ML17310A822
| ML17310A822 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/17/1993 |
| From: | Stevens R ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17310A823 | List: |
| References | |
| 102-02732-RJS-R, 102-2732-RJS-R, NUDOCS 9312020530 | |
| Download: ML17310A822 (17) | |
Text
FORD 1 RES TORY INFORNATION DISTRIBU N SYSTEN (RIDS)
NOTES: STANDARDIZED PLANT Standardi zed plant Standardi zed plant ACCESSION NBR 'F312020530 DOC. DATE
'P3/1 1/17 NOTARIZED:
NO DOCKET I, FACIL:STN-50-528 Palo Verde Nuclear Stationi Unit ii Arizona Pub li'5000528 STN-50-529 Palo Verde Nuclear Stationi Unit 2i Arizona Publi 05000529 STN-50-530 Palo Verde. NucleaT Stationi Unit 3i Arizona Publi 05000530 AUTH. NANE AUTHOR AFFILIATION STEVENSi R. J.
Arizona Public Service Co.
(formerly Arizona Nuclear Poeer RECIP. NANE RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
R
SUBJECT:
Foreards Rev 1-P to CEN-424(V)-Pi "Presentation to NRC on I
Impact of Improved Inlet Floe Distribution on CPCS. " Encl eithheid (ref 10CFR2. 7'PO).
D DISTR'IBUTION CODE:,APOiD
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INTERNAL ACRS OQC/HDS1 EXTERNAL:
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1 YOTE TO ALL 'RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE NOVAS E! CONTACT THE DOCUMENT CONTROL DESK.
ROOi! P I-37 (EXT. 504-2065) TO ELIMINATEYOUR iNAM'E FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DOY'T NEED!
TOTAL NUI1BER OF COPIES REQUIRED:
LTTR 18 ENCL lb
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Arizona Public Service Company PALO VERDE NUCLEAR GENERATING STATION P.O. BOX 52034
~
PHOENIX. ARIZONA85072-2034 102-02732-R JS/RAB/GAM November 17, 1993 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units1,2, and 3 Docket Nos. STN 50-528/529/530 Improved Inlet Flow Distribution Methodology File: 93-026-41 9.16 Representatives of the Arizona Public Service Company (APS) and ABB-Combustion Engineering met with NRC Staff in Rockville, Maryland, on October 6, 1993, to describe how uncertainties in inlet flowdistribution are accommodated at PVNGS Units 1, 2, and 3.
This meeting was held to support the NRC review of the Supplement 1-P to Enclosure 1-P to LD-82-054, "System 80'Inlet Flow Distribution," February 1993, which was submitted for NRC review and approval by APS on March 30, 1993. During the meeting, APS agreed to submit copies of the presentation slides, and to provide additional information to support the review of the System 80'Inlet Flow Distribution Supplement.
That material is being provided in Enclosure 1, "Presentation to NRC on Impact of Improved Inlet Flow Distribution on the CPCS,"
CEN-424(V)-P, Revision 1-P.
The presentation slides are included on pages 2 through 39 of Enclosure 1, with a typographical correction on page 35.
The requested additional information, an explanation of benchmarking of the thermal margin model and the treatment of inlet flow distribution uncertainties, begins on page 40 of Enclosure 1.
The information in Enclosure 1 is considered to be proprietary by ABB-CE, the owner of the information. In accordance with 10 CFR 2.790, ABB-CE requests that this proprietary information be withheld in whole from public disclosure on the grounds that information is considered to be confidential commercial information. is the affidavit required by 10 CFR 2.790 (b)(1) to support this request for confidentiality.
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Nuclear Regulatory Commission ATTN: Document Control Desk Improved Inlet Flow Distribution Methodology Page 2 Should you have any questions or require additional information, please call Richard A. Bernier at (602) 393-5882.
Sincerely, Ronald J. Stevens, Director Regulatory and Industry Affairs RJS/RAB/GAM/ki Enclosures cc:
B. H. Faulkenberry (w/o enclosures)
J. A. Sloan (w/o enclosures)
B. E. Holian (w/ enclosures)
I J
ENCLOSURE 2 AFFIDAVITPURSUANT TO 10 CFR 2.790
0
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 the application of 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:
CEN-424(V)-P Revision 1-P, "Presentation to NRC on Impact of Improved Inlet Flow Distribution on the CPCS," October 1993.
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'ollowing is furnished for
0 1
2 consideration by the Commission in determining whether the ll information sought to be withheld from public disclosure, included in the above referenced
- document, should be withheld.
2.
3.
4 ~
The information sought to be withheld from public disclosure, which is owned and has been held in confidence by Combustion Engineering, is the application of the System 80 inlet flow distribution methodology, core protection calculator design, and modified statistical combination of uncertainties 'methodology.
The information consists of test data or other'imilar data concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.
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 'n 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
0 1
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:
a ~
b.
c ~
d.
A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
Development of this information by C-E required tens of 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.
Xn order to acquire such information, a competitor would also require considerable time and inconvenience to develop the System 80 inlet flow distribution methodology, core protection calculator
- design, and modified statistical combination of uncertainties methodology.
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.
The information consists of the application of the inlet flow distribution in a modified statistical combination of uncertainties methodology for plants with digital reactor protection
- systems, 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.
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. A. Toelle Manager Nuclear Licensing Sw'orn to before me
=this".~~ day of 1993 Nota" y Public My commission expires:
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ENCLOSURE 1 PRESENTATION TO NRC ON IMPACT OF IMPROVED INLET FLOW DISTRIBUTION ON THE CPCS CEN-424(V)-P REVISION 1-P