ML20083R747

Forwards Core Operating Limits Rept,Cycle 10, for BSEP Unit 1, Suppl Reload Licensing Rept for BSEP Unit 1,Reload 9,Cycle 10, & Proprietary, LOCA Analysis Rept for BSEP, Unit 1 Reload,Cycle 10

ML20083R747
Person / Time
Site:	Brunswick
Issue date:	05/15/1995
From:	Lopriore R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19344C916	List: ML20083R747 ML20083R792 ML20083R808
References
BSEP-95-016, BSEP-95-16, NUDOCS 9505300141
Download: ML20083R747 (8)

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3 CP&L Carolina Power & Light Company P, O. Box 10429 Southport. NC 28461 MAY 121995 ,

SERIAL: BSEP 95-0169.

United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO.1 DOCKET NO. 50-325 / LICENSE NO. DPR-71

. TRANSMITTAL OF CORE OPERATING LIMITS REPORT, SUPPLEMENTAL RELOAD  !

LICENSING REPORT, AND LOSS-OF-ACCIDENT ANALYSIS REPORT Gentlemen: i The purpose of this letter is to submit, in accordance with Technical Specification 6.9.3.4, a copy of the Core Operating Limits Report for the Brunswick Steam Electric Plant, Unit 1. A copy of the  ;

o " Brunswick Unit 1, Cycle 10 Core Operating Limits Report, May 1995," Revision 0, approved May 8,1995 for Brunswick Unit 1, Cycle 10 is provided in Enclosure 1.

With each non-proprietary reload submittal, licensees must include a table of the most limiting and least limiting Maximum Average Planar Linear Heat Generation Rate (MAPLHGR) for each multiple lattice fuel type. This information for the latest fuel type is located in the Supplemental Reload Licensing Report for Brunswick Unit 1. A copy of the " Supplemental Reload Licensing Repor1 for Brunswick Unit 1 Reload 9 Cycle 10," 24A5159, Revision 0 is provided in Enclosure 2.  ;

i Enclosure 3 to this letter provides a copy of the Loss-of-Coolant Accident Analysis Report for the Brunswick Steam Electric Plant, Unit 1, Reload 9 Cycle 10 (NEDC-31624P, Supplement 1, Revision 2)._ This report contains MAPLHGR values for the General Electric Nuclear Energy fuel designs to be loaded into Brunswick Unit 1 for Cycle 10. The document contained in Enclosure 3 is considered General Electric Nuclear Energy proprietary information and should be withheld from public disclosure in accordance with 10 CFR 2.790. An affidavit attesting to this fact is ,

provided in Enclosure 4.

Please refer any questions regarding this submittal to Mr. George Honma at (910) 457-2741.

Sincerely, R. P. Loprior OQl '

Manager- Regulatory Affairs -

Brunswick Nuclear Plant 9505300141 950515 PDR ADDCK 05000325 h.h ,

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Document Control Desk BSEP 95-0169 / Page 2 WRM/wrm Enclosures cc: Mr. S. D. Ebneter, NRC Region II - Regional Administrator Mr. D. C. Trimble, NRR Project Manager (Acting)- Brunswick Mr. C. A. Patterson, NRC Senior Resident inspector- Brunswick The Honorable H. Wells, Chairman - North Carolina Utilities Commission l

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ENCLOEURE 4 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO.1 NRC DOCKET NO. 50-325 OPERATING LICENSE NO. DPR-71 TRANSMITTAL OF CORE OPERATING LIMITS REPORT, SUPPLEMENTAL RELOAD LICENSING REPORT, AND LOSS-OF-ACCIDENT ANALYSIS REPORT AFFIDAVIT FROM GENERAL ELECTRIC NUCLEAR ENERGY REGARDING WITHHOLDING FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.790 l

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GE Nuclear Energy l

l Affidavit I, James F. Klapproth, being duly su orn, depose and state as follows:

(1) I am Manager, Fuel and Facilities 1.icensing, General Electric Company ("GE") and have been del-egated 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.

(2) The information sought to be withheld is contained in the document: Loss-of-Coolant efccident ifnalysis Reportfor Brunswick Steam Electric Plant Unit 1 Reload 9 Cycle 10. NEDC-31621.Sup-plement 1, Revision 2, January,1995.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom ofInformation Act ("FOIA"),5 l USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regulations 10 CFR 9.17(a)(4),2.790(a)(4), and 2.790(d)(1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all " confidential commercial information," and some i

portions also qualify under the narrower definition of" trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Ma" Energy _RrojecLv.

Nuclear _ Regulatory Commission. 975F2d871 (DC Cir.1992), and Eublic Citi7en Health @scarch GroupxEDA,704F2dl280 (DC Cir.1983).

(4) Some examples of categories ofinformation which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other l companies;

! b. Information which, if used by a competitor, would reduce his expenditure of resources I

or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; l c. Information which reveals cost or price information, production capacities, budget lev-els, or commercial strategies of General Electric, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future General Electric L customer funded development plans and programs, of potential commercial value to l General Electric;

c. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in both paragraphs (4)a. and (4)b., above.

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l (5) The information sought to be withheld is being submitted to NRC in confidence. The information is i I

of a sort customarily held in confidence by GE, and is in fact so held. Its initial designation as pro-prietary infonnation, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowl-edge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required trans-mittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary 1 agreements which provide for maintenance of the information in confidence.  !

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information i in relation to industry knowledge. Access to such documents within GE is limited on a "need to ,

know" basis. I (7) The procedure for approval of external release of such a document typically requires review by the ,

staff manager, project manager, principal scientist or other equivalent authority, by the manager of  !

the cognizant marketing function (or his delegate), and by the Legal Operation, for technical con- l tent, competitive effect, and determination of the accuracy of the proprietary designation. Disclo-sures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only l

in accordance with appropriate regulatory provisions or proprietary agreements. 1 1

(8) The information identified in paragraph (2) is classified as proprietary because it contains the techm- l cal details and analysis of GE fuel designs, including details of the enrichment and burnable poison j distributions. This information was developed using GE proprietary analytical models, methods and processes, including computer codes, representing a substantial investment by GE.

The development of the evaluation process along with the interpretation and application of the ana- )

lytical results is derived from the extensive experience database that constitutes a major GE asset, j (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the exper-tise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GE's competitive advantage will be lost ifits competitors are able to use the results of the GE expe-rience to normalize or verify their own process or if they are able to claim an equivalent understand-ing by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be lost if the information were disclosed to the public.

Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Page 2

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' GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large  ;

investment in developing these very valuable advanced fuel designs and analytical tools. li I

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.D State of North Carolina - )

CountyofNewllanover ) l

. James F. Klapproth, 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.

Executed at Wilmington, North Carolina, this 10 day of k p $ ) ,199 6 W#

James F. Klapproth f&  ;

General Electric Company Subscribed and sworn before me this /> day of 62/ >h/ ,19 9,6~

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Wy Comm $5iS hv* l#loflff otary Public, State of North Carolina l

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ENCLOSURE 1 l

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO.1 l NRC DOCKET NO. 50-325

,. OPERATING LICENSE NO. DPR-71

TRANSMITTAL OF CORE OPERATING LIMITS REPORT, SUPPLEMENTAL RELOAD LICENSING REPORT, AND LOSS-OF-ACCIDENT ANALYSIS REPORT  !

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l-l CORE OPERATING LIMITS REPORT l BRUNSWICK UNIT 1, CYCL.E 10 l

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