ML20023B304
| ML20023B304 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/20/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19268D596 | List: |
| References | |
| NUDOCS 8212270219 | |
| Download: ML20023B304 (7) | |
Text
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O PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.191o1 SHIELDS L DALTROFF
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December 20, t982 Docket No.
3-278 Mr. John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 205S5
SUBJECT:
Peach Bottom Unit 3 Lead Tast Assemblies Ref.:
1.
U.S. Nuclear Regulatory Commission letter dated 9/23/81, T. A.
Ippolito to R. E.
Engel:
" Lead Test Assembly Licensing" 2.
General Electric Company Document NEDE-240ll-P-A-4, " General Electrjc Standard Application for Reactor Fuel", January, 1982 3.
General Electric Company Document Y1003J01A54, " Supplemental Reload Licensing Submittal for Peach Bottom Atomic Power Station Unit 3, Reload 5",
December, 1982 4.
General Electric Company Document NEDO-24082, "LOCA Analysis for Peach Bottom Atomic Power Station Unit 3",
Errata and Addenda No.
5, October, 1982 Deat: Mr. Stolz:
Philadelphia Electric Company plans to load four (4)
Lead Test Assemblies (LTAs) as part of Peach Bottom Unit 3 Reload 5 during the Unit 3 Spring, 1983 refueling outage.
The assemblies are planned to be in operation for up to four cycles as part of a joint program with General Electric Company to irradiite and test improved fuel design features prior to their use on a' production basis.
C8212270219' 821220
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PDR ADOCK 05000278 l
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Me.. John *F. Stolz, Chief Pago 2 In accordance with NRC instructions pertaining to Lead Test Assembly licensing (reference 1), this letter is being l
submitted to document conformance of the analyses of the Peach Bottom 3 Reload 5 LTAs with the approved methods and criteria given in reference 2 ac well as to provide additional information
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requested in reference 1.
A description of the LTAs is given in Attachment 1 of I
this letter.
Table 1 lists the major features of the LTAs and i
Table 2 lists those features which are unique among the LTAs.
Table 3 provides information on the bundle tie plate and spacers
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and Table 4 describes fuel rod and water rod mechanical design features.
Figures 1 and 2 provide a description of the layout of -
rods within the LTAs including enrichment and gadolinia i
distributions.
i Genezal Electric Company has designed and analyzed these LTAs utilizing the approved methods given in reference 2.
The l
LTAs are designed for and meet the same nuclear-thermal-mechanical criteria as standard reload bundles, i.e.,
analyses show that the LTAs will remain within all approved nuclear-i thermal-mechanical limits.
Further, licensing analyses have been performed for the LTAs during their initial cycle of operation i
(cycle 6) wherein the effect of the four LTAs is specifically
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considered for each of the appropriate licensing events and transients to establish appropriate reactor core thermal limits for operation.
These licensing analyses are provided in
! of this letter as well as in references 3 and 4 which will be submitted shortly in support of our forthcoming Peach Bottom 3 Reload 5 license amendment application.
In summary, the Peach Bottom 3 Reload 5 LTAs have been analyzed using reference 2 approved methods and found to meet all applicable reference 2 approved criteria.
Further, the LTAs have
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been analyzed for specific operation during cycle 6 and l
appropriate thermal limits have been established for operation l
during cycle 6, therefore it can be concluded that no unreviewed l
safety questions exist for such operation.
i i
Attachments 1 and 2 of this letter contain information which the General Electric Company customarily maintains in confidence and withholds from public disclosure.
The information 8
i has been handled and classified as proprietary to General Electric, as indicated in the attached affidavit, and we hereby request that these attachments be withheld from public disclosure l
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in accordance with the provisions of 10CFR 2.790.
NRC instructions given in reference 1 also requested that information be provided on the scope of measurements to be l
conducted on LTAs ac well as the schedules for documenting l
results of these measurements.
As currently envisioned, t
measurements on the LTAs consist of pre-irradiation characterization of fuel pellets, clad tubing, fuel rods and fuel l
l bundles.
At subsequent refueling outages, the scope of Inspections, as currently envisioned, consist of overall bundle l
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Mr.*Jehn F. Stolz, Chiof Paga 3 visual examinations, bundle and rod length measurements, rod integrity and profilometry measurements, corrosion thickness measurements, fission gas sampling, spacer spring relaxation measurements and possibly gamma scans.
The extent of such measurement and testing will be governed by the need to minimize the impact of such testing on refueling outage critical path.
Further, as requested, General Electric Company has advised us that results obtained from this LTA program will be summarized in their fuel experience reports in a timely manner.
We are most anxious to proceed with the irradiation of these LTAs in as much as we believe this program will lead to eventual improvements in nuclear fuel economy and reliability and we request your approval for installing the four LTAs as part of Peach Bottom 3 Reload 5.
Should you require any additional information, please do not hesitate to contact us.
Very truly yours,
,//
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4 x;aeayj-cc:
R. A. Blough, Site Inspector I
Attachments l
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e GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Glenn G. Sherwood, being duly sworn, depose and state as follows:
1.
I am Manager, Safety & Licensing Operation, General Electric Company, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be withheld and have been authorized to apply for its witSholding.
2.
The information sought to be withheld is contained in the attach-ments titled "LTA Bundle Description" and "LTA Unique Inputs and Analyses".
3.
In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement Of Torts, Sec-tion 757.
This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it....
A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring informa-tion....
Some factors to be considered in determining whether given information is one's trade secret are:
(1) the extent to which the information is known outside of his business; (2) the j
extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expended by him in developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."
4.
Some examples of categories of information which fit into the definition of proprietary information are:
a.
Information that discloses a process, method or apparatus where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; b.
Information consisting of supporting data and analyses, includ-ing test data, relative to a process, method or apparatus, the application of which provide a competitive economic advantage, e.g., by optimization or improved marketability;
P:ge 2, c.
Information which if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, essurance of quality or licensing of a similar product; d.
Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; e.
Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial value to General Electric; f.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection; g.
Information which General Electric must treat as proprietary according to agreements with other parties.
S.
In addition to proprietary treatment given to material meeting the standards enumerated above, General Electric customarily maintains in confidence orelimine.ry and draft material which has not been subject to complete proprietary, technical and editorial review.
This practice is based on the fact that draft doctcents eften do not appropriately reflect all aspects of a problem, may contain tentative conclusions and may contain errors that can be corrected during normal review and approval procedures.
Also, until the final document is completed it may not be possible to make any definitive determination as to its proprietary nature.
General Electric is not generally willing to release such a document to the general public in such a preliminary form.
Such documents are, howeer, on occas'on furnished to the NRC staff on a confidantial basis because it is Geaeral Electric's belief that it is in the public interest for the staff to be promptly furnished with significant or potentially significant information.
Furnishing the document on a confidential basis pending completion of General Electric's internal review penaits early acquaintance of the staff with the information while protecting General Electric's potential proprietary position and pern.itting General Electric to insure the public documents are technically accurate and correct.
6.
Initial approval of proprietary treatment of a document is made by the Subsection Manager of the originating component, the man most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.
Access to such documents within the Company is limited on a "need to know" basis and such documents at all times are clearly identified as proprietary.
1 7.
The procedure for approval of external release of such a document is reviewed by the Section Manager, Project Manager, Principal Scientist or other equivalent authority, by the Section Manager of the cognizant Marketing function (or his delegate) and by the Legal Operation for 1
N
r Pcge 3 technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above.
Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees only in accor-dance with appropriate regulatory provisions or proprietary agreements.
8.
The document :9entioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures ar.d has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.
9.
The attachments herein are classified as proprietary because they contain details concerning fuel assembly design, mechanical analysis and calculated nuclear properties which were performed and developed at considerable expense to Geraral Electric and which are not available to other parties.
lne information is of a type customarily held in confidence by General Electric since it reveals important features and contains valuable design information which were obtained at coasiderable cost to the General Electric.
In particular the following information is deemed proprietary.
a.
Results from thermal and mechanical evaluations regarding bundle design.
These designs are a result of extensive testing and development.
The design basis and methods have been developed over a long period of time and ir.volved expenditure of over $75,000. The results could disclose valuable information regarding both design and methods used.
b.
Detailed hydraulic and nuclear characteristics based on water rods spacers and other bundle design features.
These characteristics are a result of extensive development, analysis and out of reactor testing at a cost of over $600,000.
STATE OF CALIFORNIA
) ss:
COUNTY OF SANTA CLARA
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Glenn G. Sherwood, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.
P:ge 4, Executed at San Jose, California, this 8 day of December 198 2.
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/l b Glenn G. 'SffeFsood' '
General Electric Company Subscribed and sworn before me this 1 day of December 1982 cocecececococo:ococococo m f -
OFFICIAL SEAL KAREN S. YOGELHUBER TA $$1C$UN
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My Comm uion Expires Dec. 21, HM NOTARY PUBLIC, STATE OFgCALIFORNIA
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