ML17284A872

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Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld
ML17284A872
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 08/30/1999
From: Coleman D
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17284A873 List:
References
GO2-99-164, NUDOCS 9909090200
Download: ML17284A872 (10)


Text

REGULA RY INFORMATXON DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9909090200 DOC.DATE: 99/08/30 NOTARIZED: YES DOCKET

'~ACIL:50-397, WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUd~i.,NAW~, AUTHOR AFFILIATION COLEMAN,D.W. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Forwards proprietary info to support review of request for amend to license NPF-2l,re min critical power ratio safety C,

. limits TSs,as requested during 990816 conversation.

Proprietary encl withheld. A DISTRIBUTION CODE: APOID COPIES RECEIVED:LTR 1 ENCL I SIZE: 42 4. T TITLE: Proprietary Review Distribution - Pre Operating License &. Operating R E

NOTES:

G, RECIPIENT COPIES RECIPIENT COPXES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD4-2 LA 1 1 CUS 1 1 XNTERNAL: ACRS 1 1 FILE CENTER 01 1 1 OGC/RP 1 0 0XTERNAL:

NRC PDR D

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E NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.'TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, DISTRIBUTION LISTS CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF. COPIES REQUIRED: LTTR 6 ENCL

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ENÃR@I NORTH WEST 4

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PO. Box 968 a Richland, Washington 99352-0968 August 30, 1999 G02-99-164 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

WNP-2, OPERATING LICENSE NPF-21 REQUEST FOR AMENDMENT MINIMUMCRITICALPOWER RATIO SAFETY LIMITS (ADDITIONALINFORMATIONCHANNEL SOW)

Reference:

Letter GO2-99-149, dated August 2, 1999, DW Coleman (Energy Northwest) to NRC, "Request for Amendment, Minimum Critical Power Ratio Safety Limits (Supplemental Information)"

In an August 16, 1999 conversation between NRC, Energy Northwest and ABB Combustion Engineering personnel, the staff requested additional information to support its review of our pending request for an amendment to the Minimum Critical Power Ratio Safety Limit Technical Specifications.

The information requested is included in the attached letter from ABB Combustion Engineering, Inc. Some of the material in the attachment has been identified as proprietary and is marked accordingly (i.e., bracketed). Pursuant to the requirements of 10 CFR 2.790, an affidavit is enclosed to support the withholding of this information from public disclosure.

Should you have any questions or desire additional information regarding this matter, please call me or PJ Inserra at (509) 377-4147.

Respectfully, AR DW Coleman Manager, Regulatory Affairs 'L '

Mail Drop PE20 ~go Attachment ()GOU13 nfc~

pDg, l l ~b cc: EW Merschoff - NRC RIV DL Williams - BPA/1399 JS Cushing - NRR TC Poindexter - Winston Bc Strawn NRC Sr. Resident Inspector - 927N 9909090200 990830 PDR ADQCK 0500039'7 p PDR

STATE OF WASHINGTON )

Subject:

Letter ABBWP-99483, dated August 26, igh ~

) 1999, "WNP-2, Operating License NPF-21, Request for Amendment, Mnimum Critical COUNTY OF BENTON )

Poimr Ratio Safety Limits (Additional Information- Cannel Boy)"

I, D.W. Coleman, being duly sworn, subscribe to and say that I am the Manager, Regulatory Affairs, for ENERGY NORTHWEST, the applicant herein; that I have the full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information, and belief the statements made in it are true.

The attachment to this letter contains information [marked in brackets] which is considered by ABB Combustion Engineering, to be proprietary. Attached is an affidavit executed by I.C. Rickard, Director, Nuclear Licensing, of ABB Combustion Engineering Nuclear Power, Inc., dated August, 26, 1999, which provides the basis on which it is claimed that the subject document should be withheld from public disclosure under the provisions of 10 CFR 2.790.

Energy Northwest treats the subject document as proprietary information on the basis of statements by the owner. In submitting this information to the NRC, Energy Northwest requests that the subject document be withheld from public disclosure in accordance with 10 CFR 2.790.

DATE 90, 1999 D.W. Coleman Manager, Regulatory Affairs On this date personally appeared before me D.W. Coleman, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned.

GIVEN under my hand and seal this ~day of 1999.

Notary Public in and for the STATE OF WASHINGTON Residing a My Commission Expires

August 26, 1999 ABBWP-99-083 Mr. R. A. Vopalensky Energy Northwest Plant Engineering Center (PEC)

North Power Plant Loop Richland, WA 99352-0968 Mail Drop: PE10

Subject:

WNP-2, Operating License NPF-21, Request for Amendment, Minimum Critical Power Ratio Safety Limits (Additional Information Channel Bow)

Reference:

Letter GO2-99-149, dated August 2, 1999, D%'oleman (Energy Northwest) to NRC, Request for Amendment, Minimum Critical Power Ratio Safety Limits (Supplemental Information)

Dear Mr. Vopalensky:

The attachment to this letter provides the information requested in an August 16, 1999 follow-up telephone conversation with the NRC staff pertaining to the discussion of channel bow that was presented in the referenced letter.

Portions of the response contain ABB Combustion Engineering Nuclear Power, Inc., proprietary information. This, proprietary information is identified in brackets in the attachment. Please include these designations in your response to the NRC. An affidavit supporting the withholding of this information from public disclosure in accordance with 10 CFR 2.790(b) is also enclosed.

Should you require additional information or further clarification, please do not hesitate to contact me at (860) 687-8092 or Bill Harris at (860) 687-8014.

Best Regards, gtr~d~

Nirmal Jain Project Manager cc: D. Richey W. Wolkenltauer M. Reis One Attachment As stated One Enclosure As stated ABB CENO Fuel Operations 8&Combustion Engineerin~uclearPower, In .

combustion Engineering, Inc. Post ptt6attitttdtrtrt Tetephone (860) 687.8001 2000 Day"Hill Roa'9 Fax (860) 687-8002 Windsor, Connecticut 06095-0500

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AFFIDAVITPURSUANT TO 10 CFR 2.790 I, lan C. Rickard, depose and say that I am the Director, Nuclear Licensing, of ABB Combustion Engineering Nuclear Power, Inc. (ABB CENP), 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 Energy Northwest for withholding this information.

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

ABBWP-99-083, "WNP-2, Operating License NPF-21, Request for Amendment, Minimum Critical Power Ration Safety Limits Additional Information Channel Bow", August 1999 This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by of ABB CENP 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 withheld.

The information sought to be withheld from public disclosure, is owned and has been held in confidence by ABB CENP. It consists of information regarding Safety Limits and mechanical characteristics of ABB CENP fuel.

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

The information is of a type customarily held in confidence by ABB CENP and not customarily disclosed to the public. ABB CENP 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 document herein is proprietary.

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.

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 that provide for maintenance of the information in confidence.

Public disclosure of the information is likely to cause substantial harm to the competitive position of ABB CENP because:

a. A similar product is manufactured and sold by major pressurized and/or boiling water reactor competitors of ABB CENP.
b. Development of this information by ABB CENP required tens of thousands of dollars and hundreds of man-hours of effort. 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 to develop information regarding Safety Limits and mechanical characteristics of ABB CENP fuel.
d. The information consists of Safety Limits and mechanical characteristics of ABB CENP fuel, 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 ABB CENP, take marketing or other actions to improve their product's position or impair the position of ABB CENP's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
e. In pricing ABB CENP's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included. The ability of ABB CENP's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
f. Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems, nuclear fuel, analyses or other support services by reducing the costs associated with their technology development. In addition, disclosure would have an adverse economic impact on ABB CENP's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

ia C.

Director, Nuclear Licensing Sworn to before me this Q~ day of , 1999

't ipPublic My commission expires: P 9/

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