ML17194A421

Forwards XN-NF-81-84(P), Dresden Unit 3 Analysis for Reduced Flow Operation, Supporting Util 820111 Request for Tech Spec Change to Allow Use of Fuel Assemblies Designed & Mfg by Exxon Nuclear Co.Rept Withheld (Ref 10CFR2.790)

ML17194A421
Person / Time
Site:	Dresden
Issue date:	01/21/1982
From:	Rausch T COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML17194A422	List: ML17194A421
References
NUDOCS 8201260040
Download: ML17194A421 (5)

Text

j v' ** Commonwealth Edison One First National Plaza, Chicago, Illinois Address Reply to: Post Office Box 767 Chicago, lllinois'60690 January 21, 1982 RECBV£D JAN2St982*

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Dresden Station Unit 3 Supplementary Information Concerning Proposed Technical Specifi~ations to Support Operation with Fuel Supplied By Exxon Nuclear Company NRC Docket No. 50-249 Reference (a): T. J. Rausch letter to H. R.

Denton dated January 11, 1982.

J

Dear Mr. Denton:

~n Reference (a), Commonwealth Edison proposed to amend Appendix A, Technical Specifications, to Dresden Unit 3 Facility Operating License DPR-25 in order to allow the use of fuel assem-blies designed and manufactured by Exxon Nuclear Co. (Enc). In Attachment l to Reference (a), we indicated that the ENC technical report describin~ transient analyses for reduced flow operation w6uld be submitted at a later date.

Accordingly we have provided in Attachment 2 to *this letter, the ENC proprietary report entitled "Dresden Unit 3 Analysis for Reduced Flow Operation," XN-NF-81-84(P). This report is accom-panied by an affidavit (Attachment 1) signed by ENC, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commiision, and addresses with specificity the considerations listed in Paragraph (b)(4) of Section 2.790 of the Commission's regulations.

It is, therefore, respectfully requested that the information which is proprietary to Exxon Nuclear Company, Inc. be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's regulations. Correspondence with respect to the proprietary aspects of this application for withholding or the supporting ENC affidavit should be addressed to G. F. Owsley, Manager of Reload Fuel Licensing, Exxon Nuclear Company, 2101. Horn Rapids Road, P.O. Box 130, Richland, Washington 99352.

i H. R. Denton January 21, 1982 One (1) signed original .and thirty-nine (39) copies of this transmittal letter are provided for your use. In addition, six (6) copies of this ietter with proprietary Attachment 2 and the affidavit of Attachment 1 are also being provided at this time. The non-pro-prietary version of Attachment 4 will be transmitted under separate cover.

If you have any questions on this matter, please contact

• this office.

Very truly* yo~rs,

~~Rq .

Thomas J. Rausch Nuclear Licensing Administrator cc: Region III Inspebtor - Dresden (w/o Att.)

TJR/lm Attachments (1): *Affidavit of James N. Morgan attesting to the proprietary nature of XN-NF-81-84(P) dated January 8, 1982.

(2): XN-NF~81-84(P), Dresden Unit 3 Analysis for Reduced Flow

.Operation.

3290N

A F F I DA V I T

- STATE OF Washingtori SS.

COUNTY OF Benton I, James N. Mor*g~~-' being duly s~orn; -her~by 'say* a~d depos~: .

1. I am.Manager, _Licensing.and Safety_. Engineering, for Exxon

--~

Nuclear Company, Inc. ( ENC 11 1

-) ,' ~nd* as such I arr) author.ized to *e*xecute this Affidavit.

2. I am familiar with ENC's detailed document control system and policies which govern th~ protectio~*and control pf information.

• 3. *I am familiar with the document XN-NF-81-84(P)-, entitled "Dresden Unit J Analyses* for .Reduced Flow Operation, 11* referred to as*

11 Document. 11 Information c.ontained in this.Document has been classified by ENC as propri~tary in accorda~ce with the control syst~m and policies established*

by ENC _for the control and protection of information.

4. The pocument co~tains i~formation of a proprietary and con-fidential natu~e and is of the type customarily held in-confidence by ENC and not made available to th~ public. Based on*my experience, I am aware that other companfos* regard information of the kind contained in the Document as being proprietary and confidential.

5. The Document has been- made available to the United States Nuclear Regulatory Commission in confidence, with the request that the information contained in the Document not be disclosed or divulged.

.e 6. The Docu~ent contains information which is vital to a com-petitive advantage of ENC and would~e helpful to ~ompetiiors pf ENC.when

. competing.with ENC.

7. The information contained in the Document is considered to be proprietary bj ENC because it reveals certain ~istinguishing aspe~t~ of plant transi~n*t analysis methodology and results .which sec*ure competitive economic advantage to ENC for fuel de~ign optimization and improved market-abi l i~y, and includes information utilized by ENC i~ its businesi which.

affords ENC an opportunHy to obtain a competitive advantage ave( its Gorn-

• peti~ors who do not or may not know or use *fhe i~formation contai~ed iri.the.

Document.

8. The disc'losure of the proprietary informatio_n contajned in* the

.'oocuinent"to a competitor would permit the competitor to red~ce its expenditure,.

of money. and manpower and to improve .its competitive position by giving it ..

• ' J ' j ** * * * ' * - .-;

• extremely .valuable ~nsights into E~C*s* p.lant_ transient* analysis methodolo*g.y, arid would result in substantial harm t~*'the competit~ive position of ENC.

• 9. The DotLm~nt contains proprietary.informatio~ which is held in confidence by ENC .

and is not available 'in public sources.:*'.*.

• ~ . .

• 10. ** In: accordance*

w;i th ENC* si p,bl,.ide~

gqy'.erni. .rig*. ;..*the. protecti

.* . ' . :- -.... ..~

o_n and

• control of information, -

proprietary information contained in the Document . has been made :available, on

~

~'. :;imit~d bas*1s, to. ot~ersj~~tsid~ ENC. .

o~*ly*

I '

as. ,

required and ~nder suitable agreement providing for non-disclosure *and limited use of the information.

11. ENC policy requires that proprietary information be kept in a secured file or area and distributed on a ~eed-t6-know basis.

" *. ' ,_ i\

- ....3 - "*

12. This Document provides information which reveals ENC's plant transient an~lysis methodology ~eveloped"by ENC over the past sever~l years~

ENC has i nve~ted hundreds of thousands of do 11 ars and mp.ny man-years of effort

. in -developing the methods and calculating the* results revealed in - the Document.* Assuming a competitor had available the same background data and incentives as ENC, the competitor might, at a minimum, develop the information I - ' *_ ';

• foi th~ same expenditure of manpower and money as ENC.

',I * * ,' ' .~ * .; ~ ',,

. ' ,' '- '_, ' *' . ' ~  ;;  : ' ' . ' i~ .~ ~* . I* * ._

. ; 13. -**Based* on my'experience in"'the i.ndustry, I do not believe that the backgr-oun*d *dQ.ta *and incentives of EN,C' ~, competftors are* sufficiently.

-  : _, t.' _* ',!* I "t *:** '*I'*' * * ' * * ** ' '

simi)~r. **ta-*the. co~r~spondi_n*g background dat~ ,_'and incentives _of ENC* to_

" .. . ~'~ ... : *  ;- ' _; . , . - ' * ..  ? * ' * *

. reasonably expect such co_mpetitorswould be in a position*to duplicate ENC's*

proprietary ~ffformation contained in the* *Qocurnent. -

" THAT the statements made* heY:eina:bove are,' to. the best. of my knowledge,' informati.on;and belief,. truthful.and complete.

FURTHER.AFFIANT SAYETH 'NOT.

.SWOR~ TO ANO SUBSCRIBED befp~-~\~~--

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