ML18038A567

Forwards Acceptance Review Copy of Physical Security Plan. Plan Withheld (Ref 10CFR2.790)

ML18038A567
Person / Time
Site:	Nine Mile Point
Issue date:	01/26/1983
From:	Mangan C NIAGARA MOHAWK POWER CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML17053D440	List: ML17053D439 ML18038A567 ML18038A568 ML18038A569 ML18038A570
References
NUDOCS 8302020031
Download: ML18038A567 (10)

Text

III V NIAGAl4 A 4 583HANK NIAGARA MOHAWK POWER CORPORATION/300 ERIE GOUI.EVARO WEST. SYRACUSE. iV Y 13202/TEI.EPHQNE (3IS) 47' >Si I QrLJ I V,~S-~3'W January 26, 1983 Mr. Harold R. Oenton, Oirector Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, O.C. '20555 In the Matter of Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Unit 2 Oocket No. 50-410 Oear Mr. Oenton:

On January 31, 1983, Niagara Mohawk Power Corporation will tender its application for an operating license for Nine Mile Point Nuclear Station Unit 2 in accordance with Sections 2.101(a)(2), 50.30(c)(2), 73. 55 and 2. 790. of the Commission's regulations.

Enclosed are six copies of a document entitled "Physical Security Plan".

Pursuant. to 10CFR 2.790(d)(l) and of the Commission's regulations, this information is per se prohibited from public disclosure and it is hereby requested that this document be treated by the Commission as confidential and withheld from public disclosure. ,

Also enclosed is proprietary information pertaining to the safety relief valve discharge which appears in Appendix 6A. Pennsylvania Power 8 Light Company has advised us that this material contains information which is'onsidered to be proprietary. In connection with Section 2.790(a)(4) of the Commission's regulations, it is hereby requested that this document be treated by the Commission as confidential and proprietary and be withheld from public, disclosure. As required by Section 2.790(b)(1), an affidavit of Mr. Norman W.

Curtis of Pennsylvania Power & Light Company is= attached hereto in support of this request.

Very truly yours, 1 830125 830202PBOCl OSOO0410 CCWMAL)Q ~l pgg . PDR C. V. Mangak F

Vice President Nuclear Licensing & Engineering CVM/TRL:djIII Enclosures When separated from the enclosures, hand'le this document as decontrolled-

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COMMONWEALTH OF PENNSYLVANIA)

SS COUNTY OF LEHIGH )

I, NORMAN W. CURTIS, being duly sworn according to law depose and say that I am Vice President, Engineering Fs Construction Nuclear of Pennsylvania Power I Light Company (PPRL), and that:

l. For the reasons listed below, portions of Appendix QA 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 PP8rL to be confidential information containing trade secrets and should be withheld from public disclosure.

2., In support of its averment that'he above-mentioned information is confidential, PPKL provides the following reasons:

Kraftwerk Union Aktiengesellschaft (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 considerable amounts of time and money. The infor-mation developed during this research.

program is not available to the public.

PPSL entered into a contract with KWU for, inter alia., the purchase of a.n information package that tvas developed by KWU during its research program. PP8rL 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.

Part of the contractual arrangement between KWU and PP&L involved KWU performing a full scale test simulating the parameters that exist at PPLL's Susquehanna Steam Electric Station (Susquehanna). The purpose of this test

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 PPSL and KVU 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 KIU information.

K

c. Although the Susquehanna DAR and the IQlU 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, PPSL considers it to be the type that is customarily held in confidence.

As 'a result, PPErL requested and the NRC agreed to withhold this information from public disclosure pursuant to 10 CFR. 52.790 of the Nine Mile Point Unit Appendix GA Two FSAR is based on the Susquehanna DAR and the KWU information. Zt was developed as a result of significant effort and expense by PPEL. PP@L has spent, considerable time and money in obtaining a contract with KMU, and developing the test plan and test matrix.

PP8L thus far has paid KWU approximately

$ 4.5 million in connection with the KWU contract.

e. Pursuant to an agreement dated August 10, 1978, PPSrL sold to NMPC the right to use the KMU information described herein for

.h NMPC's Nine Mile Point Unit Two Nuclear Genera. ting Station. Pursuant to the agreement, iVAPC is required to maintain the proprietary and confidential nature of the information contained in Appendix 6A of the Nine <)file Point Unit Two FSAR.

The information contained in Appendix 6A the Nine Mile Point Unit Two FSAR has

'f been and will'ontinue 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.

ga 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 expenses, and the economic harm that PPSL would suffer from its inability to sell the information, the need for protecting PP&L's interest outweighs the interest involved in public disclosure.

Norman W. Curtis Vice President, Engineering 5, Construction Nuclear Pennsylvania Power 5, Light Company Sworn and subscribed before me this day of , 1983

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