L-82-450, Forwards Proprietary Response to NRC Questions on Implementation of St Lucie Unit 2 Rod Bow & Grid Spacing Penalties to Resolve Action Items Identified in SER (NUREG-0843).Withheld (Ref 10CFR2.790)
| ML17213A587 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/25/1982 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17213A588 | List: |
| References | |
| RTR-NUREG-0843, RTR-NUREG-843 L-82-450, NUDOCS 8210280067 | |
| Download: ML17213A587 (11) | |
Text
REGULATORY FORMATION DISTRIBUTION S EM (RIDS)
" ACCESSION.NBRe8210280067 DOC,DATE: 82/10/25 NOTARIZED; YES FACILBO 389 St, Lucie Plant< Unit 2~ Florida Power 8 Light Co, AUTH ~ NAME
- AUTHOR AFFILIATION UHRIGtRoEe Florida Power 8 Light Co ~
REC IP ~ NAME RECIPIENT AFFILIATION EISENHUTiD.G.
, Division of Licensing
SUBJECT:
Forwards proprietary "Response to NRC Questions on Implementation of St Lucie Unit 2
Rod Bow L Grid Spacing Penalties" to resolve SER (NUREG-0843)
~ Rept withheld (ref 10CFR2.790)e DISTRIBUTION,CODE:
PB01S COPIES RECEIVED:LTR ENCL SIZEe I
TITLE: Proprietary Review Distribution
~ Pre OL NOTES:
DOCKET 05000369 REC IP IENT, COPIES ID CODE/NAME LTTR ENCL LIC BR 03 BC 1
0
- NERSESgV, gW 1
1 RECIPIENT ID CODE/NAME LIC BR P3 LA COPIES LTTR ENCL 1
0 INTERNALS ELD 1
EG FILE 1
fD M /MIB EXTERNAL: ACRS
~<S~'~0 q 4-l3 NRC PDR 1
0 1
0 10 0
NRR DIR RGN2
+3 LPDR NTIS 1
0 1
1 1
0 1
0 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 21 ENCL 13
<<I r.,I <<",I, hh h
)
h
~r~r)
~
I
'1 Jl i),]') h),) 0 (h 1t o
< IXI 1 f)l ) f h
g),l 0 ih,ii <'.'h i hl~ i
'~of h
~ (> )
J hfh'i f
.)') i I,.
"if)fr!
I ~)
)s~>
rni> i hi>h>) t Or')IhII h
~ gc ~
I / AI )g
'l
'l>4
'd4".'I I
'i p~>~~"h r>rqh) I 1
.hI hJ!,) I~)
i>ih;) t I
)<~
<<~t>>lh <+r<<ir h
.hl<,~i 1).) ~
<<'..Jl JAR jiTg)A
.. > ~
< i ~) I >1 fi)
'j '"
<~
I J. ) I "I
. -1,
> q I >>>>ll'gl Io I I r '," 1 r.,) ( a
- h>~ r f '."h~hA t'ai
> r l'h 8
4,.)l
~I3rhgfr'~',14, "hP, 0 (" t 4
g'li>>f'hr')'lN) l 1 ~h'I~
4 lh>'I 1,)
hemic<
Jc'r 0>>
h 4 lv ref)r 4~~ ~hl'l >>l "0 h)~~h I f ski)
'3 h
'4Q lgtc~gg og
~i prp If t o'>)
/hi&
] )>>
hl I
T i:
h ]yl h )J
< il fl'j<)p e'phr<< I,'.<(fir )
'~ I hr/(<J>IT~?Ql r 9 Lh h r a N.. r.<< '~ r v;h v'i~ j ~ r h <<~'~'>
'r~.< I f ) J
)J~ >>>Tl 1
T.',>> ]L"<<-) Jhh "I
) 1.)
,l').
I
<1) le 1
I "hl<
JI
)
d5
'>5 ihl 'i
,'y I 't - I '0
'il'l
~i I )
h)
I g
$ (
R)
V
- )>> 3 'at
~ l <<'ll g I
'< (IhI)$ '-]
h'>>~,')~4
')i<A'P1.I TX h
l
)).
) r II e
$ '"y hi, ~g t,ii h
1)
I I'
II g
)pglihf
. BOX 14000, JUNO BEACH, FL 33408 COPY III)
FLORIDAPOWER & LIGHTCOMPANY October 25, I 982 L-82-450 Office of Nuclear Reactor Regulation Attention:
Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington; D. C. 20555
Dear Mr. Eisenhut:
Re: St. Lucie Unit 2 Docket No. 50-389 Implementation of Rod Bow and Grid S acin Penalties In response to the action items identified in Sections 4.4.2.I and 4.4.3.l of the St.
Lucie Unit 2
Safety Evaluation Report (NUREG 0843),
enclosed is Combustion Engineering's proprietary report, "Response'to NRC Questions on Implementation of St. Lucie 2 Rod Bow and Grid Sp'acing Penalties", CEN-22I (L) - P, Combustion Engineering, lnc., October l982.
This report should be provided to D. Powers and L. Phillips.
The enclosure to this. letter is proprietary, and therefore, it is requested that the enclosure be withheld from public disclosure in accordance with IO CFR 2.790.
If you should have any questions concerning the proprietary nature of 'the enclosed material, please address the questions directly to, Mr. A. E. Scherer, Director of Licensing (9438-I922), Combustion Engineering, I000 Prospect Hill
Very truly yours, Robert E.
rig Vice President Advanced Systems & Technology REU/RJS/cab
Enclosures:
Copies 0000I to 00005 - CEN-22I(L)-P 8Z10280067 8Z1025 PDR ADOCK 05000389 E
PDR PEOPLE... SERVING PEOPLE
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 propri etary and referenced in the paragraph immedi ately below.
I am submitting this affidavit in conformance with the provi sions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Florida Power and Light Company, for withholding this information.
The information for which proprietary treatment is. sought is contained in gl the following document:
"Response to NRC guestions on Implementation of St. Lucie 2
Rod Bow and Grid Spacing Penalties",
CEN-221(L)-P, October 1982.
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, should be withhel d.
1.
The information sought to be withheld from public disclosure is the sensitivity of the design thermal margin model, TORC, to input parameters, which is owned and has been held in confidence by Combustion Engineering.
ll
~
~
P t
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'or 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.'he 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 document 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 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 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.
~j'I
~
)jl I
g ~
~ ~
c.
In order to acquire such information, a competitor would also require considerable time and inconvenience to determine the sensitivity of. the design thermal margin model, TORC, to input paramters.
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 the sensiti vity of the design thermal margin model, TORC, to input parameters, the application of which provides a
competiti ve 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 servi ces; 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.
er r Director Nuclear Licensing Sworn to before me this /5 day of Qty~<~ y/Ip gh Notary Pu EY 1 ~EqZEL, yOTARY PU State oi Connecticut No. 59962 Commission Expires March 31, 1985
5 n"
STATE OF FLORIDA
)
)
ss.
COUNTY OF DADE
)
J.
A. DeMastry
, being first duly sworn, deposes and says:
That he is Mana er, Nuclear Licensin of Florida Power 8 Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are "true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.
All of the enclosed material is proprietary, and therefore, exempt from public disclosure in accordance with Section 2.790 of the NRC "Rules of Practice", Title 10, Code of Federal Regulations.
J.
A. DeMastry Subscribed and sworn to before me this
, '~"-5~'l.day of
, 195~
'v"
- ,NOTARY...PUB
- in and,for the County
,'f< DadeS ate of Florida.
fg Rotary Public, State of Fiortda at Large My 'CO'mmi SSiOn eXpireS My CommMon Expire~ Octob r Bg, tgB3 d
Bonding Agency
rr
'I