ML20141G641

Forwards Proprietary & Nonproprietary Versions of Steam Generator Single-Tube Rupture Analysis for Snupps Plants. Proprietary Version Withheld (Ref 10CFR2.790)

ML20141G641
Person / Time
Site:	Wolf Creek, Callaway, 05000000
Issue date:	01/08/1986
From:	Petrick N STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19276D155	List: ML20141G641 ML20141H620
References
SLNRC-86-1, NUDOCS 8601100334
Download: ML20141G641 (6)

Text

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l SNUPPS Standardized Nuclear Unit Power Plant System 5 Choke Cherry Road Nicholas A. Petrick Rockville, Maryland 20050 Executive Director (301) 869 8010 January 8,1986 SLNRC 86-1 FILE: 0278 SUBJ: Steam Generator Tube Rupture Analysis - SNUPPS Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket Nos.: STN 50-482 and STN 50-483

References:

1. Facility Operating License NPF-30 for Callaway Plant, Unit No. 1

2. Facility Operating License NPF-42 for Wolf Creek Generating Station, Unit No.1

Dear Mr. Denton:

In accordan::e with License Condition 2.c.(11) of both references 1 and 2, enclosed is a report which demonstrates that the steam generator single-tube rupture (SGTR) analysis presented in the Final Safety Analysis Reports for the SNUPPS plants is the most severe case with respect to release of fission products and calculated radiation doses. The bases for the proposed changes to the Technical Specification requirements, that are consistent with the analysis, are included in the report. The SNUPPS Utilities will individually submit license amendment requests to incorporate the specific Technical Specification changes into Appendix A of references 1 and 2 in the future. The above license condition for both Callaway and Wolf Creek has been fulfilled with this submittal.

The enclosure to this letter contains information proprietary to the SNUPPS Utilities as discussed below. Enclosed are:

1. Three copies of SNUPPS report " Steam Generator Single Tube Rupture Analysis for SNUPPS plants - Callaway and Wolf Creek"....(Preprietary)

2. Three copies of SNUPPS report " Steam Generator Single Tube Rupture Analysis for SNUPPS plants - Callaway and Wolf Creek"....(Non-pro-prietary)

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SLHRC 86-1

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Item 1 above contains information proprietary to the SNUPPS Utilities (Union Electric Company, Kansas-Gas and Electric Company and Kansas City Power & Light). Therefore, this submittal is supported by an affidavit which contains a full statement.of the basis for which the proprietary information may be withheld from public disclosure by :the Commission.

The affidavit addresses, with specificity, the considerations listed in paragraph (b)(4) of 10CFR2.790. Accordingly, it is requested that the

, proprietary information be withheld from public disclosure in accordance with 10CFR2.790 of the Commission's. regulations.

Very uly yours, b

N cholas A. Petrick i i / \

- MHF/dck/2b5819 cc: G. L. Koester KGE .

J.-M. Evans KCPL D. F. Schnell UE

. B. Little USNRC/ CAL J. E. Cummins USNRC/WC

, G. C. Wright USNRC/RIII E. H. Johnson USNRC/RIY 4

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AFFIDAVIT STATE OF MARYLAND:

ss MONTG0MERY COUNTY Before me, the undersigned authority, personally appeared James 0. Cermak, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of the SNUPPS Utilities and that the averments of fact set forth in this Affidavit are true and correct 4

to the best of his knowledge, information, and belief:

fu A Ja s 0. Cermak, Teclnical ' Director S PPS Utilities Sworn to and subscribed before me this day of/At e e-1_, 1986.

I ane HTDie Kavanagn

My Cc=i::icn Expirce: 7/1/85

(1) I am Technical Director for the Standardized Nuclear Unit Power Plant System (SNUPPS) project, representing the SNUPPS Utilities (bnion Electric Company, Kansas Gas and Electric Company, and Kansas City Power and Light) and as such, I have been specifically delegated the function of reviewilig the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the SNUPPS Utilities.

(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the SNUPPS Utilities application for withholding accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by the SNUPPS Utilities in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for considera-tion hy the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

< (1) The information sought to be withheld from public disclosure is i owned and has been held in confidence by the SNUPPS Utilities.

The information is of a type customarily held in confidence hy other organizations and not customarily disclosed to the pubitc.

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Based on a review of 10 CFR 2.790, the information to be held in confidence falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any other company without license from the SNUPPS Utilities constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.),

the application of which data secures a competitive economic advantage.

(c) Its use by another company would reduce his expediture of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance ~ of quality, or licensing a similar product.

There are sound reasons behind the SNUPPS Utilities position which include the following:

(a) It is infonnation which is marketable in many ways.

(b) Use by other companies would put the SNUPPS Utilities at a competitive disadvantage by reducing their expenditure of resources at our expense.

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f (j (c) Each component of proprietary information pertinent to a r

particular competitive advantage is potentially as valuable y' ,

as the total competitive advantage. If competitors acquire component's of proprietary information, any one component may I be the key to th$ entire puzzle, thereby depriving the SNUPPS a Utilities of; a competitive advantage.

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(ii) The information is being t aitsmitted to the Commission in confidence i

and, under.the provisions of 10CFR Section 2.790, it is to be re-ceived in confidence by/ the Commission.

(iii) The inf rmation sought to be protected is not available in public

, sources.to the best of our knowledge and belief.

i (iv) The proprietary information sought to be withheld in this submittal i is that which is appropriately marked in " Steam Generator Single-y Tube Rupture Analysis for SNUPPS Plants - Callaway and Wolf Creek",

dated December, 1985.

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The subject infonnation i:ould only be duplicated by competitors

[ if they were to invest time and effort equivalent to that invested O by the SNUPPS Utilities provided they have the requisite talent

. and experience.

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Public disclosure of this information is likely to cause substantial harm to the competitive position of the SNUPPS Utilities because it would simplify design and evaluation tasks without requiring a com-mensurate investment of time and effort.

t Further the deponent sayeth not.

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