ML20032C622
| ML20032C622 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/04/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19260J265 | List: |
| References | |
| NUDOCS 8111100658 | |
| Download: ML20032C622 (7) | |
Text
4 TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 37101 400 Chestnut Street Tower II November 4, 1981
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f Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation
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U.S. Nuclear Regulatory Commission 17 h^*A 8
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Dear Mr. Denton:
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In the Matter of the
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Docket No. 50-29f/ A
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Tennessee Valley Authority
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kl This letter provides information rega" ding the planned use of Lead Test Assemblies (LTA's) at the Browns Ferry Nuclear Plant as part of unit 3 reload 4.
The letter and enclosures nee provided as supporting information for the Browns Ferry unit 3 reload 4 request for license amendment, currently planned for submittal on or about November 20, 1981.
In accordance with a letter from T. A. Ippolito to R. E. Engel (General Electric), dated September 24, 1981 regarding Lead Test Assembly licensing, this letter and enclosures document the conformance of the analyses of these LTA's with current methods.
It is planned to load eight LTA's into Browns Ferry unit 3 as part of reload 4 during the fall 1981 refueling outage. Four test assemblies have an average bundle enrichment of 2.83 weight percent and four have an average of 3 14.
The LTA's incorporate the improved features of a third water rod, increased preprescuelzation to five atmospheres, larger pellet diameter / thinner cladding / higher stack density, 'mproved upper tie plate, improved spacer design, axial gadolinia distribution, and barrier fuel.
The eight LTA's are described in more detail in Enclosure 1.
Please note that Enclosure 1 t.o this letter is General Electric Company Proprietary Information. An affidavit providing justification for the GE Proprietary status of the information is provided as Enclosure 2.
Very truly yours, TENNESSEE VALLEY AUTHORITY C
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C~.-M. Mills, Manager Nuclear Regulation and Saf'ety OI Subscribe a d sworn t before 8
me this day of M 1981.
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My Commission Expires Enclosures 8111100658 811104 PDR ADOCK 05000296 P
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9 ENCLOSURE 1 Attachnent 1 - Lead Test Assembly Bundle Descr iptions - Lead Test Assembly Unique Inputs
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ATTACHMENT 1 LTA B'JNDLE DESCRIPTIONS l
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ENCLOSURE 2 GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Glenn G. Sherwood, being duly sworn, depose and state as follows:
1.
I am Manager Safety and Licensiag Operation, General Electric Company, and have been delegateo the function of reviewing the information described in paragraph 2 which is sought to be withheld and have been authorized to apply for its withholding.
The information sought to be withheld is contained in the attachments 2.
titled "LTA Bundle Descriptions" and "LTA Unique Inputs."
In designating material as proprietary, General Electric utilizes 3.
the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement Of Torts, Section 757. This definition provides:
1 "A trade secret may consist of any formula, pattern, device or compilation of information which is used in or.e'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 extent to which it is known by employees and others involved in his business; (3) the exten'. 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 acquirsJ or duplici'.ed by others."
4.
Some examples of categories of information which fit into the definition of proprietary information are:
Information that discloses a process, method or apparatus a.
where prevention of its use by General Electric's competitors without license from General Electric constitutes a competi-tive economic advantage over other companies;
Information consisting of supporting data and analyses, includ-ing test data, relative to a process, method or apparatus, the b.
application of which provide a competitive economic advantage, e.g., by optimization or improved marketability; Information which if used by a competitor, would reduce his expenditure of resources or improve his competitive position c.
in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product; Information which reveals cost or price information, produc-d.
tion capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs e.
of potential commercial value to General Electric; Informationwhichdisclosespatentablesubjectmatterfor f.
which it may be desirable to obtain patent protection; Information which General Electric must treat as proprietary g.
according to agreements with other parties.
In addition to proprietary treatment given to material meeting the standards enumerated above, General Electric customarily maintains 5.
in confidence preliminary and draft material which has not been subject to complete prcprietary, technical and editorial review.
This practice is based on the fact that draft documents often do not appropriately reflect all aspects of a problem, may contain tentative conclusions and may contain errors that can be corrected Also, until the during normal review and approval procedures.
final document is completed it may not be possible to make any General definitive determination as to its proprietary nature.
Electric is not generally willing to release such a document to the Such documents are, general public in such a preliminary form.however, on occasion basis because it is General Electric's belief that it is in the public interest for the staff to be promptly furnished with signifi-Furnishing the docu-cant or potentially significant information.
cent on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprie-tary position and permitting General Electric to insure the public documents are technically accurate and correct.
Initial approval of proprietary treatment of a document is made oy the Subsection Manager of the originating component, the man most 6.
likely tc be acquainted with the value and sensitivity of the Access to such information in relation to industry knowledge.
documents within the Company is limited on a "need to know" basis and such documents at all times are clearly identified as proprietary.
The procedure for approval of external release of such a document 7.
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 technical content, competitive effect and deter-mination of the accuracy of the proprietary designation in accord-ance 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 accordance with appropriate regulatory provisions or proprie-tary agreements.
The document mentioned in paragraph 2 above has been evaluated in 8.
accordance with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by G.$neral Electric.
The attachments herein are classified as proprietary because they 9.
contain details concerning fuel assembly design, mechanical analysis and calculated nuclear properties which were performed and developed at considerable expense to General Electric and which are not available to other parties. The 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 considerable expense to General Electric. In particular the following information is deemed proprietary.
Results from thermal and mechanical evaluations regarding bundle design. These designs are a result of extensive testing a.
and development.
The design basis and methods have been developed over a long period of thne and involve; the expenditure of over $75,000.
The results could disclose valuable information regarding both the design and methods used.
Detailed hydraulic and nuclear characteristics based on water b.
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.
Glenn G. Sherwood, being duly sworn, deposes and says that he has read the foregoing affidavit and the matters stated therein are true and 3
correct to the best of his knowledge, information, and belief.
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e Executed at San Jose, California, this 1 day of Oc.fowa,198_l.
Glenn G. Sherwood General Electric Company STATE OF CALIFORNIA
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COUNTY OF SANTA CLARA
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Subscribed and sworn before me this 1 day of QCloBEEl98].
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- Vf OFFICIAL SEAL A A' KAREN 5. VOGELHUNR NOTARY PUBLIC IN AND fpH 5 AID NOTARY PUBLIC. CALIFORNIA SANTA CLARA COUNTY COUNTY AND STATE a-My Commission Expires Dec. 21,1984 emmmmmmmmmmm GGS:hjr:rm/84-7 10/7/81 i
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