ML20198H243

Forwards Proprietary Info Re TS Change,Implementing Conservative Safety Limit Min Critical Power Ratio for Plant Cycle 7 Core & Fuel Designs.Revised TS Bases Pages,Also Encl.Proprietary Info Withheld

ML20198H243
Person / Time
Site:	Hope Creek
Issue date:	08/26/1997
From:	Eric Simpson Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046D759	List: ML20198H243 ML20198H247
References
LCR-H97-05, LCR-H97-5, LR-N97528, NUDOCS 9709170094
Download: ML20198H243 (6)

Text

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• Public Service Electne and Gas company E. C. Simpson Public Service Electric and Gas Company P O. Box 236, Hancocks Bridge, NJ 00038 609-339 1700 m .e, .

t - AUG 261997 LR-N97528 LCR H97-05 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS (SUPPLEMENT)

SAFETY LIMIT MINIMUM CRITICAL POWER RATIO (SLMCPR)

HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:

On March 31, 1997, Public Service Electric & Gas (PSE&G) Company transmitted, via letter LR-N97187, a proposed change to the Hope Creek Technical Specifications (TS). The proposed changes revised TS 2.1.2, "THEPMAL POWER, High Pressure and High Flow",

ACTION a.l.c for LCO 3.4.1.1, " Recirculation Loops" and the Bases for TS 2.1, " Safety Limits". The changes contained in that I request implemented an appropriately conservative Safety Limit Minimum Critical Power Ratio (SLMCPR) for Hope Creek's Cycle 7 (current cycle) core and fuel designs. Justification for those l proposed changes was developed from General Electric SLMCPR l analyses performed to address SLMCPR issues identified in a 10CFR21 notification made by General Electric on May'24, 1996.

On July 16, 1997, PSE&G supplemented the March 31, 1997, submittal to provide revised SLMCPR values for the upcoming operating cycle (Cycle 8). As a result of NRC questions received concerning the differences between the Cycle 7 and Cycle 8 SLMCPR values, PSE&G is providing additional information contained in Attachment 1 of this letter. PSE&G has determined that the information contained in this letter does not alter the conclusions reached in the 10CFR50.92 No Significant Hazards analysis previously submitted with LCR H97-05 in the July 16, 1997 letter. In accordance with 10CFR50.91(b) (1), a copy of this submittal has been sent to the State of New Jersey.

Attachment 2 of this letter provides_ revised Technical Specification Bases pages associated with Hope Creek Technical Specification Amendment No. 101, issued on July 24, 1997. The Bases pages revised by Amendment No. 101 impacted the same

-section as Technical Specification Amendment No. 100, also issued 4 on July 24, 1997. Therefore, the Bases pages for Amendment No.

4 THE INIVRMATIoN CONTAINED IN ATTACHMENT 1 oF THIS LETTER IS PROPRIETARY n

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AUG26gggy Document Control Desk LR-N97528-101 are being revised to reflect the changes already approved through the issuance of Amendment No. 100.

Should you have ar questions regarding this request, we will be pleased to discus. them with ynu.

Sincerely

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Affidavit Attachments (2)

C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Jaffe, Licensing Project Manager - HC U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris (X24)

USNRC Senior Resident Inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95 4933 n

REF: LR-N97528 LCR H97-05 STATE OF NEW - JERSEY )

) SS.

COUNTY OF SALEM )

E. C. Simpson, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.

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Subscribed and Sworn to before me this A(o day of , 1997 0-fML 0.

NotaryPudcofN[ Jersey ML.

EUZABETH J. KIDD NOTARY PU8UC OF NEW JERSEY My Commission Expires Apr# 25,2000 My Commission expires on

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. GE Nuclear Energy GenenJ Electnc Company P O Jos 780, avmington.NC 28402 Affidavit I, Ralph Reda, 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 l to be withheld, and have been authorized to apply for its withholding. I (2) The information sought to be withheld is contained in the transmittal LR N927528, dated August 26, 1997. This is a supplement to the document, Request for Change to Technical Specification Safety Limit MCPR, LCR H97-05 for llope Creek, Operating License No. NPF-57, Docket No. 50-354 (3) In making this application for withholding of proprietary information of which it is the owner, l 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 9.17M(4) and 2.790(a)(4) for " trade secrets and commercial or fmancial information obtained from a person and privileged or confidential"(Exemption 4). The mater.al for which exemption from disclosure is here sought is all " confidential commercial information," and some portions also qualify under the narrower defmition of " trade secret,"

within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Enercy Project v. Nuclear Reculatorv Commission. 975F2d871 (DC Cir.1992),

and Public Citizeri Health Research Grrun v. FDA. 704F2dl280 (DC Cir.1983).

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

a. Informa%n that discloses a process, method, or apparatus, including supporting data and analysc . 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 Electrie, 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.

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Affidxvit 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 conGdence. The information is of a sort customarily held in conGdence by GE, and is in fact so held. Its initial designation as proprietary informatia, 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 conndence 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, l 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 2 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 desi;; nation. Disclosures outside GE are limited to regulatory bodies, customers, and pctential 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 identined in paragraph (2) is classified as proprietary because it would provide other parties, including competitors, with information related to detailed results of analytical models, methods and processes, including computer codes, which GE has developed, requested NRC approval of, and applied to perform evaluations of the BWR. 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 infonnation sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of pront-making opportunities. The fuel design and analytical methodology are part of GE's comprehensive BWR safety and technology base, and their 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.

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 difGcult to quantify, but it clearly is substantial.

GE's competitive advantage will be lost if its 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.

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Affid:vit 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 GB 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 llanover )

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.

l Executed at Wilmington, North Carolina, this 2-- day of k/d9rMe4 ,1997

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. c Ralph J. Reda General Electric Company Subscribed and sworn before me this hday of gM ui,1947 l

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Nota . tic, State of North Carolina

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