ML20003D509

Forwards Proprietary & Nonproprietary Versions of Environ Impact of Extended Burnup Fuel Cycles in Calvert Cliffs Units 1 & 2. Proprietary Version Available Central Files Only

ML20003D509
Person / Time
Site:	Calvert Cliffs
Issue date:	03/23/1981
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Clark R Office of Nuclear Reactor Regulation
Shared Package
ML19260G846	List: ML20003D509 ML20003D510
References
NUDOCS 8103270487
Download: ML20003D509 (6)

Text

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B ALTIMORE G AS AND ELECTRIC COMPANY P.O. B O X 1M75 B A LTIM O R E. M A R Y L A N D 2120 3 ANTMy t C. LUN DVALL, =J R. ,

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23, 1981 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission '

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ATTENTION: Mr. R. A. Clark, Chief Operating Reactors Branch #3

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SUBJECT:

Calvert Cliffs Nuclear Power Plant Units No.1 and 2, Cocket Nos. 50-317 and 50-318 - Amendment to Environmental Report Gentlemen:

Baltimore Gas and Electric Company intends to operate the Calvert Cliffs units on 18-month refueling cycles. In addition, we propose to extend the batch average burnup of discharged fuel from about 29,000 MID/T to about 43,000 MWD /T. The first discharge batch to exceed 33,C00 MID/T is expected to be discharged during the fifth refueling of Unit 1 in Spring, 1932. Its projected discharge burnup is 34,000 fGD/T.

Fuel demonstration programs are in place to verify acceptable fuel performance at extended burnups. We have assessed the environmental inpact of the proposed action. Specifically, the environmental impact of the Calvert Cliffs fuel cycle would be reduced due to reductions in uranium mining and milling, UF6 production, fuel fabrication, transpor-tation, and spent fuel storage and disposal. Radiological effects are l

increased, but not significantly since doses are generally dominated by short-lived fission products which reach equilibrium levels at lower burnups. Based on the detailed results of the assessment reported in l Enclosure (1), we conclude that operation of Calvert Cliffs Units 1 and

! 2~ on 18-month refueling cycles and at extended discharge fuel burnups results in a net reduction in environmental impact.

Enclosure (1). Enclosure (2) (3) to this is anletter is afrom affidavit non-proprietary version of Enclosurehp Combustion Engineering, Inc.

requesting that information in Enclosure (1) be withheld from public disclosure in accordance with 10 CFR 2.790. g[

The Plant Operations and Safety Review Committee (PCSRC) and Offsite s Safety Review Committce (OSSRC) have reviewed Enclosure (1). They concluded that the action of increasing batch average discharge burnup g

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s hp beyond 33,000 MWD /T constitutes an unreviewed safety question since v s ,e jp \'

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.o e Office of Nuclear Reactor Regulation Page two there would be an increase, however insignificant, in the consequences of accidents which are postulated to release fission products beyond the site boundary. However, the OSSRC and POSRC have also concluded that the margin of safety defined in tFe basis for Technical Specifi-cation 3.4.8 (Specific Activity for Primary Ccolant) has not been reduced and therefore the proposed action does not present an undue risk to the health and safety of the public.

BALTIMORE GAS AND ELCCTRIC COMPANY BY o . s_1:_ A '1- s A / E. ).un:: val l , Jr. /

Vice 7 resident - Supply STATE OF MARYLAtlD, CITY OF BALTIMCRE, TO WIT:

Arthur E. Lundvall, Jr., being duly sworn states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he executed the foregoing Amendment for the purposes therein set forth; that the statements made in said Amendment are true and correct to the best of his knowledge, information and belief; and that he was authorized to execute the Amendment on behalf of said Corporation.

WITNESS My Hand and Notarial Seal thisMi<,(day of / Lla i 1981.

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cc: J. A. Biddison, Esquire G. F. Trowbridge, Esquire Messrs. E. L. Conner, Jr., NRC P. W. Kruse, CE

Enclosures:

(1) Environmental Impact of Extended Burnup Fuel Cycles in Calvert Cliffs Units 1 and 2, CEN-122(B)-P, March 1981 (Proprietary) copies 2 - 41 (2)- Environmental Impact of Extended Burnup Fuel Cycles in Calvert Cliffs Units 1 and 2, CEt;-122(3)-f:P, March 1981-(i:en-Proprietary) 20 copies (3) Proprietary Affidavit

r i AFFIDAVIT FURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc. )

State of Connecticut )

County of Hartford ) SS.:

I, P. L. McGill depose and say that I am the Vice President, Commercial 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 ir:Ynediately below. .I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Cornission's regulations and in conjunction with the application of Baltimore Gas and Electric Co., for withholding this information.

The infonnation for which proprietary treatment is sought is contained in the following document:

CEN-122(B)-P, Environmental Impact of Extended Burnup Fuel Cycles in Calvert Cliffs Units 1 and 2 These documents has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential comercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Comission's regulations, the following is furnished for consideration by the Comission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld, t - ~:

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1. The information sought to be withheld from public disclosure is the development of standard and advanced fuel designs for use in PWR's, which is owned and has been held in confidence by Combustion Engineering.

2. The information consists of test data or other similar data concerning a process, method or component, the application of which results in a substantial competitive advantage to Combustion Engineering.

3. The information is of a type customarily helv in confidence by Combustion Engineering and not customarily disclosed to the 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 provided to the Nuclear Regulatory Commission via letter CP-537 from F.M. Stern to Frank Schroeder dated December 2,1974. This system was applied in determining that the subject documents herein are proprietary.

4. The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Comission.

'. 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 orovisions or proprietary agreements which provide for maintenance of the information in confidence.

6. Public disclosure of the information is likely to cause sub-stantial harm to the competitive position of Combustion Engineering because:

a. A similar product is manufactured and sold by major pressurized water reactors competitors of Combustion Enginc ing.

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b. Development of this information by :-E required tens of thousands cf man-hours 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.

c. In order to acquire such information, a competitor would also require considerable time and inconvenierce related to the development of standard and advanced fuel designs.

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 discussion and milestones concerning the development of standard and advanced fuel designs, 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 Engineering, 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 infor-r _ mation without similar expenditure of resources may enable them to sell at

, prices reflecting significantly lower costs.

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g. Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing tha e 3ts 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.

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P. L. McGill Vice President Cormiercial Sworn to before me this day of ~ i . _. ; . '

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