ML20195E299
| ML20195E299 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/11/1998 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138L675 | List: |
| References | |
| GL-97-04, GL-97-4, IEB-96-003, IEB-96-3, NUDOCS 9811180304 | |
| Download: ML20195E299 (10) | |
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Stition Support Department l
GL 97-04 PECO NUCLEAR reco eee,2, cemnee, 965 chestertwook Boulevard A Unit of PECO Energy Wayne, PA 19087 5691 i
l November 11,1998 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission i
Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for AdditionalInformation in Support of Resolution of Bulletin 96-03," Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors," and Generic Letter 97-04," Assurance of Sufficient Net Positive Suction Head t'or Emergency Core Cooling and Containment Heat Removal Pumps"
Dear Sir / Madam:
1 By letter dated September 11,1998, PECO Energy responded to NRC requests for additional information conceming Bulletin 96-03," Potential Plugging of Emergency Core Cooling 1
Suction Strainers by Debris in Boiling Water Reactors," and Generic Letter 97-04, " Assurance of Sufficient Net Positive Suction Head for Emergency Core Cooling ana Containment Heat Removal Pumps," for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. In our September 11,1998 letter, we provided Net Positive Suction Head (NPSH) calculation information for the Emergency Core Cooiing System (ECCS) pumps at PBAPS.
Subsequently, during a telephone conversation on October 27,1998, between PECO Energy i
and NRC representatives, the NRC requested a
.4 'if an additional document that was referenced in one of the calculations previously pio.4ded. Specifically, the NRC requested a copy of document SDOC # NE-265-17, Revision 1, " Verification of ECCS Strainer Pressure Drops for PBAPS, Units 2 and 3" (i.e., MISC-PENG-CALC-064, Reference 23 from Calculation No. PM-1010, "RHR Pump NPSH"). In addition, we are also providing a copy of another supporting document (i.e., MISC-PENG-CALC-062, SDOC # NE-265-16, Revision 1, " Evaluation of Predictions and Data for Prototype Strainer"). This particular document is referenced in NE-265-17 Revision 1, and should be of assistance in the NRC's review.
Accordingly, the enclosures to this letter contain copies of these calculations. Enclosure 1 contains SDOC # NE-265-17 and Enclosure 2 contains SDOC # NE-265-16. TN9 !"~mation is being submitted under affirmation, and the required affidavit is contained in Att " +r,1 to this letter.
I 9811180304 981111
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Nov:mber 11,1998 Prg32 The information in Enclosures 1 and 2 is considered to be of a proprietary nature to ABB Combustion Engineering. Therefore, ABB is requesting that the information in these enclosures be withheld from public disclosure in accordance with 10 CFR 2.790(a)(4). An affidavit from ABB supporting this request to withhold from public disclosure is also attached, and is contained in.10 CFR 2.790(b)(1)(ii) stipulates that "the information sought to be withheld shall be incorporated, as far as possible, into a separate paper." Therefore, Enclosure 3 to this letter contains non-proprietary versions of the requested documentation.
If you have any questions or require additional information, p' ease do not hesitate to contact us.
Very ruly yours, md Garrett D. Edwards Director-Licensing Enclosures Attachments cc:
H. J. Miller, Administrator, USNRC, Region I 'sw! enclosures / attachments)
A. C. McMurtray, USNRC Senior Resident inspector, PBAPS (w/ enclosures / attachments) i l
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l ATTACHMENT 1 PECO Energy Affidavit l
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COMMONWEALTH OF PENNSYLVANIA ss.
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COUNTY OF CHESTER J. B. Cotton, being first duiy swom, deposes and says:
That he is Vice President of PECO Energy Company; that he has read the foregoing response to a request for additional information regarding Bulletin 96-03 and Generic Letter 97-04 for Peach Bottom Atomic Power Station, Units 2 and 3, conceming the use of containment overpressure for ensuring adequate Net Positive Suction Head (NPSH) for Emergency Core Cooling System (ECCS) pumps, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
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Ah-i Presi nt Subscribed and swom to before me this/d day o h-i 998.
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Notary Pubic l
NOTARIAL SEAL i
CAROL A. WALTON. Notary 15d135 Caly of Philadelphia. Phila. County My Commission Empires May 28. 20t
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l ATTACHMENT 2 ABB Combustion Engineering Affidavit l
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AEElDAVIT PURSUANT i
TO 10 CFR 2.790 l, l.C. Rickard, depose and say that I am the Director, 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 paragraph immediately below. I am submitting this affidavit in conjunction with the application of PECO Energy, and in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations.
The information for which proprietary treatment is sought is contained in the following documents:
1.
MISC-PENG-CALC-062, Rev. 01, Evaluation of Predictions and Data for Prototype Strainer, December 1997 2.
MISC-PENG-CALC-064, Rev. 01, Verification of ECCS Strainer Pressure Drop for Peach Bottom Units 2 and 3, April 1998 These document have been appropriately designated as proprietary.
1 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 of the Commission's l
regulations, the following is furnished for consideration by the Commission in determining l
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, is owned and has been held in confidence by Combustion Engineering. It consists of l
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_. -... - _, _.. _. information concerning the test data and methods for calculating Emergency Core Cooling System (ECCS) strainer size and design and fabrication details of ECCS strainers.
2.
The information consists of test data or other similar data 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 disu v3ed to the public. Combustion Engineering has a rational basia 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 Engineering because:
a.
A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
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b.
Development of this information by Combustion Engir,eering required hundreds of thousands of dollars and ters of thousands of manhours of effort. A competitor would have to undergo similar expense in generating equivalent interm:: tion.
c.
In order to acquire such information, a competitor would also reqJire considerable time and inconvenience to develop test data and methods for calculating ECCS strainer size and to develop an ECCS strainer design.
d.
The information consists of test data and methods for l
calculating ECCS strainer size and design and fabrication details of ECCS strainers, the application of which provides i
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, l
and avoid developing similar data and analyses in support of l
their processes, methods or apparatus.
o.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, I
manufacturing, licensing, quality assurance and other costs and expenses must be included. The ability of Combustion Engineering's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
f.
Use of the information by competitors in the international marketplace would increase their ability to market nuclear 4
steam supply systems by reducing the costs associated with
their technology development, in addition, disclosure would L
have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
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Nuclear Licensing Sworn to before me this N day o
,1998 i( : h Notary Public O3'/77 My commission expires:
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l ENCLOSURE 3 i
SDOC # NE-265-17 (MISC-PENG-CALC-064)
" Verification of ECCS Strainer Pressure Drops l
for Peach Bottom Units 2 and 3" and SDOC # NE-265-16 (MISC-PENG-CALC-062)
" Evaluation of Predictions and Data for Prototype Strainer" (Non-proprietary Versions) l