ML20042C481

Forwards Proprietary & Nonproprietary Response to Supplementary Question on Effect of Spacer Grid Design on DNBR Prediction. Proprietary Version Available in Central Files Only

ML20042C481
Person / Time
Site:	Waterford
Issue date:	03/25/1982
From:	Maurin L LOUISIANA POWER & LIGHT CO.
To:	Tedesco R Office of Nuclear Reactor Regulation
Shared Package
ML19268D102	List: ML20042C481 ML20042C488
References
W3P82-0683, W3P82-683, NUDOCS 8203310438
Download: ML20042C481 (6)

Text

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• NEW ORLEANS. LOutSIANA 70174 . (504) 366 2345 bi i s SYS E L.V. MAURIN Vice President Nuclear Operations March 25, 1982 W3P82-0683 3-A1.01.04 Mr. R. L. Tedesco g Assistant Director of Licensing Of 3

U. S. Nuclear Regulatory Commission Washington, DC 20555 g p

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SUBJECT:

Louisiana Power & Light Company { gf l 1332 s i Waterford Steam Electric Station - Unit No. 3 n. 4 ic '

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/0 Effect of Spacer Grid Design on DNB Predicti n-

\ s 8' ENCLOSURE: (1) Report, " Response to Supplementary Question C7 p on Effect of Spacer Grid Design on DNBR Prediction"

Dear Mr. Tedesco:

Mr. Holonich, of your organization, requested further information demonstrating that the final grid spacer design on Waterford 3 has a negligible effect on minimum DNBR as calculated by the FSAR Thermal Margin model. By copy of this letter, the Proprietary Report with Affidavit, prepared in response to this request is being sent along with a non-proprietary version, both of which are labeled as to the nature of their contents.

The analysis reported in the enclosure demonstrates that the new spacer grid design with revised loss coefficients has a negligible effect on minimum DNBR.

Please be advised that the data listed in enclosure (1) contains information which is proprietary to C-E. Pursuant to Section 2.790 10 CFR Part 2, you are requested to withhold this information from public disclosure. Also, in accordance with 10 CFR Section 2.790 (b), we recognize that withholding this information from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the information.

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0203310438 820325 PDR ADOCK 05000382 A PDR

W3P82-0683 ,

Mr. R. L. Tedesco

< Page 2-If you should have any questions concerning the proprietary nature of the material transmitted herewith, please address-these questions directly to:

Mr. A. E. Scherer Director of Licensing (9438-1922)

Combustion Engineering, Inc.

1000 Prospect Hill Road Windsor, CT 06095 We also request that you provide a copy of any questions concerning the proprietary nature of this submittal to Louisiana Power & Light Company.

Yours very truly, L. V. Maurin LVM/RMF/lgh Enclosure cc: S.-Black 4~\

AFFIDAVIT PURSUANT TO 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 1

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 Louisiana Power and Light Company, for withholding this information.

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

Attachment No.1 to Combustion Engineering Letter C-CE-7539.

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, should be withheld.

-1. The information sought to be withheld from public disclosure is thermal-hydraulic analisis methods and performance data 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 process, 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 applied 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, !s not available in public sources, and any disclosure to third parties has t en made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

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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 i

water reactors competitors of Combustion Engineering.

b. Development of this information by C-E required thousands of manhours of effort 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. ,

c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of thermal-nydraulic analysis methods and performance data.

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 a competitor's cost in applying 4

the information and marketing the product to which the information is applicable.

e. The information consists of thermal-hydraulic methods and performance data 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 ac', ions 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 must be included..

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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 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.

--m A. E. d rer Director Nuclear Licensing Sworn to before me this<dT../ day of Ec 5 vo cy , / 7/d as 'Ai l l' ] . 's . : . ,$

Notary Publ.fc // d ca; a j. v;zwl: .a n 1G00 s g.c at c u e:oca aa.59032 Commsion baires Much 31,1933 l

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