ML20151Y646
| ML20151Y646 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/11/1998 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138L007 | List: |
| References | |
| NUDOCS 9809180298 | |
| Download: ML20151Y646 (8) | |
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StCtion Support DepCrtment
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A 10 CFR 50.90 V
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PECO NUCLEAR eeco ceerov cemneev 965 Chesterbrook Boulevard L
. A Unit of PECO Energy Wayne. PA 19087 5691 September 11,1998 L
Docket No. 50-277 Ucense No. DPR-44 i
i U.S. Nuclear Regulatory Commission i
Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Unit 2 Additional information Concerning License Change Application ECR 98-01403
Dear Sir:
This letter is in response to a conference call between PECO Energy Company (PECO Energy) and U. S. Nuclear Regulatory Commission (USNRC) staff on September 2 -
1998 and September 9,1998 concerning License Change Application ECR 98-01403.
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. This proposed change was submitted to the USNRC on July 10,1998 (letter from G. D.
l Edwards (PECO Energy) to USNRC) and will revise Technical Specifications (TS)
Section 2.0 (" Safety Limits") and Section 5.6.5 (" Core Operating Limits Report"). These l
- Sections will be revised to incorporate revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the use of cycle-specific analysis performed by General Electric Nuclear Energy (GENE) for PBAPS, Unit 2, Cycle 13. ' contains additionalinformation requested during the September 9,1998 l
conference call. Attachment 1 contains information proprietary to General Electric.
General Electric requests that the document be withheld from public disclosure in accordance with 10 CFR 2.790(a)(4). An affidavit supporting this request is contained in. Attachment 2 contains a non-proprietary version.
If you have any questions, please do not hesitate to contact us.
Ve trulyy rs
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arrett D. Edwards Director - Licensing
Enclosures:
Affidavit, Attachment 1, Attachment 2 1
' cc:
H. J. Miller, Administrator, Region I, USNRC L %-
A. C. McMutray, USNRC Senior Resident inspector, PBAPS
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R. R. Janati, Commonwealth of Pennsylvania
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PDR ADOCK 05000277 P
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COMMONWEALTH OF PENNSYLVANIA:
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COUNTY OF CHESTER a
J. P. Hagan, being first duty sworn, deposes and says:
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That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the foregoing letter concerning License Change Application ECR 98-01403, for Feach Bottom Facility Operating License DPR-44, and knows the contents
- thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
re en Subscribed and sworn to j
before me this //
day of M
998.
wLgan
/ otary Public N
NOTARIAL SEAL CAFOL A. WALToN. Notary Putes My Comen nE re y
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s ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNIT 2 l
Docket No. 50-277 License No. DPR-44 LICENSE CHANGE APPLICATION l-ECR 98-01403 I'
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Response to Requested Information L
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GE Nuclear Energy GeneralElectric company P. o Box 780 Wilmington, Ne 28402
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Affidavit I, Glen A. Watford, being duly sworn, depose and state as follows:
1 (1) I am Manager, Nuclear Fuel Engineering, General Electric Company ("GE") and have been delegated the function of reviewing the infonnation described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
l (2) The information sought to be withheld is contained in the attachment titles, PECO Nuclear Response to NRC Additional Information: PBAPS Unit 2 Cycle 13 SIAfCPR LCA, dated j
September 10,1998. The proprietary text has been enclosed by double brackets.
j (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"),
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5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regulations 10 l
CFR 9.17(a)(4) and 2.790(a)(4) fer " 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 Mass Engray Project v.
i Nuclear Regulatory Commission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Groun v. FDA. 704F2dl280 (DC Cir.1983).
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i (4) Some examples of categories of information which fit into the definition of proprietary information are:
Information that discloses a process, method, or apparatus, including supporting data a.
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;
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c.
Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers;
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d.
Information which reveals aspects of past, present, or future General Electric customer-l 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.
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i Affidavit De 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) he 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 i
l 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 inclading any required transmittals to NRC, have been made, or must be made, pursuant to regulatory l
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 sensitisity of the r
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 I
technical content, competitive effect, and determination 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 i
information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) He 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 Peach Bottom Unit 2's actual core design with GE's 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 vd 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 substantial j
investment of time and money by GE.
The precise value of the expertise to devise an evaluation process and apply the correct analytical i
methodology is difficult to quantify, but it clearly is substantial.
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AfRd'vit i
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 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.
State of North Carolina.
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SS-County of New Hanover
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i Glen A. Watford, 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 day of
, 19 Glen A. W t d General ctric Company Subscribed and sworn before me this /e4 day of dd lw,19ff Q j Jg 0 /m i NM Public, State of North Carolina My Commission Expires
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ATTACHMENT 2 PEACH BOTTOM ATOMIC POWER STAT!ON UNIT 2 Docket No. 50-277 License No. DPR-44 Non-Proprietary Version
Non-proprietary PECO Nuclear Response to NRC Additional Information: PBAPS Unit 2 Cycle 13 SLMCPR LCA Request 1:
PECO Nuclear has been requested to provide the fuel types in the Peach Bottom Unit 2 Cycle 12 and Unit 2 Cycle 13 cores.
Cycle 13 Cycle 12 Quantity Fuel Type Reload Quantity Fuel Type Reload 228 GE13 4.09 - 13GZ 12 204 GE13 3.92 - 15GZ 11 64 GE13 4.06 - 12GZ 12 80 GE13 3.97 - 13GZ 11 204 GE13 3.92 - 15GZ 11 272 GE113.87 - 12GZ 10 80 GE13 3.97 - 13GZ 11 208 GE113.34 - 10GZ 09 188 GE113.87 - 12GZ 10
@!j$5fSisRBRi$$$$$$$i$$169i j!HiB#$5B F<equest 2:
PECO Nuclear has been requested to provide additionalinformation which justifies the decrease in the SLMCPR from Peach Bottom Unit 2 Cycle 12 (1.11) to Unit 2 Cycle 13 (1.10).
Two key parameters, (( )) are calculated by GE Nuclear Energy (GENE) to characterize the SLMCPR. The following table provides all(( )) and associated SLMCPR values which have been calculated by GENE for the PECO Nuclear reactors, as well as the data from GENE's GE13 generic SLMCPR evaluation.
Plant / Cycle
(( ))
(())
SLMCPR GENE GE13 Generic Evaluation
(( ))
(( ))
1.09 Peach Bottom Unit 2 Cycle 13
(( ))
(( ))
1.10 Peach Bottom Unit 3 Cycle 12
(( ))
(( ))
1.11 Limerick Unit 1 Cycle 8
(( ))
(( ))
1.12 The (( )) data indicates that the Peach Bottom Unit 2 Cycle 13 radial power distribution is flatter than the distribution used to perform the GE13 generic SLMCPR evaluation. The (( )) data also indicates that the radial power distribution is progressively flatter for Peach Bottom Unit 3 Cycle 12 and Limerick Unit 1 Cycle
- 8. Based on this data, as the (( )) value increased, the SLMCPR increased.
Additionally, an assessment of the SLMCPR can be made by comparing the relative radial power distributions between Peach Bottom Unit 2 Cycle 12 and Unit 2 Cycle 13. The End-of-Cycle (EOC) relative radial power for the peak bundle in the Cycle 13 core is (( )), while for the Cycle 12 core the value is (( )).
This indicates that the Cycle 13 core is less flat since the peak bundle in Cycle 13 is approximately (( ))
higher on a relative radial power basis. Since the Cycle 13 core's relative radial power distribution is less flat than the Cycle 12 core, it is expected that the Cycle 13 SLMCPR will be lower.
(( GENE Proprietary information))
September 10,1998
(( enclosed by double brackets))
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