ML19343C451

Forwards Jp Novarro Affidavit Supporting 810312 Request for Withholding from Public Disclosure Suppl to Plant Design Assessment for Safety Relief Valve & LOCA Loads, Shoreham Nuclear Power Station Unit 1, Dtd Feb 1981

ML19343C451
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/12/1981
From:	Novarro J LONG ISLAND LIGHTING CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
SNRC-541, NUDOCS 8103240235
Download: ML19343C451 (6)

Text

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gg LONG ISLAND LIGHTING COM PANY

• • • • "W SHOREHAM NUCLEAR POWER STATION P.O. BOX 604, NORTH COUNTRY ROAD e WADING RIVER,'N.Y.11792 March 12, 1981 SNRC- 541 Mr , Harold R, Denton, Director Office of Nuclear Reactor Regulation U, S. Nuclear Regulatory Commission Washington 7 D, C, 20555 Shoreham Nuclear Power Station - Unit.1 Docket No. 50/322

Dear Mr,

Denton:

On March 12, 1981 via letter SNRC-539, LILCO forwarded to your office fifteen (15) copies of a report entitled Plant Design Assessment for SRV and LOCA Loads, Shoreham Nuclear Power Station - Unit 1, Revision 4 ddted February, 1981 (DAR) .

Enclosed with our letter SNRC-540 dated March 12, 1981 were fifteen (15) copies of a Proprietary Supplement to the DAR, In that letter we (.1) requested the Staff with-hold the Proprietary Supplement from public disclosure because it contained confidential commercial information and trade secrets and (2) stated that an affidavit in support of that request would be forwarded under separate cover, The enclosed Affidavit.of Joseph P, Novarro, prepared in accordance with 10CFR f) 2. 790 (b) , fulfills that commitment.

Very truly yours, e

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLAND LIGIITING COMPANY ).

) Docket No. 50-322 (Shoreham Nuclear Power Station, 1 Unit 1) ).

AFFIDAVIT OF JOSEPH P. NOVARRO Joseph P. Novarro, being duly sworn, states as follows:

1. I am Project Manager of the Shoreham Nuclear Power Station, Unit 1, of Long Island Lighting Company (LILCO).

2. I have been delegated the function of reviewing the Plant Design Assessment for SRV and LOCA Loads, Proprietary Supplement, Shoreham Nuclear Power Station, Unit 1, Revision 4, February, 1981 (Proprietary Supplement) , and requesting that the NRC Staff withhold the Supplement from public disclosure because it contains trade secrets and confidential commercial information.

3. 2 e Proprietary Supplement contains trade secrets and confidential ~ commercial information for the following reasons:

a. Kraftwerk Union Aktiengesellschaft (KWU) has developed a technology providing improved steam _ quenching capabilities in' pressure suppression containment systems.

KWU's developmental research program required the expenditure

of large amounts of time and money, In order to recoup this investment, KWU has offered to sell the quer : hor information derived from its research program to utility companies provided that they maintain that information secret and confidential.

Thus, when LILCO purchased the quencher information from KWU for use in the Shoreham design, one condition of the purchase agreement was-that LILCO would maintain the secrecy and confidentiality of the quencher information. The agreement does permit LILCO to disclose the information, on a need-to-know basis, to its employees, its consultants, and the NRC 3

in connection with the construction and licensing of Shoreham,

b. KWU also sold the quencher information to Pennsylvania Power & Light Company (PP&L), PP&L has sponsored a full-scale test program to verify the analyses used to design the quencher. This test program required the expenditure of large amounts of time and money, In order to recoup this t

investment, PP&L has offered to sell information derived from its test program to utility companies provided that they maintain that information secret and confidential, Thus, when LILCO i

purchased the test information from PP&L for use in the Shoreham

' design,'one condition of the purchase agreement was that LILCO would. maintain the secrecy and confidentiality of the information acquired from PP&L. The agreement permits LILCO to disclose the information; on a need-to-know basis, to its employees, its consultants, 'and. the NRC -in connection with the construction and-licensing offShoreham.

c. The quencher information developed by KWU and PP&L is not publicly available and it is of a type usually held secret and confidential. KWU, PP&L and LILCO have maintained that information secret and confidential. When any of them have conveyed that information to a private party, the recipient has agreed to keep it secret and confidential. When PP&L submitted their quencher information to the NRC for the Susquehanna Steam Electric Station, it was accompanied by a request that the NRC withhold the information from public disclosure..

d. The information contained in the Proprietary Supplement.is based on the quencher information that LILCO obtained;from KWU and PP&L. Therefore, as indicated in paragraphs 3.a-b above, LILCO is obligated to maintain the information in the Proprietary Supplement secret and confidential.

It has fulfilled-this obligation and continues to do so with this request that the NRC withhold the Proprietary Supplement from public disclosure,

e. LILCO's estimated cost, to obtain the information from'KWU and PP&L is $1,200,000 LILCO has engaged Stone & Webster Engineering Corporation to-perform the analysis reflected in the Proprietary. Supplement at an estimated cost of approximately

$150,000. -It would cost someone else at least the same amounts to acquire and/or develop.tho same information. The information in the Propriet'rya Supplement is not publicly available and it'is of a type usually held secretiand confidential.

f. The proprietary supplement also includes data obtained from " Memorandum Report, Ramshead Suppression Pool Temperature Limit" submitted to NRC by General Electric Company letter MFN343-77 dated September 6, 1977. This data is pro-prie ary to General Electric Company as described in the affidavit submitted with the referenced letter. The data included in the memorandum report is not publicly available and is of a type usually held secret and confidential. It has been made available to LILCO by virtue of LILCO's participa-tion in the Mark II Owners Group which has thus far cost LILCO approximately $1,800,000. LILCO has maintained this information secret and confidential and is obliged to do so by agreement between the Mark II Owners Group and General Electric Company.

The agreement does permit LILCO to disclose the information, on a need-to-know basis, to its employees, its consultants and the NRC in connection with the construction and licensing of Shoreham.

g. The proprietary supplement also includes data obtained from a safety relief valve discharge test program performed by NUTECH, Inc., under the joint sponsorship of Commonwealth Edison, Cincinnati Gas and Electric Company and Long Island Lighting Company.

The data referenced in the proprietary supplement is not publicly available and is of a type usually held secret and confidential.

LILCO's share of the program cost amounted to approximately $52,400.

LILCO has maintained this information secret and confidential and is obliged to do so by agreement among the joint sponsors. The

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agreement does permit LILCO to disclose the information, on a need-to-know basis, to its employees, its consultants and the NRC'in connection with the construction and licensing of

- Shoreham.

4. For the above reasons, the Proprietary Supplement contains trade' secrets and confidential commercial information and, therefore, should be withheld from'public disclosure.

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- Subscribed'end sworn to before me this 21 day of: March, 1981.

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