ML20054L326

Amend 35 to Application for Ol,Consisting of Revision 7 to Fsar,Revision 2 to Emergency Plan & Proprietary Version of Vol 3 of Design Assessment Rept

ML20054L326
Person / Time
Site:	Limerick
Issue date:	06/25/1982
From:	Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML19268B109	List: ML20054L320 ML20054L326
References
NUDOCS 8207070401
Download: ML20054L326 (7)

Text

.-

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of  : Docket Nos. 50-352 PHILADELPHIA ELECTRIC COMPANY : 50-353 AMENDMENT NO. 35 TO LICENSE APPLICATION OF PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATION STATION UNITS NO. 1 & 2 Edward G. Bauer, Jr.

Eugene J. Bradley 2301 Market Street Philadelphia, PA 19101 Attorneys for Philadelphia Electric Company 8207070401 820630 PDR ADOCK 05000352 K PDR

BEFORE Tile -

UNITED STATES NUCLEAR REGULATORY COMMISSION I

In the Matter of  : Docket Nos. 50-352 PHIIADELPHIA ELECTRIC COMPANY : 50-353 AMENDMENT NO. 35 TO LICENSE APPLICATION OF PHILADELPHIA ELECTRIC COMPANY ,

Philadelphia Electric Company hereby amends its Applica-tion in the above entitled proceedings (a) by making the deletions, substitutions and additions to the Final Safety Analysis Report shown on the dtcument entitled " Limerick Generating Station, Units 1 & 2 Final Safety Analysis Report, Revision 7 Page Changes", dated June, 1982, which is filed herewith and made a part hereof; (b) by making the deletions, substitutions and additions to the Emergency Plan shown on the document entitled " Limerick Generating Station Units 1 &

2, Revision 2 Emergency Plan Page Changes" dated June, 1982, i .

which is filed herewith and made a part hereof; and (c) by adding thereto Volume 3 of a document entitled " DESIGN ASSESSMENT

REPORT, LIMERICK GENERATING STATION UNITS 1 & 2", which is filed herewith and made a part hereof. "

Volume 3 of the Design Assessment Report contains detailed information on the analysis of suppression pool and hydrodynamic loads which is considered by Pennsylvania Power & Light Company to be confidential and proprietary information containing trade secrets. Accordingly, it is hereby requested that Volume 3 of the Design Assessment Report be withheld-from public disclosure in accordance with Section 2.790 of the Commission's regulations. An affidavit of Norman W. Curtis, Vice President of Pennsylvania Power &

Light Company, in support of this request is attached heretc as Exhibit A.

Respectfully submitted, PHIIADELPHIA ELECTRIC COMPANY

,/ .

By: /- < 'V Senior Vice President

COMMONWEALTH OF PENNSYLVANIA  :

ss.

COUNTY OF PHILADELPHIA  :

V. S. BOYER, being first duly sworn, deposes and says:

That he is Senior Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Amendment and knows the contents thereof; and that the state-ments and matters set forth therein are true and correct to the best of his knowledge, information and belief.

Senior Vice 7 resident Subscribed and sworn to before me this c2 day of <6 , 1982.

$NsL k CW Notary Pdblic PATRICR D. SCHOLL ristary Pu%c, F'ntg tp:a P+ 'Nd;5ia Co.

My Commission Everes Feruary 10.1956 1

COMMONWEALTH OF PENNSYLVANIA)

SS COUNTY OF LEllIGli )

I, NORMAN W. CURTIS, being duly sworn according to law depose and say that I am Vice President, Engineering &

Construction - Nuclear of Pennsylvania Power & Light Company (PP&L), and that:

1. For the reasons listed below, Volume 3 of the Design Assessment Report (DAR) for Limerick. Generating Station Units 1 and 2 (Volume 3 of the Limerick DAR), which is being filed with the U.S. Nuclear Regulatory Commission (NRC) by Philadelphia Electric Company (PECO) in connection with its

License Application at Docket Nos. 50-352 and 50-353, contains information considered by PP&L to be confidential information containing trade secrets and should be withheld from public disclosure.

2. In support of its averment that the above-mentioned information is confidential, PP&L provides the following reasons:

a. KraftwerkUnionAktiengesc1kschaft(KWU) developed a quencher technology as a means of pressure suppression in a wetwell containment system. This technology was developed by KWU during a research program which cost consider-able amounts of time and money. The informa-tion developed during this research program

. is not available to the public. PP&L entered into a contract with KWU for, inter alia, the purchase of an information package that was developed by KWU during its research program.

PP&L sent copies of the information package to the NRC. This information was accompanied by an affidavit signed by KWU requesting the NRC to withhold it from public disclosure.

b. Part of the contractual arrangement between KWU and PP&L involved KWU performing a full scale test simulating the parameters that exist at PP&L's Susquehanna Steam Electric Station (Susquehanna). The purpose of this test was to verify the design analyses used Exhibit A

. ^t to engineer the quencher device.- PP&L submitted to the NRC its Susquehanna DAR (See Docket Nos. 50-387 and 50-388) w'n ich explain -

ed the response of the containment system to safety relief valve (SRV) discharge and loss of coolant accident (LOCA) loads, and con-tained certain information considered by PP&L as proprietary. These proprietary portions of the Susquehanna DAR concerned the full scale test portion of the PP&L and KWU efforts and the design teepnique for assess-ing the containment system margins. The document is of considerable importance because it enables one to define loads associated with SRV discharge. The document, therefore, is a valuable tool in applying the KWU information.

c. Although the Susquehanna DAR and the KWU information was prepared specifically for application to Susquehanna, it is of value to anyone desiring to apply it to any plant employing a similar pressure suppression system. Because of the value of this in-formation and its market potential, PP&L

, considers it to be the type that is custom-arily held in confidence. As a result, PP&L requested and the NRC agreed to Vithhold this information from public disclosure pursuant to 10 CFR $2.790.

d. Volume 3 of the Limerick DAR is based on the Susquehanna DAR and the KWU information. It was developed as a result of significant effort and expense by PP&L. PP&L has spent considerable time and money in obtaining a contract with KWU, and developing the test plan and test matrix. PP&L thus far has paid KWU approximately $4.5 million in connection with the KWU contract.

e. Pursuant to an agreement dated August 10, 1978, PP&L sold to PECO the right to use the KWU information described herein for PECO's Limerick Generating Statio'n Units 1 and 2.

Pursuant to the agreement, PECO is required to maintain the proprietary and confidential nature of the information contained in Volume 3 of the Limerick DAR.

3-

f. The information contained in Volume 3 of the Limerick DAP. has been and Kill continue to be held in strict confidence. External distribu-tion of this information is restricted. Each of the recipients of this information has promised to honor the proprietary value of the information and is precluded from using this information for any purpose other than certain specific enumerated applications.

These recipients limit the access of the information to those persons in their employ who have a need to use the information in the performance of their duties.

g. None of the information provided therein will be found in any public sources.

h. Because of the expense it has incurred in the development of this information, the marketability of this information, which will enable it to recoup a portion of these additional expenses, and the economic harm that PP&L would suffer from its inability to sell the information, the need for protecting PP&L's interest outweighs the interest involved in public disclosure.

A e  %

Norman W. Curtis Vice President, I Engineering & Construction - Nuclear Pennsylvania Power a Light Company Sworn and 'subscribg'd

! before pc this 05 I day of(RULL , 1982 OW% 11h MARTHA C. BARTO, Notary Pubiic Allentown, Lehigh County, Pa.

l My Commisdon Expires Jan.13,198G l

-c (?

I

, - - -