ML20059F087
| ML20059F087 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 10/29/1993 |
| From: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17059A090 | List: |
| References | |
| NMP2L-1449, NUDOCS 9311040125 | |
| Download: ML20059F087 (5) | |
Text
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M Y NIAGARA R UMOHAWK NIAGARA MOHAWK POWER CORPORATION /NINE MILE POINT, P.O. BOX 63, LGMING, NY 13093/ TELEPHONE (315) 349-2882 B. Ralph Sylvia Ex cutive Vice President i
Nuclear October 29,1993 NMP2L 1449 U. S. Nuclear Regulatory Commission 10 C.F.R. 62.790 Attn: Document Control Desk Washington, D.C. 20555 Re:
Nine Mile Point Unit 2 Docket No. 50-410 NPF-69 i
Gentlemen:
SUBJECT:
REQUEST FOR WITIIIIOLDING INFORMATION FROM-PUBLIC DISCLOSURE In conjunction with the submittal of Revision 5 to the Nine Mile Point Unit 2 Updated Safety Analysis Report (USAR), enclosed are one (1) signed original and ten (10) copies of Nine -
Mile Point Unit 2 USAR Proprietary Appendix 6D.
The information presented in Unit 2 USAR Appendix 6D (Safety Relief Valve Loads) was previously contained in Section 6A.3 of the Nine Mile Point Unit 2 Design Assessment Report for Hydrodynamic Loads (DAR). The proprietary material has not changed. The i
material was previously intermixed with nonproprietary material presented in USAR Appendix 6A, DAR. The proprietary material has been segregated from the nonproprietary material and relocated to USAR Appendix 6D. By letters to the Nuclear Regulatory Commission (NRC) dated January 26,1983, December 13, 1983, September 16,1985, and September.30,1985, Niagara Mohawk requested that this information be withheld from j
public disclosure pursuant to 10 C.F.R. 62.790. The NRC approved these requests by letters i
dated September 21,1983, March 20,1984, and November 6,1985.
Data Appendix 6D to the I? nit 2 USAR describes in detail the methodology used for the design O
evaluation of the main steam line safety relief valve (SRV) discharge system. Each Nine g
- $y Mile Point Unit 2 SRV discharge line is connected to a T-quencher device developed on a O
similar quencher installation at the Pennsylvania Power & Light (PP&L) Susquehanna Steam po Electric Station. The application of the Kraftwerk Union Aktkngesellschaft (KWU) quencher technology to Susquehanna was originally established during a test program ugg conducted for PP&L in the Susquehanna DAR. Pennsylvania Power & Light requested, and (5
the NRC agreed, to withhold this information from public disclosure pursuant to 0
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10 C.F.R. 62.790. Pursuant to an agreement dated August 10,1978, PP&L sold to Niagara i
Mohawk the right to implement the KWU quencher technology at Nine Mile Point Unit 2.
Subsequently, Niagara Mohawk contracted with KWU directly to perform an engineering study to document the applicability of KWU's T-quencher design for Nine Mile Point Unit 2, based on the design developed for Susquehanna. The underlying basis for this Nine Mile Point Unit 2 study was the original work performed by KWU for PP&L.
Accordingly, pursuant to the provisions of Section 2.790(b)(1) of the Commission's Regulations, it is hereby requested that the information contained in Unit 2 USAR Appendix 6D continue to be treated by the Commission as confidential and proprietary and be withheld from public disclosure. In support of this request, enclosed herewith is a copy of the original affidavit of Mr. Norman W. Curtis of Pennsylvania Power & Light containing a full statement of the reasons for this request for withholding from public disclosure.
Because of the time that has passed since the original submittal of this proprietary information, Niagara Mohawk has requested that PP&L review the proprietary information and their original affidavit for continued applicability. Pennsylvania Power & Light has not yet completed their review. Upon notification by PP&L, NMPC will apprise the Commission of any change in the status of this proprietary information, and if appropriate, will submit an updated affidavit. However, until such time as we are otherwise advised by PP&L, Niagara Mohawk remains contractually obligated to assert the proprietary nature of this information.
Very truly yours, fb0 b
B. Ral i Syl ia Exec. Vice President-Nuclear JJUmis 00446000 pc:
Mr. T. T. Martin, Regional Administrator, Region I -
Mr. R. A. Capra, Director, Project Directorate I-1, NRR Mr. J. E. Menning, Project Manager NRR Mr. B. S. Norris, Senior Resident Inspector Records Management l
l
O COMMONWEALTH OF PENNSYLVANIA): SS COUNTY OF LEHIGH
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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, portions of Appendix GA of the Niagara Mohawk Power Corporation Nine Mile Point Unit Two Final Safety Analysis Report (Appendix 6A of the Nine Mile Point Unit Two FSAR), which is being filed with the U.S. Nuclear Regulatory Commission (NRC) by Niagara Mohawk Power Corporation (NMPC) in connection with its License Application at Docket No. 50-410, 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:
Kraftwerk Union Aktiengese11schaft (KWU) a.
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 considerable amounts of time and money.
The-infor-mation 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
'i 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 t
'I
t was to verify the design analyses used to engineer the quencher device.
PP&L submitted to the NRC its Susquehanna DAR (See Docket Nos. 50-387 and 50-388) which explained the response of the containment system to safety relief valve (SRV) discharge and loss of coolant accident (LOCA) loads, and contained 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 technique for assessing the containment system margins.
The document is of considerable impor-tance because it enables one to define loads associated with SRV discharge.
The document, therefore, is a valuable tool in applying the KWU information.
Although the Susquehanna DAR and the KWU c.
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 information and its market poten-tial, PP&L considers it to be the type that is customarily held in confidence.
As a result, PP&L requested and the NRC agreed to withhold this information from public disclosure pursuant to 10 CFR'$2.790.
d.
Appenuix GA of the Nine Mile Point Unit Two FSAR is be. sed-on the Susquehanna DAR and the KWU information.
It was developed as a result of significant i
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.
Pursuant to an agreement dated August 10, e.
1978, PP&L sold to NMPC the right to use p
the KWU information described herein for j
q i
NMPC's Nine Mile Point Unit Two Nuclear Generating Station.
Pursuant to the agreement, NMPC is required to maintain the proprietary and confidential nature of the information contained in Appendix 6A of the Nine Mile Point Unit Two FSAR.
f.
The information contained in Appendix 6A of the Nine Mile Point Unit Two FS AR has been and will continue to be held in strict confidence.
External distribution 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.
None of the information provided therein g.
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 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.
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Norman W. Curtis Vice President, Engineering & Construction - Nuclear Pennsylvania Power & Light Company Sworn and subscribed before me this 46 4 day of 1983
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