ML20137C617

Forwards Proprietary Rev 1 to NEDC-32687P, Copper Nuclear Station SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis. Encl Withheld (Ref 10CFR2.790)

ML20137C617
Person / Time
Site:	Cooper
Issue date:	03/19/1997
From:	Stramback G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20007F660	List: ML20137C617
References
NLS970040, NUDOCS 9703250060
Download: ML20137C617 (7)

Text

r moJ ife:SnrJaLLm,

v. Nebraska Public Power District ]y2=?'"

NLS970040 March 19,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

Subject:

SAFER /GESTR Loss-of-Coolant Accident Analysis Report Cooper Nuclear Station, NRC Docket 50-298, DPR-46 The Nebraska Public Power District (the District) is hereby submitting "S AFER/GESTR Loss-of-Coolant Accident Analysis" Report, NEDC-32687P, Revision 1, for Cooper Nuclear Station (CNS). The purpose of the submittal is to request your approval prior to its implementation at CNS.

The report summariz.es the loss-of-coolant accident analysis performed for CNS using the NRC-approved SAFER /GESTR methodology and current thermal power level of 2381 MWt. The results of the analysis demonstrate the following:

(1) The acceptance criteria for Emergency Core Cooling System (ECCS) performance as dermed in 10CFR50.46 are satisfied.

(2) The Licensing Basis Peak Cladding Temperature (PCT) calculated by SAFER /GESTR is below 1600 F, which is well below the 2200 F limit.

(3) The statistical Upper Bound PCT calculated by S AFER/GESTR is below 1460" F.

Based on the above-mentioned SAFER /GESTR analysis results, the District concludes that CNS meets the NRC's SAFER /GESTR licensing analysis requirements.

In accordance with the provisions of 10CFR2.790, the report, NEDC-32687P, Revision 1, enclosed herewith contains proprietary information and should be withheld from public disclosure.

Attached is General Electric's aflidavit attesting to the proprietary nature of the information contained in NEDC-32687P, Revision 1.

f 9703250060 970319 +,. t /

PDR ADOCK 05000298 1 i

, 3 P PDR g f ;,, j

.t ~U.,- t as i -

i a V U 4t< ' a ,ev, tw ( -\

. .~

/<

/t 1 i ge

~

ss gga y m R gm n w_ ~ mityMRWam

,~ -

__ ~ = = . -

c . i= = n= = L = =

NLS970040 March 19,1997 Page 2 of 2 Should you have any questions concerning this matter, please contact me.

Sincerely, PBA P. D. Graham Vice President - Nuclear

/gs Attachment Enclosure cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - nim Project Directorate IV-1 Senior Resident Inspector i

USNRC NPG Distribution i

i

l ATTACHMENT 3 LIST OF NRC COMMITMENTS l

Correspondence No: NLS970040 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE None l

l l

l l

l l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 8 OF 9 l

}

l

)

i General Electric Company l

AFFIDAVIT i

1, George H. Stramback, being duly sworn, depose and state as follows:

(1) I am Project Manager, Regulatory Services, General Electric Company ("GE") and j have been ddegated 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.

1 (2) The information sought to be withheld is contained in the GE proprietary report NEDC-32687P, Cooper Nuclear Station SAFER /GESTR-LOCA Loss-of-Coolant l Accident Analysis, Revision 1, Class III (GE Proprietary Information), dated March j 1997. The proprietary information is delineated by bars marked in the margin j adjacent to the specific material.  !

(3) In making this application for withholding of proprivary information of which it is  :

the owner, GE relies upon the exemption from disclosure set forth in the Freedom of I Information Act ("FOIA"),5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 i USC Sec.1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and l 2.790(d)(1) for " trade secrets and commercial or financial information obtained from l a person and privileged or confidential" (Exemption 4). The material for which i exemption from disclosure is here sought is all " confidential commercial I 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 Mass Energy Proiect v. Nuclear Regulatorv ,

Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Groun i

v. FDA,704F2dl280 (DC Cir.1983). l (4) Some examples of categories of information 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 ofits 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; i

GBS-97-2-atSAFER3. doc Aflidavit Page 1

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;

e. 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.

(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. 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 availeble 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. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(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. l l

(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 I of the accuracy of the proprietary designation. Disclosures 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 infom1ation, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GE has developed, obtained NRC approval of, and applied to perform evaluations of the loss-of-coolant accident for the BWR.

GBS-97-2-af5A FER 3. doc Aflidavit Page 2

- - - .- . .. - --. .=. - _ - - -.

The development and approval of the BWR loss-of-coolant accident analysis computer codes used in this analysis was achieved at a significant cost, on the order of several million dollars, to GE.

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to cause l 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 expertise to detennine 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 3 of the GE experience to normalize or' verify their own process or if they are able to l claim an equivalent understanding 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 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. l l

I

! GBS-97-2-afSAFER3. doc Afridavit Page 3 l

STATE OF CALIFORNIA )

) ss:

COUNTY OF SANTA CLARA )

George B. Stramback, 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 San Jose, California, this /~7 b day of 7/tmld 1997. .

LVSALI $

' ' Golfrge B. S'tramback General Electric Company T

Subscribed and swom before me this /714 day of )hld1997.

u- _c; N rytublic, State of California I

JUUE A CUES Commhsten # 1113834  ;

Notcry Put$c-Cercrnlo  :

-[ santo Ctra County 4 My Comrn Expires Oct 20.2GD I GBS-97-2-atSAFER3. doc Affidavit Page 4