View source for LIC-94-0092, Forwards Rev 6 to OPPD-NA-8301-NP,Rev 4 to OPPD-NA-8302-NP, Theoretical Manual & User'S Manual for Axial Shape Analyzer..., Rev 6 to OPPD-NA-8301-P & Rev 4 to OPPD-NA-8302-P.OPPD-NA-8301-P & OPPD-NA-8302-P Withheld

{{Adams
| number = ML20070P361
| issue date = 05/02/1994
| title = Forwards Rev 6 to OPPD-NA-8301-NP,Rev 4 to OPPD-NA-8302-NP, Theoretical Manual & User'S Manual for Axial Shape Analyzer..., Rev 6 to OPPD-NA-8301-P & Rev 4 to OPPD-NA-8302-P.OPPD-NA-8301-P & OPPD-NA-8302-P Withheld
| author name = Gates W
| author affiliation = OMAHA PUBLIC POWER DISTRICT
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000285
| license number = 
| contact person = 
| document report number = LIC-94-0092, LIC-94-92, NUDOCS 9405110263
| package number = ML19304C106
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 8
}}

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Omaha Public Power District 444 South 16th Street Mall Omaha, Nebraska 68102-224'7 402/636-2000 May 2, 1994 LIC-94-0092 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, DC 20555

==Reference:==
Docket No. 50-285 Gentlemen:

==SUBJECT:==
Revised Core Reload Analysis Methodology Topical Reports for Fort Calhoun Station (FCS) Cycle 16 Omaha    Public Power Reload Analysis          District for FCS. This(OPPD) analys is includes revisions of methodology topicalis currently p reports, which will require NRC approval .                     The topical reports incorporate methodology changes and reference updates including FCS-specific application of methods previously approved by the NRC for other plants. The early submittal of these enclosed reports for NRC review, as agreed during discussions between the NRC and OPPD staffs, will allow timely NRC feedbuk on the acceptability of the use of CASM0-3/ SIMULATE-3 computer codes for reload design.
Enclosure 1 is the Core Reload Analysis Methodology Overview (OPPD-NA-8301-P, Revision 6, May 1994), and Enclosure 2 is the Neutronics Design Methods and Verification (OPPD-NA-8302-P, Revision 4, May 1994). Revisions are indicated by vertical lines in the right margins of affected pages; a summary of changes is provided for each report.            The proposed changes to the OPPD methodology specifically consist of:
: 1)     Use of the NRC approved CASMO-3 and SIMULATE-3 codes for aeutronics design analysis.
: 2)     Implementation of various description changes and revisions to physics methods     that    are     consistent            with       the          capabilities      of the CASMO-3/ SIMULATE-3 design model.
: 3)     Documentation of benchmark results for FCS measured physics data versus SIMULATE-3 predictions for Cycles 11-15.
9405110263 940502                                                                    0 PDR     ADOCK 05000285                                                      i P                     PDR                                                     l       g (5-5124                                         Employment with Equal opportun:ty

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U. S. Nuclear Regulatory Commission LIC-94-0092 Page 2 Pursuant to 10 CFR 2.790, proprietary versions of the topical reports (Enclosures          ,
I and 2) contain trade secrets and/or privileged commercial information - as               i determined by ABB-Combustion Engineering and Westinghouse Electric Corporation,            l owners of the information. Accordingly. OPPD requests that this proprietary information be withheld from public disclosure; Enclosure 3 includes supporting affidavits and other associated documentation from these companies. Enclosure 4 contains the non-proprietary versions of Enclosures 1 and 2.
Also enclosed is a copy of the recently published Axial Shape Analyzer for SIMULATE-3 (ASAS) Theoretical Manual and User's Manual (Yankee Atomic Electric Company, April 19,1994). This document is listed as Reference 6-3 in topical report OPPD-NA-8301-P and as Reference 2-7 in topical report OPPD-NA-8302-P.
Fort Calhoun Station is currently scheduled to begin Cycle 16 on April 29, 1995 following the 1995 refueling outage. To support this schedule, OPPD requests feedback by July 1,1994 through the NRC Project Manager on the acceptability of the use of CASMO-3/ SIMULATE-3 for reload design. Formal approval of the topical reports in Enclosures 1 and 2 is requested by March 29, 1995.
If you should have any questions, please contact me.
Sincerely, d                '
W. G. Gates A Vice President WGG/tcm Enclosures c:     LeBoeuf, Lamb, Greene and MacRae (Enclosures 1, 2, & 3)
L. J. Callan, NRC Regional Administrator, Region IV (w/o Enclosures)
S. D. Bloom, NRC Pro 3ect Manager R. P. Mullikin, NRC Senior Resident Inspector (w/o Enclosures)
H. Borchert, Director-Division of Radiological Health, Nebraska Department of Health (w/o Enclosures) j

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Enclosure 3 f
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AFFIDAVIT PURSUANT                                                '
TO 10 CFR 2.790 Combustion Engineering, Inc.            )
State of Connecticut                    )
County of Hartford                      )      SS.:                                               -
I, S. A. Toelle, depose and say that I am the Manager, Nuclear Licensing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed-the
                                                                                                      ?
information which is identified as proprietary and referenced in the                             ,
paragraph immediately below.              I am submitting this affidavit- in conjunction with the application of Omaha Public Power District and in    conformance      with the     provisions    of  10            CFR  2.790     of      the h
Commission's regulations.
The information for wh1,           proprietary treatment is sought'is contained in the following doci ants:
: 1)     " Omaha Public Power District Nuclear Analysis, Reload Core                              'i Analysis Methodology Overview, OPPD-NA-8301-P, Rev. 06,"                                   '
i May 1994.
: 2)     " Omaha Public Power District Nuclear Analysis, Reload Core Analysis     Methodology,     Neutronics     Design            Methods     and            !
Verification, OPPD-NA-8302-P, Rev. 04," May 1994.
r These documents have been appropriately designated as. proprietary.
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a                               7 h
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                                                                                                                   .1
                                                                                                                    )
trade secret, privileged or as confidential commercial or financial                                        l l
information.                                                                                               j Pursuant to the provisions of paragraph (b) (4) of Section 2.790                                  l l
of the Commission's regulations, the following is furnished for                                             ,
consideration         by    the   Commission     in       determining           uhether           the information sought to be withheld from public disclosure, included in the above referenced documents, should be withheld.
: 1.       The information sought to be withheld from public disclosure,                                  .
which is owned and has been held in confidence by Combustion Engineering, is the methodology for reload fuel engineering and F
nuclear design methodology accuracy benchmarks.                                                  ;
: 2.       The information consists of test data or other similar data                                      .
concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.                                                                                     !
: 3.       The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to the                                      l public.      Combustion Engineering has             a rational basis for determining      the types   of    information        customarily held                    in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.       The details of the aforementioned system were                               i provided to the Nuclear Regulatory Commission via letter DP-537                                  ,
8 i

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                                              -             from  F.         Stern to Frank Schroeder dated December       2,    1974.
This sys es was applied in determining that the subject document harein    proprietary.
: 4. The in:  rmation is being transmitted to the Commission in confide :e under the provisions of 10 CFR 2.790 with the undersi Auding that it is to be received in confidence by the-Commitfion.
: 5. The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties              ,
has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
: 6. Public disclosure           of the   information  is  likely  to     cause substantial harm to the competitive position of Combustion Engineering because:
: a. A similar product           is manufactured and     sold by major pressurized       water     reactor   competitors   of  Combustion Engineering.
: b. Development of this information by C-E required thousands of manhours and hundreds of thousands of dollars.            To the best of my knowledge and belief, a competitor would have to undergo        similar     expense    in   generating   equivalent information.

                                -4   -
: c. In order to acquire such information, a competitor would also require considerable time and inconvenience developing a reload methodology and accuracy benchmarks.
: d. The information required significant effort and expense to obtain the licensing approvals necessary for application of the information. Avoidance of this expense would decrease a  competitor's   cost   in     applying      the information and marketing   the   product     to   which      the  information  is applicable,
: e. The information consists of a methodology for reload fuel engineering   and   nuclear      design     methodology   accuracy benchmark , the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Enginc- ing,'take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
: f. In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical,        ;
manufacturing, licensing, quality assurance and other costs and expenses must be included.        The ability of Combustion Engineering's   competitors to utilize such            information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.

        .                                                   . _  =              . ~
: g. Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development.         In addition, disclosure would have    an   adverse  economic    impact    on  Combustion Engineering's    potential   for   obtaining     or  maintaining foreign licensees.
Further the deponent sayeth not.
n S. 4.    /
S. A. Toelle Manager Nuclear Licensing                      ,
Sworn to before me this M2 d      day of   AAl[             ,  1994
(
i               . fD D obary Pult1dc My commission expires: e9 -3 /-9 9 l
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