ML20096D795

Forwards Proprietary & Nonproprietary R-84-011-P & R-84-011-NP, Final Rept for Phase I of Arkansas Power & Light Inadequate Core Cooling ..., Per NUREG-0737,Item II.F.2.Proprietary Rept Withheld (Ref 10CFR2.790)

ML20096D795
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/30/1984
From:	John Marshall ARKANSAS POWER & LIGHT CO.
To:	John Miller Office of Nuclear Reactor Regulation
Shared Package
ML19269A500	List: ML20096D795 ML20096D801
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM NUDOCS 8409060301
Download: ML20096D795 (4)

Text

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK. ARKANSAS 72203 [501)371-4000 August 30, 1984 2CAN088412 Director of Nuclear Reactor Regulation ATTN: Mr. James R. Miller, Chief Operating Reactors Branch #3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 ANO-2 Inadequate Core Cooling Order Final Report of ICC Instrument Confirmatory Test Program Gentlemen:

As committed during the July 12, 1984 meeting, we have enclosed five (5) copies (copies nos. 01-05) of R-84-011-P " Final Report for Phase I of the AP&L ICC Monitoring System Confirmatory Test Program," by Technology for Energy Corporation (TEC) for AP&L. Five non proprietary copies are also enclosed. The report demonstrates the capability of the AP&L ICC incore instruments for ANO-2 to satisfy the requirements specified in NUREG 0737, Item II.F.2 in accordance with the December 10, 1982, Order for Modification.

Due to the proprietary nature of the information contained in R-84-011-P, AP&L requests this report to be withheld from public disclosure in accordance with the provisions of 10CFR Part 2.790. The reasons for the proprietary classification of this report are delineated in the enclosed affidavit.

In keeping with our intention to install this instrumentation during the upcoming 2R4 refueling outage, we are ready to meet with your staff and discuss this report at your earliest convenience. Please contact us with regard to your desire for a meeting.

Very truly yours, 'N

(}'4d 8409060301 840830 F PDR ADOCK 05000368 F PDR .

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ohn R. Marshall Manager, Licensing p[0 JRM/JM/ac fed MEMETEF1 MIDDLE GOUTH U riUTIES SYGTEM Oh'6 d

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. AFFIDAVIT PURSUANT l TO 10 CFR 2.790

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' Technology for Energy Corporation .)  %

State of Tennessee )

County of Knox )

and ) $$.:

. Arkansas Power & Light Company )

-State of Arkansas )

County of Pulaski )

_. I,'J. C. Robinson, depose and say that'I am the Vice President,

-Products Group of Technology for Energy Corporation (TEC) and I,

'J. M. Griffin, depose and say that I am the Senior Vice President, of Arkansas Power.& Light Company (AP&L), both 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. This information is submitted in conformance with the

,  : provisions of 10 CFR Part 2.790 of the Commission's regulations in connection with applications for withholding.

The information for which proprietary treatment is sought is contained

- in the document " Final Report for the AP&L ICC Monitoring System Confirmatory Test Program," TEC Report No. R-84-011-P.

Pursuant to the provisions of paragraph (b)-(4) of Part 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 are the

. details of the Readcal Inventory Meter (RIM) for ICC monitoring which is owned and has basen held in confidence by TEC and AP&L.

2. The information consists of test data or other siellar data concerning a process, method or component, the applicrtion of which results in c substantial competitive advantage to TEC, and is of financial interest to AP&L -

3. The information is of a type customarily held in confidence by commercial entities'and not customarily discicsed to the public.

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.

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5. , The information, to the best of our knowledge and belief, is not s

available in public sources, and'any disclosure to third parties has ,

, _been made pursuant to regulatory provisions or proprietary agreements

. which provide for naintenance of the information in confidence. ,

4' 6. Public disclosure of the information is likely to cause substantial harm to the competitive position of TEC and to the financial interests of AP&L because:

a. Products for similar application are manufactured and sold by ,

major nuclear industry competitors of TEC;

b. Development of this information by.TEC and AP&L required hundreds ,

4 of manhours of effort and tens of thousands of dollars. To the >

3 best of our 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 developing an equivalent incore inventory monitoring technique; l

. d. AP&L and TEC have undertaken the effort and expense to obtain the $

licensing approvals necessary for application of the information. i Avoidance of this expense would decrease a competitor's cost in A applying the information and marketing the product to which the. .

information is applicable;

e. .The information consists of details of design, construction ard

. operation of the RIM, the application of which provides a competitive economic advantage. The availability of such ,

.information to competitors would enable them to modify their products to better compete with TEC, take marketing or other ,

actions to improve their. Product's position or impair the position  ;

of TEC's products, and avoid developing similar_ data and analyses t in support of their processes, methods or apparatus;

f. In pricing TEC's products and services, significant research, ,

development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be incluoed. _

The ability of TEC's competitors to utilize such information  !

without similar expenditure of resources may enable them to sell ,

at prices reflecting significantly lower costs; and <

g. Use of this information by competitors in international markets would increase their ability to market sinflar core inventory monitoring systems by reducing the costs associated with their .!

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technology development. In addition, disclosure would have an adverse economic impact on TdC's potential for obtaining or

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maintaining foreign licensees. ,,

Further the deponents sayeth not.,

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( C. Robinson ice President, Products Group

, Technoldgy f6r Energy Corporation f y J. M_,, Griffin Sr. tice President, upply State of Arkansas Arkansas Power & Light Company County of Pulaski Sworn to before me State of Tennessee County of Knox this 30 day of August, 1984 f Sworn 7to before me this 4th day of September, 1984.

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., My Comission Expires: 9/19/89 r

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, My Commission Expires: 10/20/87

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