ML19323J233

Forwards Nonproprietary Info Re LOCA Portion of Application for Amend to Ol.Affidavit Encl.Proprietary Version Withheld (Ref 10CFR2.790)

ML19323J233
Person / Time
Site:	Calvert Cliffs
Issue date:	06/17/1980
From:	Olson R BALTIMORE GAS & ELECTRIC CO.
To:	Clark R Office of Nuclear Reactor Regulation
References
NUDOCS 8006190530
Download: ML19323J233 (9)

Text

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CALTIMORE GAS AND ELECTRIC CHARLES CENTER . P.O. BOX 1475 BALTIMORE, MARYLAND 21203 June 17, 1980 ELECTRIC ENGINEERING DEPARTMENT Office of Nuclear Reactor Feculation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Mr. Robert A. Clark, Chief Operating Reactors Branch tr'3 Division of Licensing Subject : Calvert Cliffs Uuclear Ibver Plant Units Ibs.1 & 2, Docket Ibs. 50-317 & 50-313 Partial-Icop Ooeration

References:

a) BG&S letter dated 4/5/79 from.A. E. Inndvall, Jr.

to H. R. Denton, Application for Icendment, b) HRC letter dated 3/31/80 from R. 'J. Reid to A. E. Lundvall, Jr., Fequest for Suppler. ental Information.

Gentlemen:

Reference (b) requested supplerental information concerning the LOCA portion of our application for an amendment to the Calvert Cliffs operating licenses to allow operation with less than four reactor coolant pumps operation, Feference (a).

Enclosure (1) to this letter provides the requested information, which is priprietary. Enclosure (2) is an Affidavit from Combustion Engineering, Inc requestin6 that the information contained in Enclosure (1) be withheld from public disclosure in accordance with 10 CFR 2.790.

Enclosure (3) is the non-proprietary version of Enclosure (1).

Very truly yours, i l 96 6 R. C. L. Olson Principal Engineer

Enclosures:

Copies 1 thru 40 40 copies 20 copies cc: encl 2,3)

J.

G. A.

F. Biddison, Troubridge,Esquire Esquire (w/(w/ enel 2,3)

Mr. E. II. Conner, Jr. (w/ enc 12,3)

Mr, 9. W. Kruse - CE (w/o encl) 8006190 f

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f J' > . Combustion Engineering, Inc.

i Response to NRC Request for Calvert Cliffs Part Loop Data Docket No: 50-317 & 50-318 f CEN-132(B)-NP t

June 5, 1980 i- -

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, , - e LEGAL NOTICE 3

. THIS REPORT WAS PREPARED AS AN ACCOUNT OF WORK SPONSORED

. BY COMBUSTION ENGINEERING, INC. NEITHER COMBUSTION ENGINEERING NOR ANY PERSON ACTING ON ITS BEHALF: .

A. MAKES ANY WARRANTY OR REPRESENTATION. EXPRESS OR IMPLIED INCLUDING THE WARRANTIES OF FITNESS FOR A PARTICULAR

. PURPOSE OR MERCHANTABILITY, WITH RESPECT TO THE ACCURACY, COMPLETENESS, OR USEFULNESS OF THE INFORMATION CONTAINED IN THIS REPORT, OR THAT THE USE OF ANY INFORMATION/ APPARATUS, METHOD,

. OR PROCESS DISCLOSEO IN THIS REPORT.MAY NOT INFRINGE PRIVATELY OWNED RIGHTS;OR .

B. ASSUMES ANY LIABILITIES WITH RESPECT.TO THE USE OF,OR FOR DAMAGES RESULTING FROM THE USE OF, ANY INFORMATION, APPARATUS, , ,

METHOD OR PROCESS O!SCLOSEO IN THIS REPORT.

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Response to NRC Data Request

. The requested infonnation is listed in Reference 1. The information is requested for both high and low density fuels. The present cores for both Calvert Cliffs Units I and II contain only high density fuel, therefore,

the response listed below will only address high density fuel.

Question #1

" Provide the initial clad inside (gap region) and outside oxide thickness in mils."

Response

This information is part of the C-E approved ECCS Model and is described in CENPD-132. Specifically, the initial inside oxidation thickness is[ ]

and the initial outside thickness is[ ]

Question #2 "There has been a recent review of the vendor clad swelling and rupture models used in LOCA analysis (NUREG-0630). Provide the ruptured node strain and assumed flow blockage for the present calculations. Also include references for these models."

Response

The description of the model is part of the C-E approved ECCS Model and is provided in Section III.B.1 of CENPD-132. The rupture strain was 29.75%.

The associated flow area blockage was 35.3%.

Question'#3

" Justify the duration of the refill portion of the transient where thennal radiation heat transfer is the only heat transfer mechanism."

Response

The use of rod-to-rod thermal radiation in the refill period is part of the

', C-E approved ECCS Model and is discussed in Section III.D.7 of CENPD-132. The length of the refill period was discussed in Reference 2. The duration of

, this refill period is determined by the discharge of the-safety injection o

i tanks. It was assumed that the rate at which the tanks discharge for part loop operation would be the same as that for full power operation. In fact, while the difference in tank discharge rate is expected to be negligible, there would be a tendency for the two loop tank discharge rate to be greater than that for full power due to the lower back pressure as a result of the lower power during two loop operation. Thus, the use of the refill time from the four loop analysis for use in the two loop ECCS analyses is considered conservative.

References

1. Letter 'from R. W. Reid (NRC) to A. E. Lundvall, Jr. (BG&E) . dated 3/31/80.

2. C-E's Response to NRC Data Request Letter from R. W. Reid (NRC) to

- , A. E. Lundvall, Jr. (BG&E) dated 2/7/80.

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AFFIDAVIT PURSUANT T0 10 CFR 2.790 Combustion Engineering, Inc. )

State of Connecticut )

County of Hartford ) SS.:

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 Baltimore Gas & Electric Company, for withholding this information.

The information for which proprietary treatment is sought is contained in the fol. lowing document:

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CEN-132(B)-P, Rssponse to NRC Request for Calvert Cliffs Part Loop Data.

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, g.,- - ,_ - - -

should be withheld.

1. The information sought to be withheld from public disclosura is a part of the C-E ECCS performance evaluation model which is owned and has been held in confidence by Combustion Engineering.

2. The information consists of test data or other similar data concerning a pro. cess, method or component, the application of which results in a 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 applie,d in determining that the subject documents 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 of the information in confidence.

6. 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 _ reactors competitors of Combustion Engineering.

b. Development of this information by C-E required hundreds of man-hours of effort and tens 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 to assess fuel design data and perform sensitivity studies in order to verify the approp'riate model to be employed in ECCS performance analysis. -

d. The information required significant effort and expense to .

obt'a in 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

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applicable.

e. The information consists of initial zirconium-oxide thicknesses

.on the inner and outer surfaces of tne f.uel cladding assumed in ECCS perfor-mance analyses, 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,

f. In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses mus't be included.

_4-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.

g. Use of the information by competitors in the international marketplace would increase their ability to mar ket nuclear steam supply systems by reducisig 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.

Vt. edlerer_

Director Nuclear Licensing Swurn to before me

'this d day of /9 78

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_.1 No ary ublic USA G. WAICUNAS N0TARY PUBUC State of Connecticut No. 54492 Commission Empires March 31, 1983 4

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