ML20098H261

Forwards Proprietary Rev 2 to NSPNAD-8102P, Reload Safety Evaluation Methods for Application to Prairie Island Units. Affidavit Encl.Rept Withheld (Ref 10CFR2.790)

ML20098H261
Person / Time
Site:	Prairie Island
Issue date:	08/30/1984
From:	Musolf D NORTHERN STATES POWER CO.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML19269A518	List: ML20098H261
References
TAC-55816, TAC-55817, NUDOCS 8409120277
Download: ML20098H261 (8)

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Northern States Power Company 414 Nicollet Mall Minneapoks. %nnesota 55401 August 30, 1984 Teleonone tet2> 330 5soo Director Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission Wa shington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLAhT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 PROPRIETARY Topical Report -

reload Safety Evaluation Metheds, NSPNAD-8102P, Rev 2 Twenty-five copies of proprietary topical report NSPNAD-8102P, Revision 2, are being submitted for your review. A check in the amount of $150.00 is also being submitted in accordance with 10CFR Part 170 as the required application fee.

Revision 1 of NSPNAD-8102P was reviewed and approved by the NRC Staff as documented by a February 17, 1983 Safety Evaluation Report (SER). This SER contained several limitations, one involving the control rod drop accident. This submittal is being made to remove the limitation assocated with the control rod drop accident. Upon approval of this topical (NSPNAD-8102P, Rev 2) appropriate Technical Specification changes will be proposed. Following approval of these Technical Specification changes, the current operational restriction (above 90% power, when rods are less than 215 steps withdrawn, the control rods must be operated in manual) will then be removed from plant procedures.

Additional minor changes have also been made in Revision 2. We believe these changes do not require NRC Staff review and are provided for info rmation. Attachment 1 contains a detailed list of the location of the minor changes.

Attachment 2 contains a copy of the affidavit of tir " O Anderson and Mr J R Fisher which states the basis for exemption from public disclosure of this topical. The original affidavit was submitted on February 12, 1982 with NSPNAD-8102P Revision 0.

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David ifusolf I

Manager - Nuclear Suppart ices .

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I, c: Regional Adninistrator-III, NRC i f C{N%g9 NRR Project Managa r , NRC g ** b'd Resident Inspector, NRC G Charnoff

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v Attachments Attached Report, NSPNAD-8102P Revision 2, Contains 10 CFR Part 2.790(a)(4) Information 8409120277 840830 PDR ADOOK 05000292 P PDR

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ATTACHMENT 1 Minor Changes

' Revised' Title Page.

1.

Page 1 of 305 (1)*

Revised 2 Proprietary Data Clause .

Page 3 of 305 (11)

Addition3. of NSP Legal Notice Page 4 of 305 .

Revised4. Table of Contents.

Pages 5 through 13 of 305 (iv th rough xi)

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. Added 5 description Page-15 of 305 (1-2) of appendices on.

to Introduction sec Specific6. Reload Physics ParameteAdded reference to rs. procedure for calculating cycle

• Page 16 of 305 (2-1) .

Revised Terminology.

7.

8. Page 16 of 305 2-1)

Page 17 of 305 ((2-1) according 9 to the Reload Page 18 of 305 Safety EvalRevised definitio y how the calculation is run

10. 2-3) uation procedure.

24. Page 19 of 305 '(2-4) 27

28. Page 84 'of 305 ((3-42)Page 54 of 305 (3-34)

-* Page' 84 of 305 (3-42)

Revised calculation of 1*

a more 11. exact calculation (prompt neutron lifetime) par Page 21 of 305 (2-6) ameter. This is Deleted sentence.

as discussed in Section 2.1.The moderator temperature coefficie t i n as discussed in or may not be positive as wr.

Section 3.0 Conservatisms in the analysis are s calculated The applied in value used in the safety analy i 12.

19. Page 27 of 305 (3-16) itten Revision 1. s s may Page 39 of 305 (3-19)

R: vision 1 Page Number

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, , Attachment 2 1 of 6 AFFIDAVIT Before me, the undersigned authorities, personally apoaared John R.

Fisher, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Nuclear Associates International (NAI), a consulting service of Control Data Corporation, and Roger 0. Anderson,' who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Northern States Power Company (NSP), and that the averments of fact set forth in this Affidavit are true and correct to the best of their knowledge, information, and belief:

" Nd Aonn R. Fisner Technical Director Nuclear Associates International (NAli

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[ 'Ropbr 0. Andersori

! General Supt., Nuclear Analysis l Northern States Power Company (NSP) l Sworn to and subscribed

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?.b. me this 10N' day l /U' 'of Febtair h 1982.

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Attachment 2 2 of 6

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1.0 J. R. Fisher is Technical Director of Nuclear Associates International (NAI), a consulting service of Control Data Corporation (CDC), and Roger O. Anderson is General Superintendent of Nuclear Analysis of .

Northern States Power Company (NSP), and as such we have been speci-fically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing or rule-making proceedings, and are authorized

- to apply for its withholding on behalf of NAI and NSP.

2.0 We are making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in conjuncticn with N/.I/NSP application for withholding accompany this affidavit.

3.0 We have personal knowledge of the criteria and procedures utilized by NAI/NSP in designating information as a trade secret, privileged or as confidential connercial or financial information.

4.0 The following is furnished, per Section 2.790 paragraph (b) (4) of the Commission's regulations, for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

1) A significant part of NAI/NSP's present and future consulting business to utilities is based on the licensing of proprietary computer codes, proprietary procedures for setup and application of these codes, and proprietary results used for validating said system of computer codes and procedures.

2) The information sought to be withheld from public disclosure is owned and has been held in confidence by NAI and its licensees.

3) This information is the type normally held proprietary by NAI/NSp

' and not custorarily disclosed to the public. There is rational basis for det'ermining the types of information that NAI/NSP normally holds proprietary.

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• 3 of 6 4.1 ~ Information is hald proprietary if its release might result in the loss of existing or potential comoetitive advantage. These types of information are categorized as follows: * -

1) Tne information reveals the distinguishing aspects of a program, methodology, algorithms, procedures, etc.

where prevention of their use without license provides a competitive advantage over other companies.

2) The information consists of supporting data, including test data, which aids in validation of methodologies and thereby provides a competitive advantage, e.g.,

computer runtime, reduced number of computer runs, creditability, etc.

3) The use of the information by a competitor would reduce his expenditure of resources and/or improve his competi-tive position in application or licensing of a similar product.

4) The information reveals aspects of past, present, or future NAI/CDC and/or NSP funded development plans and programs of potential commercial value to NAI/;oP.

5) The information is not the property of NAI or NSP, but must be treated as proprietary by NA'I and NSP according

! to agreements with the owner.

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4.2 There are valid reasons for NAI and NSP establishing these categories for evaluation of the confidentiality of information which include the following:

l 1) The use of such information by NAI gives NAI a competi-l.

tive advantage over its competitors. It is, therefore, withheld from disclosure to protect the NAI competitive i position.

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~ 2) It is information which is marketable in many ways. The

- extent to which such information is available to competi-tors diminishes NAI's and NSP's ability to license systems and services involving the use of the information.

3) Use by our competitor would put NAI and NSP at a competitive

, disadvantage by reducing his expenditure of resources at our expense.

4)'Each component of-proprietary information pertinent to a particular competitive advantage is potentially as valuable as -the total competitive advantage. If competitors

. acquire components of proprietary information any one cc.moonent would provide sufficient indication of the total thereby depriving NAI and NSP of a competitive advantage.

'5) NAI and NSP have begun a concerted effort in the world market.

Unrestricted disclosure would jeopardize a potential advantage in this market.

6) The NAI/NSP capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage in the licensing of systems

and services.

r 5.0 The information-is being transmitted to the Commission in confidence I and under the provision in 10 CFR Section 2.790; it is to be _ received l

in confidence by the Commission.

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! -6.0 The information is r.::t available in public sources to the best of l

our knowledge and belief.

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I 7.0 The proprietary information sought to be withheld in this submittal

is that which is appropriately marked in the report. " Qualification i of Reactor Physi

s $iethods for Application to pI Units."

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Attachment 2 l

5 of 6 Tha document is being submitted as a Topical Report and will be referenced in future licensing or standardized reference approval applications.

The information enables NAI and NSP to:

. 1) Justify the methodology and procedures used in the reload analysis.

2) Assist its clients to obtain licenses.

.3) Provide greater flexibility and additional reload design obtions to its clients and through in-house capability.

4) Provide to its clients a means of supporting the olant on a day-to-day basis and hence the potential of increasing availability.

In addition, the information presented in the subject documents and other similar endeavors is of commercial value to NAI and NSP and can be a source of considerable sums of money, for example:

1) NAI and NSP use the information to support the methodology, ,

procedures, and services that NAI/NSP provide to their clients.

2) NAI and NSP use the information to provide a database which aids in the validation of the system of computer codes and provedures which NAI and NSP license to their clients. '

' 3) Based.on the experience gained and the methods developed from this and like information for other clients, NAI and NSP are automating the approach and procedures described and plan to license the resulting system.

8.0 Public disclosure of information concerning the " Qualification of Reactor Physics hethods for Application to PI Units" program is likely to cause substan'tial harm to the competitive position of NAI and NSP by allowing their competitors to develop similar analysis methods and models at a much reduced cost. The analysis performed in this t .

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Attachment 2 6 of 6 endeavor is a result of an analytical system (methodology, programs and procedures) which has been developed at ,NAI and NSP over a period of years. This represents.a significant amount of-highly qualified development effort resulting in NAI's and NSP's current business posture. Should a potential competitor be able to use the results of this analyses and descriptions of methodology in the attached document to establish and verify their own programs and procedures, the technical and monetary effort to achieve a comparable capability wo'uld be vastly reduced. NAI and NSP have expended a significant amount of money and technical resource to achieve their current position, a position which a competitor can attain only through a like investment of money and qualified technical talent.

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