ML20077K049

Forwards Nonproprietary Copyrighted WCAP-12997 & Proprietary WCAP-12996 Augmentation Factor Elimination for Westinghouse Fuel in Fort Calhoun. Proprietary WCAP-12996 Withheld (Ref 10CFR2.790)

ML20077K049
Person / Time
Site:	Fort Calhoun
Issue date:	07/26/1991
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19302E970	List: ML20077K049 ML20077K054 ML20077K065
References
LIC-91-140R, NUDOCS 9108060274
Download: ML20077K049 (7)

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Omaha Pubtle Power District 444 South 16th Stteet Mall July 26, 1991 Omaha, Nebraska 68102 2247 LIC 91-140R 402/636-2000 (

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Staticn Pl-137 [

Washington, DC 20555

References:

1. Docket No. 50 285

2. Letter from 0 PPD (W. G. Gates) to NRC (Document Control Desk) dated April 19, 1991 (LIC-91-0126R)

3. Letter from NRC (T. R. Quay) to OPPD (W. G. Gates), dated '

May 28, 1991 Gentlemen:

SUBJECT:

Submittal of Westinghouse Topical Reports WCAP-12996 -

(Proprietary) and WCAP 12997 (Nonproprietary)

Omaha Public Power District (OPPD) is enclosing eighteen (18) copies each of the proprietary (WCAP-12996) and nonproprietary (WCAP-12997) versions of the Westinghouse lopical Report titled " Augmentation Factor Elimination for Westinghouse fuel in Fort Calhoun," dated June 1991. OPPD committed to provide the NRC with this Westinghouse Topical Report in item 4 of Reference 2 by July 31, 1991. Items 1 and 3 of Reference 2 are not enclosed but will be submitted by July 31, 1991 as committed.

However, OPPD must extend the submittal date for item 2 (Cycle 14 Small and Large Break LOCA Antlyses Summary) to September 2, 1991 to correct input errors identified during OIPD's review process. As agreed in the March 11, 1991 NRC-0 PPD meeting, these reports are beina submitted in advance of OPPD's Cycle

-14 Reload License Application scheduled .s, November 1991 to allow the NRC additional time for review.

Please note that pursuant to 10 CFR 2.790, Westinghouse has determined that Topical Report WCAD-12996 contains proprietary information to be withheld from public disclosure. Appropriate documentation justifying this determination is enclosed.

Also enclosed is the proprietary affidavit for the CENTS topical report CENPD 282-P, Volumes 1 and 2, dated February 1991 which was inadvertently omitted from Reference 2. It is OPPD's understanding that the CENTS computer code will be submitted by Asea Brown Boveci - Combustion Engineering (CE) as a generic topical report. OPPD's previous submittal of the CENTS code will remain on the docket pending NRC apnroval of the CE generic topical report. In theinterim,theCESECcodeisavailableforuseby0 PPD.

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• U. S. Nuclear Regulatory Commission LIC 31-140R Page 2 The NRC indicated in Reference 3 that its review of OPPD's methcdology topical report ; updates is expected to be completed in January 1992. As a result, OPPD is concerned that requests for revisions to the OPPD methodology topical reports may occur after the Cycle 14 Reload License Application is submitted in November 1991. To insure sufficient time is available for the resolution of any problems, OPPD is asking that the NRC forward any preliminary results of the reviews of the OPPD methodology topical reports as soon as they ere available.

If you should have any questions, please contact me.

Sincerely,

/4.N../ da-W. G. Gates Division Manager Nuclear Operations WGG/sel Enclosures I c: LeBoeuf, Lamb, Leiby & MacRae (w/o Enclosures)

R. D. Martin, NRC Regional Administrator, Region IV (w/o Enclosures)

W. C. Walker, NRC Project Manager (w/o Enclosures)

R. P. Mullikin, NRC Senior Resident -Inspector (w/o Enclosures)

H. Borchert, Director - Division of Radiological Health, Nebraska Department of Health (w/o Enclosures) 1 l

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n. .

f AFFIDAVIT PURSUANT t

TO 10 CFR 2 dRQ I

Combustion Engineering, Inc.

)

State of Connecticut )

County of Hartford ) SS.: ,

I, A. E. Scherer, depose and say that I am the Vice President, Nuclear Quality, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the

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information which is identified as proprietary and referenced in tho paragraph ' immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and- in conjunction with the application of the Omaha ,

Public Power District for withholding this information.

The information for which proprietary treatment is sought is contained in the following documents:

- CE-NPD 282-P, " Technical Manual for the CENTS CODE", Volumes 1 and 2, February 1991.

These documents have been appropriately designated as proprietary.

I have personal knowledge of the criteria und procedures utilized by combustion Engineering in designating information as.a trade secret, privileged or as confidential commercial of financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.790 t

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of the Commission's regulations, the following is furnished for consideration by the commission in dotormining whether the information sought to be withheld from public disclosure, included in the above referenced documents, should be withheld.

1. The information sougnt to be withhold from public disclosuro is the models, methods and algorithms used to simulato a pressurized water reactor nuclear steam supply system transient response, which is owned and has been hold in confidence by combustion Engineering.

2. The information consists of test data or other similar data concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.

3. The information is of a type customarily hold in confidence by Combustion Engineering and not customarily disclosed to the public. Combustion Engineering has a rational basis for datormining the types of information customarily hold in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The details of the aforementioned system vero provided to the Nuclear Regulatory Commission via letter DP-537 from F. M. Stern to Frank Schroeder dated December 2, 1974.

This system was applied in datormining that the subject document heroin is proprietary.

4. The information is being transmitted to the Commission in confidence under the provisions of 10 CD 2.790 with tho l

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understanding that it is to be received in confidenco by the Commission.

5. The information, to the best of my knowledge and belief, is not available in public sourcos, and any disclosure to third parties has boon made pursuant to 1ogulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

6. Public disclosure of the information is likely to causo substantial harm to the competitive position of Combustion Engineering becauset

a. A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.

b. Development of this information by C-E required thousands of manhours and hundreds of thousands of dollars. To the best of my knowledge and belief, a competitor would have to

. undergo similar expense in generating equivalent information.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience to develop the models, methods and algorithms used to simulato a pressurized water reactor nuclear steam supply system transient responso,

d. The information required significant effort and expense to obtain the licensing approvals nocessary for application of the information. Avoidance of this expenso would decreaso

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a competitor's cost in applying the information and marketing the product to which the information is applicable.

e. The information consists of the models, methods and algorithms used to simulate a pressurized water reactor nuclear steam supply system transient response, the application of which provides a competitive economic advantage. -The availability of- such information to competitors would enable them to modify their product to better compete with combustion Engineering, take marketing or other actions to improve their product's position or impair-the position'of combustion Engineering's product, and avoid developing.similar data and analyses in support of their processes, methods or apparatus.

f. In pricing combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and_ expenses must-be included. The ability of. combustion

. Engineering's competitors to . utilize such without information sir.ilar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.

. g.. Use of the information by competitors in the international

- marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development. In addition, disclosure L

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5 would have an adverse economic impact on combustion Engineering's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

2_. _

J Ah_2 A. E Vice President

/ heter Nuclear Quality Sworn to before me A o this M "'( day of t_%'4ina4e/

, 1991 6

(NotaryPublibkia;e,0. lJfbte ,

My commission expires J' 3/ d'/

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