ML17306B371

Forwards Proprietary Sys 80-TM Inlet Flow Distribution, Suppl 1-P to Encl 1-P to LD-82-054, Statistical Combination of Uncertainties:Combination of Sys Parameter Uncertainties in Thermal Margin Analyses for Sys 80. Encl Suppl Withheld

ML17306B371
Person / Time
Site:	Palo Verde
Issue date:	03/30/1993
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17306B372	List: ML17306B371
References
102-02465-WFC-T, 102-2465-WFC-T, NUDOCS 9304060083
Download: ML17306B371 (19)

Text

r t CCELERAT DOCUMENT DIST TION SYSTEM--

REGULA INFORMATION DISTRIBUTIO STEM (RIDS)

ACCESSION NBR:9304060083 DOC.DATE: 93/03/30 NOTARIZED: YES DOCKET N FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi .05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529-STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION CONWAYsW.F.

<<RECIP<<NAME

SUBJECT:

Arizona Public Service Co. (formerly Arizona Nuclear Power RECIPIENT AFFILIATION Document Control Branch ttDocument Control Desk)

Forwards proprietary "Sys 80-TM Inlet Flow Distribution," ~j Suppl 1-P to Encl 1-P to LD-82-054, "Statistical Combination of Uncertainties:Combination of Sys Parameter Uncertainties

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R in Thermal Margin Analyses for Sys 80." Encl suppl withheld. +li~fZ S DISTRIBUTION CODE: APOID COPIES RECEIVED:LTR ( ENCL SIZE: i /

TITLE: Proprietary Review Distribution Pre Operating icense  !'perating R NOTES:STANDARDIZED PLANT 05000S28A Standardized plant. 05000529 Standardized plant. 05000530D RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PDS PD 1 1 TRAMMELLsC 3 3 TRAN,L 3 3 INTERNAL: ACRS 6 6 AE~OD J)OA 1 1 OGC/HDS1 1 . 0 EG FI 01 1 1 EXTERNAL: NRC PDR 1 0 D

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NOTE TO ALL"RIDS" RECIPIENTS:

I'LEASE HELP US TO REDUCE WASTE! CONTACT TIIE DOCUMENT CON'I'ROL DESK, ROOM Pl-37 (EXT. 504-206S) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 16

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Arizona Public Service Company P.O. BOX 53999 i PHOENIX. ARIZONA85072<999 102-02465/WFC/TRB/GAM WILLIAMF. CONWAY March 30, 1993 EXECUTIVEVICE PRESIDENT NUCLEAA U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3 Docket Nos. STN 50-528/529/530 Supplement 1-P to Enclosure 1-P to'LD-82-054 File: 93-026-419.16 Enclosure 1 to this letter is a proprietary copy of Supplement 1-P to Enclosure 1-P to LD-82-054, "System 80' Inlet Flow Distribution," February 1993. Enclosure 1-P to LD-82-054, "Statistical Combination of Uncertainties - Combination of System Parameter Uncertaintie's in Thermal Margin Analyses for System 80," May 14, 1982, is used to calculate the Departure from Nucleate Boiling Ratio (DNBR) limit for the PVNGS units.

The NRC review of Enclosure 1-P to LD-82-054 is contained in NUREG 0852, Supplement 2, Section 4.4.6, dated September 1983 (CESSAR System 80 SSER 2).

Supplement 1-P to Enclosure 1-P to LD-82-054 describes a revised core inlet flow distribution for use with ABB-Combustion Engineering (ABB-CE) Statistical Combination of Uncertainty (SCU) methodology for assessing core thermal margin, as applied to ABB-CE System 80' units. The revised System 80' SCU methodology will treat core inlet flow distribution and its associated uncertainties in a statistical manner, similar to that for a pre-System 80'plant, as opposed to the deterministic method currently used. The revised methodology will remove excessive conservatism in the current deterministic approach and will result in additional calculated core thermal margin.

APS intends to use th'e revised methodology beginning with PVNGS Unit 1 Cycle 5. The fuel assemblies to be installed for Unit 1 Cycle 5 will be constructed by ABB-CE with GUARDIAN'debris resistant grids. The use of the GUARDIAN'grids may limit the power rating of Unit 1 if. core thermal margin is assessed using the current methodology instead of the enclosed revised methodology. Therefore, it is requested that the NRC approve the enclosed supplement by September 30, 1993.

9304060083,930330 r PDR i

ADOCK 05000528 PDR

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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Supplement 1-P to -P to LD-82-054 Page 2 In accordance with 10 CFR 2.790, ABB-CE, the owner of this report, requests that this proprietary report be withheld in whole from public disclosure on the grounds that information in the',report is considered to be confidential commercial information. is the affidavit required by 10 CFR 2.790 (b)(1) to support this request for confidentiality.

If you have any questions or require additional information, please call Thomas R. Bradish at (602) 393-5421.

Sincerely, WFC/TRB/6AM/rv Enclosure cc: J. B. Martin J. A. Sloan

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ENCLOSURE 2 AFFIDAVITPURSUANT TO 10 CFR 2.790

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AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc. )

State of Connecticut )

County of Hartford ) SS.:

I, S. A. Toelle, depose and say that I am the Manager, 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 conjunction with Arizona Public Service Company in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations for withholding this information.

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

Supplement 1-P to Enclosure 1-P to LD-82-054, "System 80~ Inlet Flow Distribution," February 1993.

This document has been appropriately designated as proprietary.

I have personal knowledge of th'e 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

I 1 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, which is owned and has been held in confidence by Combustion Engineering, concerns experimental data and application of a statistical combination of uncertainties methodology for assessing core inlet flow distribution.

2. 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 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 is proprietary.

4 ~ The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the

. ~ I l 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 which provide for maintenance of the information in confidence.

Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:

a0 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 tens of thousands of manhours and millions of dollars. To the best of my knowledge and belief, a competitor would have to I

undergo similar expense in generating equivalent information.

c ~ In order to acquire such information; a competitor would also require considerable time and inconvenience to g

revising and applying a statistical 'combination of uncertainties methodology for assessing .core inlet flow t(

distribution.

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

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a competitor's cost in applying the information and marketing the product to which the information is applicable.

The information consists of experimental data and a statistical combination of uncertainties methodology for assessing core inlet flow distribution, the application of which provides a competitive economic advantage. iThe 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.

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 without'similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.

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.

s. 4.

S. A. Toelle Manager Nuclear Licensing Sworn to before me this ~/W day of 1993 o -ary-Publ My.--o~zsshcn expires:

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ENCLOSURE 1 SUPPLEMENT 1-P TO E N C LOS UR E 1-P TO LD-82-054

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