ML15356A184

St. Lucie, Unit 2 - RAI Response for Snpb RAI-9 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel

ML15356A184
Person / Time
Site:	Saint Lucie
Issue date:	12/08/2015
From:	Costanzo C R Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15356A251	List: L-2015-300, ANP-3352NP, Revision 1, Transition License Amendment Request, Technical Report. ML15356A184 ML15356A185
References
L-2015-300, TAC MF5494, TAC MF5495
Download: ML15356A184 (5)

Text

0 Contains ProprietarySP'~cler eu latory ommissionDocument Control DeskWashington, DC 20555-0001Information -Withhold per 10 CFR 2.390December 8, 2015L-20 15-30010 CFR 50.90RE: St. Lucie Unit 2Docket No. 50-389RAI Response for SNPB RAI-9 for the Technical Specification LAR and ExemptionRequest Regarding the Transitioning to AREVA Fuel

References:

l. FPL letter L-20 14-366 dated December 30, 2014, "Application for TechnicalSpecification Change and Exemption Request Regarding the Transitioning toAREVA Fuel," Accession No. ML15002A0912. FPL letter L-2015-091 dated March 23, 2015, "Supplemental Information forTechnical Specification Change and Exemption Request Regarding the Transitioningto AREVA Fuel," Accession No. ML 15084A01 13. NRC letter dated May 12, 2015, "St. Lucie Plant, Unit No. 2 -Request for AdditionalInformation Regarding License Amendment Request and Exemption Request-Regarding the Transitioning to AREVA Fuel (TAC NOS. MF5494 AND MF5495),"Accession No. ML1 1127A4054. FPL Letter L-2015-166 dated June 2, 2015, "RAI Reply for Application forTechnical Specification Change and Exemption Request Regarding the Transitioningto AREVA Fuel," Accession No. ML 15161 A3165. FPL Letter L-2015-177 dated June 18, 2015, "Resubmittal of the AREVA SmallBreak LOCA Summary Report Within the Application for Technical SpecificationChange and Exemption Request Regarding the Transitioning to ARE VA Fuel,"Accession No. ML15181A2906. NRC Letter dated June 24, 2015, "St. Lucie Plant, Unit 2 -Request for AdditionalInformation Regarding License Amendment Request and Exemption RequestRegarding the Transitioning to AREV A Fuel (TAC Nos. MF5494 and MF5495),"Accession No. ML1 1166A3687. FPL Letter L-2015-206 dated July 30, 2015, "RAI Response to SNPB-RAI-1 for theTechnical Specification LAR and Exemption Request Regarding the Transitioning toAREVA Fuel," Accession No. ML 1521 9A1 848. NRC Letters dated September 4, 2015, "St. Lucie Plant, Unit No. 2 -Request forAdditional Information Regarding License Amendment Request and ExemptionRequest Regarding the Transitioning to AREVA Fuel (TAC Nos .MF5494 ANDMF5495)," Accession Nos. ML 1 5233A03 1 and ML 1523 3A03 69. FPL Letter L-2015-259 dated October 2, 2015, "RAI Response to SRXB-RAI-1 andSNPB RAI-2 thru RAI-20 for the Technical Specification LAR and ExemptionRequest Regarding the Transitioning to AREVA Fuel," Accession No.ML 1 5279A22610. FPL Letter L-2015-279 dated November 3, 2015, "RAI Response Clarification for oti proprietary information per 10 CFR 2.390, upon removal, this document is -uncontrolled6501 S. Ocean Drive, Jensen Beach, FL 34957 L-2015-300Page 2SRXB-RAI-1 and SNPB RAI-2 thru RAI-20 for the Technical Specification LARand Exemption Request Regarding the Transitioning to AREVA Fuel," AccessionNo. ML 15322A134Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) submitted via Reference 1and supplemented via Reference 2 a license amendment to the Technical Specifications (TS)for St. Lucie Unit 2 to allow the use of AREVA fuel. References 4, 7 and 9 provided theresponses to the NRC requests for additional information (RAIs) contained in References 3, 6and 8. Reference 5 modified theproprietaiyz markings contained in the SBLOCA summaryreport. Reference 10 provided clarifications and justification for the Westinghouseproprietary information provided in ANP-3440P, Revision 1 included in Reference 9.The NRC transmitted additional RAIs in Reference 8 for which responses were provided inReference 9, excluding the response to SNPB RAI-9. This letter provides the response to SNPBRAI-9 in ANP-3456, which addresses in detail the seismic/LOCA issue discussed in Reference 9and the actions taken to resolve the issue. The details of the work performed are described inANP-3456, Section 1.0. In addition, AREVA licensing report ANP-3352, Revision 1 is alsoincluded due to the updated seismic/LOCA analysis results, and the previously transmitted (inReference 9) revised SBLOCA results. The changes to ANP-3352 are identified in the revisionsummary section of the revised report ANP-3352, Revision 1. The original no significanthazards evaluation conclusions remain unchanged by these RAI replies.Executed on c¢ 8 , 2015.Sincerely,Christopher R. CostanzoSite Vice PresidentSt. Lucie PlantCRCiKWFAttachments1. Affidavit for withholding the supporting proprietary ARE VA licensing report ANP-3456P from the public.2. Proprietary AREVA licensing report, ANP-3456P, Revision 0.3. Non-proprietary version of the ARE VA licensing report, ANP-3456NP, Revision 0.4. Affidavit for withholding the supporting proprietary AREVA technical report ANP-3352P, Revision 1 from the public.5. Proprietary ARE VA technical report, ANP-3352P, Revision 1.6. Non-proprietary version of the AREVA technical report, ANP-3352NP, Revision 1.cc: USNRC Regional Administrator, Region IIUSNRC Senior Resident Inspector, St. Lucie Nuclear PlantMs. Cindy Becker, Florida Department of Health (w/o attachments)

L-2015-300Attachment 1Page 1 of 3AFFIDAVITCOMMONWEALTH OF VIRGINIA )) 55.CITY OF LYNCHBURG)1. My name is Nathan S. Hottle. I am Manager, Product Licensing, for AREVAInc. (AREVA) and as such I am authorized to execute this Affidavit.2. I am familiar with the criteria applied by AREVA to determine whether certainAREVA information is proprietary. I am familiar with the policies established byAR EVA to ensure the proper application of these criteria.3. I am familiar with the AREVA information contained in the following document:"ANP-3456P Revision 0, Response to SLU2 NRC SNPB RAI-9," referred to herein as"Document." Information contained in this Document has been classified by AREVA asproprietary in accordance with the policies established by AREVA Inc. for the contmol andprotection 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 and not made available to thepublic..Based on my experience, I am aware that other companies regard information of thekind contained in This Document as proprietary and confidential.5. This Document has been made available to the U.S. Nuclear RegulatoryCommission in confidence with the request that the information contained in this Document bewithheld from public disclosure. The request for withholding of proprietary information is made inaccordance with 10 CFR 2.390. The information for which withholding from disclosure is L-2015-300Attachment 1Page 2 of 3requested qualifies under 10 CFR 2.390(a)(4) 'Trade secrets and commercial or financialinformation."6. The following criteria are customarily applied by AREVA to determine whetherinformation should be classified as proprietary:(a) The information reveals details of AREVA's research and development plansand programs or their results.(b) Use of the information by a competitor would permit the competitor tosignificantly reduce its expenditures, in time or resources, to design, produce,or market a similar product or service.(c) The information includes test data or analytical techniques concerning aprocess, methodology, or component, the application of which results in acompetitive advantage for AREVA.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitive advantage for AREVA in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA, would behelpful to competitors to AREVA, and would likely cause substantial harm tothe competitive position of AREVA.The information in this Document is considered proprietary for the reasons set forth inparagraphs 6(c) and 6(d) above.7. In accordance with AREVA's policies governing the protection and control ofinformation, proprietary information contained in this Document has been made available, on alimited basis, to others outside AREVA only as required and under suitable agreement providingfor nondisclosure and limited use of the information.8. AREVA policy requires that proprietary information be kept in a secured file orarea and distributed on a need-to-know basis.

L-2015-300Attachment 1Page 3 of 39. The foregoing statements are true and correct to the best of my knowledge,information, and belief.SUBSCRI BED before me this .A Lday of. NSherry L. McFadenNOTARY PUBLIC, COMMONWEALTH OF VIRGINIAMY COMMISSION EXPIRES: 10/31118Reg. # 7079129A SII MCAUJ- Put Wlc l