ML18038A626

Forwards Proprietary & Nonproprietary Structural Audit Open Issue Close Out Info.Affidavit Requesting Proprietary Status for Info Encl.Proprietary Info Withheld

ML18038A626
Person / Time
Site:	Nine Mile Point
Issue date:	02/10/1984
From:	Lempges T NIAGARA MOHAWK POWER CORP.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML17054A447	List: ML18038A626
References
(8037), NUDOCS 8402150345
Download: ML18038A626 (56)

Text

I REGULATORY x..

ORMATION DISTRIBUTION SYS 8 (RIDS)

ACCESSION NOR'8402150345 DOC ~ DATE: 84/02/10 NOTARIZED'ES DOCKET FACIL:50-410 Nine Mile Point Nuclear Stationi Unit 2i Niagara Moha 05000410 AUTH INANE AUTHOR AFFILIATION LEMPGESiT.E, Niagara Mohawk Power Corp.

RECIP ~ blAME RECIPIENT AFFILIATION SCHNKNCERgA ~

Licensing Branch

'2

SUBJECT:

For wards proprietary nonproprietary structural audit open issue close out info,Affidayit requesting proprietary status for info encl. Proprietary info withheld.

DISTRIBUTION CODE:

8001S COPIKS RECEIVED:LTR ENCL, 3 SIZE:

(

gP

. '2,'7++~~

TITLE: LicenSing Submittal:

PSAR/FSAR Anldts 8 Related Correspondence NOTES:PNL 1cy FSAR'S 8

AMDTS ONLY, 0500041.0 RECIPIENT

'COPIES ID CODE/NAME LTTR EbICL NRR/DL/ADL 1

0 NRR LB2 LA 1

0 RECIPIENT IO CODE/NAME NRR L82 BC HAUGHEYiM IE FII E P3 IE/DEPER/IRB ftfif.

NRR/DK/AEAB NRR/DF/EHEB 0

3 1

1 "2

1 1

1 1

1 1

1 1

NRR/DE/GB NRR/DE/MTEB NRR/DE/SGEB NRR/DHFS/LQB NRR/DL/SSPB NRR/DS I/ASB NRR/DSI/CSB NRR/DS I/METB NR G FILEI/MIB

>I Ql3lf t

6 BNL(AMOTS ONLY) f400 FEMA "REP DIV 39

@Pa NRC PDR 02 HAP NTIS INTERNAL: ELO/HDS3 1

IE/DEPER/EP8 Qi5(6)7 5 IE/DQASIP/GABE]g 1

NRR/DE/CKB Q'iq 1

NRR/DE/EQB

~yogi 2

NRR/DE/MKB Qx~

1 NRR/DE/SAB

@fZ+

1 NRR/DHFS/HFEB+@$

1 NRR/DHFS/PSRB~~

1 NRR/DS I/AKB

@Q4 1

NRR/DSI/CPB AZa 1

NRR/DSI/ICSB NRR/DS I/PSB ~X/

1 NRR/DSI/RSB

+35 1

RGN1 P3>sf' EXTERNAL: ACRS esw"1'>

DMB/DSS (AMDTS)

QPg LPOR 03 gpO NSIC 05 HPO COPIES LTTR ENCL 1

0 1

1 1

-1 1

1 1

0 1

1 2

2 1

1 1

1 1

.1 1

0 1

1 1

1 1,

1 1

1 1

1 1

0

@&0 NPa, NPo NOa' 1

N$'o ppo NOTES-'

1 TOTAL NUMBER OF COPIES REQUIRED:

LTTR 54 ENCL 47

ql 'f'(

~

IN fj I/.j f, l,',l) j,)I'>I, ~g),fr

,g q>>ef.~,rj,f'j f j f<<f<<jt zj, lf

7) r

f)'jg 'I ).

jf tlt l

)) J, fit ll>> II) II I)

I))

f! 't)I pl t>>

fffsl)f' "5

jr f

'j fj,

'>> 'jjA I I

)f)

'.<<f

<<>j ll j h

~

~ t g,

>>)

tl jli, g I

I',I),ttf I), 'I II',

t f I

g I)

'l')

y<,)t~ge frt)~ j,g jf l

I I

0f rr

)a, g)!)'

f')3>> If 9 It"Ij )l I '

~ f!f!, ft fI!jr,fg 1 lt

,11

",Ir I! I fly t I'jf I

I' ft)

I I t

I I'I P'j,f P QC jj t!j ff)'h t <<

>>W P.+;",l>>

e~>>>>>>>>tet>>>>>>>> +

I!

II p jrf g

fr

)gt'<<f lrh! tIhft I

"II jtf f )gh,'r.'ft>>,) fj

~

f f'I l

il I

~

'h r 'ht) )g

) t v

I

'h

~ ~ <<

I

. ~

)l

~'>>

gggt ggf I 4 49M 0't w$

,K 5-J H~

hj) l

)I C~"t r$

Cist g)I)~O) jf ht l" ll

NIAGARAMOHAWKPOWER CORPORATION/300 ERIE BOULEVARDWEST. SYRACUSE, N,Y, 13202/TELEPHONE (315) 474-1511 February 10, 1984 (8037)

A. Schwencer, Chief Licensing Branch No.

2 U. S. Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Mr. Schwencer:

RE:

Nine Mile Point Unit 2 Docket No. 50-410 Enclosed for your review are eight copies of information to close out certain open issues of the NRC Structural Audit.

During the Structural Audit of December 12 through 16, 1983 we committed to provide this information.

I '

Attachment A provides the non-proprietary information.

Attachment B

provides an affidavit requesting proprietary status for information in Attachment C which is considered proprietary by Stone and Webster Engineering Corporation.

) ~

Sincerely, Vice President of Nuclear Generation TEL/NLR'lf Attachment cc:

A. F. Zallnick, Jr.

C.

V. Mangan M. Haughey W. Morrison S.

Z. Doyle (File)

R. Pinney (CHOC) ego>pgyo

'9490500.

p98

<O~

qO<V',"

egg,. b>,~-.-'u>~

i 7

. @pe quoit pI~~

IroP Nfl<

LLL' 4

4

~ 4

~

ATTACHMENT A

j

~ i

NINE MILE POINT UNIT 2 NRC REQUEST NO.

1 Verify and confirm the design of all structures affected by SRV and hy-drodynamic loading.

RESPONSE

The design of structures within the reactor building will be verified for the SRV and hydrodynamic loading during the load verification stage.

Structures within the reactor building either are designed for conceptual (i.e., preliminary)

SRV and hydrodynamic loading or are provided with an adequate design

margin, which should account for future load verifica-tion.

Based on current schedule, the load verification for the reactor pedestal is planned to be completed by June 1984.

The load verification for other structures will be completed by September 1985.

The NRC will be notified of the results of this verification upon completion.

a402150345 C2/12177/7/2RH

0

NINE NILE POINT UNIT 2 NRC REQUEST NO.

2 Provide an assessment of the significant differences between the require-ments of ACI 349, as augmented by the NRC Regulatory Guide 1.142 and the requirements of ACI 318-77.

(Reference NRC Q Nos.

220.31 and 220.33).

RESPONSE

Results of an assessment of the significant differences between the codes used in NMP2 design versus those referenced in NRC Regulatory Guide 1.142, Revision 1, will be submitted by June 1984.

C2/12177/7/2RH

NINE 11ILE POINT UNIT 2 NRC REQUEST NO.

3 Review the effect of vertical floor flexibilityin the analysis of equip-ment and floor designs.

RESPONSE

An assessment of the effect of vertical floor flexibilityin the analysis of equipment and floor designs will be performed and submitted 'y June 1984.

C2/12177/7/2RH

NINE MILE POINT UNIT 2 NRC REQUEST NO.

4 Provide a

summary of cable tray support calculation methodology for the supports attached to floor and ceiling.

RESPONSE

ELECTRICAL TUNNEL CABLE TRAY SUPPORTS ATTACHING FIOOR TO CEILING

~Summar The most critical cable tray support type FP87 was reanalyzed to include differential movement of the top (roof) slab relative to the base.

The support at the top of the slab was modeled first as pinned, which was the condition used in the original design calculation.

all stresses were found to be acceptable.

The second case assumed the support to be fixed and stresses were still found to be acceptable.

A~nal sis Static Anal sis - Dead loads from the members and cable tray-loadings were included.

Differential slab movement of the top slab relative to the base was also statically analyzed by treating the OBE profile (maximum) displacements as support displacements.

This is a conservative

approach, since the profile displacements are the maximum values of the actual displacements.

2.

D namic Anal sis " A lump mass model was used to perform the dynamic analysis.

The response spectra of the roof slab were input into the analysis.

OBE being the most critical seismic case (after consid-ering load factors),

was used.

Member forces and moments were determined by using modal superposition and SRSS of the responses.

D~esi n

All members were checked and found to be within allowable stress limits for both cases (top support, fixed, and pinned).

Results of the computer run for static were added by absolute sum method to the SRSS of dynamic stresses.

C2/12177/7/2RH

0

NINE MILE POINT UNIT 2 ELECTRICAL TUNNEL TRAY SUPPORTS WITH DISPLACEMENT Summary of Results Verticals Axial Load Bending Moment*

Combined Stress Equation+

Original

~Desi n

0.7 K

10.1 IN-K 0.3 W/Differential Movement - Pinned 1.1 K

9.6 IN-K-0.35 W/Differential Movement - Fixed 1.1 K

21.9 IN-K 0.67

'>NOTE:

The original design has a

higher moment than the

pinned, differential movement design because of a conservative, sim-plifying used assumption used during the original analysis

~

Horizontals For all designs, the vertical member stresses govern the shape selection.

Therefore, for horizontal members using the same members as verticals is adequate.

Vertical Connection NOTE:

The design of vertical connection governs over Horizontal to connection.

Allowable Loads-Connection Ca acit Original

'~Desi n

W/Diffe rent ia 1 Movement - Pinned W/Differential Movement - Fixed Shear Axial 2.0 K 1.5 K

0.5 K

0.7 K

0.4 K

1.1 K

0.77 K

1.1 K

"Combined stress equation Fa

+

Fb

<1.0 Similar to AISC 1.6-la Fa allow Fb allow C2/12177/7/2RH

NINE MILE POINT VNIT 2 NRC REQlJEST NO.

6 Provide data on strength, material

type, and mechanical properties of Nelson studs, used in NMP2 polar crane rail support design.

RESPONSE

Nelson studs Type CPL, 7/8-inch diameter threaded studs are used in fastening polar crane rail supports.

This method of fastening offers easy installation, reduced maintenance, and added safety during instal,-

lation and operation.

The attachment provides the data on material composi,tion, type, strengthi etc, Crom the catalog, Nelson - Construction Applications in Power Generating Plants by (TRW - Nelson Division).

C2/12177/7/2RH

~

(

APPLICATION 10 STEEL MILLS

.Ntt00DIN KIB3 N800WOMR II2lMKI2l60Q iSTANDARD STUD DIMENSIONS CPL PITCH DIAMETER BASE STUDS f

i C

B J

rsvp Ttireed Std. INn.

Diameter t.

th 5/8

/8 E

Weld fillet Dilnetei

/4 F

Weld fNet t

4Available inreqmrcd tcngtlo above cpcoficdmimmvm, D

c-ELSON PITCH DIAMETER BASE AND FULL BASE HREADED STUDS FOR SECURINO OVERHEAD CRANE AILSUsed with a variety ol clips designed for par ticular situations.

NELSON pitch diameter and lull base threaded studs provide overhead crane rail fastening that offers speed of installation, added

safety, and reduced maintenance at lower cost.

Tbread Std. Btin.

iiaeeter L

Wold fittet Dianeter Weld fittct H

t HBL FULL BASE THREADED STUDS iSTANOARD STUD DIMENSIONS E

I f 5/B 34 5/8 3/4 3/8

/2 I I/2

~ /4 3

16

/4

~.eerr

<<'y lrc

~ tcI BENEFITS:

~ FASTER RAIL INSTALLATIONAll installation is topside no underneath staging or scaffolding unnecessary to back up nuts with wrench on under.

side.

~ QUALITYASSEMBLY AT LOWEST COST Weak.

nesses in craneway sections caused by drilled or punched holes is eliminated.

~ RfDUCED MAINTENANCELess corrosion because holes are eliminated.

~ SAFER Drop out of bolts, due to loosening in service or assembly, is eliminated.

Pri<<red ie U.S.A.

CPL CFP, CFL, FFL NBI.

84X RGP R7P L2L SSL CKL F3L H3P N3A N3P R9L SL SL SL P2P D2L S3L H4L ATC,ATS,ATA,FTC TPC CHP S7X VXCD RWP GENERAL INFORMATION 1

SPEC 1 THREADED PITCH DIAMETER BASE STUD.

~

"~

~

~

~

2.3 SPEC 2 FULLTHREADED STUDS.

4,6 SPEC 3 NO THREAD STUDS..

~ ~.....,

~ ~...,, ~,,

~

~

~

~

~

~

~

~

~

~

~

~

~

6 SPEC 4 - REFRACTORY "Y"ANCHOR BTUDS............,.........,......

~..

d SPEC 6-RECTANGULAR STUDS...............,. ~,.......

~..

8 SPEC 6 RECTANGULAR STUDS w/HOlE

~ ~...,....'. ~....

~.,.

~ ~,,.......

7 SPEC 7 - LAGGING STUDS w/HOLE

~.....,

~

~. ~.....

~..

7 SPEC 8 FEMALE SPRINKLER STUDS........ ~... ~.....,......

~. ~.........,,

8 SPEC 9-THREADED COLLAR STUDS 8

SPEC 10- NO THREAD COLLAR STUDS

~

~ ~.

~....

~ ~..

9 SPEC 11 NAMEPLATESTUDS......,.......

9 SPEC 12 ALUMINUMNAVYTYPE ANNULARRING STUDS

~.. ~.... ~,...

~

~.

~..

10 SPEC 13 NAVYTYPE ANNULARRING STUDS

~.

~...

~

10 SPEC 14 ROPE HOOK STUD

~

11 SPEC 16 20- STANDARD CABLE HANGER STUDS 12 SPEC 21 PLATE HANGERS 13 SPEC 22 TUBULARHANGERS 13 SPEC 23 DOUBLE POINTED INSULATIONPINS

~

14 SPE C 24 DEFORMED BAR ANCHOR 16 SPEC 26 SHEAR CONNECTORS

~

18 SPEC 26 CONCRETE ANCHORS 17 SPEC 27 THREADED STORED ARC STUDS 18 SPEC 28 STORED ARC PIN l9 SPEC 29-CUPPED HEAD INSULATIONPIN 20 SPEC 30 REFRACTORY "STEERHORN" ANCHOR 21 SPEC 31 ANCHOR ASSEMBLY 21 SPEC 32 WIGGLED RECTANGULAR TWO TINE STUD 22 SPEED CLIPS 23 STUD ACCESSORIES 24 INSULATIONFASTENERS QTY'S. PER CARTON.

~,

26 STANDARD FERRULES

.26, 27 WEIGHT CHART THREADED STUDS, NON THREADED..............

28 WEIGHT CHART SHEAR CONNECTORS, ANCHOR STUDS......,.....

29 STUD TENSILE TORQUE STRENGTHS M,31 STORED ARC STUD TENSIlE TORQUE STRENGTHS ~.................

32

]r,

~

~

~

\\

~

~

~

~

~

~

~

~

~

~

~

~.'I 'o

~

~

o

~

~

~

~

~

~

~

~

~

~

~

~

~

~ ~,

~

~

~

~

~

~

~ I ~

~

~

~

~

~

~

~

~

~

~

~

I

~

~

~

~

~

~

~

~

~ '

~

~

~

~ ~,

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

o o

o

~

~

~

~

~

~

~

~

~

~ ~;

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~ '

~

~ '

~

~

~

~ ',

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

o o

~.:

~

~ ~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

o

~

~

~

~

~,

~

~

~

~

~ ~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~ ~

~

'o

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

o

~

~

~

~

~

~

I

~

~

~

~ ~

o

~

~

~ ~ ~

~

~ I

~

~

II

~ I ~ ~

~

~

~

~ I

~

~

~ ~ ~

~

~

~ ~ ~

~

~

~

~ I

~

~

~

~ I I

~

I I I ~

~

I ~

~

~

~ ~

o ~ '

I I I I o

~

~

~ ~ I

~

NINE MILE POINT UNIT 2 NRC REQUEST NO.

7 Provide a

summary of how cable (rope) slack is considered in the con-tainment polar. crane design.

RESPONSE

Dynamic analysis of the polar crane considered trolley positions at mid-span (MID), at quarter-span, and at the end of span (END); with the load positioned at maximum lift (UP), i.e., highest elevaiton, at minimum lift (DOWN) and with no load.

the trolley at quarter span analysis was discontinued when it became apparent that stress levels would be lower than other load conditions.

The attached table summarizes the rope accelerations under OBE and SSE seismic loading for the preceding various conditions.

The maximum dynamic acceleration alone had a value 'of 1.01 g, which when considered against 1 g gravity loads results in a stable rope situation, with essentially no differential acceleration and no slack-rope condi-tion.

C2/12177/7/2RH

NINE MILE POINT UNIT 2

SUMMARY

OF POLAR CRANE ROPE LOADS OBE Load Position MID/UP MID/DOWN END/UP END/DOWN Dynamic Acceleration (Gs) 0.63 0.48 1.00 0,44

.Static and Dynamic 1.63 1.48 2.00 1.44 SSE Load Position MID/UP MID/DOWN END/UP END/DOWN Dynamic Acceleration Gs) 0.68 0'1 1.01 0.54 Static and Dynamic Acceleration Gs 1.68 1.61 2.01 1.54 C2/12177/7/2RH

NINE MILE POINT UNIT 2 NRC REQUEST NO.

9 Revise response to NRC Question 220.28 based on reviewing a

seismic Category I structure for an additional torsional rqoment resulting from additional eccentricity of 5 percent of the maximum building dimension.

RESPONSE

See revised response to NRC Question 220.28.

C2/12177/7/2%I 14

NINE MILE POINT UNIT 2 QUESTION F220.28 (SRP 3.7.2-II.ll)

To account for accidental

torsion, the SRP states that an additional eccentricity of +5 percent of the maximum building dimension at the level under consideration should be assumed in the seismic analysis of Category I structures.

For Nine Mile Point 2,

however, the accidental torsion effects for the additional

+5 percent were not considered in the analysis.

Provide an assessment of the adequacy of the analysis con-sidering the effects of accidental torsion.

RESPONSE

As explained in Section 3.7.2.11A, the seismic analyses of Category 1

structures consider the effects of actual eccentricities between the centers of rigidity and centers of mass of structural components (which cause the torsional loading).

Therefore,

'since the results of the analyses already account for the torsional effects, it is not necessary to consider an additional eccentricity of 5 percent of the maximum building dimension.

Additionally, the design of the control building, which is considered representative of Category I structures, was reviewed for an additional torsional moment resulting from additional eccentricity of 5 percent of the maximum building dimension.

It was shown that the additional shear stresses resulting from this analysis were not significant and were within the design capacities.

C2/12177/7/2RH 15

NINE MILE POINT UNIT 2 NRC REQUEST NO.

10 Provide additional justification for the validity of the use of the 1.3 static coefficient factor in equipment design (Reference NRC Ques-tion 220.9).

RESPONSE

Response to this request is already incorporated in FSAR Amendment 7, December 1983.

C2/12177/7/2M'

NINE MILE POINT UNIT 2 NRC REQUEST NO.

11 Provide a discussion on the primary containment hatch boundary conditions and the correlation of forces/displacements between the two models.

RESPONSE

Response to this request will be provided by March 1984.

C2/12177/7/2RH 17

NINE NILE POINT UNIT 2 NRC RE(UEST NO.

14 Verify all Category I foundations for stability considering upward seismic forces.

RESPONSE

Response to this request will be provided by March, 1984.

1 Ir fI t

t A

NINE MILE POINT UNIT 2 NRC REQUEST NO.

15 Verify that radwaste and screenwell buildings are analyzed and designed as independent structures.

RESPONSE

The screenwell building design is updated to reflect the results of the revised seismic analysis, which does not include the radwaste building.

The radwaste building is seismically analyzed as an independent struc-ture; therefore, both structures are analyzed and designed independently of each other.

C2/12177/7/2RH 23

NINE NILE POINT UNIT 2 NRC REQUEST NO.

16 For all Category I buildings, verify vermiculite concrete-bearing capacity against sliding resistance.

RESPONSE

Response to this request will be provided by March, 1984.

I C

ATTACHMENT B

I

Commonwealth of Massachusetts)

County of Suffolk

)

SS.

FEB v~ )~~~

~V<8cuso 9u8rfegs I,

Ben Charlson, being duly sworn according to law depose and say I am Vice President of Stone 6 Webster Engineering Corporation (SWEC) and that:

For the reasons listed below the material contained in Attach-ment C of the responses to the U.S. Nuclear Regulatory Commis-sion (NRC) request for information from their structural audit which is being filed with the U.S. Nuclear Regulatory Commis-sion by Niagara Mohawk Power Corporation (NMPC) in connection with its license application for Nine Mile Point Unit 2, Docket No. 50-410, contains information considered by SWEC to be con-fidential information containing trade secrets and should be withheld from public disclosure.

2.

In support of its averment that the above-mentioned information is confidential, SWEC provides the following reasons:

a

~

The information sought to be withheld consists of modeling techniques used in seismic analyses of the structures, techniques to analyze column loading of the spent fuel

pool, and design basis and details for the polar crane supports.

b.

I am a Vice President for SWEC and have the authority to review and protect the confidential commercial information sought to be withheld.

c ~

SWEC is in the business of designing and constructing nuclear power plants.

This business is competitive and firms that engage in it compete on the basis of the nature and quality of the products and services that they offer clients.

The above referenced material is one such pro-duct.

d.

The subject material was developed at considerable expense to SWEC and is of substantial value to SWEC in the conduct of its business.

A competitor would derive an unfair advantage in obtaining the proprietary information sought to be withheld.

Thus the unrestricted disclosure of this material could have an adverse commercial impact on SWEC.

The data is plant specific and the methodology is for Nine Mile Point Unit 2;

however, the data could be applied to other situations.

e.

It is, accordingly, the customary practice of SWEC to treat such material as confidential commercial informa-tion.

C3/12177/192/5Y

~

~, ~ F'

f.

To the best of my knowledge and belief, the identified materials are not, available from any public source and have not been made available to third parties, except in confidence.

Ben Charlson, being duly sworn, deposes and says that he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

Ben Charlson Vice President Stone 8 Webster Engineering Corporation Sworn and su/scribed before me this J

day of January 1984 Catherine Trabucco

).y pic (r.NOTARY PUBLIC For the Cofnmopvealth of MassaofIIII)t0 My Co~issi6n Expires ffov, 8, NN C3/12177/192/5Y

l 4

l c

wynd y~

k' P

l fl

'1

ATTACHMENT B

U

Commonwealth of Massachusetts)

SS.

County of Suffolk

)

~Ylacro Quarterly I,

Ben Charlson, being duly sworn according to law depose and say I am Vice President of Stone 6 Webster -Engineering Corporation (SWEC) and that:

For the reasons listed below the material contained in Attach-

,ment C o'f the responses to the U.S. Nuclear Regulatory Commis-sion (NRC) request for information from their structural audit which is being filed with the U.S. Nuclear Regulatory Commis-sion by Niagara Mohawk Power-Corporation (NMPC) in connection with its license application for Nine Mile Point Unit 2, Docket No. 50-410, contains information considered by SWEC to be con-fidential'nformation containing trade secrets and should be withheld from public disclosure.

In support of its averment that the above-mentioned information is confidential, SWEC provides the following reasons:

a

~

b.

.The information sought to be withheld consists of modeling techniques used in seismic analyses of the structures, techniques to analyze column loading of the spent fuel

pool, and design basis and details for the polar crane supports.

v

\\

I am a Vice President for SWEC and have the authority to review and protect the confidential commercial information sought to be withheld.

C.

SWEC is in the business of designing and constructing nuclear power plants.

This business is competitive and firms that engage in it, compete on the basis of the nature and quality of the products and services that they offer clients.

The above referenced material is one such pro-duct.

d.

The subject material was developed at considerable expense to SWEC and is of substantial value to SWEC in the conduct of its business.

A competitor would derive an unfair advantage in obtaining the proprietary information sought to be withheld.

Thus the unrestricted disclosure of this material could have an adverse commercial impact on SWEC.

The -data is plant specific and the methodology is for Nine Mile Point Unit 2; however, the data could be applied to other situations.

e.

It is, accordingly, the customary practice of SWEC to treat such material as confidential commercial informa-tion.

C3/12177/192/5Y

.~

To the best of my knowledge and belief, the identified materials are not available from any public source and have, not been made available to third parties, except in confidence.

Ben Charlson, being duly sworn, deposes

.and says that he has read the foregoing.affidavit and the matters-stated therein are true and correct to the best of his knowledge, information,.and belief.

Ben Charlson Vice President Stone 8 Webster Engineering Corporation Sworn and su/scribed before me this l

day of January 1984 Catherine Trabucco

,< j rr,hlOTARY PUBLIC

,Foi,the~6mrrionwealth of MasNchNON

,> "'y Comrtrission~Expires NoV. 8, NN

~

~ >

l~

C3/12177/192/5Y

'4 ~

0

ATTACHMENT C