ML13282A141

Maximum Extended Load Line Limit Analysis Plus License Amendment Request - Request for Additional Information Responses

ML13282A141
Person / Time
Site:	Monticello
Issue date:	10/04/2013
From:	Fili K D Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-13-096, TAC ME3145
Download: ML13282A141 (9)

Text

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-22Subject: Maximum Extended Load Line Limit Analysis Plus License AmendmentRequest -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 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.

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.

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)

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