ML18057B339
| ML18057B339 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/28/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18057B341 | List: |
| References | |
| NUDOCS 9111060088 | |
| Download: ML18057B339 (8) | |
Text
1
., je consumers Power POW ERi Nii
- NllCHlliAN'S PRDliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 October 28, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
TECHNICAL seECIFICATIONS CHANGE REQUEST - FUEL ASSEMBLY ENRICHMENT ALLOWED IN NEW FUEL AND SPENT FUEL RACKS Enclosed is a proposed change to the Palisades Technical Specifications which will allow the storage of fuel assemblies enriched to 4.20 weight percent (w/o) U235 in the new fuel racks and enriched to 4.40 w/o U235 in the Region I (NUS) racks in the spent fuel pool. This change is the result of changes to the enrichment of the Palisades fuel in order to design a low leakage core to minimize the effect of fluence on the reactor vessel and to maintain a reasonable length fuel cycle.
Plant operation with the higher U23~ enrichment will be the subject of a separate change request to be submitted 1n the near future.
Storage of fuel assemblies enriched as described above in the new fuel racks and spent fuel racks has been analyzed and evaluated by Siemens Nuclear Power Corporation, the Palisades nuclear fuel supplier. Siemens Nuclear Power reports, "Criticality Safety Analysis for the Palisades New Fuel Storage Array" (EMF-91-142l(P)) and "Criticality Safety Analysis for the Palisades Spent Fuel Storage Pool NUS Racks" (EMF~91-174(P)), find that the fuel stored as proposed by this change request meets the reactivity criteria of Sections 9.1.1 and 9.1.2 of NUREG 0800, ANSI/ANS 57.2-1983 and 57.3-1983, and the Palisades Technical Specifications (Keff ~.95). contains proposed changed Technical Specifications pages. contains marked up Technical Specifications pages. Attachment 3 is Siemens report EMF-91-174(P) and Attachment 4 is Siemens report EMF 142l(P).
Siemens Nuclear Power Corporation considers the information contained in EMF-91-174(P) and EMF-91-142l(P) to be proprietary.
In accordance with the requirements of 10 CFR 2.790(b), two affidavits are enclosed to support the withholding of this proprietary information from public disclosure.
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Consumers Power Company requests approval of this change before February 1, 1992 when the new fuel (Cycle 10, Reload N) with U2 enrichment greater than the existing allowable max-imum enrichment is schedu3fed to arrive at Palisades.
The amendment should become effective on the date it is issued.
~~
General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades
.-*""-1 AFFIDAVIT STATE OF WASHINGTON SS.
COUNTY OF BENTON I, R. A. Copeland being duly sworn,.hereby say and depose:
- 1.
I am Manager, Reload Licensing, for Siemens Nuclear Power Corporation,
("SNP"), and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with SNP's detailed document control system and policies which govern the protection and control of information.
- 3.
I am familiar with the topical report EMF-91-174(P) entitled "Criticality Safety Analysis for the Palisades Spent Fuel Storage Pool NUS Racks," referred to as "Document."
Information contained in this Document has been classified by SNP as proprietary in accordance with the control system and policies established by SNP for the control and protection of information.
- 4.
The Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by SNP 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 Document as proprietary and confidential.
- 5.
The Document has been made available to the U.S. Nuclear Regulatory Commission in confidence, with the request that the information contained in the Document will not be disclosed or divulged.
I
- 6.
The Document contains information which is vital to a competitive advantage of SNP and would be helpful to competitors of SNP when competing with SNP;-
- 7.
The information contained in the Document is considered to be proprietary by SNP because it reveals certain distinguishing aspects of SNP licensing methodology which secure competitive advantage to SNP for fuel design optimization and marketability, and includes information utilized by SNP in its business which affords SNP an opportunity to obtain a competitive advantage over its competitors who do not or may not know or use.the information contained in the Document.
- 8.
The disclosure of the proprietary information contained in the Document to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it valuable insights into SNP licensing methodology and would result in substantial harm to the competitive position of SNP.
- 9.
The Document contains proprietary information which is held in confidence by SNP and is not available in public sources.
1 O. In accordance with SNP's policies governing the protection and control of information, proprietary information contained in the Document has been made available, on a limited basis, to others outside SNP only as required and under suitable agreement providing for nondisclosure and limited use of the informatio,n.
- 11. SNP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 12. Information in this Document provides insight into SNP licensing methodology developed by SNP. SNP has invested significant resources in developing the methodology as well as the strategy for this application. Assuming a competitor had available the same background data and incentives as SNP, the competitor might, at a minimum, develop the information for the same expenditure of manpower and money as SNP.
THAT the statements made hereinabove are, to the best of my knowledge,
- information; and belief; truthful and *complete.
FURTHER AFFIANT SAYETH NOT.
R. A. Copeland SUBSCRIBED and sworn to before me this ~y-of~_O dJL,
1991.
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~ ~
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Notary Pubh In and For t State of Washington, Residing in Fran in County MY COMMISSION EXPIRES:
1/10/92
AFFIDAVIT STATE OF WASHINGTON )
)
SS.
COUNTY OF BENTON
)
I, R. A. Copeland being duly sworn, hereby say and depose:
- 1.
I am Manager, Reload Licensing, for Siemens Nuclear Power Corporation,
("SNP"), and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with SNP's detailed document control system and policies which govern the protection and control of information.
- 3.
I am familiar with the topical report EMF-91-1421 (P) entitled "Criticality Safety Analysis for the Palisades New Fuel Storage Array," referred to as "Document." Information contained in this Document has been classified by SNP as proprietary _in accordance with the control system and policies established by SNP for the control and protection of information.
- 4.
The Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by SNP 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 Document as proprietary and confidential.
- 5.
The Document has been made available to the U.S.. Nuclear Regulatory Commission in confidence, with the request that the information contained in the Document will not be disclosed or divulged.
- 6.
The Document contains information which is vital to a competitive advantage-of SNP and would be helpful to competitors of SNP when-competing with SNP. -
- 7.
The information contained in the Document is considered to be proprietary by SNP because it reveals certain distinguishing aspects of SNP licensing methodology which secure competitive advantage to SNP for fuel design optimization and marketability, and includes information utilized by SNP in its-business which affords SNP an opportunity to obtain a competitive advantage over Its competitors who do not or may not know or use the information contained in the Document.
- 8.
The disclosure of the proprietary information contained in the Document to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it valuable insights into SNP licensing methodology and would result in substantial harm to the competitive position of SNP.
- 9.
The Document contains proprietary information which is held in confidence by SNP and is not available in public sources.
- 10. In accordance with SNP's policies governing the protection and control of information, proprietary information contained in the Document has been made available, on a limited basis, to others outside SNP only as required and under suitable agreement providing
- for nondisclosure and limited use of the information.
- 11. SNP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 12. Information in this Document provides insight into SNP licensing methodology developed by SN~. SNP has invested significant resources in developing the methodology as well as the strategy for this application. Ass!:Jming a competitor had available the same background data and incentives as SNP, the competitor might, at a minimum, develop the information for the same expenditure of manpower and money as SNP.
THAT the statements made hereinabove are, to the best of my knowledge, information, and belief; truthful and-complete~
FURTHER AFFIANT SAYETH NOT.
R. A. Copeland e State of lin County MY COMMISSION EXPIRES:
1/10/92