ML20141B759

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Proposed Tech Specs 2.1.1.2,revising Safety Limit Minimum Critical Power Ratio to Reflect Results of Cycle Specific Calculation Performed for Unit 1 Operating Cycle 18,expected to Commence in Nov 1997
ML20141B759
Person / Time
Site: Hatch Southern Nuclear icon.png
Issue date: 05/09/1997
From:
SOUTHERN NUCLEAR OPERATING CO.
To:
Shared Package
ML19355F167 List:
References
NUDOCS 9705160025
Download: ML20141B759 (7)
v • d • e


Text

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SLs 2.0 2.0 SAFETY LIMITS'(SLs) 2.1 SLs- l 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 psig or core flow < 10% rated core flow:

THERMAL POWER shall be s 25% RTP.

2.1.1.2 With the reactor steam dome pressure a 785 psig and core

' flow 210% rated core flow:

MCPR shall be 21.10 for two recirculation loop operation or 21.12 for single recirculation loop operation.

2.1.1.3 Reactor vessel water level shall be greater than the top of active irradiated fuel.

2.1.2 Reactor Coolant System (RCS) Pressure SL Reactor steam dome pressure shall be s 1325 psig.

2.2 SL Violations With any SL violation, the following actions shall be completed:

2.2.1 Within I hour, notify the NRC Operations Center, in accordance with 10 CFR 50.72.

2.2.2 Within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

2.2.2.1 Restore compliance with all SLs; and 2.2.2.2 Insert all insertable control rods.

2.2.3 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the plant manager, the corporate executive responsible for overall plant nuclear safety, and the offsite review committee.

9705160025 970509' DR ADOCK 050003 1 (continued)

HATCH UNIT 1 2.0-1 MCPR ,

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SLs 2.0 2.0 SAFETY LIMITS (SLs) 2.1 SLs 2.1.1 Reactor Core SLs 2.1.1.1 With the reactor steam dome pressure < 785 psig or core flow < 10% rated core flow:

THERMAL POWER shall be s 25% RTP.

2.1.1.2 With the reactor steam dome pressure h 785 psig and core flow 210% rat igor flow:

1.10 MCP ska be 2 htP or two recirculation loop operation or a F 00- r sin e recirculation loop operation.

i.I 2.1.1.3 Reactor vessel water level shall be greater than the top of active irradiated fuel.

2.1.2 ' Reactor Coolant System (RCS) Pressure SL Reactor steam dcme pressure shall be s 1325 psig.

. 2.2 SL Violations With any SL violation, the following actions shall be completed:

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2.2.1 Within I hour, notify the NRC Operations Center, in accordance l

with 10 CFR 50.72.  !

1 2.2.2 Within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

2.2.2.1 Restore compliance with all SLs; and 2.2.2.2 Insert all insertable control rods.

2.2.3 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the plant manager, the corporate executive responsible for overall plant nuclear safety, and the offsite review committee.

(continued)

HATCH UNIT 1 2.0-1 = Amend::r.t-Nor-195-~

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1 I ATTACllMENT 1 Edwin I. Ilatch Nuclear Plant - Unit 1 Request to Revise Technical Specifications:

Safety Limit Minimum Critical Power Ratios (SLMCPR)

Affidavit of Proprietary Information i

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4 9 [ws GENuclentEnergy i GeneralBeat Company P. O Bon 7M 1%mmgns, hC 26@2

I, James F. Klapproth, being duly sworn, depose and state as follows: i l

l i- (1)I am Manager, Product Definition, General Electric Company ("GE") and have been delegated the ftmction of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

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(2) The information sought to be withheld is contained in the letter number HL-5368 from H. L. Sumner,.fr. to NRC, Proposed Change to Edwin L Hatch NuclearPlant Unit 1 Technical l Specification Conceming the Safety Limit Minimum Critical Power Ratio (SLMCPR), April 15, l 1997. The proprietary text is denoted by enclosure within double brackets.

!S) In making this application for withholding of proprietary information of which it is the j owner, GE relics upon the exemption from disclosure set forth in the Freedom of 3 3' 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 i

sought is all " confidential commercial infonnation," and some portions also qualify under the narrower definition of " trade secret," within the meanings assigned to those tenns for purposes of FOIA Exemption 4 in, respectively, Critical Mass Encrev Project v.

Nuclear Regulatory Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Groun v. FDA. 704F2dl280 (DC Cir.1983).

(4) Some examples of categories ofinformation which fit into the defimition of proprietary infonnation are:

a. Information that - discloses a process, method, or apparatus, including i 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;

c. -Infonnation which reveals cost or price information, production capacities, .

budget levels, or commercial strategies of General Electric, its customers, or its  !

suppliers; i

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

customer-funded development plans and programs, of potential commercial i value to General Electric; ' -

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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 proprieta.y for the reasons set forth in both paragraphs (4)a. and (4)b., above.  !

(5) The infonnation sought to be withheld is being submitted to NRG in confidence. The .;

infonnation 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 - i its unauthorized disclosure, are as set forth in (6) and (7) following. The infonnation j sought to be withheld has, to the best of my knowledge and belief, consistently been held . j 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 j agreements which provide for maintenance of th' e infonnation 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. I 1

, (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 j accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory l bodies, customers, and potential customers, and their agents, suppliers, and licensees,

and othen 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 proprie*ary because it contains details of GE's Safety Limit MCPR analysis and the corresponding results which  ;

GE has applied to El Hatch Unit I actual core design for cycle 18 with GE's GEIS fuel.

i 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 infonnation sought to be withheld is likely to cause substantial  !

hann 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  !

s 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 NRG-approved methods.  ;

, The research, development, engineering, analytical, and NRC review costs comprise a substantialinvestment 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. i Page 2 l 1

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l GE's competitive advantage will be lost ifits competitors are able to use the results of the GE experience to nonnalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can anive at the same or similar conclusions.

The value of this information to GF 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.

State of North Carolina ) gg',

County of New lianover )

Ja mes 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 1 est of his knowledge, infonnation, and belief.

-th Executed at Wilmington, North Carolina, this il dayof hG .19 %

c t 1sV Wh James F. Klapproth h General Electric Company Subscribed and sworn before me this l day of 'l[ .1997

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ATTACIIMENT 2 Edwin L IIatch Nuclear Plant - Unit I Request to Revise Technical Specifications:

Safety Limit Minimum Critical Power Ratios (SLMCPR)

Nonproprietary Version of the Basis for Change Request l

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