LD-87-019, Forwards Proprietary CENPD-275-P, C-E Methodology for Core Designs Containing Gadolinia-Urania Burnable Absorbers, in Support of Facility May 1989 Cycle 5 Startup.Fee Paid.Rept Withheld (Ref 10CFR2.790)

Forwards Proprietary CENPD-275-P, C-E Methodology for Core Designs Containing Gadolinia-Urania Burnable Absorbers, in Support of Facility May 1989 Cycle 5 Startup.Fee Paid.Rept Withheld (Ref 10CFR2.790)

ML20209C302
Person / Time
Site:	Saint Lucie
Issue date:	04/22/1987
From:	Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Funches J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
Shared Package
ML19292H156	List: LD-87-019, Forwards Proprietary CENPD-275-P, C-E Methodology for Core Designs Containing Gadolinia-Urania Burnable Absorbers, in Support of Facility May 1989 Cycle 5 Startup.Fee Paid.Rept Withheld (Ref 10CFR2.790)
References
LD-87-019, LD-87-19, NUDOCS 8704280645
Download: ML20209C302 (6)

Text

COIRBUSTION ENGINEERING April 22,1987 LD-87-019 Mr. Jesse L. Funches, Chief Policy Developuent and Technical Support Branch Office of Nuclear Reactor Regulation Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Analysis Methods for Gadolinium Bearing Fuel

Enclosures:

(1) CENPD-275-P, C-E Methodology for Core Designs Containing Gadolinia-Urania Burnable Absorbers, (Copy Nos.00001-00023)

(2) Proprietary Affidavit (3) Check for Application Fee

Dear Mr. Funches:

I The purpose of this letter is to submit to the NRC a topical report describing Combustion Engineering's (C-E) analysis methods for assessing the performance of Gadolinium bearing fuel. To this end, twenty three (23) copies of CENPD-275-P "C-E Methodology for Core Designs Containing ,

Gadolinia-Urania Burnable Absorbers", are provided herewith as Enclosure (1).  !

l The report describes the models, analysis methods and procedures C-E will l employ in the neutronics and fuel performance analyses used to design and license fuel containing Gadolinium burnable absorbers. Information contained in the enclosed topical report is considered by Combustion Engineering to be proprietary in nature. As such, we request that it be withheld from public disclosure in accordance with the provisions of 10CFR2.790 and that this material be safeguarded. The reasons for the classification of this material as propriehry are delineated in the affidavit provided in Enclosure (2).

o-ryg Combustion Engineering intends to apply the methodology described in the rd o c. subject topical report in support of a reload fuel application employing 88 Gadolinia-Urania fuel in Florida Power and Light Company's St. Lucie Unit M 2 plant during Cycle 5. We, therefore, request that your review and approval be completed prior to January,1988 to allow sufficient time to eu support a May 1989 Cycle 5 startup. Additionally, while St. Lucie Unit 2 88 (D <

Q Power Systerns 1000 Prospect Hill Road (203) 688 1911 o c: Combustion Engineering, Inc. Post Office Box 500 Telex: 99297 bQ Win r, Connecticut 06095-0500 ly t.)f $* l0 9Y l

Mr. Jesse Funches LD-87-019 April 22,1987 Page 2 will be the first application of the methodology described in CENPD-275-P, C-E is conducting discussions with the Baltimore Gas and Electric Company and the Southern California Edison Company regarding Gadolinia-Urania reload cores at their Units. Interest expressed to date leads us to believe that there is a high likelihood for generic application of the methods described. A check [ Enclosure (3)] in the amount of $150.00 is also provided to cover the application fee.

If you have any questions regarding this matter, please do not hesitate to call me or Mr. C.M. Molnar of my staff at (203) 285-5205.

Very truly yours, COMBUSTION ENGINEERING, INC.

a$

A. E."ScYerer Director Nuclear Licensing AES:ss Enclosures xc: Mr. J. Perryman, FPL l

l I

AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering,.Inc. )

State of Connecticut )

' County of Hartford .) SS.:

I, A.E. Scherer, depose and say that I am the Director, Nuclear Licensing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or carased to have reviewed the information which is identified as proprietary and referenced in the parag,aph immediately below. I am submitting this affidavit in conformance with th'e provisions of 10 CFR 2.790 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought is contained in the following document:

CENPD-275-P, C-E Methodology for Core Designs Containing Gadolinia-Urania Burnable Absorbers, March 1987 This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential commercial of financial information.

)

Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the  !

Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld. j

=

- -. . - . . ~ ..

I ~ p 1. The information sought to.be withheld from public' disclosure are test' data and a'alysis methods for the performance of safety evaluations of

~

n Gadolinium bearing fuel, which is owned and has been held in confidence _by

, ~ Combustion Engineering.

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2. The information consists of test' data or other similar data concerning a.

process, method or component, the application of which; results in substantial competitive advantage to Combustion Engineering.

3. The information is of a type customarily held in confidence by Combustion l

, Engineering and not customarily disclosed to the public. Combustion '

i Engineering has a rational basis for determining the types of information-customarily held in confidence by it and, in that connection, utilizes a system to determine when. and whether to hold certain types of information in i

confidence. The details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F. M. Stern to Frank 1 Schroeder dated December 2, 1974. This system was applied in determining that the subject document herein are proprietary.

4. The information is being transmitted to the Commission in confidence

~

under the provisions of 10 CFR 2.790 with the understanding that it is to be l received in confidence by the Commission.

l

5. The information, to the best of my knowledge and belief,_is not available in public sources, and any disclosure to third parties has been made pursuant.

to regulatory provisions or proprietary ag* cements which provide for f- maintenance of the information in conf W ect

6. Public. disclosure of the inforu % 1on  ; likely to cause substantial harm l to the competitive position of Combustion Engineering because:

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F a. A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.

b. Development of this information by C-E required thousands of manhours and hundreds of thousands of dollars. To the best of my knowledge and belief a competitor would have to undergo similar expense in generating equivalent information.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of test data and analysis methods for performing safety evaluations of Gadolinium bearing fuel.

d. The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.

Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable.

e. The information consists of test data and analysis methods for the performance of safety evaluations of Gadolinium bearing fuel, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus,

f. In pricing Combustion Engineering's products and services, significant research, development, engineering, analyti al, manufacturing, i licensing, quality assurance and other costs and expenses must be included.

The ability of. Combustion Engineering's competitors to utilize such

. _ . _~ __. _ _ _ _ _ . _ . .__

information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.

g. Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development.

In addition, disclosure would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

_2ff T.E. St!Ferer Director Nuclear Licensing Sworntopeforeme -

this R2"llay of Agt<.I, /f P2 w

Notary Public SUSANNE SMITH, NOTARY PUBUC State of Connect: cut No. 74148 Comm!ssion Expires March 31,1990 l

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