ML20081C982

Forwards Nonproprietary Version of XN-NF-82-90(NP),Suppl 1, Potential Radiological Consequences of Incidents Involving High Exposure Fuel, Which Supports Application for Tech Spec Changes for Cycle 5 Reload

ML20081C982
Person / Time
Site:	Cook
Issue date:	03/13/1984
From:	Chandler J SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20081C987	List: ML20081C982 ML20081D002
References
JCC:048:84, JCC:48:84, NUDOCS 8403150097
Download: ML20081C982 (6)

Text

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Eh NUCLEAR COMPANY,Inc.

2101HomRnnittnumf P. 0 Bar 15 AkMmg WashbytmStE?

Phone:(509)375 8100 Telex: 15-2878 March 13, 1984 JCC:048:84 Donald C. Cook Nuclear Plant Unit No. 2 Docket No. 50-316 License No. DPR-74 TRANSMITTAL OF XN-NF-82-90(NP), SUPPLEMENT 1, IN SUPPORT OF APPLICATION FOR UNIT 2 TECHNICAL SPECIFICATION CHANGES FOR CYCLE 5 RELOAD Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, D.C. 20555

References:

(1) Letter, M.P. Alexich (AEPSC) to H.R. Denton (NRC),

" Application For Unit 2 Technical Specification Changes for Cycle 5 Reload," AEP:NRC:0860.

(2) Letter, J.C. Chandler (ENC) to H.R. Denton (NRC), " Donald C. Cook Nuclear Plant - Supporting Documentation for Unit 2 Technical Specification Changes for Cycle 5 Reload,"

dated March 2, 1984 (JCC:040:84).

Dear Mr. Denton:

Enclosed are forty copies of the Exxon Nuclear Company report XN-NF 90(NP), Supplement 1, entitled " Potential Radiological Consequences of Incidents Involving High Exposure Fuel," which supports the application for the D.C. Cook Unit 2 Technical Specification changes for the Cycle 5 reload.

At the request of American Electric Power Service Company (AEPSC) and as stated in the Reference (1) letter, this report is being transmitted directly by Exxon Nuclear. Two of the forty copies are enclosed with the copy of this letter provided to the D.C. Cook project manager.

The enclosed report is the non-proprietary version of one of the proprietary reports issued by Exxon Nuclear Company in support of the D.C.

Cook Unit 2 Cycle 5 reload as forwarded by the Reference (2) letter. This report was inadvertently omitted from the Reference (2) submission.

The information supporting the withholding of XN-NF-82-90(P), Supplement 1, from public disclosure was also inadvertently omitted from the Reference (2) submission. The enclosed Affidavit executed by our Dr. Richard B. Stout

~ provides the necessary it. formation to support the withholding of XN-NF 90(P), Supplement 1, from oublic disclosure under 10 CFR 2.790(b).

8403150097 840313 PDR ADOCK 05000316

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H. R. Denton 2 March 12, 1984 JCC:048:84 i

Exxon Nuclear regrets any inconvenience that these omissions may have i caused. If there are questions about this submission, please contact Mr.

James G. Feinstein of AEPSC at (614) 233-2040.

Very truly yours, J.C. Chandler, Lead Engineer Reload Fuel Licensing cc

Mr. D.L. Wigginton (NRC) '

Mr. M.P. Alexich (AEPSC) 1 1

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APFI DAVIT STATE OF WASHINGTON )

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COUNTY OF BENTON )

I, Richard B. Stout, being duly sworn, hereby say and depose:

1. I am Manager, Licensing and Safety Engineering, for Exxon Nuclear Company, Inc. (" ENC"), and as such I am authorized to execute this Affidavit.

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2. I am familiar with ENC's detailed document control system and policies . which govern the protection and control of information.

3. I am familiar with the document XN-NF-82-90(P),

Supplement 1, entitled " Potential Radiological Consequences of Incidents Involving High Exposure Fuel," referred to as " Document."

Information contained in this Document 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 document contains 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 ny experience, I am aware that other companies regard information of the kind contained in the Document as proprietary and confidential.

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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 ENC and would be helpful to competitors of ENC when competing with ENC.

7. The information contained in the Document is considered to be proprietary by ENC because it reveals certain distinguishing aspects of reactor safety analysis methods 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 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 extremely valuable insights into reactor safety analysis methods and would result in substantial harm to the competitire position of ENC.

9. The Document contains proprietary information which is held in confidence by ENC and is not available in public sources.

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10. In accordance with ENC'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 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.

12. This Document provides information which reveals reactor safety analysis methods developed by ENC over the past several years. ENC has invested millions of dollars and many man-years of effort in developing the reactor safety analysis methods revealed in the Document. 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 'i ncentive s of ENC's competitors are sufficiently similar to the corresponding background data and incentives of ENC to reasonably expect such competitors would be in a position to duplicate ENC's proprietary information contained in the bocument.

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

FURTHER AFFIANT SAYETH NOT.

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8 SWORN TO AND SUBSCRIBED f before me this fj . day of Af a 19ffl. '

NOTARY PUBLIC l

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