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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217F8911999-10-13013 October 1999 Forwards Copy of FEMA Region IV Final Rept for 990623-24, Grand Gulf Nuclear Station Exercise.Rept Indicates No Deficiencies or Areas Requiring Corrective Action Identified During Exercise ML20216J8891999-10-0404 October 1999 Forwards Details of Existing Procedural Guidance & Planned Administrative Controls.Util Respectfully Requests NRC Review & Approval of Changes by 991020.Date Will Permit to Implement Changes & Realize Full Benefit During Refueling ML20217B0361999-10-0404 October 1999 Refers to Investigation Conducted by NRC OI Re Activities at Grand Gulf Nuclear Station.Investigation Conducted to deter- Mine Whether Security Supervisor Deliberately Falsified Unescorted Access Authorizations.Allegation Unsubstantiated ML20212J8151999-09-29029 September 1999 Forwards Insp Rept 50-416/99-12 on 990725-0904.One Violation Noted & Being Treated as Noncited Violation.Licensee Conduct of Activities at Grand Gulf Facility Characterized by Safety Conscious Operations,Sound Engineering & Maint Practices ML20216J6811999-09-28028 September 1999 Ack Receipt of ,Transmitting Rev 31 to Physical Security Plan for GGNS Under Provisions of 10CFR50.54(p). NRC Approval Not Required,Based on Determination That Changes Do Not Decrease Effectiveness & Limited Review ML20212J7361999-09-28028 September 1999 Forwards Insp Rept 50-416/99-11 on 990830-0903.No Violations Noted.Purpose of Insp to Review Solid Radioactive Waste Management & Radioactive Matl Transportation Programs ML20212J5321999-09-27027 September 1999 Forwards Insp Rept 50-416/99-14 on 990830-0903.No Violations Noted.Inspectors Determined That Radioactive Waste Effluent Releases Properly Controlled,Monitored & Quantified ML20216J7101999-09-26026 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator License Examinations ML20216J8141999-09-26026 September 1999 Forwards Proprietary Renewal Applications for Licensed Operators for Wk Gordon & SA Elliott at Grand Gulf Nuclear Station.Proprietary Info Withheld ML20212F5521999-09-23023 September 1999 Forwards SER Accepting Util Analytical Approach for Ampacity Derating Determinations at Grand Gulf Nuclear Station,Unit 1 & That No Outstanding Ampacity Derating Issues as Identified in GL 92-08 Noted ML20212D9211999-09-16016 September 1999 Informs That NRC Staff Completed Midcycle PPR of GGNS on 990818 & Identified No Areas in Which Licensee Performance Warranted Insp Beyond Core Insp Program.Details of Insp Plan Through March 2000 Encl ML20212A9331999-09-13013 September 1999 Forwards Partially Withheld Insp Rept 50-416/99-15 on 990816-20 (Ref 10CFR73.21).One Violation of NRC Requirements Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy ML20211P7631999-09-10010 September 1999 Discusses Staff Issuance of SECY-99-204, Kaowool & FP-60 Fire Barriers at Plant.Proposed Meeting to Discuss Subj Issues Will Take Place in Oct or Nov 1999 ML20212A6951999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20212A8341999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20211Q3471999-09-0909 September 1999 Forwards Federal Emergency Mgt Agency Final Rept for 990623 Plant Emergency Preparedness Exercise.No Deficiencies Noted & One Area Requiring Corrective Action Identified ML20211Q3091999-09-0909 September 1999 Forwards Safety Evaluation Accepting BWROG Rept, Prediction of Onset of Fission Gas Release from Fuel in Generic BWR, Dtd July 1996 ML20211Q4861999-09-0808 September 1999 Informs That Util Has Discovered Dose Calculation Utilized non-conservative Geometry Factor for Parameter.Calculation Error Being Evaluated in Accordance with Corrective Action Program ML20211Q0091999-09-0808 September 1999 Forwards Request for Addl Info Re Individual Plant Exam of External Events for Grand Gulf Nuclear Station,Unit 1. Response Requested by 000615 ML20211N4301999-09-0808 September 1999 Discusses Proposed Meeting to Discuss Kaowool Fire Barriers. Staff Requesting That Affected Licensees Take Issue on Voluntary Initative & Propose Approach for Resolving Issues ML20211P4171999-09-0707 September 1999 Ack Receipt of ,Which Transmitted Addendum to Rev 30 to Physical Security Plan for Ggns,Per 10CFR50.54(p).NRC Approval Is Not Required,Since Util Determined That Changes Do Not Decrease Effectiveness of Plan ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211K6061999-08-31031 August 1999 Informs That Plant Has No Candidates to Take 991006 Generic Fundamentals Exam ML20211K5641999-08-31031 August 1999 Forwards Rev 39 to Grand Gulf Nuclear Station Emergency Plan Non-Safety Related, IAW 10CFR50,App E,Section V. Changes Do Not Decrease Effectiveness of Plan & Continues to Meets Stds of 10CFR50.47(b) & Requirements of App E ML20211J2321999-08-26026 August 1999 Advises That Info Contained in to Support NRC Review of GE Rept, Prediction of Onset of Fission Gas Release from Fuel in Generic BWR, Will Be Withheld from Public Disclosure ML20211J3761999-08-25025 August 1999 Corrected Ltr Informing That Info Provided (on Computer Disk & in Ltr to Ineel ) Marked as Proprietary Will Be Withheld from Public Disclosure Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954,as Amended.Corrected 990827 ML20211F4881999-08-25025 August 1999 Advises That Info Submitted by 990716 Application & Affidavit Containing Diskette & to Ineel Mareked Proprietary Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954 ML20211F7751999-08-24024 August 1999 Forwards Insp Rept 50-416/99-10 on 990809-13.No Violations Noted.Insp Covered Licensed Operator Requalification Program & Observations of Requalification Activities ML20211C4381999-08-20020 August 1999 Forwards Rev 31 to Physical Security Plan for Protection of Grand Gulf Nuclear Station,Iaw 10CFR50.54(p).Util Has Determined That Rev Does Not Decrease Effectiveness of Plan. Encl Withheld,Per 10CFR73.21 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20211B3761999-08-16016 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001, ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20211A9481999-08-12012 August 1999 Informs of Completion of Analysis of Heat Transfer in Cooler During Fan Coast Down & Concludes That Potential Exists for Steam Foundation,Under Conditions Where Dcw Sys Flow Is Lost Prior to Full Isolation Valve Closure ML20210P8411999-08-0909 August 1999 Forwards Insp Rept 50-416/99-09 on 990613-0724.No Violations Noted.Activities at Facility Generally Characterized by safety-conscious Operations,Sound Engineering & Maint Practices & Careful Radiological Work Controls ML20210N6401999-08-0303 August 1999 Informs That Eighteeen Identified Penetrations Will Be Restored to Conformance with Licensing Requirements Prior to Restart from RFO10,scheduled for Fall 1999,per GL 96-06. Example of Piping Analysis Being Performed,Encl ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210K1951999-07-30030 July 1999 Forwards Insp Rept 50-416/99-03 on 990405-08 & 0510-11.No Violations Identified ML20211K7491999-07-30030 July 1999 Forwards Ltr Rept Documenting Work Completed Under JCN-W6095,analyses Performed at Ineel to Calculate Minimum Time to Fuel Pin Failure in Boiling Water Reactors (BWR) ML20210K6661999-07-29029 July 1999 Forwards Fitness for Duty Program Performance six-month Rept for Period Covering Jan-June 1999,per 10CFR26.71 ML20210F3591999-07-26026 July 1999 Forwards Proprietary Version & Redacted Version of Wyle Test Rept M-J5.08-Q1-45161-0-8.0-1-0,re Pressure Locking & Thermal Binding Test Program.Proprietary Version Withheld ML20210E3251999-07-23023 July 1999 Forwards Insp Rept 50-416/99-07 on 990622-25.No Violations Noted.Emergency Plan & Procedures During Biennial Emergency Preparedness Exercise Was Conducted ML20210D2401999-07-21021 July 1999 Informs of Resignation of Operator WE Griffith,License OP-20806-1,from Entergy Operations,Inc ML20209J0311999-07-16016 July 1999 Forwards Proprietary Info Supporting Review of Generic Alternate Source Term Request.Proprietary Info Withheld Per 10CFR2.790 ML20209G4791999-07-15015 July 1999 Forwards Proposed Emergency Plan Change as Addendum to Changes Previously Submitted Via GNRO-98/00028 & GNRO-99/00007,for NRC Review & Approval ML20210B1031999-07-15015 July 1999 Forwards Insp Rept 50-416/99-08 on 990502-0612.Determined That Three Severity Level IV Violations Occurred & Being Treated as Noncited Violations ML20210H3211999-07-14014 July 1999 Forwards Proprietary Info Supporting Review of 970506 Submittal of BWROG Rept, Prediction of Onset of Fission Gas Release from Fuel in Generic Bwr. Proprietary Info Withheld Per 10CFR2.790 ML20209D7511999-07-0909 July 1999 Responds to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. as Result of NRC Review of Util Responses,Info Revised in Rvid & Rvid Version 2 Will Be Released ML20209D7671999-07-0101 July 1999 Submits Response to Violations Noted in Insp Rept 50-416/99-02 on 990222-26 & 0308-12.Corrective Actions: Contractor Performance Has Been re-evaluated in Regards to UFSAR Reviews ML20196K4901999-07-0101 July 1999 Discusses Relief Requests PRR-E12-01,PRR-E21-01,PRR-E22-01, PRR-P75-01,PRR-P81-01,VRR-B21-01,VRR-B21-02,VRR-E38-01 & VRR-E51-01 Submitted by EOI on 971126 & 990218.SE Accepting Alternatives Proposed by Util Encl ML20196J5711999-06-30030 June 1999 Advises That Versions of Submitted Info in 990506 Application & Affidavit, Re Proposed Amend to Revise Ts,Marked Proprietary Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20216J8891999-10-0404 October 1999 Forwards Details of Existing Procedural Guidance & Planned Administrative Controls.Util Respectfully Requests NRC Review & Approval of Changes by 991020.Date Will Permit to Implement Changes & Realize Full Benefit During Refueling ML20216J7101999-09-26026 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator License Examinations ML20216J8141999-09-26026 September 1999 Forwards Proprietary Renewal Applications for Licensed Operators for Wk Gordon & SA Elliott at Grand Gulf Nuclear Station.Proprietary Info Withheld ML20211Q4861999-09-0808 September 1999 Informs That Util Has Discovered Dose Calculation Utilized non-conservative Geometry Factor for Parameter.Calculation Error Being Evaluated in Accordance with Corrective Action Program ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211K6061999-08-31031 August 1999 Informs That Plant Has No Candidates to Take 991006 Generic Fundamentals Exam ML20211K5641999-08-31031 August 1999 Forwards Rev 39 to Grand Gulf Nuclear Station Emergency Plan Non-Safety Related, IAW 10CFR50,App E,Section V. Changes Do Not Decrease Effectiveness of Plan & Continues to Meets Stds of 10CFR50.47(b) & Requirements of App E ML20211C4381999-08-20020 August 1999 Forwards Rev 31 to Physical Security Plan for Protection of Grand Gulf Nuclear Station,Iaw 10CFR50.54(p).Util Has Determined That Rev Does Not Decrease Effectiveness of Plan. Encl Withheld,Per 10CFR73.21 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20211B3761999-08-16016 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001, ML20211A9481999-08-12012 August 1999 Informs of Completion of Analysis of Heat Transfer in Cooler During Fan Coast Down & Concludes That Potential Exists for Steam Foundation,Under Conditions Where Dcw Sys Flow Is Lost Prior to Full Isolation Valve Closure ML20210N6401999-08-0303 August 1999 Informs That Eighteeen Identified Penetrations Will Be Restored to Conformance with Licensing Requirements Prior to Restart from RFO10,scheduled for Fall 1999,per GL 96-06. Example of Piping Analysis Being Performed,Encl ML20211K7491999-07-30030 July 1999 Forwards Ltr Rept Documenting Work Completed Under JCN-W6095,analyses Performed at Ineel to Calculate Minimum Time to Fuel Pin Failure in Boiling Water Reactors (BWR) ML20210K6661999-07-29029 July 1999 Forwards Fitness for Duty Program Performance six-month Rept for Period Covering Jan-June 1999,per 10CFR26.71 ML20210F3591999-07-26026 July 1999 Forwards Proprietary Version & Redacted Version of Wyle Test Rept M-J5.08-Q1-45161-0-8.0-1-0,re Pressure Locking & Thermal Binding Test Program.Proprietary Version Withheld ML20210D2401999-07-21021 July 1999 Informs of Resignation of Operator WE Griffith,License OP-20806-1,from Entergy Operations,Inc ML20209J0311999-07-16016 July 1999 Forwards Proprietary Info Supporting Review of Generic Alternate Source Term Request.Proprietary Info Withheld Per 10CFR2.790 ML20209G4791999-07-15015 July 1999 Forwards Proposed Emergency Plan Change as Addendum to Changes Previously Submitted Via GNRO-98/00028 & GNRO-99/00007,for NRC Review & Approval ML20210H3211999-07-14014 July 1999 Forwards Proprietary Info Supporting Review of 970506 Submittal of BWROG Rept, Prediction of Onset of Fission Gas Release from Fuel in Generic Bwr. Proprietary Info Withheld Per 10CFR2.790 ML20209D7671999-07-0101 July 1999 Submits Response to Violations Noted in Insp Rept 50-416/99-02 on 990222-26 & 0308-12.Corrective Actions: Contractor Performance Has Been re-evaluated in Regards to UFSAR Reviews ML20209B6081999-06-30030 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20195J6351999-06-16016 June 1999 Forwards Addendum to Rev 30 of GGNS Physical Security Plan IAW 10CFR50.54(p).Addendum Is Submitted to Announce Relocation/Reconfiguration of Plant Central & Secondary Alarm Station Facilities.Rev Withheld,Per 10CFR73.21 ML20195G0281999-06-0909 June 1999 Submits Summary on Resolution of GL 96-06 Re Eighteen Penetrations Previously Identified as Being Potentially Susceptible to Overpressurization ML20207F5041999-06-0202 June 1999 Forwards Updated Medical Rept IAW License Condition 3 for DA Killingsworth License OP-20942-1.Without Encls ML20206P2981999-05-13013 May 1999 Forwards Responses to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, Cancelling 990402 Submittal ML20206N1921999-05-10010 May 1999 Provides Revised Attachment 2 for Alternative Request IWE-02,originally Submitted 990429 Re Bolt Torque or Tension Testing of Class Mc pressure-retaining Bolting as Specified in Item 8.20 of Article IWE-2500,Table IWE-2500-1 ML20206J0941999-05-0404 May 1999 Forwards Proprietary & Redacted ME-98-001-00,both Entitled, Pressure Locking & Thermal Binding Test Program on Two Gate Valves with Limitorque Actuators. Rept ME-98-002-00 Re Flexible Wedge Gate Valves,Encl.Proprietary Rept Withheld ML20206E7811999-04-29029 April 1999 Proposes Alternatives to Requirements of ASME B&PV Code Section XI,1992 Edition,1992 Addenda,As Listed.Approval of Alternative Request on or Before 990915,requested ML20206D8171999-04-29029 April 1999 Informs NRC of Results of Plant Improvement Considerations Identified in GGNS Ipe,As Requested in NRC . Licensee Found Efforts Have Minimized Extent of Radiological Release in Unlikely Event That Severe Accident Occurred ML20206D7281999-04-28028 April 1999 Forwards South Mississippi Electric Power Association 1998 Annual Rept, Per 10CFR50.71(b).Licensee Will Submit 1998 Annual Repts for System Energy Resources,Inc,Entergy Mississippi,Inc & EOI as Part of Entergy Corp Annual Rept ML20206C9551999-04-22022 April 1999 Forwards 1999 Biennial Emergency Preparedness Exercise Scenario. Without Encl ML20205M1311999-04-0202 April 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. Info Was Discussed During Conference Call with NRC on 990126.Wyle Position Paper Encl.Subj Paper Withheld ML20205H5861999-04-0101 April 1999 Requests Relief from ASME B&PV Code,Section XI for Period of Time That Temporary non-code Repair Was in Effect,Per 10CFR50.55a(g)(5)(iii) ML20205F1781999-03-31031 March 1999 Forwards Consolidated Entergy Submittal to Document Primary & Excess Property Damage Insurance Coverage for Nuclear Sites of Entergy Operations,Inc,Per 10CFR50.54(w)(3) ML20196K7101999-03-26026 March 1999 Submits Reporting & Recordkeeping for Decommissioning Planning,Per 10CFR50.75(f)(1) ML20205A6511999-03-25025 March 1999 Responds to NRC Re Violations Noted in Insp Rept 50-416/99-01 on 990201-05.Corrective Actions:Program Will Be Implemented to Ensure Accessible Areas with Radiation Levels Greater than 1000 Mrem/H ML20204E7391999-03-15015 March 1999 Forwards Objectives for June 1999 Emergency Preparedness Exercise for Plant.Without Encl ML20207H9291999-03-0404 March 1999 Submits Update to Original Certification of Grand Gulf Nuclear Station Simulation Facility IAW Requirements of 10CFR55.45(b)(5) ML20207E3081999-03-0303 March 1999 Informs That GGNS Severe Accident Mgt Implementation Was Completed on 981223.Effort Was Worthwhile & Station Ability to Respond & Mitigate Events That May Lead to Core Melt Has Been Enhanced ML20207E3221999-03-0303 March 1999 Notifies of Change in Status of Mj Ellis,License SOP-43846. Conditional License Requested to Accommodate Medical Condition.Revised NRC Form 396 with Supporting Medical Evidence Attached.Without Encls ML20207A8161999-02-24024 February 1999 Forwards 1998 Annual Operating Rept for Ggns,Unit 1. Listed Attachments Are Encl ML20207A9901999-02-24024 February 1999 Informs That Util Has No Candidates from GGNS to Nominate for Participation in Planned Gfes,Scheduled for 990407 ML20203A1551999-02-0101 February 1999 Forwards Grand Gulf Nuclear Station Fitness for Duty Program Performance six-month Rept for Reporting Period 980701-981231 ML20202G0791999-01-26026 January 1999 Informs That He Mcknight Has Been Permanently Reassigned from Position Requiring License to Perform Assigned Duties. License Is No Longer Needed,Effective 981231 ML20199K4151999-01-20020 January 1999 Forwards Proposed Addendum to Emergency Plan Changes Previously Submitted Via GNRO-98/00028 for NRC Review & Approval as Required by 10CFR50.54(q) & 50.4 ML20199K6771999-01-14014 January 1999 Provides Notification of Planned ERDS Software Change Scheduled to Take Place on 990215 ML20199D8811999-01-11011 January 1999 Submits Response to SE JOG Program on Periodic Verification of motor-operated Valves,In Response to GL 96-05 ML20199D9521999-01-0808 January 1999 Informs That CE Cresap,License SOP-4220-4,has Been Permanently Reassigned from Position Requiring License & No Longer Has Need for License,Per 10CFR50.74 ML20199A6081999-01-0606 January 1999 Submits List of Plant Info Brochures Disseminated Annually to Public & List of Updated State &/Or Local Emergency Plan Info,Per NRC Administrative Ltr 94-07, Distribution of Site-Specific & State Emergency Planning Info ML20202B7531998-12-21021 December 1998 Submits Ltr Confirming Discussion with J Tapia,Documenting Extension for Response to NOV 50-416/98-13.Util Response Will Be Submitted by 990212 1999-09-08
[Table view] |
Text
. . . _ _ _ _ _ _ _ _
, Entirgy operiti:ns,Inc.
l OkfJJ l P.O. Box 756 Port Gibson, MS 39150 l
Tel 601437 6408 l Fax 601437 2795 October 22,1996 $$'gpf;lagan l Opsations Grand Gulf Nuclear Station i
l l
l U.S. Nuclear Regulatory Commission
! Mail Station P1-37 Washington, D.C. 20555 Attention: Document Control Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Cycle 9 Reload Revised Response to NRC Request for Additional Information Regarding Minimum Critical Power Safety Limit
References:
- 1. GNRO-96/0053, Proposed Amendment to the Operating License, dated May,5,1996
- 2. GNRO-96/0087, Revision to Proposed Amendment to the Operating License, dated July,31,1996
- 3. GNRO-96/00100, Response to NRC Request for Additional Information Regarding Minimum Critical Power Safety Limit GNRO: 96/00119 Gentlemen:
By letter dated August 22,1996, the staff requested information regarding proposed changes to the minimum critical power safety limit in the Grand Gulf Nuclear Station Technical Specifications (references 1 and 2). EOl responded to this request on September 5,1996 (reference 3). Discussions of these response <3 were held with members of the staff on October 10,1996. These discussions concluded that the response to question 2 should be supplemented to provide additional details regarding the use of SPC (Siemens Power Corporation) experimental critical power test data in the GGNS Cycle 9 MCPR safety limit analysis. In addition, the staff raised questions concerning the statistical expressions used to determine uncertainty values. A revised response to question 2 is attached.
Based on the guidelines in 10CFR50.92, EOl has concluded that the revised A
/'POfb response involves no additional significant hazards considerations.
l General Electric (GE) considers portions of the information contained in this I
submittal to be proprietary. The proprietary portions are marked by vertical bars in y 7, , the right hand margin. In accordance with the requirements of 10CFR2.790(b), an 9610310264 961022 PDR ADOCK 05000416 P PDR
..~ .- .
GNRO-96/00119 Page 2 of 4 ,
i affidavit (Attachment 3) is provided to support withholding of the information from public disclosure.
Portions of the information considered proprietary by Siemens Power Corporation (SPC) are enclosed with "[ ]". This information was obtained from Topical Report '
ANF-1125, Supplement 1 (P)(A), a proprietary document previously approved by the staff on March 8,1990. Since this information has already been approved as i proprietary, an application for withholding is not being submitted. Of course, the !
l Information should continue to be treated as proprietary.
In addition,'some information is considered proprietary by EOl and is enclosed
- within "{ }". This information was developed by EOl using a combination of data l and analytical methods considered proprietary by both GE and SPC. EOl's l contractual obligations prohibit disclosure of this information to other persons or ,
agencies. Therefore EOl is applying Sr its withholding per 10CFR2.790(b). An l affidavit for this request is included as Attachrnent 4.
Yours truly, f !
i g -
J JJH/RWB/be attachments: 1. Affir per 10CFR2.790
- 2. Revised EOl Response to NRC Request for Additional Information l 3. GE Affidavit to Support the Withholding of Proprietary Information l- 4. EOl Affidavit Request for Withholding Per 10CFR2.790(b) i cc: (See Next Page) l
\ l 1
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- - _ .-. .. - . .- . = .
I i .
GNRO-96/00119 l Page 3 of 4 l cc: Ms. S. C. Black (w/a) (NRC/NRR)
Mr. A. Heymer (NEI) ;
l Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a) l Mr. J. E. Tedrow (w/a) )
Mr. H. L. Thomas (w/o) l Mr. J. W. Yelvertori (w/a)
Mr. L. J. Callan (w/a) l Regional Administrator l U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 l Mr. T. P. Gwynn i
Director, Division of Reactor Safety l U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission l Mail Stop 13H3 Washington, D.C. 20555 Mr. A. C. Thadani Associate Director for Technical Assessment ,
i Office of Nuclear Reactor Regulation l
U.S. Nuclear Regulatory Commission l Mail Stop 13H3 Washington, D.C. 20555 l
I
r
.' Att chm:nt 1 to:
GNRO-96/0011C Page 1 of 1 BEFORE THE l UNITED STATES NUCLEAR REGULATORY COMMISSION l LICENSE NO. NPF-29 DOCKET NO. 50-416 l lN THE MATTER OF ENTERGY MISSISSIPPI l and SYSTEM ENERGY RESOURCES, INC.
! and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.
1 AFFIRMATION
)
l 1, J. J. Hagan, being duly sworn, state that I am Vice President, Operations GGNS of
! Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this applicction; that I signed this application as Vice President, Operations GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my knowledge, information and belief.
l mW J. .
an}
l STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and State abbve named, this 22'* day of ee.-r.au. ,1996.
^
' (SEAL)
M L 6)&../l.O Notary Public' i
My commission expires:
( tm:: risnmm :cist muc bis?)hibbl$f SY51,Y.NE
...r..__..._ ..- . _ _ . . . __ _ _ . ...--. _. _ _ __ _ . _ _._.. _ .-..._ _ _ _._ ..- _ .___ _ _ _ ._ ~
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Attachm:nt 3 to: i GNRO-96/00119 Page 1 of 1 GE Affidavit to Support the Withholding of Proprietary Information 1.
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GENuclear Energy GeneralElectac Company P O Box 780, Wilmington. NC 28402 Affidavit I, Ralph J. Reda, being duly sworn, depose and state as follows:
(1) I am Manager, Fuels and Facility Licensing, General Electric Company ("GE") and have been delegated the function of reviewing the infonnation 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 the document Clarifications to ]
Responses to NRC Requestfor AdditionalInformation (RA1) regarding GGNS Proposed i Amendment to the Operating Limit, dated August 30,1996, and is indicated by " bars" drawn )
in the margin of the text.
(3) In making this application for withholding of proprietary information of which it is the i 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 CFF. 9.17(a)(4) and 2.790(a)(4) 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 FOI A Exemption 4 in, respectively, Critical Mass Enerev Proiect v. Nuclear Regulatory Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Group v.
EDA,704F2dl280 (DC Cir.1983).
(4) Some examples of categories ofinformation which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors withe it license from General Electric constitutes a competitive economic advaraage 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;
- c. Information which reveals cost or price information, production capacities, l budget levels, or commercial strategies of General Electric, its customers, or i
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;
_ _ _ _ . _ _ ___.-m _ _ . _ _ . _ . _ _ . _ _ _ _ _ _ _ _ _ _ ._..___ ,
?.
AWidavit
- e. 'Information which discloses patentable subject matter for which it may be {
desirable to obtain patent protection.
- f. The information sought to be withheld is considered to be proprietary for the i reasons set forth in both paragraphs (4)a. and (4)b., above.
l (5) The infonnation 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. Its j initial designation as proprietary information, and the subsequent steps taken to prevent its :
unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, censistently 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 confM ace.
~
.'(6)' initial approval of proprietary treatment of a document m eh by the manager of the l' originating component, the person most likely to be acquamted with the value and sensitivity L of the information in relation to industry knowledge. Access to such documents within GE is
. limited on a "need to know" basis.
1
- (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 l
Operation, for technical content, competitive effect, and determination of the accuracy of the j proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, l I
and potential customers, and their agents, suppliers, and licensees, and others with a j- legitimate need for the information, and then only in accordance with appropriate regulatory
]
provisions or proprietary agreements.
i (8) The information identified in paragraph (2) is classified as proprietary because it contams -
details of GE's Safety Limit MCPR analysis and the corresponding results which GE has !
! applied to GGNS's actual core design with GE's gel 1 fuel. !
The development of the methods used in these analysis, along with the testing, development and approval of the supporting critical power correlation was achieved at a significant cost, j- on the order of several million dollars, to GE.
l l ,
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm l
to GE's competitive position and foreclose or reduce the availability of profit-making !
opportunities. The fuel design is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of i the technology base goes beyond the extensive physical database and analytical methodology ;
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 r done with NRC-approved methods.
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i Atfl6xit ;
i i l The research, development, engineering, analytical, and NRC review costs comprise a i . substantial investment of time and money by GE.
, The precise value of the expertise to devise an evaluation process and apply the correct j
- analytical methodology is difficult to quantify, but it clearly is substantial. J 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 or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same ca 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
j to undertake a similar expenditure of resources would unfairly provide competitors with a j 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.
I i
State of North Carolina ) sg:
. County of New llanover )
l Ralph J. Reda, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and correct to i the best of his knowledge, information, and belief.
! Executed at Wilmington, North Carolina, this Mday of IModd'4 ,19 94
/
Ra! .Reda General Electric Company i
Subscribed and sworn before me this ll day of Ob6( ,19
, vanN.,
j** #(
9k 0.6 / i g+f.^? 't Notary Public, State of North Carolina gQ O f
. My commission expires W commicelan r.,a,-g gp
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Attachm:nt 4 to:
I
, GNRO-96/00119 Page 1 of 2 EOI Affidavit Request for Withholding Per 10CFR2.790(b) l l
l Affidavit I, Michael J. Meisner, state that I am Director of Nuclear Safety & Regulatory Affairs of Entergy Operations, Inc.; (EOl) and that I dispose and state the following:
l 1. I am designated by EOl to review the confidential commercial information referenced herein l which is sought to be withheld and authorized to apply for the withholding of the information on behalf of Entergy Operations, Inc. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.970 (b)(1) and in conjunction with the application of EOl for withholding this information.
l l 2. EOl seeks to withhold from public disclosure portions of its response to question 2 in l Attachment 2 of the document GNRO-96/00119, Revised Response to NRC Request for l Additional Information Regarding Minimum Critical Power Safety Limit, October 22,1996.
l The information in the submittal has been marked as confidential.
i 3. EOl has a rational basis for determining the type of information customarily held in confidence by it and reviews documents or reports which might contain confidential )
information to determine whether the subject documents should be accorded confidential treatment. This review concluded that the indicated portions of the subject document referenced herein does contain confidential commercial information which justifies it being withheld from public disclosure.
- 4. This information is of the type customarily held in confidence by EOl and its fuel suppliers and, other than the Commission, is intended to be held in confidence and not disclosed to the public. The information is classified as confidential because it contains information on test data and analytical methods applied to Grand Gulf Nuclear Station's Cycle 9 core design
, which contains both GE11 fuel and SPC 9X9-5 fuel. Although EOl is the owner of the l
information, the information was developed by using data and analytical methods which l General Electric and Siemens Power Co. individually designate as proprietary. Entergy Operations is under contractual obligation to General Electric and Siemens Power Co. to treat this information as proprietary.
- 5. The research, development, engineering and NRC review costs comprise an investment of l l
time and costs to GE, SPC, and EOI. Disclosure of this information to a competitor would l permit the competitor to improve its competitive position by giving valuable insights into BWR fuel design and licensing methodology. In addition, disclosure would harm EOl's contractual obligations related to this information.
- 6. The information sought to be withheld has been held in confidence by EOl and its contractors.
- 7. The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has and will be made only to the regulatory requirements
( of proprietary agreements which provice for the maintenance of this information.
l k
I Attichm:nt 4 to:
i
.. GNRO-96/00119 ;
l- Page 2 of 2 l EOl Affidavit Request for Withholding Per 10CFR2.790(b) l l
l THAT the statements made hereinabove are, to the best of my knowledge, information and belief, truthful and complete.
1 I I l >
I M. J. Meisner -
STATE OF MISSISSIPPI COUNTY OF chaus i
SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the county and state above named, this e z " day of -een a.. .1996
-J h W ..L D
- -*" 1 STATaa:27 t.0T AhY FUBu,v
> gyi nc Nismcr.a Jer 2 Not'ary Public
! My comminion expires: co;cDTic')EEm sta Sgj?.'M CE l
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l f.
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