ML20045G352
| ML20045G352 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 07/07/1993 |
| From: | Hebert J Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19303F703 | List: |
| References | |
| JRH-93-143, MN-93-66, NUDOCS 9307130229 | |
| Download: ML20045G352 (8) | |
Text
m MaineYankee 56Ah1[_1Ll(i[RiCJTY SRGE_195 r
ED! SON DRIVE
- AUGUSTA, MAINE 04330 + (207) 622-4868 July 7, 1993 l
MN-93-66 JRH-93-143 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention:
Document Control Desk t
Washington, DC 20555
References:
(a)
License No. DPR-36 (Docket No. 50-309).
(b) Attachment to Letter, USNRC to MYAPCo, Docket No. 50-309,
" Safety Evaluation by the-Office of the Nuclear Reactor Regulation Relating to Maine Yankee RPS Setpoint Methodology Using Statistical Combination of Uncertainties", September 20, 1990.
(c) YAEC-1642P, Volumes 1 and 2,
" Maine Yankee RPS Setpoint Methodology Using Statistical Combination of Uncertainties",
March 1988.
Subject:
Submittal of VAEC-1642P, Volume 3 Gentlemen:
Please find enclosed a copy of Volume 3 of our report, VAEC-1642P, entitled
" Maine Yankee RPS Setpoint Methodology using Statistical _ Combination of 4
Uncertainties". This report is being submitted to complete the. requirements of the Safety Evaluation applicable to the Maine Yankee Statistical Combination of t
Uncertainties (SCU) methodology submittal, Reference (b). Volumes 1 and'2 of the SCU report, Reference (c), describe the methodology used to statistically' combine appropriate uncertainties by using representative values of the uncertainties and their probability distribution function;. These volumes were transmitted to the NRC in April,1988, and were approved in Reference (b).
Since the methodology reports-contained representative values for the uncertainties, the Safety Evaluation in Reference (b) requested that the actual values, the justification for their use, and the actual Statistical DNBR Limits (SDLs) be provided to the staff for the first' operating cycle to which the methodology is to be applied.
This transmittal complies with the request of Reference (b). Volume 3 of the SCU report was developed to provide the SDLs, the bases for each of the uncertainties, and their probability distribution functions used in the Cycle 14 reload analysis. Maine Yankee Atomic Power Company plans to complete the Cycle 14 reload analysis under the provisions of 10 CFR 50.59.
Several of the uncertainties, particularly those related to fuel fabrication tolerances, are vendor specific.
Consequently, the SDLs and their associated uncertainties provided in Volume 3 are specific to the ABB-CE fuel. Prior to the use of fuel from a different fuel vendor, these uncertainties will be reviewed using uncertainty values specific to the fuel vendor, and the SDL will be updated as appropriate.
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[dhine iH}030 UNITED STATES NUCLEAR REGULATORY COMMISSION MN-93-66 Attention:
Document Control Desk Page 2 i
The enclosed volume report is considered proprietary by. >.nkee Atomic Electric Company and Combustion Engineering.
Maine Yankee Atomic Power Company hereby requests, pursuant to 10 CFR 2.790, that this information be withheld from public disclosure.
An affidavit attesting to the proprietary nature of the enclosure is attached.
Enclosed is an application fee of $150.00 pursuant to 10 CFR 170.
Very truly yours, GkW. V(
James R. Hebert, Manager Licensing & Engineering Support Department RPJ/ jag Enclosures c:
Mr. Thomas T. Martin (w/o YAEC-1642P enclosure)
Mr. Charles S. Marschall (w/o YAEC-1642P enclosure)
Mr. E. H. Trottier Mr. Patrick J. Dostie (w/o YAEC-1642P enclosure) l Li\\93ma\\9366
AFFIDAVIT PURSUANT TO 10 CFR 2.790 YANKEE ATOMIC ELECTRIC COMPANY
)
NUCLEAR SERVICES DIVISION
)
COMMONWEALTH OF MASSACHUSETTS
)
WORCESTER COUNTY
)
ss (1)
I, Stephen P. Schultz, depose and say that I am Vice President of Yankee Atomic Electric Company (" Yankee"), duly authorized to make this affidavit, and have reviewed or cause to have reviewed the information which is identified as proprietary.
I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations for withholding this information from public disclosure.
(2)
The information for which proprietary treatment is sought is contained in report YAEC-1642P - Volume 3. This report provides technical descriptions of analytical methods and data developed by Yankee. Volumes 1 and 2 of this report, dated March 1988, have previously been submitted and approved by the Commission.as Proprietary documents.
(3)
Pursuant to the provisions of Paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for the consideration of the Commission in determining whether the information in the above report should be withheld from the public disclosure:
The information sought to be withheld from public disclosure is owned and a.
has been held in confidence by Yankee.
b.
The information is of a type customarily held in confidence by Yankee and not customarily disclosed to the public.
Yankee has a rational basis for determining the type of information customarily held in confidence which includes a procedure which determines whether to hold information in confidence. Under that procedure, information that is determined to har
" actual or potential commercial value", i.e., is potentially marketable e' provides a potential competetive advantage, is held in confidence.
c.
This information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it be received in confidence by the Commission.
d.
The information, to the best of Yankee's knowledge and belief,is not available in public sources.
e.
The material contained in this report contains significant information and detail pertaining to the development of a methodology and/or data. This material, which is marketable in several ways, was obtained at considerable expense to Yankee and our sponsor companies. The public release of this information, making it readily available to our competitors, would diminish Yankee's ability to sell products and services involving the use of this information.
f.
The use of the information and data provided in this document by our
competitor would put Yankee at a competitive disadvantage by reducing his expenditure of resources at the expense of Yankee and our sponsor companies.
g.
The information provided in this report is intended to be combined with the methodologies described in Volumes 1 and 2 of YAEC-1642P which have previously been submitted and approved by the Commission as Proprietary documents. Each component of proprietary information is potentially as valuable to a competitor as the entire package in that the one component may be the key element needed to complete the development of a competitive product or service, thereby depriving Yankee of a competitive advantage.
(4)
This information is for Commission internal use only and should not be released to persons or organizations outside the Directorate of Regulation and the ACRS without prior approval of Yankee. Should it become necessary to release this information to such persons as part of the review process, please contact Yankee.
(5)
The proprietary information sought to be withheld is that which is appropriately marked in " Maine Yankee RPS Setpoint Methodology Using Statistical Combination of Uncertainties, Volume 3, Bases for the Uncertainties Included in the Statistical Combinations", YAEC-1642P (Proprietary), March,1993. The methodology and data is expected to be applicable for other licensee submittals seeking to perform analyses expand operating space via the methodology of statistically combining or uncertainties.
This information is part of that which would enable Yankee to:
(a)
Develop licensable methods for using statistically combined uncertainties for additional licensees.
(b)
Calculate uncertainties and probability distributions for parameters which can be statistically combined.
Public disclosure of this proprietary information is likely to cause substantial harm to the competetive position of Yankee because it would enhance the ability of competitors to develop similar methodologies without commensurate expenditures.
Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
Further the deponent sayeth not.
Ob 1
Stephen P. Schultz Vice President Sworn to before me this F day of June,1993
.I f
. Tyu t. ) s.,- J a li n Kathryn Cates, Notary Public My Commission Expires January 24,1997
4 i
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 i
paragraph immediately below.
I am submitting this affidavit in conjunction with the application of Yankee Atomic Electric Company.
and 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:
Pages 19, 20, 33, 34, 38, 41, 44, 45, 46, and 52 of YAEC-1642P,
" Maine Yankee RPS Setpoint Methodohgy Using Statistical Combination of Uncertainties, Volume 3, Bases for the Uncertainties Included in the Statistical Combinations," March 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
-g-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.
l i
l 1.
The information sought to be withheld from public disclosure, j
which is owned and has been held in confidence by Combustion
]
'l Engineering, is the methodology for statistical combination of uncertainties and bounding engineering factors.
2.
The information consists of test data or other similar data i
concerning a process, method or component, the application of which results in 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 document herein is 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 1
Engineering because:
a.
A similar product is manufactured and sold by major-pressurized water reactor competitors of Combustion Engineering.
j l
b.
Development of this information by C-E required thousands of manhours and hundreds of thousands of dollars.
To the i
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 developing a methodology for statistical combi.'ation of uncertainties and bounding engineering factors.
J
e s
-4 d.
The information required significant effort and expense to I
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 methodology for statistical e.
combination of uncertainties and bounding engineering factors, 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 must be included.
The ability of Combustion Engineering's competitors to utilize such information l
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 g.
marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated uith 7
. 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.
I S.
A.
Toelle Manager Nuclear Licensing Sworn to l}efore me this /7 46 day of MdA 1993 6
( 02LU t
J
'~liobary Publ.ic My commission expires: 3-3l-9h k