L-80-263, Forwards RCS Asymmetric LOCA Load Evaluation, Revision 1, Including App B & Nonproprietary & Proprietary Versions of App A.Proprietary Version Withheld (Ref 10CFR2.790). Affidavit Encl
| ML17266A243 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/08/1980 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17208A891 | List: |
| References | |
| LL-80-263, NUDOCS 8008120427 | |
| Download: ML17266A243 (13) | |
Text
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR '-8008120)27 DOC ~ DATE: 80/08/08 NOTARIZED: YES, FACIL:50-335 St. Lucie Planti Unit 1i Florida Power 8 Light Co.
AUTH NAME AUTHOR AFFILIATION UHR I G i R. E-Florida Power 8 Light Co.
REC IP ~ NAME RECIPIENT AFFILIATION CLARKgR ~ A.
Operating Reactors Branch 3
DOCKET 05000335
SUBJECT:
Forwards "RCS Asymmetric LOCA Load Evaluationi" Revision if includina App B
lI nonprroprietary 8 proptietary versions of App A.Proprietary version wi'thheld (ref 10CFR2.790).
Affidavit encl.
DISTRIBUTION CODE:
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,6 TITLE: Prop> ietary Info after Issuance of License NOTES:
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P.o. BOX 529100, MIAMI,FL 33152 i'
FLORIDA POWER 8 LIGHTCOMPANY August 8, 1980 L-80-263 WITHHOLD ATTACHMENT FROM PUBLIC DISCLOSURE Office of Nuclear Reactor Regulation Attention:
Mr. Robert A. Clark, Chief Operating Reactors Branch 83 Division of Operating Reactors U.
S. Nuclear Regulatory Commission Washington, D. C.
Dear Mr. Clark:
Re:
St. Lucie Unit 1
Docket No. 50-335 As mmetric LOCA Loads An NRC Staff letter dated February 16, 1978 requested that we expand the analysis of asymmetric LOCA loads beyond the scope committed in our letter of February 9, 1976, which addressed the capability of reactor vessel supports only.
Our August 1977 report, entitled "Reactor Support System - Evaluation of Margins",
was fully responsive to our February 1976 commitment.
By letter dated March 23, 1978, we indicated a willingness to consider further studies once FP8L received Staff concurrence as to the acceptability of the analytical methods used in our August 1977 report.
On January 16, 1980, the Staff and its consultant met with us to discuss the asymmetric load evaluation for St.
Lucie Unit 1.
At that time, we agreed to provide additional data on our efforts to assess the effects of asymmetric LOCA loads.
Although we believe that sufficient data exists to support the contention that these large reactor coolant system pipes cannot fail in the instantaneous manner postulated by the Staff, we have conducted additional analyses because we recognize the Staff's need to assess the potential impact that could be associated with these exceedingly low probability events.
An initial report submitted in March 1980 (letter L-80-77, dated March 7, 1980) discussed additional analyses conducted to assess the significance of structural
- gaps, the capability of other reactor coolant system component
- supports, and the effects of connected ECCS piping.
The revised report submitted herein addresses the capability of the control element assemblies, the reactor internals, and the fuel.
The conclusion reached is that, for the guillotine breaks
- analyzed, the existing design can acceptably accommodate these arbitrarily postulated events.
These analyses also reconfirm the conclusions reached in our August 1977 report.
The conclusions to be derived from our efforts to date are that the pj}o/
probability of the types of pipe failures required to be assumed for these 5
analyses is acceptably low, and that the St. Lucie Unit 1 design has a
significant inherent capability to accommodate these non-design basis events.
/
Sg P8129 PEOPLE... SERVING PEOPLE
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Office of Nuclear Reactor Regulation Page 2
Appendix A of this report, three copies of which are enclosed (numbered 000002 through 000004), is considered proprietary.
Enclosed is an affidavit from Combustion Engineering, Inc. requesting that the information contained in Appendix A be withheld from public disclosure in accordance with 10 CFR
- 2. 790.
A non-proprietary version of Appendix A is also included, as is a non-proprietary Appendix B.
Very truly yours, Robe E. Uhrig Vice President Advanced Systems 8 Technology HAS/pah Attachment cc:
J.
P.
0 Reilly, Region II (w/o attachment~)
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Harold Reis, Esquire (w/o attachment)
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AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
State of Connecticut County of Hartford I, A.
E. Scherer depose and say that I am the Director, 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 conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the Application of Florida Power and Light Company-Docket 50-335 for withholding this information.
The informatsan for which proprietary treatment is sought is contained in the following document:
Attachment to Combustion Engineering letter F-CE-7334 This document 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 commercial or financial information.
Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included, in the above referenced
- document,
4 l
should be withheld.
1.
The information sought to be withheld from public disclosure is a
report appendix detailing the numerical tests and analyses performed to identify the dynamic response of fuel assemblies to a LOCA event with vessel motion, 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 held 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 DP-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 Commission.
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
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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 Engineering.
b.
Development of this information by C-E required hundreds of man-hours of effort and tens 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 inconvenience related to conducting extensive testing, obtaining access to similar test facilities, and developing analytical methods.
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 supporting data for analysis and the numerical results of that analysis, 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,
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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.
Sch er
.Sworn to 'before me
.,'" this" g.I
~ day of
/P'Q'l tary Public USA G. WAICUNAS, NOTARY PUBUC State ot Connecticut No. 54492 Commission Expires March 31, 1983 Director, Nuclear Licensing
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