ML20248C483

Forwards Rev 1 to Vermont Yankee Nuclear Power Station Cycle 20 COLR & Supplemental Reload Licensing Rept. Proprietary Repts,Including Rev 0 to 24A5416AA & TR NEDC-32814P,encl.Proprietary Info Withheld,Per 10CFR2.790

ML20248C483
Person / Time
Site:	Vermont Yankee
Issue date:	05/28/1998
From:	Reid D VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20013J785	List: ML20248C483 ML20248C495 ML20248C508
References
BVY-98-74, NUDOCS 9806020165
Download: ML20248C483 (13)

Text

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VERMONT YANKEE NUCLEAR POWER CORPORATION 185 Old Ferry Road, Brattleboro, VT 05301-7002 (802) 257-5271 May 28,1998 BVY 98-74 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington,DC 20555

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References:

' (a) Core Operating Limits Report for Vermont Yankee Cycle 20, May 1998 (b) Supplemental Reload Licensing Report for Vermont Yankee Naclear Power Station Reload 19 Cycle 20, May 1998 i (c) Lattice Dependent MAPLHGR Report for Vermont Yankee Nuclear (

Power Station Reload 19 Cycle 20, March 1998 (d) Vermont Yankee Nuclear Power Station SAFER /GESTR-LOCA )

Losr-of-Coelant Analysis, NEDC-32814P, March 1998 (e) Letter, VYNPC to USNRC, BVY 97-69, May 22,1997

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket 50-271) .

Core Operating Limits Report and Additional Reports In accordance with Section 6.7.A.4 of the Vermont Yankee Technical Specifications, enclosed is the Core Operating Limits Report (COLR) for Vermont Yankee Cycle 20, May 1998 (Reference (a)). This report presents the cycle-specific cperating limits for the operation of Cycle 20 of the Vermont Yankee Nuclear Power Station. g Also enclosed for your convenience is a copy of the Supplemental Reload Licensing Report for Vermont Yankee Nuclear Power Station Reload 19 Cycle 20, May 1998 (Reference (b)), and a copy of the Lattice Dependent MAPLHGR Report for Vermont Yankee Nuclear Power Station Reload 19 Cycle 20, March 1998 (Reference (c)). These reports present design information, calculation results, and operating limits pertinent to l the operation of Cycle 20 of the Vermont Yankee Nuclear Power Station.

In addition to the above cycle-specific documents, we are also submitting a copy of the Vermont Yankee Nuclear Power Station SAFER /GESTR-LOCA Loss-of-Coolant Analysis, NEDC-32814P, March 1998 (Reference (d)). With this submittal, the RELAPSYA Loss-of-Coolant Accident (LOCA) analysis is being replaced as the analysis of record by SAFER /GESTR analysis for Vermont Yankee. Therefore, the SAFER /GESTR analysis establishes the updated licensing basis for Cycle 20. However, f l the RELAP5YA LOCA analysis methodology is still being maintained for use at Vermont Yankee. \

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Vamosi vni,u; .Nimw i><>wi n ci>io oinu.is Reference (e) provided Vermont Yankee's detailed plans for the Cycle 20 reload and committed to submit a discussion of the LOCA analysis changes and a comparison of analysis results. Since then, it has been determined in NEDC-32814P that the SAFER /GESTR analysis for Vermont Yankee demonstrates compliance with 10 CFR 50.46 and Appendix K. Therefore, it is not necessary to compare the results of the RELAP5YA methodology against the results from the SAFER /GESTR methodology.

Please note that the attached References (c) and (d) contain proprietary information of General Electric Company. In accordance with 10 CFR 2.790(b)(1), a5 davits attesting to the proprietary nature of these references are attached. As such, General Electric requests that the enclosed References (c) and (d) be withheld from public disclosure.

Should you have any questions or require additional information, please ccntact this omce.

Sincerely, Vermont Yankee Nuclear Power Corporation Donald A. Reid Senior Vice President, Operations Enclosure cc: USNRC Projed Manager VYNPS USNRC Region I, A&ninistrator USNRC Resident inspector, VYN?h BVY 98-74 May 28,1998 Page 2 of 2

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GE Nuclear Energy GwseralElectric conq>any P. o Box 780, Witnhytun, NC 2602 Affidavit I, Glen A. Watford, being duly sworn, depose and stme as follows:

(1) I am Manager, Nuclear Fuel Engineering, General Elevric Company ("GE") 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) *Ihe information sought to be withheld is contained in 24A5416AA, Revision 0, "Iottice DependentMAPIllGR Reportfor Verment Yanke Nuclear Power Station Peload 19 Cycle 20,"

March 1998.

(3) In makmg this application for withholding of proprietary infonnation of which it is the owr,er, GE relies upon the exemption from disclosure set forth in the Freedom ef 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 couunercial or fmancial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is al! " confidential commercial 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 Enercy Project v.

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

(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 dats and analyses, where prevention of its use by General Electric's competitors without licenr: 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; l c. Information dich reveals cost or price infonnation, production capacities, budget levels, or commercial strategies of General Electric, its customera, or its suppliers;

d. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential conuncreial value to General Electric;

c. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

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Affid'vit 1

i l He 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. He information I 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 f

as set forth in (6) and (7) following. He information sought to be withheld has, to the best of my knowledge and belief, consistently been held in con 6dence by GE, no public disclosure has been

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made, and it is not available in public sources. All disclosures to third parties including any j required transmittals to NRC, have been made, or must be made, pursuant to regulatory 1 provisions or proprietary agreements wh;ch 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 'oe acqua:nted with the value and sensitivity of the i information in relation to industry knowledge. Access to such documents witlun GE is limited on a l "need to know" basis.

(7) He procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent anthority, by the manager of the cogmzant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary des lgnation. 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 information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) He infonnation identified in paragraph (2) is classi6ed as proprietary because it contains details of GE's fuel designs and the corresponding results which GE has applied to actual core designs with GE's fuel.

%e development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a signiDeant cost, on the order of several million dollars, to GE.

(9) Public disclosure of the informatieri 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 stability analysis is part of GE's comprehensive 13WR 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 me60dology 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.

%e research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GE.

He precise value of the expertise to devise an evaluation process and apply the corre:,t analytical

! methodology is difficult to quantify, but it clearly is substantial.

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 u 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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A]idavit The value of this information to GE would be lost if the infonnation 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 ) SS; County of New Hanover )

Glen A. Watford, being duly sworn, deposes and says:

nat he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

st Executed at Wilmington, North Carolina, thi } ~ day of M ,19 3E

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/ Glen A rd Gene Electric Company Subscribed and sworn before me this A/J/ day of M ,19 f/[

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Notary Public, State of North Carolina My Commission Expires /#/[6d"/

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General Electric Company AFFIDAVIT I, David J. Robare, being duly swom, depose and state as follows:

(1) I am Technical Account Manager, Technical Services, General Electric Company

("GE") 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 forits withholding.

(2) The information sought to be withheld is contained in the GE proprietary report NEDC-32814P, DRF B13-01874, Vermont Yankee Nuclear Power Station SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis, Class III (GE Company Proprietary Information), dated March 1998. The proprietary information is delineated by bars marked in the margin adjacent to the specific material.

(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 of Information Act ("FOIA"),- 5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and 2.790(d)(1) 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 sought is all " confidential commercial 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 Enerev Proiect v. Nuclear Reculatory Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Group

v. FDA,704F2dl280 (DC Cir.1983),

(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 daL' and analyses, where prevention ofits use by General Electric's competitors without license from General Electric constitutes a competitive economic l advantage over other companies; l

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;

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 infornntion 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 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 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 knowledgc. 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 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 information, 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.

1243N3RTil Afridavit Page 2 L_____________________--_____ _ m

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.

'Ilie 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 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 develog.nent 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 difficult to quantify, but it clearly is substantial.

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 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.

1 12/13/93RTil Affidavit Page 3 k .

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STATE OF CALIFORNIA )

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COUNTY OF SANTA CLARA )

David J. Robare, 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.

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Executed at San Jose, California, this 21 st day of May 1998, 1

David J. Robare General Electric Company l

Subscribed and sworn before me this 21 st day of May I '98.

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1 Notary Public, State of California l

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NOTARY PUBUCCALIFORNIA 9 SAN FRANCISCO COUNTY -

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CHANGE 11 TO VERMONT YANKEE CORE OPERATING LIMITS REPORT

1. Please remove the existing cover page and replace.with the attached: Vermont Yankee Nuclear Power Station Cycle 20 Core Operating Limits Report, Revision 1, cover page, dated May 1998.

- 2. Please remove the existing pages ii and iii and replace with the attached pages ii and iii.

3. Please remove the existing pages 13,16,17, and 18 and replace with the attached pages 13,16,17, and 18. ,

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MEMORANDUM DE&S-BOLTON To' Records Manacement Services Date May 27.1998 Group # NER VY 98-008 From M. A. Sironen W.O.# 00241.00.0021.00.00000

. Subject Vermont Yankee Core Ooeratine Limits Reoort

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Cycle 20, Rev.1 File # NEVY9808.WPD I Please Lssue the attached Vermont Yankee Core Operating Limits Report for Cycle 20, Rev. I as a controlled document. This revision incorporates an improved stability exclusion and buffer

region for Cycle 20 and revises the reference to the GE Supplemental Reload Licensing Report.

l The document has been reviewed and approved and is ready for issuence. The chan'es are:

Replace the Cover Sheet with the attached Cover Sheet.

Replace pages ii and iii with the attached pages il and iii.

! Replace page 13 with the attached page 13.

Replace pages 16,17 and 18 with the attached pages 16,17 and 18.

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.fhd>& /1. O M. A. Sironen, I l VY Client Manager i

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'B.T. Hubbard, VY Reload Coordinator 1

c: File WRF #98-0017 j 1

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CHANGE 10 TO VERMONT YANKEE CORE OPERATI"G LIMITS REPORT

1. Please remove the entire contents of your manual and u, place with the attached: Vermont T: .,kee Nuclear Power Station Cycle 20 Core Operating Limits Report, Revision 0, dated May 1998.

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MEMORANDUM 1

DE&S-BOLTON To Records Management Services Date Mav 24.1998 Group # NER VY 98-007 From . M. A. Sironen W.O.# 00241.00.0021.00.00000 Subject Vermont Yankee Core Operating Limits Renort I.M.S.#

l Cycle 20, Rev. O File # VY98007. DOC Please issue the attached Vermont Yankee Core Operating Limits Report for Cycle 20, Rev. 0 ,

as a controlled document. The revision incorporates the Cycle 20 core operating limits based on EDCR 97-422. The document has been reviewed and approved and is ready for issuance. The entire document should be replaced with the attachment.

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n j M. A. Sironen, VY Client Manager p/f.

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VY Reload Coordinator )

. c: File WRF #98-0017 Q

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