ML20117M702

Proposed Tech Specs Re Min Critical Power Safety Limit

ML20117M702
Person / Time
Site:	Grand Gulf
Issue date:	09/05/1996
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML19311C285	List: ML20117M693 ML20117M702
References
NUDOCS 9609170612
Download: ML20117M702 (6)

Text

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Attachment 3 to GNRO-96/00100

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< Total 2 pages including this page J

b Replacement Page of the Affected Technical Specifications 4

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1 9609170612 960905 PDR ADOCK 05000416 P PDR i

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. Reporting Requirements 5.6

5.6 Reporting Requirements 5.6.5 Core Operatina limits Report (COLR) (continued)

, 10. XN-NF-85-74(P)(A), "RODEX2A (BWR): Fuel Rod Thermal-Mechanical Response Evaluation Model," Exxon Nuclear j- Company, Inc., Richland, WA.

11. XN-CC-33(P)(A), "HUXY: A Generalized Multirod Heatup Code g with 10CFR50 Appendix K Heatup Option," Exxon Nuclear g( ,, Company, Inc., Richland, WA.

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12. XN-NF-825(P)(A), "BWR/6 Generic Rod Withdrawal Error jg 3

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Analysis, MCPR, for Plant Operation Within the Extended Operating Domain," Exxon Nuclear Company, Inc., Richland, i

j .5 y g6 y WA.

l'51.a5  ;$ 13. XN-NF-81-51(P)(A), "LOCA-Seismic Structural Response of j]T x j an Exxon Nuclear Company BWR Jet Pump Fuel Assembly,"

E s[ f!

e Exxon Nuclear Company, Inc., Richland, WA. .

<a { 14. XN-NF-84-97(P)(A), "LOCA-Seismic Structural Response of

]j j5 u an ENC 9x9 BWR Jet Pump Fuel Assembly," Advanced Nuclear E Fuels Corporation, Richland, WA.

m G 1 j33 .

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15. XN-NF-86-37(P), " Generic LOCA Break Spectrum Analysis for  !

g BWR/6 Plants," Exxon Nuclear Company, Inc., Richland, WA.

[ B h :j 16. XN-NF-82-07(P)(A), " Exxon Nuclear Company ECCS Cladding D

8 g Swelling and Rupture Model," Exxon Nuclear Company, Inc:,

Richland, WA.

$(y o 8-h 3

s4 17. XN-NF-80-19(A), Volumes 2, 2A, 2B, & 2C, " Exxon Nuclear-As s a

Ji 2 Methodclogy for Boiling Water Reactors EXEM BWR ECCS I y

1 l552 tzlld Ei Evaluation Model," Exxon Nuclear Company, Inc., Richland, WA.

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s J 18. XN-NF-79-59(P)(A), " Methodology for Calculation for Pressure Drop in BWR Fuel Assemblies," Exxon Nuclear Company, Inc., Richland, WA.- .

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling i Systems (ECCS) limits, nuclear limits such as SDM, transient l analysis limits, and accident analysis limits) of the safety  :

analysis are met.

I (continued)

GRAND GULF 5.0-20 Amendment No. 120

Attachment 4 to GNRO-96/00100

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i General Electric Affidavit to Support Withholding Information

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m GENuclearEnergy GeneralBeetnc Company P 0. Son 180, H6lmmgton, NC 28402 Affidavit I, Ralph J. Reds, being duly sworn, depose and state as follows:

- (1) I am Manager, Fuels and Facility Licensing, General Electric Company ("GE") 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 withholding.

(2) The information sought to be withheld is contained in the document Responses to NRC Requestfor AdditionalInformation (RAI) regarding GGNS Proposed Amendment to the Operating Limit, dated August 30,1996, and is indicated by " brackets" drawn in the margin of the text.

(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 of

. Information Act ("FOIA"),5 USC Sec'. 552(b)(4), and the Trade Secrets Act,18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.790(a)(4) 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 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 Macc Energy Proiect v. Nuclear Regulatorv l Commission 975F2d871 (DC Cir.1992), and Public Citi7en Health Research Groun v.  !

EDA,704F2d1280 (DC Cir.1983). l (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 companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. . Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or -

its suppliers;

d. Information which reveals aspects of past, present, or future General Electric -)

customer-funded development plans and programs, of potential commercial .

value to General Electric; I

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

f. - 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.

(5) The information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. Its initial designation as proprietary information, 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 knowledge 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 transmittals to NRC, have

' been made, or must be made, pursuant to regulatory provisions or proprietary 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 in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(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 content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE ere limited to regulatory bodies, custo ners, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GE's Safety Limit MCPR analysis and the corresponding results which GE has applied to GGNS's actual core design with GE's Gell fuel.

The development of the methods used in these analysis, along with the testing, development and approval of the supporting critical power correlation was achieved at a significant cost, on the order of several million dollars, to GE.

(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 fuel design 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 expertise 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.

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. The research, development, engineering, analytical, and NRC review costs comprise a - l 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 experience to normalize or verify their own process or if they are able to claim an i equivalent underttanding by demonstrating that they can arrive at the same or similar .

conclusso.is.

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 GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools. I 1

State ofNorth Carolina ) SS:

County of New Hanover )

Ralph J. Reda, 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 D ay of $4.5k .19 74  ;

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l Ra ph J. Reda General Electric Company I

Subscribed and sworn before me this de day of dem/ ,19 0 e 71f, h4u d i

No ry Public, State of North Caroi...a My commission expires /0/0//M

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