information.
Document Control DeskPage 2Enclosure 2 provides a non-proprietary copy of the Enclosure 1 RAI responses.
Thenon-proprietary copy of the RAI responses is being provided based on the NRC'sexpectation that the submitter of the proprietary information should provide, if possible, a non-proprietary version of the document with brackets showing where the proprietary information has been deleted.Enclosure 3 provides page changes to the MELLLA+ Safety Analysis Report (NEDC-33435P).
These page changes are based on corrections and changes in the analysispresented in Enclosure
- 1. Enclosure 3 contains proprietary information.
Enclosure 4 provides a non-proprietary version of Enclosure 3.Enclosure 5 provides an affidavit executed to support withholding Enclosures 1 and 3from public disclosure.
Information in Enclosures 1 and 3 contain proprietary information as defined by 10 CFR 2.390. The affidavit sets forth the basis on which theinformation may be withheld from public disclosure by the NRC and addresses withspecificity the considerations listed in 10 CFR 2.390(b)(4).
Accordingly, NSPMrespectfully requests that the proprietary information in Enclosures 1 and 3 be withheldfrom public disclosure in accordance with 10 CFR 2.390(a)4, as authorized by10 CFR 9.17(a)4.
Correspondence with respect to the copyright or proprietary aspects of GEH information or the supporting GEH affidavit in Enclosure 5 should be addressed to Peter M.Yandow, Vice President, Nuclear Plant Projects/Services Licensing, Regulatory Affairs,GE-Hitachi Nuclear Energy Americas LLC, 3901 Castle Hayne Road, Wilmington, NC28401.Enclosure 6 contains a response to RAI 1 from Reference 2 and a commitment associated with the MELLLA+ analysis implementation.
The supplemental information provided herein does not change the conclusions of theNo Significant Hazards Consideration and the Environmental Consideration evaluations provided in Reference 1 for the MELLLA+ license amendment request.In accordance with 10 CFR 50.91(b),
a copy of this application supplement, withoutenclosures is being provided to the designated Minnesota Official.
Summary of Commitments This letter makes the following new commitment:
NSPM commits to train and test licensed reactor operators to initiate Monticello Nuclear Generating Plant feedwater flow reduction in less than or equal to 90seconds to support the MELLLA+ Anticipated Transient without Scram Instability analysis.
Document Control DeskPage 3I declare under penalty of perjury that the foregoing is true and correct.Executed on: October 2013KarenbD FiliSite Vice-President Monticello Nuclear Generating PlantNorthern States Power Company-Minnesota Enclosures (6)cc: Regional Administrator, Region III, USNRC (w/o enclosures)
Project Manager, Monticello Nuclear Generating Plant, USNRCResident Inspector, Monticello Nuclear Generating Plant, USNRC (w/oenclosures)
Minnesota Department of Commerce (w/o enclosures)
L-MT-1 3-096ENCLOSURE 5GENERAL ELECTRIC
-HITACHI AFFIDAVIT FORWITHHOLDING PROPRIETARY INFORMATION 3 pages follow GE-Hitachi Nuclear Energy Americas LLCAFFIDAVIT I, Peter M. Yandow, state as follows:(1) I am the Vice President, Nuclear Plant Projects/Services Licensing, Regulatory
- Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function ofreviewing the information described in paragraph (2) which is sought to be withheld, andhave been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Enclosures I and 3 of GEH letter,GE-MNGP-AEP-3304R1, "GEH Response to MELLLA Plus Requests for Additional Information,"
dated October 3, 2013. The GEH proprietary information in Enclosure 1,which is entitled "GEH Response to MELLLA+ RAI 2," and Enclosure 3 which is entitled"NEDC-33435P Corrected Pages," is identified by a dark red dotted underline inside doublesquare brackets.
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.Figures containing GEH proprietary information are identified with double square brackets before and after the object. In eachcase, the superscript notation 131 refers to Paragraph (3) of this affidavit that provides thebasis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is theowner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedomof Information Act (FOIA), 5 U.S.C. Sec. 552(b)(4),
and the Trade Secrets Act, 18 U.S.C.See. 1905, and NRC regulations 10 CFR 9.17(a)(4),
and 2.390(a)(4) for trade secrets(Exemption 4). The material for which exemption from disclosure is here sought alsoqualifies under the narrower definition of trade secret, within the meanings assigned tothose terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass EnergyProiect v. Nuclear Regulatory Commission, 975 F.2.d 871 (D.C. Cir. 1992), and PublicCitizen Health Research Group v. FDA, 704 F.2.d 1280 (D.C. Cir. 1983).(4) The information sought to be withheld is considered to be proprietary for the reasons setforth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit intothe definition of proprietary information are:a. Information that discloses a process, method, or apparatus, including supporting dataand analyses, where prevention of its use by GEH's competitors without license fromGEH constitutes a competitive economic advantage over GEH or other companies.
- b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture,
- shipment, installation, assurance of quality, or licensing of a similar product.c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, that may include potential products of GEH.Affidavit for GE-MNGP-AEP-3304R1 Page I of 3 GE-Hitachi Nuclear Energy Americas LLCd. Information that discloses trade secret or potentially patentable subject matter forwhich it may be desirable to obtain patent protection.
(5) To address 10 CFR 2.390(b)(4),
the information sought to be withheld is being submitted tothe NRC in confidence.
The information is of a sort customarily held in confidence byGEH, and is in fact so held. The information sought to be withheld has, to the best of myknowledge and belief, consistently been held in confidence by GEH, not been disclosed
- publicly, and not been made available in public sources.
All disclosures to third parties,including any required transmittals to the NRC, have been made, or must be made, pursuantto regulatory provisions or proprietary or confidentiality agreements that provide formaintaining the information in confidence.
The initial designation of this information asproprietary information, and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in the following paragraphs (6) and (7).(6) Initial approval of proprietary treatment of a document is made by the manager of theoriginating component, who is the person most likely to be acquainted with the value andsensitivity of the information in relation to industry knowledge, or who is the person mostlikely to be subject to the terms under which it was licensed to GEH. Access to suchdocuments within GEH is limited to a "need to know" basis.(7) The procedure for approval of external release of such a document typically requires reviewby the staff manager, project manager, principal scientist, or other equivalent authority fortechnical
- content, competitive effect, and determination of the accuracy of the proprietary designation.
Disclosures outside GEH are limited to regulatory bodies, customers, andpotential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary or confidentiality agreements.
(8) The information identified in paragraph (2) above is classified as proprietary because itcontains results of an analysis performed by GEH to support the Monticello MaximumExtended Load Line Limit Analysis Plus (MELLLA+)
license application.
This analysis ispart of the GEH MELLLA+ methodology.
Development of the MELLLA+ methodology and the supporting analysis techniques and information, and their application to the design,modification, and processes were achieved at a significant cost to GEH.The development of the evaluation methodology along with the interpretation andapplication of the analytical results is derived from the extensive experience database thatconstitutes a major GEH asset.(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities.
The information is part of GEH's comprehensive BWR safety andtechnology base, and its commercial value extends beyond the original development cost.The value of the technology base goes beyond the extensive physical database andAffidavit for GE-MNGP-AEP-3304R1 Page 2 of 3 GE-Hitachi Nuclear Energy Americas LLCanalytical methodology and includes development of the expertise to determine and applythe appropriate evaluation process.
In addition, the technology base includes the valuederived from providing analyses done with NRC-approved methods.The research, development, engineering, analytical and NRC review costs comprise asubstantial investment of time and money by GEH. The precise value of the expertise todevise an evaluation process and apply the correct analytical methodology is difficult toquantify, but it clearly is substantial.
GEH's competitive advantage will be lost if itscompetitors are able to use the results of the GEH experience to normalize or verify theirown process or if they are able to claim an equivalent understanding by demonstrating thatthey can arrive at the same or similar conclusions.
The value of this information to GEH would be lost if the information were disclosed to thepublic. Making such information available to competitors without their having beenrequired to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these veryvaluable analytical tools.I declare under penalty of perjury that the foregoing affidavit and the matters stated therein aretrue and correct to the best of my knowledge, information, and belief.Executed on this 3rd day of October, 2013.Peter M. YandowVice President, Nuclear Plant Projects/Services Licensing Regulatory AffairsGE-Hitachi Nuclear Energy Americas LLC3901 Castle Hayne RdWilmington, NC 28401Peter.Yandow@ge.com Affidavit for GE-MNGP-AEP-3304R1 Page 3 of 3 L-MT-1 3-096ENCLOSURE 6MAXIMUM EXTENDED LOAD LINE LIMIT PLUS (MELLLA+)
REQUEST FOR ADDITIONAL INFORMATION This enclosure provides a response from the Northern States Power Company, aMinnesota corporation (NSPM), doing business as Xcel Energy, to a request foradditional information (RAI) provided by the Nuclear Regulatory Commission (NRC) inReference 1.NRC RequestThe failure of the reactor to shut down during certain transient can lead to unacceptable reactor coolant system pressure, fuel conditions, and/or containment conditions.
Provide a training schedule and tracking method to train operators on the importance oftaking action within 90 seconds to mitigate an A TWS event.NSPM ResponseThe current MELLLA+ Anticipated Transient Without Scram (ATWS) Instability (ATWSI)analysis demonstrates acceptable performance and resulting fuel protection whenoperators initiate actions to reduce feedwater flow to the reactor vessel in less than orequal to 90 seconds of the onset of an ATWS event initiation.
The Monticello Nuclear Generating Plant (MNGP) Time Critical Operator Actions(TCOA) procedures identify tasks contained in the plant's operating procedures that arecredited by the design and licensing basis to be accomplished in a specified time. Forthe ATWS event at MNGP, operators are currently required to reduce feedwater flow in78 seconds.
Training for operators, validation of satisfactory performance of the TCOAby operators and periodic validation of the equipment necessary to perform TCOAs areall required and controlled by the TCOA procedures.
Currently, operator training on MELLLA+ revisions to the design and licensing basis arescheduled to be completed by October 4, 2013. The Simulator Exercise Guide (SEG),used for training and verification of operator compliance with the TCOA, requires thatthe feedwater reduction step be completed in less than or equal to 90 seconds of theonset of an ATWS event.To ensure continued future compliance of the performance of the ATWS feedwater flowreduction TCOA, NSPM is providing the following commitment:
Page 1 of 2 L-MT-1 3-096NSPM commits to train and test licensed reactor operators to initiate Monticello Nuclear Generating Plant feedwater flow reduction in less than or equal to 90seconds to support the MELLLA+ Anticipated Transient without Scram Instability analysis.
References 1 -Email from K. Feintuch for T. Beltz (NRC) to J. Fields (NSPM), "Monticello NuclearGenerating Plant -Revised Draft Request for Additional Information Associated withNRC Staff Review of the MELLLA+ License Amendment Request (TAC No.ME3145),"
dated September 11, 2013.Page 2 of 2