ML17334A516

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Forwards Proprietary & Nonproprietary Info Supporting Application for Tech Spec Changes for Cycle 5 Reload. Proprietary Repts Withheld
ML17334A516
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 03/02/1984
From: Chandler J
SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML17320A942 List:
References
JCC:040:84, JCC:40:84, NUDOCS 8403080205
Download: ML17334A516 (11)


Text

REED'ULATORY <FORMATION DISTRIBUTION S M (R IDS)

ACCESSION NBR:8003080205 DOCGDATE: 8'/03/02 NOTARIZED: YFS DOCKET FACIL:50 316 Donald BYNAME C ~ Cook Nuclear Power Planti Unit 2i Indiana 8 05000316 AUTH AUTHOR AFFILIATION CHANDLERiJ,C, Exxon Nuclear Co.i Inc (subs, of Exxon Corp.)

RFCIP ~ NAME RECIPIENT AFFILIATION DENTONiH ~ RE Office of Nuclear Reactor Regulationi Director

SUBJECT:

Forwards proprietary L nonproprietary supporting application for Tech Spec chanses for Cycle 5 reload. P~

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2191 Hom Rapids Road P. 0 Box 199 Richland, washington 9%52 Phone: (509) 375-8 l00 Telex: 15-2878 March 2, 1984 JCC:040:84 Donald C. Cook Nuclear Plant Unit No. 2 Docket No. 50-316 License No. DPR-74 SUPPORTING DOCUMENTATION FOR UNIT 2 TECHNICAL SPECIFICATION CHANGES FOR CYCLE 5 RELOAD Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

Letter, M.P. Alexich (AEPSC) to H.R. Denton (USNRC), "Appli-cation For Unit 2 Technical Specification Changes for Cycle 5 Reload", AEP:NRC:0860

Dear Mr. Denton:

Enclosed are thirty-eight copies of each of the Exxon Nuclear Company reports supporting the application for the D.C. Cook Unit 2 Technical Specification changes for'he Cycle 5 reload. At the request of American Electric Power Service Company (AEPSC) and as stated in the reference letter, these reports are being transmitted directly by Exxon Nuclear. The enclosed reports are as follows:

XN-NF-83-85, "D.C. Cook Unit 2, Cycle 5 Safety Analysis Report", October 1983.

I XN-NF-83-85 Supplement 1, "D.C. Cook Unit 2, Cycle 5 Safety Analysis Report", February 1984.

XN-NF-82-32(P) and (NP), Revision 2, "Plant Transient Analysis for Donald C. Cook Unit 2 Reactor at 3425 NWt, Operation with 5X Steam Generator Tube Plugging", February 1984.

XN-NF-84-21(P) and (NP), "Donald C. Cook Unit 2 Cycle 5 5X Steam Generator Tube Plugging Limiting Break LOCA ECCS Analysis", February 1984.

XN-RF-82-9D supplement I, "D.C. Cook Unit 2, Potential Radiological Consequences of Incidents Involving High Exposure Fuel", January 1984.

Exxon Nuclear Company considers the information contained in certain of the enclosed reports to be proprietary. In accordance with the Commission's Regulation 10 CFR 2.790(b), the enclosed affidavit executed by Exxon Nuclear Company's Dr. Richard B. Stout provides the necessary information to support the withholding of these documents from public disclosure. Non-proprietary copies of these documents are also enclosed for your use.

.. =AN AFFIUATEOF EXXON CORPORATION anal'

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March 2, 1984 H.R. Denton JCC 040 84 If there are questions about this submission, please contact- Mr. James G.

Feinstein of AEPSC at (614) 233-2040.

Sincerely, J. C. Chandler, Lead Engineer Reload Fuel Licensing JCC:naa cc: Mr. D. L. Wigginton (USNRC)

Mr. M. P. Alexich (AEPSC)

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AFF IDA V IT STATE OF Washington )

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COUNTY OF Benton )

I, Richard B. Stout, being duly sworn, hereby say and de-pose:

l. I am Manager, Licensing and Safety Engineering, for Exxon Nuclear Company, Inc. ("ENC"), and as such I am authorized to execute this Affidavit.
2. I am fami liar with ENC's detailed document control system and policies which govern the protection and control of information.
3. I am fami liar with the documents XN-NF-84-21(P) and XN-NF-82-32(P) Revision 2, entitled "Donald C. Cook Unit 2 Cycle 5 Steam Generator Tube Plugging Limiting Break LOCA/ECCS Analysis" and "Plant Transient Analysis for the Donald C. Cook Unit 2 Reactor at 3425 NWt Operation with 51 Steam Generator Tube Plugging", respectively, referred to as "Documents". Information contained in these Documents has been classified by ENC as proprietary in accordance with the control system and policies established by ENC for the control and protection of information.
4. The Documents contain information of a proprietary and confidential nature and is of the type customarily held in confidence by ENC and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in the Documents as proprietary and confidential.
5. The Documents have been made available to American Electric Power Service Corporation in confidence, with the request that the information contained in the Document not be disclosed or divulged.
6. The Documents contain information which is vital to a com-petitive advantage of ENC and would be helpful to competitors of ENC when competing with ENC.
7. The information contained in the Documents is considered to be proprietary by ENC because it reveals certain distinguishing aspects of 1

the safety analysis methodology which secure competitive advantage to ENC for fuel design optimization and marketability, and includes information utilized by ENC in its business which affords ENC an opportunity to obtain a competitive advantage over its competitors who do not or may not know or use the information contained in the Documents.

8. The disclosure of the proprietary information contained in the Documents to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it extremely valuable insights into the ENC safety analysis methodology and would result in substantial harm to the competitive position of ENC.
9. The Documents contain proprietary information which is held in confidence by ENC and is not available in public sources.
10. In accordance with ENC's policies governing the protection and control of information, proprietary information contained in the Documents has been made available, on a limited basis, to others outside ENC only as required and under 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 need-to-know basis.

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12. These Documents provide information which reveals the ENC safety analysis methodology developed by ENC over the past several years.

ENC has invested millions of dollars and many man-years of effort in developing the analysis methods revealed in the Documents. Assuming a competitor had available the same background data and incentives as ENC, the competitor might, at a minimum, develop the information for the same expenditure of manpower and money as ENC.

13. Based on my experience in the industry, I do not believe that the background data and incentives of ENC's competitors are suf-ficiently similar to the corresponding background data and incentives of ENC to reasonably expect such competitor s would be in a position to duplicate ENC's proprietary information contained in the Documents.

THAT the statements made hereinabove are, to the best of my knowledge, information, and belief, truthful and complete.

FURTHER AFFIANT SAYETH NOT.

SWORN TO AND SUBSCRIBED before me:this~ day of F-

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NOTARY PUBLIC

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