ML17298A576
| ML17298A576 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/26/1983 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17298A577 | List: |
| References | |
| RTR-NUREG-0857, RTR-NUREG-857 ANPP-27883-WFQ, NUDOCS 8310030425 | |
| Download: ML17298A576 (15) | |
Text
REGULATORY
]FORMATION DISTRIBUTION S EM (RIDS)
ACCESSION NBR:8310030425 DOC ~ DATE: 83/09/26 NOTARIZED; YES DOCKET FACIL:STN-50-528 Palo Verde Nuclear StationP Unit 1E'rizona Publi 05000528 STN 50 529 Palo Verde Nuclear StationP Unit 2g Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear StationP Unit 3P Arizona Publi 05000530 AUTH BYNAME AUTHOR AFFILIATION VAN BRUNTpE,E, Arizona Public Service Co ~
ECIP ~ NAME RECIPIENt AFFII IATIO KNIGHTONp G a Licensing Branch 3
S UBJECT:
Forwards proprietary "Final Assessment of Palo Verde Nuclear Generation Station Fuel Assembly Spacer Grid Impact Loads Under Faulted Conditionsi" per SER (NUREG 0857) Section 4,2 ',Affidavit encl'ept withheld (ref 10CFR2 790).
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Arizona Public Service Company P.o. SOX 2I666
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PHOENIX. ARIZONA 65036 September 26, 1983 ANPP-27883 - WFQ/TFQ Director of Nuclear Reactor Regulation Attention:
Mr. George Knighton, Chief Licensing Branch No.
3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3
Docket Nos.
STN-50-528/529/530 File:
83-056-026; G.1.01.10
Reference:
NUREG-0857, "Safety Evaluation Repor t related to the operation of Palo Verde Nuclear Generating Station, Units 1, 2 and 3", dated
- November, 1981.
Dear Mr. Knighton:
Transmitted herewith are copies of Combustion Engineering's (CE's) report on the System 80'fuel performance analysis under combined seismic and LOCA loads for PVNGS.
The report is provided in response to the open item described in Section 4.2.1 of the referenced SER.
The information presented in the enclosed report-. has been discussed informally with the staff and we understand that the submittal of this report should close out the issue.
Due to the proprietary nature of the material contained in the enclosure, we request that it be withheld from public disclosure in accordance with the provisions of 10CFR 2.790 and that this material be safeguarded.
The reasons for the proprietary classification of this report are delineated in the enclosed affidavit.
Please contact me if you have any questions on this matter.
Very truly y urs, EEVB/TFQ/sp Enclosures 83iQ030425 83092
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PDR ADOCK 05000528 Ii)'.'DR Qg~
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PAL l6 LPGA P g 5'Pl, p)5(C NT(5 E. E.
Van Brunt, Jr.
APS Vice President Nuclear Projects Management ANPP Project Director
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Mr. G.
W. Knighton Page 2
September 26, 1983 ANPP-27883 WFQ/TFQ cc:
E. A. Licitra A.
C. Gehr Office of Nuclear Reactor Regulation September, 1983
Enclosures:
Proprietary Affidavit CEN-256(V)-P, "Final Assessment of PVNGS Fuel Assembly Spacer Grid Impact Loads Under Faulted Conditions",
- August, 1983.
Proprietary copies 0001 through 0025.
CEN-256(V)-NP, "Final Assessment of PVNGS Fuel Assembly Spacer Grid Impact Loads Under Faulted Conditions:,
- August, 1983.
Non-proprietary version, 15 copies.
September 26, 1983 ANPP-27883 HFQ/TFQ STATE OF ARIZONA
)
) ss.
COUNTY OF MARICOPA)
I, Edwin E.
Van Brunt, Jr.,
represent that I am Vice President, Nuclear Projects of Arizona Public Service
- Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its
- contents, and that to the best of my knowledge and belief, the statements made therein are true.
Edwin E.
Van Brunt, Jr.
Sworn to before me this~,~
day of 1983.
My Commission Expires:
My Gommfss1on Expires April 6, $987 Notary 'P.,ubl-ic
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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 Arizona
'Public Ser vice for withholding this information.
The information for which proprietary treatment is sought is contained in the fol lowing document:
CEN-256(V)-P, "Final Assessment of PVNGS Fuel Assembly Spacer Grid. Impact Loads Under Faulted Conditions", August, 1983 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 withheld.
~
~
1.
The information sought to be withheld from public disclosure is the structural performance information (test and analytical results) of the System 80 fuel assemblies under seismic and LOCA conditions, which is owned and has been held in confidence by Combustion Engineering.
2.
The information consists of test data or other similar data concerning J
a process, method or component, the application of which results in a
substantial competiti ve 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 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 o'f the information in confidence.
G.
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 reactor competitors of Combustion Engineering.
b.
Development of this information by C-E required thousands of manhours of effort 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 inconvenience related to the development of a fuel design for reactors manufactured by Combustion Engineering, Inc.
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 test results and analytical data of the fuel performance characteristics for Palo Verde Nuclear Generating Stations I, 2, and 3, 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 avoi d 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 information
A C
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.
A. E.
cherer Director Nuclear Licensing Sworn to before me this'ay of IQ8'>
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THFCESif M. RE(qAN,:."NOTHER'( PU8LIC
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- PF '(:D!4,.CTi(lU7 No.
66097','Q<
ill'SSIOl'(.Ej"filA;".5HAACH 3l. 1998
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