ML14036A100

Brunswick Steam Electric Plant, Unit 1, Submittal of Confirmatory Evaluation for Unit 1 Cycle 20

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

Text

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

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

Subject:

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

References:

1. Letter from Christopher Gratton (NRC) to Michael J. Annacone (CP&L), "Brunswick Steam Electric Plant, Units 1 and 2 -Issuance of Amendments Regarding Addition ofAnalytical Methodology Topical Report to Technical Specification 5.6.5 and Revision toMinimum Critical Power Ratio Safety Limit (TAC Nos. ME8135 and ME8136),"

datedMarch 1, 2013, ADAMS Accession Number ML13037A551 Ladies and Gentlemen:

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

These amendments included a licensecondition in Appendix B, "Additional Conditions,"

to require Safety Limit Minimum Critical PowerRatio (SLMCPR),

setpoint, and core operating limit values be evaluated with methods described in an AREVA Operability Assessment to verify the values determined using the NRC-approved method remain applicable and the core operating limits include margin sufficient to bound theeffects of a K-factor calculation issue described in AREVA Operability Assessment CR 2011-2274, Revision 1.The results of the evaluation are required to be submitted to the NRC, for review, at least60 days prior to startup of each operating cycle. Based on planned return-to-service date ofMarch 30, 2014, for the upcoming BSEP Unit 1 Cycle 20 refueling outage, submittal of theseUnit 1 evaluation results is required by January 29, 2014.The evaluation results are documented in an AREVA report titled "Operability Assessment (CR #2013-8241),"

a copy of which is provided in Enclosure

1. This Operability Assessment report contains information that AREVA considers proprietary, as defined by 10 CFR 2.390.AREVA, as the owner of that proprietary information, has executed the affidavit provided inEnclosure 2 and stated that the identified proprietary information has been handled andclassified as proprietary, is customarily held in confidence, and has been withheld from publicdisclosure.

AREVA requests that the identified proprietary information be withheld from public U.S. Nuclear Regulatory Commission Page 2 of 3disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of theOperability Assessment (CR #2013-8241) is provided in Enclosure 3.This document contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager -Regulatory

Affairs, at (910) 457-2487.

Sincerely, Anne te H. PopeManager -Organizational Effectiveness Brunswick Steam Electric PlantWRM/wrm

Enclosure:

1. Operability Assessment (CR #2013-8241)

(Proprietary Information

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

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

U.S. Nuclear Regulatory Commission Page 3 of 3cc (with Enclosures 1, 2, and 3):U. S. Nuclear Regulatory Commission, Region IIATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Siva P. Lingam (Mail Stop OWFN 8G9A)11555 Rockville PikeRockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River RoadSouthport, NC 28461-8869 cc (with Enclosures 2 and 3):Chair -North Carolina Utilities Commission P.O. Box 29510Raleigh, NC 27626-0510 BSEP 14-0007Enclosure 2AREVA Affidavit Regarding Withholding Operability Assessment (CR #2013-8241)

AFFIDAVIT STATE OF WASHINGTON

)) ss.COUNTY OF BENTON )1. My name is Alan B. Meginnis.

I am Manager, Product Licensing, for AREVANP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whethercertain AREVA NP information is proprietary.

I am familiar with the policies established byAREVA NP to ensure the proper application of these criteria.

3. I am familiar with the AREVA NP information contained in the Operability Assessment for Condition Report 2013-8241,

entitled, "Operability Assessment (CR #2013-8241)," and referred to herein as "Document."

Information contained in this Document has beenclassified by AREVA NP as proprietary in accordance with the policies established by AREVANP for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential natureand is of the type customarily held in confidence by AREVA NP 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 Regulatory Commission in confidence with the request that the information contained in this Document bewithheld from public disclosure.

The request for withholding of proprietary information is madein accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4)

'Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA NP's research and development plans and programs or their results.(b) Use of the information by a competitor would permit the competitor 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 AREVA NP.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitive advantage for AREVA NP in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA NP, wouldbe helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.The information in the Document is considered proprietary for the reasons set forth inparagraphs 6(b), 6(d) and 6(e) above.7. In accordance with AREVA NP's policies governing the protection and controlof information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP policy requires that proprietary information be kept in a securedfile 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 thisday of 0-9-ý , 2013,MY COMMISSION EXPIRES:

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