ML20207M804
| ML20207M804 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/09/1987 |
| From: | Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Harold Denton NRC OFFICE OF ADMINISTRATION (ADM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19292G591 | List: |
| References | |
| NUDOCS 8701130292 | |
| Download: ML20207M804 (5) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 CDW ARD G. B AUER J R-1215)1341 4000 Ja 't. :.""*.'"a;"7..s.,
CUGENE J. BR Af' LEY mesocsa re esammat counset DON ALD BLANN EN KUDOLPH A. CHILLEMI E. C. MI R M H A LL T. H. M AHEFI fpRN ELL J ail u a r f' 9,
1987 PAUL AUERBACH mesesvaser emmenas causeset 2DW ARD J. COLLEN J R.
THOM AS H. MILLER JR.
assesvasar cowarsat Harold R. Denton, Director Office of Nuclear Reactor Regulation Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Peach Bottom Atomic Power Station Unit 2 Docket No. 50-277
Dear Sir:
Enclosed for filing with the Commission is Philadelphia Electric Company's Application for Amendment of Facility Operating License DPR-44.
This Application requests changes to the Peach Bottom Unit 2 Technical Specifications relating to Cycle 8 operation and requests changes to correct several typographical errors.
This filing consists of: 1) the original executed Application; 2) a document entitled " Supplemental Reload Licensing Submittal for Peach Bottom Atomic Power Station Unit 2, Reload 7" dated November, 1986; 3) Errata And Addenda Sheet No. 11 to NEDO-24081, dated November, 1986; 4) a document entitled " Loss-Of-Coolant Accident Analysis for Peach Bottom Atomic Power Station Unit 2, Supplement 1" dated November, 1986, (NEDE-24081-P); 5) a document entitled " General Electric Boiling Water Reactor Extended Load Line Limit Analysis for Peach Bottom 2, Cycle 7 And Peach Bottom 3, Cycle 7" dated May, 1986 (NEDC-31298); 6) a document entitled " Safety Review of Peach Bottom Atomic Power Station, Unit No. 2 At Core Flow Conditions Above Rated Flow Throughout Cycle 7" dated June, 1984 (NEDC-30639); and 7) Errata And Addenda Sheet No. 1 to NEDC-30639 dated July, 1984.
l As stated in the Application, Document 4 above (NEDE 24081-P) contains information which General Electric Company considers confidential and i
proprietary and which is sought to be withheld from public disclosure in kgoI accordance with Section 2.790 of the Commission's regulations. An executed I
affidavit of R. Villa, Manager, Products Licensing of General Electric h
l Company, in support of this request is attached hereto.
8701130292 870109 d M 0*
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Document Control Desk Page 2 January 9, 1987 In accordance with Section 170.12 of the Commission's Regulations, there is enclosed Philadelphia Electric Company's check in the amount of $150 to cover the filing fee for this Application.
Very truly yours, W,
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b Eg e J. Bradle.
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EJB:pkc cc: Regional Administrator, Region I (w/ enclosures)
T. P. Johnson, Resident Inspector (w/ enclosures)
I I
Enclosures 0012q i
r y
GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Rudolph Villa, being duly sworn, depose and state as follows:
1.
I am Manager, Products Licensing, General Electric Company, 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 " Loss-of-Coolant Accident Analysis for Peach Bottom Atomic Power Station Unit 2, Supplement 1" NEDE-24081-P Supplement 1, November 1986.
3.
In designating material as proprietary, General Electric utilizes the def-inition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757. This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it....
A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring information....
Some factors to be considered in determining whether given information is one's trade secret are: (1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expanded by him in developing the information; (6) the ease or difficulty with the which the information could be properly acquired or duplicated by others."
4.
Some examples of categories of information which fit into the definition of proprietary information are:
Information that discloses a process, method or apparatus where a.
prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; b.
Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus, the application of which provide a competitive economic advantage, e.g., by optimization or improved marketability; 1
Information which if used by a competitor, would reduce his expenditure
- c.
of resources'or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product; d.
Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; Information which reveals aspects of past, present or future General e.
Electric customer-funded development plans and programs of potential commercial value to General Electric:
f.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection; Information which General Electric must treat as proprietary according g.
to agreements with other parties.
5.
Initial approval of proprietary treatment of a document is typically made by the Subsection manager of the originating component, the person who is most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within the Company is limited on a "need to know" basis and such documents are clearly identified as proprietary.
6.
The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project Manager, Principal Scientist or other equivalent authority, by the Subsection Manager of the cognizant Marketing function (or delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees then only with appropriate protection by applicable regulatory provisions or proprietary agreements.
7.
The document mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.
I 8.
The document mentioned in paragraph 2 above is classified as proprietary because it contains important details of current and future fuel designs that 1
are not available to other parties.
}
9.
The information to the best of my knowledge and belief has consistently been i
held in confidence by the General Electric Company, no public disclosure has
.ources. All disclosures to been made, and it is not available in public third parties have been made pursuant to reguiatory provisions of proprietary agreements which provide for maintenance of the information in confidence.
2 l
l 4
10.
Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of the General Electric Company and deprive or reduce the availability of profit making opportunities because it would provide other parties, including competitors, with valuable design information regarding current and future fuel designs which was obtained at considerable cost to the General Electric Company. Design information contained in this document includes thermal limits for the current and future General Electric multiple-lattice fuel designs. For a multiple-lattice bundle, one lattice may be the most limiting with respect to Technical Specification thermal limits over one part of the exposure range, and another lattice may be limiting over another part of the range.
In these cases, ccmposite curves of most and least limiting thermal limits will be developed and placed in the plant Technical Specifications. The lattice specific thermal limits themselves, however, are proprietary to the General Electric Company since valuable design information (i.e., lattice local peaking factors) could be derived by competitors with knowledge of the lattice specific thermal limits. Although it is necessary to include some thermal limits information in plant Technical Specifications, thus making this information available to competitors, it is important to limit the amount of information available to the maximum extent possible.
The man-power, computer and manufacturing resources expended by General Electric to develop the generic multiple-lattice fuel designs are valued at approximately $8 million. In addition, the development of individual bundle and lattice designs require over 120 man-hours and approximately $20,000 in computer resources.
STATE OF CALIFORNIA
) ss:
COUNTY OF SANTA CLARA
)
Rudolph Villa, 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 d y of N'*It, 198_{.
ACd/dO Rudolph )tflla General Electric Company Subscribed and sworn before me this y of /h 198[.
N81 18A/l NOTARY PUBLIC, STATE OF CALIFORNIA
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OFFICIAL SEAL
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